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HomeMy WebLinkAboutCorrespondence - Non Agenda J = _ j��.8 o vl e,L)eT r r� `�' �?i t �q,,�.l� 0'� L c✓c T U e r dc}o2ly /1 aAC/� �/' �L b ci U 1�G CA oe e t'J�G1 l s c� ems , ��� `� �-1 Gn � I cL- C1�n.S G'�'e�'C" � f/1���o�✓�(y�=o�� �'-rU�� C��1a�1 ��5. � �1 �'1�S 110.1- �- � 1 _ I � G2-��:��`1.tom' 1 Kl�tl ey�e✓1, 1j _5���� `��? i n3 e �W -- ry\ PcLs5czri le sw S C Pe- i _ I i i eve�)aet� SANTA ANA CA 926 21 MAR 2022'6 PM 3 L � \ USA 6� SAC, Na oaEVEa o �� - )N gX70 a as �i 1;Nil Ca c i ' ��H MAR 24'2 Becerra, Alexis From: Yenny Bernal <upliftingsoulart@gmail.com> Sent: Thursday, March 19, 2026 1:13 PM To: eComment Subject: Public Art & Preservation Policy Public Comments section City Council Meeting 3/19/2026 Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Dear Mayor, City Councilwoman &Councilmen, My name is Yenny Bernal, and I am the owner of Uplifting Soul Art Events,we are a small arts and culture events crew, as well as a makerspace and local gallery studio at MainPlace Mall in Santa Ana as Galeria of Imagination. I was DTSA's Art Walk Coordinator from 2015 to 2021, and have deep love and connection to the history that involves our local visual talent's work on street walls and plazas all over our beloved town. It was with great joy that I read through the drafted document that seeks the protections for Public Art in Public Spaces and the creators rights in the City of the Arts in Orange County. So,today I ask for your unanimous support as our elected leaders and heroes and sheros of our time to approve and move forward with implementations. Thank you for your time, looking forwards to Yes's from all members as this is a great initiative.The time for Art's Champions is NOW! Have a good evening. Best Wishes,s Yenny Wilson-Bernal Uplifting Soul Art Events 657/549-1122 "Create the highest,grandest vision possible for your life, because you become what you believe." Oprah Winfrey 1 Becerra, Alexis From: Elyan Husari < Sent: Tuesday, March 24, 2026 3:23 PM To: eComment Subject: VERY URGENT REGARDING TRULY FRESH J. Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Dear City of Santa Ana Officials, I hope this letter finds you well. I am writing to express a critical concern regarding my business, Truly Fresh J, located in Santa Ana, California. My business is part of a small corporation we launched in December 2025. Since then, we have averaged $6,000 to $7,000 in monthly sales. However, to meet all of our expenses—rent, utilities, and other business costs—we must average at least $14,000 per month. Thus, we face a $7,000 monthly shortfall. I have heard from not only my employees but also from customers at the MainPlace Mall that the presence of ICE (U.S. Immigration and Customs Enforcement) has instilled fear, causing people to stay home instead of visiting the mall. This fear has severely reduced foot traffic. In fact, people are so afraid that they won't even leave their homes. Without business vitality in Santa Ana, the city will also lose the ability to collect crucial revenues—business licenses, certificates of occupancy, and other fees—which are vital to City Hall's operations. Today, March 23, 2026, I spoke with a city clerk at City Hall about starting a petition for action. She will get back to me, and I am also forwarding this letter to S.Mills at santa- anaior.. Please do not hesitate to contact me at by phone at Sincerely, Elyan Husari Becerra, Alexis From: Yang Gu < Sent: Thursday, March 26, 2026 3:43 PM To: eComment Subject: Santa Ana needs to prepare for riots Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. My name is Yang Gu, and I am a recently moved resident of Orange County. You no doubt remember the events of last summer in Santa Ana regarding ICE arrests, riots, and the federalization of the California National Guard. I believe this will happen again this summer, and not only that, the magnitude will be worse. There were "only" 50-some school walkouts last year according to DefendingEd (Link in the footer), and Q1 of this year(still not over) has had over 380. There was a literal dumpster fire lit at the LA federal building in January, outside of hot-weather seasonality. And President Trump has signalled the deportation actions will escalate. President Trump assumed direct control of the Cailfornia National Guard in 2025 and directed them to facilitate the deportation effort instead of protecting the public. He will surely do so again if riots are bad enough. My questions: How much has Santa Ana prepared for this eventuality?What plans are there to anticipate, defuse, or contain rioting?What about a possible spike in petty crime, like what happened during and after the George Floyd riots?What lines of communication and protocols of cooperation exist with the Governor's Office, California High Patrol, and the OC government and Sheriff? Los Angeles was#1 in riots last year, and Santa Ana was an uncomfortably close#2. The Federal Buildings will be likely ground zeroes. Santa Ana in summer of 2026 may require decisive leadership. 1 From: Jackie Angel Investor To: eComment Subject: Santa Ana Sellouts David Penaloza for Assembly 2026 Committee for Candidate David Penaloza FYI Date: Monday,March 30, 2026 8:44:54 AM Attachments: 1000016675.Dng 1000016692.mD4 1000016684.mD4 Attention:This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Santa Ana city hall shut down here RIP 3/31/26 Erg * 1 rJ-bL .AJ. F^y; AIPAC Tracker TrackAIPAC TRACK AIPAC [ U.S.REPRESENTATIVE ' REPRESENTATIVE CtOrRACMPAC @TRNKWAC dl�f + ; Ryan Grim 0 Cibryangrim i 18h Democrats postponing a War Powers vote whHe Trump plans aground invasion RepGreor [Vleeks Re Jeffries @reploucorrea 3:58 PM - 25 NO DEAL PEDOFILES BURN IN HELL Most relevant r Santa Ana @SantaAnaResists • Ils w Replying to CTraekAlPA N DEAL ON P'EDOFILEB BURN IN HELL Santa Ana Councilman Publicly Calls Out Dark Money Campaign, Welcomes FBI Interview Dec 9, 2019 #governmentshutdown #anaheimaudit https://voiceofoc.org/2019/12/santa-ana-councilman-publicly-calls-out-dark-money campaign-welcomes-fbi-interview/ Wow, what does Perla Mexican Cuisine get for their "donation"? LOL Santa Ana Sellouts David Penaloza for Assembly 2026 Committee for Candidate David Penaloza $247,383 Cash on Hand $287,791 Total Contributions $11,800.00 Assoc of CA School Adminstrators ENTITY $11,800.00 Association of Orange County Deputy Sheriffs PAC ENTITY $11,800.00 Avelino Valencia ENTITY $11,800.00 John Ferrone INDIVIDUAL $11,800.00 Santa Ana Police Officers Association PAC ENTITY $10,800.00 California Real Estate PAC (Crepac) - California Association of Realtors ENTITY $5,900.00 Americas Physician Groups CA PAC ENTITY $5,900.00 Anaheim Police Association ENTITY $5,900.00 Anheuser-Busch Companies ENTITY $5,900.00 California Credit Union League PAC ENTITY $5,900.00 California New Car Dealers Association PAC ENTITY $5,900.00 Edison International & Affiliated Entities ENTITY $5,900.00 James Ramos INDIVIDUAL $5,900.00 Morongo Band of Mission Indians Native American Rights Fund ENTITY $5,900.00 Southern California Pipe Trades District Council No 16 PAC ENTITY $5,900.00 Tom Daly ENTITY $5,900.00 Ua Journeymen & Apprentices Local 250 PAC ENTITY $5,900.00 Ua Plumbers & Steamfitters Local Union 582 ENTITY $5,900.00 Western Manufactured Housing Communities Association PAC (Wma PAC) ENTITY $5,900.00 Yuhaaviatam of San Manuel Nation ENTITY $5,500.00 Perla Mexican Cuisine $5,000.00 Apartment Association of Orange County PAC ENTITY $5,000.00 Bruce Hamlin INDIVIDUAL $5,000.00 Cottie Petrie-Norris ENTITY $4,900.00 Californians for Job and a Strong Economy ENTITY $4,000.00 United Nurses Associations of California / Union of Health Care Professionals PAC (Unac PAC) ENTITY $3,000.00 Angelenos for Safe Transportation ENTITY $3,000.00 International Union of Operating Engineers (luoe) ENTITY $3,000.00 Jose Solache INDIVIDUAL $3,000.00 Patrick Ahrens INDIVIDUAL $3,000.00 Wescom Credit Union State PAC ENTITY $2,500.00 Amalgamated Transit Union 1277 PAC ENTITY $2,500.00 American Pistachio Growers California PAC ENTITY $2,500.00 Bail Hotline Bail Bonds ENTITY $2,500.00 Blanca Pacheco ENTITY $2,500.00 East West Bank ENTITY $2,500.00 Edwin Laird INDIVIDUAL $2,500.00 Efrain Davalos INDIVIDUAL $2,500.00 International Brotherhood Electrical Workers Educational Fund (IBEW) ENTITY $2,500.00JohnneyZhang INDIVIDUAL $2,500.00 Los Angeles Police Protective League PAC ENTITY $2,500.00 Sprinkler Fitters Local 709 ENTITY $2,500.00 Steven Murow INDIVIDUAL $2,000.00 Avila Farias ENTITY $2,000.00 Garden Grove Police Assoc ENTITY $2,000.00 Richard Contreras INDIVIDUAL $1,750.00 Catie Chase INDIVIDUAL $1,750.00 Irving Chase INDIVIDUAL $1,750.00 Ryan Chase INDIVIDUAL $1,500.00 Anesthesia Service Medical Group ENTITY $1,500.00 Personal Insurance Federation of CA Agents & Employees PAC ENTITY $1,500.00 Troy Eubank INDIVIDUAL $1,250.00 Sara Fainbarg ENTITY $1,000.00 Araceli Padilla Insurance Agency ENTITY $1,000.00 Boma Oc PAC - Building Owners & Managers Association of Orange County PAC ENTITY $1,000.00 California Association of Pest Control Advisors ENTITY $1,000.00 California Citrus Mutual PAC ENTITY $1,000.00 California Dairies PAC Federal ENTITY $1,000.00 Cesar Mcguire INDIVIDUAL $1,000.00 Csi Color Science Inc ENTITY $1,000.00 Dana Strader INDIVIDUAL $1,000.00 Faculty Association of California Community Colleges-PAC ENTITY $1,000.00 Fred Flores INDIVIDUAL $1,000.00 Jason Carig INDIVIDUAL $1,000.00 Jason Young INDIVIDUAL $1,000.00 Jocelyn Eubank INDIVIDUAL $1,000.00 John Harabedian INDIVIDUAL $1,000.00 Josh Lowenthal ENTITY $1,000.00 Jr Ltd LP ENTITY $1,000.00 Mike Fong ENTITY $1,000.00 Mpi Modified Plastics Inc ENTITY $1,000.00 Peter Mitchell INDIVIDUAL $1,000.00 Plastics Analytical Laboratory ENTITY $1,000.00 Rick Chavez Zbur ENTITY $1,000.00 Sharon MacDonald INDIVIDUAL $1,000.00 Taxpayers for Sustainable Economy ENTITY $1,000.00 Virginia Mangione INDIVIDUAL $1,000.00 William K Wong INDIVIDUAL $966.00 Aggregated Unitemized Contributions INDIVIDUAL $750.00 Bill Taormina INDIVIDUAL $750.00 John Ford INDIVIDUAL $750.00 M H ET PAC ENTITY $750.00 William Taormina INDIVIDUAL $500.00 Bill Witte INDIVIDUAL $500.00 Bristol Car Wash Inc ENTITY $500.00 Caylin Vidaurri INDIVIDUAL $500.00 Howard Welknsky INDIVIDUAL $500.00 James Rogers INDIVIDUAL $500.00 Jody Campbell INDIVIDUAL $500.00 Nick Taormina INDIVIDUAL $500.00 Nick Taormina INDIVIDUAL $500.00 Oscar Reyes INDIVIDUAL $500.00 Outfront Media ENTITY $500.00 Rouzbeh Vandatpour INDIVIDUAL $500.00 Sara Fainbarg INDIVIDUAL $500.00 Sprinkler Fitters United Association PAC ENTITY $300.00 Josefina Avarca INDIVIDUAL $250.00 American Promotional Events ENTITY $250.00 Barry Cottle INDIVIDUAL $250.00 Creative Outdoors Advertising Bulletin Displays LLC(mark Kudler) ENTITY $250.00 Daniel Kalmick INDIVIDUAL $250.00 Eddie Quillares Jr INDIVIDUAL $250.00 Faubel Public Affairs ENTITY $250.00 Ira Handelman INDIVIDUAL $250.00 John Stephens INDIVIDUAL $250.00 Jorge Reyes INDIVIDUAL $250.00 Juan Garcia INDIVIDUAL $250.00 Kacey Taormina INDIVIDUAL $250.00 LuisAndres Peez INDIVIDUAL $250.00 Natalie Taormina INDIVIDUAL $250.00 Overland Strategies LLC(derek Humphrey) ENTITY $250.00 Patrick Strader INDIVIDUAL $250.00 Peter Whittingham INDIVIDUAL $250.00 Plumbers & Steamfitters Local Union 403 ENTITY $250.00 Robert Lapsley INDIVIDUAL $250.00 Steve Gallegos INDIVIDUAL $250.00 Steven Mendoza INDIVIDUAL $250.00 Timothy OBrien INDIVIDUAL $250.00 Timothy Psomas INDIVIDUAL $250.00 Todd Cottle INDIVIDUAL $200.00 Tuan Nguyen INDIVIDUAL $200.00 Valerie Amezcua INDIVIDUAL $200.00 Wendy Bacerra INDIVIDUAL $150.00 Claudio Gallegos INDIVIDUAL $150.00 Yolanda Muniz INDIVIDUAL $125.00 Alex Burrola INDIVIDUAL $125.00 Collin Felch ENTITY $125.00 Custom Auto Service ENTITY $125.00 Dale Helvig INDIVIDUAL $125.00 Ilana Meirovitch INDIVIDUAL $125.00 Robert Escalante INDIVIDUAL $125.00 Teresa Saldivar INDIVIDUAL $100.00 Ana Padilla INDIVIDUAL $100.00 Andrew Linares INDIVIDUAL $100.00 Connor Traut INDIVIDUAL $100.00 Michelle Murphy INDIVIDUAL $100.00 Ron Demeter INDIVIDUAL $100.00 Samuel Johnson INDIVIDUAL $100.00 Stephanie Oddo INDIVIDUAL $0.00 Robert Rivas ENTITY Becerra, Alexis From: Jackie Angel Investor < Sent: Wednesday, April 1, 2026 1:35 PM To: eComment Cc: Durham, Daniel Subject: Re: CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION SAPID is the liability Attachments: Kachirisky_-_Complaint[)].pdf -Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. John Kachirisky vs. City of Santa Ana police officer retaliation employment claim "On May 4 2023, Kachirisky exhausted his administrative remedies by causing City to be served with a government claim. On May 9 2022, although Ciity, via its third party administrator, acknowledged receipt of the claim and stated that "an investigation will be conducted, and upon conclusion, there will be further communication with your office", neither Kachirisky nor his counsel was ever contacted and the claim was denied by operation of law. Regarding gang camps within ranks and the Culichi Town incident and it's coverup resulting in the emboldening of the Valentin camp and the City's major enforcement team (met). met is a swat like team created in January 2020 by Chief Valentin. Persons associated with met are considered to be part of"Valentin camp" and receive extreme and obvious favoritism from Chief Valentin, both regarding promotions and lack of discipline. The Promotional Process and Chief Valentin "The process had become unfair, biased, discriminatory and contrary to law." "Wherefore, Kachirisky prays for judgment against defendants, and each of them, as follows: 1. For compensatory damages, including loss of earnings, deferred compensation, bonuses, vacation and other employment perquisites and other special and general damages according to proof; 2. Damages for pain and suffering and emotional distress; 