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<br />PETITION OF CELANESE CORPORATION OF AMERICA <br />TO CITY OF LA PORTS, TEXAS <br />THE STATE OF TEXAS <br />COUNTY OF HARRIS <br />Comes now Celanese Corporation of America, a <br />Delaware corporation, with a permit to do business in the <br />State of Texas, being the owner, operator and manager of <br />real property and chemical plant facilities located within <br />the territory proposed to be annexed to the City of La <br />Porte pursuant to and in accordance with City of La <br />Porte Ordinance No. 53~+ as published in the La Porte Liberal <br />on Friday, April 4, 1958, and hereby does object to and <br />contest said proposed annexation and as basis for such <br />represents as follows: <br />I <br />That said annexation constitutes an amendment <br />to Article 1, Section 2, of the Home Rule. Charter for the <br />City of La Porte and is in violation of Article 11, Section <br />5, of th.e Constitution of the State of Texas, which pro- <br />vides that no city charter shall be altered, amended or <br />repealed oftener than every two years. <br />II <br />That said Ordinance No. 53~+ as published in the <br />La Porte Liberal on April 4, 1958, does not give a <br />description of the territory proposed to be annexed sufficient <br />to support further action thereon by the City of La Porte. <br />III <br />That petitioner's real property and chemical plant <br />facilities located within the territory proposed to be <br />annexed is not adaptable to or necessary for the municipal <br />needs and growth of the City of La Porte. <br />