HomeMy WebLinkAboutCORRESPONDENCE - CLOSED SESSION 1BCS-16
City Council Meeting Correspondence
10/1/2019
1.CONFERENCE WITH LEGAL COUNSEL - EXISTING LITIGATION - B.City of Santa Ana v. County of
Orange, et al., (Cross -Complaint), U.S. District Court (Central District of California), Case No. SA CV 18-
0155-DOC (KESx)
Date of Name
Correspondence
1011/2019 Tim Johnson
*RA - Recommended Action
Representative of In Favor In Opposition Comment
of RA*. of RA.*
Sub -total•
TOTAL:
Yes
Tuesday, October 01, 2019 Page 1 of 1
Lopez, Kenia
From: Tim Johnson <
Sent: Tuesday, October 01, 2019 7:24 AM
To: eComment
Cc: Pulido, Miguel; Sarmiento, Vicente; Penaloza, David; Iglesias, Cecilia; Solorio, Jose;
Villegas, Juan; Ridge, Kristine
Subject: 1 B- Cross Complaint
Attachments: 158- Santa Ana Cross Complaint suing other OC Cities dtd 4.26.18.pdf; 246- SA ANA
Orange Tustin Stip to extend response date to SA Suit dtd 7..... pdf; 232- SA ANA Orange
Tustin Stip to extend response date to SA Suit dtd 5..... pdf
Mayor, Council, and CM Ridge ... As in each of your prior closed sessions, you have the city's cross complaint in the
Catholic Worker case agendized on tonight's closed session (item 113). Obviously, with the settlement also before you on
agenda item 25H, this is ultimately very important. As I have suggested in the past, I believe that the council is not
staying true to what it voted on in April of 2018 when it chose, after public discussion, to sue the other cities in Orange
County, and the county itself, over the impact of homelessness in our community of Santa Ana. Despite voting to
proceed with litigation, the city decided only to serve 3 cities (Orange, Tustin, Anaheim) and the county. Subsequently,
the cities have been released due to prior settlements in the Catholic Worker case and only the county remains. By not
serving the other cities, I believe that the city is allowing South County cities to continue to do what they have been
doing which is to continue to disproportionately impact our city with quality of life issues as well as fiscal obligations. It
has been 15 months since the city council voted to proceed with litigation yet no service of the suite on any South
County city has occurred. It is time for the council to follow through on its vote to sue or to have a public discussion in
an open forum on its decision not to proceed.
There likely are reasons for the council to not follow through on its prior vote ... some of those reasons may be valid while
others may not be in the public's eye, but the residents and businesses have a desire to know what is going on.
Additionally, the city has chosen to delay indefinitely the responses from the county in the case. So essentially, we have
spent the time and resources to prepare the suit, serve 4 jurisdictions, not serve any of the South County cities, released
3 of the cities (likely rightfully so) and even chosen to allow the one jurisdictions that was served, and not released, to
not even respond to the lawsuit. The timeline for these matters is as follows:
• April 25, 2018: During Closed Session, city council voted unanimously (6-0, 1 absent) to file a cross complaint
against all cities in Orange County and the County of Orange over the impact of homelessness in our city of
Santa Ana
• April 26, 2018: The filing actually happened in federal court. See attached document #158.
• May 1, 2018: The county of Orange and the cities of Tustin, Anaheim, and Orange were served the lawsuit (no
other cities including those in South County have been served). See attached document #232 indicating the
service date of May 1, 2018.
• May 17, 2018: The cities of Santa Ana, Tustin, Anaheim, Orange and the county of Orange agree to a response
date of July 23, 2018 for the defendants to respond to the Santa Ana cross -complaint. See attached document
#232.
• July 11, 2018: The cities of Santa Ana, Tustin, Anaheim, Orange and the county of Orange agree to delay the
response date indefinitely until such a time that the court issues an order that a responsive pleading must be
filed. See attached document #246.
Now, in another agenda item you will be discussing the settlement which also has ties to the city's cross complaint with
the county in Section 3.3 of that settlement so we may actually have a lawsuit filed where the defendant does not even
respond to such suit despite it being active for well over a year.
I
I urge the council to consider serving the suit against South County cities in order to protect the interests of Santa Ana's
residents, businesses, and visitors. There may be concerns about whether Judge Carter is able to preside or whether
serving the suit will allow other cities and their leaders to look down upon our city or its leadership, yet that is not what
you are tasked with doing. Instead, I ask that you do what is best for the city of Santa Ana. If it is determined to be best
not to pursue this course of action, you owe it to the residents to provide an explanation or at a minimum a vote to
reverse action on this item because the last vote that happened was on April 25, 2018 where the then current council
voted unanimously (6-0, 1 absent) to file the suit which would presumably include serving and progressing forward with
litigation.
The task at hand is a big one. I trust that you will do what is best for our city. Thank you for the time you devote to this
topic.
Blessings,
Tim Johnson
Case
155-DOC-JDE Document 158 Filed 04/26/18 Page 1 of 27 Page ID #:2479
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Attorneys for Defendant and Cross -Claimant
CITY OF SANTA ANA
UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
SOUTHERN DIVISION
ORANGE COUNTY CATHOLIC
WORKER, an unincorporated
association; Lisa Bell, Shawn Carroll,
Melissa Fields, Larry Ford, Cameron
Ralston, Kathy Schuler, Gloria
Shoemake, as individuals;
Plaintiffs,
V.
ORANGE COUNTY, the City of
Anaheim, the City of Costa Mesa, the
City of Orange, and the City of Santa
Ana,
Defendants.
Case No.: SA CV 18-0155-DOC
(JDE)
CROSS -COMPLAINT BY Cl'
1. Eighth Amendment (Cruel &
Unusual Punishment)
2. fourteenth Amendment (Equal
Protection)
3, Fourteenth Amendment (Due
Process)
Case 8:
DE Document 158 Filed 04/26/18 Page 2 of 27 Page ID #:2480
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City of Santa Ana,
Cross -Claimant,
V.
