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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 21 of 45 Page ID #:21 1 also in contact the City to begin the process of obtaining the necessary approvals for the 2 Project. 3 C. Attempts By Turner And SOS To Develop The Main Street Property 4 Run Into Resistance From City Staff. 5 74. At the time the PSA was executed, Medical and dental offices were 6 permitted as a matter of right in the P District in which the Main Street Property is 7 located, and there were no restrictions regarding the entities that could operate such 8 offices. Accordingly, the primary entitlements necessary were a building permit and 9 approval of a major commercial remodel application (the "Major Remodel 10 Application"). Also, the original plans for the Main Street Property required a minor 11 exception to reduce the off-street parking requirements for the site, and to permit tandem 12 parking. 13 75. Turner submitted the materials supporting its application for the minor 14 exception to the City on August 30, 2023. Those materials included a project 15 description, which stated that "Share Our Selves Corporation, a non-profit, Federally 16 Qualified Health Center providing healthcare services to the general public regardless of 17 insurance status or ability to pay, would operate the first- and second-floor medical 18 offices." 19 76. The City denied the minor exception application on October 27, 2022. 20 77. While Turner and SOS initially planned on appealing the denial of the 21 minor exception, they eventually decided that simply altering the plans for the remodel 22 to decrease floor space and increase parking space in order to fully comply with the 23 City's parking requirements might be a better course of action. 24 78. Accordingly, on November 17, 2022, Turner's representative contacted 21 Complaint of Share Our Selves