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1 1. KACHIRISKY is an individual who, at all times relevant herein, is and was employed as a <br /> 2 <br /> police officer by Defendant City of Santa Ana("CITY"or"Defendant")at CITY's business office located <br /> 3 <br /> 4 in the County of Orange, State of California. <br /> 5 2. KACHIRISKY alleges that CITY is a municipality doing business in the County of Orange, <br /> 6 State of California. The Santa Ana City Council, as the governing body of the City of Santa Ana, acts, <br /> 7 <br /> represents, and implements policy on the behalf of CITY. <br /> 8 <br /> 9 3. Defendants CITY and DOE Defendants 1 through 50 are hereinafter sometimes collectively <br /> 10 referred to as "DEFENDANTS". <br /> 11 4. On May 4,2023,KACHIRISKY exhausted his administrative remedies by causing CITY to <br /> 12 <br /> be served with a Government Claim. On May 9, 2022, although CITY, via its Third Party Administrator, <br /> 13 <br /> 14 acknowledged receipt of the claim and stated that "(a)n investigation will be conducted, and upon <br /> 15 conclusion,there will be further communication with your office",neither KACHIRISKY nor his counsel <br /> 16 was ever contacted and the claim was denied by operation of law. <br /> 17 <br /> 5. KACHHUSKY is presently not aware of the true names and/or capacities of Defendants <br /> 18 <br /> 19 DOES 1 through 50,inclusive,and therefore sues said Defendants by such fictitious names.KACHIRISKY <br /> 20 is informed and believes and upon such information and belief alleges that said fictitiously named <br /> 21 Defendants are directly and proximately responsible for the injuries and damages alleged herein. <br /> 22 <br /> KACHIRISKY will amend this Complaint to allege the true names and capacities of said fictitiously named <br /> 23 <br /> 24 Defendants when, and if, ascertained. <br /> 25 <br /> 26 <br /> 27 <br /> 28 <br /> z <br /> KACAIRISKY v. CFFY OF SANTA ANA CASE No. <br /> COMPLAINT <br />