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Case: 1:17-cv-01613 Doc #: 1 Filed: 08/01/17 1 of 13.

PageID #: 1

UNITED STATES DISTRICT COURT


NORTHERN DISTRICT OF OHIO

Alison Abdul-Kareem, : Case No. 1:17-cv-1613

: Judge
Plaintiff,
:
v. VERIFIED COMPLAINT FOR
: DECLARATORY JUDGMENT,
Board of Park Commissioners of the TEMPORARY RESTRAINING ORDER,
Cleveland Metropolitan Park District : PRELIMINARY AND PERMANENT
INJUNCTION AND NOMINAL
And : DAMAGES

John Does #1-15, Cleveland Metropolitan :


Park District park rangers, names unknown
:
Defendants.

It is offensive--not only to the values protected by the First Amendment, but to


the very notion of a free society--that in the context of everyday public discourse
a citizen must first inform the government of her desire to speak to her neighbors
and then obtain a permit to do so. Even if the issuance of permits by the mayor's
office is a ministerial task that is performed promptly and at no cost to the
applicant, a law requiring a permit to engage in such speech constitutes a dramatic
departure from our national heritage and constitutional tradition.

Parks v. Finan, 385 F.3d 694, 701 (6th Cir.2004).

Now comes Plaintiff Alison Abdul-Kareem and for her Complaint against the Cleveland

Metropolitan Park District and the Cleveland Metropolitan Park District employees whose

identities are not currently known, and alleges as follows:

INTRODUCTION

1. This is an action for declaratory judgment, temporary restraining order, preliminary and

permanent injunction, and damages arising from the unconstitutional actions and polices of the

Board of Park Commissioners of the Cleveland Metropolitan Park District, and multiple Park

District law enforcement officers whose identities are currently unknown, but will become known

in the course of discovery.


Case: 1:17-cv-01613 Doc #: 1 Filed: 08/01/17 2 of 13. PageID #: 2

2. This action arises due to the Plaintiffs efforts and desire to engage in core political speech

within the grounds of a public park maintained by the Park District The Park Districts policies, as

well as the associated actions of numerous Park District law enforcement officers, have denied and

continue to threaten to deny Plaintiff (as well as other members of the public) the free and

unrestricted use of the traditional public fora, specifically, the public area of Edgewater Park, all

in violation of the First and Fourteenth Amendments to the United States Constitution.

JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction over this case pursuant to 28 U.S.C. 1331, as

this action arises under the First and Fourteenth Amendments to the United States Constitution;

under 28 U.S.C. 1343(a)(3), in that it is brought to redress deprivations, under color of state law,

of rights, privileges and immunities secured by the United States Constitution; under 28 U.S.C.

1343(a)(4), in that it seeks to recover damages and secure equitable relief under an Act of

Congress, specifically, 42 U.S.C. 1983, which provides a cause of action for the protection of

civil and constitutional rights; under 28 U.S.C. 2201(a), to secure declaratory relief; under 28

U.S.C. 2202, to secure preliminary and injunctive relief and damages; and under 42 U.S.C.

1988, to award attorneys fees.

4. Venue is proper within this judicial district and division pursuant to 28 U.S.C. 1391(b)

and Local Rule 82.1, as (i) the Defendants are situated within this judicial district and division;

and (ii) all of the claims asserted by Plaintiff arose within this judicial district and division.

FACTUAL ALLEGATIONS

5. Plaintiff ALISON ABDUL-KAREEM (Abdul-Kareem) is a resident of Cuyahoga

County, Ohio.

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6. Defendant Board of Park Commissioners of the CLEVELAND METROPOLITAN PARK

DISTRICT (the Park District) is a political subdivision organized under the laws of the State

of Ohio.

7. Defendants JOHN DOES #1-15 (the Park Rangers) are park rangers, who are members

of the law enforcement division of the Park District whose identities are currently unknown to the

Plaintiff, but will become known in the course of discovery. The Park Rangers are charged with

enforcing the Park Districts regulations, including those regulations at issue in this matter.

8. The Park District was established in 1917 and consists of over 22,000 acres of land,

including Edgewater Park.

