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I Petitioner and Plaintiff, Santa Ana Short-Term Rental Alliance (the "Rental Alliance" or <br /> 2 "Petitioner"), hereby petitions for a writ of mandate and brings a complaint for injunctive and <br /> 3 declaratory relief and for attorneys' fees against Respondents and Defendants the City of Santa <br /> 4 Ana (the "City" or "Santa Ana"), and alleges as follows. <br /> 5 INTRODUCTION <br /> 6 1. The Rental Alliance is an unincorporated community association made up of hard- <br /> 7 working residents of both the City of Santa Ana and Southern California that own and or manage <br /> 8 homes located within City limits rented on a short-term basis. The members of the Rental Alliance <br /> 9 come from diverse backgrounds and call California home. However, the City unlawfully enacted <br /> 10 an ordinance banning short-term rentals ("STRs") in the City with almost no public notice and <br /> 11 without undertaking the environmental review required by the California Environmental Quality <br /> 12 Act ("CEQA"). The STR Ban is extreme. It not only completely prohibits any STR throughout <br /> 13 the entire city, it also exceeds the boundaries and fundamental tenets of what is reasonable and <br /> 14 permissible government regulation under common law and the California and United States <br /> 15 Constitutions. <br /> 16 2. The Rental Alliance brings this action on behalf of its members and others who rent <br /> 17 homes they own, or work with other homeowners to manage, on a short -term basis, meaning for <br /> 18 terms of less than 31 days. The Rental Alliance hosts renters in need of housing accommodations <br /> 19 for less than the typical twelve month lease term sought by traditional landlords. Until adoption <br /> 20 of the STR Ban at issue in this Petition, hosts rented homes on a short-term basis to obtain critical <br /> 21 income for themselves and their families. <br /> 22 3. Abruptly, and initially on an emergency basis with virtually no public notice or <br /> 23 environmental review, and in contravention of the longstanding practice and economic <br /> 24 expectations of these hosts, the City enacted the STR Ban, thereby preventing hosts from <br /> 25 continuing to earn income from STRs. <br /> 26 3. In particular, the City has enacted unsupported, unlawful, and unconstitutional <br /> 27 ordinances which immediately criminalizes hosts from renting homes on a short-term basis. This <br /> 28 action challenges this decision. <br /> VERTFTED PETTTTON FOR WRTT OF MANDATE <br /> AND COMPLATNT <br /> 2 <br />