3. Interest, including prejudgment interest, at the prevailing legal rate; 4. Attorneys fees and costs incurred herein; and 5. Cost of suit; and 6. Such further and other relief as the court deems just and proper. REQUEST FOR TRIAL BY JURY Kachirisky hereby demands a trial by jury. Dated September 5, 2023 https://citVofsantaanaca.nextrequest.com/requests/26-719 From:Jackie Angel Investor<jcordova4@msn.com> Sent: Sunday, March 15, 2026 7:21 PM To: eComment<ecomment@santa-ana.org> Subject: CONFERENCE WITH LEGAL COUNSEL—EXISTING LITIGATION 1 Hello, we would like details on these closed session cases and why so many Santa Ana police officers are suing us. https://citVofsantaanaca.nextrequest.com/requests/26-719 CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION Frank Rocha v. City of Santa Ana, WCAB Case No.: ADJ15955468; ADJ18623576; ADJ17697034 B. Stephen Hahm v. City of Santa Ana, WCAB Case No.: ADJ19377542; ADJ19377509; ADJ19885630 A. Anthony Cardenal v. City of Santa Ana, Orange County Superior Court Case No. 30-2022-01293127 B. John Kachirisky v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01348299 C. Nelson Menendez v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01339537 D. Manuel Moreno v. City of Santa Ana, Orange County Superior Court Case No. 30-2024-01372127 E. Rita Ramirez v. City of Santa Ana, Orange County Superior Court Case No. 30-2022-01287702 F. Judith Valdez v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01359457 From: Jackie Angel Investor <jcordova4@msn.com> Sent: Tuesday, October 8, 2024 11:30:39 AM To: scarvalho@santa-ana.org <scarvalho@santa-ana.org>; anunez@santa-ana.org <anunez@santa-ana.org> Cc: Ryberg, Erinn <Erinn.Ryberg@asm.ca.gov>; eComment <eComment@santa-ana.org> Subject: City of Santa Ana, Formal Complaint Filed - City Attorney Notice Sonia R. Carvalho, FIRED As general counsel to the City Today I was assured you would never be of service to me. After all these years, you offer me nothing, not even a return phone call. As our City Attorney, you can't be bothered. You are hereby put on notice. You are no longer my city attorney. Never did you represent me. {We The People} Never did you provide services for me<. Never did you counsel me or guide me in matters regarding the City of Santa Ana. This is the acknowledgement. -Santa Ana California Frank E. Rocha, a Police Services Dispatcher for the City of Santa Ana in 2024, had a total salary of $9,344.00, with regular pay of$8,639.09 . Total compensation including benefits and pension debt was $16,454.45. Stephen C. Hahm is a Police Officer for the City of Santa Ana, California, with a reported total pay of $337,526.05 in 2024, according to data from Transparent California. His compensation included a high regular salary along with additional pay and benefits typical of law enforcement officers. • 2024 Salary: $337,526.05 2021 Salary: $110,839.50 Anthony Cardenal earned $207,331 in 2017, according to public payroll data from Santa Ana. His job title was listed as a Police Officer. John Kachirisky, a Police Officer for the City of Santa Ana, had a total pay and benefits package of $347,114.56 in 2022 2 • 2022 (Pension Debt): $92,990.41 • Nelson A. Menendez worked as a Police Officer for the City of Santa Ana, earning a total pay of $196,996.30 which included a regular salary of$112,104.00. His total compensation, including benefits and pension debt coverage, was $361,812.66. • Salary Breakdown (2022): • Total Pay: $196,996.30 • Regular Pay: $112,104.00 • Benefits: $69,745.32 • Pension Debt: $95,071.04 • Manuel Moreno J. earned $432,264 in 2024, according to public payroll data from Santa Ana. His job title was listed as a Police Lieutenant (Rm). • According to public records, Manuel Moreno J.'s salary increased by 38% ($118,565) from 2023 to 2024. • Manuel Moreno J.'s salary was 190% higher than the average and 220% higher than the median salary at Santa Ana in 2024. • His salary was 164% higher than the average Police Lieutenant salary in 2024. Judith A. Valdez Police Officer (2020) Regular pay: $107,820.00 Overtime pay: $13,919.75 Other pay: $42,079.52 Total pay: $163,819.27 Benefits: $65,508.11 Pension debt: $68,406.54 Total pay & benefits: $297,733.92 3 Electronically Filed by Superior Court of California, County of Orange, 09/06/2023 02:06:22 PM. 30- 23-01348299-CU-OE-CJC - ROA#2 - DAVID H. YAMASAKI, Clerk of the Court By A. Burton, Deputy Clerk. 1 JOHN A. GIRARDI, State Bar No. 54917 JOHN A. GIRARDI, APC 2 29900 Hawthorne Boulevard Rolling Hills Estates, CA 90274 3 (310) 265-5787 Telephone j ohn(a,j ohngirardilaw.c om 4 LAWRENCE J. LENNEMANN, State Bar No. 134108 5 LAW OFFICE OF LAWRENCE J. LENNEMANN, APC � iar�ed cor All PWrrao,�� 29900 Hawthorne Boulevard judge Michael Stri c kroth 6 Rolling Hills Estates, CA 90274 (310) 265-5788 Telephone 7 lennemannle(a-),gmail.com 8 Attorneys for Plaintiff JOHN KACHIRISKY 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF ORANGE 12 JOHN KACHIRISKY, an Individual ) CASE NO.: 30-2023-01348299-CU-OE-CJC 13 ) PLAINTIFF JOHN KACHIRISKY'S 14 ) COMPLAINT FOR RETALIATION IN Plaintiff, ) 15 VIOLATION OF LABOR CODE §1102.5 16 vs. REQUEST FOR JURY TRIAL 17 ) 18 ) CITY OF SANTA ANA, an entity of unknown ) 19 origin; and DOES 1 - 50, Inclusive, ) 20 ) 21 ) 22 Defendants. ) 23 24 25 Plaintiff John Kachirisky("KACHIRISKY"or"Plaintiff'),with knowledge as to his own acts and 26 based upon information and belief with regard to all other matters,by and through his attorneys of record, 27 28 alleges: KACHnusKY v. CITY OF SANTA ANA CASENo. COWLAI NT 1 1. KACHIRISKY is an individual who, at all times relevant herein, is and was employed as a 2 police officer by Defendant City of Santa Ana("CITY"or"Defendant")at CITY's business office located 3 4 in the County of Orange, State of California. 5 2. KACHIRISKY alleges that CITY is a municipality doing business in the County of Orange, 6 State of California. The Santa Ana City Council, as the governing body of the City of Santa Ana, acts, 7 represents, and implements policy on the behalf of CITY. 8 9 3. Defendants CITY and DOE Defendants 1 through 50 are hereinafter sometimes collectively 10 referred to as "DEFENDANTS". 11 4. On May 4,2023,KACHIRISKY exhausted his administrative remedies by causing CITY to 12 be served with a Government Claim. On May 9, 2022, although CITY, via its Third Party Administrator, 13 14 acknowledged receipt of the claim and stated that "(a)n investigation will be conducted, and upon 15 conclusion,there will be further communication with your office",neither KACHIRISKY nor his counsel 16 was ever contacted and the claim was denied by operation of law. 17 5. KACHHUSKY is presently not aware of the true names and/or capacities of Defendants 18 19 DOES 1 through 50,inclusive,and therefore sues said Defendants by such fictitious names.KACHIRISKY 20 is informed and believes and upon such information and belief alleges that said fictitiously named 21 Defendants are directly and proximately responsible for the injuries and damages alleged herein. 22 KACHIRISKY will amend this Complaint to allege the true names and capacities of said fictitiously named 23 24 Defendants when, and if, ascertained. 25 26 27 28 z KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 6. KACHHUSKY is informed and believes,and upon such information and belief alleges, that, 2 at all relevant times, each and every Defendant was a principle, agent, employer, employee, manager, 3 4 supervisor, officer, shareholder and/or owner of each and every other Defendant, and each and every act 5 and/or omission of each and every Defendant occurred by and through the governing body and/or 6 management of the Defendant and within the course and scope of such agency and/or employment and/or 7 was approved and/or ratified by the acts and/or omissions of each and every other Defendant. 8 9 FACTUAL BACKGROUND 10 A. Plaintiff KACHIRISKY. 11 7. By way of brief background,after serving honorably for four years in the United States Navy, 12 in January of 2005,KACHHUSKY was hired by the California Highway Patrol where he worked as a Patrol 13 14 Officer for over three years. 15 8. In February of 2008, KACHIRISKY was hired by CITY as a Police Officer. In November 16 2017,after serving in various capacities,KACHIRISKY was promoted to Corporal. Since February of 2019, 17 KACHHUSKY has served as a Lead Corporal, during which time he received consistently Outstanding 18 19 Performance Evaluations and various recognitions/awards. 20 9. Since 2020, KACHIRISKY has been an Executive Board member of the Police Officers 21 Association ("POA"), serving as the elected POA Vice President until his July/August 2023 elevation to 22 POA President. Additionally, as discussed in more detail below, KACHIRISKY was instrumental in 23 24 coordinating the successful September 1,2021 Vote ofNo Confidence against Police Chief David Valentin. 25 B. CITY's Police Chief David Valentin and the "Gangs/Camps" he Fosters. 26 10. Since 2017, David Valentin has been CITY's Police Chief. 27 28 3 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 11. During this time,myriad claims have been made against CITY as a result of Chief Valentin's 2 (and those acting on his behalf) unlawful acts of, inter alia, harassment (including claims of sexual 3 4 harassment), discrimination and retaliation. 5 12. As CITY is well aware from numerous complaints and from other publicly-filed lawsuits, 6 although an effective police department functions as a whole,it has been a common recent practice(and the 7 subject of much ongoing discussion and concern between CITY's police department personnel) for Chief 8 9 Valentin(and others at his behest)to attempt to force personnel to choose between two"gangs"or"camps"- 10 what is referred to as "the Valentin camp"or what Chief Valentin perceives to be the other"gang"/"camp" I 1 allegedly led by then-POA President Gerry Serrano.It became a very hostile and dysfunctional atmosphere 12 as "the Valentin camp"attempted to pigeonhole/ostracize employees as belonging to one camp or another. 13 14 Many employees became extremely fearful that,if they were labeled as belonging to the"camp"associated 15 with the POA/Serrano,they would be retaliated against,denied promotional opportunities or possibly even 16 disciplined, demoted and/or terminated for minor infractions. 17 13. KACHHUSKY,as an active POA Board member who had been promoted to Executive Board 18 19 Secretary in 2020,was quickly characterized by Chief Valentin(and those acting on his behalf)as being part 20 of"the POA camp" and not part of"the Valentin camp". 21 14. Chief Valentin has been repeatedly accused of not simply allowing but fostering these 22 "camps"within the Police Department.Additionally,Chief Valentin has been repeatedly accused of actively 23 24 retaliating/discriminating against or harassing those who did not choose to be in his "camp" and of 25 retaliating/discriminating against or harassing those who chose to even associate with those perceived to be 26 in the other"camp".It is also common knowledge that those perceived to be in the"Valentin camp"-even 27 those who repeatedly and significantly violate laws, statutes, regulations and policies - are not 28 charged/investigated/disciplined for such conduct while those not perceived to be in the "Valentin camp" 4 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT I (especially those who stand up against the "Valentin camp"'s wrongful acts) are routinely 2 charged/investigated/disciplined for far less egregious purported "misconduct." Despite the numerous 3 4 complaints of this unlawful conduct over the years, CITY has allowed this conduct to continue. 5 C. The Culichi Town Incident- and its Cover-Up - Resulted in the Emboldening 6 of the Valentin Camp and the CITY's Major Enforcement Team("MET"). 7 15. MET is a SWAT-like team "created" in January of 2020 by Chief Valentin. Persons 8 9 associated with MET are considered to be part of"the Valentin camp" and receive extreme and obvious 10 favoritism from Chief Valentin, both regarding promotions and lack of discipline. 11 16. For sake of example, a very public and disturbing incident involving the alleged August 9, 12 2020 sexual assault by an off-duty CITY police officer at the Culichi town restaurant - and the resulting 13 14 cover-up by Chief Valentin and those acting at his direction - was recently addressed in a May 24, 2023 15 complaint made by Commander Manny Moreno,an unredacted copy of which was released via investigative 16 journalist Ben Camacho's June 21,2023 article entitled"Santa Ana Police DepartmentDelays Investigation 17 of a Child Sexual Assault by an Off-Duty Officer by More than Half a Year, Commander Alleges." 18 19 KACHHUSKY is informed and believes that not only were the officers involved in the Culichi Town 20 Incident not disciplined but they have received multiple promotions 21 17. Specifically, on August 9, 2020, five other CITY MET police officers (Dorin Buchanan, 22 Mark Campi, then-Sergeant Oscar Lizardi, Jonathan McKee, Jonathon Perez) -who were hand-picked for 23 24 this assignment with Chief Valentin's blessing -were accused of verbally harassing two teenage girls and 25 of sexually-assaulting one at the Culichi Town restaurant in Santa Ana("the Culichi Town Incident"). 26 18. The girls' family (who had been told by the officers that they were CITY police officers) 27 and/or others repeatedly called 911 to report the Culichi Town Incident.The MET members reportedly fled 28 prior to patrol officers arriving. The MET members also reportedly coordinated with officer Andres Gil to s KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT I tell officers at the scene that they should not take the mandated police report. (Officer Gil was eventually 2 rewarded with a transfer to MET.) 3 4 19. Thus, in violation of federal law, state law and CITY policy, no police report was taken. 