County of Orange, City of Aliso Viejo,
City of Anaheim, City of Brea, City of
Buena Park, City of Costa Mesa, City of
Cypress, City of Dana Point, City of
Fountain Valley, City of Fullerton, City of
Garden Grove, City of Huntington Beach,
City of Irvine, City of La Habra, City of
La Palma, City of Laguna Beach, City of
Laguna Hills, City of Laguna Niguel, City
of Laguna Woods, City of Lake Forest,
City of Los Alamitos, City of Mission
Viejo, City of Newport Beach, City of
Orange, City of Placentia, City of Rancho
Santa Margarita, City of San Clemente,
City of San Juan Capistrano, City of Seal
Beach, City of Stanton, City of Tustin,
City of Villa Park, City of Westminster
and City of Yorba Linda,
Cross -Defendants.
For itself, and on behalf of its residents, Defendant and Cross -Claimant, City
of Santa Ana, a charter city and municipal corporation organized and existing under
the Constitution and laws of the State of California, alleges the following:
11,611 .8
1. Across Orange County, a social crisis has unfolded whereby the
number of individuals experiencing homelessness has skyrocketed to
unprecedented levels. In January 2017, the Orange County Continuum of Care
Case 8:N8-cv-00155-D0C-JDE Document 158 Filed 04/26/18 Page 3 of 27 Page ID #:2481
1 Point -in -Time Count and Survey found there were 4,792 homeless individuals in
2 Orange County, more than half of whom were unsheltered.
3 2. Many of these individuals struggle to meet the basic necessities of
4 life, including food, shelter, and health care. They often combat mental illness,
5 1 substance abuse issues, physical disabilities, or any combination of these
6 afflictions. A significant number are single women and veterans.
7 3. Social, mental health, and other services provided to homeless
8 individuals by the County of Orange and entities contracting with the County,
9 along with their funding levels, are woefully inadequate to address the instant and
10 ongoing crisis of homelessness.
11 4. The Orange County Board of Supervisors has publicly admitted that it
12 has failed to spend tens of millions of dollars available for homeless housing and
13 services for the homeless population in the County.
14 5. The number of homeless individuals living in Orange County rose
15 almost 8% from 2013 to 2017. (See, Exhibit "A".) Nowhere in the County was
16 there and is there, a greater concentration of homeless individuals than in the City
17 of Santa Ana.
18 6. Ultimately, Santa Ana seeks by this Cross -complaint, a fair and
19 equitable distribution of responsibilities for homeless services among the County
20 and all Orange County cities, as well as reimbursement and sustained funding by
21 the County for Santa Ana's decades long efforts to relieve homelessness in Orange
22 County. The recent actions of the County and Cross -Defendant cities show that
23 such a result is not likely to be voluntarily achieved.
24 THE PARTIES
25 7. Defendant and Cross -Claimant City of Santa Ana is and at all relevant
26 times has been a charter city and municipal corporation organized and existing
27 under the Constitution and laws of the State of California.
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Case
DE Document 158 Filed 04/26/18 Page 4 of 27 Page ID #:2482
I 8. Cross -Defendant County of Orange is and at all relevant times has
2 11 been a political and geographical subdivision of the State of California having its
3 I principal offices in the City of Santa Ana.
4 9. Cross -Defendant City of Aliso Viejo is and at all relevant times has
5 been a general law city operating under the general laws of the State of California.
6 10. Cross -Defendant City of Anaheim is and at all relevant times has been
7 a charter city and municipal corporation organized and existing under the
8 Constitution and laws of the State of California.
9 11. Cross -Defendant City of Brea is and at all relevant times has been a
10 general law city operating under the general laws of the State of California.
11 12. Cross -Defendant City of Buena Park is and at all relevant times has
12 been a charter city and municipal corporation organized and existing under the
13 Constitution and laws of the State of California.
14 13. Cross -Defendant City of Costa Mesa is and at all relevant times has
15 been a general law city operating under the general laws of the State of California.
16 14, Cross -Defendant City of Cypress is and at all relevant times has been a
17 charter city and municipal corporation organized and existing under the Constitutior
IS and laws of the State of California.
19 15, Cross -Defendant City of Dana Point is and at all relevant times has
20 been a general law city operating under the general laws of the State of California.
21 16. Cross -Defendant City of Fountain Valley is and at all relevant times
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has been a general law city operating under the general laws of the State of
California.
1.7. Cross -Defendant City of Fullerton is and at all relevant times has been
a general law city operating under the general laws of the State of California.
18. Cross -Defendant City of Garden Grove is and at all relevant times has
been a general law city operating under the general laws of the State of California.
Case 8:
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155-DOC-JDE Document 158 Filed 04/26/18 Page 5 of 27 Page ID #:2483
19. Cross -Defendant City of Huntington Beach is and at all relevant times
has been a charter city and municipal corporation organized and existing under the
Constitution and laws of the State of California.
20. Cross -Defendant City of Irvine is and at all relevant times has been a
charter city and municipal corporation organized and existing under the Constitution
and laws of the State of California,
21. Cross -Defendant City of La Habra is and at all relevant times has been
a general law city operating under the general laws of the State of California.
22. Cross -Defendant City of La Palma is and at all relevant times has been
a general law city operating under the general laws of the State of California.
23. Cross -Defendant City of Laguna Beach is and at all relevant times has
been a general law city operating under the general laws of the State of California.
24. Cross -Defendant City of Laguna Hills is and at all relevant times has
been a general law city operating under the general laws of the State of California.
25. Cross -Defendant City of Laguna Niguel is and at all relevant times has
been a general law city operating under the general laws of the State of California.
26, Cross -Defendant City of Laguna Woods is and at all relevant times has
been a general law city operating tinder the general laws of the State of California.
27. Cross -Defendant City of Lake Forest is and at all relevant times has
been a general law city operating under the general laws of the State of California.
28. Cross -Defendant City of Los Alamitos is and at all relevant times has
been a charter city and municipal corporation organized and existing under the
Constitution and laws of the State of California.
29. Cross -Defendant City of Mission Viejo is and at all relevant times has
been a general law city operating under the general laws of the State of California.
30. Cross -Defendant City of Newport Beach is and at all relevant times hash
been a charter city and municipal corporation organized and existing under the
Constitution and laws of the State of California.
Case 8:
DE Document 158 Filed 04/26/18 Page 6 of 27 Page ID #:2484
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31. Cross -Defendant City of Orange is and at all relevant times has been a
general law city operating under the general laws of the State of California.
32. Cross -Defendant City of Placentia is and at all relevant times has been
a charter city and municipal corporation organized and existing under the
Constitution and laws of the State of California.
