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1 11. In fact, Valentin told RAMIREZ that the best thing that now-former Deputy Chief Jim <br /> 2 <br /> Schnabl ever did for the police department was to hire RAMIREZ. <br /> 3 <br /> 4 C. Initially, RAMIREZ Apparently "Passed" CITY's Police Chief's Gang-Like <br /> 5 "Loyalty" Tests. <br /> 6 12. Towards the end of February 2018, Valentin called RAMIREZ into his office to discuss <br /> 7 <br /> "loyalty" and to explain his understanding of the concept of "loyalty". <br /> 8 <br /> 9 13. During this same time frame,as RAMIREZ's then-supervisor Deputy Chief Jim Schnabl had <br /> 10 been on leave after being injured on duty,Valentin put RAMIREZ in charge of a proj ect known as Tri-Tech. <br /> 11 14. In mid-March of 2018, Valentin asked RAMIREZ to go photograph Schnabl while he was <br /> 12 <br /> teaching at a Tri-Tech conference. <br /> 13 <br /> 14 15. As it was well-known that Valentin greatly disliked both Schnabl(as well as former Deputy <br /> 15 Chief Doug McGeachy), it was obvious that Valentin's intent was to "catch" Schnabl doing something <br /> 16 "wrong" and to "gather evidence" against him while he was out on leave. <br /> 17 <br /> 16. Valentin made this request by asking: "Are you down for this?" This phrase struck <br /> 18 <br /> 19 RAMIREZ as odd coming from Valentin as she recognized it as gang term - often used to prove loyalty <br /> 20 where a more senior gang member asked an "underling" whether they were willing to do something <br /> 21 unsavory for the benefit of the gang. <br /> 22 <br /> 17. In retrospect, Valentin was clearly aware that what he had asked RAMIREZ to do was <br /> 23 <br /> 24 improper'. <br /> 25 <br /> 26 <br /> 27 <br /> 28 <br /> ' Had Valentin's request been legitimate, Valentin should have instructed Internal Affairs to take <br /> the photographs. This is just one of many examples of times when Valentin acts as if he can do what he <br /> wants, when he wants and how he wants and that normal procedures did and do not apply to him. <br /> 4 <br /> RAminzv. CrrYOFSANTAANA CASENO. <br /> COMPLAINT <br />