CORRESPONDENCE - 75A (COMMENT) - Laserfiche WebLink

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11 2 3 V. PRIVATE ATTORNEY GENERAL DOCTRINE 26. Petitioners bring this action as private attorney generals pursuant to Code of Civil section 1021.5, and any other applicable legal theory, to enforce important rights 4 affecting the public interest. 5 27. Issuance of the relief requested in this Petition will confer a significant benefit on 6 the general public by requiring Respondents to carry out their duties under CEQA and other 7 applicable laws before approving the Project. 8 28. Issuance of the relief requested in this Petition will also result in the enforcement of 9 important rights affecting the public interest by compelling Respondent to engage in a legally 10 adequate analysis of the Project, and to ensure that the public has a meaningful opportunity to 11 review and comment on the impacts and mitigation measures for the Project. 12 29. The necessity and financial burden of enforcement make an award of attorneys' fees 13 appropriate in this case. Without this Petition, Respondents and Real Parties will proceed with 14 development of a Project that will cause significant, unmitigated environmental impacts that might 15 otherwise have been reduced or avoided through legally adequate environmental review, and the 16 adoption of feasible mitigation measures. 17 18 V1. STATEMENT OF FACTS 19 A. Uses of 301 And 325 N. Tustin Avenue Before the Proposed Project 20 30. Real Parties in Interest and project applicant have had a development project 21 pending for the neighboring properties located at 325 N. Tustin Avenue and 301 N. Tustin Avenue 22 since 2016. These properties are located in between the intersection of N. Tustin Avenue and 23 Fourth Street and the 55 Freeway offramp into Santa Ana. Currently, a gas station with a small, 24 attached automated car wash, and a convenience store is located on 325 N. Tustin Avenue, as 25 shown below. 26 27 28 8 PETITION FOR WRIT OF MANDATE