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1 13. Third, the City disregarded clear case law from the Court of Appeal to determine <br /> 2 that existing STRs in the City were prohibited based on the City's "permissive [zoning] <br /> 3 ordinance." <br /> 4 14. In one fell swoop, on April 16, 2024, the City destroyed livelihoods and threatened <br /> 5 housing security, closed the door to Santa Ana for countless would-be visitors, and <br /> 6 disproportionately affected the individuals and families most in need of flexible housing options <br /> 7 and who are often shut out of the long-term residential housing market. <br /> 8 15. The City's actions here are not just bad government and bad policy, they are <br /> 9 contrary to law, and for the reasons set forth below, the STR Ban must be rescinded. <br /> 10 PARTIES <br /> 11 16. Petitioner Santa Ana Short-Term Rental Alliance (the "Rental Alliance") is an <br /> 12 unincorporated association whose members include individuals and entities who owned and/or <br /> 13 operated STRs in Santa Ana prior to the adoption of the Emergency Ordinance and Ordinance No. <br /> 14 NS-3061 and who are concerned with the environmental impacts of the STR Ban at issue in this <br /> 15 petition upon their properties and the surrounding community. <br /> 16 17. The City of Santa Ana is a charter city formed under the laws of the State of <br /> 17 California. <br /> 18 JURISDICTION AND VENUE <br /> 19 18. This Court has jurisdiction over this action pursuant to California Constitution Art. <br /> 20 6, section 10; sections 1085, 1060 and 187 of the California Code of Civil Procedure; and sections <br /> 21 21167, 21167.5, and 21168.5 of the California Public Resources Code. <br /> 22 19. Venue is proper in Orange County Superior Court. Ordinance No. NS-3061 <br /> 23 regulates land use regarding STRs within the City of Santa Ana. Section 392 of the Code of Civil <br /> 24 Procedure makes venue in this Court proper because the case involves interests in, and injuries to, <br /> 25 real property that is in Orange County. The City of Santa Ana is located in Orange County. An <br /> 26 action or proceeding against a city may be tried in the county in which the city is situated. Cal. <br /> 27 Code Civ. Proc. § 394(a). <br /> 28 <br /> VERTFTED PETTTTON FOR WRTT OF MANDATE <br /> 6 AND COMPLATNT <br />