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Case 8:23-cv-00504 Document I Filed 03/20/23 Page 12 of 45 Page ID #:12 1 adopted, it was common knowledge that SOS's patient base in Santa Ana consisted 2 mainly of poor Latino persons, whose national origin was the U.S., Mexico, or countries 3 outside the U.S. (e.g., immigrants). And those individuals, as well as homeless persons, 4 were precisely the "kind of people" that the City's councilmembers and staff feared 5 would be attracted to SOS's proposed new facility near the Main Place Mall if SOS's 6 major remodel application were approved by staff and SOS was able to timely close 7 escrow on the Main Street Property. 8 39. One of the findings set forth in the Urgency Ordinance reveals the City's 9 true discriminatory intent in requiring Non-Profit Entities to obtain a CUP in order to 10 operate Medical Offices in the City's P District—while exempting Far-Profit Entities 11 from that same requirement: 12 WBEREAS, the absence of a conditional use permit requirement for 13 medical offices operated by government, government-subsidized, not-for- 14 profit, or philanthropic entities is inconsistent with the goals expressed by 15 SAMC Section 4 1-1 (Purpose) in that discretion by the Planning 16 Commission and Citv Council cannot be exercised to ensure that the 17 location and operation of such facilities are compatible with the scale 18 character, and nature of surrounding properties and neighborhoods as 19 specified in SAMC sections 41-1. (a), (b), (e), and (f). 20 40. The "code words" embedded in the above-quoted finding unmask the 21 City's biased belief that, while Medical Offices operated by For-Profit Entities would 22 always be "compatible" with the "character" of"surrounding properties and 23 neighborhoods" in the P District, the same would not be true, as the City sees it, for 24 Medical Offices operated by Non-Profit Entities. Motivated by this highly- 12 Complaint of Share Our Selves