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6I <br />71 <br />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 />include a car wash when Petitioner expressly inquired in early July. These factors evidence that <br />the ten day notice distributed only to those within 500 feet of the Revised Project was not intended <br />to inform the public, but rather to conceal the drastic change in the project for 301 N. Tustin <br />Avenue. If Petitioners were provided adequate notice, they could have obtained experts, had <br />necessary studies conducted regarding the Revised Project, submitted Public Records Act requests <br />for project documents and materials, and had time to review and analyze the documents and plans <br />I for the newly proposed Revised Project, before the September 9` hearing. Respondents denied <br />Petitioners of this opportunity and the result was prejudicial to them. <br />H. Petitioners Submit Written Oppositions and Speak at the Hearing in <br />Opposition <br />56. Prior to the September 9, 2019 hearing on the Revised Project before Respondent's <br />Planning Commission, Petitioner Choe submitted written comments opposing the Revised Project <br />stating her concerns over the impact of noise and vibrations on her dental practice because of the <br />sensitive nature of her work and her medical equipment, as well as her tenant's massage business. <br />57. Petitioners William Conklin and Karina Conklin also timely submitted written <br />comments in opposition prior to the hearing addressing, among other things, Respondents' <br />violation of CEQA. Petitioners also objected that the August 301 Notice was insufficient to afford <br />interested persons like themselves an adequate opportunity to prepare and protect their interests. <br />Petitioners requested that the hearing being continued so that interested parties may have sufficient <br />time to obtain and review the project materials for the newly Revised Project, but Respondents' <br />Planning Commission denied that request. <br />58. Petitioner Choe appeared in person at the September 9, 2019 Planning Commission <br />hearing and voiced her concerns to the Board of Commissioners over the significant <br />environmental impacts the Revised Project will have on her property and business as an <br />immediately adjacent, and uniquely sensitive use. <br />59. Petitioners William and Karina Conklin spoke in opposition to the Revised Project <br />at the September 91' hearing through their representative. <br />PETITION FOR WRIT OF MANDATE <br />