9. Edgewater Park is a public park maintained by the Park District that consists of

approximately 146 acres, which includes 9,000 feet of shoreline, beaches, boat ramps, a

fishing pier, picnic areas and grills, and a recently constructed Edgewater Beach House.

Edgewater Park attracts visitors from throughout Cuyahoga County and the surrounding area.

10. The actions of the Defendants as described herein were undertaken in and under the

color and authority of state law.

Park Districts First Amendment Activities Permit Requirement

11. The Park District has established a policy, practice, and procedure requiring that, among

other things, people who wish to engage in First Amendment Activities within public parks

must first apply for and receive permission. A copy of the Park Districts First Amendment

Activity permit application (the Permit Application) is attached hereto as Exhibit A.

12. The above referenced policy is enforced by the Park Districts law enforcement officers.

13. Among other things, Park Districts First Amendment restrictions limit the exercise of

the First Amendment to one specific area within each park.

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14. Of the 146 acres of land that make up Edgewater Park, the Park District permits First

Amendment Activity within one picnic area described as Upper Edgewater Near Statue.

15. The Park District requires that an application for a permit to engage in First Amendment

activity be made not less than one week before a person intends to engage in First Amendment

Activities within a public park.

16. The Permit Application requires that a person who wishes to engage in First Amendment

Activity within the grounds of a public park first provide her name, address, and telephone

number.

17. Additionally, the First Amendment Conditions of Use provides that, Individuals failing

to meet any of these conditions of use will be asked to leave, and future permits may not be

awarded to these individuals or organizations.

18. The First Amendment Conditions of Use further specifies that, Soliciting or selling is

not permitted. The transaction of money, goods or services is strictly prohibited. Thus, the

permitting requirement is aimed specifically at non-commercial speech.

Plaintiff attempts to engage in First Amendment Activity

19. Abdul-Kareem is involved in an initiative petition effort to place the issue of

decriminalizing marijuana possession before the voters of Cleveland on the November 2017

ballot.

20. Initiative petitions efforts are activities afforded protection under the First Amendment

to the United States Constitution.

21. In support of such efforts, on July 27, 2017, at approximately five p.m., Abdul-Kareem

was present at Edgewater Park soliciting signatures in support of the foregoing ballot petition

effort.

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22. Abdul-Kareem did not apply for a First Amendment Activity permit prior engaging in

First Amendment activities, and does not wish to apply for or obtain a First Amendment

Activity permit in the future.

23. On the evening of July 27, 2017, Edgewater Park was host to the Edgewater Live music

series, a concert series running Thursday evenings for ten weeks in Edgewater Park.

24. In 2016, Edgewater Live attracted approximately 100,000 people, and has been touted

as one of the main events that will draw Clevelanders to the space. See, the June 1, 2017

Cleveland Scene Article, Take a Look at Edgewater Park's New Multi-Million Dollar Beach

House, Which Opens Friday Attached hereto as Exhibit B.

25. Abdul-Kareem positioned herself in an area of Edgewater Park open to the public but

outside the designated First Amendment Area. Specifically, Abdul-Kareem stationed herself

on a walkway near the recently opened Edgewater Beach House (See attached Exhibit C which

shows Abdul-Kareems approximate location).

26. Attached as Exhibit D is an overhead image of Edgewater Park showing the

approximate location of the designated First Amendment Activity area in relation to Abdul-

Kareems location, and showing that according to Google Maps it is an approximately 13

minute walk from the designated First Amendment Activity Area to Abdul-Kareems chosen

location.

27. Abdul-Kareem specifically chose this location so as to interact with the numerous

Clevelanders who were drawn to the space by the Edgewater Live music event.

28. Had Abdul-Kareem stationed herself in the designated First Amendment Activity area,

she would not have had access to the audience she was trying to reach namely the attendees

of the Edgewater Live music event.

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29. At no time did Abdul-Kareem threaten, harass, or intimidate other park visitors, nor does

she wish to. Once someone declines to sign the petition, Abdul-Kareem thanks them for their

time and wishes them a good day, Abdul-Kareem does not pursue or harass them in any way.

30. When soliciting signatures on the initiative petition Abdul-Kareem does not litter or

encourage others to litter.

