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MARK S. -RoSEN <br />ATTORNEY AT L.AW <br />2728i LAS FtAM$LAS. SUJTE 204 <br />MISSION VIEJO, CAT-IFORYIA 92691 <br />TELEPHONE (949} 32$-3333 <br />{7(41 2$5-9a3a <br />EMAIL' MAR KROS E.N@MAf; CKROSEN LAW.COM <br />January 19, 2022 <br />FIRST CLASS AND VIA EMAIL <br />Daisy Gomez, Clerk of the Council dgomezr_cr�,santa-ana.org <br />Sonia Carvalho, Esq. scarvalho(&santa-ana.org <br />John Funk, Esq. <br />Brandon Salvatierra, Esq. <br />City of Santa Ana <br />City Attorney's Office <br />20 Civic Center Plaza <br />Santa Ana, California 92702 <br />j runk@santa-ana.org <br />bsalvatien a cisanta-ana.org <br />Re: 2702 North Bristol. Santa Ana <br />Dear Ms. Goanez and members of the City Attorney's Office: <br />I am writing in response to the letter of January 5, 2022, in which Ms. Gomez invited <br />comments on the hearing regarding adoption of a Resolution of Necessity to acquire a portion of <br />the property at 2702 N. Bristol Street, Santa Ana 92706 ("the property"). The hearing is <br />scheduled for February 1, 2022. <br />I represent Metro Star, LLC, the owner of the property. This is the property at the <br />northwest corner of Bristol and Memory Lane, perhaps best known for the political signs that are <br />posted on the chain link fence around the property. This letter is written in opposition to the <br />Resolution of Necessity. <br />The City has attempted to take a portion of the property oil the perimeter of the property. <br />On October 13, 2021, the city made an offer of $135,000, It has always been my client's <br />contention that taking the perimeter would render the entire property unusable under current city <br />codes and therefore the only proper action by the city is to take the entire property if there is to <br />be any taking at all, or to provide relief from the city codes by way of a variance. The city has <br />refused to consider taking the entire property. <br />In addition, the demand by the city for the perimeter has created a cloud on the property <br />that has rendered the property unsalable on the open market. As a precaution, I submitted a claim <br />to the city, which tilt city rejected. My client and the city agreed to several extensions of the <br />