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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 2 of 45 Page ID #:2 <br /> 1 For a Complaint against Defendants and Respondents City of Santa Ana (the <br /> 2 "City"), and DOES 1 through 10, inclusive (collectively, "Defendants"), Plaintiff and <br /> 3 Petitioner Share Our Selves Corporation ("SOS" or "Plaintiff') alleges as follows: <br /> Ie SUMMARY OF COMPLAINT <br /> 4 <br /> S 1. As part of an orchestrated campaign to use the City's land use regulations <br /> 6 to thwart and obstruct the operations of charitable organizations, like Micah's Way and <br /> 7 the Salvation Army, who try to provide much-needed services to poor and homeless <br /> persons residing in Santa Ana, the City has recently adopted two zoning ordinances that <br /> 9 unabashedly—and unlawfully—discriminate against non-profit medical and dental <br /> 10 offices and the patients that they serve. <br /> 11 2. SOS, whose mission, as a Federally Qualified Health Center ("FQHC"), is <br /> 12 to provide medical and dental care to the underserved residents of Santa Ana, including <br /> 13 poor and homeless persons, has been sorely victimized by the City's illegal <br /> 14 discrimination in adopting these ordinances. Indeed, the City's unlawful actions have <br /> 15 prevented SOS from closing escrow on a three-story, 44,000 SF commercial office <br /> 16 building, located at 2670 North Main Street in Santa Ana (the "Main Street Property" or <br /> 17 the "Property"), a block south of the Main Place Mall. That building was the only one <br /> 1$ in Santa Ana that met SOS's needs to establish an expanded outpatient clinic. <br /> 19 3. As alleged in greater detail below, the City's discriminatory conduct has <br /> 20 caused SOS to lose the opportunity to use the Main Street Property to (a) meet the <br /> 21 growing demand for health services in the Santa Ana community; (b) expand SOS's <br /> 22 ability to serve more individuals in the community that are not currently able to obtain <br /> affordable care, while also expanding the services available at the new location to <br /> 23 <br /> 24 include dental, pharmacy and vision services, given that SOS's current location in Santa <br /> 2 <br /> Complaint of Share Our Selves <br />