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I iv. An award of such other and further relief as the court deems just and <br /> 2 proper. <br /> 3 4. For the Fourth Cause of Action for Declaratory and Injunctive Relief for <br /> 4 Violation of Due Process: <br /> 5 i. A declaration finding that STRs were permitted under the Santa Ana <br /> 6 zoning code as it existed prior to adoption of Ordinance No. NS-3061, <br /> 7 and thus, that STRs are a legal nonconforming use under the Santa Ana <br /> 8 zoning code as amended by Ordinance No. NS-3061; <br /> 9 ii. An injunction restraining the City and its agents, servants, and <br /> 10 employees, and all others acting in concert with the City, from taking <br /> 11 any action to implement Ordinance No. NS-306 and a permanent <br /> 12 injunction setting aside Ordinance No. NS-3061 and holding unlawful <br /> 13 Ordinance No. NS-3061; <br /> 14 iii. An award of costs of suit and litigation expenses, including, without <br /> 15 limitation, attorneys' fees incurred herein as permitted or required by <br /> 16 law; and/or <br /> 17 iv. An award of such other and further relief as the court deems just and <br /> 18 proper. <br /> 19 5. For the Fifth Cause of Action for a Writ of Mandate Due to Abuse of Discretion: <br /> 20 i. A writ of mandate directing the City to rescind and set aside its approval <br /> 21 of Ordinance No. NS-3061 and to undertake the required review of the <br /> 22 relevant law and evidence; <br /> 23 ii. An injunction restraining the City and its agents, servants, and <br /> 24 employees, and all others acting in concert with the City, from taking <br /> 25 any action to implement the Ordinance No. NS-3061 pending a review <br /> 26 of all applicable law and facts; <br /> 27 <br /> 28 <br /> VERTFTED PETTTTON FOR WRTT OF MANDATE <br /> 27 AND COMPLATNT <br />