33, Cross -Defendant City of Rancho Santa Margarita is and at all relevant
times has been a general law city operating under the general laws of the State of
California.
34. Cross -Defendant City of San Clemente is and at all relevant times has
been a general law city operating under the general laws of the State of California.
35. Cross -Defendant City of San Juan Capistrano is and at all relevant
times has been a general law city operating under the general laws of the State of
California.
36, Cross -Defendant City of Seal Beach is and at all relevant times has
been a charter city and municipal corporation organized and existing under the
Constitution and laws of the State of California.
37. Cross -Defendant City of Stanton is and at all relevant times has been a
charter city and municipal corporation organized and existing under the Constitution
and laws of the State of California.
38. Cross -Defendant City of Tustin is and at all relevant times has been a
general law city operating under the general laws of the State of California.
39, Cross -Defendant City of Villa Park is and at all relevant times has
been a general law city operating under the general laws of the State of California.
40. Cross -Defendant City of Westminster is and at all relevant times has
been a general law city operating under the general laws of the State of California.
41_ Cross -Defendant City of Yorba Linda is and at all relevant times has
been a general law city operating under the general laws of the State of California.
Case 48-cv-00155-DOC-ME Document 158 Filed 04/26/18 Page 8 of 27 Page ID #:2486
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Supervisor Do, Buena Park had the tenth highest number of unsheltered homeless
individuals in the County with a reported count of 70, or 15% of Santa Ana's total.
47. On March 31, 2018, a point -in -time count in Santa Ana revealed there
is at least 1,030 unsheltered individuals within city borders, 8 1 % of whom are
chronically homeless (for one year or more). Combined with sheltered homeless,
the number of homeless individuals in Santa Ana rises to 1,617. Santa Ana's 2018
count total is more than double the 2017 Count as reported by Supervisor Do.
Santa Ana's Count established that 52% of the individuals counted came from
outside Santa Ana and identified 32 Santa Ana public schools located within 1,000
feet of a homeless encampment.
48. Santa Ana is home to a low -barrier emergency shelter, a winter shelter,
a home for homeless women and children, and a women's shelter. In total, Santa
Ana has over 700 shelter beds or approximately 70% of the shelter beds across
Orange County,
IMPACTS ON SANTA ANA
49. The impact of homeless related issues on Santa Ana has been
staggering. In 2017, Santa Ana estimates it spent approximately $15 million
providing fire and police, security and other necessary services to address homeless
related issues in and around the Civic Center and Santa Ana.
50. Santa Ana estimates it will be compelled to spend over $17 million in
2018 to address homeless issues at the expense of core services to Santa Ana
residents. This figure represents approximately 7% of Santa Ana's general fund
that pays for police and fire among other services.
51. Santa Ana's physical resources have been overwhelmed. Just until
very recently, over 200 homeless individuals lived in the Civic Center in tents and
other makeshift shelters. This encampment necessitated the leasing of temporary
bathroom facilities and created issues regarding the storage of personal property left
unattended in and around the Civic Center. The circumstances gave rise to the
Case 8:
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near -constant law
enforcement presence in the
Civic Center.
Santa Ana police
provided homeless
outreach services and faced
quality of life
issues, a suicide
attempt, physical assaults, petty crimes, and investigating a homicide, among a
variety of other issues. City personnel also undertook extraordinary health and
safety measures, including the collection of abandoned, used, uncapped
hypodermic needles, disposal of human waste left in public areas, increased
maintenance services to confront excessive trash, and the implementation of weekly
power washing to minimize Hepatitis A and other health concerns — all at Santa
Ana's expense.
52. Homeless individuals are intentionally or unintentionally abandoned
within Santa Ana by various means. Some are transported for services to Santa
Ana and left without a plan for return transportation to the city of origin. Other
homeless individuals are brought to Santa Ana for shelter and essentially remain in
Santa Ana if that housing solution ends. For others, it is believed they are simply
transported to Santa Ana by neighboring agencies and ultimately abandoned.
Regardless of the intent as to how or why homeless individuals are brought to Santa
Ana, the impact is severe and burdens its residents.
53. Despite the wealth and considerable size of Orange County, the only
low barrier emergency shelter is found in Santa Ana. In fact, the County placed the
sole emergency shelter known as "The Courtyard" in Santa Ana and within
proximity of sensitive land uses such as nearby residences, several schools, and two
public libraries. The Courtyard provides shelter for upwards of 400 individuals on
a nightly basis irrespective of weather. The dramatic need for shelter is
exemplified by individuals camped on the sidewalk across the street from The
Courtyard when it closes its doors to individuals because of overcrowding. The
living conditions themselves in The Courtyard have come under severe criticism
due to overcrowding, exposure to the elements, and the lack of privacy for women.
18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 10 of 27 Page ID
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54. Santa Ana has made multiple efforts to engage other Orange County
cities in developing solutions for addressing homelessness, but with little success.
In October 2016, Santa Ana reached out to the County's 33 other cities to hold a
meeting to discuss potential solutions. When the group finally met eight months
later on June 29, 2017, only 12 other Orange County cities sent representatives.
PLAINTIFFS' ORIGINAL LITIGATION
55. On January 29, 2018, Plaintiffs in these proceedings filed the
underlying civil rights action to halt the County's eviction of hundreds of homeless
individuals living in or near the Santa Ana Riverbed.
56. On or about February 4, 2018, the Court stayed the County's efforts
and later lifted that stay only after requiring the County to provide 30-day motel
vouchers for individuals relocated from the Riverbed and concurrent assessments of
those individuals to determine future shelter options and services.
57. Over 700 persons were relocated from the Riverbed, including single
women and veterans. Later, approximately 200 individuals from the Santa Ana
Civic Center were relocated.
58. As the motel stays for individuals were ending, the County faced
significant challenges in providing adequate services and shelter beds. The Court
has convened numerous bearings to resolve issues raised by Plaintiffs in this
process. However, there are continued and consistent new issues arising with
individuals who were removed from the Riverbed and placed in shelters or services
outside of Santa Ana or in Santa Ana, who are now living on the streets of Santa
Ana.
59. The Court has repeatedly implored the County and all Orange County
cities to identify both short- and long-term solutions to the homeless crisis,
including at the very least the placement of low -barrier emergency -type shelters.
