rental application to complete and explained the requirements to hold a show at the convention center: payment of a use fee (including an initial deposit and a larger, final payment), an assembly permit and floor plan approval from the fire department, an occupational license from the City of Miami financial department, a certificate of insurance, and police security. He emphasized that an actual certificate of insurance was necessary; an insurance binder would be inadequate.
On September 15, Ellisor submitted a rental application, together with a $2,500 deposit check provided by the Miami Motorcycle Show. Ellisor then submitted a proposed contract on November 10, three days after the November 7 deadline; nonetheless, Wright did not enforce the deadline. On November 13, Ellisor gave Wright a check for $5,000 toward theoutstanding use fee, but that check bounced due to nonsufficient funds. Wright then informed Ellisor that he would no longer accept checks as payment; Ellisor reassured Wright that he had plenty of money coming in. On November 19, Ellisor gave Wright $1,050 in cash.
In the days leading up to the show, Ellisor continued to confirm that the show would proceed as planned. Ellisor asked one teacher to give the school's check for $1,060 directly to the convention center. On December 1, the teacher went to the convention center and attempted to give the check to Gregory Wright, who refused to accept it. Ellisor then picked up the check in person from the school on December 2, assuring the students that the show would proceed as planned. He also