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IN THE CHANCERY COURT FOR THE STATE OF TENNESSEE

TWENTIETH JUDICIAL DISTRICT, DAVIDSON COUNTY

HONKY TONK PARTY EXPRESS, LLC, )

)
Plaintiff, )
)
V. ) No. 22-1132-
)
METROPOLITAN GOVERNMENT OF ) C)
NASHVILLE AND DAVIDSON COUNTY, )
’

by and through the Transportation )

Licensing Commission,
g

)
Defendant. )

ORDER 0N PLAINTIFF’S MOTION FOR TEMPORARY INJUNCTION f

This matter came before the Court for hearing on September 20, 2022, on Plaintiff Honky

Tonk Party Express, LLC’S Motion for Temporary Injunction. Participating in the hearing were

Attorney Scott W. Sims, representing Plaintiff Honky Tonk Party Express, LLC (“Honky

Tonk”), and Metropolitan Assistant Attorneys Andrew D. McClanahan, Hannah E. McCann, and
Theresa Costonis, representing Defendant Metropolitan Government of Nashville and Davidson

13County (“Metro”), by and through the Transportation Licensing Commission (“MTLC”).

Attorney Jonathan Cooper, representing Nashville Convention & Visitor’s COrp., Nashville

Downtown Partnership, Inc., the Nashville Area Chamber of Commerce, and the Greater

Nashville Hospitality Association (“Interested Parties”), as amici curiae, also appeared.

Based on the Plaintiff’s motion, Metro’s Response, supporting declarations and exhibits,

and the arguments of counsel, the Court finds that the motion for temporary injunction should be

granted, in part, and denied, in part, for the reasons discussed below.
 Case No. 22-1 132-1

I. FACTUAL AND PROCEiDURAL BACKGROUND

Plaintiff Honky Tonk Party Express, LLC is an entertainment transportation company

(“ETC”) that has operated entertainment transportation vehicles (“ETVS”) on downtown

Nashville streets since 2016. Honky Tonk’s vehicles are decommissioned school buses with

portions of the sides removed and replaced by rails, and with the tops removed and replaced by

see-through coverings. Until recently, Tennessee state law prohibited local governments from

regulating ETVs. In March 2022, however, the General Assembly passed legislation recognizing

ETVs as a new class of vehicles and permitting local governments to regulate them. See 2022

Tenn. Pub. Ch. 666 (amending Tenn. Code Ann. § 7-51-1007).

In anticipation of this new legislation, the Metropolitan Council and Mayor adopted and

approved ordinances pertaining to ETVs. See Substitute Ordinance BL2021-9l l, as amended,

and BL2022-1089 (Metro’s Response to Temporary Injunction (“Metro Resp”), Exs. C, D, E

and F). These ordinances were codified in the Metro Code. Metro Code §6.77. Metro

authorized MTLC to adopt and enforce regulations governing ETCs and ETVs, and to issue

permits for ETVs. Id. MTLC held a series of public meetings to develop rules and regulations

for ETCs and ETVs and to consider permit applications.‘ MTLC formally adopted its rules and

regulations as of August 25, 2022. See MTLC Entertainment Transportation (ETC) Rules, Metro
i

Resp., Ex. I.

On August 22, 2022, Honk Tonk filed a Verified Complaint seeking a declaratory

judgment that three of MTLC’s regulations—limiting hours of operation, requiring enclosure of

vehicles, and requiring liquor liability insurance—are unconstitutional and unenforceable. The

regulation limiting hours of operation has already taken effect. The vehicle enclosure and liquor

Honky Tonk has separately filed another lawsuit seeking judicial review of MTLC’s action
I
on
Honky Tonk’s permit applications awarding twelve of twenty permits requested.

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 Case N0. 22-1 132-1

liability insurance requirements are scheduled to take effect October 3, 2022.

At the time of filing its complaint, Honky Tonk sought a temporary restraining order,

enjoining Metro, through the MTLC, from enforcing the challenged regulations. The Court

denied the restraining order, but set a temporary injunction hearing. At the request of the parties,

the hearing was rescheduled for September 20, 2022.

Honky Tonk now moves for a temporary injunction under Rule 65.04 to enjoin and

restrain Metro, through MTLC, from enforcing the three challenged regulations based on

allegations that they violate Honky Tonk’s federal and state constitutional substantive due

process and equal protection rights.

