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Answer in Vivid Entertainment v. Fielding

Answer in Vivid Entertainment v. Fielding

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Published by Derek Muller
Addressing intervention in Measure B litigation.
Addressing intervention in Measure B litigation.

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Categories:Business/Law
Published by: Derek Muller on Sep 12, 2013
Copyright:Attribution Non-commercial

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02/21/2014

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792787
PATRICIA
.
GLASER
State
Bar
No.
5668
pglaser(a~glaserweil.com
JOEL
N:
LEVENS
State
Bar
No.
5446
Jklevens(c~
laserweil.com
70HN
LY
State
Bar
No.
47477
~l~y
laserweil.com
GL
~ER
WEIL
FINK
JACOB
HOWARD
VCHEN
&
HAPIROLLP
10250
onstellation
Boulevard,
9th
Floor
Los
Angeles,
alifornia
90067
Telephone:
(310)
53-3000
Facsimile:
(310)
56-2920
Attorneys
for
Defendants
UNITED
STATES
DISTRICT
COURT
CENTRAL
ISTRICT
OF
CALIFORNIA
VIVID
ENTERTAINMENT,
LC;CALIFA
PRODUCTIONS,
NC.;
JANE
DOE
/k/a
Kayden
Kross;
and
JOHN
DOE
/k/a
Logan
ierce,
Plaintiffs,
v.
JONATHAN
IELDING,
irector
of
Los
Angeles
County
Department
of
Public
Health,
JACKIE
LACEY,
os
Ange~le~s
Coun
District
Attorney,
and
COUNTY OF~OS
ANGELES,
Defendants.
CASE
NO.
V
3-00190
DDP
AGI)
Hon. ean
Pregerson
DEFENDANTS'
ANSWER
O
PLAINTIFFS'
COMPLAINT
DEFENDANTS'
NSWER
TO
OMPLAINT
Case 2:13-cv-00190-DDP-AGR Document 21 Filed 02/27/13 Page 1 of 17 Page ID #:77
 
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Defendants'
Jonathan
Fielding, Jackie
Lacey,
and
County
of
Los
Angeles,
by
and
through
counsel,
answer
laintiffs'
Complaint
or
Declaratory
and
Injunctive
Relief
sfollows:
Plaintiffs'
Complaint
presents
important
constitutional
questions
that
require
and
warrant
udicial
determination.
In
a
constitutional
democracy,
t
is
the
role
of
he
courts to
determine
and
resolve
such
questions.
To
heextent
that
Plaintiffs
have
stated
a
usticiable
controversy,
setting
forth
federal
constitutional
challenges
to
the
Countyof
os
Angeles
Safer
Sex
n
the
AdultFilm
Industry
Act
"Measure
B"),
t
is
appropriatefor
the
federal
courtsto
determine
and
resolve
those
challenges.
Defendants encourage
he
Court
oresolve
the
merits
of
his
action
expeditiously.
Inresponse
to
each
of
he
specific
allegationsin
Plaintiffs'
Complaint,Defendantsrespond
as
follows:
INTRODUCTION
1.
Answering
paragraph
1
of
he
Complaint,Defendants
admit
hat
Plaintiffs
have
alleged
that
theyseek
to
protect
the
First
Amendment
ights
of
producers
of
exually
oriented
films,
to
uphold
the
supremacyof
he
law
of
he
State
of
alifornia,
and
to
protect
the
livelihoods
of
hose
who
ork
n
and
around
the
adult
film
industry.
As
o
all
other
allegations
contained
therein,
Defendants contend
that
said
paragraph
contains
conclusions
of
awand
not averments
of
act to
which
an
answer
may
be
required.
2.
Answering
paragraph
2
f
he
Complaint,efendants
admit
hat
Plaintiffs
have
iled
a
ivil
rights
action
for declaratory
and
injunctive
relief
that
seeks
to
enjoin the
enforcement
of Measure
B.
As
o
all
other
allegations
contained
therein,
Defendantscontend
that said
paragraph
contains
conclusions
of aw
and
not
averments
of
act
to
which
an
answer
may
e
required.
3.
Answering
paragraph
3
f
he
Complaint,efendants
admit
hat
~
Measure
B
equires
producers
of
dult
films
to
paya
ee
and
obtain
a
permit
hat
requires
the
completion
of
bloodbornepathogen
training.
Defendants
urther
admit
i
DEFENDANTS'
ANSWER
TO
COMPLAINT
Case 2:13-cv-00190-DDP-AGR Document 21 Filed 02/27/13 Page 2 of 17 Page ID #:78
 
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that
Measure
B
llows
forthe
revocation
of
herequiredpermit.
Defendants
urther
admit
hat
Measure
B
equires
the
use
ofcondoms
during
the
production
of
dultfilms.
As
o
all
other
allegations
contained
therein,
Defendants
lack
sufficient
information
or
knowledge
o
enable
them
to
answer
he
allegations
contained
in
said
paragraph,
and
basing
their
denial
on
hat
ground,
enerally
and
specifically
deny
each
and
every
allegation
contained
in
said
paragraph.
4.
Answering
paragraph
4
f
he
Complaint,Defendants
contend
thatsaid
paragraph
contains
conclusions
of
aw and
not
averments
of
act
to
whichan
answer
may
e
required.
As
o
all
other
allegations
contained
therein,
Defendants
lack
sufficient
information or
knowledge
to
enable
them
to
answer
he
allegations
contained
in
said
paragraph,
and
basing
their
denial
on
hat
ground,
enerally
and
specifically
deny
each
and
every
allegation
contained
in said
paragraph.
5.
Answering
paragraph
5
of
he
Complaint,efendants contend
that said
paragraph
contains
conclusions
of
awand
not
averments
of
act
to
which an
answer
may
e
required.
As
o
all
other
allegations
contained
therein,
Defendants
lack
sufficient
information
or
knowledge
o
enable
them
to
answer
he
allegations
contained
in
said
paragraph,
and
basing
their
denial
on
hat
ground,
enerally
and
specifically
deny
each
and
every
allegation
contained
insaid
paragraph.
6.
Answering
paragraph
6
f
he
Complaint,Defendants
lack
sufficient
information or
knowledge
o
enable
them
to
answer
he
allegations
contained
in
said
paragraph,
and
basing
their
denial
on
hat
ground,
enerally
and
specifically
deny
each
and
every
allegation
contained
in said
paragraph.
7.
Answering
paragraph
7
f
he
Complaint,efendants
lack
sufficient
information or
knowledge
to
enable
them
to
answer
he
allegations
contained
in
said
paragraph,
and
basing
their
denial
on
hat
ground,
enerally
and
specifically
deny
each
and
every
allegation
contained
in said
paragraph.
PARTIES
8.
Answering
paragraph
8
f
he
Complaint,Defendants
lack
sufficient
2DEFENDANTS'
ANSWER
TO
COMPLAINT
Case 2:13-cv-00190-DDP-AGR Document 21 Filed 02/27/13 Page 3 of 17 Page ID #:79

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