CORRESPONDENCE - CLOSED SESSION 1B

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I as 8:18-cv-00155-DOC-JDE Document 158 Filed 04/26/18 Page 14 of 27 Page ID #:24 92 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 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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.