5 However, as several 911 calls had been made, an incident number (200805316) - and a related Incident 6 Detail Report - had been generated. A review of the Incident Detail Report evidences some obvious 7 irregularities: 8 9 Although Culichi Town is in the"Southcoast areas",Watch 3(graveyard)officers responded from three different areas(Southcoast, Westend and Southeast) evidencing that this was a 10 significant incident, requiring multiple units to respond; and 11 Despite this(and despite the fact that then-probationary Sergeant Rich Riberio who,contrary 12 to typical CITY practice,was thereafter promoted shortly afterpassing probation,was shown as"available"and should have been at the call),not a single patrol supervisor was on scene. 13 14 20. Many at CITY are informed and believe that the only reasonable conclusion to be drawn from 15 the above is that one or more of the involved MET officers contacted the supervisor/s and told them not to 16 respond. 17 D. Let's Skip Ahead and Look at Commander Moreno's Recent Complaint. 18 19 21. Almost immediately, numerous officers reported the Culichi Town Incident to CITY. As 20 such, the Culichi Town Incident has been an "open secret" at CITY since August of 2020. 21 22. Despite this,on May 9,2022, Chief Valentin released a video in which he described how"a 22 blog" [written by the above-referenced investigative journalist Camacho] that had been"shared on social 23 24 media" contained "serious misinformation" and "baseless attacks on the integrity of some of the most 25 dedicated members of our police department." 26 23. In the video, Chief Valentin also stated that he wished to "assure the community my 27 command staff and I hold our officers to the highest standards"and that"we investigate any allegations of 28 wrongdoing and hold officers accountable to our department policies and the law." 6 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 24. Chief Valentin then described how an"anonymous complaint"was received"seven months" 2 after the Culichi Town Incident and then stated: 3 4 "Upon receiving the initial complaint, an internal affairs investigation was opened." 5 25. However, as: (1) the "initial complaint[s]" were made in August of 2020; and (2) no 6 investigation was admittedly opened until (at the earliest) seven months later, this statement was false. 7 26. Despite this, Chief Valentin retained purported "independent" "investigators" (the OIR 8 9 Group)who conducted an almost-year-long assessment based,not only on the false lack-of-prompt-notice 10 premise, but, pursuant thereto - admittedly- interviewed only MET personnel. 11 27. Thus, not surprisingly, the OIR Report which - despite the fact that Chief Valentin and 12 Assistant Chief Rodriguez,various members of the command staff and numerous officers were indisputably 13 14 aware of the incident in August of 2020 - essentially opined "gee, it would be nice if your officers had 15 promptly reported bad stuff up the chain." 16 28. On April 5, 2023, in another released video, Chief Valentin then weaponized the 17 "assessment"to falsely imply the absence of any wrongdoing 18 19 29. Many at CITY's police department-who were informed and believed that some independent 20 entity must have been(during the past years) investigating CITY's cover-up of allegations against its own 21 officer of a sexual assault against a minor of which numerous supervisors were indisputably aware-were 22 23 shocked by the conclusions of the OIR Report. 24 30. On May 24, 2023, Commander Moreno (one of those shocked by the report) made his 25 complaint of "misconduct of a serious nature"which detailed reports to him and his reporting to others and 26 which states, in part: 27 "Up until the Office of Independent Review published the Assessment, I believed that SAPD's 28 Internal Affairs Investigation would account and accurately explain the seven-month gap from when misconduct was reported(August 2020)to DC Rodriguez to when SAPD received the anonymous complaint (—March 2021). 7 KACHIRISKY V. CITY OF SANTA ANA CASENo. COWLAINT I It is my belief that if the Office of Independent Review,was made aware that Commander Alvarez 2 and I had indeed followed SAPD policy/procedure, with regards to the reporting of officer misconduct, they would not have made some of the assertions and recommendations they did. 3 Additionally, had an Internal Affairs Investigation been initiated in August of 2020 instead of 7 4 months later, our Internal Affairs Unit would have had the ability to conduct a more thorough and accurate investigation. This 7-month delay impeded and interfered with the alleged sexual assault 5 and Internal Affairs investigation." 6 31. With regard to post-OI Report communications,Commander Moreno's complaint also stated: 7 "On 4/11/23, I met with DC Rodriguez and we discussed the OIR's Assessment report. DC 8 Rodriguez did not deny that I had reported misconduct to him shortly after the Culichi Town incident 9 . . . I asked DC Rodriguez if he had told Chief Valentin about the misconduct I had reported. DC Rodriguez indicated that he indeed did notify Chief Valentin at the time I reported it to him"; and 10 "On April 6, 2023 I spoke to Sergeant Barragan; we discussed the Assessment by the OIR and his 11 initial reporting of the alleged misconduct. 12 I spoke to Commander Alvarez on April 7, 2023 and I advised him that I was going to make an 13 allegation of misconduct against DC Rodriguez about this incident. Commander Alvarez stated he 14 Would be available to be interviewed and discuss his interaction with DC Rodriguez regarding the alleged misconduct of our officers at the Culichi Town restaurant." 15 16 32. Commander Moreno's complaint also detailed some of the reports to him and by him: 17 "Approximately a week after the incident,I was approached by Sergeant Luis Barragan,who at the time was assigned as the Watch 2 sergeant of the Southcoast District(280). I subsequently learned 18 from Sergeant Barragan, that he was not working on the night of the incident, however when he 19 returned to work,he learned about the incident which had occurred at the Culichi Town restaurant. Officer's that responded to the call were concerned how the alleged sexual assault by one of 20 members of the MET team was investigated. Sergeant Barragan stated that his officers told him that some members from the SAPD's Major Enforcement Team (MET) were off-duty and were 21 patronizing the Culichi Town Restaurant. Sergeant Barragan indicated that his officers told him that 22 Officer Andres Gil also responded and proceeded to interfere and impede in the manner in which the investigation was conducted. Sergeant Barragan also learned that one of the responding officers 23 viewed a cell phone video that had been taken by an unknown patron.According to this officer,he 24 told Sergeant Barragan that the video had captured Sergeant Lizardi (off-duty) at the incident. Sergeant Barragan's officers were concerned because it involved members of the MET team and 25 because there was outside interference by on and off-duty officers at the scene. They felt that the sexual assault investigation had not been handled properly because members of the MET team had 26 been involved and other officers (on-duty and off-duty officers) ensured that the proper 27 documentation and notifications were not conducted.They also expressed concern of retaliation from members of other SAPD personnel if they reported this alleged misconduct in a formal manner. 28 After Sergeant Barragan's reporting of the alleged misconduct, I met with my direct supervisor, Deputy Chief Eric Paulson. I advised Deputy Chief Paulson of what had been reported by Sergeant s KACHnusKYv. CITYOFSANTAANA CASENo. COWLAINF I Barragan. Deputy Chief Paulson was immediately concerned about the allegations and we agreed 2 that I would formally advise Deputy Chief Rodriguez,who at the time of this incident still held the rank of Commander and was the Commander of the Internal Affairs Unit.As I prepared to meet with 3 Deputy Chief Rodriguez, he stopped by the Watch Commanders Office. I told DC Rodriguez that 4 I had something important to discuss with him. He sat down and I reported the alleged misconduct that Sergeant Barragan had reported to me. 5 I specifically told DC Rodriguez that Sergeant Lizardi was allegedly present when members of our 6 MET team were involved in an alleged sexual assault incident at the Culichi Town Restaurant. I 7 printed a copy of the incident from the INFORM RMS system and I handed him the copy of the call for his review. We ended our conversation and he exited the Watch Commander's Office. 8 9 I immediately reported this interaction, in person, to DC Paulson. This interaction was done in person and I also believe we may have/or not have exchanged emails, about our conversations 10 referencing this matter. 11 I also shared my interactions, with DC Rodriguez, with my peer Commander Chuck Elms. 12 Specifically, we discussed that it appeared that DC Rodriguez had not taken my complaint of misconduct seriously and was not going to immediately initiate an Internal Affair's investigation 13 14 In addition, another SAPD field supervisor expressed to me similar misconduct allegations that Sergeant Barragan had made. This supervisor is fearful of retaliation by SAPD personnel so he/she 15 is not comfortable, at this time, to be identified. 16 A few weeks after my interaction with DC Rodriguez,I was talking to Commander Andrew Alvarez. 17 We began discussing the incident at Culichi Town, I told him about my interaction with DC Rodriguez and Commander Alvarez told me that he too had received complaints from some of his 18 officers about the alleged sexual assault at Culichi Town. Commander Alvarez also told me that he 19 had also reported the alleged misconduct by our officers to DC Rodriguez." 20 33. Per CITY's Police Department Policy 1010.8,both Chief David Valentin and Assistant Chief 21 Robert Rodriguez should have immediately been placed on administrative leave.However, as of the filing 22 of this Complaint, both Chief David Valentin and Assistant Chief Robert Rodriguez remain at CITY, 23 24 directly supervising Commander Moreno. 25 E. CITY's Sergeant Position and Sergeant Promotional. 26 34. The position of Police Sergeant is a civil service protected supervisory position and 27 candidates are selected from the ranks of current police officers. CITY employs a selection process for the 28 position of Police Sergeant consisting of several components that are touted as being fair and unbiased.After 9 KACHimwy v. CITY OF SANTA ANA CASENo. COWLAINT I meeting minimum qualifications of years of service, candidates complete a written test and series of three 2 interviews. Based on combined scores from the test and interviews, the candidates are then placed on a 3 4 ranked eligibility list - valid for two years. As Police Sergeant vacancies occur (through promotion or 5 retirements), candidates from the eligibility list are used to fill the open positions. 6 35. In theory, the testing process is designed to select/rank the most suitable and qualified 7 candidates through a completely fair and impartial process. However, in practice,this is far from the case. 8 9 F. CITY's 2015-2016 Modifications to the Sergeant Promotional. 10 36. Pre 2015-2016, per the norm in nearly all municipal police departments across the nation, 11 officers and detectives who were not Corporals were eligible to test for Sergeant.However,in or about 2015- 12 2016, CITY modified the Sergeant selection process from the format of previous years by instituting a 13 14 requirement that candidates testing for the position of Sergeant must first be Corporals. 15 37. The position of Corporal is a non-civil service classification consisting of a hybrid between 16 line level and supervisory duties.A Corporal therefore performs the normal duties of a police officer but is 17 also permitted a limited amount of supervisory duties. In reality,CITY Corporals are usually tasked by their 18 19 Sergeants with completing administrative paperwork and responsibilities that a Sergeant would(and often 20 should)normally perform. This frees up Sergeants from having to do undesirable tasks and is justified as 21 a means of"developing" Corporals. 22 38. In addition to requiring that Sergeant candidates be Corporals,CITY shortened the selection 23 24 process. The new process consisted of a written test, followed shortly thereafter by two internal interviews 25 hosted on the same day for each candidate and concluding with an external interview conducted by ranking 26 members from outside agencies. The two internal interviews held the heaviest weight in terms of scoring 27 by accounting for 50% of the overall score. 28 io KACAIItISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 39. The stated purpose of these changes was to make the selection process shorter(now a period 2 of weeks as opposed to months)and to provide greater flexibility for command staff to select the candidates 3 4 they deemed appropriate. However,it became common knowledge throughout CITY that this process was 5 designed to allow for greater internal control over who would be selected and to negate the possibility for 6 the promotion of"unpopular/undesirable" candidates. 7 40. Essentially, CITY wanted to be able to essentially make it easier to pick the "preferred" 8 9 candidates.Needless to say,this contradicts the fundamental principles of the selection process that the best, 10 most qualified candidates be selected in a fair, equal, and impartial manner. 11 G. The Promotional Process and Chief Valentin. 