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1 <br />2I <br />3 <br />4 <br />5 <br />6I <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />15 <br />20 <br />into law Amendment A-56-5 and place among the ora.inances of the City of <br />San Leandro an ordinance reclassifying the ;property at 260 vv'est Juana fiCo-n <br />an R-3 zone to a C-1 zone; that saic: clemanc+s of petitioner have Ls <br />refused. <br />I viii <br />That the refusal to act and enact on the part of the 11;ity Council is <br />unreasonable, arbitrary, capricious, and. zleprives petitioner of its prop- <br />erty vAthout (7'Aie process of law; that petitioner has no plain, speedy and <br />adequate remedy at law wherebythe L,ity Got-uicil can re co-,T pelle ' to pass <br />an ordinance enacting Amendment A-56-5 into later. <br />'WHEREFORE, petitioner -o , ay s, etc. <br />AS AND FOR A S LG'%-_ND, SLPA':.A1 ' AND DISTINCT CAUSE CF <br />AGTIGN against responc_ents herein, petitioner alleges as follows: <br />I <br />Incorpo:cates by reference and repleae s as though fully set forth <br />herein Paragraphs I through an- including 1-�VIII of the first cause of action. <br />II <br />That an actual controversy has arisen between the petitioner herein <br />and respon-clients relating to the legal rightsof petitioner in connection with <br />Building Per.tnit No. 9�a5; that the purported revocation of said pernut was <br />22 ' basel-I on the fact that a cor naercial type of building intender. fo.e commer- <br />23 c_ d use was to be built on land. in an : -3 zone; that in view of the Lacts <br />241 hereinabove stated your petitioner _`esiras a declaration of its rights undeA <br />25 anci by virtue of having obtainer:. Building hermit No. =995. <br />26' <br />27' <br />28, <br />29 <br />30 <br />31 <br />32 <br />`1z''HFREFCRE, your petitioner prays as follows: <br />1. flor the court to grant, issue anec awarc an alternative Vi rit of <br />Mandate to the Gity Council of the City of San Leandro and to Thomas C. <br />Knick, ,lack D. Maltester, Valance Gill, P.11liam Swift, Joseph 0. Delliri, <br />Albert Kant anL. James R. Frazier, members thereof, compelling and <br />commanding sai ' City Council, and each member thereof, to pass an <br />ordinance enacting into law Amendnnent A-56-5, or such other air.,.enc:m.e: <br />SPRUANCE S SIMONIAN <br />ATTORNEYS AT LAW <br />1514 WASHINGTON AVE. <br />PELTON CENTER <br />SAN LEANDRO, CALIF. <br />LOCKHAVEN 9-1301 <br />10. <br />