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1 MacArthur Place <br />Suite 200 <br />Santa Ana, California 92707 <br />Phone: 714.852.6800 <br />Fax: 714.852.6899 <br />www.AlvaradoSmith.com <br />Kevin A, Day <br />(714) 852-6800 <br />kday@AlvaradoSmilh.com <br />VIA HAND DELIVERY <br />&VARADOSMITH <br />A PROFESSIONAL CORPORATION <br />INCLUDING PROFESSIONAL CORPORATIONS <br />March 15, 2016 <br />Jose Sandoval Maria D. Huizar <br />Chief Assistant City Attorney City Clerk <br />City of Santa Ana City of Santa Ana <br />20 Civic Center Plaza, M-29 20 Civic Center Plaza, <br />Santa Ana, CA 92701 Santa Ana, CA 92701 <br />Re: Bristol Street Improvements Project — Jeronimo Chavez <br />1415 N. Bristol, Santa Ana, CA 92706 — APN: 405-252-22 <br />ITEM 75-C On The City Council Agenda <br />Dear City of Santa Ana: <br />Los Angeles <br />213.229.2400 <br />San Francisco <br />415.624.8665 <br />Raymond G. Alvarado, <br />1936-2014 <br />This letter is intended as written challenge to the City of Santa Ana's potential adoption <br />of a Resolution of Necessity to condemn Mr. Chavez's property located at 1415 N. Bristol, Santa <br />Ana ("Subject Property") as a component of the Bristol Street Improvements Project ("Project"). <br />The City's stated intent to use the power of eminent domain to acquire the Subject <br />Property for the Project was clearly announced via letter from the City on October 1, 2013. The <br />letter followed multiple pronouncements from the City regarding the acquisition of the Subject <br />Property, to include clear statements that designated the property for a complete acquisition even <br />before the scope of the Project was modified to demonstrate any public need or necessity for <br />more than the 12 feet of right of way slated for actual use in the Project. This October 2013 <br />letter included an offer to acquire the Subject Property at a claimed appraised value that was <br />below market value at the time. Additionally, while the City offered to acquire Mr. Chavez's <br />real property interests in October 2013, it did not provide any notice of eligibility for relocation <br />of his operating business. <br />As the City's October 2013, June 2014 and November 2015 offer letters sought to acquire <br />the entirety of the Subject Property, Mr. Chavez would obviously be forced to relocate his <br />business, and would qualify as a displaced person per Government Code §§ 7260 and 7262. As <br />specifically set forth in Government Code §7262(a): <br />"Whenever a program or project to be undertaken by a public <br />entity will result in the displacement of any person, the displaced <br />4050975.1 —N1475.1 <br />