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large. By failing to provide notice of this meeting, the City has again denied interested members of the public due process. As you know, the Native American tribe ancestrally and geographically affiliated with the location of the RF project consulted with the City and provided substantial evidence of the significant adverse impacts this project would have on their tribal cultural resources if appropriate mitigations were not adopted. Moreover, over twenty Santa Ana residents attended the October 15, 2019 City Council meeting on behalf of SANE to object to yet another car wash approval and voiced why the retail center previously approved would have benefited the community and the City, and how RF's car wash would be detrimental. With respect to the proposed recission of the 2019 RF project approvals, although my Clients agree that the 2019 approvals (among others) should be voided, RF's purported basis for requesting their rescission is patently false, and the related findings made by the City and included in the proposed Resolution rescinding the 2019 approvals is completely improper. To the contrary, the sole reason the City seeks to include findings pertaining to RF's alleged financial inability to proceed with the subject car wash project is because of my Clients' pending Lawsuit. We fully support the City Council rescinding the entirety of the 2019 Approvals because the City Council violated the law in adopting those approvals. That is part of the relief that was sought in the Lawsuit and to which the City and RF are now agreeing to. However, the City Council should stop there and not try and buy itself further litigation by attempting to bootstrap in these ridiculous purported findings. Let's be real. RF claimed that the retail center was not financial viable, and that is the reason it claimed it revised the project to substitute the car wash. RF never asked for the approvals of the retail version of the project to be rescinded because it is not necessary due to the project becoming economically not feasible. The normal response -the same one RF had previously —was not to proceed with the project, seek approvals for a revised project, or it could sell the land with the approvals to someone who might be interested. In addition, RF's purported reason does not pass the smell test given that there is a condition precedent to the request for rescission, that the City approve the secrete settlement agreement between RF and the City. If the financial non -feasibility is the reason for the request for rescission, then RF would unconditionally be requesting rescission. The Council has NO EVIDENCE to support its finding. Russell Fischer did not provide any documentation to show that it even engaged in any financial analysis. In addition, the City has no basis for making findings about the effect on the 2018 Approvals. The Court has already suggested he agrees with my client's position that adoption of the 2019 Approvals caused the 2018 to become void by their own terms. The City has no place in attempting to make a finding about the legal effect of its actions. Lastly, the City has hidden all of the documents related to this item from the public. The City refused to provide any documents for review to the public and my representative today related to this matter other than the six pages of the Staff Report with exhibit. The City Council should (1) rescind the 2019 Approvals, (2) strike Section 3 of the Resolution, and (3) strike the other inaccurate and unsupported proposed findings in Section 1. grant-law.net