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SANTA ANA'S PROPERTY BASED IMPROVEMENT DISTRICT corrective actions. Continuing to ignore this matter can only result in further discourse, both conversationally and legally, which will be detrimental to all. FINDINGS: In accordance with California Penal Code §933 and §933.05, the 2011-2012 Orange County Grand Jury requires responses from each agency affected by the Findings/Conclusions presented in this section. The responses are to be submitted to the Presiding Judge of the Superior Court. Based on its study of the Santa Ana Property Based Improvement District, the 2011-2012 Orange County Grand Jury makes the following Findings/Conclusions: Fl. City of Santa Ana appears to be in violation of California State Law in the formation of this hnprovement District. F2. Monies collected from the improvement district appear to have only benefited a few and have not resulted in a direct benefit to the assessed property as required by California law. F3. An appearance of impropriety exists in the relationship between the developer and the City of Santa Ana. F4. An appearance of impropriety exists in the relationship between the developer and Downtown Inc., the administrator of the funds from the special district. F5. The process by which the district was established in regard to the mailing of ballots, the process of tabulation, and the voting by the City of Santa Ana does not appear to be in compliance with the statutory requirements for establishing an assessment on property owners. RECOMMENDATIONS: In accordance with California Penal Code §933 and §933.05, the 2011-2012 Orange County Grand Jury requires responses from each agency affected by the Recommendations presented in this section. The responses are to be submitted to the Presiding Judge of the Superior Court. Based on its study of the Santa Ana Property Based Improvement District, the 2011-2012 Orange County Grand Jury makes the following recommendations: 2011-2012 ORANGE COUNTY GRAND JURY Page 220