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1 locations. However, the mere fact that one can picket at <br />2 another location does not permit a picketing ban in a certain <br />3 location unless such a ban is narrowly tailored to support <br />4 specific interests, either in safety or in residential privacy. <br />QUESTION: But I think that any court familiar with <br />our cases might be more likely to uphold a ban on residential <br />7 picketing if there was an opportunity to picket the individual <br />that they desire to bring the message home to somewhere else. <br />9 MR. MCDOWELL: Certainly, aiternative channels can <br />I 0 figure into the analysis. However, once again, the key point <br />11 is is this ordinance which forbids all picketing flatly in the <br />12 Town of Brookfield an ordinance which is narrowly tailored to <br />13 support the interests involved. <br />14 QUESTION: Why do you say that it is not narrowly <br />15 tailored to support privacy and safety? <br />16 MR. MCDOWELL: Turning first to safety, the reason <br />17 why it is not narrowly tailored to support the safety interests <br />18 is number one, because the ordinance prohibits only picketing <br />19 but permits a number of expressive and non -expressive <br />20 activities which can have just as severe an effect upon the <br />21 interests of free vehicular movement and free pedestrian <br />22 movement and the like as anything else. <br />23 Furthermore, the ordinance addresses the problem in a <br />24 way which does not make much sense. If the problem is with the <br />25 picketers' safety and with the safety of the community with <br />34 <br />Heritage Reporting Corporation <br />(202) 628-4888 <br />