31. Abdul-Kareem is always willing to step aside while soliciting signatures and let others

pass by. She never attempts to block people as they pass by.

32. At no time did Abdul-Kareem enter into or propose to enter into any commercial

transaction with any other park visitor, nor does she wish to.

Park District Rangers harass and intimidate Abdul-Kareem

33. Shortly after commencing her efforts to collect signatures and communicate her

message, Abdul-Kareem noticed that her activities were being monitored by a Park Ranger who

appeared to be taking photographs or video of Abdul-Kareem.

34. Abdul-Kareem also noticed another Park Ranger who appeared to be monitoring her

activity from within a patrol vehicle.

35. Shortly thereafter, Abdul-Kareem was approached by numerous Park Rangers.

36. Notwithstanding Abdul-Kareems presence in a public park, the Park Rangers, acting to

enforce the regulations described above, declared to Abdul-Kareem that that Park District rules

prohibited her from soliciting signatures within the park grounds without a permit and

demanded that she remove herself from Edgewater Park.

37. One Park Ranger demanded that Abdul-Kareem produce her drivers license and Abdul-

Kareem complied.

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38. Abdul-Kareem asked if she was being detained and a Park Ranger responded that Abdul-

Kareem was being detained.

39. Eventually, the Park Rangers returned Abdul-Kareems drivers license was returned to

her at which point Abdul-Kareem asked the Park Rangers if she would be arrested if she

continued to gather signatures in the park. The Park Rangers told Abdul-Kareem that she would

not be arrested.

40. In response, Abdul-Kareem walked approximately twenty feet down the path and

continued to engage passersbys to obtain signatures.

41. A few minutes later, while Abdul-Kareem was engaged with a person who was signing

the petition, a second group of Park Rangers approached Abdul-Kareem These Park Rangers

likewise declared that Abdul-Kareem was prohibited from gathering signatures in the park

without a permit.

42. During this second interaction, the individual stopped signing the petition prior to fully

filling out the required information. The individual quickly exited the area, presumably out of

fear or intimidation from the Park Rangers.

43. During this second interaction, not only did Park Rangers approach on foot, but also in

official Park Ranger vehicles, and two Park Rangers approached on horse back, suggesting a

show of force intended to intimidate not only Abdul-Kareem, but any other citizen who may

wish to exercise their First Amendment rights within Edgewater Park.

44. Park Rangers surrounded Abdul-Kareem in an intimidating fashion, stood within a few

feet of her, and interfered with her constitutionally protected right to engage with members of

the public.

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45. Abdul-Kareem again informed the Park Rangers that she intended to continue gathering

signatures.

46. Eventually, the Park Rangers stopped harassing Abdul-Kareem.

47. The Park Rangers actions caused Abdul-Kareem fear and anxiety and served to create

the impression in passersby that Abdul-Kareem was a pariah or a person to otherwise be

avoided.

48. Abdul-Kareems efforts to collect signatures on the initiative petition were frustrated by

the actions of the Park Rangers. As a result of the Park Rangers actions, Abdul-Kareem

discontinued her initiative petition efforts.

49. Abdul-Kareem (as well as others) desires to collect signatures in support of the present

initiative petition effort (as well as future initiative petition efforts) in all public areas of

Edgewater Park, including without limitation, within the same part of Edgewater Park that the

Park Rangers harassed her.

50. However, in doing so, Abdul-Kareem, as well as others, risks the real and present

consequence of engaging in such activities protected by the First Amendment, including,

without limitation, the potential of harassment, intimidation and detention by Park Rangers due

to, inter alia, the direction and policies given to them by the Board of Park Commissioners of

the Cleveland Metropolitan Park District.

COUNT 1
DECLARATORY JUDGMENT AND INJUNCTION
(28 U.S.C. 2201, et seq.)

51. Plaintiff hereby incorporates by reference the allegations in the foregoing paragraphs as

if set forth fully herein.

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52. Public parks such as Edgewater Park are quintessential public fora under First

Amendment jurisprudence, open to the public for the exercise of rights protected and guaranteed

by the First Amendment, including political advocacy and religious expression.

