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LOFTIN I BEDELL P.C. Honorable Mayor and CouncHmembers City of Santa Ana October 13, 2022 Page 5 of 5 RENT STABILIZATION ORDINANCE The numerous changes made in response to the pending litigation are hereby acknowledged. We snake reference to the adjoining letter addressing the issues with the RSO portion of the Ordinance as though such continents were fully incorporated herein. CONCLUSION Incorporated hereby reference, as though fully set forth for the record in this matter, are all prior comments, objections and legal issues raised in the correspondence provided to the City from this Firm, including without limitation, correspondence dated October 1, 2021 and September 30, 2022, the correspondence sent concurrently with this letter and the staff report, draft ordinances, City records, communications with and among or in any way related to the City "study group" organized among City Council representation, City staff and tenant representatives and presented prior to, at or after all hearings related to the Just Cause Ordinance or Rent Stabilization Ordinance and the Amended Ordinance combing the two prior Ordinances commencing with the hearings on September 21, 2021, October 5, 2021, October 19, 2021, and October 4, 2022 to the present date. For purposes of specifically setting forth the remaining factual and legal objections to the provisions of the proposed Amended Ordinance, please refer to the October 1, 2021, and September 30, 2022 correspondence from this Firm and the Amended Complaint in the matter Kingsley et al. vs. City of Santa Ana, et. al., case number S : 22-ev-00076-CJC-JDE. Again, we appreciate the City's work and apparent partial corrections and refinements in response to the pending litigation. We reserve the right to further supplement this letter and administrative record concerning this Item 21, 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 RS/JCE 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. r / 13 Arie/1 R. Bedell, Esq. cc: Clients