Case 3:16-cv-01296-JM-BLM Document 3-2 Filed 05/31/16 Page 1 of 2

1 David Loy (SBN 229235)

ACLU F OUNDATION OF S AN D IEGO &
2 I M PERIAL C OUNTIES
P.O. Box 87131
3 San Diego, CA 92138-7131
Telephone: (619) 232-2121
4 Facsimile: (619) 232-0036
davidloy@aclusandiego.org
5
Ryan T. Darby, Esq. (SBN 264357)
6 THE LAW OFFICE OF RYAN T. DARBY
525 B Street, Suite 1500
7 San Diego, CA 92101
Telephone: (619) 858-4766
8 Facsimile: (619) 243-7226
E-mail: darby@darby.law
9
Attorneys for Plaintiff THE KOALA
10
11 UNITED STATES DISTRICT COURT
12 SOUTHERN DISTRICT OF CALIFORNIA
13
14 THE KOALA, Case No.: '16CV1296 JM BLM
15 Plaintiff, DECLARATION OF
GEORGE LIDDLE III IN
16 v. SUPPORT OF PLAINTIFF’S
MOTION FOR
17 PRADEEP KHOSLA, et al., PRELIMINARY
INJUNCTION
18 Defendants.
19
20
I, George Liddle III, declare that I am over eighteen (18) years of age. I am a
21
resident of San Diego County, California. I could—if called as a witness to this
22 matter—competently testify of my own personal knowledge to the matters set forth
23 in this declaration.
24 I therefore declare and state as follows:
25 1. I was an undergraduate student at University of California, San Diego
26 (“UCSD”) from 1998-2003.
27 2. I served as Editor in Chief of The Koala from 2001-2002.
28 3. In 2002, The Koala published photographs mocking the chairman of the

1
 Case 3:16-cv-01296-JM-BLM Document 3-2 Filed 05/31/16 Page 2 of 2

1
Student Affirmative Action Committee, which was a registered student
2
organization.
3 4. The photos were taken at a public meeting hosted by MEChA, which was
4 another registered student organization.
5 5. UCSD alleged that The Koala committed the disciplinary violation of
6 disrupting an official university activity by photographing the public
7 MEChA meeting.
8 6. If these charges were sustained, The Koala' s registration as a student
9 organization would have been revoked.
10 7. The UCSD Judicial Board acquitted The Koala of any wrongdoing.

11
12 I declare under penalty of perjury that the foregoing is true and correct.

13 Executed on May~, 2016, in San Diego, California.

14
Dated: May -2!j_, 2016
15
16
17
18 ~
GEGELIDriLEUI :j!C
19
20
21
22
23
24
25
26
27
28