53. The actions and policies of the Defendants in denying Abdul-Kareem (as well as others)

access to such forum, as well as the requirement that a permit be acquired prior to engaging in

First Amendment activity, fails to comply with the standards and requirements for the regulation

of activities protected by the First Amendment.

54. The actions and policies of the Defendants in denying Abdul-Kareem (as well as others)

access to such forum was taken in violation of the First and Fourteenth Amendments to the

United States Constitution.

55. In order to prevent further violation of Abdul-Kareems constitutional rights by

Defendants, as well as the rights of others who might wish to freely exercise their First

Amendment rights in Edgewater Park, it is appropriate and proper that a declaratory judgment

be issued, pursuant to 28 U.S.C. 2201 and FED.R.CIV.P. 57, declaring unconstitutional the

actions of the Park Rangers and the policy and practice of the Board of Commissioners of the

Cleveland Metropolitan Parks District to prohibit activities protected by the First Amendment

in the public area of Edgewater Park, in general, and at the specific location where Abdul-

Kareem was located on July 27, 2017.

56. Furthermore, pursuant to 28 U.S.C. 2202 and FED.R.CIV.P 65, it is appropriate and

hereby requested, that this Court issue a preliminary and permanent injunction enjoining the

Defendants from enforcing the prohibition on advocacy by Abdul-Kareem (as well as others)

in the forum at issue, and that the Court award nominal damages to Abdul-Kareem as a result

of the violation of her constitutional rights.

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Case: 1:17-cv-01613 Doc #: 1 Filed: 08/01/17 10 of 13. PageID #: 10

COUNT 2
VIOLATION OF THE FIRST AND FOURTEENTH AMENDMENTS
TO THE UNITED STATES CONSTITUTION
(42 U.S.C. 1983)

57. Plaintiff hereby incorporates by reference the allegations in the foregoing paragraphs as

if set forth fully herein.

58. All acts alleged herein of the Defendants, their agents, servants, employees, or persons

acting at their behest or direction, were done and are continuing to be done under the color and

pretense of state law.

59. The policy and practice of the Board of Commissioners of the Cleveland Metropolitan

Park District of refusing access to a traditional public forum by Abdul-Kareem (as well as

others) is in violation of Plaintiffs First Amendment right to the freedom of speech and to

petition the government for redress of grievances and the Fourteenth Amendments right of

equal protection of the laws.

60. As a direct and proximate result of the Park Districts prohibition against the right to free

speech and to petition the government for redress of grievances in a traditional public forum,

Abdul-Kareem (as well as others) are suffering and will continue to suffer irreparable harm for

which there is no adequate remedy at law.

61. As a direct and proximate result of the Defendants acts in pursuit of the policy

prohibiting Abdul-Kareem (as well as others) from engaging in activities protected by the First

Amendment at Edgewater Park except within certain areas therein, and only after applying for

and receiving permission, Abdul-Kareem has had her political speech directed to the public

squelched, which has deprived her of her constitutional rights to freedom of speech as protected

by the First Amendment, and she has suffered damage as a result.

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62. As a legal consequence of the Defendants' violation of Abdul-Kareem's First and

Fourteenth Amendment rights, as alleged above, Abdul-Kareem is entitled to recover nominal

damages.

WHEREFORE, Plaintiff prays for judgment against Defendants and that the Court:

A. Adjudge, decree and declare the rights and other legal relations of the parties to

the subject matter in controversy in order that such declarations shall have the force

and effect of final judgment and that the Court retain jurisdiction of this matter for the

purpose of enforcing the Court's Orders;

B. Pursuant to 28 U.S.C. 2201, declare that Defendants' policy and practice, as alleged

above, violates the First and Fourteenth Amendments to the United States

Constitution;

C. Pursuant to 28 U.S.C. 2202, 42 U.S.C. 1983, and FED. R.CIV. P. 65 preliminarily

and permanently enjoin Defendants from enforcing their unconstitutional policies against

Plaintiff and others similarly situated now or in the future, order Defendants to provide

equal access to the forum, and award nominal damages to Plaintiff;

D. Pursuant to 42 U.S.C. 1988 and other applicable law, award Plaintiff her costs and

expenses incurred in bringing this action, including reasonable attorneys' fees; and