60. The underlying litigation in these proceedings raised hopes of global
participation by the County and its cities in addressing homelessness, a solution
18-cv-001.55-DOC-JDE Document 158 Filed 04/26/18 Page 11 of 27 Page ID
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long sought by Santa Ana. However, those hopes were dealt a fatal blow once the
County, backed away from a plan to establish low barrier homeless shelters in three
I cities.
THE COUNTY'S ABORTED PLAN
61. On March 17, 2018, federal district court Judge David O. Carter held a
status conference in the Santa Ana City Council Chambers. He invited the mayors
and city managers for all 34 cities in Orange County to attend. Judge Carter
specifically stated that homeless issues should be addressed by Orange County, a
place that was home to five of the twenty wealthiest cities in the entire nation. He
noted that Santa Ana was overburdened compared to other cities in the County with
not only the sheer number of homeless individuals, but also with the number of
services located in Santa Ana. By the end of the Status Conference, Supervisor Do
announced his laudable commitment to addressing homeless issues within the
County.
62. To this end, on March 19, 2018, the Orange County Board of
Supervisors voted to add up to 400 new emergency shelter beds on county -owned
properties in the cities of Irvine, Huntington Beach, and Laguna Niguel. This plan
would have located 200 homeless people in Irvine, then 100 in Huntington Beach
and 100 in Laguna Niguel, if needed. The County also voted to spend about $70.5
million in unspent Mental Health Services Act funds for housing and services for
homeless people with mental illnesses.
63. Within one day of the County's approval, all three cities vigorously
opposed this plan and threatened to sue the County, The Huntington Beach and
Laguna Niguel city councils voted to sue the County. Irvine filed a lawsuit on March
26, 2018 against the County. These actions were taken despite the fact that
California law requires each city to zone for homeless shelters.
64. By March 27, 2018, the Board of Supervisors formally rescinded its
approval of the three -shelter plan.
DE Document 158 Filed 04/26/18 Page 12 of 27 Page ID
#:2490
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65. On April 19, 2018, the South Orange County Mayors proposed
Silverado Elementary School, a rural county owned property, as a potential site for a
I homeless shelter,
66. On April 24, 2018, the Board of Supervisors voted to reject the
Silverado Elementary School site proposal, As of the filing of this Cross -Complaint,
no Orange County city has provided a location for an emergency shelter.
Ufl
67. Santa Ana seeks meaningful progress toward an equitable distribution
of homeless services, whether it be through resources or shelter throughout the
County. Cross -Defendants must work collaboratively to resolve the current
homeless crisis and to avert another. The communal goal must be a sustainable,
long-term plan that is both city -specific and regional in nature. There must be a
basic willingness to seriously consider, or at least not oppose, the provision of low
barrier shelters and permanent supportive housing by Cross -Defendants as well as
the provision of social services by city representatives or third parties, all in a
dignified and humane manner.
FIRST CAUSE OF ACTION
Violation of Eighth Amendment (42 U.S.C. § 1983)
(Against All Cross -Defendants)
68. Defendant and Cross -Complainant City of Santa Ana incorporates by
reference and realleges Paragraphs 1 through 67 as if fully set forth herein.
69. Cross -Defendant cities have either opposed, refused, or rejected the
siting of homeless shelters and services in their jurisdictions. Santa Ana has the
densest concentration of homeless individuals in the County. Despite state
requirements for each city to provide housing for homeless individuals, Cross -
Defendant cities have made insubstantial progress or failed to do so entirely.
18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 13 of 27 Page ID
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70. Cross -Defendant County has established homeless services almost
exclusively in Santa Ana, thereby further contributing to the dense concentration
I I homeless individuals therein.
71. Cross -Defendant County has failed to spend in excess of $200 million
it has available for the provision of services to mitigate homelessness in Orange
County. 1t has also failed to account for the interest earned on these monies.
72.
As a direct and proximate result of Cross -Defendants' acts and
omissions, Santa Ana has been compelled to spend millions of dollars from its
general fund budget to address a myriad of health and safety concerns attributable
to Santa Ana's homeless population, including until just recently the over 200
unsheltered individuals living in the Santa Ana Civic Center, Santa Ana residents
(have faced: homeless encampments, the possibility of a Hepatitis A outbreak, the
threat of or actual physical and verbal assault, exposure to public defecation and
public urination, carelessly discarded, uncapped, used hypodermic needles, and
excessive trash in the Civic Center and around Santa Ana.
73. Santa Ana would otherwise have spent these funds on the provision of
core services to its residents but has been forced to divert such funds to provide
homeless -related services, resulting in a deprivation of critical services that could
potentially positively affect the quality of life of its residents.
74. The foregoing acts and omissions of Cross -Defendants have caused
this deprivation of core services and quality of life by necessitating the expenditure
of Santa Ana funds on services related to homelessness. Residents of Santa Ana
are entitled to these services and by this deprivation, they have been subjected to
cruel and unusual punishment in violation of the Eighth Amendment to the United
States Constitution.
111
Ill
I
as 8:18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 14 of 27 Page ID
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1 SECOND CAUSE OF ACTION
2 Violation of Fourteenth Amendment: Equal Protection (42 U.S.C. §1983)
3 (Against All Cross -Defendants)
4 75. Defendant and Cross -Complainant City of Santa Ana incorporates by
5 reference and realleges Paragraphs 1 through 74 as if fully set forth herein.
6 76. The population of Santa Ana is approximately 341,000, 78% of which
7 is Hispanic. No other city in Orange County has a higher Hispanic population.
8 77. Santa Ana's median household income is also near the lowest of all
9 cities in Orange County,
10 78. These ethnicity and income demographics are well-known to Cross-
11 Defendants.
12 79. On account of these demographics, Cross -Defendants have either
13 established, encouraged, or been content with the provision of homeless shelters
14 and services almost exclusively within the borders of Santa Ana instead of their
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own jurisdictions.
80. This practice has continued unabated for years. Santa Ana hosts the
only true low barrier emergency shelter in Orange County and by far the highest
measure of social and other services targeted at homeless individuals.
81. Based on Cross -Defendants' acts and omissions, Santa Ana and its
residents have suffered a denial of the equal protection of the laws, as guaranteed
by the Fourteenth Amendment of the United States Constitution.
THIRD CAUSE OF ACTION
Violation of Fourteenth Amendment: Due Process (42 U.S.C. §1983)
(Against All Cross -Defendants)
82. Defendant and Cross -Complainant City of Santa Ana incorporates by
reference and realleges Paragraphs 1 through 81 as if fully set forth herein.
