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Case 8:23-cv-00504 Document 1 Filed 03/20/23 Page 31 of 45 Page 1D #:31 1 and finally rejected by the City in Exhibits E and F, hereto. 2 123. SOS was prevented and excused from appearing at the first reading of the 3 Permanent Ordinance because notice of that hearing was defective under California 4 Government Code section 65094. 5 124. Specifically, the notice did not reference the Planning Commission's 6 recommendation regarding the Ordinance as required by law, did not provide any hint or 7 suggestion that government subsidized, non-profit, and philanthropic medical offices 8 were going to be treated differently than all other medical offices, and, most importantly, 9 the notice did not indicate that applications that had been duly submitted before the 10 Permanent Ordinance took effect (such as SOS's) were not going to be grandfatbered in 11 and exempted from the CUP Requirement. 12 1. Standing. 13 125. SOS has standing to bring this Action on behalf of itself for injuries to its 14 own rights as set forth below. SOS also has standing to assert Turner's claims by virtue 15 of Turner's assignment of all of its claims and causes of action to SOS. A true and 16 correct copy of the Assignment of Claims Agreement between Turner and SOS is 17 attached hereto as Exhibit H. 18 126. In addition, SOS has organizational standing to bring suit on behalf of its 19 staff of doctors, nurses, and other health care providers, because (1) those staff members 20 would have standing to sue on their own right, (2) the interests this Action seeks to 21 vindicate are germane to SOS's purpose, and (3) neither the claim asserted nor the relief 22 requested requires the participation of individual staff members in the lawsuit. 23 127. Finally, SOS also has standing to assert claims for discrimination and 24 violation of the rights of its patients for two reasons. First, SOS is asserting claims 31 Complaint of Share Our Selves