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1 6. KACHHUSKY is informed and believes,and upon such information and belief alleges, that, 2 at all relevant times, each and every Defendant was a principle, agent, employer, employee, manager, 3 4 supervisor, officer, shareholder and/or owner of each and every other Defendant, and each and every act 5 and/or omission of each and every Defendant occurred by and through the governing body and/or 6 management of the Defendant and within the course and scope of such agency and/or employment and/or 7 was approved and/or ratified by the acts and/or omissions of each and every other Defendant. 8 9 FACTUAL BACKGROUND 10 A. Plaintiff KACHIRISKY. 11 7. By way of brief background,after serving honorably for four years in the United States Navy, 12 in January of 2005,KACHHUSKY was hired by the California Highway Patrol where he worked as a Patrol 13 14 Officer for over three years. 15 8. In February of 2008, KACHIRISKY was hired by CITY as a Police Officer. In November 16 2017,after serving in various capacities,KACHIRISKY was promoted to Corporal. Since February of 2019, 17 KACHHUSKY has served as a Lead Corporal, during which time he received consistently Outstanding 18 19 Performance Evaluations and various recognitions/awards. 20 9. Since 2020, KACHIRISKY has been an Executive Board member of the Police Officers 21 Association ("POA"), serving as the elected POA Vice President until his July/August 2023 elevation to 22 POA President. Additionally, as discussed in more detail below, KACHIRISKY was instrumental in 23 24 coordinating the successful September 1,2021 Vote ofNo Confidence against Police Chief David Valentin. 25 B. CITY's Police Chief David Valentin and the "Gangs/Camps" he Fosters. 26 10. Since 2017, David Valentin has been CITY's Police Chief. 27 28 3 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT