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Demand to Stop the Unlawful Discrimination Against Individuals with Disabilities and Request for Reasonable Accommodation Page 2 of 11 infrastructure. And the City of Santa Ana's lawsuit against the South Main Street Site discriminates against individuals with disabilities and eliminates access to this necessary Homeless Program. The reasons alleged are wholly related to the disabilities of individuals who utilize the Site. We demand that the City halt its discriminatory practices and allow the Site to remain open. And though the closure is discriminatory as a whole, we also request that the City exempt individuals with disabilities, who utilize the South Main Street Site, from the Site's closure, as reasonable modifications under Title 11 of the Americans with Disabilities Act ("ADA"). We ask that the individuals be allowed to continue to utilize the Site until such time as the City (1) establishes a Santa Ana location that allows homeless individuals with disabilities to obtain treatment for their mental health disabilities, (2) provides a center and services to enable individuals with disabilities to maintain their symptoms and regular services for life -sustaining needs, such as nutrition, hygiene, and respite, and (3) connects individuals to permanent housing options. This request for reasonable modifications is made under Title I I of the Americans with Disabilities Act ("ADA") and all other applicable state and federal laws. Factual Background A. The City of Santa Ana's Homelessness Issue The 2018 Santa Ana Point -In -Time Count estimated that there were 1,030 unsheltered individuals living in Santa Ana, with an additional 564 individuals who were homeless.z Of the homeless individuals counted, 32.6% reported having mental health concerns and 36.9% reported having disabilities.3 The City attributes the causes of the unsheltered population to loss of job or loved Continuum of Care, and Emergency Solutions Grant ("ESG") to address rapid re -housing, emergency shelters and street outreach. Programs respectively cited and available online at: HUD programs - http://www.cl.santa-ana,ca.us/homelessness/documents/HomelessDraftPlan3-17-18.pdf at 104; H.E.A.R.T. program and services - https://www.santa-ana.org/homeless-engagement: ESG programs and services - https://www.santa-ana.org/hometess-enaaeement, 2 City of Santa Ana Paint -In -Time Count Survey Report at 3 (March 2018). Available online at: https://www.santa-ana.org/sites/default/files/Documents/Homelessi mi)actCCM040318.pdf. 9 Id. at 6.