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transportation, thereby jeopardizing their ability to stay employed. Approximately 95% <br /> of Ideal Option's patients are working and are not homeless. Of that group, 70% are <br /> among the working poor. When access to treatment is difficult these individuals are at <br /> risk for losing their jobs, giving up, becoming homeless and overdosing. <br /> Overwhelmingly, these individuals have other family members as well who are greatly <br /> impacted by such barriers to treatment. When a patient must regularly spend time <br /> traveling to medical clinics, counseling services, pharmacies and courts while trying to <br /> hold down a job, they are unlikely to seek or continue treatment. <br /> Ideal Option practitioners know that its patients have a unique set of symptoms,causes, <br /> diagnoses and treatments when compared to the general population. They work closely <br /> with each individual to strengthen the efficacy of their treatment. In addition to OBOT <br /> programs, Ideal Option's designated case workers maintain close contact with each <br /> person to ensure they are receiving the care they need. Ideal Option works to remove <br /> barriers patients face, including treatment that allows them to continue working and <br /> increasing functionality in all areas of their lives. To do so, the importance of location <br /> cannot be overstated. <br /> SUPPORT FOR EVERETT LEADERSHIP: <br /> The City of Everett has been a national leader in its commitment to solve the opioid crises. <br /> From its landmark lawsuit against Purdue Pharma to the City's Safe Streets Plan,Everett <br /> has sought to address "the effects of rampant drug use on our streets, and our <br /> neighborhoods and business owners feel the impact as well."2 City Officials have <br /> acknowledged that systems have been overwhelmed by this crisis and capacity is lacking <br /> to respond to and treat the individuals who are suffering from addiction in Everett. Ideal <br /> Option has the capacity, the tools and the track record to significantly address Everett's <br /> lack of treatment capacity if we are allowed to occupy our leased space at 2808 Hoyt. <br /> LEGAL ISSUES: <br /> Apart from our grandfathering, vesting and exemption arguments, we have received <br /> legal opinions indicating that the current moratorium and contemplated prohibition are <br /> constitutionally suspect under the law. Numerous courts, including federal courts in the <br /> Third,Sixth,and in the Ninth Circuit,where Washington is located,have found that state <br /> and local ordinances which single out methadone or medication assisted treatment <br /> ("MAT")clinics and either prohibit them or restrict their locations violate the Americans <br /> with Disabilities Act (the "ADA") and the Rehabilitation Act. See, e.g., New Directions <br /> Treatment Servs. v. City of Reading, 490 F.3d 293 (3d Cir. 2007); MX Group v. City of <br /> Covington,293 F.3d 326(6th Cir.2002); Bay Area Addiction Research &Treatment, Inc.v. City <br /> of Antioch, 179 F.3d 725 (9th Cir. 1999). <br /> 2 From City of Everett News Release(Jan. 19,2017) <br />