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18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 13 of 27 Page ID <br />#:2491 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />70. Cross -Defendant County has established homeless services almost <br />exclusively in Santa Ana, thereby further contributing to the dense concentration <br />I I homeless individuals therein. <br />71. Cross -Defendant County has failed to spend in excess of $200 million <br />it has available for the provision of services to mitigate homelessness in Orange <br />County. 1t has also failed to account for the interest earned on these monies. <br />72. <br />As a direct and proximate result of Cross -Defendants' acts and <br />omissions, Santa Ana has been compelled to spend millions of dollars from its <br />general fund budget to address a myriad of health and safety concerns attributable <br />to Santa Ana's homeless population, including until just recently the over 200 <br />unsheltered individuals living in the Santa Ana Civic Center, Santa Ana residents <br />(have faced: homeless encampments, the possibility of a Hepatitis A outbreak, the <br />threat of or actual physical and verbal assault, exposure to public defecation and <br />public urination, carelessly discarded, uncapped, used hypodermic needles, and <br />excessive trash in the Civic Center and around Santa Ana. <br />73. Santa Ana would otherwise have spent these funds on the provision of <br />core services to its residents but has been forced to divert such funds to provide <br />homeless -related services, resulting in a deprivation of critical services that could <br />potentially positively affect the quality of life of its residents. <br />74. The foregoing acts and omissions of Cross -Defendants have caused <br />this deprivation of core services and quality of life by necessitating the expenditure <br />of Santa Ana funds on services related to homelessness. Residents of Santa Ana <br />are entitled to these services and by this deprivation, they have been subjected to <br />cruel and unusual punishment in violation of the Eighth Amendment to the United <br />States Constitution. <br />111 <br />Ill <br />