Petition for Preliminary and Permanent Injunction

MAY IT PLEASE THE COURT: Defendant, THE CITY OF NEW ORLEANS, respectfully represents that the Petition for Preliminary Injunction should be denied because the law in dispute, an amendment to the Home Rule Charter of the City of New Orleans, is a permitted and constitutional exercise of the Police powers of the City and, the state statute which purports to prohibit such an action does not apply to the Home Rule powers of the City of New Orleans.