Metro opposes the requested injunctive relief on‘several grounds. It argues Honky

Tonk’s motion fails to establish irreparable harm that cannot otherwise be adequately

compensated by monetary damages; the public interest will be harmed if the regulations limiting
hours of operations and enclosure of the vehicles are enjoined from going into effect and

outweighs any potential harm to Honky Tonk; Honky Tonk cannot show a likelihood of success

on the merits on its substantive due process claim because the MTLC regulations are reasonably

related to Metro’s legitimate interests in controlling traffic flow in downtown Nashville during

peak hours, reducing noise pollution, and promoting safety of passengers; and Honky Tonk

cannot show a likelihood of success on the merits of its equal protection claim because Metro’s

reasons for not imposing an enclosure requirement on pedal carriages is related to unique safety

concerns regarding ETVs.

The Court granted the motion of the Interested Parties for leave to file an amici curiae

brief, as amended, in support of Metro’s position and in opposition to Honky Tonk’s position.
 Case No. 22-1 132-1

II. CHALLEN GED MTLC REGULATIONS

Honky Tonk points out that it is generally in favor of regulations for ETVs to promote the

safety and well-being of ETV passengers and others, and it does not challenge the majority of

MLTC’s regulations. Honky Tonk, however, asserts challenges as to the following three MTLC

regulations:

Enclosure Requirement. MTLC Rule 040 requires ETVs to be “fully enclosed” as

follows:

040. Enclosed/Unenclosed Vehicles

(a) “Enclosed vehicle” means any motor vehicle that is fully enclosed by
metal, plexiglass or glass on all sides and on the top/roof. Any vehicle
not meeting this definition would constitute an “unenclosed vehicle.”
A vehicle is unenclosed if any portion of it lacks solid sides and a roof,
including all appurtenances attached thereto, including, but not limited
to, a pickup truck or a wagon or trailer pulled by a tractor, within
which passengers are capable of standing and circulating while the
vehicle is in motion. For purposes of this section, a vehicle “side”
must be a full side enclosure of the vehicle and cannot consist of solely
a guard rail or railing. It may contain windows capable of being
opened, but all windows shall be fully closed while the vehicle is in
operation. Enclosed vehicles shall maintain any required emergency
access or exits but the emergency access or exits may not be used to
avoid the safety goals intended by the enclosure.
>l< * *

(c) ETV are required to be fiilly enclosed, with the exception of those
meeting the definition for the subcategory “Seated Sightseeing or
Charter Tour vehicle.” Seated Sightseeing or Charter Tour vehicles
are exempt from the requirement applicable to other types of ETV that
the vehicle be required to be enclosed.

See Verified Complaint, Ex. A.

Honky Tonk claims that, even if it could comply with the enclosure requirement during

cooler fall and winter months (November through February) with light, shatter—proof plexiglass,

it is not feasible to comply with the enclosure requirement during warmer months, which will
 Case No. 22-1132-1

require the installation of air conditioning for the safety and comfort of its drivers and

passengers, without great difficulty and undue expense. Honky Tonk has submitted declarations

attesting to engineering limitations for installing generators and air conditioning units on

decommissioned school buses not previously equipped with air conditioning, as well as supply

chain issues that will make it unable to comply with the October 3, 2022 effective date. Honky

Tonk further submits that, to the extent the enclosure requirement is directed to noise concerns,

Metro’s noise ordinance is sufficient to control noise levels. And, to the extent the enclosure

requirement is directed to safety concerns, Honky Tonk submits MTLC’s “Safety Rules”

otherwise provide for passenger safety, such as the requirement of side rails at a minimum of 40

inches in height from the floorboard. See MTLC Rule 050(e). Finally, Honky Tonk contends

there is no proof that safety will be increased by implementing the enclosure requirement and

points to the fact that pedal carriages, which are governed by separate regulation} are similarly

situated to ETVs but are not subject to enclosure requirements, notwithstanding that pedal

carriages travel on the same streets, have seats without backs or seatbelts, play music, serve

alcohol, and have patrons who shout and interact with passersby on the streets. Honky Tonk

further submits it has no significant history of traffic accidents or safety issues, its drivers have

“CDL class A/B license with P (passenger) endorsement, the size of the vehicles makes them

easily visible and less likely to be hit by other vehicles, and has an additional staff member, or

“host,” on every tour who monitors passenger activity and compliance.

