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1 11. During Valentin's time as Police Chief, myriad claims were made against CITY as a result <br /> 2 <br /> of Valentin's (and those acting on his behalf) unlawful acts of,inter alia, harassment(including claims of <br /> 3 <br /> 4 sexual harassment), discrimination and retaliation. <br /> 5 12. As CITY is well aware fromnumerous complaints and from other publicly-Bled lawsuits and <br /> 6 i claims,although an effective police department functions as a whole,it has been a common recent practice <br /> 7 <br /> (and the subject of much ongoing discussion and concern between CITY's police department personnel)for <br /> 8 <br /> 9 Valentin(and others at his behest)to attempt to force personnel to choose between two"gangs"or"camps"- <br /> 10 what is referred to as "the Valentin camp" or what Valentin perceived to be the other "gang"/"camp'" <br /> I I allegedly led by then-Police Association C'POA'J President Gerry Serrano. <br /> 12 <br /> 13 13. Valentin was repeatedly accused of not simply allowing but fostering these "camps"within <br /> 14 CITY's Police Department in violation of California law, the Califomia, Constitution and CTTY's own <br /> 15 policies and procedures. <br /> 16 14. Additionally, Valentin was repeatedly accused of actively retaliating/discriminating against <br /> 17 <br /> 18 or harassing those who did not choose to be in his "camp" and of retaliating/discriminating against or <br /> 19 harassing those who chose to even associate with those perceived to,be in the other"camp�'. <br /> 20 15. It is also common knowledge that those perceived to be in the"Valentin camp"-even those <br /> 21 who repeatedly and significantly violate laws, statutes, regulations and policies - are not <br /> 22 <br /> 23 charged/investigated/disciplined for such conduct while those not perceived to be in the"Valentin camp" <br /> 24 (especially those who stand up against the "Valentin camp ..s wrongful acts) are routinely <br /> 25 charged/investigated/disciplined for far less egregious purported "misconduct." <br /> 26 16. Despite the numerous complaints ofthis unlawful conduct over the years,CITY has allowed <br /> 27 <br /> this conduct to continue. <br /> 28 <br /> 4 <br /> IMOMM V. MY OF SANTA ANA CASENOL <br /> COMPIAM <br />