Excerpts from the Injunction –
Local politicians and area citizens have filed a complaint against the City of Jackson in Jackson Chancery Court from allowing the Defendant from permitting use of the Defendant’s property known as the Carl Perkins Civic Center from being utilized for the purposes of hosting female impersonators in contrivance of Tennessee law.
Specific grounds for this injunction are in violations of numerous laws, including operating a cabaret within 1,000 feet of a church.
All of the Plaintiffs – including State Senator Ed Jackson (R-Jackson) District 27 and State Representative Chris Todd (R-Jackson) District 73, are residents of Madison County, Jackson, Tennessee and number more than ten (10) citizens of the county where the public nuisance may exist, therefore, pursuant to T.C.A. § 29-3-102, the Plaintiffs may petition this Court for injunctive relief.
The following Plaintiffs are members of the First United Methodist Church in Jackson, Tennessee and are residents of Madison County, Tennessee: Forrest and Paula Butler, Sara Rainey, Carolyn Yarbough (sic), Laurie Horton, Ron and Yvonne Hale, Lewis and Charlotte Zerfoss, Thomas and Janet Stallings, and Mary Rudd. These Plaintiffs have standing to bring this action as an adult cabaret seeks to have a performance within 1,000 feet of their church on October 8, 2022.
Upon information and belief, the Carl Perkins Civic Center is also within one thousand feet (1,000′) of other churches, including, but not limited to, St. Luke’s Episcopal Church and Mother Liberty CME Church.
On September 27, 2022, Jackson Pride, a fund of the West Tennessee Healthcare Foundation, announced via press release that the 3rd Annual Jackson Pride event would be held at the Carl Perkins Civic Center. A copy of said press release is attached as Exhibit B and incorporated herein by reference.
The press release goes on to announce that the group will host a, “family friendly Drag Show, featuring some of the regions [sic] most talented performers.”
Before moving the event to the Carl Perkins Civic Center, Jackson Pride previously planned to host the Drag Show at Conger Park in Jackson, Tennessee.
A copy of a flyer advertising the Jackson Pride Drag Show and featured performers is attached hereto as Exhibit C and incorporated herein by reference.
The flyer advertising the Drag Show features ten (10) female impersonators.
The host for the Drag Show is a performer known as Bella DuBalle who maintains a public Facebook page. A screenshot of Bella DuBalle’s public Facebook page is attached hereto as Exhibit D and incorporated herein by reference.
Bella DuBalle’s Facebook page features Bella DuBalle and various performers, with two of the featured men undressed except for articles of clothing covering their groin.
One man has his buttocks exposed.
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