MTLC responds that enclosure of ETVs is necessary to address public safety concerns

due to ETV patrons standing, dancing, and interacting with pedestrians outside of the ETVs, in

addition to noise concerns from the loud music played by ETVs and singing and yelling of ETV

2
Pedicabs, pedal carriages and low-speed vehicles operated within Metro are subject to separate
Metro ordinances, codified at Metro Code 88 6.75 and 6.73, and rules adopted by the MTLC.

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 Case No. 22-1132-1

patrons. MTLC maintains that ETVs loud music and patrons’ noise disrupts work, sleep, and

daily life of Nashville residents, guests, business workers and business owners. MTLC

acknowledges that enclosure is required for ETVs but not pedal carriages based on reduced

safety concerns and the fewer number of pedal carriages and patrons as compared with the

number of with ETVs and their patrons.

Hours of Operation. MTLC’S hours of operation regulations, set forth in Rule 050(t)

and 070(t), provide as follows:

050. Safety
* * *

(t) To enhance safety and encourage traffic flow, vehicles must travel in a
manner consistent with the flow of traffic and may not operate during
the rush hour period between 4-6 p.m., Monday through Friday.

070. Vehicle Operations

* * *

(t) ETV may begin operations after 9 a.m. and must cease operations
from the public roadway at 11 p.m. Any deviations from this schedule
must be requested in writing to the MTLC Director 10 days in advance
of the requested deviation. Where merited, the MTLC may grant this
request.

See id.

Honky Tonk alleges these hour restrictions violate its due process and equal protection

rights under the United States and Tennessee constitutions and bear no rational relation to

controlling traffic and noise. Honky Tonk asserts that MTLC adopted these restrictions without

the benefit of a current traffic study on ETVs’ impact on downtown traffic; that the traffic study

it did rely on from 2018 indicates “buses” are only .7% of downtown traffic during peak hours,

and ETVs are only a small subset of that number; and unlike other types of entertainment

vehicles, such as pedal and horse-drawn carriages, golf carts, and scooters, ETVs keep up with

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 Case No. 22-1 132-1

the speed of traffic and do not make stops to let passengers on and off during their routes.

Honky Tonk further submits it has a private property depot facility where passengers are safely

and securely loaded, identifications are checked, and safety rules are reviewed. Honky Tonk

states it currently is complying with the MTLC’s hours of operation, but at a serious financial

detriment to its business.

In response, MTLC relies on numerous concerns raised. by residents, visitors, and

businesses in the downtown area complaining of noise pollution and traffic congestion. In

addition, concerns and criticisms have been lodged with the MTLC concerning the behavior of

passengers on ETVs and their interaction with pedestrians and other

downtown patrons

(evidence of which includes thrown beer cans and lewd behavior), and the overall negative

impact on the safety, culture, and image of downtown Nashville. In the amici curiae brief, the

Interested Parties set forth their shared concerns.

Liquor Liability» Insurance. Honky Tonk challenges MTLC’s Rule 030(e) requirement

that ETCs must obtain liquor liability insurance:

030. Insurance requirement

***

(e) With regard to any holder of a certificate of convenience and necessity

who serves or dispenses alcoholic beverages to customers, whether or
not the certificate holder also supplies the alcoholic beverages served
to the customers, adequate insurance coverage shall also mean a policy,
of liquor liability insurance, with the minimum amount of liquor
liability insurance to be one million dollars, issued by 'an insurance
company qualified to do business in the state and naming the
metropolitan government as an additional insured and complying in all
other respects with the terms of this section.

See id. Honky Tonk also challenges this regulation on due process and equal protection grounds,

claiming it is likely not possible for ETCs to obtain such insurance within the time period

required, and that pedal carriages, which also serve alcohol, are not required to maintain such

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 Case No. 22-1132-1

insurance.

In response, Metro states that the liquor liability insurance requirement is on the MTLC

agenda for its September 22, 2022 meeting to consider whether this rule should be amended and

enforcement delayed. See Metro Resp. Ex. J.

