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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 35 of 45 Page ID #:35 1 that District. 2 139. This pretextual justification was designed to disguise the City's 3 discriminatory motive, by making it appear that the City was expanding the rights of 4 Non-Profit Entities when, in fact, it was unlawfully restricting them as a result of animus 5 towards the type of patients who typically visit Medical Offices operated by Non-Profit 6 Entities. 7 140. There is no governmental interest that justifies the City's discriminatory 8 conduct as alleged herein, and such actions on the part of the City truly shock the 9 conscience, because they are intended to injure and exclude people who are homeless, 10 low-income, immigrant, and Latino, as well as the charitable organizations that provide 11 these individuals with medical care. 12 141. California law prohibits local governments from engaging indiscrimination 13 based on race, national origin, immigration status, or wealth. In its February 6, 2023 14 letter to the Mayor and the City Council, which was hand-delivered to the City Clerk at 15 the outset of the February 7, 2023 meeting of the City Council, SOS explained the 16 discriminatory and unlawful nature of the Permanent Ordinance. 17 142. After the letter was delivered, the meeting was then delayed for almost 90 18 minutes as the Mayor and councilmembers remained in closed session, apparently to 19 watch President Biden's State of the Union address on TV. The letter--which the 20 Mayor, councilmembers, and. City Attorney had adequate time to read, and did read 21 based on and the statements that the City Attorney made later in the meeting—and the 22 remarks that the representatives of SOS and Turner addressed to the Mayor and 23 councilmembers during the public comment segment of the meeting, provided the City 24 with an opportunity to reflect and make reasoned and rational decisions, eliminating any 35 Complaint of Share Our Selves