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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 8 of 45 Page ID #:8 1 Mayor, various councilmembers, and staff persons to plead SOS's case in requesting 2 that the new CUP requirement either be eliminated or be deemed inapplicable to the 3 Project. 4 22. SOS's representatives also appeared at the Council's February 7t' meeting 5 for the second reading of the Permanent, submitted a letter of objections to the City 6 Clerk, and, during the public comment segment of the meeting, implored the Mayor and 7 the Council to reopen the public hearing on the Permanent Ordinance and allow them to 8 explain why that Ordinance was ill-advised and unlawful, and should not be approved. 9 23. One of the arguments advanced by the representatives of SOS, both before 10 and at the February 7t' Council meeting, was that the seller of the Main Street Property 11 was not willing to further extend the escrow on SOS's purchase of the Property and, as 12 such, if the Project were not exempted from the new CUP requirement, SOS would lose 13 the Property, the Project would be stopped dead in its tracks, and Santa Ana would lose 14 the valuable benefits associated with a remodeling project that would bring $34 million 15 in construction jobs and resources into the City and would generate at least 120 16 permanent jobs at the new clinic to provide medical and dental care to the City's 17 residents. 18 24. Ironically, however, SOS's pleas about how it was going to lose the right to 19 purchase the Main Street Property if the CUP requirement remained in place turned out 20 to be music to the ears of those councilmembers, city staff persons, and members of the 21 City Attorney's office who had planned all along to stymie the Project by imposing the 22 CUP requirement on SOS, knowing full well that it would make it impossible for SOS to 23 close escrow on the Main Street Property before the due diligence period expired in 24 February 2023. _ 8 Complaint of Share Our Selves