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Brooke Weitzman

for Elder Law and Disability Rights Center

WHEREFORE, Plaintiffs pray as follows:

1. For a temporary restraining order, preliminary and permanent Read more

WHEREFORE, Plaintiffs pray as follows:

1. For a temporary restraining order, preliminary and permanent injunction, enjoining and restraining Defendant Orange County from limiting the hours or otherwise closing the Santa Ana Riverbed bike path for any purpose, including maintenance, until an alternative location is provided for the 800-1200 homeless people currently there.

2. For a temporary restraining order, preliminary and permanent injunction, enjoining and restraining Defendant Orange County from citing individuals for trespassing or nuisance in the Santa Ana Riverbed under Penal Code Sections 602 & 555, for nuisance based on the presence of themselves and/or their property under Penal Code Sections 370 and 372 and absent an actual obstruction of the Riverbed or the trail, and from enforcing County of Orange Ordinance §2-5-95.

3. For a temporary restraining order, preliminary and permanent injunction, enjoining and restraining Defendants City of Anaheim, City of Costa Mesa, and City of Orange from citing or arresting individuals for violations of camping laws, including Anaheim Municipal Code 11.10, Orange Municipal Code §12.66.030, Costa Mesa Municipal Code §11-304, and/or County of Orange Ordinance §2-5-95.4. For a temporary restraining order, preliminary and permanent injunction, enjoining and restraining Defendant City of Anaheim from enforcing its loitering ordinance, §7.28.010.

5. For a temporary restraining order, preliminary and permanent injunction, enjoining and restraining Defendants City of Anaheim, City of Costa Mesa, and City of Orange from stopping and detaining homeless individuals without probable cause and from threatening homeless persons with tickets or citations if they continue to be present in public space in that city.

6. For a declaratory judgment that Defendant’s policies, practices and conduct as alleged herein violate Plaintiffs’ rights under the United States and California constitutions and the laws of California;

7. For damages to the individual plaintiffs in an amount to be determined according to proof based on their federal claims only;

8. For costs of suit and attorney fees as provided by law;

9. For such other relief as the Court deems just and proper.

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