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<br />1iv.An award of such other and further relief as the court deems just and <br /> <br />2 proper. <br /> <br />3 4. For the Fourth Cause of Action for Declaratory and Injunctive Relief for <br /> <br />4 Violation of Due Process: <br /> <br />5 i. A declaration finding that STRs were permitted under the Santa Ana <br /> <br />6 zoning code as it existed prior to adoption of Ordinance No. NS-3061, <br /> <br />7 and thus, that STRs are a legal nonconforming use under the Santa Ana <br /> <br />8 zoning code as amended by Ordinance No. NS-3061; <br /> <br />9 ii. An injunction restraining the City and its agents, servants, and <br /> <br />10 employees, and all others acting in concert with the City, from taking <br /> <br />11 any action to implement Ordinance No. NS-306 and a permanent <br /> <br />12 injunction setting aside Ordinance No. NS-3061 and holding unlawful <br /> <br />13 Ordinance No. NS-3061; <br /> <br />14 iii. An award of costs of suit and litigation expenses, including, without <br /> <br />15 <br /> <br />16 law; and/or <br /> <br />17 iv. An award of such other and further relief as the court deems just and <br /> <br />18 proper. <br /> <br />19 5. For the Fifth Cause of Action for a Writ of Mandate Due to Abuse of Discretion: <br /> <br />20 i. A writ of mandate directing the City to rescind and set aside its approval <br /> <br />21 of Ordinance No. NS-3061 and to undertake the required review of the <br /> <br />22 relevant law and evidence; <br /> <br />23 ii. An injunction restraining the City and its agents, servants, and <br /> <br />24 employees, and all others acting in concert with the City, from taking <br /> <br />25 any action to implement the Ordinance No. NS-3061 pending a review <br /> <br />26 of all applicable law and facts; <br /> <br />27 <br /> <br />28 <br /> <br /> <br /> <br /> VERIFIED PETITION FOR WRIT OF MANDATE <br />AND COMPLAINT <br />27 <br /> <br /> <br />