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T LOFTIN I BEDELL <br /> LATTORNEYS AT LAW <br /> Via Electronic Transmission (eCommentAsanta-ana.org) <br /> September 19, 2023 <br /> Honorable Mayor and Council Members <br /> City of Santa Ana <br /> c/o Office of the City Clerk <br /> c/o City Attorney, Sonia R. Carvalho <br /> 20 Civic Center Plaza M-30 <br /> Santa Ana, CA 92701 <br /> Re: Hearing Date: City Council Meeting, September 19, 2023 <br /> Agenda Item 26: Opposed <br /> Request: Amend the Existing Ordinance No. 3027 to Comply with Existing <br /> State and Federal Statutory, Regulatory and Case Law. <br /> Dear Honorable Mayor Valerie Amezcua,Mayor Pro Tem Jessie Lopez, and Councilmembers Thai <br /> Viet Phan, David Penaloza, Phil Bacerra, Johnathan Ryan Hernandez and Benjamin Vazquez: <br /> This Firm represents Kingsley Management Corporation, and its affiliated companies, which <br /> manage, own, and operate, with care and concern for the Homeowners (residents), multiple <br /> mobilehome parks within in the City of Santa Ana. <br /> This Firm, on behalf of Kinsley Management Corporation and its affiliated companies, has <br /> noted, commencing January 2, 2020, to the present, violations of California Government Code <br /> sections 54950 and 36934 in various communications, correspondences, and statements presented to <br /> the City Council at various stages of and in relation to the City Council's consideration and adoption <br /> of the various rent control and eviction protection ordinances and related policies. Such prior <br /> violations and deficiencies noted previously in the public record are incorporated herein as though <br /> set forth in full, which were presented in the following public proceedings: (i)City Council Hearings <br /> held on September 21, October 5 and November 19, 2021 ("2021 Record") for the adoption of <br /> Ordinance Nos. NS-3009 and NS-3010 ("2021 Ordinances"); (ii) City Council Hearings held on <br /> October 5, 2022 and October 18, 2022 ("2022 Record")for the adoption of Ordinance No.NS-3027 <br /> ("2022 Ordinance") which fully replaced the 2021 Ordinances; and (iii) adoption all regulations, <br /> policies,retention of third-party vendors/agents,including the adoption of Resolutions related thereto <br /> ("2023 Resolution"). The public records commencing approximately January 2, 2020 of the <br /> meetings, communications and hearings include all memorandums, electronic transmissions, letters <br /> between and among staff, consultants, and members of the public, excepting attorney-client <br /> privileged materials; and between any City staff person, consultant or elected or appointed official <br /> with any third party, and all opposition letters, emails and verbal presentations and the video <br /> recording of those hearings are hereby incorporated for the record in this matter. <br /> 2540 Gateway Road • Carlsbad • California • 92009 <br /> T: 760.431.2111 9 Direct: 760.444-4040 • www.loffnbedell.com • Sue@loftinbedell.com <br />