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�w wr wZ 2O 3= W -� Z❑ 0 0 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 structures. The proposed development would be 5-stories and be topped with mezzanines reaching approximately 65 feet 8-inches in height. The development would tier down to 2-stories (slightly over 20-feet in height) on the eastern portion of the site. The residential units would be wrapped around a 358,630 square foot central parking/fitness center/club room structure with a roofline of approximately 90 feet from the ground surface, which is the highest point of the proposed project. The project would result in approximately 930,705 square feet of development and a density of 84 dwelling units per acre. 15. On November 15, 2018, the City released the Final Environmental Impact Report ("Final EIR"). The City received hundreds of comments to that Final EIR, incorporated by reference herein. The City failed to meaningfully respond to these comments. (See Final EIR, pp. 3-1 to 7.) 16. On or about February 19, 2019, upon recommendation of the Santa Ana Planning Commission ("Planning Commission") to deny the Initial Plan's application and certification of the Final EIR, the City Council directed the Applicant to consult with the community and revise its plans. (See City Council Minutes 2/19/2019.) 17. On information and belief, between February and June of 2019, Applicant modified the Initial Plan. Ultimately, the modified Initial Plan proposed a 347-unit multi -family residential development ("Second Plan"). Petitioner opposed this Second Plan, as it still did not address or mitigate for the significant impacts. In the City's Clarification to the Final EIR dated July 11, 2019 ("July Clarifications"), the City improperly rejected that the Final EIR needed to be recirculated. (See Clarification to Final EIR, July 11, 2019, p. 1.) 18. On or about August 12, 2019, the Planning Commission's vote on the proposed Second Plan resulted in an impasse (3 votes for, 3 votes against). (See Planning Commission Minutes, Aug. 12, 2019.) The Applicant appealed the Project to the City Council. (Ibid.) 19. On information and belief, the Second Plan was then revised to the current Project, an unrecognizable, rashly considered apartment complex that is a far cry from the Initial Plan considered and evaluated in the Final EIR. The Project, in its present iteration, purports to demolish the existing two-story, 81,172 square foot office building. In its stead, Applicant would construct a 256-unit multi -family housing project on a 4.4 acre parcel at 58 dwelling units per 4516.101 / 8560319.1 5- VERIFIED PETITION FOR WRIT OF MANDATE/MANDAMUS