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1 18. Despite the numerous complaints of this unlawful conduct over the years,CITY has allowed <br /> 2 <br /> this conduct to continue. <br /> 3 <br /> 4 19. Despite the above-alleged conduct of Chief Valentin(and the myriad of claims and lawsuits <br /> 5 arising out of his conduct), VALDEZ is informed and believes that Chief Valentin has communicated to <br /> G CITY that he will also be suing CITY for perceived retaliation,harassment and hostile work environment. <br /> 7 <br /> C. The Major Enforcement Team ("MET"), the Culichi Town Incident and <br /> 8 <br /> 9 Disparate Discipline. <br /> 10 20. MET is a SWAT-like team"created" in January of 2020 by Chief Valentin. <br /> 11 21. persons associated with MET are considered to be part of"the Valentin camp"and receive <br /> 12 <br /> extreme and obvious favoritism from Chief Valentin,regarding both promotions and lack of discipline. <br /> 13 <br /> 14 22. For sake of example, a very public and disturbing incident involving the alleged August 9, <br /> 15 2000 sexual assault by off-duty CITY police officerls at the Culichi town restaurant - and the resulting <br /> 16 cover-up by Chief Valentin and those acting at his direction- was recently addressed in a May 24, 2023 <br /> 17 <br /> complaint made by Commander Manuel Moreno,an unredacted copy of which was released by CITY and <br /> 18 <br /> 19 included as an attached link in investigative journalist Ben Camacho's June 2 t,2023 article entitled"Santa <br /> 20 Ana Police Department Delays Investigation of a Child Sexual Assault by an Off-Duty Officer by More than <br /> 21 Half a Year, Commander Alleges." <br /> 22 <br /> 23. In fact,when the wife of one of the officers involved in the Culichi Town incident discussed <br /> 23 <br /> 24 her husband's concern regarding the incident, VALDEZ immediately disclosed same to Commander <br /> 25 Moreno. <br /> 26 24. VALDEZ is informed and believes that not only were the officers involved in the Culichi <br /> 27 <br /> 28 Town Incident not disciplined but they have received multiple promotions. <br /> 111 <br /> s <br /> VALDU V.OTY OF SANTA ANA CASHNO. <br /> COMPLAW <br />