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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 5 of 45 Page 1D #:5 <br /> 1 "administrative." In other words, the Project would not require any discretionary <br /> 2 permits and would simply "be subject to administrative review by the Planning <br /> 3 Division." Importantly, in its e-mail, the Planning Division did not dispute the fact that, <br /> 4. if SOS acquired the Main Street Property, it would have a"right"to operate a medical <br /> 5 office at that location without the need for any discretionary permits, such as a <br /> 6 conditional use permit ("CUP"), for example. <br /> 7 11. Unbeknownst to SOS, which had been assured in writing by the City's <br /> 8 Planning Division that the plans for the Project would only require a ministerial <br /> 9 approval following an administrative review by City staff,there were other persons at <br /> 10 the City, including various councilmembers, the City Manager and members of her staff, <br /> 11 as well as the City Attorney and members of her office, who—armed with the <br /> 12 knowledge that SOS's extension of time to close escrow on the its purchase of the Main <br /> 13 Street Property was going to expire in February 2023--started working behind the <br /> 14 scenes to kill the Project by making it impossible for SOS to purchase the Main Street <br /> 15 Property before SOS's time to do so expired. <br /> 16 12. As explained below in greater detail, at the December 12, 2022 meeting of <br /> 17 the City's Planning Commission, which was held a mere two weeks after the Planning <br /> 18 Division had sent its e-mail to SOS, assuring SOS that the Project would only be subject <br /> 19 to an administrative review by City staff, an omnibus amendment to various provisions <br /> 20 of the City's Zoning Code—an earlier earlier version of which had been initially been <br /> 21 considered by the Planning Commission in September 2022 without taking any action <br /> 22 on it----was presented.to the Commission for a second review. <br /> 23 13. However, this time, the amendment suddenly contained provisions that <br /> 24 would not allow "medical offices operated by government, government subsidized, not- <br /> 5 <br /> Complaint of Share Our Selves <br />