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1 B. Soon-to-be-Former Chief Valentin and CITY's "Gangs/Camps". <br /> 2 <br /> 13. As CITY is well aware from numerous complaints and from other publicly-filed lawsuits(i.e., <br /> 3 <br /> 4 Rita Ramirez v. City of Santa Ana;Anthony Cardenal v. City of Santa Ana, Nelson Menendez v. City of <br /> 5 Santa Ana, Manuel Moreno v. City of Santa Ana), although an effective police department functions as a <br /> 6 whole, it has been a common recent practice (and the subject of much ongoing discussion and concern <br /> 7 <br /> between CITY's police department personnel) for Chief Valentin(and others at his behest) to attempt to <br /> 8 <br /> 9 <br /> force personnel to choose between two"gangs"or"camps"-what is referred to as"the Valentin camp"or <br /> 10 what Chief Valentin perceives to be the other "gang"/"camp" allegedly led by then-Police Association <br /> 11 ("POA")President Gerry Serrano. <br /> 12 <br /> 14. VALDEZ is perceived by Chief Valentin(and those acting on his behalf)as not being part <br /> 13 <br /> 14 of"the Valentin camp"and is, thus,perceived as being part of what is referred to as "the POA camp". <br /> 15 15. Chief Valentin has been repeatedly accused of not simply allowing but fostering these <br /> 16 "camps"within CITY's Police Department, <br /> 17 <br /> 16. Additionally, Chief Valentin has been repeatedly accused of actively <br /> 18 <br /> 19 retaliating/discriminating against or harassing those who did not choose to be in his "camp" and of <br /> 20 retaliating/discriminating against or harassing those who chose to even associate with those perceived to be <br /> 21 in the other"camp". <br /> 22 <br /> 17. It is also common knowledge that those perceived to be in the"Valentin camp"-even those <br /> 23 <br /> 24 who repeatedly and significantly violate laws, statutes, regulations and policies - are not <br /> 25 charged/investigated/disciplined for such conduct while those not perceived to be in the"Valentin camp" <br /> 26 (especially those who stand up against the "Valentin camp"'s wrongful acts) are routinely <br /> 27 <br /> charged/investigated/disciplined for far less egregious purported"misconduct." <br /> 28 <br /> 111 <br /> 4 <br /> VALDRZV.CITYpBSANTAANA CAS6NIo. <br /> COMPLAINT <br />