and continuance of this practico merely amounts to harrassment of a particular group of American citizens. This harrassment has not been effective in ridding our cities of such bars, for it is a well known fact that when one bar is closed, another springs up over night.

This point is best expressed in the closing brief presented by Attorneys Morris Lowenthal, Juliet Lowenthal and Karl D. Lyon as Amici Curiae on behalf of the appellants in the Vallerga case:

"Finally, we call attention to certain other aspects of the issue posed by the respondent. At the close of respondent's brief, it is contended that Section 24200(c) is intended to remove the 'congregation' of homo sexuals but they are free to visit bars who re the temptation from others of their kind may not be as great.'

"This assertion is an admission that if the ABC succeeds in closing all bars that are claimed to be resorts for homosexuals, it will not and cannot 'stamp out homosexuality' but will simply drive homosexuals to other bars. Furthermore, it is an admission that the legislati on (under respondent's interpretation) is clearly an attempt to limit personal liberty and the 'freedom of association' and 'freedom to assemble' which all persons have as a constitutional and statutory right.

"The practical adverse effects of supporting respondent's interpretation of Section 24200 (e) cannot be underestimated. It would not only result in a deprivation of the civil rights of the patrons involved, but it will cause irreparable loss to the individual licensees who would have no control over the situation.

"The adverse effects will be cumulative and widespread. Homosexual activities will not be diminished, nor will drinking by such people be discouraged. On the other hand, homosexuals would be required to transfer their patronage to other bars, including hotel bars, where they could not be refused service. The se bars, in turn, will have their own licenses jeopardized by ABC proceedings against them, and a never-ending process will be initiated, which presumably could continue ad infinitum until,

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