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MANI BROTHERS REAL ESTATE GROUP v. CITY OF LOS ANGELES
Petitioners' repeated objections to project addendum voiced at various public meetings were sufficient to satisfy CEQA exhaustion requirement where agency did not provide for a public comment period or provide the public with notice that it was preparing an addendum. City's decision to approve modified project with addendum rather than to require a supplemental EIR was unsupported by substantial evidence with respect to impact on police services where the addition of over 800 residential units and features designed to encourage pedestrian use of the area established that changes in the modified project would increase the original project's impact, but SEIR was not required to address other issues where there was substantial evidence that modified project's impacts would be no more severe than original project's as to those aspects.

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