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1 12. Also during this time,and as CITY is well aware from other publicly-filed lawsuits(i.e.,Rita <br /> 2 <br /> Ramirez v. City of Santa Ana;Anthony Cardenal v. City of Santa Ana) which MENENDEZ incorporates <br /> 3 <br /> 4 herein,although an effective police department functions as a whole,there has been-as CITY is well aware <br /> 5 - a common recent practice (and the subject of much ongoing discussion and concern between CITY <br /> 6 personnel)that Chief Valentin(and others at his behest) attempt to force personnel to choose between two <br /> 7 <br /> "gangs" or "camps" - Chief Valentin's "gang"/"camp" or what Chief Valentin perceives to be the other <br /> 8 <br /> 9 <br /> "gang"/"camp" allegedly led by Police Association("POA") President Gerry Serrano. <br /> 10 13. As discussed in more detail below,MENENDEZ is perceived by Chief Valentin(and those <br /> 11 acting on his behalf) as being part of the "Serrano gang/camp" and not part of the "Valentin gang/camp". <br /> 12 <br /> 14. Chief Valentin has been repeatedly accused of- not simply allowing but - fostering these <br /> 13 <br /> 14 "gangs"/"camps"within the Police Department. <br /> 15 15. Additionally,Chief Valentin has been repeatedly accused of actively retaliating against those <br /> 16 who did not choose to be in his "gang/camp" and of retaliating against those who even chose to associate <br /> 17 <br /> with those perceived to be in the other"gang/camp". <br /> 18 <br /> 19 16. Despite these numerous claims of unlawful conduct over the years, CITY has allowed this <br /> 20 unlawful conduct to continue. <br /> 21 C. CITY Police Officer John Rodriguez. <br /> 22 <br /> 17. In or about 2018, an incident occurred involving CITY's police officer John Rodriguez, a <br /> 23 <br /> 24 close friend and associate of Chief Valentin. <br /> 25 18. Following the incident, the following letter was sent to Chief Valentin: <br /> 26 "The Police Department you have built is a great testimony to your leadership.Ultimately,will you <br /> 27 be known for your outstanding achievements or the cover up of Officer John Rodriguez[?] <br /> 28 <br /> 4 <br /> MENENDEZ V. CITY OF SANTA ANA CASENO. <br /> COMPLAINT <br />