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<br />A. WHEREAS, on January 29, 2018, OCCW and certain individual
<br />plaintiffs filed an action, entitled Orange County Catholic Worker et al. v. Orange
<br />County et al., United States District Court, Central District of California, Case No.
<br />8:18-ev-00155-DOC-KES ("OC Catholic Worker Action"), against the County of
<br />Orange ("County"), the City of Anaheim, the City of Costa Mesa, and the City of
<br />Orange.
<br />B. WHEREAS, on March 17, 2018, the City of Santa Ana intervened in
<br />the OC Catholic Worker Action as a defendant.
<br />C. WHEREAS, on April 26, 2018, the City of Santa Ana filed a cross -
<br />complaint in the OC Catholic Worker Action against the County and all other cities
<br />in the County, alleging violations of the: (1) Eighth Amendment (cruel and unusual
<br />punishment); (2) Fourteenth Amendment (equal protection); and (3) Fourteenth
<br />Amendment (due process) ("Cross -Complaint"). The Cross -Complaint was served
<br />on the County, the City of Anaheim, the City of Orange, and the City of Tustin.
<br />The Cross -Complaint remains unserved on all other cross -defendants.
<br />D. WHEREAS, on July 26, 2018, OCCW filed a First Amended
<br />Complaint ("OCCW FAC"), which, among other changes, pleaded a potential class
<br />action against the County. At the time of execution of this Agreement, the OCCW
<br />FAC is the operative complaint in the OC Catholic Worker Action.
<br />E. WHEREAS, on November 13, 2018, OCCW filed a Supplemental
<br />Complaint adding the City of Tustin as a defendant.
<br />F. WHEREAS, on June 28, 2019, OCCW filed a Supplemental
<br />Complaint adding the cities of Brea, Buena Park, Cypress, Fullerton, La Habra, La
<br />Palma, Los Alamitos, Placentia, Stanton, Villa Park, and Yorba Linda as
<br />defendants ("North SPA Cities").
<br />G. WHEREAS, the OCCW FAC as well as the Supplemental
<br />Complaints, alleges that OCCW is an unincorporated association dedicated to the
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