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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 23 of 45 Page ID #:23 1 telling Turner or SOS, began formulating plans to prevent the Project from going 2 forward. The plan they devised, and proceeded to conceal from Turner and SOS, 3 involved adding language to an omnibus amendment to the Zoning Code that had been 4 floating around for months at the City. 5 83. Indeed, months earlier, at a meeting of the City's Planning Commission 6 held on September 26, 2022, consideration of proposed omnibus Zoning Ordinance 7 Amendment 2022-03 (the "Proposed Omnibus Amendment") was placed on the agenda. 8 This Proposed Omnibus Amendment to the Zoning Code was the precursor to what 9 would ultimately be adopted by the City Council as the Permanent Ordinance on 10 February 7, 2023. 11 84. However, as of the September 2022 timeframe, the Proposed Omnibus 12 Amendment did not include any provisions requiring CUPs for Medical Offices in the P 13 District that are operated by government, government-subsidized, not-for-profit, or 14 philanthropic entities (previously defined hereinabove as "Non-Profit Entities"). 15 85. Moreover, as of the December 2022 timeframe, there was nothing pressing 16 or urgent about adopting the Proposed Omnibus Amendment, given that it had been 17 taken off calendar at the September 26, 2022 meeting without discussion by the 18 Planning Commission, and had been allowed to languish for nearly three months until it 19 had been rescheduled for hearing on December 12, 2022. 20 86. The public notice for the Proposed Omnibus Amendment to be considered 21 at the December 12, 2022 Planning Commission meeting was published on November 22 29, 2022, and no mention whatsoever about imposing any CUP requirements on Non- 23 Profit Entities that sought to operate any Medical Offices in the P District. 24 87. Ncvertheless, despite this blatant lack of public notice, and without any _ 23 Complaint of Share Our Selves