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Demand to Stop the Unlawful Discrimination Against Individuals with Disabilities <br />and Request for Reasonable Accommodation <br />Page 4 of 11 <br />B. MHA-QC South Main Street Site <br />Despite the financial resources the City of Santa Ana has obtained through its <br />Homeless Program, the City intends to worsen the living conditions for its most <br />vulnerable residents — homeless individuals with mental health disabilities — by <br />closing the South Main Street Site.9 This Site provides services to only <br />homeless individuals with disabilities and referrals come from County -operated <br />programs.10 The South Main Street Site services include: evaluation and <br />assessment, individual and group counseling, substance use prevention and <br />education, case management, referrals services, housing services, vocational <br />services, and other therapeutic activities.11 The goal of the Site is to provide <br />homeless individuals with disabilities with assistance in a safe and comfortable <br />atmosphere for them to engage in services and address their disability.92 <br />Facts Relating to Individuals Clients <br />We represent the following individuals with disabilities in the City's denial of their <br />access to the Homeless Programs and the request for reasonable <br />modifications. <br />L.W. is 39 years old and has mental health disabilities. These disabilities <br />include manic depression, bipolar disorder, and dissociative identity disorder <br />stemming from a history of severe trauma and abuse. L.W. is a client of MHA- <br />OC and visits the South Main Street Site every day. She uses the Site's mental <br />health services, has a caseworker, and receives assistance with housing. She <br />has placed her name on all the available housing lists. She can shower, do <br />laundry, receive mail, and charge her phone at the Site. The Site provides her <br />mental health treatment and helps her manage her mental health disability <br />through the services and safe community provided at the Site. <br />9 See City of Santa Ana et at. v. Orange County Association For Mental Health DBA Mental Health <br />Association of Orange County et al., Case No. 30.2020-01124174-CU-MC-CJC, Orange County Superior <br />Court, filed on Jan. 13, 2020. <br />10 Homeless Multi -Service Center, Behavioral Health, Orange County Health Care Agency. Available <br />online at: http://www.ochealthinfo.com/bhs/homeless multi service center. <br />11 Id, <br />12 Id. <br />