83. Santa Ana has a significant liberty interest in administering an efficient
and effective government for the benefit of its citizens.
DOC-JDE Document 158 Filed 04/26/18 Page 15 of 27 Page ID
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84. This interest has been severely compromised by Santa Ana's need to
devote substantial monetary and human resources to managing and relieving the
acute homelessness crisis within its borders. The diversion of such resources has
been to the detriment of Santa Ana residents.
85. This crisis has been precipitated and exacerbated by the foregoing
actions and omissions of Cross -Defendants, thereby depriving Santa Ana of its
liberty interest without due process of law in violation of the Fourteenth
Amendment of the United States Constitution, and detrimentally affecting its
residents.
111
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18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 16 of 27 Page ID
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PRAYER FOR RELIEF
WHEREFORE, Defendant and Cross -Claimant City of Santa Ana prays for
the following:
1. As against Cross -Defendant County, monetary damages according to
proof as reimbursement for the costs spent on homeless resources and necessary
related services;
2. As against Cross -Defendant County, monetary damages according to
proof for funding the continued provision of homeless resources and necessary
related services;
3. As against all Cross -Defendants, declaratory judgment that Cross -
Defendants and each of them have denied Santa Ana's rights under the Eighth and
Fourteenth Amendments as alleged herein;
4. As against all Cross -Defendants, an order requiring Cross -Defendants !i
and each of them to establish city -specific and regional solutions to homeless issues
or comply with state law as required;
5. As against all Cross -Defendants, reasonable attorney's fees;
6. As against all Cross -Defendants, costs of suit; and
7. Such further relief as the Court may deem just and proper,
Dated: Apri{L�t, 2018 By:
CITY OF SANTA ANA
Case 8:18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 17 of 27 Page ID
#:2495
Ak
4NUMMEAMAMILI
DIC
Orange County's Point In Time (PIT) count occured on) an uary28th, 2017. The PIT count is a biennWtally of people without a
home on a particular night. We countbecausewe want to understand homelessness In ourcommunity in orderto end It.This
PITcountprovidesvital Informationthatguides and shapesthe waywe approach and solve homelessness in Orange County.
This information is provided to the federal Department of Housing and Urban Development (HUD) and Informs the
amount and type of resources Orange County receives to help end homelessness.
UNSHELTERED • SHELTERED
2,584 EMERGENCY TRANSITIONAL
♦ SHELTER SHELTER
1,248 960
A Continuum of Care (CoC) is an Integrated system of care that guides her
Individuals & families through a comprehensive array of services and housing de:
to prevent and end homelessness. The County of Orange is the lead for Orange Co
CoC, which funds 14 nonprofits across the OC CoC.
SUMMARY OF KEY FINDINGS
Orange County Is divided into three Service Planning Areas (SPAS) that
efficiently direct resources as Individuals experiencing homelessness
enter the Coordinated Entry System.
2013
2015
2017:
Unsheltered Homeless people
T27
2,2tl1
2,584
Sheltered Homeless People
2,261
2,208
Emergency Shelter
1,145
925
1,248
Transitional Shelter 1,428
1,326
960
Total PIT Count fi 4,251
4,452
4,782
Change Year to Year
+4,73%(201)
+7.6%(340)
In conjunction with 2-1-1 Orange County, the OC Commission to End
tbeds
ssness convened an ad hoc committee to provide
ance on the 2017 PIT count project. The ad hoc
mmittee's direction Included a public places count
with sampling methodology. This methodology was
also used for the 2013 and 2015 PIT counts. During
the 2017 PIT count, 86 additional maps were counted
and surveyed for a total of 270 maps in comparison
to 184 maps In the 2015 PIT count. Reductions in
transitional shelter beds is reflective of national
UD funding priorities. Increase in emergency shelter
is a result of The Courtyard, a County investment.
eaocation of resources to permanent housing are not
reflected in the count results.
HOMELESSNE
INORANNTY
*2017 Poin t-M-l7me Count-
SU' LE
1F CA Ii
2,150
434
�I UNSHELTERED
TOTAL:2 O VETERANS
e County is the third largest county in California, and sixth largest In the nation with a population of more than
million people. Despite our affluent reputation, we have residents who have needs you might not expect. Like many
ies across the nation, we have people experiencing homelessness. The County of Orange is working diligently to
de funding and resources for this vulnerable population, Here Is a look at what we've done in the last year.
cuesreea
The Board of SUParyNors has committed more than
MILLION
to providing multiple shelter options that meet a variety of needs.
KRAEMER CENTER
(North Anaheim)
County's that year-round emergency
shelter and multi -service center with
on -site programs. 100 beds In phase one
opening Spring 2017, 100 additional beds
In phase two anticipated in late 2018.
400
BEDS
THECOURTYARD
(Santa Ana Civic Center)
Day serviae center and low barrier, low
threshold safe sleep shelter.
MILLION
AVAILABLE
ARMORIES
(Santa Ana and Fullerton)
overnight cold -weather emergency shelter
providing 400 beds from Decemborto April,
The Board approved Issuance or the 2016
Permanent Su heoMbo Housing Notice of Funding
Avdhinlity to provide up to $8 million for the
acyuildon, new construction and acquisition/
rehabilitation of permanant supportive housing
for Orange County's extremely low-income
households that are homeless.
RESTAURANT MEALS PROGRAM ---
50K PER YEAR
The Board approved the Restaurant Meals Program
that will enable Cafresh ollbentswho amhomeless,
disabled and/or olderly to purchase meals from
participating manuumes with their Coltman benefits.
It Is Intended to Increase food access for those who
do not have a place to store or cook two, may not be
able to prepare food or lack access to a grocery store.
— WHOLE PERSON CARE INITIATIVE —
The Whole Person Care initiative will target services to those that are
experiencing homelessness and are high utilizers of emergency rooms.
$23.5 MILLION 1 $9.6MILLION
PHASE ONE PHASE TWO
NOVEMBER 2016 - DECEMBER 2020 TED- DECEMBER 2020
Housing
Navigators
0„IT < Beds e g
Support
Service
Coordinators 1
CRISIS STABILIZATION UNITS
23.9 MILLION
N
In funding from the County has Increased the number of beds
available for people In a psychiatric ass,.showing Individuals to
receive immediate psychiatric care as opposed to going to the
enlergencyroam.