12 41. Following David Valentin's February 2018 permanent appointment to Police Chief, CITY 13 14 maintained the above-described testing process so as to allow the selection of candidates Valentin and his 15 immediate circle of supporters deemed "acceptable".Nonetheless, occasionally a candidate deemed "not 16 acceptable"made it through the selection process.This was attributed to those particular candidates'ability 17 to perform exceptionally well on the written and outside interview tests.Therefore,it soon became common 18 19 that candidates who were not part of"the Valentin camp"were encouraged to perform exceptionally well 20 in order to simply pass the selection process and avoid being eliminated. 21 42. Meanwhile,those candidates deemed members of"the Valentin camp"merely had to perform 22 at minimal standards and could be assured of being selected. A double standard therefore became 23 24 institutionalized in the selection process. Those candidates who were"approved of by Chief Valentin and 25 his "camp" only had to show up with minimal preparation and could be assured they would be selected. 26 Meanwhile, candidates disliked by "the Valentin camp" had to perform at the highest levels possible 27 (typically through very extensive preparation)and,even then,their success in passing could not be assured. 28 In sum, the process had become unfair, biased, discriminatory and contrary to law. KAcHmisKY v. CFFY OF SANTA ANA CASE NO. COMPLAINT I H. In 2017, prior to the Culichi Town Incident, KACHIRISKY was Promoted to 2 Corporal. 3 4 43. In July of 2017,KACHIRISKY became the Traffic Representative on the Board of Directors 5 for the Police Officers Association("POA")Board. At the time, Sergeant Gerry Serrano was the President 6 of the POA Board. 7 44. In September-October 2017, KACHIRISKY tested for the position of Corporal. 8 9 45. The testing process for Corporal was essentially an abridged version of the Sergeant testing 10 process as it consisted of a multiple-choice written test and an internal resume-based interview in front of 11 a 3-member panel of ranking department members. Interestingly, at that time the written test for Corporal 12 was much more difficult than the written test for Sergeant. The internal resume-based interview was 13 14 identical to that of Sergeant. It required the candidate to submit an "enhanced" resume covering four 15 dimensions of supervision and leadership and then undergo an interview consisting of four questions 16 covering each dimension.Typically,the questioners simply asked the candidate to give an example of how 17 they demonstrated that particular dimension as applicable to the position. 18 19 46. KACHIRISKY performed very well on the Corporal test and was ranked in the No.2 position 20 on the eligibility list. 21 47. In or about November of 2017, KACHIRISKY was promoted to the position of Corporal. 22 I. In the Fall of 2020, KACHIRISKY applied for a Promotion to Sergeant. 23 24 48. In September of 2020, after serving nearly three successful years in various Corporal 25 assignments, KACHIRISKY - who met the qualifications for promotion - applied for the position of 26 Sergeant. 27 49. KACHIRISKY took the written multiple choice examination and passed, performing very 28 well and scoring in the mid-90 percentile. 12 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 50. At this time,the written multiple-choice examination was a hybrid test of questions obtained 2 from an outside vendor(Donnoe &Associates) and questions written by ranking internal members of the 3 4 department from the Human Resources Division.Outside vendor Donnoe's questions typically covered legal 5 concepts("Legal Sourcebook"case law and search and seizure tenets)and the internally generated questions 6 generally covered City policy and procedure material. 7 51. After the conclusion of the written test, a 5-day"grievance period"was allowed for all test- 8 9 takers. 10 52. KACHfRlSKY progressed to the internal interviews two weeks after the written test. This 11 consisted of two interviews held back-to-back on the same day for each candidate. Each interview was 12 conducted in front of a different panel of three ranking members of the department, consisting of two 13 14 Lieutenants and one Sergeant. 15 53. One interview was a timed"Practical Exercise"in which the candidate was prompted through 16 a tactical scenario by the interviewers and graded on their response in appropriately handling the scenario 17 as a field Sergeant. 18 19 54. The second interview was an "Enhanced Resume Assessment" interview identical to the 20 Corporal interview in which the candidate answered four questions related to each of four dimensions on 21 the enhanced resume previously submitted in the initial application. The four questions were similar in that 22 they simply asked the candidate to provide "one example" from the particular dimension and how that 23 24 example demonstrated they were prepared to be a Sergeant. The"Enhanced Resume Assessment"interview 25 utilized by CITY is an odd means of assessing qualifications that has morphed into a ridiculous absurdity 26 and charade.The interview is structured with the panel members instructing the candidates at the outset that 27 there will be no opening statement allowed by the candidate. Additionally,the panel members instruct the 28 candidates to provide only"one" example from the candidates experience to illustrate each dimension. 13 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 55. Nonetheless, it has become common knowledge and practice that in order to actually pass 2 the interview the candidate must in fact provide an opening statement in their response to question of the 3 4 first dimension. Additionally,the candidate must try to touch on or allude to multiple examples from their 5 personal experience in each response before narrowing down to one primary example. As panel members 6 have remarked about their experience in doing these interviews, there is an unwritten "formula" that has 7 become the norm in these interviews that candidates must follow in order to pass. Simply answering the 8 9 questions as asked is not sufficient. 10 56. To make matters worse,the biased scoring on these panels (both the Practical Exercise and 11 Enhanced Resume)became common knowledge to department members and the scoring became a veritable 12 game to assure the success of the popular candidates. Those ranking members who served on these panels 13 14 readily admitted that favorable candidates (i.e., "the Valentin camp") were scored highly regardless of 15 performance. Likewise, unfavorable candidates (i.e., "the POA camp")were scored poorly or failed even 16 when performing well.Moreover,favorable candidates were provided with outlandishly high scores on the 17 internal interviews to ensure that no matter how poorly they performed or had performed on the written test 18 19 and external interview,they would still rank highly on the eligibility list due to the heavy overall weight of 20 the internal interviews.Panel members even remarked about having provided their preferred candidates with 21 scores of 100% across the board in all dimensions just to ensure that they would do well in the final 22 rankings, regardless of their actual performance in the interviews. As these scores were arbitrary based on 23 24 the panelists' own opinions,they could not(at the time)be questioned or held to any type of accountability. 25 The complete lack of integrity and moral bankruptcy of this process was apparent, but nonetheless 26 acquiesced to by department members because there was no alternative means of achieving promotion or 27 advancement without submitting to this process. 28 14 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 57. In anticipation ofthese interviews,KACHIRISKY engaged in customarily proper preparation 2 for these interviews(i.e.,he received interview coaching during his days off from a job interview specialist; 3 4 conducted"mock" interviews with CITY supervisors who provided him with constructive criticism, etc.). 5 58. KACHIRISKY completed the Practical Exercise panel interview. KACHIRISKY then 6 completed the Enhanced Resume Assessment Interview with Lieutenants Sergio Enriquez and Sandra Gatt 7 and Sergeant Sergio Gutierrez.As Valentin decided who sat on these interview panels,the panels consisted 8 9 entirely of those from "the Valentin camp" ( i.e., Enriquez was considered highly incompetent by many 10 department members but had risen in rank solely due to his complete loyalty and subservience to Valentin). 11 59. KACHIRISKY completed the interviews and answered according to the unwritten"formula" 12 required to pass. A 5-day grievance period was provided for both interviews. KACHIRISKY was notified 13 14 a week later that he failed the Enhanced Resume Assessment by purportedly failing three of the four 15 dimensions and that he was eliminated from the testing process. The testing process continued for other 16 candidates who successfully made the eligibility list and were later promoted to Sergeant. KACHIRISKY 17 had outranked several of these candidates in the Corporal testing process or had considerably more 18 19 experience as a police officer and Corporal. 20 60. It became common discussion throughout the police department: (1)that Enriquez was the 21 primary determinant of who passed and failed on the Enhanced Resume Assessment interview;and(2)that 22 Enriquez deliberately failed KACHIRISKY in direct support of Valentin's desires due to KACHIRISKY's 23 24 association with the POA/Serrano and the POA's/Serrano's ongoing attempts to hold Valentin and his 25 supporters accountable for their acts. 26 61. KACHIRISKY and other candidates who had been failed by Enriquez in this part of the 27 testing process spoke directly with Enriquez in the aftermath of the testing process. 28 15 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 62. In these discussions,while it is remarkable that Enriquez(now a Police Captain)would admit 2 to departmental personnel the existence of blatant prejudice and bias in the selection process, Enriquez 3 4 readily admitted that panelists often do not even read the Enhanced Resumes submitted by the candidates. 5 Moreover, Enriquez openly admitted the panelists utilize their own subjective judgment in assessing a 6 candidate's suitability,regardless ofthe candidate's qualifications.Enriquez explained that,because he only 7 served as a supervisor in a patrol capacity and had no additional experience,he was favorable to candidates 8 9 with only patrol experience and biased toward candidates with additional experience. 10 63. KACHIRISKY-fearful of additional retaliation from Valentin and"the Valentin's camp"- 11 did not contest or file a grievance after this testing process in 2020.Additionally,KACHIRISKY is the sole 12 wage earner for a large family and could not afford suffering what Valentin had done to others who 13 14 questioned him or voiced an unpopular opinion (i.e., possible demotion or termination). Moreover, 15 KACHIRISKY was told repeatedly by other department members and supervisors not to complain and just 16 accept his fate as having been failed by Enriquez. KACHIRISKY was told to not "boo hoo" and simply 17 move on or perform better next time. Despite the fact that KACHIRISKY "failed" only because he was 18 19 associated with the wrong "camp" (and despite Enriquez's own statements that he would have failed 20 KACHIRISKY no matter how well he performed),KACHIRISKY was criticized by department members 21 for having"failed"the interview. 22 J. The 2020-2022 Time Period. 23 24 64. Between 2020 and 2022, KACHIRISKY concentrated on progressing in his career 25 development and on preparing for the Sergeant position by assuming various Lead Corporal'roles in various 26 capacities, performing all the work of a Sergeant while reporting directly to a Lieutenant. 27 28 A Lead Corporal is a position akin to Sergeant in that it is a Corporal acting in the capacity of a Sergeant when there is no Sergeant present in the chain of command. 16 KAcunu KYv. CITY OFSANTAANA CASENO. COMPLAINT 1 65. KACHIRISKY also continued to serve as a ranking Board Member of the POA and in 2022 2 was elected Vice President. 3 4 66. In March of 2022,KACHIRISKY received a threatening letter via the United States Postal 5 Service at his home from"the silent majority"(i.e.,members of"the Valentin camp")urging KACHIRISKY 6 to "take a stand against Gerry Serrano" and falsely accusing KACHIRISKY of various activities. 7 KACHIRISKY reported this letter to both CITY and to the Glendora postal service. While CITY was 8 9 required to investigate this issue within one year,to date,KACHIRISKY has received no further information 10 from CITY. 11 67. On August 26, 2022, Corporal Paul McClaskey located a "flyer" posted in the police 12 department's third floor west mens' bathroom entitled"Santa Ana Police Officers Association Widows& 13 14 Orphans Fund 2022 Casino Fundraiser"which stated: 15 "Proceeds will help recover funds [KACHIRISKY] borrowed from the Widows &Orphans Fund. Funds will also go to: Gerry[Serrano's] personal legal fees[;] Gerry's bar tab[; and] the soon to be 16 bankrupt legal defense fund." 17 68. Again, KACHIRISKY immediately reported this activity to his direct supervisor [Gil 18 19 Hernandez] at CITY and Corporal McClaskey provided the flyer to the on-duty Watch Commander.Again, 20 CITY failed to comply with its mandated investigation duties. 21 69. On September 1,2021,the POA membership completed a"Vote of No Confidence" against 22 Chief Valentin with the majority voting that they had no confidence that he was capable of being the Chief 23 24 of Police. Despite this, CITY responded - a mere 87 minutes afterwards - by posting a Memo on social 25 media with statements from Mayor Vicente Sarmiento and City Manager Kristine Ridge voicing their 26 support for Chief Valentin. Commander Enriquez then forwarded the Memo to all Department employees. 27 70. The Sergeant eligibility list from the 2020 testing process remained valid from November 28 2020 through November 2022. 