E. Grant such other and further relief, as the Court deems equitable, just and proper.

Respectfully submitted,

/s/ Brian C. Shrive


Brian C. Shrive
(OH Bar No. 0088980)
Christopher P. Finney
(OH Bar No. 0038998)
FINNEY LAW FIRM, LLC
4270 Ivy Pointe Blvd., Suite 225

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Case: 1:17-cv-01613 Doc #: 1 Filed: 08/01/17 12 of 13. PageID #: 12

Cincinnati, Ohio 45245


Tel: (513) 943-6656
Fax: (513) 943-6669
Email: brian@finneylawfirm.com

Attorney for Plaintiff

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Cleveland Metroparks
First Amendment Activities
Application
__________________________________________________________________________________
3900 Wildlife Way, Cleveland, OH 44109 Telephone: 216-635-3304 Fax: 216-661-3312

Please read the following carefully before completing the First Amendment
Activities Application. For additional information or assistance, please
contact Special Events & Experiences at Cleveland Metroparks by mail, fax,
or phone from 8:30am to 4:30pm, Monday Friday.

First Amendment Activities Application Procedures

A permit must be obtained to conduct First Amendment activities in Cleveland Metroparks.


Requests are accepted up to one (1) month in advance and until one (1) week prior to the
date of the activity.

Refer to the First Amendment Activities Conditions of Use for areas in which to conduct the
activity.
Case: 1:17-cv-01613 Doc #: 1-2 Filed: 08/01/17 2 of 3. PageID #: 18

Cleveland Metroparks
First Amendment Activities
Conditions of Use
All rules and regulations of Cleveland Metroparks, including but not limited to those specified in this permit, as highlighted
below, must be strictly observed at all times. Please read the following carefully. Any questions should be directed to
the Special Events & Experiences Division at 216-635-3304

First Amendment activities are permitted in Cleveland Metroparks on a non-exclusive use basis. Please be aware that
other park visitors will be using the area for a variety of non-exclusive use activities such as picnicking, kite flying,
etc. These activities are permitted and you may encounter them, so please plan accordingly.

You may not harass individuals passing by the First Amendment areas. At all times extend care, consideration and
courtesy to others.

Soliciting or selling is not permitted. The transaction of money, goods or services is strictly prohibited.

Distribution of materials outside the free speech area is not permitted. This includes placing fliers on car windshields.

Permit holders are required to remain in the free speech area at all times while engaging in First Amendment
activities.

Please note that alcoholic beverages and amplified music/public address systems are not permitted.

You may set up chairs or tables immediately preceding the activity with removal, cleaning and restoration of the area
to its original condition required immediately following the activity.

If a sign is to be used in this activity, the sign must be an above-ground type (i.e. A-frame) not more than
3 x 3 in size. Digging and/or the use of other in-ground signs of any kind is strictly prohibited. At no time is the
sign to be attached to any trees, posts, signs, buildings or any other property belonging to Cleveland Metroparks. The
sign must be located no closer than twenty feet from the parkway and/or intersections and shall in no way, or at any
time, obstruct the view or flow of traffic.

Permittee is responsible for any and all damages to and/or caused by the sign and shall be further responsible for
ensuring the satisfactory appearance of the sign at all times, as determined by Cleveland Metroparks.

Non-reservable picnic areas where this activity is permitted are listed below. The shelter and cookhouse facilities are
to remain available as eating areas for park visitors and are not to be used for this activity.

Individuals failing to meet any of these conditions of use will be asked to leave, and future permits may
not be awarded to these individuals or organizations.
Reservation Picnic Area Reservation Picnic Area
Acacia Grass area north of Lakefront Upper Edgewater Near Statue
Cedar Rd. parking lot
Bedford Egbert Mill Stream Run Bonnie Park
Big Creek Memphis North Chagrin Forest
Bradley Woods Codrington Ohio & Erie Canal Settlers Bluff
Brecksville Harriet-Keeler Rocky River (north) South Mastick
Brookside Meadow Ridge (south) Lagoon
Euclid Creek Welsh Woods South Chagrin The Shelterhouse
Garfield Park Red Oak Washington Arborview
Hinckley Johnsons West Creek As designated
Huntington Lake Cleveland Metroparks Zoo Ticket Plaza as designated

