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Vivid Files Measure B Reply Brief to 9th Circuit

LOS ANGELES — Vivid Entertainment attorneys once again filed court papers with the 9th U.S. Circuit Court of Appeals seeking for the court to dump the district court’s earlier finding over its request for a preliminary injunction and toss the AIDS Healthcare Foundation as intervenors in the appeal.

Vivid’s 26-page reply brief, filed Friday in response to a previous AHF brief, put an emphasis on the porn studio’s contention that the AHF shouldn’t be allowed as intervenors in an action where there already is a defendant.

Measure B was passed almost one year ago — Nov. 6, 2012 — by voters, who green lighted the “Safer Sex in the Adult Film Industry Act” that requires the use of condoms in the production of adult movies in Los Angeles County.

“It is not as though there is no defendant or appellee in this case — [Los Angeles] County, et al., are proper party defendants/appellees,” Vivid attorneys argued. “That the county has opted not to raise arguments, [the AHF wishes] to see put forward is not sufficient to grant party status to those who lack an interest undifferentiated from any other member of the general public.

“Indeed, the county filed an answer and issued a letter saying it was authorized to ‘take appropriate measures to enforce’ Measure B,” Vivid attorneys said.

Vivid also pointed to the assertion by the AHF that that portions of Measure B are “severable,” contrary to what AHF claims. The district court held that the licensing requirements of Measure B operates as a prior restraint that generally lacks procedural safeguards is in most respects not narrowly tailored and gives the county unbridled discretion, Vivid attorneys said.

“[The district court] upheld certain portions of Measure B only after revising its definitions and substantive reach,” Vivid attorneys said. “This plainly violates the rule that courts cannot rewrite a … law conform it to constitutional requirements.”

“This court recently recognized that the doctrine of severability is ‘inapplicable’ where a ‘provision encompasses both valid and invalid restrictions of free speech and its language is such that a court cannot reasonably undertake to eliminate its invalid operation by severance or construction,” said Vivid attorneys, citing a 1968 9th Circuit ruling, Acosta vs. City of Costa Mesa. “[T]he remnants of Measure B that the district court preserved do not satisfy the test for severability, which under California law requires the text severed to be “volitionally, grammatically and functionally severable.”

It is unclear any time frame the 9th Circuit will render a decision on Vivid’s appeal.

Vivid, along with co-plaintiffs Kayden Kross and Logan Pierce, filed an appeal with the 9th Circuit in September after they were denied a preliminary injunction over Measure B by U.S. District Court Judge Dean Pregerson in Los Angeles.

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  • Several excellent arguments are made by the Appellants (Vivid Entertainment et al) in the Reply Brief:

    First, that "in this case, it is far from certain voters would have approved Measure B if they knew it could become an unfunded mandate." During the campaign, Measure B's backers touted in the official Voter Information Guide that "Measure B makes clear that no public dollars will be spent to enforce condoms in porn.” Indeed, Measure B’s proponents made the promise of the public not funding the new regime one of only two primary arguments in support of Measure B. Putative Intervenors promised voters in bold face that Measure B would cost them nothing, and that its implementation would not divert resources from more pressing public health concerns.

    Second, that "the stated – and only purpose – of Measure B is 'to ensure that producers comply with preexisting law.' [] Putative Intervenors never explain why it is necessary to adopt what the Supreme Court has described as 'the most serious and the least tolerable infringement on First Amendment rights,' [a prior restraint of speech], as merely a backstop for Cal-OSHA regulations. Indeed, this Court repeatedly has struck down permitting requirements where 'the government could simply enforce its existing rules' rather than require speakers 'to pre-register with the government as a prerequisite to engaging in communicative activity.'" [citations omitted]

    Third, Appellants make an argument that even Mr. Fattorosi and I agreed during the Measure B is among the strongest in the adult business' arsenal: that the government, which only has an interest in that which it can prove, lacks sufficient governmental interest in this instance.

    In the section entitled, The Asserted Governmental Interest is Unsupported, Appellants note:

    "Appellants do not dispute that there is a substantial interest in curbing sexually transmitted diseases and infections (“STDs” and “STIs”) as a general proposition, [] but Measure B’s stated intent is “minimiz[ing STIs] resulting from the production of adult films,” which are alleged to have a “negative impact on public health and quality of life” for all Los Angeles residents. [] In finding this first element satisfied, the District Court failed to cite any evidence that allegedly higher incidents of STDs in the adult film industry have any impact on the health of the general population of Los Angeles County, and Putative Intervenors cite no such evidence here."

    Measure B’s proponents fail even to identify what percentage of the population of Los Angeles County works as performers in adult films. Perhaps that is because, even if the DPH Letter undercounted the number of adult film performers in Los Angeles County by several multiples, [] they would still make up but a miniscule proportion of the County’s nearly 10 million residents.

    "Putative Intervenors’ seek to divert attention from the actual government interest asserted for Measure B, claiming instead that it lies in 'lowering the rate of STD infection among adult film performers' and 'curb[ing] transmission of [STDs] in the adult film industry.' [] But, as shown above, the text of Measure B states a different purpose, one the Answering Brief ignores insofar as it requires showing a connection between adult filmmaking and the health of Los Angeles County’s general population."

    And lastly, with regard to the cases of Cameron Bay/Rod Daily, Appellants note:

    "Significantly, recent cases of HIV found by adult film testing, as cited by Putative Intervenors [] – resulted from transmissions outside adult film production, which would not be prevented by Measure B."

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