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Sonia Carvalho, Santa Ana City Attorney 00�?®®� are binding on the City and limit the City's jurisdiction at the hearing. Before filing suit,Kingsley provided detailed written notice for each hearing identifying the specific provisions at issue, and its objections to the Ordinances were directed to those provisions, not to rent control itself, Kingsley acknowledged in writing to the City and in the Pleadings the City's authority to adopt a lawful rent control ordinance. Kingsley also sought to negotiate before and during the litigation to avoid the time and expense of court proceedings, including requesting a stay after the first amendment to allow discussions; that request was denied, requiring Kingsley to either file to preserve its rights or forgo them. Ultimately, the City amended and readopted the Ordinances in ways that addressed many of the issues raised in the Complaints (previously presented at the hearings considering the Ordinances) rendering those sections of the Complaints moot. In short, Kingsley did sue the City twice, but both matters could have been avoided had the Ordinance initially complied with state and federal law. From Kingsley's perspective, the City was difficult to work with, declined to meet to discuss the issues, and did not engage meaningfully in settlement discussions but did amend the Complaints. The City acknowledged the illegal and conflicting provisions effectively resolving those issues through the amendments thereby making sections of the litigation moot confirming Kingsley's position was correct. Kingsley is a privately owned company, not a public or large corporate entity. Its ownership structure supports a community-focused approach that considers residents' interests, and the employees and vendors interests. Kingsley complies with laws governing mobilehome park communities and,like all park owners, is required to comply with the Mobilehome Residency Law and with the Mobilehome Park Act and related regulations to enforce Title 25. The records for the residents who are contesting their evictions will substantiate Kingsley's compliance. Your statement that you will "make sure the management company complies" suggests you believe Kingsley did not comply. With due respect, the request is the comments that were made as set forth above or similar comments not be repeated and as the opportunity presents itself, are corrected. Looking forward to sharing with you and your office a positive and beneficial relationship for all concerned with the Mobilehome Park Communities. Sincerely, L. Sue Loftin, Esq. 6965 El Camino Real, 4105-599, Carlsbad, CA 92009 • (760) 607-7340 • sue@lsloftin.com