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1 11. During this time,myriad claims have been made against CITY as a result of Chief Valentin's <br /> 2 <br /> (and those acting on his behalf) unlawful acts of, inter alia, harassment (including claims of sexual <br /> 3 <br /> 4 harassment), discrimination and retaliation. <br /> 5 12. As CITY is well aware from numerous complaints and from other publicly-filed lawsuits, <br /> 6 although an effective police department functions as a whole,it has been a common recent practice(and the <br /> 7 <br /> subject of much ongoing discussion and concern between CITY's police department personnel) for Chief <br /> 8 <br /> 9 Valentin(and others at his behest)to attempt to force personnel to choose between two"gangs"or"camps"- <br /> 10 what is referred to as "the Valentin camp"or what Chief Valentin perceives to be the other"gang"/"camp" <br /> I 1 allegedly led by then-POA President Gerry Serrano.It became a very hostile and dysfunctional atmosphere <br /> 12 <br /> as "the Valentin camp"attempted to pigeonhole/ostracize employees as belonging to one camp or another. <br /> 13 <br /> 14 Many employees became extremely fearful that,if they were labeled as belonging to the"camp"associated <br /> 15 with the POA/Serrano,they would be retaliated against,denied promotional opportunities or possibly even <br /> 16 disciplined, demoted and/or terminated for minor infractions. <br /> 17 <br /> 13. KACHHUSKY,as an active POA Board member who had been promoted to Executive Board <br /> 18 <br /> 19 Secretary in 2020,was quickly characterized by Chief Valentin(and those acting on his behalf)as being part <br /> 20 of"the POA camp" and not part of"the Valentin camp". <br /> 21 14. Chief Valentin has been repeatedly accused of not simply allowing but fostering these <br /> 22 <br /> "camps"within the Police Department.Additionally,Chief Valentin has been repeatedly accused of actively <br /> 23 <br /> 24 retaliating/discriminating against or harassing those who did not choose to be in his "camp" and of <br /> 25 retaliating/discriminating against or harassing those who chose to even associate with those perceived to be <br /> 26 in the other"camp".It is also common knowledge that those perceived to be in the"Valentin camp"-even <br /> 27 <br /> those who repeatedly and significantly violate laws, statutes, regulations and policies - are not <br /> 28 <br /> charged/investigated/disciplined for such conduct while those not perceived to be in the "Valentin camp" <br /> 4 <br /> KACAIRISKY v. CFFY OF SANTA ANA CASE No. <br /> COMPLAINT <br />