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2107 N. Broadway, gulte 106 Santa Ana, CA b BLAKE 6 AYAZ <br />July 5, 2023 <br />Delivered in Person <br />Jennifer L. Hall <br />Santa Ana City Clerk <br />20 Civic Center Plaza, M-30 <br />Santa Ana, CA 92701 <br />3 <br />Re: GROUNDS FOR APPEAL <br />Conditional Use Permit No. 2019-41-MOD-1 and Conditional Use Permit No. <br />2023-03 <br />Ms. Hall: <br />Please allow this correspondence to set forth some of the grounds to appeal the decision made by <br />the Planning Commission at its scheduled hearing on June 26, 2023 with regard to the above <br />entitled matter. <br />GROUNDS TO APPEAL <br />1) Findings cannot no do support the decision of the planning commission; 2) Facts relied upon <br />by the decision body are not supported in the record 3) The manner in which the hearing was <br />conducted along with the actions of several planning commissioner violated the law, to include <br />but not in any way limited to the applicants constitutional rights, the Brown Act, the Santa Ana <br />Municipal code and various legal and binding precedents of the state and federal courts; 4) Grave <br />procedural errors including but not limited to requiring applicant to file an appeal without <br />providing a written determination of the city's decision, to include factual analysis and/or findings; <br />5) Decisions was not based on land use principals or laws; 6) The planning commissioners failed <br />to consider applicant's testimony and evidence, rather they had made up their minds well before <br />the hearing even took place; 7) Planning Commission failed their duty in remaining neutral and <br />unbiased in the decision making; 8) There was no evidence either substantial or circumstantial <br />provided at the hearing to support the Planning Commission's decision to deny applicants <br />application; 8) and any other grounds based on review of the entirety of the record to include, <br />