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Demand to Stop the Unlawful Discrimination Against Individuals with Disabilities and Request for Reasonable Accommodation Page 10 of 11 C1 Community Commercial zoning district, under Sec. 41-365(h), allows for the permitted use of hospitals, clinics, and sanitariums,1' The County of Orange lists the South Main Street Site as a County -contracted, homeless resource for "psychiatrically disabled homeless adults in Orange County" that provides housing specialists to help move individuals into permanent housing.1' The County further states that this County -contracted agency provides services at the South Main Street Site that includes evaluation and assessment, individual and group counseling, and referrals to appropriate mental health services according to specific needs.19 Because of the nature of the services it offers, the South Main Street Site is in compliance with the City's zoning provisions. The City discriminates against our clients by maintaining that the Site is in violation of the City's zoning codes. Per Welfare and Institutions Code section 5120 and its own laws, the City cannot discriminate "in the enactment, enforcement, or administration of any zoning laws, ordinances, or rules and regulations between the use of property for the treatment of general hospital or nursing home patients and the use of property for the psychiatric care and treatment of patients, both inpatient and outpatient." E. Failure to Provide Notice or Warning of Public Nuisance Allegations Finally, the City violated due process as it never provided reasonable notice or warning to MHA-OC or the individuals with disabilities who rely on the South Main Street Site to manage their disabilities or their essential life -sustaining needs of the City's plans to close down the Site.20 The City cites issues of public nuisance but took no action to work with MHA-OC, the provider, on accommodations that would continue to allow homeless individuals with disabilities to access the City's Homeless Program and balance the. City's other interests. 11 "Uses permitted in the C1 district.... (h) Hospitals, clinics, and sanitariums." Section 41-365(h), C1 Community Commercial of the City of Santa Ana Planning and Building Agency, Planning Division (emphasis omitted). Available online at: https://www.santa- ana.org/sites/`default/files/"DocumentsZC1. . 11 Housing Resource Guide, Orange County 2019, at 42. Available online at: santa- ana.org/sites/default/files/2019-06/HRG2019.pdf. "See fn. 11. 10 42 U.S.C, §§ 1983,1988; Fourteenth Amendment.