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Request for Reasonable Accommodation <br />Page 2 of 3 <br /> <br />Requests for Reasonable Modifications <br />Specifically, we request that: <br /> <br />1. The City provides an accessible center where our clients can manage <br />their disabilities – including mental health services for chronically <br />homeless individuals with severe mental health disabilities – and access <br />life-sustaining resources like food, hygiene, and rest. <br /> <br />2. The City collaborate with the County of Orange to keep MHA-OC open <br />until a suitable alternative location or service is provided. <br /> <br />3. The City ensures these individuals are connected to permanent housing <br />options that provide mental health and essential services. <br /> <br />This request for reasonable modifications is made under Title II of the <br />Americans with Disabilities Act (“ADA”), Section 504 of the Rehabilitation Act, <br />California Disabled Persons Act, Gov. Code Section 11135, and all other <br />applicable state and federal laws. Notably, the Ninth Circuit has recognized that <br />when specialized medical services are closed to individuals with disabilities who <br />need them, it deprives those individuals of an equal opportunity to benefit from <br />services, effectively denying them access to government-provided services due <br />to their unique needs and is a violation of the ADA. Rodde v. Bonta, 357 F.3d <br />988, 998 (9th Cir. 2004). <br /> <br />Facts Relating to Individuals Clients <br /> <br />We represent the following individuals with disabilities and their requests for <br />reasonable modifications: <br /> <br />E.A. is a 72 year old woman with physical and developmental disabilities. After <br />the recent death of her husband, she became unhoused and was introduced to <br />MHA-OC by a friend. She attends MHA-OC daily for a sense of community, <br />access to mental health services, and relies on the staff to help her manage <br />her medical appointments. E.A. also has limited mobility. Because of this, <br />MHA-OC provides her with transportation, meals, a shower, and safe place to <br />rest. These services are crucial for her mental and physical well-being as she <br />waits for placement into a housing program.