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Case 8:23-cv-00504 Document 1 Piled 03/20/23 Page 3 of 45 Page ID #:3 <br /> 1 Ana provides no opportunity to expand space for medical services or add other service <br /> 2 lines; and (c) provide a significant increase in the number of medical, dental and <br /> 3 pharmacy internships and residencies for new health professional coming into the field <br /> 4 from UC Irvine, Chapman, UC Southern California, etc., including physicians, nurse <br /> 5 practitioners, physician assistants, nurses, medical assistants, dentists, dental assistants, <br /> 6 and clinical pharmacists. <br /> 7 4. In 2022, SOS and its development partner, Turner Healthcare Facilities <br /> 8 Acquisition LLC ("Turner") [hereinafter, SOS and Turner are sometimes collectively <br /> 9 referred to as "SOS"], incurred at least $500,000 in purchase-related fees and <br /> 10 development costs, in formulating plans to remodel the Main Street Property to serve as <br /> 11 an expanded outpatient clinic to replace SOS's El Sol Wellness Center, located at 1014 <br /> 12 North Broadway in Santa Ana, which SOS has outgrown after faithfully providing <br /> 13 medical and dental care to Santa Ana residents for the past 14 years at that location. <br /> 14 5. Now, all of those purchase and planning expenses have gone to waste as a <br /> 15 result of a carefully-crafted scheme by the City to ,scuttle SOS's plans to purchase and <br /> 16 remodel the Main Street Property, all because City leaders feared that SOS's new <br /> 17 outpatient clinic at the Main Street Property would attract too many "undesirables" to <br /> 18 that area of the City—i.e., financially poor individuals of Latino descent, as well as <br /> 19 homeless persons. <br /> 20 6. In fact, when representatives of SOS first starting previewing SOS's <br /> 21 remodeling plans for the Main Street Property in mid-2022, one of the first changes <br /> 22 requested by the City was that SOS agree not to operate a food pantry at the new <br /> 23 location because it might support the homeless. That was the first indication that the <br /> 24 City was concerned about the "type" of people that SOS's new outpatient clinic would <br /> 3 <br /> Complaint of Share Our Selves <br />