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file the CEQA petition to preserve their rights in light of the 35-day statute of limitations prescribed <br />under CEQA section 21167(d). Petitioners opposition to the Project concerning the City's CEQA <br />violations are further discussed in the attached Petition. <br />The attached Notice and Petition are submitted to the City as written comments in addition to <br />this letter for the October 15, 2019 hearing on the Appeal of the Russell Fischer Commercial Center <br />Project (Appeal Application No. 2019-03). The comments are submitted on behalf of Petitioners, Santa <br />Ana Needs Equity (SANE), William Conklin, Karina Conklin, and Yoon Hee Choe. The FIR excerpt <br />from a different City project attached is also submitted in support of these written comments and in <br />support of Appeal Application No. 2019-03. <br />Sincerely, <br />Kara E. Grant <br />Attorney at Law <br />