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Law Offices of <br />KENT G. SNYDER <br />ATTORNEY AT LAW <br />KENT G. SNYDER 2301DUPONT DRIVE, SUITE 430 (949) 833-9078 <br />KATHLEEN A. KELLY IRVINE, CALIFORNIA 92612 Fax: (949) 833-8209 <br />kent@kentsnyderlaw.com kathleen@kentsnyderlaw.com <br />August 8, 2023 <br />Ms. Sonia R. Carvalho <br />City Attorney, City of Santa Ana <br />22 Civic Center Plaza <br />Santa Ana, California 92701 <br />Re: Agenda Item for Vacation of Alley In Floral Park between 2383 N Flower and 2379 N <br />Flower Street, Santa Ana, CA <br />Dear Ms. Carvalho: <br />I have been engaged by two of the residents of Floral Park to represent them in the above -subject <br />matter which comes before the City Council on August 15, 2023. My clients are Irene Myers of 2393 <br />N. Flower Street, and Cheryl Newton of 2379 N. Flower Street. My clients oppose the Application. <br />I am writing to you about an error in the Application. The error is in the Title Guarantee issued by <br />Chicago Title Company. Attached to this letter please find a copy of an email between Colin Donnelly <br />and the Title Company dated November 16, 2022 at the time the first draft of the Title Report <br />Guarantee was issued. <br />My observations of this email reveal: <br />1) The Title Officer was correct in the first draft that he produced of the Title Report Guarantee <br />in that he included item 6 which says "the rights of the public to use that portion of the alley <br />adjoining said lot 57 on the south, until such time said alley is vacated to the Public by the <br />City of Santa Ana. <br />2) The Title Officer was correct in the above statement because this is a dedicated roadway as <br />stated in the language in the upper right-hand corner of the recorded map for Tract 754 <br />which was recorded in 1925 and it says that all streets and roadways are dedicated for public <br />use. The alley fits within this category. <br />3) The alley was dedicated to the City for the use by the Public in fee simple absolute. It was <br />not then, has never been, and is not now any portion of Lot 57. Lot 57 lies contiguous to the <br />alley, but three other lots also lie contiguous to the alley. Ms. Newton's lot, plus two lots <br />which front onto Heliotrope. Mr. Donnelly intentionally suborned the Title Officer to state in <br />