Planning
The County is the lead for Orange County's Continuum
of Pare, which provides $2Z3 MILLION
In funding to nonprofits to provide permanent housing
options insipid rehousing or permanent supportive housing)
to Individuals and families In our community. Provides
funding for Increased 'and strategic coordination of
resources targeting the most vulnerable populations.
00
Coordinated Permanent
Enere Svcfam Housing
— EMERGENCY SOLUTIONS GRANTS
$1=1 MILLION
The Board approves local nonprofitsto receive said gantfunding to provide emergency
shelter and rapid rehousing servicesto individuals and families In the community,
STATE COUNTY N--O"'711NNPPRRROFFIIT INDIVIDUAL
Case 8:18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 20 of 27 Page ID
#:2498
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4/26/2018 Case II:18-cv-00155-DOCR,ML'd Di9 UNj'�. unigiW /�BY7g- �l,01.abf 27 Page ID
#:2499
u sum total percentage point deviation of place from
�0 Orange County
# rank of place out of 40 by %
f non-I-lispanic 2excluding black and Asian Hispanics
Ifl=12p
o -WhILO
o �l panto
o Black
o Asian
o M=d
o Othe1
Hispanicl Population by Place 22
Percentage of the total population.
Scope: population of Orange County, selected places in
Orange County, and entities that contain Orange County
https://statisticalaties.comfcounty/California/Orange-County/Race-and-Ethnicity 13/43
4/16/2011, Case 8:18-cv-00155-DOC83E)L'd M UrYi&MT5$"n'Fifigi o(94,TWt8-sP121Pbf 27 Page ID
0% 20% 40% 60%
Cou#:2500
Santa Ana
267k
1
La Habra
36.6k
2
Anaheim
52
2%
177k
3
Stanton
47.6%
18.2k
4
Los Angeles
44.20
5.72M
Tustin
39.2°I°
30.01k
5
San Juan Capistrano
8.3%
13.5k
6
Buena Park
&.2°i,
31.1k
7
Orange
8.1 %
52.61<
8
California
7A%
14.1M
Placentia
6.9%°
18.9k
9
Garden Grove
6,6%
63.2k
10
Costa Mesa
3
.9%°
38.7k
11
Fullerton
3
.2%°
46.8k
12
Orange
3
.6%
1,03M
Pacific:
30.
%
15.5M
Midway City
28.
%
2,677
13
'West:
28.
%
20,8M
Brea
26.7
a
10.6k
14
Lake Forest
23.0%
18.Ok
15
Westminster
22.5%
20.4k
16
Los Alamitos
21.4%
2,470
17
Rancho Santa Mara;
8.7%
9,036
18
Huntington Bch
8.6%
35.9k
19
Laguna Hills
8.5%
5,638
20
Cypress
&.0%
8,719
21
San Clemente
7.4%
11.1k
22
United States "<
16,2%
%5M
La Palma
9%
2,493
23
Yorba Linda
5.7%
10.2k
24
Aliso Viejo
1 .6%
7,627
25
Fountain Vly
1 .6°%
8,702
26
Mission Viejo
1 ',5%
14.7k
27
Ladera Ranch
1 A%°
3,669
28
Las Flores
1 .3% 1
1,007
29
Dana Point
1 .7%
4,937
30
Laguna Niguel
1 .1%°
8,971
31
Seal Beach
I .1%
3,422
32
North Tustin
11, `l°
3,061
33
Rossmoor
10=%,
1,175
34
Villa Park
0.6 n
565
35
Irvine
9.51,,
21.1k
36
Coto deCaza
9.1°q
1,357
37
Newport Beach
&.301
7,146
38
Laguna Beach
74%�
1,690
39
Laguna Woods
4.6% 1
755
40
httpsJlstatisticalatlas.comlcountylCalifornial0range-CountyiRaco-and-Ethnicity 14143
Case 8:18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 23 of 27 Page ID
#:2501
4/26/2018 Case 8:18-cv-00155-DOC-t9D&o'Vuetit*ewtnlbWurpilMf6*EeAS)• FMNLoaNaaf 27 Page ID
#:2502
Household Income by Place in Orange County
There are 40 places in Orange County. This section compares all 40 of those to each other, Orange County, and other
entities that contain or substantially overlap with Orange County,
Median Household Income by Place
Scope: households in Orange County, selected places in
Orange County, and entities that contain Orange County
hBpsa/statisticalatias.com/county/California/Oranga-CountyMousehoId-Income 13/44
4/26/2018 Case 8:18-cv-00155-D0CH D9ol Page ID
$Ok $50k $100k $150k %%#:,2§03
Coto de Caza
Villa Park
Las Flores
Ladera Ranch
North Tustin
Yorba Linda
Rossmoor
Newport Beach
Rancho Santa Mar...
Laguna Niguel
Aliso Viejo
Mission Viejo
Laguna Beach
Lake Forest
Laguna Hills
Irvine
San Clemente
La Palma
Los Alamitos
Huntington Bch
Fountain Vly
Dana Point
Brea
Orange
Cypress
Placentia
San Juan Capistrano
Orange
Tustin
Fullerton
Buena Park
Costa Mesa
La Habra
California
Los Angeles
Pacific
Garden Grove
Anaheim
West
Santa Ana
United States
Westminster
Seal Beach
Stanton
Midway City
Laguna Woods
+117%u
+106%
+70.1 %
+64.5%
+62.6%
+48.8%4
+44.3%
+41.0%
+38.0%
+32.3%
+31.8%a
+27.6°%
+25.1 %
+24.1 %
+20.3%
+20.1 %
+19A%
+13.7%
+9.62%
+7.91 %
+7.22%
+6.25%
+4.91 %
+4.53%
+3.90%
+3.73%
+0.24%
0%
-2.95%
-10.7%
-12.0%
-12.7%
-18.2%
-19.0%
-20.1 %
-20.3%
-20.9%
-21.6%
-24.2%
-29.3%
-29.7%
-30.2%
-32.1 %
-36.5%
-40.0%
-51 A%
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
https:llstatisticalaties.com/county/California/0range•County/Household-Income 14/44
4126/2018 Case 8:18-cv-00155-DOC BelcBroom a ni6ounl-riWco* fiito- "(Pi26�af 27 Page ID
#:2504
olu percentage above or below median household income of
Orange County
# rank of place out of 40 by median household income
Six -Figure Incomes by Place
Percentage of households with incomes above $100k.