III. LEGAL STANDARDS

A. Temporary Injunctions

Under Rule 65.04 of the Tennessee Rules of Civil Procedure, “[a] temporary injunction

may be granted during the pendency of an action if it is clearly shown by verified complaint,

affidavit or other evidence that the movant’s rights are being or will be violated by an adverse

party and the movant will suffer immediate and irreparable injury, loss or damage pending a final

judgment in the action, or that the acts or omissions of the adverse party will tend to render such

final judgment ineffectual.” Tenn. R. Civ. P. 65.04(2). The standard for determining whether

injunctive relief is appropriate, requires a court to consider the well-known four-factor test:

“(1) the threat of irreparable harm to plaintiff if the injunction is not granted; (2) the balance

between this harm and the injury that granting the injunction would inflict on the defendant;

(3) the probability that plaintiff will succeed on the merits; and (4) the public interest.” Fisher v.

Hargett, 604 S.W.3d 381, 394 (Tenn. 2020) (internal quotation omitted); Gentry v. McCain, 329

S.W.3d 786, 792 (Tenn. Ct. App. 2010). All factors are to be considered, and no single factor is

controlling. The grant or denial of a request for temporary injunction is discretionary with the

trial court. Fisher, 604 S.W.3d at 395.

B. Substantive Due Process Standards

To establish a claim for violation of substantive due process, a plaintiff must show either

a deprivation of a fundamental constitutional right without adequate justification or actions by

 Case No. 22-1132-1

the government which are or conscious shocking” in a constitutional sense. See Lynch
“arbitrafi
v. City of Jellico, 205 S.W.3d 384, 392 (Tenn. 2006). Unless a fundamental constitutional right

is involved, the test for determining whether governmental action violates substantive due

process is a “rational basis” test, meaning the challenged government action must bear a

reasonable relation to a legitimate governmental purpose. Newton v. Cox, 878 S.W.2d‘ 105, 110

(Tenn. 1994) (citing Nebbia v. New York, 291 U.S. 502, 537 (1934)).

Neither the Metro Ordinance nor the MTLC Rules impinge upon Honky Tonk’s

fundamental constitutional rights of life, liberty or The legal ability to operate

property.

entertainment vehicles within Metro is a privilege extended by permit. Consequently, in order

for Honky Tonk to state a substantive due process claim, it must establish that the MTLC Rules

are arbitrary or conscience shocking in a constitutional sense and do not bear a reasonable

relation to a proper legislative purpose. Newton, 878 S.W.2d at 111; see also G and N p

Restaurant Group, Inc. v. City of Chattanooga, No. E2013-02617-COA-R3-CV, 2014 WL

5035428, at *5 (Tenn. Ct. App. Oct. 8, 2014) (successfully challenging restriction on hours of

operation of restaurants to obtain beer permits).

C. Equal Protection Standards

The Tennessee Supreme Court recognizes that the equal protection clause of the

Tennessee Constitution is coextensive with the equal protection clause of the United States

Constitution. Calaway ex rel. Calaway v. Schucker, 193 S.W.3d 509, 518 (Tenn. 2005). Under

both federal and state constitutions, the equal protection clause guarantees that all persons

similarly situated shall be treated alike; but things that are different in fact are not required to be

treated the same. Riggs v. Burson, 941 S.W.2d 44, 52 (Tenn. 1997). Depending on the nature of

the right or class of persons affected, an equal protection challenge may be subject to strict
 Case No. 22-1132-1

scrutiny, heightened scrutiny, or reduced scrutiny, the latter of which applies a rational basis test.

Id. (citing Newton v. Cox, 878 S;.W.2d at 110). Again, because the ability to operate ETVs

within Metro is a privilege granted by permit, and is not a fundamental right, the reduced

scrutiny or rational basis test applies. G and N Restaurant Group, 2014 WL 5035428, at *10.

IV. ANALYSIS

Under Rule 65 of the Tennessee. Rules of Civil Procedure, the Court makes the following .

preliminary findings at this early stage of the proceedings on the motion for temporary

injunction.

A. Likelihood 0f Success on the Merits

Tennessee’s Declaratory Judgment Act provides for the determination of the

constitutionality of a law or local ordinance by declaratory action. Tenn. Code Ann. 8 29-1-101,

et seq. Generally, local ordinances are entitled to a “presumption of validity,” and those

questioning the validity of an ordinance have the burden of proof. See H&L Messengers, Inc. v.

City ofBrentwood, 577_ S.W.2d 444, 452 (Tenn. 1979) (citing State ex rel. Balsz'nger v. Town of

Madisonville, 435 S.W.2d 803, 805 (Tenn. 1968)).

