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=w <br />Ur <br />WZ <br />J <br />LU <br />Z G <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 />Petitioner/plaintiff, Santa Ana Citizens for Responsible Development, an unincorporated <br />association of concerned residents ("Petitioner"), hereby petitions this Court for a peremptory <br />writ of mandate/mandamus, pursuant to Code of Civil Procedure sections 1085 and 1094.5, to be <br />directed to respondents/defendants, the City of Santa Ana ("City") and its City Council <br />(collectively, "Respondents"), along with other causes of action alleged herein, including as to the <br />applicant and real parry in interest AC 2525 Main, LLC ("Applicant"), and real party in interest <br />Discovery Science Center of Orange County ("Discovery Science Center"). This <br />petition/complaint alleges conduct in violation of the California Environmental Quality Act (Pub. <br />Resources Code, §§ 21000-21189.57) ("CEQA"). <br />THE PARTIES <br />Petitioner is an unincorporated association of concerned City residents. Diane <br />Fradkin is a City resident and a member of Petitioner. Ms. Fradkin lives within one mile of the <br />project at issue in this petition ("Magnolia at the Park" or the "Project"), which includes the <br />demolition of an existing office building and development of a 256-unit multi -family residential <br />development with associated parking, located at 2525 N. Main Street, Santa Ana, California. Ms. <br />Fradkin will be directly affected by the Project's numerous significant and unmitigated <br />environmental impacts and has standing to seek such relief as that requested herein. Petitioner <br />has standing based on the standing of its members, including, without limitation, Ms. Fradkin. <br />2. Respondent/defendant City is a public entity located in the State of California. <br />The City is required to comply with state, local, and federal law, rules, and regulations, including, <br />without limitation, CEQA. <br />3. Respondent/defendant City Council of the City of Santa Ana ("City Council") is <br />the elected governing body of the City and has final decision -making authority, including the <br />resolution of appeals. Like the City, the City Council is required to comply with local, state, and <br />federal law, including CEQA. <br />4. Petitioner is informed and believes that Applicant is a Delaware limited liability <br />corporation that is the applicant for the Project. <br />4516.101 18560319.1 <br />-2- <br />VERIFIED PETITION FOR WRIT OF MANDATE/MANDAMUS <br />