Scope: households in Orange County, selected places in
Orange County, and entities that contain Orange County
< $25k $25-50k $50-100k
$100-200k $200k+
https://statisticelatias.com[county/Californ1a/Orange•County/HoLisehold-Income 15/44
4/26/2018 Case 8:18-cv-00155-DOCK3DEoIdDmuigOMnifRunFyiWc(WMORO- le".%aqjf 27 Page ID
50% 0% 50% Gou�ti2505
Villa Park
Coto de Caza
Laders Ranch
North Tustin
Las Flores
Yorba Linda
Newport Beach
Rancho Santa Mar...
Rossmoor
Laguna Niguel
Aliso Viejo
Mission Viejo
Laguna Beach
Lake Forest
Irvine
Laguna Hills
San Clemente
La Palma
Dana Point
Huntington Bch
Los Alamitos
Fountain Vly
Brea
San Juan Capistrano
Cypress
Placentia
Orange
Orange
Tustin
Fullerton
Costa Mesa
California
Buena Park
Los Angeles
Seal Beach
Pacific
La Habra
Anaheim
West
Garden Grove
Westminster
United States
Santa Ana
Stanton
Midway City
Laguna Woods
1,415
3,428
4,757
5,512
1,260
12.5k
20.3k
8,712
2,048
12.2k
9,228
16.0k
5,271
12,7k
36.9k
4,703
10.9k
2,076
5,890
30.1 k
1,623
7,356
5,509
4,429
6,092
6,091
16.2k
368k
8,529
14.Ok
12.6k
3.63M
6,578
1.21 M
3,511
4.80M
4,782
25.4k
6.49M
11,5k
6,721
26.0M
14.4k
2,091
483
1,267
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
https:llstatisticalatlas.com/county/California/Orange-CountylHousehold-Income 16/44
Case 8V-cv-00155-D0C-JDE Document 246 Filed 07/11/18 Page 1 of 6 Page ID #:2694
1 WAYNE W. WINTHERS, CITY ATTY. #134659
wwinthers cityyo�forange.org
2 RYAN E. L MM, ASSIST. CITY ATTY. #286564
rlumm cityoforange.org
3 CITY O ORANGE
300 East Chapman Avenue
4 Orange, California 92866
(714)744-5580
5
Attorneys for Defendant and Cross -Defendant
6 CITY OF ORANGE
7
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UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
SOUTHERN DIVISION
ORANGE COUNTY CATHOLIC
WORKER, an unincorporated
association; Lisa Bell, Shawn Carroll,
Melissa Fields, Larry Ford, Cameron
Ralston, Kathy Schuler, Gloria
Shoemake, as individuals;
Plaintiffs,
V.
ORANGE COUNTY, the City of
Anaheim, the City of Costa Mesa, the
City of Orange, and the City of Santa
Ana,
Defendants.
1
Case No.: SACV 18-00155-DOC-JDE
Hon. David O. Carter
STIPULATION TO EXTEND TIMI
TO RESPOND TO CROSS
COMPLAINT FILED BY CITY OF
SANTA ANA
Cross Complaint served: May 1,
2018
Current response due: July 23, 2018
Indefinite per Court Order
Case
DE Document 246 Filed 07/11/18 Page 2 of 6 Page ID #:2695
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City of Santa Ana,
Cross -Claimant,
V.
County of Orange, City of Aliso Viejo,
City of Anaheim, City of Brea, City of
Buena Park, City of Costa Mesa, City of
Cypress, City of Dana Point, City of
Fountain Valley, City of Fullerton, City of
Garden Grove, City of Huntington Beach,
City of Irvine, City of La Habra, City of
La Palma, City of Laguna Beach, City of
Laguna Hills, City of Laguna Niguel, City
of Laguna Woods, City of Lake Forest,
City of Los Alamitos, City of Mission
Viejo, City of Newport Beach, City of
Orange, City of Placentia, City of Rancho
Santa Margarita, City of San Clemente,
City of San Juan Capistrano, City of Seal
Beach, City of Stanton, City of Tustin,
City of Villa Park, City of Westminster
and City of Yorba Linda,
Cross -Defendants.
WHEREAS, Defendant and Cross -Claimant City of Santa Ana ("City") filed
a Cross Complaint within the above -captioned action on April 26, 2018;
WHEREAS, the City served its Summons and Cross Complaint on Cross -
Defendants County of Orange, City of Anaheim, City of Orange, and City of Tustin
("Cross -Defendants") on May 1, 2018;
WHEREAS, the Court has previously granted Cross -Defendants a 60-day
extension to respond to City's Cross -Complaint to July 23, 2018; and
2
Case 8:
Document 246 Filed 07/11/18 Page 3 of 6 Page ID #:2696
1
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WHEREAS, the parties have agreed to an open-ended extension to file a
responsive pleading to follow the Court's open-ended extension for filing responsiv+
pleadings to the underlying complaint and the Cowl tentatively stated its agreement
at our last court appearance.
NOW, THEREFORE, by and through their respective counsel, the parties
hereby stipulate and agree, subject to approval by the Court, that Cross -Defendants'
time to file a responsive pleading be extended indefinitely, until the court issues an
order that responsive pleadings must be filed.
IT IS SO STIPULATED,
Dated: July JL 2018
Dated: July 2018
July 2018
CITY OF SANTA ANA
By:__
hn M.Funk
Assistant City Attorney
THEODORA ORINGHER PC
in
Kevin N. Royer
Attorneys for County of Orange
CITY OF ANAHEIM
By:
3
Gregg M. Audet
Deputy City Attorney
DE Document 246 Filed 07/11/18 Page 4 of 6 Page ID #:2697
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WHEREAS, the parties have agreed to an open-ended extension to file a
responsive pleading to follow the Court's open-ended extension for filing responsiv
pleadings to the underlying complaint and the Court tentatively stated its agreement
at our last court appearance.
NOW, THEREFORE, by and through their respective counsel, the parties
hereby stipulate and agree, subject to approval by the Court, that Cross -Defendants'
time to file a responsive pleading be extended indefinitely, until the court issues an
order that responsive pleadings must be filed.
IT IS SO STIPULATED.
