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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 44 of 45 Page ID #:44 <br /> 1 65858(a). <br /> 2 177. SOS desires a declaration as to both the expiration of the Urgency <br /> 3 Ordinance, and the City's obligation to comply with the expiration period set forth in <br /> 4 Government Code section 65858(a) when enacting urgency ordinances that prohibit and <br /> 5 restrict land uses in the future. A judicial declaration is necessary and appropriate at this <br /> 6 time so that the parties may ascertain their respective rights and duties with respect to <br /> 7 the City's Urgency Ordinance and similar ordinances in the future. Without such a <br /> 8 declaration, the City will continue to pass urgency ordinances, and take the unlawful <br /> 9 position that the ordinances do not expire in accordance with California law. <br /> 10 WHEREFORE, Plaintiff prays for relief and judgment as follows: <br /> 11 For the First and Second Claims for Relief, an award of compensatory damages <br /> in an amount to be determined according to proof at trial, but in no event less than <br /> 12 <br /> $500,000. <br /> 13 For the First through Fifth Claims for Relief, appropriate declaratory and <br /> 14- injunctive relief, as prayed for above. <br /> 15 For the Sixth Claim for Relief, a writ of mandate as prayed for above. <br /> 16 For the Seventh Claim for Relief, appropriate declaratory relief as prayed for <br /> 17 above. <br /> For costs of suit and attorney's fees incurred by Plaintiff herein; and <br /> 18 <br /> For such other and further relief as the Court may deem just and proper. <br /> 19 <br /> DATED: March 20, 2023 CONNOR, CH ER & HEDENK MP LLP <br /> 20 <br /> 21 By: <br /> Ed o d M. Connor <br /> 22 AlWheys for Plaintiff Share Our Selves <br /> Corporation <br /> 23 <br /> 24 <br /> 44 <br /> Complaint of Share Our Selves <br />