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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 6 of 45 Page ID#:6 1 for-profit, or philanthropic entities" to operate anywhere within the City's Professional 2 zoning district (the "P District") unless and until such "entities" obtained a discretionary 3 permit—i.e., a CUP. 4 14. The Planning Commission quickly recommended approval of this new CUP 5 requirement and sent the matter on the City Council to take action on its 6 recommendation. No one at the City took any steps to directly inform SOS, either 7 before or after the Planning Commission meeting, that the City was going to amend its 8 Zoning Code to require SOS to obtain a CUP before its Project could get underway. In 9 fact, the public notice for the omnibus zoning amendment that was to be considered at 10 the Planning Commission's December 12, 2022 meeting contained no reference to the 11 new provisions relating to medical offices in the P District that were actually considered 12 and approved at that meeting. 13 15. On December 20, 2022, obviously concerned that it needed to act swiftly to 14 bring a halt to SOS's Project before it could be approved by staff, the City Council---- 15 without providing any notice to the public at large or any direct notice to SOS, itself- 16 adopted an ur_ gency ordinance, i.e., Zoning Ordinance Amendment No. 2022-07 (the 17 "Urgency Ordinance") 18 16. The Urgency Ordinance immediately imposed a new CUP requirement that 19 would apply to any medical offices operated in the P District by any "government, 20 government-subsidized, not-for-profit, or philanthropic entities" (hereinafter, 21 collectively referred to as "Non-Profit Entities"). 22 17. Two days later, on December 22, 2022, SOS, completely unaware that the 23 Urgency Ordinance had been adopted by the City Council, submitted its major remodel 24 application for the Project, expecting that it would be subject to staff review only and 6 Complaint of Share Our Selves