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