17 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 71. As the list neared expiration, only one candidate (Daniel Padron)remained on the list and 2 various irregularities began to arise.Although Chief Valentin had assured Officer Padron that every attempt 3 4 would be made to promote him from the list, shortly before the list expired, Sergeant Alex Lopez (the 5 Adjutant to Chief Valentin)informed Officer Padron that the list expired and that he would not be promoted 6 due to a lack of any Sergeant vacancies.Officer Padron-then disfavored by"the Valentin camp"-had been 7 allowed to"die on the list." 8 9 72. Then, approximately two weeks after expiration of the 2020 Sergeant list, Chief Valentin 10 announced that Sergeant Rosa Ponce De Leon would be promoted to the position of Lieutenant. This 11 promotion - clearly expected by Chief Valentin - created a Sergeant vacancy. It became well known 12 throughout the department that Chief Valentin did this deliberately because he had another specific candidate 13 14 in mind for the position of Sergeant:Johanna Lizardi,wife of Valentin's main confidant and MET member 15 then-Lieutenant Oscar Lizardi. However, in order to promote Johanna Lizardi, a new Sergeant testing 16 process would have to be conducted. 17 K. The December 2022 Sergeant Promotional: 18 19 73. In mid-December 2022, Human Resources Captain Enrique Esparza emailed an 20 announcement that the Sergeant's Testing Process was to begin soon.This caused tremendous stress among 21 potential testing candidates,including KACHIRISKY, as the department was beginning the testing process 22 during the holidays for only one potential vacancy that was already unofficially slated for Johanna Lizardi. 23 24 (It was also unusual for the department to suddenly embark on an extensive and costly selection process for 25 one vacancy when it typically would wait for additional openings before commencing such an ordeal.) 26 Moreover,this placed undue added stress on those candidates deemed opposed to"the Valentin camp"such 27 as KACHIRISKY. 28 18 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 74. KACHIRISKY would have to study and prepare much more thoroughly than candidates in 2 "the Valentin camp" (i.e., Lizardi) because he would have to perform exceptionally well just to be 3 4 considered. Meanwhile, candidates in "the Valentin camp" (i.e., Lizardi) would only require minimal 5 preparation and were guaranteed to succeed simply by showing up. 6 75. The announcement became official in early January and KACHIRISKY applied again for the 7 position. KACHIRISKY also submitted an updated Enhanced Resume. 8 9 76. The rumor spreading through the department was that Chief Valentin and his command staff 10 had already created a Sergeant's list (with the top three candidates on the final list to be, in order: (1) 11 Johanna Lizardi; (2) former MET Corporal Travis Johnson; and(3) current MET Corporal Luis Galleana) 12 and that the civil service testing process was simply a"formality". 13 14 77• The testing process was announced by Senior Human Resources Analyst Lourdes Ferrer. Ms. 15 Ferrer is situated on the 4t' Floor of the police department within the Human Resources Division near 16 Valentin's office.While Chief Valentin's command staff and supervisors refer to Ms.Ferrer as an impartial 17 detached city employee, since she is privy to the corrupt practices of Chief Valentin-particularly in recent 18 19 promotional processes related to the Lieutenant and Captain positions-she knowingly operates/colludes in 20 the improper human resources processes. 21 78. Ms.Ferrer stated through written materials(as well as via a verbal"orientation"presentation 22 on January 4, 2023)that the testing process would be nearly identical to the process in 2020. There would 23 24 be a written multiple-choice test of possibly 90 to 100 questions,the two internal interview panels, and an 25 external interview panel. In fact, it was quickly apparent that Ms. Ferrer's handout regarding the testing 26 process was the same used in 2020 because she neglected to even change the previous date to the current 27 date, still using"September 2020."This was the first of many indications that this Sergeant testing process 28 was being hastily assembled and pushed through as quickly as possible. 19 KACAIItISKY v. CFFY OF SANTA ANA CASE NO. COMPLAINT 1 79. Ms.Ferrer's handouts stated that both the internal and practical examinations would be held 2 on the same date for each candidate(as was the usual practice)and that a 5-day grievance period would be 3 4 allowed for each interview. Ms. Ferrer also stated that the panel members had yet to be chosen. However, 5 it was understood by department members that, as the panel members would be chosen by Chief Valentin, 6 they would be highly favorable to his preferred candidates (i.e., those in"the Valentin camp.") 7 80. However,Ms. Ferrer informed the candidates that there would be a change in the multiple- 8 9 choice written test which was a departure from past practice. The test would now entirely consist of"in- 10 house" questions written by"subject matter experts" from within the department. No longer would any I I questions from outside vendors such as Donnoe be utilized.As to whom these"subject matter experts"were, 12 how they were selected, or how they obtained their "expertise" was kept a complete mystery and not 13 14 disclosed. Who was formulating these questions, who vetted them for accuracy or correctness, and, most 15 importantly,who had access to them remained a secret. Of course, this just added to speculation about the 16 increasing corruption of the testing process among department members. 17 81. This change in the written test corresponded to a similar recent change in the Corporal written 18 19 test.The Corporal written test had been altered earlier in 2022 to exclude the difficult Donnoe questions and 20 instead consisted entirely of simpler, easier internally-generated questions. 21 82. It became common discussion that the Corporal test was deliberately"dumbed down" to 22 benefit favorable"Valentin camp" candidates. In particular, the test was engineered to be simpler in order 23 24 to directly benefit members of Chief Valentin's favored MET members,thereby enabling them to pass the 25 test and be promoted. As the MET team members were not known to be particularly astute or highly 26 educated,the Corporal test was specifically re-engineered to their lower capabilities. This was particularly 27 relevant with this Sergeant testing process as it now included several MET team candidates including Travis 28 Johnson and Luis Galleana. It appeared a similar dynamic was now being utilized on the Sergeant's test. ao KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 83. As with the Corporal test,when the preferred candidates passed the written test,their scores 2 would later be artificially inflated on the internal interviews to ensure high placement on the final eligibility 3 list. 4 5 84. Ms. Ferrer further announced a new change in that the times and dates of the testing 6 components would now be "self-scheduled"by the candidates themselves. This was a departure from past 7 practice in which the test times for each candidate were randomly(and therefore fairly as possible)generated 8 9 by computer.Now candidates would be notified via email when they could log on and register for time slots 10 to take the test/interview.Naturally,this led to widespread speculation as to whether the notifications would 11 be emailed simultaneously or if certain candidates(i.e.,"the Valentin camp", specifically Lizardi and MET 12 team members)would receive it first and therefore schedule times most convenient for them. As this was 13 14 also kept a complete secret, speculation ran rampant about the widespread and increasing unfairness of the 15 process. 16 85. In the run-up to the written test, the names of the panel members were finally announced. 17 The names were announced so that candidates could no longer speak with them or seek guidance from them 18 19 about the promotional process.The Practical Exercise panel consisted of Lieutenants Mat Sorensen and Gil 20 Hernandez and Sergeant Gary Couso. Sergeant Couso was the current MET Sergeant and all three were 21 closely affiliated with the SWAT Team. Moreover, all three were considered to be within "the Valentin 22 camp"and highly approved by him. The Enhanced Resume Assessment panel consisted of Lieutenants Joe 23 24 Marty and Roland Andrade and Sergeant Ricardo Diaz,all three of whom were considered to be within"the 25 Valentin camp." 26 86. On January 25, 2023, KACHIRISKY completed the written test which consisted of 90 27 questions.Unlike previous tests,this test contained very few questions related to Legal Sourcebook case law 28 and search and seizure issues. The test primarily concerned policy and procedure matters. 21 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 87. Moreover, the test contained a number of questions taken directly from prior Sergeant and 2 Corporal written tests. Some of the material was dated and no longer applicable.Not only did this give rise 3 4 to the question of the reliability of the so-called"subject matter experts,"but it demonstrated how rapidly 5 the test had been assembled.It appeared to have been"thrown together"in a rush to push it through. As the 6 test was relatively simple compared to previous tests,all of the candidates,including KACHIRISKY,passed 7 the test. 8 9 88. During this time, Valentin appointed Lieutenant Lizardi to be in charge of the Training 10 Division and Human Resources. Moving Lizardi to Human Resources (where he would be privy to 11 information concerning the test and testing results)was an enormous conflict of interest,given that his wife 12 was currently in the testing process. 13 14 89. The internal interviews were scheduled to occur two weeks after the written test-which was 15 normal practice in the Sergeant and Corporal testing processes.It became known that there was a scheduling 16 problem with Lieutenant Andrade as he had training during the week of the interviews.Department members 17 confirmed this was correct through the ISE departmental scheduling system. Typically in this situation, 18 19 which frequently arises during testing processes,another ranking member of the department would be called 20 to fill in for the unavailable panel member. Lieutenant Andrade's impending absence from the process 21 created a considerable stir among applicants because the remaining lieutenants who could replace him were 22 those considered(wrongly or rightly)to be from"the POA camp". In other words, only lieutenants whom 23 24 Chief Valentin and his faction had labeled as "opposition"were available to replace Lieutenant Andrade. 25 This generated some excitement among those candidates deemed unpopular or associated with the wrong 26 "camp"because there was a chance now that the panel might become slightly less biased against them with 27 a lieutenant not from the Valentin camp. 28 zz KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 90. However,not one to leave anything to chance,Chief Valentin made the unprecedented move 2 of rescheduling the Enhanced Resume Assessment interview to the following week.This allowed Lieutenant 3 4 Andrade to remain on the panel and it avoided the "risk" of having to place a potentially unfriendly 5 lieutenant on the panel. 6 91. This unusual and unprecedented move by Chief Valentin to change the date of the Enhanced 7 Resume Assessment interview created confusion among the candidates as to when the Practical Exercise 8 9 would be held.It was assumed that,in congruence with past practice that the interviews be held on the same 10 day, the Practical Exercise would also be pushed back a week. Moreover, since each interview required a 11 5-day grievance period, the Practical Exercise could not be held a week before the Resume Assessment. 12 However,contrary to past practice,CITY announced that the Practical Exercise was to be held as scheduled 13 14 and, therefore, occur a week before the Enhanced Resume Assessment. 15 92. The 5-day grievance period for the Practical Exercise was simply eliminated.The elimination 16 of a grievance period for an internal interview was not only extremely unusual, but highly unprecedented 17 for a civil service hiring process. When Ms. Ferrer was confronted by candidates about this elimination of 18 19 the grievance period for the Practical Exercise interview, she informed them that the grievance period did 20 not apply to this interview (despite past practice and what was written on her own handouts). Ms. Ferrer 21 claimed that,because the Practical Exercise was based on a strict point scoring system, it was ineligible for 22 grievance. 23 24 93. However, as all of the components of the testing process were points-based (and even the 25 written test which was an objective point scoring test had a 5-day grievance period), this made absolutely 26 no sense and was completely counterintuitive. Moreover, the Practical Exercise is far from an unbiased, 27 purely points-based scoring system. The interview involves a tactical scenario and there are no absolute 28 singular correct answers in these scenarios;otherwise,all police officers would be taught the one correct way 23 KACAIItISKY v. CFTY OF SANTA ANA CASE NO. COMPLAINT I to address these scenarios in the police academy and in training. Rather,these practical exercises and their 2 assessment are highly subjective and open to broad interpretation. Clearly, Ms. Ferrer was trying to justify 3 4 a decision made by Chief Valentin over which she either had no authority or control or she was simply 5 unwilling or afraid to oppose him. 6 94. On February 9, 2023, KACHIRISKY completed the Practical Exercise. There were no 7 observers or members of Human Resources present during the interview.The panelists were essentially left 8 9 to their own devices.KACHIRISKY was informed later that day that he had passed the interview and would 10 proceed to the Enhanced Resume interview the following week. 11 95. However, in the aftermath of the Practical Exercise interviews, a disturbing revelation was 12 uncovered through conversations between department members and panel interviewers. One of the 13 14 candidates had clearly failed the interview based on their unsatisfactory responses to the scenario.Two panel 15 members readily agreed that the candidate had failed. Another panel member indicated that he personally 16 worked with the candidate,however,and knew the candidate could properly handle the scenario despite not 17 being able to articulate it sufficiently to pass the interview. This panel member subsequently persuaded the 18 19 other two panel members to alter their scores in order to allow the candidate to pass. Department members 20 immediately began to speculate as to the identity of this candidate as well as how many other candidates 21 received this type of preferential treatment or treatment of the opposite effect. 