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1 b. MORENO is info ed and believes, and upon such information and belief'alleges,that, at <br /> all relevant times, each and every Defendant was a principle, agent, employer, employee, manager, <br /> 3 <br /> supervisor, officer, shareholder and/or owner of each and every other Defendant, and each and every act <br /> 5 and/or omission of each and every Defendant occurred by and through the governing body and/or <br /> management of the Defendant and within the course and scope of such agency and/or employment and/or <br /> 7 <br /> was approved and/or ratified by the acts and/or omissions of each and every other Defendant. <br /> h <br /> FACTUAL AC G DUN <br /> 10 A. For Decades,MORENO has been an Outstanding Police Employee of CITY,Resulting <br /> l l in Numerous Promotions, Including his Most Recent to Police Commander. <br /> 1 <br /> 13 7. By way of brief background,MORE O -following decades of exceptional public service- <br /> 1 was promoted to his current position of police Commander with the City's Police Department. <br /> 15 g. As detailed herein, because of D O's reporting/disclosure of CITY's unlawful acts, <br /> 16 <br /> Valentin (.and those acting on his behalf) perceived MORENO as not being part of the below-described <br /> 17' <br /> "Valentin camp" but, rather, as part of the below-described"POA camp". <br /> 18 <br /> 19 a CITY's RecentlySeparate olice Chief David Valentin and CITY's"Gangs,/Camps"'. <br /> 20 9. Valentin was CITY's Police Chief from 2017 until his November 2, 2023 separation. <br /> 21 10. While, on September,27, 2023,Valentin notified City that he was "retiring"[which he later <br /> 22 <br /> claimed, both in writing and orally (with Frank Sinatra's song "lily Way actually playing in the <br /> 3 <br /> 24 background),was on"his terms''',"something that hasn't happened in four decades"],also on September 27, i <br /> 25 2023,Valentin wrote to CTTY: (1)"(a)lthough [he] intended to serve[CITY]as Chief of Police for several <br /> 26 more years, the fact is that over the course of the last five years, [he] was subjected to a targeted and <br /> 27 <br /> 28 unrelenting campaign of harassment" and that, as a result of CITY's taping "no substantive action", he <br /> "fe[lt] [he]' ha[d] no choice but to retire." <br /> 3 <br /> COWLAINT <br />