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1 6. MENENDEZ is informed and believes, and upon such information and belief alleges, that, <br /> 2 <br /> at all relevant times, each and every Defendant was a principle, agent, employer, employee, manager, <br /> 3 <br /> 4 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 /> 6 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 /> 8 <br /> 9 FACTUAL BACKGROUND <br /> 10 A. Over 25 Years Ago, MENENDEZ was Hired by CITY as a Police Officer, Received <br /> 11 Consistent "Outstanding" Performance Evaluation and Served in Leadership Roles. <br /> 12 <br /> 7. By way of brief background, for approximately 25 years MENENDEZ has been employed <br /> 13 <br /> 14 by CITY as a police officer. <br /> 15 8. During his employment,MENENDEZ received both consistent"Outstanding"Performance <br /> 16 Evaluations and various recognitions/awards. <br /> 17 <br /> 9. Additionally, as discussed in more detail below, MENENDEZ serves on the Board of <br /> 18 <br /> 19 Directors for the Police Officers Association("POA")and was instrumental in coordinating the successful <br /> 20 September 1, 2021 Vote of No Confidence against Police Chief David Valentin. <br /> 21 B. CITY's Police Chief David Valentin. <br /> 22 <br /> 10. Since 2017, David Valentin has been CITY's Police Chief. <br /> 23 <br /> 24 11. During this time,myriad claims have been made against CITY as a result of Chief Valentin's <br /> 25 (and those acting on his behalf) unlawful acts of, inter alia, harassment (including claims of sexual <br /> 26 harassment), discrimination and retaliation. <br /> 27 <br /> 28 <br /> MENENDEZ V. CITY OF SANTA ANA CASENO. <br /> COMPLAINT <br />