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5. Because of the location and configuration of Industrial Drive and the growth and expansion of Bad Boy and LifePlus, the Industrial Drive Section is used almost exclusively by employees and invitees of Petitioners, including tractor trailers delivering parts and transporting products to/from Bad Boy's facilities on a constant basis. 6. Since Petitioners are the sole owners of the land adjoining the Industrial Drive Section,Petitioners' interests are best served by closing the Industrial Drive Section. 7. A large number of tractor trailers and other trucks enter and exit the industrial Drive Section from Bad Boy's facilities on a daily basis. 8. There are sufficient streets and thoroughfares in the area to carry traffic volume through that part of the city so that the general public will not be hindered by the closing. 9. Vacating and abandoning the Industrial Drive Section will create a safer environment for tractor trailers to enter and exit Bad Boy's facilities and increase the safety and security of the hundreds of individuals employed by Petitioners and Petitioners' invitees, as well as the public at large. 10. Vacating and abandoning the Industrial Drive Section will save the city maintenance costs associated with its upkeep. Given the repeated exposure to heavy tractor trailer rigs, the savings will be significant. The Affidavit of City Engineer, Daman Johnson, is attached hereto as Exhibit"E". 11. Vacating and abandoning the Industrial Drive Section will protect Petitioners from possible criminal activity. The Industrial Drive Section runs through the heart of Bad Boy and LifePlus and their adjoining assets.As it exists now, the Industrial Drive Section is a public street that can easily be used to burgle or steal the assets of Petitioners. Given that the public does not use the Industrial Drive Section to any meaningful extent,this risk is unnecessary. 2