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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 18 of 45 Page ID #18 1 must provide cradle to grave primary care services and must accept all patients 2 regardless of insurance status or ability to pay. FQHCs are also required to establish 3 "sliding scale" fees for uninsured patients based on an assessment of the patient's 4 income relative to federally adjusted poverty line which takes into consideration the size 5 of the individual's household among other factors. FQHCs are mandated to charge at 6 least a"nominal fee" regardless of how low an individual's income may be. 7 B. SOS And Turner Agree To Develop Medical Offices At The Main 8 Street Property. 9 60. SOS currently operates medical offices in four locations across Orange 10 County, California. One of those offices, the SOS El Sol Wellness Center, is located at 11 1014 N. Broadway, in Santa Ana, California (the "North Broadway Office"). 12 61. SOS has outgrown the North Broadway Office, and needs more space to 13 expand its operations. 14 62. Accordingly, in the fall of 2021, SOS and Turner began looking for a larger 15 building that could house a new medical office to replace the North Broadway Office, 16 based on an understanding that Turner would purchase the building, and SOS would 17 lease the building from Turner with the option to purchase the Main Street Property at 18 year four of the lease. 19 63. Turner is an investment company that invests in under-resourced 20 communities, and builds healthcare facilities on its properties. Turner then leases those 21 facilities to healthcare providers to serve those under-resourced communities. 22 64. Eventually, SOS and Turner found the Main Street Property, located at 23 2670 N. Main Street. The Property consists of a 1.44 acre parcel of land, with an 24 existing office building of approximately 44,000 square feet. The Main Street Property 18 Complaint of Share Our Selves