ELANA SHRIRA VS CITY OF LOS ANGELES, A MUNICIPAL CORPORATION

1 Petitioner challenges the approval by Respondent City of Los Angeles (“City” or

“Respondent”) of Transit Oriented Communities (“TOC”) Incentives for the 1050 La Cienega

Boulevard Project (“Project”). The City Planning Commission (“CPC”) violated the Los

Angeles Municipal Code (“LAMC”) when it denied Petitioner’s appeals and granted the TOC

Additional Incentive for reduced yards.

The CPC’s decision to approve the TOC Additional Incentive for reduced yards

10 violates the LAMC. The CPC affirmed the Director’s Letter of Determination (“LOD”) which

11 exceeded their scope of authority by purporting to grant the right to substantially change the

ahr 12 approved project in violation of the LAMC. Moreover, the CPC’s findings lack substantial

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zn? 13 evidence to support the findings required for granting TOC Additional Incentives. Specifically,

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14 there was substantial evidence that the incentives will have a specific adverse impact upon

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oa> 15 public health and safety or the physical environment, which could have been mitigated without

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£2 16 rendering the development unaffordable to Very Low, Low and Moderate income households.

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17 3 Petitioner seeks a Peremptory Writ of Mandate under California Code of Civil

18 Procedure section 1094.5 directing Respondent to vacate, rescind and set aside approval of the

19 TOC Base and Additional Incentives because Respondent failed to comply with CEQA and

20 violated the LAMC.

21 4 The City’s approval of the Project will cause Petitioner irreparable injury for

22 which Petitioner has no adequate remedy at law. Petitioner will be irreparably harmed by the

23 City’s actions in approving the Project.

Causes of Action

Superior Court of California,

County of Los An ge les

3/11/2024 9:29 PI

David W. Slayton,

Executive Officer/Clerk of Court,

By R. Perez, Deputy Clerk