With respect to the enclosure and liquor liability regulations, the Court finds that MTLC

did not consider the feasibility of ETV’s compliance with those specific regulations. Honky

Tonk has established significant obstacles to complying with both rules through the declarations -

submitted. The lack of feasibility of complying within the short time period imposed by MTLC,

is indicative of a level of arbitrariness. Indeed, Metro seems to acknowledge the feasibility issue

with respect to the liquor liability insurance regulation and, on its own initiative, is
reconsidering

that regulation. In addition, to the extent the enclosure requirement is directed to safety

concerns, there are other MTLC regulations not being challenged by Honky Tonk to effectuate

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Metro’s legitimate interest in protecting the public safety and safety of ETV patrons, such as the

required height of side rails and the presence of ETV staff members or “hosts” on ETVs to

monitor ETV patron behavior. To the extent the enclosure requirement is directed to noise

pollution concerns, other regulations not being challenged effectuate Metro’s legitimate interest

in limiting noise, including the requirements set forth under Rule 090 “Sound” regulation and the

limited hours of operation as discussed below. The Court finds, at this preliminary stage of the

proceedings, that Honky Tonk has shown a likelihood of sucCess on the merits in challenging the

enclosure and liquor liability insurance regulations on substantive due process grounds.

With respect to the two regulations addressing hours of operation, however, the Court

finds that Honky Tonk has failed to establish a likelihood of success on the merits that these

regulations are arbitrary or conscious shocking and not reasonably related to legitimate

governmental interest. MTLC Rule 050(f) limits hours of operation of ETVs during rush hour

travel times of 4:00-6:00-p.m. to protect the governmental interest in enhancing safety and

reducing traffic congestion at peak travel times. MTLC Rule 070(f) allows ETVs to begin daily

operations after 9:00 a.m. and cease operations on public roads at 11:00 p.m., to limit noise

pollution during the late evening and overnight hours. Both of these regulations for hours of

operation are rationally related to legitimate governmental interests for the safety and benefit of

the public, residents, guests and visitors in the downtown Nashville. While Honky Tonk asserts

that its compliance with the hours of operation rules has and will cause it to lose customers and

revenues, where the regulations are rationally related to government interests, “economic injury

alone will not invalidate” the regulations. G and N Restaurant Group, 2014 WL 5035428, at *8

(citing Rivergate Wine & Liquors v. City ofGoodlettsville, 647 S.W.2d 631, 635 (Tenn. 1983)).

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The Court reaches a different conclusion on Honky Tonk’s equal protection argument.

The Court finds that Honky Tonk has failed to establish that pedal cabs or carriages, which are

subject to different Metro Code provisions, are similarly situated to Honky Tonk’s ETVS. Pedal

carriages are smaller in size, patrons must remain seated while the vehicles are in motion, and

there are a smaller number of pedal carriages and pedal carriage patrons On the public streets in

downtown Nashville. Honky Tonk has not clearly shown a likelihood of success on the merits

that is rights are being violated by the MTLC’s ETV regulations regarding enclosure, hours of

operation, and liquor liability insurance requirements under the equal protection clauses of the

federal and state constitutions.

B. Threat of Irreparable Harm

With respect to the enclosure and liquor liability insurance requirements, Honky Tonk

has demonstrated its inability to comply with these two regulations within the short time period

imposed by MTLC. MTLC has already decided to reconsider the liquor liability insurance

requirement and placed that issue on the agenda for its September 22, 2022 meeting. Honky

Tonk has sufficiently shown through the declarations it submitted regarding the engineering

barriers for retrofitting decommissioned school buses with air conditioning that previously were

not equipped for air conditioning, and the supply chain issues impacting the timing of delivery of

materials to install and air condition the enclosures. The Court finds the threat of immediate and -

irreparable harm due to Honky Tonk’s inability to comply with requirements within the time
I

frame allowed and the risk of enforcement of those regulations against it weighs in favor of

Honky Tonk on both the liquor liability insurance and enclosure requirements where it lacks the

present ability to comply.

With respect to the hours of operation limitation, the Court finds that Honky Tonk has

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 Case No. 22-1 132-1

'

already implemented limited hours of operation rules. And while Honky Tonk submits that

reduced hours is negatively impacting its revenues and may generate bad publicity through

negative reviews on social media, it has the present ability to comply with this requirement

during the pending litigation. It has also been shown that the reduced hours of operation apply to

pedicabs, pedal carriages, and low-speed vehicles, eliminating any equal protection argument.

