Summary of the Defense Statements Filed by DOX and Hildegard Draaijer (1)

The following is a summary of the principal themes contained in the defense statements filed by DOX and Hildegard Draaijer in the ongoing Dutch court proceedings. It is intended to help readers understand the positions adopted by the defendants. It is not intended as commentary or criticism.

Overview

The defense statements present a consistent narrative in which DOX describes itself as having played a significant and continuing role in Anderson Carvalho's artistic development and in the subsequent development of Anderson Carvalho Dance & Choreography ("ACDC").

According to the defense statements, the relationship between Anderson Carvalho and DOX should not be viewed as a short period of employment followed by independent artistic development, but rather as a continuing relationship that evolved over time into an international artistic collaboration.

Within that overall narrative, the defense statements make several principal arguments.

1. DOX played a continuing role in Anderson Carvalho's artistic development

   The defence statements describe Anderson Carvalho as an artist who developed within the artistic environment of DOX.

   According to DOX:

   • Anderson became involved with DOX in 2017.
   • DOX provided opportunities for his artistic growth.
   • DOX continued supporting his development after his initial involvement.
   • The later collaboration between Anderson and DOX should therefore be understood as a continuation of an existing relationship rather than the beginning of a new one.

   The defense statements therefore portray DOX as an important institutional influence in Anderson's artistic career.

2. ACDC and DOX developed a continuing artistic collaboration

   The defense statements describe the relationship between ACDC and DOX as developing from individual cooperation into a broader institutional partnership.

   According to DOX, this collaboration included:

   • artistic coaching;
   • production support;
   • international artistic exchange;
   • rehearsal facilities;
   • organisational support;
   • co-production of artistic works;
   • and long-term collaboration.

   The defense statements therefore present the relationship as substantially broader than a series of isolated projects.

3. DOX considers itself a co-producer of Dance Intersect-related work

   One of the central themes throughout the defense statements is that DOX made significant contributions to work associated with Dance Intersect.

   According to the defense statements, those contributions included:

   • artistic coaching;
   • rehearsal periods;
   • production support;
   • technical support;
   • rehearsal facilities;
   • dancers;
   • organisational assistance;
   • financial contributions;
   • and international networking.

   The defense statements argue that these contributions justify describing DOX as a co-producing partner in relation to the relevant productions.

4. DOX describes the Utrecht collaboration as part of a broader partnership

   The defense statements present the Utrecht production not as an isolated collaboration but as one element within a wider international partnership between DOX and ACDC.

   According to the defense statements, the parties intended to continue collaborating internationally beyond Utrecht.

   Within this narrative, Utrecht forms part of a longer-term artistic relationship rather than a standalone project.

5. DOX included Anderson Carvalho and ACDC in its international funding strategy

   The defense statements explain that Anderson Carvalho, ACDC and Dance Intersect formed part of DOX's international artistic ambitions.

   According to the defense statements:

   • ACDC appears within several multi-year funding applications;
   • Dance Intersect is presented as an international collaboration;
   • Anderson Carvalho is described as an artist whom DOX would continue supporting through artistic coaching;
   • DOX presents itself as acting as co-producer in multiple countries;
   • those collaborations formed part of DOX's internationalisation strategy.

   The defense statements further explain that DOX received substantial public funding during the relevant funding period.

   The defense statements present these funding applications as reflecting genuine intended collaborations between the parties.

6. Hildegard Draaijer's role

   Hildegard Draaijer's defense statement presents her role as that of an experienced cultural professional acting in the interests of both ACDC and DOX.

   According to her defense statement, she:

   • became involved with ACDC in a supportive capacity;
   • provided artistic coaching;
   • assisted with governance;
   • advised on funding;
   • facilitated relationships within the Dutch cultural sector;
   • supported international collaborations;
   • and contributed to the development of artistic projects.

   Her defense statement presents these activities as being undertaken in good faith and in support of Anderson Carvalho's artistic development.

7. The documentary record

   The defense statements rely on numerous documents in support of the above narrative.

   These include, among others:

   • annual reports;
   • collaboration agreements;
   • protocols;
   • reports;
   • funding applications;
   • subsidy decisions;
   • correspondence;
   • project planning documents;
   • promotional material;
   • and internal planning documents.

   According to the defense statements, these documents demonstrate the existence of a continuing collaborative relationship between DOX and ACDC.

The overall narrative presented by the defense statements

Viewed as a whole, the defense statements advance one overarching proposition.

They present Anderson Carvalho's career, the development of ACDC, the Utrecht collaboration, Dance Intersect and the international funding applications as elements of a single, continuing relationship between Anderson Carvalho and DOX.

Within that narrative:

• DOX is presented as an institution that discovered, supported and continued developing Anderson Carvalho;

• ACDC is presented as an organisation with which DOX developed an ongoing institutional partnership;

• Dance Intersect is presented as a project to which DOX made meaningful artistic and organisational contributions;

• and the international funding applications are presented as reflecting genuine collaborative activities between the parties.

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