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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 13 of 45 Page ID #:13 <br /> 1 discriminatory view, the City imposed a CUP requirement on Non-Profit Entities to <br /> 2 ensure that the Planning Commission and City Council would have sufficient <br /> 3 "discretion"to prevent Medical Offices operated by such Entities from conducting <br /> 4 operations within the P District. <br /> 5 41. The question that naturally arises, therefore, is what makes the City believe <br /> 6 that Medical Offices operated by Non-Profit Entities might be "incompatible" with <br /> 7 "surrounding properties and neighborhoods" in the P District, whereas Medical Offices <br /> 8 operated by For-Profit Entities could always be counted on to be "compatible" with such <br /> 9 properties and neighborhoods? <br /> 10 42. Asked another way, when City officials realized that SOS was poised to <br /> 11 relocate its operations to the Main Street Property, why did the City suddenly spring into <br /> 12 action, hurriedly adopt the Urgency Ordinance, and amend its Zoning Code to provide <br /> 13 that Medical Offices operated by Non-Profit Entities are not allowed to operate in the P <br /> 14 District unless and until such Entities (a) undergo a costly and time-consuming <br /> 15 application, review, and public hearing process to seek a conditional use permit <br /> 16 ("CUP"), (b) run the gauntlet of public opposition to the requested CUP, and (c) actually <br /> 17 succeed in obtaining a CUP, which will be of limited duration, will be subject to any <br /> 18 number of onerous conditions and restrictions, and will always be at risk of being <br /> 19 revoked at the City's discretion? <br /> 20 43. There is only one answer to these troubling questions: the distinction that <br /> 21 the City has drawn in the Ordinances between Medical Offices operated by Non-Profit <br /> 22 Entities and those operated by For-Profit Entities is based solely on the City's belief that <br /> 23 1 the former are likely to attract poor Latino persons from Mexico and other countries <br /> 24 outside the United States (immigrants), as well as homeless persons of various races and <br /> 13 <br /> Complaint of Share Our Selves <br />