22 96. On February 16, 2023, KACHIRISKY completed the Enhanced Resume Assessment. A 23 24 civilian employee from the Human Resources Division was present in the interview room. However, she 25 was entirely and obviously preoccupied with her cell phone during the entire course of the interview and 26 seemed to be paying no heed to anything occurring during the interview. 27 97. Candidates were subsequently informed they would not be notified if they passed or failed 28 the Enhanced Resume Assessment until February 27, 2023. This was an inordinately long period of time 24 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT I (well beyond the 5-day grievance period),and the reason provided was that two city holidays resulted in the 2 extended time frame. Talk quickly circulated among supervision, particularly at the patrol level, that this 3 4 extended time fame was being used by Human Resources personnel to alter the scoring on the interviews 5 according to Chief Valentin's preferences. Whether true or not, the mere fact that supervisory level 6 personnel were perpetrating this possibility was a testament to the moral bankruptcy and lack of legitimacy 7 in the selection process. In other words, it had became commonly accepted that the selection process was 8 9 now completely corrupt. 10 98. Candidates were then notified that the External Panel examination was to be held during the 11 second week of March. Information began circulating that Oscar Lizardi had met with potential external 12 panel members at"Avila's El Ranchito"restaurant at 2201 E. Ist Street in Santa Ana. While it would not 13 14 be unusual for a Human Resources Lieutenant to meet with prospective panel members for lunch,the fact 15 remained that Lizardi's wife was involved in the promotional process and the perception of Lizardi meeting 16 with panel members further confirmed the general sentiment that the selection process was entirely biased, 17 fraudulent and corrupt. 18 19 99. On February 27, 2023, KACHIRISKY was notified that he passed the Enhanced Resume 20 Assessment. While KACHIRISKY was relieved,given his prior experience with Enriquez,it was clear that 21 KACHIRISKY's resume was very strong and far surpassed many of the candidates, particular in terms of 22 years of experience in various assignments as a Lead Corporal. 23 24 100. On March 7, 2023, KACHIRISKY completed the External Panel interview. The panel 25 consisted of two lieutenants from the Orange Police Department and the Garden Grove Police Department 26 and a Captain from the Orange County Sheriff's Department. No one else was present in the interview 27 including no representative from Human Resources. 28 zs KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT 1 101. There were two major irregularities from past practice in terms of the interview questions. 2 First,there was no opening statement allowed.To completely eliminate this from the process was extremely 3 4 unusual,previously unheard of in an external panel interview and a dramatic departure from past practice. 5 Candidates are always afforded an opportunity to explain their qualifications to an outside panel in order to 6 familiarize the panel with the candidates'background and preparation for the position.Particularly in terms 7 of the position of Sergeant, the importance of the candidates' experience in supervision and career 8 9 development goes without saying. However, it quickly became apparent why this was done: "The Valentin 10 camp"candidates(Johanna Lizardi and the MET/SWAT candidates)had very weak resumes and a glaring 11 lack of experience, particularly in terms of supervision/leadership and Corporal assignments. Thus, the 12 elimination of the opening statement prevented the other candidates from outshining "the Valentin camp" 13 14 candidates at the very outset of the interviews. In other words, eliminating the opening statement was a 15 major disservice to candidates such as KACHIRISKY and a tremendous benefit to "the Valentin camp" 16 candidates. 17 102. Secondly, the first question(in lieu of the opening statement)was an abbreviated Practical 18 19 Exercise scenario. Despite having already completed a Practical Exercise interview, yet another Practical 20 Exercise scenario was introduced in this external panel interview. The initial Practical Exercise interview 21 involved a scenario in which an armed male was waving a gun and acting erratically in front of his residence. 22 The scenario in the external panel involved an armed suspect with a gun who committed a robbery and had 23 24 been tracked to a specific location(i.e., a slightly different scenario covering the exact same ground). This 25 was not only confusing(should candidates reiterate everything they had said in the Practical Exercise as it 26 involved essentially the same tactical concepts, approaches, and considerations?)but made clear that this 27 question's sole purpose was to serve to benefit the MET/SWAT candidates because of their supposed 28 tactical knowledge and experience by allowing them to highlight their SWAT backgrounds. 26 KACAIItISKY v. CFFY OF SANTA ANA CASE NO. COMPLAINT 1 103. In the aftermath of the External Panel interview and before the final results were released, 2 it came to light that Oscar Lizardi was a friend of the Garden Grove Lieutenant who sat on the external 3 4 panel. Additionally, it also was learned that Lizardi had recently sat on a Sergeant's hiring panel at Garden 5 Grove Police Department and had specifically been asked by the Garden Grove command staff to treat one 6 of their own preferred candidates favorably. In other words, the Garden Grovel lieutenant"owed"Lizardi 7 a favor on this panel. 8 9 104. Based on the information being circulated throughout the department, KACHIRISKY was 10 not hopeful of his chances to withstand such a corrupt process as he was aware that Chief Valentin was 11 extremely vindictive,particularly toward department members such as himself who were affiliated with"the 12 POA Camp". In other words, unlike the other candidates who only had to worry about their own 13 14 performance, KACHHUSKY had to worry about specifically being targeted by Chief Valentin and those 15 acting on his behalf simply for being a perceived member of the "other" camp. 16 105. On March 15, 2023, the results were released and KACHIRISKY was informed he was 17 eliminated from the process after scoring a 61.67% on the external interview. This was in stark contrast to 18 19 his scores in the mid-to-upper 80% range on the other components of the testing. 20 106. The rankings of the final eligibility list confirmed that the selection process was entirely 21 corrupt and tainted to the core. The top three candidates and their order was the exact same as had been 22 forecast by department members before the testing process even began: (1) Johanna Lizardi; (2) Travis 23 24 Johnson;and(3)Luis Galleana.Moreover,all of the preferred SWAT members ranked well and will achieve 25 promotion. As members remarked throughout the department, the blatant corruption was now plainly"in 26 your face." 27 107. Chief Valentin and those acting on his behalf were no longer making any effort to hide the 28 unlawful corruption,favoritism and discrimination even in a so-called"fair"civil service selection process. 27 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT I FIRST CAUSE OF ACTION 2 RETALIATION IN VIOLATION OF LABOR CODE §1102.5 3 4 (Against All DEFENDANTS) 5 108. KACHHUSKY realleges Paragraphs 1 through 107 above and incorporates same as though 6 fully set forth herein. 7 109. KACHHUSKY, as described more fully above,reported/disclosed to a government agency 8 9 and/or law enforcement agency and/or a person with authority over her or to an employee with authority to 10 investigate,discover,or correct legal violations and/or noncompliance to DEFENDANTS. KACHIRISKY 11 had reasonable cause to believe that the information reported/disclosed a violation of state,or federal statute 12 and/or a violation of and/or noncompliance with a local, state and/or federal rule and/or regulation [i.e., 13 14 Penal Code §§186.22, 13670 and Assembly Bill 958 (prohibition of gangs among police officers); 15 Government Code §§12900-12999 (California Fair Employment and Housing Act; Government Code 16 §§12945.2 et seq.); The California Occupational Safety and Health Act of 1973; Labor Code §6310 17 (workplace safety); Penal Code §§ 118, 127, 136.1 (perjury, suborning perjury, witness 18 19 tampering);Government Code§§6250 et seq. (California Public Records Act);Penal Code§§ 832.5, 832.7 20 (police officer confidentiality, internal investigation mandates and public records act compliance)]. 21 110. In response to the disclosures and complaints initiated by KACHIRISKY,DEFENDANTS 22 retaliated against KACHIRISKY as more fully described herein. 23 24 111. Because of the retaliation that KACHIRISKY faced,KACHHUSKY was not promoted and 25 suffered other adverse employment actions. 26 112. DEFENDANTS' treatment of and response to the disclosures, complaints and grievances 27 filed by KACHHUSKY was in violation of Labor Code §1102.5. 28 as KACFIIRISKY v. CFTY OF SANTA ANA CASE No. COMPLAINT 1 113. KACHIRISKY's reporting/disclosure of information was a contributing factor in 2 KACHIRISKY's lack of promotion and suffering of other adverse employment actions. 3 4 114. Asa direct result ofDEFENDANTS'actions as alleged above,KACHIRISKY suffered harm 5 and injury that was legally(proximately)caused by the conduct of DEFENDANTS. Said harm and injury 6 includes, but is not limited to, special (economic) damages, general (non-economic) damages, litigation 7 costs, future damages and past damages, lost economic earning capacity in future employment endeavors 8 9 and such further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. 10 115. Additionally,as a direct and proximate result of the above-described acts of DEFENDANTS, 11 KACHIRISKY has necessarily incurred attorney's fees and costs and he is entitled, per, inter alia,Labor 12 Code §§98.6(b), §1105, 1102.5(f), Code of Civil Procedure §1021.5 and Assembly Bill 1947 to the 13 14 reasonable value of such attorney's fees and costs. 15 16 WHEREFORE, KACHIRISKY prays for Judgment against DEFENDANTS, and each of them, as 17 follows: 18 19 1. For compensatory damages, including loss of earnings, deferred compensation, bonuses, 20 vacation and other employment perquisites and other special and general damages according to proof, 21 2. Damages for pain and suffering and emotional distress; 22 3. Interest, including pre judgment interest, at the prevailing legal rate; 23 24 4. Attorneys' fees and costs incurred herein; and 25 5. Costs of suit; and 26 6. Such further and other relief as the Court deems just and proper. 