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LOF"TIN I BEDELL P.C. Honorable Mayor and Councilmembers City of Santa Ana October 13, 2022 Page 6 of 7 enumerated in our communications dated September 29, 2022, which have been attached hereto and incorporated into this letter. Prior Commiunications Incorporated For avoidance of doubt, this correspondence incorporates by reference the following records into the administrative record for the October 4, 2021 and October 18, 2022 hearing, as they appear in the public records of the City of Santa Ana: the Staff Reports and all public records in the City records are hereby incorporated as though fully set forth: (i) for the City Council Hearings on September 21, 2021, October 5, 2021, October 19, 2021, adopting Rent Stabilization Ordinance, NS-3009 (RSO) and Just Cause Eviction Ordinance, NS 3010; (ii) September 6, 2022, Resolution No. 2021-054, Adoption of the Long - Term Implementation Plan and direction of direction from City Council; (iii) the City Council Hearing on October 4, 2022, for "Item 25" October, including all proceedings, testimony, and documents, correspondence, and source records and reports referenced or provided, and specifically including without limitation the communication sent by this firm dated September 29, 2022, a copy of which is attached hereto for convenience. Conclusion 1. We respectfully object and disagree with the proposed findings in the resolution, and allege they are unsupported by substantial evidence, particularly as to Section 1(c), and particularly as they relate to mobilehome parks. There is no evidence of significant rent increases and housing instability at mobilehome parks in the City. If there were actual issues, then a referral to code enforcement and/or nonprofit legal assistance are available to residents, Council and staff. (Section 1. C) 2. We respectfully object and disagree with the legal citations previously relied upon by the City as to Ordinance NS-3009, NS-3010, and Resolution 2021-054, and they do not reasonably relate to the extension of the Ordinances and proposed amendments in this Item 25 to mobilehome parks. 3. The alleged regulatory nexus of ameliorating housing instability at mobilehome parks does not bear a reasonable relationship and rough proportionality to the purposed legislative adoptions —which include, without limitation the forfeiture, without hearing, of the vested right to continue operation of a mobilehome park upon sale, and without a proposed change in use. 4. The City's proposed legislation lacks substantial evidence in support of findings for the imposition of an imbalanced board in favor of the pecuniary interests of tenants (and without representation of mobilehome park landlords). This will amount to a due process violation of mobilehome park landlords at adoption, and should be corrected now to avoid unnecessary cost and delay to the City and its constituents. We acknowledge the City's work and partial corrections and refinements in response to the pending litigation. /Volumes/Shared/Kingsley Management Company/700 Litigation/Kingsley V City Of Santa Ana/010 Correspondence/2022.10-13 Correspondence To City Regarding Implementation Of Reni Board V4.Docx