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1 6. VALDEZ is informed and believes,and upon such information and belief alleges,that,at all 2 relevant times,each and every Defendant was a principle,agent,employer,employee,manager,supervisor, 3 4 officer,shareholder and/or owner of each and every other Defendant,and each and every act and/or omission 5 of each and every Defendant occurred by and through the governing body and/or management of the 6 Defendant and within the course and scope of such agency anal/or employment and/or was approved and/or 7 ratified by the acts and/or omissions of each and every other Defendant. 8 9 FACTUAL BACKGROUND 10 A. In November 2009, VALDEZ Began Her Career with CITY and, Thereafter, 11 Repeatedly Received Outstanding Performance Evaluations,was Promoted and 12 Received No Non-Retaliatory Discipline. 13 14 7. On November 9, 2009,VALDEZ began her career with the City as a Police Officer. 15 8. During VALDEZ's almost 14 years of service in law enforcement,VALDEZ has been a loyal 16 and hard-working employee who received consistent"Outstanding"performance evaluations. 17 9. In or about February of2018,VALDEZ was promoted to Detective. 18 19 10. In or about February of 2019, VALDEZ was promoted to Corporal. 20 11. Other than the retaliatory discipline at issue herein, VALDEZ has never been disciplined. 21 12. Despite this, as set forth herein in detail,VALDEZ suffered retaliation,discrimination and 22 harassment due to circumstances entirely unrelated to her performance and was unlawfully disciplined and 23 24 not promoted. CITY's discrimination,harassment and retaliation against VALDEZ violates California law, 25 CITY's own Municipal Code and policies and procedures and VALDEZ's civil service rights. 26 111 27 1I1 28 111 3 VALOIIZ V, CITY OF SANTA ANA CASENG. COWLAINT