10.  This matter is properly maintainable as a class action pursuant to Fed. R. Civ. P.  23(a) in that:  (a) The Putative Class, which potentially includes in excess of sixty persons, is  so numerous that joinder of all members is impracticable;  (b) There are substantial questions of law and fact common to the Putative Class;  (c) The claims of the representative parties are typical of the claims of the  Putative Class; and  (d) The representative parties will fairly and adequately protect the interests of the  Putative Class.   12.  The case is properly maintainable as a class action pursuant to Fed. R Civ. P.  23(b)(3), in that questions of law or fact common to class members predominate over any questions  affecting only individual class members, and a class action is superior to other methods for fairly  and efficiently adjudicating the controversy.   13.  The relief sought in this action will effectively provide relief to all of the class  members.   14.  There are no unusual difficulties foreseen in the management of this class action.  18.  Once Defendant had granted an application in the exercise of its discretion, its  Streets Department was required to erect a sign at the location of the exclusive electric vehicle  parking space, designating it as such.   19.  After the adoption of Section 12-1131, and in reliance thereon, Plaintiffs and the  members of the Putative Class each took a series of steps in order to apply for approval of a  reserved electric vehicle parking space.   20.  Plaintiffs and members of the Putative Class each applied to the Philadelphia  Parking Authority ("PP A") for approval of a designated electric vehicle parking space, paid all  fees associated with such applications, and submitted all materials in support of their respective  applications as required by the PPA and Section 12-1131, including but not limited to proof that  an electric vehicle had been purchased or leased and registered with the Pennsylvania Department  of Transportation to a resident of each of their respective homes.   22.  By installing the curbside electrical vehicle chargers, solely at their own cost and  expense, Plaintiffs and the Putative Class made substantial improvements upon public property.   23.  In response to the respective applications of the Plaintiffs and the Putative Class,  the PPA granted its approval for the exclusively reserved, designated electric vehicle parking  spaces, and Plaintiffs and the members of the Putative Class thus obtained such a parking space  at their place of residence, all in conformity with Section 12-1131.   24.  On or about April 6, 2017, the City, through City Council, and without due process  to the Plaintiffs or members of the Putative Class, passed Bill No. 170093-A, which amended  Section 12-1131 by imposing a "moratorium on new electric vehicle parking spaces, under certain  terms and conditions." The amendment further changed Section 12-1131 ( c ), providing that instead  of the Streets Department posting signs at the existing approved electric parking spaces that  prohibited all parking in such spaces by non-electric vehicles, the signs to be posted at the spaces  now only reserved those spaces for the use of electric vehicles during the hours from 6:00 p.m. to  6:00 a.m. Pursuant to the amendment, City Council further provided that the signs were to  specifically indicate that non-electric vehicles were permitted to park in the previously  exclusively-reserved spaces for two hours at a time during the hours from 6:00 a.m. to 6:00 p.m.   26.  The City thus amended Section 12-1131, depriving each Plaintiff and member of  the Putative Class of the exclusively-reserved electric vehicle parking spaces which they had  previously obtained upon application and compliance \vith the City's ordinance, and upon  expending substantial funds in furtherance of such applications. Instead, under the revised version  of Section 12-1131, for twelve hours of every day, non-electric vehicles are now permitted to  occupy the parking spaces that were previously exclusively designated for electric vehicles, thus  depriving Plaintiffs and the Putative Class of access to their electrical vehicle chargers.  27.  Plaintiffs hereby incorporate the above paragraphs as if fully set forth herein.   28.  Each Plaintiff and member of the Putative Class applied for a reserved electric  vehicle parking space according to the process and standards established and required by the City,  as articulated in Section 12-1131, before it was subsequently amended.   29.  In so doing, each Plaintiff and Putati,,e Class member expended substantial sums  of money so as to comply with the requirements of Section 12-1131, and made substantial  improvements upon public property.   30.  Pursuant to Section 12-1131, the City approved the application of each Plaintiff and  Putative Class member and designated a reserved electric vehicle parking space in close proximity  to their respective homes.   32.  By unilaterally amending Section 12-1131 so as to allow non-electric vehicles to  park in the parking spaces that previously were reserved exclusively for electric vehicles,  Defendant has unlawfully deprived each Plaintiff and the Putative Class members of his or her  protectable property interest without due process.   33.  Defendant's amendment to Section 12-1131 reflects its policy, practice, procedure  and/or custom, and exhibits deliberate indifference to the constitutional rights of Plaintiffs and the  Putative Class.   34.  Defendant's actions violated Plaintiffs' and the Putative Class's constitutional due  process rights and have caused them injury.  35.  Plaintiffs hereby incorporate the above paragraphs as if fully set forth herein.   36.  Defendant's actions have operated to treat Plaintiffs and the Putative Class  differently than other similarly situated persons.   37.  There is no permissible basis for Defendant's arbitrary and capricious  discrimination toward and against Plaintiffs and the Putative Class.   38.  Defendant's actions violated the constitutional equal protection rights of Plaintiffs  and the Putative Class, and caused injury to each of them.  40.  Plaintiffs and the Putative Class have made substantial improvements upon public  property.   41.  Defendant appreciated or had knowledge of the benefit conferred upon it by  Plaintiffs and the Putative Class.   42.  By stripping Plaintiffs and the Putative Class of their exclusively reserved electric  vehicle parking spaces after they had expended substantial funds installing the electrical charging  stations servicing those spaces, Defendant has caused Plaintiffs and the Putative Class to lose the  benefit and value of their respective investments in the charging stations, and the improvements  they have made upon public property.   43.  At the same time, Defendant unjustly has gained the value of and been enriched by  these improvements.   44.  Plaintiffs and the Putative Class have been injured by Defendant's actions in this  regard.  