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1 14. Additionally,CARDENAL served as a supplemental investigator in Crimes Against Persons <br /> 2 <br /> and Robbery divisions as part of the Violent Crime Reduction Program from 2017 to 2020. <br /> 3 <br /> 4 C. CITY's Police Chief David Valentin. <br /> 5 15. Since 2017,David Valentin has been CITY's Police Chief. <br /> 6 16. During this time,myriad claims have been made against CITY as a result of Chief Valentin's <br /> 711 <br /> unlawful acts of, inter alia, harassment (including claims of sexual harassment), discrimination and <br /> 8 ' <br /> 9 retaliation. <br /> 10 17. Also during this time,although an effective police department functions as a whole,there is- <br /> 11 as CITY is well aware-much ongoing discussion and concern between CITY personnel regarding the fact <br /> 12 <br /> that Chief Valentin(and others at his behest)attempt to force personnel to choose between two"gangs"or <br /> 13 <br /> 14 <br /> `camps" - Chief Valentin's "gang"/"camp" or the perceived "gang"/"camp" allegedly led by Police <br /> 15 Association("PDX)President Gerry Serrano. <br /> 16 � Chief Valentin has been repeatedly accused of-not simply allowing but-fostering these <br /> 17 <br /> "gangs"/"camps"within the Police Department, <br /> 18 <br /> 19 19. Additionally,Chief Valentin has been repeatedly accused of activelyretaliating against those <br /> 20 who did not choose to be in his"gang"/camp"and of retaliating against those who even chose to associate <br /> 21 with those perceived to be in the other"gang"/"camp" <br /> 22 <br /> 20. Despite these numerous claims of unlawful conduct over the years,CITY has allowed this <br /> 23 <br /> 24 unlawful conduct to continue. <br /> 25 D. CITY's Major Enforcement Team. <br /> 26 21. The Major Enforcement Team("MET')is a SWAT-like team"created"in January of 2020 <br /> 27 <br /> by CITY's Police Chief David Valentin. <br /> 28 <br /> 22. Persons associated with MET are considered to be part of Chief Valentin's"gang"/"camp." <br /> CAmFN Lv.CnTorSAwAANA CANNO. <br /> COWL W <br />