UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

Defendant City is responsible for passing the OSV Ordinance and the 1153 Human Habitation Ordinance, and through its agents the Mayor, City Council, City Attorney, 1164 Parking Enforcement, Police Department, and Police Chief enforces the Human Habitation Ban 1175 and the OSV Ban and cites Plaintiffs and Class members for violations. [...] The Class meets the 2264 numerosity requirement based on community records and the City’s estimates of a daily count 2275 residency of seventy-five RVs parked on City streets prior to the OSV Ordinance. [...] Tellingly, the Ordinance’s whereas clauses noted 1153 “the City has experienced a significant increase in the number of oversized vehicles, including 1164 motorhomes and trailers, that are regularly or routinely parked on City streets for long periods of 1175 time.” The Ordinance also stated the City had to “address complaints relating to the parking of 1186 oversized vehicles.” 1197 52. [...] In other neighborhoods, the City has placed a sign at the entrance to the 4 3 neighborhood prohibiting RV parking at only some of the streets in the neighborhood. [...] Worsening the unclarity of where the OSV Ban applies, the City has enforced the 119 OSV Ban in a discriminatory matter aimed to intimidate and push out the vehicularly housed.