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Correspondence - #21
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08/29/2023 Special
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Correspondence - #21
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10/25/2023 12:56:43 PM
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8/28/2023 3:28:39 PM
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City Clerk
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8/29/2023
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LOFTIN I BEDELL P.C. <br />City of Santa Ana City Council <br />c/o Office of City Clerk <br />City of Santa Ana <br />August 28, 2023 <br />Page 9 of 10 <br />provided herein and in the records for the hearings related to this matter, the coordination with <br />and consideration of the requirements of the rental unit owners has not been welcomed or <br />considered. <br />H. This is standard boiler plate language, which has now been discussed and it has been established <br />since September 2021 to the present date Opposing Agenda Item 21, that the facts and law do <br />not support the 2022 Ordinance as implemented and drafted nor the proposed Amendment to said <br />ordinance. <br />I. This is standard boiler plate language, which has now been discussed and the record has <br />established since September 2021 to the present date Opposing Agenda Item 21 that the facts <br />and law do not support the 2022 Ordinance as implemented and drafted nor the proposed <br />Amendment to said ordinance. <br />J. The only citizen or interested party "testimony" the City Council will deem required to establish <br />the necessary Findings is "oral testimony." The City Council will not consider the record from <br />the other hearings, written testimony, contradicting documents among other customary and <br />ordinary acceptance of evidence related to findings. submitted for consideration and as a basis <br />for this Amendment to the Ordinance. This requirement further invalidates the Notice of the <br />Meeting and the Agenda. <br />Section 2. This is boilerplate customary language, except the modification to limit the record <br />to those persons who provide oral testimony with limited time for presentation. The truth of the recitals <br />and statements of fact need to be established through the record. The assumption is that the goal of <br />"truthfulness" is being advanced by only permitting oral testimony with time limits which by necessity <br />excludes contrary documentary or detailed evidence and relies on the Staff Report and attachments. <br />Section 3. As to the substance of each section, except Section 7 of the RSO JCEO, the <br />opposition, objections and other assertions related to each of the provisions, including those provisions <br />listed here, have been incorporated into this Record and are set forth in the pending litigation, which <br />public record portion of the litigation record has likewise been incorporated into this Record. As to <br />Section 7, this prohibition on legislative action by a future council is questionable and from a literal <br />reading prohibits compliance with Federal and State statutes including the implementing regulations and <br />case law interpretations and orders as applicable as of this writing and as may be amended from time to <br />time. <br />For the reasons set forth above, there has been no justification, evidence or other basis for requiring a <br />supermajority vote to amend the RSO JACO Ordinance presented. <br />
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