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Case 8: <br />1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />155-DOC-JDE Document 158 Filed 04/26/18 Page 7 of 27 Page ID #:2485 <br />JURISDICTION AND VENUE <br />42. The Court has jurisdiction over this action because the claims alleged <br />herein arise out of the transactions and occurrences that are the subject matter of the <br />original action. <br />43. Venue is proper in this Court under 28 U.S.C. section 1391(b) because <br />a substantial part of the events or omissions giving rise to the claims occurred in <br />Ithis district. <br />FACTUAL ALLEGATIONS <br />BACKGROUND <br />44. The City of Santa Ana has a population of approximately 341,000 and <br />covers 27 square miles. It is ethnically diverse and boasts an ethnic make-up as <br />follows: 78% Hispanic, 10% Asian, 9% White, and other ethnicities in smaller <br />percentages. The average median income in Santa Ana is approximately $54,500, <br />as compared to the median income in Orange County of $75,400. Santa Ana has <br />the highest Hispanic population in the County and is one of the lowest income <br />cities in the County. (See, Exhibit "B" & "C".) <br />45. For decades, Santa Ana has borne the largest and most inequitable <br />burden of addressing and relieving homelessness in Orange County, whether by <br />providing necessary, related services on its own or by hosting the provision of such <br />services by the County and third parties within its borders. <br />HOMELESS STATISTICS <br />46. In 2017, there were a total of 2,584 unsheltered homeless individuals <br />and an additional 2,208 sheltered individuals, for a total 4,792 homeless individuals <br />in Orange County. (See, Exhibit "A".) On March 30, 2018, Andrew Do, the <br />Chairman of the Board of Supervisors, reported at a Special Meeting of the City <br />Council of the City of Santa Ana that in 2017, Santa Ana alone had 466 unsheltered <br />homeless individuals, which was the highest number in the County. In comparison, <br />Santa Ana had 100 more such individuals than Anaheim. Of the cities identified by <br />