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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 22 of 45 Page ID #:22 1 City staff to inform them that Turner and SOS intended to modify their development 2 plans in order to fully comply with all parking requirements. Turner's representative 3 explained that this was being done in order to complete the application process before 4 the PSA expired in February of 2023. She then asked City staff to confirm that, if the 5 remodel project complied with the parking requirements and other zoning and building 6 requirements, the approval of the project would consist of an administrative review by 7 City staff and the use would be:allowed as a matter of right. 8 79. The City replied by e-mail on November 28, 2022, and confinned that the 9 Project "would be subject to administrative review by the Planning Division." A true 10 and correct copy of the email chain including Turner's email of November 17, 2022, and 11 the City's email of November 28, 2022, is attached as Exhibit A hereto 12 80. On December 6, 2022, Turner informed City Staff that it was planning on 13 submitting a Major Remodel Application that complied with the parking requirements 14 by December 22, 2022. 15 81. On December 22, 2022, Turner submitted the plans for their Major 16 Remodel Application in full compliance with the parking requirement (and all other 17 applicable requirements). Turner believed that the Application would quickly be 18 approved on a ministerial basis. 19 D. The City Adopts The Urgency Ordinance To Prevent Purchase And 20 Remodeling Of The Main Street Property By Turner And SOS. 21 82. Once it became known at the City that Turner had resolved the parking 22 issues by reducing the square footage of the Project so that a minor exception was no 23 longer needed and the plans for the Project could be quickly approved, various persons 24 at the City became alarmed that the Project might actually become a reality and, without 22 Complaint of Share Our Selves