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Demand to Stop the Unlawful Discrimination Against Individuals with Disabilities and Request for Reasonable Accommodation Page 3 of 11 one, fleeing domestic violence, lack of affordable housing, low wages, substance abuse or mental illness.4 The City has not provided adequate homeless services or programs to meet the needs of its residents. For example, the City allowed the 25+ years Civic Center homeless encampment to grow right outside of its City Hall, courthouse, and other government buildings. Only in April 2018 did the City, under court supervision and with the help of healthcare workers, close the Civic Center encampment by outreaching to individuals who were interested in accessing homeless services and housing — like the services provided at the South Main Street Site.5 However, the homeless population in Santa Ana continues to grow and shelters such as the Courtyard and the Link are consistently at capacity. And because the Santa Ana shelters are not accessible, many disabled homeless individuals are left on the streets.5 Without a place to maintain their disability symptoms, rest, store property, obtain food, or maintain hygiene, the death rate of homeless individuals continues to rise in Orange County.? The City recognizes that it needs to provide more resources for its homeless population, as evidenced by the funds it is obtaining to further provide housing and mental health services to homeless Individuals.' But while the City has made clear that it would prefer for other Orange County cities (particularly in the south) to increase their homeless programs, every city in Orange County needs to do so. The City cannot on the one hand receive funds to address homelessness, and, on the other, decide that those that serve homeless individuals with disabilities should be shut down. It is discriminatory. ° Why are People Homeless? Available online at: https://www.santa- ana.org/sites/default/files/Documents/HomelesslmpactCCM040318 pdf. s Civic Center plaza in Santa Ana cleared of homeless encampment, places to stay found for nearly 100, The Orange County Register (April 13, 2018), available online at: https://www ocreeister com/2018104/13/civic-center-plaza-1n-santa-ana-cleared-of-homeless encampment-p I aces-to-stay-found-for-n ea rly-100/, 6 "This Place is Slowly Killing Me."Abuse and Neglect in Orange County Emergency Shelters, ACLU of Southern California (March 14, 2019), available online at: https://www.aclusocal.org/sites/default/files/aclu socal oc shelters report pdf. 7 Orange County Draws Criticism For Over 200 Homeless Deaths This Year, The Orange County Register (December 30, 2019), available online at: https://voiceofoc.org/2019/`12 oran e-county- draws-criticism-for-over-200-homeless-deaths-this-year 8 See fn. 1.