Dated: July , 2018
Dated: July , 2018
Dated: July , 2018
CITY OF SANTA ANA
John M.Funk
Assistant City Attorney
THEODORA ORINGHER PC
Kevin N. Royer
Attorneys for County of Orange
CITY OF ANAHEIM
LIN
3
Gregg M. Audet
Deputy City Attorney
Case
DOC-JDE Document 246 Filed 07/11/18 Page 5 of 6 Page ID #:2698
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WHEREAS, the parties have agreed to an open-ended extension to file a
responsive pleading to follow the Court's open-ended extension for filing responsiv
pleadings to the underlying complaint and the Court tentatively stated its agreement
at our last court appearance.
NOW, THEREFORE, by and through their respective counsel, the parties
hereby stipulate and agree, subject to approval by the Court, that Cross -Defendants'
time to file a responsive pleading be extended indefinitely, until the court issues an
order that responsive pleadings must be filed.
IT IS SO STIPULATED.
CITY OF SANTA ANA
Dated: July , 2018 By:
John M. Funk
Assistant City Attorney
THEODORA ORINGHER PC
Dated: July 2018 By:
Kevin N. Royer
Attorneys for County of Orange
CITY OF ANAHEIM
Dated: July (� , 2018 By:_. 1 11V ' T--_
Gregg M. Audet
Deputy City Attorney
3
Case
DE Document 246 Filed 07/11/18 Page 6 of 6 Page ID #:2699
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Dated: Tuly I/ , 2018
Dated: July JL, 2018
CITY OF ORANGE
By:,
ne . Winthers
City Attorney
r'
..�
155-DOC-JDE Document 232 Filed 05/17/18 Page 1 of 5 Page ID #:2651
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8793)
Attorneys
ITY OF SANTA Defendant and Cross -Claimant
UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
SOUTHERN DIVISION
ORANGE COUNTY CATHOLIC
WORKER, an unincorporated
association, Lisa Bell, Shawn Carroll,
Melissa Fields, Larry Ford, Cameron
Ralston, Kathy Schuler, Gloria
Shoemake, as individuals;
Plaintiffs,
V.
ORANGE COUNTY, the City of
Anaheim, the City of Costa Mesa, the
City of Orange, and the City of Santa
Ana,
Defendants,
I
Case No.: SACV 18-00155-DOC-JDE
Hon. David O, Carter
STIPULATION TO EXTEND TIMI
TO RESPOND TO CROSS
COMPLAINT FILED BY CITY OF
SANTA ANA
Cross Complaint served: May 1,
2018
Current response due: May 22, 2018
New response date: July 23, 2018
Case 84-cv-00155-DOC-ME Document 232 Filed 05/17/18 Page 2 of 5 Page ID #:2652
1 11 City of Santa Ana,
3 (I Cross -Claimant,
V.
M
5
County of Orange, City of Aliso Viejo,
6 City of Anaheim, City of Brea, City of
7 Buena Park, City of Costa Mesa, City of
8 Cypress, City of Dana Point, City of
Fountain Valley, City of Fullerton, City of
9 Garden Grove, City of Huntington Beach,
10 City of Irvine, City of La Habra, City of
La Palma, City of Laguna Beach, City of
11 Laguna Hills, City of Laguna Niguel, City
12 of Laguna Woods, City of Lake Forest,
City of Los Alamitos, City of Mission
13 Viejo, City of Newport Beach, City of
14 Orange, City of Placentia, City of Rancho
15 Santa Margarita, City of San Clemente,
City of San Juan Capistrano, City of Seal
16 Beach, City of Stanton, City of Tustin,
17 City of Villa Park, City of Westminster
18 and City of Xorba Linda,
19 11 Cross -Defendants.
20
21
22 11 WHEREAS, Defendant and Cross -Claimant City of Santa Ana ("City") filed
23 11 a Cross Complaint within the above -captioned action on April 26, 2018;
24 11 WHEREAS, the City served its Summons and Cross Complaint on Cross-
25 Defendants County of Orange, City of Anaheim, City of Orange, and City of Tustin
26 11 ("Cross -Defendants") on May 1, 2018;
27 II WHEREAS, Cross -Defendants are required to file their answer and/or
0
respond to City's Cross Complaint by May 22, 2018, or twenty-one days following
service of the Summons and Cross Complaint; and
2
Case 8:18-cv-00155-DOC-JDE Document 232 Filed 05/17/18 Page 3 of 5 Page ID #:2653
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WHEREAS, the parties have agreed to a sixty-day extension in light of the
importance of the issues to be raised.
NOW, THEREFORE, by and through their respective counsel, the parties
hereby stipulate and agree, subject to approval by the Court, that Cross -Defendants'
answer and/or response to the City's Cross Complaint shall be due on July 23, 2018.
IT IS SO STIPULATED.
Ir �
CITY OF SANTA ANA
By: /, T4
tl6hn M. Funk
Assistant City Attorney
May _, 2018 By:
Kevin N. Royer
Attorneys for County of Orange
Dated: May �l , 2018
Gregg M. Audet
Deputy City Attorney
May r '2018 By: ~~
Wa e W. Winthers
City Attorney
P
Case 8:18-cv-00155-DOC-JDE Document 232 Filed 05/17/18 Page 4 of 5 Page ID #:2654
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WHEREAS, the parties have agreed to a sixty-day extension in light of the
importance of the issues to be raised.
NOW, THEREFORE, by and through their respective counsel, the parties
hereby stipulate and agree, subject to approval by the Court, that Cross -Defendants'
answer and/or response to the City's Cross Complaint shall be due on July 23, 2018.
IT IS SO STIPULATED.
Dated: May _., 2018
Dated: May 17 , 2018
Dated: May 2018
Dated: May l % 11018
CITY OF SANTA ANA
John M.Funk
Assistant City Attorney
THEODORA ORINGHER. PC
By: 4
Kevin N. oyer
Attorneys for County of Orange
CITY OF ANAHEIM
am
Gregg M. Audet
Deputy City Attorney
CITY OF ORANGE
9
WeFyfe W. Winthers
City Attorney
Case 8:1#-cv-00155-DOC-JDE Document 232 Filed 05/17/18 Page 5 of 5 Page ID #:2655
I WOODRUFF, SPRADLIN & SMART
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3 Dated: May 17, 2018 By: J57
4 DLavid. T. enrlj 0
5 Attorneys for City of Tustin
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