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Case 8:23-cv-00504 Document 1. Filed 03/20/23 Page 33 of 45 Page ID#:33 <br /> 1 Profit Entities providing medical services is that Non-Profit Entities provide medical <br /> 2 services to patients who generally cannot afford to purchase those services from For- <br /> a Profit Entities. In Santa Ana, the patients who typically visit Medical Offices operated <br /> 4 by Non-Profit Entities are (a) predominantly Latino immigrants with low incomes and <br /> 5 (b) homeless persons of various ethnicities. <br /> 6 M. The motivating intent, and effect, of the CUP Requirement enacted by the <br /> 7 Ordinances is to discriminate against the homeless, low-income, immigrant, and Latino <br /> 8 patients who are served by Medical Offices operated by Non-Profit Entities by depriving <br /> 9 them of the fundamental right of the opportunity to access healthcare from entities <br /> 10 willing to provide it, including the right to access reproductive healthcare. The <br /> 11 motivating factor and effect of the CUP Requirement is also to discriminate against the <br /> 12 Non-Profit Entities, themselves, based on their willingness to provide health care to such <br /> 13 patients. <br /> 14 133. The discriminatory CUP Requirement, both on its face and as applied, also <br /> 15 (1) infringes on and violates SOS's fundamental right of association and the <br /> 16 fundamental rights of its doctors, nurses, and other health care providers to privacy and <br /> 17 to freely associate with persons of their own choosing, guaranteed by the First and <br /> 18 Fourteenth amendments to the United States Constitution, and (2) infringes on and <br /> 19 violates the fundamental rights of SOS's patients to privacy and to freely associate with <br /> 20 persons of their own choosing, guaranteed by the First and Fourteenth amendments to <br /> 21 the United States Constitution by, among other things, interfering with their right to seek <br /> 22 health care, including reproductive health care, from doctors, nurses, and other health <br /> 23 care providers willing to provide it. <br /> 24 134. The CUP Requirement is not narrowly tailored, and does not serve any <br /> 33 _ <br /> Complaint of Share Our Selves <br />