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zI <br />various other Project documents, including but not limited to, the Notice of Public Hearing Before <br />the Santa Ana Planning Commission, for the September 9, 2019 hearing on various entitlements <br />3 11 for the Project. <br />4 <br />10 <br />11 <br />12 <br />15. Real Party in Interest, Chase Russell is also identified as the "Applicant" on certain <br />City documents in connection with the Project. <br />16. Petitioners are ignorant of the true names and capacities of the real parties in interest <br />named herein as ROES 1 through 20, and therefore, names those real parties in interest by such <br />fictitious names. Petitioners will amend this Petition and Complaint to allege their true names and <br />capacities when ascertained. Richard Keith Finkel, Bundy -Finkel Associates, Russell Fischer LP, <br />Chase Russell, and ROES 1 through 20 are collectively referred to herein as "Real Parties." <br />17. Venue is proper in this Court as this lawsuit arises out of findings that the Project <br />exempt from environmental review under CEQA, that decision occurred within the County of <br />13 Orange, by Respondents City of Santa Ana, and the Project at issue is located at 325 & 301 N. <br />14 Tustin Avenue, in the City of Santa Ana, County of Orange. <br />15 18. Respondents' actions and failures to act, which gave rise to this Petition, occurred in <br />16 Orange County, California. The Project is located within Orange County, California. The <br />17 environmental effects resulting from the Project will impact businesses and residents of the City of <br />18 Santa Ana, located in the County of Orange. <br />19 19. Petitioners provided Respondents written notice of the commencement of these <br />20 proceedings prior to filing this Petition for Writ of Mandate in compliance with section 21167.5 of <br />21 1 the Public Resources Code. A true and correct copy of the proof of service for that notification is <br />22 attached to this Petition as Exhibit A. <br />23 III. STANDING <br />24 20. Petitioners have standing to assert the claims alleged in this Petition because they <br />25 are beneficially interested in this matter, as required by Code of Civil Procedure section 1086. <br />26 Petitioners have a direct and beneficial interest in Respondents' compliance with laws bearing <br />27 upon approval of the Project. These interests will be directly and adversely affected by the <br />28 Project, which violates the law as set forth in this Petition and would cause substantial harm to the <br />PETITION FOR <br />