Cleveland Metroparks 1/2014


Special Events & Experiences
Case: 1:17-cv-01613 Doc #: 1-2 Filed: 08/01/17 3 of 3. PageID #: 19

Cleveland Metroparks
First Amendment Permit
Application
__________________________________________________________________________________
3900 Wildlife Way, Cleveland, OH 44109 Telephone: 216-635-3304 Fax: 216-661-3312

To apply for a First Amendment permit, this application must be completed submitted via mail, fax, or email
up to one (1) month in advance and at least one (1) week prior to the date of the activity. By submitting the
application, the applicant certifies that they have read and will comply with all First Amendment Conditions of
Use. A confirmed permit will be returned. Please call Special Events & Experiences for any additional
questions.

I have read and agree to Cleveland Metroparks First Amendment Conditions of Use.

X ________________________________ X_______________
Signature of Permit Holder Date

APPLICANT INFORMATION
__________________________________________________________________________________
Applicant Name * Organization/ Group (if applicable)
__________________________________________________________________________________
Street Address * Apartment/Suite
__________________________________________________________________________________
City * State * Zip Code *
__________________________________________________________________________________
Daytime Phone * Evening Phone
__________________________________________________________________________________
Cell Phone Email *
__________________________________________________________________________________
Event Day On-Site Contact (if different from applicant) Cell Phone

FIRST AMENDMENT ACTIVITY INFORMATION


______________________________________________________________________
Name of Organization *
__________________________________________________________________________________
Requested Reservation *
__________________________________________________________________________________
Requested Area(s) *

Proposed Date(s) of Activity: * ___________________________________________

Hours of Activity: * From _____________ AM/PM - _____________ AM/PM

Expected Number of Participants: * _______________ Expected Number of Spectators: ___________

Additional Activity Description:


__________________________________________________________________________________________________
__________________________________________________________________________________________________
Case: 1:17-cv-01613 Doc #: 1-3 Filed: 08/01/17 1 of 6. PageID #: 20
Take a Look at Edgewater Park's New Multi-Million Dollar Beach House, Which Opens Friday | Scene and Heard: Scene's News Blog 7/31/17, 10:24 PM

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SCENE & HEARD Thursday, June 1, 2017

Take a Look at Edgewater Park's New


Multi-Million Dollar Beach House, Which Opens
Friday
Posted By Laura Morrison on Thu, Jun 1, 2017 at 4:25 pm

The Edgewater Beach House opens this


Friday, just in time for next Thursday's
kickoff of the Edgewater Live music
series.

The project, which began last fall, was one


of a few renovations to the popular public
beachfront park. A plaza, trails, and a
roundabout were also added to the space,
to help entering, enjoying and exiting the All photos via clevemetroparks/Instagram

park an easier experience.

But the $3.3 million two-story beach house is the highlight.

Metroparks CEO Brian Zimmerman told Cleveland.com that he and his team
worked diligently to preserve the park's history when building the structure.

"We looked at the history of the park and what Edgewater means to
Clevelanders," Zimmerman said. "We listened to so many people sharing
stories of coming down to Edgewater for years and years. This was an

https://www.clevescene.com/scene-and-heard/archives/2017/06/01/take-a-look-er-parks-new-multi-million-dollar-beach-house-which-opens-friday?mode=print Page 1 of 6
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Take a Look at Edgewater Park's New Multi-Million Dollar Beach House, Which Opens Friday | Scene and Heard: Scene's News Blog 7/31/17, 10:24 PM

opportunity to connect the beach with its past."

The stunning new 12,000-square foot location with open-air walkways is also
an opportunity for the park systems to sell drinks and food to patrons. There is
enough seating for 250 people, and park even plans on serving a happy hour.

Edgewater Live, which brought out at least 100,000 fans last summer,
however, is one of the main events that will draw Clevelanders to the space.

For those who may not have seen it yet, here's the 2017 Edgewater Live concert
schedule. The shows all start at 4:30 p.m.

