City of Franklin Brief Opposing Completing the Record

FCA

Jul 16, 2021

CITY OF FRANKLIN’S RESPONSE BRIEF TO PLAINTIFFS’MOTION TO COMPLETE THE RECORD AND FOR AN EXTENSION OF THE BRIEFING SCHEDULE

The City of Franklin, by its attorneys, Municipal Law & Litigation Group, S.C., submits the following in opposition to Plaintiff’s Motion to Complete the Record and for an Extension of the Briefing Schedule. Plaintiffs’ case is one of certiorari review of an administrative body. They are challenging the decision of the City of Franklin Common Council at its November 2, 2020 regular meeting to approve Strauss Brands, LLC’s Special Use Permit (“SUP”) application.From the beginning of this lawsuit Plaintiffs have attempted to muddy the certiorari waters by claiming that social media posts and other extraneous correspondence invalidates the entire Case 2020CV007031 Document 105 Filed 07-16-2021 Page 1 of 9 FILED 07-16-2021 John Barrett Clerk of Circuit Court 2020CV007031