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