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1 6. RAMIREZ is informed and believes, and upon such information and belief alleges,that, at 2 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. After Almost Three Decades of Exemplary Public Service Employment, 11 RAMIREZ was Recruited by CITY to be its Police Administrative Manager. 12 7. On July 3,2017,following decades ofpublic service,RAMIREZ began her careerwith CITY 13 14 as the Police Administrative Manager after being actively recruited from her prior employment. 15 8. During RAMIREZ's 32 years of service in the law enforcement community(five years with 16 CITY), RAMIREZ was consistently a loyal and hard-working employee who received exemplary 17 performance evaluations. 18 19 9. Despite this, on July 7, 2022, RAMIREZ was unlawfully constructively terminated, after 20 suffering retaliation, discrimination and harassment due to circumstances entirely unrelated to her 21 performance. CITY's termination of, and discrimination, harassment and retaliation against, RAMIREZ 22 violates California law, City's own Municipal Code and policies and procedures and RAMIREZ's civil 23 24 service rights. 25 B. Initially, CITY's Police Chief was Thrilled with RAMIREZ and her Work. 26 10. More specifically,byway of brief background, Chief of Police David Valentin was initially 27 obviously very comfortable with RAMIREZ when she was hired. 28 3 RAminzv. CITYoFSANTAANA CASENo. COMPLAINT