June 8: Faction
June 15: Breakfast Club
June 22: The Caliber Band
June 29: Shout!
July 6: Carlos Jones
July 13: Welshly Arms
July 20: Abby Normal and The Detroit Lean
July 27: Kinsman Dazz Band
Aug. 3: Collage
Aug. 10: The Spazmatics

Take a look at more of what you can expect at the new boat-like beach house
below:

https://www.clevescene.com/scene-and-heard/archives/2017/06/01/take-a-look-er-parks-new-multi-million-dollar-beach-house-which-opens-friday?mode=print Page 2 of 6
Case: 1:17-cv-01613 Doc #: 1-3 Filed: 08/01/17 3 of 6. PageID #: 22
Take a Look at Edgewater Park's New Multi-Million Dollar Beach House, Which Opens Friday | Scene and Heard: Scene's News Blog 7/31/17, 10:24 PM

https://www.clevescene.com/scene-and-heard/archives/2017/06/01/take-a-look-er-parks-new-multi-million-dollar-beach-house-which-opens-friday?mode=print Page 3 of 6
Case: 1:17-cv-01613 Doc #: 1-3 Filed: 08/01/17 4 of 6. PageID #: 23
Take a Look at Edgewater Park's New Multi-Million Dollar Beach House, Which Opens Friday | Scene and Heard: Scene's News Blog 7/31/17, 10:24 PM

Tags: Edgewater Park, Beach House, Image

Jump to comments (3)

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SPEAKING OF EDGEWATER PARK, BEACH HOUSE

Cleveland Metroparks Celebrates Major Renovations Coming to Scheduled Edgewater Water


100 Years in Spectacular Fashion Edgewater Park and Euclid Balloon Fight Causing Ruckus
This Saturday Beach Pier Online
Jul 20, 2017 Sep 30, 2016 Jun 13, 2016
MORE

https://www.clevescene.com/scene-and-heard/archives/2017/06/01/take-a-look-er-parks-new-multi-million-dollar-beach-house-which-opens-friday?mode=print Page 4 of 6
Case: 1:17-cv-01613 Doc #: 1-3 Filed: 08/01/17 5 of 6. PageID #: 24
Take a Look at Edgewater Park's New Multi-Million Dollar Beach House, Which Opens Friday | Scene and Heard: Scene's News Blog 7/31/17, 10:24 PM

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COMMENTS (3) Sort Oldest to Newest

Showing 1-3 of 3 add a comment

does the new Beach House have showers like the old one?

report 1 like, 0 dislikes like dislike


Posted by Chris Bragg on 06/04/2017 at 9:30 PM

Looked ugly and terrible while under construction, but all that changed once they
got the wooden facing done. And the bridge is a nice touch. Love the swings that
hang down beneath it.

I was wondering about the showers, too, and the changing rooms.
Are they still available? Underneath the upper deck?.
They do have two of those outdoor spray thingies, though.

Gonna be the "in spot" to watch the summer sunsets...it might outdraw the Lakewood Solstice
Steps.

Chuckles the Clown


report 1 like, 0 dislikes like dislike
Posted by Chuckles the Clown on 06/07/2017 at 2:33 AM

Nice atmosphere.....I just don't like all of the racist park ranger cops there. People
of color are having bad experiences with those guys.....

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Posted by Anthony Fore on 07/14/2017 at 11:21 AM

https://www.clevescene.com/scene-and-heard/archives/2017/06/01/take-a-look-er-parks-new-multi-million-dollar-beach-house-which-opens-friday?mode=print Page 5 of 6
Case: 1:17-cv-01613 Doc #: 1-3 Filed: 08/01/17 6 of 6. PageID #: 25
Take a Look at Edgewater Park's New Multi-Million Dollar Beach House, Which Opens Friday | Scene and Heard: Scene's News Blog 7/31/17, 10:24 PM

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https://www.clevescene.com/scene-and-heard/archives/2017/06/01/take-a-look-er-parks-new-multi-million-dollar-beach-house-which-opens-friday?mode=print Page 6 of 6
Case: 1:17-cv-01613 Doc #: 1-4 Filed: 08/01/17 1 of 1. PageID #: 26
Case: 1:17-cv-01613 Doc #: 1-5 Filed: 08/01/17 1 of 1. PageID #: 27

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