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1 1. VALDEZ is an individual who,at all times relevant herein,was employed by Defendant City <br /> 2 <br /> of Santa Ana("CITY"or"DEFENDANT") as a Police Officer at CITY's business office(s)located in the <br /> 3 <br /> 4 County of Orange, State of California. <br /> 5 2. VALDEZ alleges that CITY is a municipality doing business in the County of Orange, State <br /> 6 of California. The Santa Ana City Council,as the governing body of the City of Santa Ana,acts,represents, <br /> 7 <br /> 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 August 8,2023,VALDEZ exhausted her administrative remedies by causing CITY to be <br /> 12 <br /> served with a Government Claim. CITY failed to respond to VALDEZ's Government Claim which was <br /> 13 <br /> 14 thereafter denied by operation of law. Additionally on or about July 28,2023,VALDEZ filed a Complaint <br /> 15 with the California Civil Rights Department and,on August 8,2023,VALDEZ caused both her Complaint <br /> 16 and the resulting Right-to-Sue Notice to be served on CITY. <br /> 17 <br /> 5. VALDEZ is presently not aware of the true names and/or capacities of Defendants DOES <br /> 18 <br /> 19 1 through 50,inclusive, and therefore sues said Defendants by such fictitious names.VALDEZ is informed <br /> 20 and believes and upon such information and belief alleges that said fictitiously named Defendants are <br /> 21 directly and proximately responsible for the injuries and damages alleged herein.VALDEZ will amend this <br /> 22 <br /> Complaint to allege the true names and capacities of said fictitiously named Defendants when, and if, <br /> 23 <br /> 24 ascertained. <br /> 25 111 <br /> 26 111 <br /> 27 <br /> 111 <br /> 28 <br /> 111 <br /> 2 <br /> VALDHZ v.Cm OF,SANTA ANA CASSNO, <br /> COMPLAINT <br />