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Case DE Document 158 Filed 04/26/18 Page 7 of 27 Page ID #:2485 I JURISDICTION AND VENUE 2 42. The Court has jurisdiction over this action because the claims alleged 3 herein arise out of the transactions and occurrences that are the subject matter of the 4 original action. 5 43. Venue is proper in this Court under 28 U.S.C. section 1391(b) because 6 a substantial part of the events or omissions giving rise to the claims occurred in 7 this district. 8 FACTUAL ALLEGATIONS 9 BACKGROUND 10 44. The City of Santa Ana has a population of approximately 341,000 and 11 covers 27 square miles. It is ethnically diverse and boasts an ethnic make-up as 12 follows: 78% Hispanic, 10% Asian, 9% White, and other ethnicities in smaller 13 percentages. The average median income in Santa Ana is approximately $54,500, 14 as compared to the median income in Orange County of $75,400. Santa Ana has 15 the highest Hispanic population in the County and is one of the lowest income 16 cities in the County. (See, Exhibit `B" & "C".) 17 45. For decades, Santa Ana has borne the largest and most inequitable 18 burden of addressing and relieving homelessness in Orange County, whether by 19 providing necessary, related services on its own or by hosting the provision of such 20 services by the County and third parties within its borders. 21 HOMELESS STATISTICS 22 46. In 2017, there were a total of 2,584 unsheltered homeless individuals 23 and an additional 2,208 sheltered individuals, for a total 4,792 homeless individuals 24 in Orange County. (See, Exhibit "A".) On March 30, 2018, Andrew Do, the 25 Chairman of the Board of Supervisors, reported at a Special Meeting of the City 26 Council of the City of Santa Ana that in 2017, Santa Ana alone had 466 unsheltered 27 homeless individuals, which was the highest number in the County. In comparison, 28 Santa Ana had 100 more such individuals than Anaheim. Of the cities identified by