Correspondence - CS Item No. 3 - Laserfiche WebLink

Home Browse Search

I I MORENO is an individual who,at al I times relevant herein,is and was employed as a Police 2 Commander by Defendant City of Santa Ana("CITY"or"Defendant")at CITY's business office,located 3 4 in the County of Orange, State of California. 5 2. MORENO alleges that CITY is a municipality doing business,in the County of Orange, State 6 of California. The Santa Ana City Council,as the governing body of the City of Santa Ana,acts,represents, 7 and implements policy on the behalf of CITY. 8 9 3. Defendants CITY and DOE Defendants I through 50 are hereinafter sometimes collectively 10 referred to as "DEFENDANTS". 11 4. On or about August 1, 2023, MORENO filed a Complaint with the California Civil Rights 12 Department and, on August 15, 2023, MORENO caused the resulting Right-to-Sue Notice to be served on 13 14 CITY.Additionally,on November 3, 2023,MORENO caused CITY to be served with a Government Claim. 15 Although on November 7, 2023, CITY, via its Third Party Administrator, acknowledged receipt of 16 MORENO's claim and stated that its "investigation has begun" and it"w[ould] be communicating with 17 [MORENO] in the near future in regard to this matter", on November 8, 2023 (i.e, the next day) CITY's 18 19 Third Party Administrator wrote - without investigation or communication- that MORENO's claim "was 20 rejected on 11/8/2023." 21 5. MORENO is presently not aware of the true names and/or capacities of Defendants DOES 22 23 1 through 50, inclusive,and therefore sues said Defendants by such fictitious names.MORENO is informed 24 and believes and upon such information and belief alleges that said fictitiously named Defendants are 25 directly and proximately responsible fbrthe injuries and damages alleged herein.MORENO will amend this 26 Complaint to allege the true names and capacities of said fictitiously named Defendants when, and if, 27 ascertained. 28 2 MOMW V. CITY OF SANTA ANA CASENo. COMnAINT