As a result, the Court finds that Honky Tonk has not clearly shown the threat of immediate and

irreparable harm as to the hours of operation limitation which could not otherwise be adequately

compensated through money damages.

C. Balance 0f Harms

Because other regulations adopted by the MTLC are directed to passenger safety and

noise concerns and Metro has decided to reconsider the liquor liability insurance requirement,

the Court finds that the balance of harms weighs against Metro and in favor of Honky Tonk on

the enclosure and liquor liability insurance issues. With respect to the hours of operation,

however, the Court finds that Honky Tonk Currently is complying with that requirement, which

also applies to other passenger vehicles such as pedicabs, pedal carriages and low-speed vehicles

and the balance of harms does not favor Honky Tonk on this issue.

D. Public Interest

Metro has a strong public interest in maintaining the safety and well-being of both

passengers on ETVs and the public using Nashville’s downtown areas, as well as a strong public

interest in protecting Nashville’s residents, guests and visitors from unreasonable noise pollution,

unsafe conditions from ETV passengers interacting with pedestrians or other offensive behavior.
Plaintiff counters that the public interest strongly favors protection of constitutional rights from

government intrusion; however, the ability to operate ETVs on Nashville’s public streets is a

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privilege and not a fundamental constitutional right. The Court finds this factor weighs in favor

of Metro and against the temporary injunctive relief requested as to all three regulations.

V. CONCLUSION
'

It is, therefore, ORDERED

Plaintiffs Motion for Temporary Injunction is hereby
that

GRANTED, in part, and DENIED, in part, as follows pursuant to Tennessee Rules of Civil
i I

Procedure 65.04, pending further orders of this Court:

A. Honky Tonk’s motion to temporarily enjoin Metro from enforcing MTLC Rule

4030(e) requiring liquor liability insurance is hereby GRANTED, and Metro, acting by and

through the MTLC, and its agents are hereby RESTRAINED and ENJOINED from enforcing

MTLC Rule 030(e) pending further orders of the Court;

B. Honky Tonk’s motion to temporarily enjoin Metro from enforcing MTLC Rule

040 requiring enclosure of Plaintiffs vehicles is hereby GRANTED, and Metro, acting by and

through the MTLC, and its agents are hereby RESTRAINED and ENJOINED from enforcing

MTLC Rule 040 pending further orders of the Court; and

C. Honky Tonk’s motion to temporarily enjoin Metro from enforcing MTLC Rules

050(f) and 070(f) limiting hours of operation for Plaintiffs entertainment transportation vehicles

is hereby DENIED; and

It is further ORDERED that pursuant to Rule 65.05 of the Tennessee Rules of Civil

Procedure, Plaintiff shall provide an injunction bond with sufficient surety in amount of
the

$2,500.00.

All other issues are reserved.

w M/jn,
PATRICIA HE® D MOSKA\L
CHANCELLEgR, PARTI
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 Case No. 22-1 132-1

92
ISSUED this them day of : Q}
E mtbol/ , 2022 at 2 .9 Q o’clock a.m./p.m.

MARIA M. SALAS, Clerk and Master

39“ Deptfill
Lilli
Clerk and -

ster
W
CC:
W. Scott Sims, Attorney at Law Andrew McClanahan, Asst. Metro. Attorney
D. Gil Schuette, Attorney at Law Hannah E. McCann, Asst. Metro. Attorney
Sims Funk, PLC
|
Angela D. Williams, Asst. Metro. Attorney
3322 West End Avenue, Suite 200 Metropolitan Department of Law
Nashville, TN 37203 Metropolitan Courthouse, Suite 108
ssims simsfunk.com Nashville, TN 37219
gschuette®simsfunk.com andrew.mcclanahan@nashville.gov
I
hannah.mccann@nashvillegzov
angela.d.wi11iams@nashville.gov

Jonathan B. Cooper, Attorney at Law

Michael A. Cottone, Attorney at Law
Waller, Lansden, Dortch & Davis, LLP
511 Union Street, Suite 2700
Nashville, TN 37219
ioncooper@wallerlaw.com
michael.cottone@wallerlaw.com

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