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LOFTIN|BEDELL P.C. City of Santa Ana c/o City Clerk and City Attorney June 17, 2024 Page 3of 3 (“2023 1st Amendment Hearings”) and the opposition orally and in writing, including the correspondences dated August 28, 2023 from Sue Loftin, Loftin|Bedell P.C. and Terry Dowdall, Dowdall Law to the attempted modification of the Ordinance, see record for City Council Hearing September 29, 2023 and October 2, 2023; and(iv) adoption all regulations, policies, retention of third- party vendors/agents, including the adoption of all Resolutions from 2021 to current date including all oppositions related thereto (“2023 Resolutions”). The public records commencing approximately January 2, 2020 of the meetings, communications and hearings include all memorandums, electronic transmissions, letters between and among staff, consultants, and members of the public, excepting attorney-client privileged materials; and between any City staff person, consultant or elected or appointed official with any third party, and all opposition letters, emails and verbal presentations and the video recording of those hearings are hereby incorporated for the record in this matter. Additionally, the Public Records including all pleadings for cases the two cases naming the City of Santa Ana as the defendant in the Federal District Court Cases Nos. 8:22-cv-00076-CJC-JDEx and 8:33-cv-00102- CJC-JDE and the Ninth Circuit Court of Appeal for Case No. 8:22-cv-00076-CJC (JDEx) are hereby incorporated into this record. Kingsley Management Corporation and its related affiliated companies have consistently said the City has the right to adopt Rent Control (rent stabilization) and Just Cause Eviction Ordinances in concept. Rather, the purpose of all opposition to the Ordinances, whether at City public hearings including all the written and oral objections, or in Federal Court, has been to require the Ordinances to comply with the State and Federal Statues including the respective regulations and case law specifically applicable to the Mobilehome Park Community. The laws applicable to the Mobilehome Park Community are significantly different than for all other residential rental housing and such differences have been largely ignored by the City in adopting the Ordinances, despite repeated and detailed language including proposed modifications to the Ordinances being provided to the City to bring the Ordinances in line with such bodies of law. Sincerely, LOFTIN | BEDELL P.C. By: L. Sue Loftin, Esq. cc: Client (Via Email) City Council Members (Via Overnight Mail) Honorable Mayor Valerie Amezcua Mayor Pro Tem Jessie Lopez Council Members Thai Viet Phan, Genjamin Vazquez Phil Bacerra Johnathan Ryan Hernandez David Penaloza KMC700SAO1.010