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Honorable Mayor and City Council Persons City of Santa Ana Hearing: October 4, 2022; Item: 25 September 30, 2022 Page 11 of 11 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. This issue is stated only to emphasize the practice of gross generalization of some Findings and Statements. (Section 1. Q 2. We respectfully object and disagree with the proposed findings in the resolution, as alleged above specifically, and extended here generally, the alleged regulatory nexus of ameliorating housing instability at mobilehome parks does not bear a reasonable relationship and rough proportionality to the proposed RSIJCE Ordinance, which amounts not to an iterative amendment, but rather a wholesale repeal and readoption of new regulation. 3. 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. Again, we appreciate the City's work and apparent corrections and refinements in response to the pending litigation. We must reserve the right to further supplement this letter and administrative record concerning this Item 25, and its future readings, as our review of the proposed adoption and public proceedings continues. For avoidance of doubt, this correspondence and the correspondence and pleadings incorporated by reference are not intended to list all of the deficiencies, and errors or omissions of facts and law contained in both the Rent Stabilization Ordinance, the Just Cause Eviction Ordinance, in the amended RSIJCE Ordinance, and all related findings and resolutions. All legal rights and remedies based upon the impacts of these Ordinances are reserved on behalf of our clients. Sincerely, LOFTIN I BEDELL P.C. By: Sue oftin Es Y � . q cc: Clients Kingsley - 426 Santa Ana Ordinances