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8:23-cv-00183-DOC-KES Document 25 Filed 05/09/23 Page 6 of 18 Page ID #:185 <br />1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />"Christian ministry" that follows the teachings of Jesus Christ, and particularly the <br />words of Matthew 25:35-40, which state, "For I was hungry and you gave me something <br />to eat, I was thirsty and you gave me something to drink ..." Id. ¶4. Consistent with <br />this mandate, MW provides charitable services to homeless individuals, including by <br />providing light food and beverages, to persons who come to their Resource Center. Id. <br />¶7. In particular, MW believes it "has a religious duty to help the homeless that come to <br />it ... including by providing a cup of coffee and a muffin if a client is hungry." Id. ¶27. <br />Since early 2016, MW's Resource Center has been located at 1517 East Fourth <br />Street in Santa Ana, California. Compl. ¶51. MW describes this as an "excellent <br />location" because it is only half a mile from the Department of Motor Vehicles <br />("DMV"), facilitating its ID voucher services.' Id. ¶52. MW has paid yearly fees to the <br />City for a business license, but does not have a Certificate of Occupancy ("COO"). Id. <br />¶�10, 54-56. <br />In early 2020, MW began providing snacks and beverages outdoors in response to <br />the COVID-19 pandemic. Compl. �57. Around this same time, a needle exchange <br />program operated by the American Addiction Institute began operations two doors down <br />from MW. The exchange was associated with increased neighborhood complaints of <br />drug use, trespassing, littering, and loitering. Id. ¶158-60, 64-67. <br />In November 2021, the City's mayor received a complaint "begging" him to "do <br />something about the homeless houses" after individuals "dump[ed] trash and bleach" on <br />a local resident's door. Compl. 164. In response, the mayor instructed various city <br />departments "to devise whatever measures they could come up with to compel MW and <br />the Needle Exchange to move out of the 4th Street neighborhood or, at the very least, to <br />severely curtail their operations." Id. �¶67, 68, 74. <br />MW assists homeless persons fill out ID vouchers, which allows them to obtain a free <br />California photo ID from the DMV. MW also assists homeless persons in obtaining <br />birth certificates so that they can qualify for various government benefits, including <br />housing assistance. Compl. ¶52. <br />5 <br />