27 28 29 KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT I REQUEST FOR TRIAL BY JURY 2 KACHIRISKY hereby demands a Trial by Jury. 3 4 5 DATED: September 5, 2023 LAW OFFICE OF LAWRENCE J. LENNEMANN 6 7 By: Lawrence J Lennemann 8 LAWRENCE J. LENNEMANN 9 Attorneys for Plaintiff JOHN KACHIRISKY 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 30 KACHiRisKY V. CITY OF SANTA ANA CASENo. COWLAINT Becerra, Alexis From: Jackie Angel Investor < Sent: Wednesday, April 1, 2026 2:00 PM To: eComment Cc: Durham, Daniel Subject: Re: CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION SAPID is the liability Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Nelson Menendez vs. City of Santa Ana police officer retaliation employment claim "On April 24 2023, Menendez exhausted his administrative remedies by causing City to be served with a government claim. On May 24 2023, although Ciity, via its third party administrator, acknowledged receipt of the claim and stated that it "would be communicating with Menendez in the near future in regard to this matter", Menendez was never contacted and the claim was denied by operation of law. Regarding employees being made to choose sides, gang camps within ranks Chief Valentin's gang vs. POA Gerry Serrano "Despite these numerous claims of unlawful conduct over the years, City has allowed this unlawful conduct to continue. "The coverup of officer John Rodriguez illegal immoral acts because of your friendship with officer Rodriguez City's Major Enforcement Team - met part of Chief Valentin's gang continued to act unlawfully The Brandon Lopez shooting "As City is well aware, on September 28th 2021, Brandon Lopez was shot and killed by members of the Anaheim Police department within City limits. For unknown reasons, despite the fact that the standoff occurred within City limits and, thus, within City's jurisdiction, Chief Valentin handed over control of the incident to the Anaheim Police department. "Wherefore, Menendez prays for judgment against defendants, and each of them, as follows: 1. For compensatory damages, including loss of earnings, deferred compensation, bonuses, vacation and other employment perquisites and other special and general damages according to proof; 2. Damages for pain and suffering and emotional distress; 3. Interest, including prejudgment interest, at the prevailing legal rate; 4. Attorneys fees and costs incurred herein; and 5. Cost of suit; and 6. Such further and other relief as the court deems just and proper. REQUEST FOR TRIAL BY JURY Menendez hereby demands a trial byjury. Dated July 28, 2023 https://citVofsantaanaca.nextreguest.com/requests/26-719 1 From:Jackie Angel Investor<jcordova4@msn.com> Sent: Sunday, March 15, 2026 7:21 PM To: eComment<ecomment@santa-ana.org> Subject: CONFERENCE WITH LEGAL COUNSEL—EXISTING LITIGATION Hello, we would like details on these closed session cases and why so many Santa Ana police officers are suing us. https://citVofsantaanaca.nextrequest.com/requests/26-719 CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION Frank Rocha v. City of Santa Ana, WCAB Case No.: ADJ15955468; ADJ18623576; ADJ17697034 B. Stephen Hahm v. City of Santa Ana, WCAB Case No.: ADJ19377542; ADJ19377509; ADJ19885630 A. Anthony Cardenal v. City of Santa Ana, Orange County Superior Court Case No. 30-2022-01293127 B. John Kachirisky v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01348299 C. Nelson Menendez v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01339537 D. Manuel Moreno v. City of Santa Ana, Orange County Superior Court Case No. 30-2024-01372127 E. Rita Ramirez v. City of Santa Ana, Orange County Superior Court Case No. 30-2022-01287702 F. Judith Valdez v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01359457 From: Jackie Angel Investor <jcordova4@msn.com> Sent: Tuesday, October 8, 2024 11:30:39 AM To: scarvalho@santa-ana.org <scarvalho@santa-ana.org>; anunez@santa-ana.org <anunez@santa-ana.org> Cc: Ryberg, Erinn <Erinn.Ryberg@asm.ca.gov>; eComment <eComment@santa-ana.org> Subject: City of Santa Ana, Formal Complaint Filed - City Attorney Notice Sonia R. Carvalho, FIRED As general counsel to the City Today I was assured you would never be of service to me. After all these years, you offer me nothing, not even a return phone call. As our City Attorney, you can't be bothered. You are hereby put on notice. You are no longer my city attorney. Never did you represent me. f We The People} Never did you provide services for me<. Never did you counsel me or guide me in matters regarding the City of Santa Ana. This is the acknowledgement. -Santa Ana California Frank E. Rocha, a Police Services Dispatcher for the City of Santa Ana in 2024, had a total salary of $9,344.00, with regular pay of$8,639.09 . Total compensation including benefits and pension debt was $16,454.45. Stephen C. Hahm is a Police Officer for the City of Santa Ana, California, with a reported total pay of $337,526.05 in 2024, according to data from Transparent California. His compensation included a high regular salary along with additional pay and benefits typical of law enforcement officers. • 2024 Salary: $337,526.05 2021 Salary: $110,839.50 2 Anthony Cardenal earned $207,331 in 2017, according to public payroll data from Santa Ana. His job title was listed as a Police Officer. John Kachirisky, a Police Officer for the City of Santa Ana, had a total pay and benefits package of $347,114.56 in 2022 • 2022 (Pension Debt): $92,990.41 • Nelson A. Menendez worked as a Police Officer for the City of Santa Ana, earning a total pay of $196,996.30 which included a regular salary of$112,104.00. His total compensation, including benefits and pension debt coverage, was $361,812.66. • Salary Breakdown (2022): • Total Pay: $196,996.30 • Regular Pay: $112,104.00 • Benefits: $69,745.32 • Pension Debt: $95,071.04 • Manuel Moreno J. earned $432,264 in 2024, according to public payroll data from Santa Ana. His job title was listed as a Police Lieutenant (Rm). • According to public records, Manuel Moreno J.'s salary increased by 38% ($118,565) from 2023 to 2024. • Manuel Moreno J.'s salary was 190% higher than the average and 220% higher than the median salary at Santa Ana in 2024. • His salary was 164% higher than the average Police Lieutenant salary in 2024. Judith A. Valdez Police Officer (2020) Regular pay: $107,820.00 Overtime pay: $13,919.75 Other pay: $42,079.52 Total pay: $163,819.27 Benefits: $65,508.11 Pension debt: $68,406.54 Total pay & benefits: $297,733.92 3 Becerra, Alexis From: Jackie Angel Investor < Sent: Wednesday, April 1, 2026 2:55 PM To: eComment Cc: Durham, Daniel Subject: Re: CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION Ramirez Complaint Attachments: Ramirez_-_Complaint[2].pdf Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Rita Ramirez vs. City of Santa Ana police department retaliation employment claim "On July 18 2022, Ramirez exhausted administrative remedies by causing City to be served with a government claim. On July 20th 2022, although City, via its third party administrator, acknowledged receipt of the claim and stated that it "would be communicating with Ramirez in the near future in regard to this matter", Ramirez was never contacted and the claim was denied by operation of law. Additionally on or about July 18th 2022, Ramirez filed a complaint with the department of Fair employment and housing and on July 25th 2022, Ramirez caused both her complaint and the resulting right to sue notice to be served on City. Police chief's gang like loyalty tests Physical threats made against employees to pick a side Sexual harassment, condescending behavior from superiors City continually unlawfully retaliate against Ramirez Unlawful termination of employee by City "Wherefore, Ramirez prays for judgment against defendants, and each of them, as follows: For compensatory damages, including loss of earnings, deferred compensation, bonuses, vacation and other employment perquisites and other special and general damages according to proof; Damages for pain and suffering and emotional distress; Interest, including prejudgment interest, at the prevailing legal rate; Attorneys fees and costs incurred herein; and Cost of suit; and Such further and other relief as the court deems just and proper. REQUEST FOR TRIAL BY JURY Ramirez hereby demands a trial by jury. Dated October 21, 2022 https://citVofsantaanaca.nextreguest.com/requests/26-719 From:Jackie Angel Investor<jcordova4@msn.com> Sent: Sunday, March 15, 2026 7:21 PM To: eComment<ecomment@santa-ana.org> Subject: CONFERENCE WITH LEGALCOUNSEL—EXISTING LITIGATION 1 Hello, we would like details on these closed session cases and why so many Santa Ana police officers are suing us. https://citVofsantaanaca.nextrequest.com/requests/26-719 CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION Frank Rocha v. City of Santa Ana, WCAB Case No.: ADJ15955468; ADJ18623576; ADJ17697034 B. Stephen Hahm v. City of Santa Ana, WCAB Case No.: ADJ19377542; ADJ19377509; ADJ19885630 A. Anthony Cardenal v. City of Santa Ana, Orange County Superior Court Case No. 30-2022-01293127 B. John Kachirisky v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01348299 C. Nelson Menendez v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01339537 D. Manuel Moreno v. City of Santa Ana, Orange County Superior Court Case No. 30-2024-01372127 E. Rita Ramirez v. City of Santa Ana, Orange County Superior Court Case No. 30-2022-01287702 F. Judith Valdez v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01359457 From: Jackie Angel Investor <jcordova4@msn.com> Sent: Tuesday, October 8, 2024 11:30:39 AM To: scarvalho@santa-ana.org <scarvalho@santa-ana.org>; anunez@santa-ana.org <anunez@santa-ana.org> Cc: Ryberg, Erinn <Erinn.Ryberg@asm.ca.gov>; eComment <eComment@santa-ana.org> Subject: City of Santa Ana, Formal Complaint Filed - City Attorney Notice Sonia R. Carvalho, FIRED As general counsel to the City Today I was assured you would never be of service to me. After all these years, you offer me nothing, not even a return phone call. As our City Attorney, you can't be bothered. You are hereby put on notice. You are no longer my city attorney. Never did you represent me. {We The People} Never did you provide services for me<. Never did you counsel me or guide me in matters regarding the City of Santa Ana. This is the acknowledgement. -Santa Ana California Frank E. Rocha, a Police Services Dispatcher for the City of Santa Ana in 2024, had a total salary of $9,344.00, with regular pay of$8,639.09 . Total compensation including benefits and pension debt was $16,454.45. Stephen C. Hahm is a Police Officer for the City of Santa Ana, California, with a reported total pay of $337,526.05 in 2024, according to data from Transparent California. His compensation included a high regular salary along with additional pay and benefits typical of law enforcement officers. • 2024 Salary: $337,526.05 2021 Salary: $110,839.50 Anthony Cardenal earned $207,331 in 2017, according to public payroll data from Santa Ana. His job title was listed as a Police Officer. John Kachirisky, a Police Officer for the City of Santa Ana, had a total pay and benefits package of 2 $347,114.56 in 2022 • 2022 (Pension Debt): $92,990.41 • Nelson A. Menendez worked as a Police Officer for the City of Santa Ana, earning a total pay of $196,996.30 which included a regular salary of$112,104.00. His total compensation, including benefits and pension debt coverage, was $361,812.66. • Salary Breakdown (2022): • Total Pay: $196,996.30 • Regular Pay: $112,104.00 • Benefits: $69,745.32 • Pension Debt: $95,071.04 • Manuel Moreno J. earned $432,264 in 2024, according to public payroll data from Santa Ana. His job title was listed as a Police Lieutenant (Rm). • According to public records, Manuel Moreno J.'s salary increased by 38% ($118,565) from 2023 to 2024. • Manuel Moreno J.'s salary was 190% higher than the average and 220% higher than the median salary at Santa Ana in 2024. • His salary was 164% higher than the average Police Lieutenant salary in 2024. Judith A. Valdez Police Officer (2020) Regular pay: $107,820.00 Overtime pay: $13,919.75 Other pay: $42,079.52 Total pay: $163,819.27 Benefits: $65,508.11 Pension debt: $68,406.54 Total pay & benefits: $297,733.92 3 Electronically Filed by Superior Court of California, County of Orange, 10/21/2022 12:12:55 PM. 30 022-01287702-CU-OE-NJC - ROA#2 - DAVID H. YAMASAKI, Clerk of the Court By K. Trent, Deputy Clerk. 1 JOHN A. GIRARDI, State Bar No. 54917 LAW OFFICES OF JOHN GIRARDI 2 29900 Hawthorne Boulevard Rolling Hills Estates, CA 90274 3 (310) 265-5787 Telephone j ohn(a,j ohngirardilaw.c om 4 LAWRENCE J. LENNEMANN, State Bar No. 134108 5 LAW OFFICE OF LAWRENCE J. LENNEMANN 29900 Hawthorne Boulevard 6 Rolling Hills Estates, CA 90274 (310) 265-5788 Telephone 7 lennemannle(-,gmail.com 8 Attorneys for Plaintiff RITA RAMIREZ 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF ORANGE Assigned for All Purposes 12 Judge Nathan �+u RITA RAMIREZ, an Individual ) CASE NO.: 13 ) 30-2022-01287702-CU-OE-NJC PLAINTIFF RITA RAMIREZ'S COMPLAINT 14 FOR: Plaintiff, ) 15 ) (1)RETALIATION IN VIOLATION OF LABOR CODE §1102.5; 16 vs. ) (2) RETALIATION IN VIOLATION OF THE FAIR EMPLOYMENT AND HOUSING ACT; 17 (3) DISCRIMINATION IN VIOLATION OF 18 ) THE FAIR EMPLOYMENT AND HOUSING CITY OF SANTA ANA, an entity of unknown ) ACT; 19 origin; and DOES 1 - 50, Inclusive, ) (4) HARASSMENT IN VIOLATION OF THE 20 FAIR EMPLOYMENT AND HOUSING ACT; AND 21 (5) FAILURE TO TAKE CORRECTIVE 22 Defendants. ACTION IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 23 24 REQUEST FOR JURY TRIAL 25 Plaintiff Rita Ramirez ("RAMIREZ"or"Plaintiff'), with knowledge as to her own acts and based 26 upon information and belief with regard to all other matters,by and through her attorneys of record,alleges: 27 28 RAminzv. CITYoFSANTAANA CA$ENo. COWLA NT 1 1. RAMIREZ is an individual who, at all times relevant herein, was employed by Defendant 2 City of Santa Ana("CITY"or"Defendant")as CITY's Police Administrative Manager at CITY's business 3 4 office(s) located in the County of Orange, State of California. 5 2. RAMIREZ alleges that CITY is a municipality doing business in the County of Orange, State 6 of California. The Santa Ana City Council,as the governing body of the City of Santa Ana,acts,represents, 7 and implements policy on the behalf of CITY. 8 9 3. Defendants CITY and DOE Defendants 1 through 50 are hereinafter sometimes collectively 10 referred to as "DEFENDANTS". 11 4. On July 18,2022,RAMIREZ exhausted her administrative remedies by causing CITY to be 12 served with a Government Claim. On July 20, 2022, although CITY, via its Third Party Administrator, 13 14 acknowledged receipt of the claim and stated that it"w[ould] be communicating with [RAMIREZ] in the 15 near future in regard to this matter",RAMIREZ was never contacted and the claim was denied by operation 16 of law. Additionally on or about July 18, 2022, RAMIREZ filed a Complaint with the Department of Fair 17 Employment and Housing and, on July 25, 2022, RAMIREZ caused both her Complaint and the resulting 18 19 Right-to-Sue Notice to be served on CITY. 20 5. RAMIREZ is presently not aware of the true names and/or capacities of Defendants DOES 21 1 through 50,inclusive,and therefore sues said Defendants by such fictitious names.RAMIREZ is informed 22 and believes and upon such information and belief alleges that said fictitiously named Defendants are 23 24 directly and proximately responsible for the injuries and damages alleged herein.RAMIREZ will amend this 25 Complaint to allege the true names and capacities of said fictitiously named Defendants when, and if, 26 ascertained. 