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68. When MORENO told him to stop making the false allegation and apologize, Commander <br /> 2 <br /> ;i Gonzales responded: "Fuck you." <br /> 3 <br /> 4 69. This was witnessed by at least two other City police officers. <br /> 5 1. CITY Continued to Retaliate. <br /> 6 7'0. In August 2021, MORENO was notified that then-Sergeant Lizardi had served a Public <br /> 7 <br /> Records Request for emails between MORENO,Deputy Chief Paulson and then-POA President Serrano. <br /> 8 <br /> 9 L. CITY Continued to Retaliate. <br /> 10, 71. In November 2021,MORENO was notified-via email-that his position as the Investigative <br /> I I Services Commanderhad been dissolved and that he was being reassigned to be the Comman der of Criminal <br /> 12 <br /> Investigative Division. <br /> 13 <br /> 14 72. After a year in that assignment, MORENO was again reassigned to be the Commander of <br /> 15 Urban Area Security Initiative and Quality of Life Team in Field Operations,. <br /> 16 73. These clearly retaliatory repeated reassignments were contrary to, policy and practice. <br /> 17 <br /> M. MORENO Continued to Disclose/Complain. <br /> 18 i <br /> 19 74. In February 2022, MORENO was interviewed twice by CITY's "independent"third-party <br /> 20 investigators as part of other claimants' Fair Employment and Housing Act ('TEHA') complaints, <br /> 21 75. During these two interviews,MORENO both further disclosed additional unlawful conduct <br /> 22 <br /> 23 of CITY and supported the claims of these FEHA complainants (i.e., participated as a witness and <br /> 24 reported/resisted). <br /> 25 76. As a result of MORENO's filing of the grievance on behalf of Commander Claborn, then- <br /> 26 Director of Human Resources Jason Motsick(currently believed to be on an extended leave of absence)was <br /> 27 <br /> 28 told(and told others including Commander Matt Sorenson)that MORENO was"conspiring"with the POA <br /> and/or its then-President Serrano. <br /> 12 <br /> MOREND V. CffY OF SANTA ANA CASENO. <br /> COMPLAINT <br />