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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 11 of 45 Page !D #:11 1 Santa Ana were of Latino descent, and of those Latino patients, 80% qualified for Medi- 2 Cal with incomes either below, or no higher than 138% of the Federal Poverty Level. In 3 addition, approximately two to five percent of the patients served at SOS's Santa Ana 4 facility were homeless persons. 5 34. On a county-wide basis, including all four of the community health centers 6 run by SOS in Costa Mesa, Santa Ana, Mission Viejo, and Newport Beach, the 7 demographics are similar. Sixty-five percent of SOS's patients county-wide identify as 8 Latino, 55% of its patients are best served in a language other than English, 65% are 9 covered by Medicaid, approximately 10% are homeless, and 72% have family incomes 10 at or below the Federal Poverty Level. 11 35. SOS's clients include patients covered by Medicare, Medi-Cal, and private 12 insurance, as well as uninsured patients who may be low income or homeless, and who 13 often have no way of paying for healthcare services. 14 36. As an FQHC, SOS is mandated by the federal government to operate 15 community based health centers that provide high quality comprehensive medical, 16 dental, and behavioral health services, regardless of a patient's ability to pay. 17 37. Both in the meetings that took place before the second reading of the 18 Permanent Ordinance at the February 7, 2023 Council meeting, and by a letter submitted 19 at that meeting by SOS's representatives, City staff persons, the Mayor, and various 20 councilmembers were expressly apprised of these facts and demographics, including the 21 fact that, in Santa Ana, SOS's patients were predominantly poor persons of Latino 22 ethnicity. 23 38. Moreover, given the fact that SOS had been operating its El Sol Wellness 24 Center on Broadway in Santa Ana for some 14 years as of the time the Ordinances were 11 Complaint of Share Our Selves