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April 05, 2016

Three Expo Events Answers Dallas' Opposition to Injunction Motion

DALLAS, Tex.—Three Expo Events, LLC, which recently filed a Motion for Preliminary Injunction in an attempt to overturn a City Council resolution barring the company from putting on its Exxxotica Lifestyle Convention at the city-owned Kay Bailey Hutchison Convention Center, has responded to the city's attempt to have the injunction motion dismissed. In Three Expo's reply brief, which can be read here, the company renews its argument that the city council resolution is an unconstitutional prior restraint of the company's ability to hold its convention on city property, charging that the sole reason for the resolution was the city's unhappiness with the content of the Exxxotica convention. What follows is a point by point refutation of the "reasons" cited in Dallas' response to Three Expo's Motion, including the charge that certain events which took place during the prior Exxxotica convention in 2015 violated various Dallas ordinances, with the reply noting that none of those "violations" played any part in the passage of the resolution. "Defendants claim they passed the resolution directing the City Manager not to enter into a contract with Plaintiff for its trade show because it is a sexually oriented business regulated by Chapter 41A," the reply brief states. "That ordinance, they argue, prohibits Plaintiff from leasing the convention center because of the ordinance’s location restrictions. But Defendants’ argument glosses over the absence of any citation to Dallas’s ordinances pertaining to sexually oriented businesses in the Resolution, and overlooks the legal opinion and advice rendered to them by their counsel that Chapter 41A simply does not apply." [Citations omitted here and below] The reply brief goes on to note that these "after the fact" justifications for the council's resolution cannot be used to cure the unconstitutionality of the resolution itself. "They tell us, for the first time in their Response, Plaintiff breached provisions of its agreement with the convention center, violated city and state laws governing public nudity and lewdness, and 'fraudulently misrepresented' the entity that entered into the contract with the convention center in connection with its three-day expo in August 2015," the reply brief states. "But none of these after-the-fact justifications or instances of alleged past misconduct in any way alters the unconstitutionality of Defendants’ action or Plaintiff’s entitlement to relief..." The brief goes on to examine in detail Plaintiff's responses to the Defendants' opposition brief, and even provides a timeline of three Expo's interactions with Dallas officials, noting in particular that Dallas Deputy Chief of Police Vernon Hale stated under oath that, "Vice officers were assigned to attend portions of Exxxotica Dallas. They did not make any arrests or report having witnessed any crimes during their time at Exxxotica Dallas." Three Expo also denied that the "video evidence" cited by Dallas to justify its anti-Exxxotica position could be authenticated as having been shot at the convention. All in all, Three Expo's attorneys do a thorough job of debunking the vast majority of the claims raised by the city regarding its ban on Exxxotica at the city convention center—but this is not likely to be a fight that the City of Dallas will lose easily—or cheaply.

 
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