Correspondence - CS Item No. 3 - Laserfiche WebLink

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1 104. As MORENO was the senior Commander in the Field Operations Bureau,MORENO should 2 have been selected to be the,Acting Deputy Chief of Field Operations. 3 4 105. Contrary to past practice and established precedent,CITY did not elevate MORENO but, 5 rather, announced that: (1)Deputy Chief Enriquez would serve as the Assistant Chief of Police (with three- 6 star insignia leading the Field, Operations, Bureau); and (2) Commander Gonzalez(current Commander of 7 Internal Affairs/Executive Officer) would serve as Acting Deputy Chief for the Administration Bureau. 8 9 106. In other words, CITY moved Deputy Chief Enriquez (current Deputy Chief of the 10 Administration Bureau)to be the Deputy Chief of the Field Operations Bureau in order to retaliate against I I MORENO by not elevating him to Acting Deputy Chief of Field Operations. 12 107. Simply,as CITY's ongoing retaliation remains widespread and unaddressed,MORENO has 13 14 suffered significant damage. 15 FIRST CAUSE OF ACTION 16 RETALIATION IN VIOLATION OF LABOR CODE§1102.5 17 (Against All DEFENDANTS) 18 19 108. MORENO; real leges Paragraphs, I through 107 above and incorporates same as though fully 20 set forth herein. 21 109., MO ENO,as described more fully above,reported/dis closed to a government agency and/or 22 23 law enforcement agency and/or a person with authority over her or to an employee with authority to 24 investigate, discover, or correct legal violations and/or noncompliance to DEFENDANTS.MORE NO had 25 reasonable cause to believe that the information reported/disclosed is a violation of state,or federal statute 26 and/or a violation of and/or noncompliance with a local, state and/or federal rule and/or regulation [i.e., 27 28 Penal Code §§1 .22, 13670 and Assembly Bill 958 (prohibition of gangs among police officers); Government Code §§12900-12999 (California Fair Employment and Housing Act; Government Code MOMM V. MY OF SAWTA ANA CA NO, COKVL04T