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<br />1iii.An award of costs of suit and litigation expenses, including, without <br /> <br />2 <br /> <br />3 law; and/or <br /> <br />4 iv. An award of such other and further relief as the court deems just and <br /> <br />5 proper. <br /> <br />6 2. For the Second Cause of Action for Declaratory Relief for Violation of CEQA: <br /> <br />7 i. A declaration finding that Ordinance No. NS-3061 is <br /> <br />8 CEQA and that the City violated CEQA by failing to perform <br /> <br />9 environmental review prior to passing Ordinance No. NS-3061; <br /> <br />10 ii. An award of costs of suit and litigation expenses, including, without <br /> <br />11 <br /> <br />12 law; and/or <br /> <br />13 iii. An award of such other and further relief as the court deems just and <br /> <br />14 proper. <br /> <br />15 3. For the Third Cause of Action for Declaratory and Injunctive Relief for <br /> <br />16 Violation of California Common Law Regarding Nonconforming Use: <br /> <br />17 i. A declaration finding that STRs were permitted under the Santa Ana <br /> <br />18 zoning code as it existed prior to adoption of Ordinance No. NS-3061, <br /> <br />19 and thus, that STRs are a legal nonconforming use under the Santa Ana <br /> <br />20 zoning code as amended by Ordinance No. NS-3061; <br /> <br />21 ii. An injunction restraining the City and its agents, servants, and <br /> <br />22 employees, and all others acting in concert with the City, from taking <br /> <br />23 any action to implement Ordinance No. NS-306 and a permanent <br /> <br />24 injunction setting aside Ordinance No. NS-3061 and holding unlawful <br /> <br />25 Ordinance No. NS-3061; <br /> <br />26 iii. An award of costs of suit and litigation expenses, including, without <br /> <br />27 <br /> <br />28 law; and/or <br /> <br /> <br /> <br /> VERIFIED PETITION FOR WRIT OF MANDATE <br />AND COMPLAINT <br />26 <br /> <br /> <br />