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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 1.0 of 45 Page ID #:10 <br /> 1 of the Ordinances; (b) both Ordinances unlawfully infringe on the fundamental <br /> 2 constitutional rights of association and of privacy and result in a denial of substantive <br /> 3 due process and equal protection; and (c) invidious discrimination was a motivating <br /> 4 factor in the adoption of both Ordinances, resulting in a denial equal protection under <br /> 5 the law. <br /> 6 29. On their face, both Ordinances unlawfully discriminate a aft Non-Profit <br /> 7 Entities, and in favor of entities that seek to make a profit in providing mental or dental <br /> 8 care (collectively, "For-Profit Entities") in connection with operating medical or dental <br /> 9 offices (collectively, "Medical Offices") in the City's P District. <br /> 10 30. In this regard, the Ordinances allow For-Profit Entities to operate Medical <br /> 11 Offices in the P District"by right." In other words, in order to operate such Medical <br /> 12 Offices, For-Profit Entities do not have to submit any permit applications, obtain any <br /> 13 discretionary permits, or face any opposition from members of the public at any hearings <br /> 14 held by the City's Planning Commission or City Council. <br /> 15 31. By sharp contrast, however, the Ordinances treat Non-Profit Entities that <br /> 16 operate Medical Offices in the P District quite differently—not because the doctors, <br /> 17 dentists, or nurses who are employed by such Entities practice medicine or dentistry any <br /> 18 differently than their counterparts employed at Medical Offices operated by For-Profit <br /> 19 Entities, but, rather, because of the characteristics of the people whom the City believes <br /> 20 will be attracted to Medical Offices operated by Non-Profit Entities. <br /> 21 32. For example, people who are homeless, people who are of Hispanic or <br /> 22 Latino (collectively, "Latino") ethnicity, people who are living at or below the Federal <br /> 23 Poverty Level, or people who cannot afford or obtain medical insurance. <br /> 24 33. In 2022, 87% of the patients served at SOS's El Sol Wellness Center in <br /> 10 <br /> Complaint of Share Our Selves <br />