Britton

I. BACKGROUND

1 A. Factual Background 2 Plaintiff Cove Britton is a licensed architect residing and doing business in Santa Cruz 3 County, California. FAC ¶ 1. Plaintiff Matson Briton Architects, Inc. is a California corporation 4 doing business in Santa Cruz County, California. Id. Cove Britton is the president of Matson 5 Briton Architects, Inc. FAC at 12. County of Santa Cruz is a political subdivision of the State of 6 California. FAC ¶ 2. County of Santa Cruz Planning Department is an administrative department 7 within County of Santa Cruz. Id. ¶ 3. Defendants process permit applications for development 8 projects, and Plaintiffs “routinely handle” the submission of such applications to Defendants on 9 behalf of Plaintiffs’ clients. Id. ¶ 4. 10 On May 6, 2019, Plaintiffs received a written notice from Defendants that a permit 11 application was not complete, and that Plaintiffs’ appeal should be directed in a letter to the 12 Planning Director, pursuant to Santa Cruz County Code section 18.10.320 and California 13 Government Code section 65943. Id. ¶ 8. Plaintiffs allege that Defendants’ appeal procedure and 14 Santa Cruz County Code section 18.10.320 violate…