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10 <br />11 <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 />TO THE CITY OF SANTA ANA; THE CITY COUNCIL OF THE CITY OF SANTA <br />PLANNING COMMISSION OF THE CITY OF SANTA ANA: <br />PLEASE TAKE NOTICE that under Section 21167.5 of the California Public <br />Resources Code, Petitioners Santa Ana Needs Equity, an unincorporated association, William <br />Conklin, an individual, Karina Rangel Conklin, an individual, and Yoon Hee Choe, an individual <br />(collectively, the "Petitioners"), intend to file a petition under the provisions of the California <br />Environmental Quality Act ("CEQA") against Respondents the City of Santa Ana, a California <br />Municipal Corporation, the City Council of the City of Santa Ana, and the Planning Commission <br />of the City of Santa Ana, challenging (1) the determination that the commercial development <br />ect at Tustin Avenue and Fourth Street in Santa Ana (including the recently approved <br />development of 325 N. Tustin Avenue and 301 N. Tustin Avenue) (the "Project") is categorically <br />exempt from environmental review under CEQA as an in -fill development project pursuant to <br />Section 15332 of CEQA (14 Cal. Code Regs. § 15332), (2) the adequacy of the notice of the <br />Planning Commission hearing concerning the Project, and (3) that Respondents may approve the <br />Project without further environmental review under CEQA and/or the preparing a subsequent <br />environmental review document, and without compliance with the Mitigated Negative Declaration <br />and Mitigation Monitoring and Reporting Program previously adopted for the Project, as more <br />fully described in the Petition for Writ of Mandate and Complaint for Injunctive Relief attached <br />hereto as Exhibit "A" and incorporated herein by reference. <br />DATED: October 1.3, 2019 <br />Respectfully submitted, <br />KARA GRANT LAW <br />By: <br />Kara E. Grant NV <br />Attorneys for Pe i ioners <br />2 <br />NOTICE OF INTENT TO FILE CEQA PETITION <br />