Edmonton's Twilight Afterhours Club is trying to get its licence back.
The city ordered the downtown club to close earlier this summer, saying it was a hotspot for violence and threatened public safety.
The city's chief licensing officer, Randy Kirillo, cited six violent incidents at or near the club in 30 months, including a fatal shooting in February. He also cited poor business practices by the owners in determining to close the club in June.
However, in a written submission to the city clerks office and the public safety compliance team, Twilight's lawyer Shauna Finlay argues the club hasn't been give a fair chance.
Finlay said much of the violence the city cites wasn't on the club's property and the people involved were not patrons.
Finlay wrote the "decision to revoke the business licence of Twilight was based on facts that had not been established, on hearsay, and was in ordinarily punitive…"
The fatal shooting on Feb. 15 for example was not on Twilight property and those involved were not patrons of Twilight, Finlay stated.
Twilight wants to reopen, but under strict conditions, including tighter security and more oversight from the police.
Finlay also said in the letter that the club's owner Sang Nguyen and manager James O'Malley were making changes to ensure the club would be safer around the time of the closure.
Nguyen and O'Malley installed video monitoring, ID scanning, more lighting and had hired new security.
"Restricting the terms of Twilight's business licence, if reinstated, provides Twilight with the opportunity to demonstrate that its new business practices, signage and security arrangements are effective in creating a safe atmosphere," Finlay wrote.
Also, included in Finlay's submission was a draft letter to the Edmonton Police Service, stating Twilight is willing to allow police officers to enter the club and do their own ID checks.
Twilight's owner and manager are expected to make their case before the city's community standards and licence appeal committee on Tuesday.