27 28 a RAminzv. CITYoFSANTAANA CASENo. COMPLAINT 1 6. RAMIREZ is informed and believes, and upon such information and belief alleges,that, at 2 all relevant times, each and every Defendant was a principle, agent, employer, employee, manager, 3 4 supervisor, officer, shareholder and/or owner of each and every other Defendant, and each and every act 5 and/or omission of each and every Defendant occurred by and through the governing body and/or 6 management of the Defendant and within the course and scope of such agency and/or employment and/or 7 was approved and/or ratified by the acts and/or omissions of each and every other Defendant. 8 9 FACTUAL BACKGROUND 10 A. After Almost Three Decades of Exemplary Public Service Employment, 11 RAMIREZ was Recruited by CITY to be its Police Administrative Manager. 12 7. On July 3,2017,following decades ofpublic service,RAMIREZ began her careerwith CITY 13 14 as the Police Administrative Manager after being actively recruited from her prior employment. 15 8. During RAMIREZ's 32 years of service in the law enforcement community(five years with 16 CITY), RAMIREZ was consistently a loyal and hard-working employee who received exemplary 17 performance evaluations. 18 19 9. Despite this, on July 7, 2022, RAMIREZ was unlawfully constructively terminated, after 20 suffering retaliation, discrimination and harassment due to circumstances entirely unrelated to her 21 performance. CITY's termination of, and discrimination, harassment and retaliation against, RAMIREZ 22 violates California law, City's own Municipal Code and policies and procedures and RAMIREZ's civil 23 24 service rights. 25 B. Initially, CITY's Police Chief was Thrilled with RAMIREZ and her Work. 26 10. More specifically,byway of brief background, Chief of Police David Valentin was initially 27 obviously very comfortable with RAMIREZ when she was hired. 28 3 RAminzv. CITYoFSANTAANA CASENo. COMPLAINT 1 11. In fact, Valentin told RAMIREZ that the best thing that now-former Deputy Chief Jim 2 Schnabl ever did for the police department was to hire RAMIREZ. 3 4 C. Initially, RAMIREZ Apparently "Passed" CITY's Police Chief's Gang-Like 5 "Loyalty" Tests. 6 12. Towards the end of February 2018, Valentin called RAMIREZ into his office to discuss 7 "loyalty" and to explain his understanding of the concept of "loyalty". 8 9 13. During this same time frame,as RAMIREZ's then-supervisor Deputy Chief Jim Schnabl had 10 been on leave after being injured on duty,Valentin put RAMIREZ in charge of a proj ect known as Tri-Tech. 11 14. In mid-March of 2018, Valentin asked RAMIREZ to go photograph Schnabl while he was 12 teaching at a Tri-Tech conference. 13 14 15. As it was well-known that Valentin greatly disliked both Schnabl(as well as former Deputy 15 Chief Doug McGeachy), it was obvious that Valentin's intent was to "catch" Schnabl doing something 16 "wrong" and to "gather evidence" against him while he was out on leave. 17 16. Valentin made this request by asking: "Are you down for this?" This phrase struck 18 19 RAMIREZ as odd coming from Valentin as she recognized it as gang term - often used to prove loyalty 20 where a more senior gang member asked an "underling" whether they were willing to do something 21 unsavory for the benefit of the gang. 22 17. In retrospect, Valentin was clearly aware that what he had asked RAMIREZ to do was 23 24 improper'. 25 26 27 28 ' Had Valentin's request been legitimate, Valentin should have instructed Internal Affairs to take the photographs. This is just one of many examples of times when Valentin acts as if he can do what he wants, when he wants and how he wants and that normal procedures did and do not apply to him. 4 RAminzv. CrrYOFSANTAANA CASENO. COMPLAINT 1 18. As RAMIREZ had only been employed for a few months, although she was very 2 uncomfortable with this request,RAMIREZ felt obligated to tell Valentin that she would do what Valentin 3 4 wanted in order to prove her"loyalty" and maintain her employment. 5 19. By this time,RAMIREZ had heard rumblings about how Valentin operated and did not want 6 to be in the position that others were in when they did not adequately prove or show their"loyalty"to him. 7 20. RAMIREZ did attend the conference, took the photos Valentin requested and sent them to 8 9 him from her work phone. 10 21. RAMIREZ felt dirty and used and as though she was being disloyal to the man who recruited 11 her for her job but was afraid that if she did not follow through with Valentin's request that she would be 12 considered"disloyal" and suffer an adverse employment action. 13 14 22• During this time,Valentin met with RAMIREZ on a bi-weekly basis to discuss the Tri-Tech 15 project and was friendly and was very supportive. 16 23. Valentin continued to tell RAMIREZ that she was doing a good job and even personally 17 delivered her uniform bars to her office,leaving a note on her desk and placing her Wonder Woman figurine 18 19 on top of the note. 20 24. Valentin would also routinely acknowledge RAMIREZ in the hallways. 21 25. Valentin regularly met with RAMIREZ and, at times, RAMIREZ would pop in to say"hi" 22 to Valentin and to check in on how he was doing. 23 24 26. On occasions,RAMIREZ and Valentin would have short conversations about family and life 25 in general. RAMIREZ and Valentin would also, on occasion, send each other encouraging text messages. 26 27 28 s RAminzv. CITYoFSANTAANA CA$ENo. COMPLAINT I D. However, CITY's Police Chief Improperly Begins to View RAMIREZ as 2 "Disloyal" for, Inter Alia, Attending the Retirement Party of a then-Deputy 3 4 Chief whom the Police Chief Perceived as an Enemy or Rival. 5 27. Shortly after this time, RAMIREZ received an invitation to Schnabl's retirement event. 6 28. Commander Jose Gonzalez immediately spoke to RAMIREZ about the invitation and told 7 her that, if she was to attend, "the Chief would not be happy." 8 9 29. Concerned,RAMIREZ spoke with Valentin about what Gonzalez had told her. RAMIREZ 10 wondered: Was this yet another test of RAMIREZ's "loyalty"? Was she being "jumped in", so to speak? 11 30. During this conversation,Valentin appeared to be okay with RAMIREZ attending Schnabl's 12 retirement event. 13 14 31. However,Gonzalez later told RAMIREZ that Valentin had been aware of every person who 15 had attended the retirement event and that it had been"a bad idea" for her to go. 16 E. RAMIREZ is then Threatened for Meeting with Another of the Police Chiefs 17 Perceived Rivals/Enemies, the CITY's Police Officers Association President 18 19 Gerry Serrano. 20 32. In or about January of 2020, RAMIREZ had a meeting with Police Officer Association 21 ("POA") President Gerry Serrano. RAMIREZ wanted to assure that she had a good working relationship 22 with the POA and its leadership since RAMIREZ's subordinate evidence employees were POA members. 23 24 33. As RAMIREZ had come to understand that there were issues between Valentin and Serrano 25 and that Valentin also considered Serrano a"rival",RAMIREZ told Valentin about her upcoming meeting 26 with Serrano prior to it occurring. 27 34. This meeting(and subsequent meetings)were strictly business and resulted from RAMIREZ 28 doing her job as a manager. 6 RAminzv. CITYoFSANTAANA CASENo. COMPLAINT 1 3 5. On January 29,2020,Valentin told RAMIREZ in a telephone call that preceded this meeting 2 with Serrano: "You better be careful who you associate with." 3 4 36. RAMIREZ immediately understood that as threat not to meet with Serrano. 5 37. RAMIREZ then began to notice a lot of drama and tension between McGeachy,Schnabl and 6 Peter Semelsburger and others with whom Valentin had"issues." 7 F. CITY, Continuing with its Gang-like Actions, Threatens RAMIREZ to "Pick 8 9 a Camp." 10 38. Around this same time, Gonzalez and then Commander Robert Rodriguez went to 11 RAMIREZ's office and told her that she needed to "pick a camp." 12 39. (It was well known that Valentin viewed Serrano as the leader of the other"camp.") 13 14 40. These "camps" had been the subject of much discussion throughout the department and 15 RAMIREZ felt as though she had just been delivered a message from the "gang leader"(i.e. Valentin)via 16 his more senior gang members. 17 41. RAMIREZ wanted no involvement whatsoever with this situation and explained to them that, 18 19 while she worked for Valentin, she was a CITY employee and would not be forced into choosing a"camp". 20 42. RAMIREZ understood that if she chose Valentin's "camp", she could no longer associate 21 with those who were in Serrano's "camp". 22 43. RAMIREZ was then told that, if she did not pick a"camp",she would end up at the bottom 23 24 of the hill or bottom of the food chain. 25 44. During this time frame, Gonzalez, Anthony Bertagna and RAMIREZ would often go to 26 lunch. 27 45. At the time, RAMIREZ considered Gonzalez a close work friend and felt a lot of pressure 28 from him to pick a"camp". 7 RAminzv. CITYOFSANTAANA CASENO. COMPLAINT 1 46. However,RAMIREZ was steadfast in her conviction that a professional organization should 2 not work this way and that the Santa Ana citizens expected its CITY employees to protect them from gang 3 4 activity- not to act like one. 5 47. At one point Gonzalez and Rodriguez took RAMIREZ to dinner and again told RAMIREZ 6 that she needed to "pick a camp." 7 48. RAMIREZ understood that they liked her and that they were trying to influence her to join 8 9 Valentin's "camp." 10 49. RAMIREZ also understood that,if they had relayed her first refusal to Valentin,RAMIREZ 11 would have already been"cast out." 12 50. RAMIREZ again told them that they were not in high school and she would not pick a 13 14 "camp". 15 51. RAMIREZ made it very clear to them that, while she would support Valentin, she was not 16 going to play this game of choosing sides. 17 52. RAMIREZ told them that she would not agree to completely disassociate herself from people 18 19 who were not in Valentin's "camp" and that she could not- and would not -work that way. 20 53. At this time, RAMIREZ hoped that, as long as she continued to do her job well and work 21 within the boundaries taking a very neutral position, she would be allowed to simply do her work. 22 54. However, Valentin would not allow for that to happen. 23 24 G. CITY's Police Chief Retaliated Against RAMIREZ for her Refusal to Pick a 25 "Camp." 26 55. It soon became clear that RAMIREZ's refusal to pick a "camp" had been delivered to 27 Valentin. 28 56. The way that Valentin communicated with RAMIREZ significantly changed. s RAminzv. CITYOFSANTAANA CASL NO. COMPLAINT 1 57. For sake of example,when RAMIREZ attempted to walk into Valentin's office-just to say 2 "hi"as she had many times in the past-RAMIREZ was stopped by Valentin's assistant, Elizabeth Plotnik. 3 4 58. Plotnik made clear to RAMIREZ that she was no longer allowed to just walk in. 5 59. Additionally, although the Tri-Tech project required Valentin's attention, the bi-weekly 6 meetings that RAMIREZ and Valentin had been having came to an abrupt stop. 7 60. RAMIREZ then attempted to schedule a few meetings with Valentin,only to have him cancel 8 9 each and every one of them. 10 H. CITY Further Retaliated Against RAMIREZ for her Participation in and 11 Opposition to CITY's Conduct in Violation of the Fair Employment and 12 Housing Act. 13 14 61. In September of 2020,a Women Leaders in Law Enforcement conference was conducted on- 15 line. 16 62. A few women CITY employees decided that, due to the training being virtual, they would 17 attend the conference together in a group at one of the sergeant's houses. 18 19 63. All the women that attended were contacted by CITY, ordered to report to the station and 20 ordered to participate in the remaining portion of the conference from there. 21 64. Needless to say,this - coupled with CITY's sexist rude reference to the event as a"pajama 22 party" - created a lot of bad feelings. 23 24 65. Although RAMIREZ only became aware of this incident after the fact,she was asked by the 25 women to attend the remainder of the conference with them at the station. 26 66. RAMIREZ was happy to attend and did so. 27 28 9 RAminzv. CITYoFSANTAANA CASENo. COMPLAINT 1 67. After the conference was over, several of the attendees and RAMIREZ began to have a 2 discussion about how poorlywomen(both sworn and non-sworn)in the department were being treated under 3 4 Valentin's leadership. 5 68. RAMIREZ - as part of management - initially attempted to defend Valentin. 6 69. As soon as Valentin learned of this discussion,he instructed Rodriguez to order RAMIREZ 7 to write a"memo"regarding her discussions. 8 9 70. On September 11, 2020, RAMIREZ did as ordered and submitted her 3-page memo which 10 described the "topics of discussion" as: 11 0 "The language used towards females versus males such as tone, demeanor,verbiage 12 and condescending behavior"; 13 0 "Double standards in regards to the way women are treated in general"; 14 "Retaliation for speaking up.If a woman complains then they are being`emotional. 15 • "If a woman makes a `mistake' then the mistake is magnified or highlighted 16 throughout their career and used against them." 17 71. RAMIREZ's memo also detailed how the women discussed that"this type of behavior is the 18 19 `culture' of the department and appears to be condoned by leadership"; "how [Valentin] is perceived to be 20 supportive of this type of behavior"; and that this behavior"starts at the top". 21 72. Of course, Valentin, himself, has also previously been accused of sexual harassment. 22 73. Additionally,while Valentin loves to give lip service to the phrase"one team,one mission", 23 24 he is known throughout the police department as the single largest violator of this philosophy. 25 74. Valentin is not only content with the division in the department but actively fosters it. 26 75. RAMIREZ came to understand that, when she was ordered to"write the memo",her memo 27 was actually expected to report back to Valentin regarding who said what to whom so the women at issue 28 could be"dealt with" (i.e., RAMIREZ had been expected to "rat out"the women). io RAminzv. CITYoFSANTAANA CASENo. COMPLAINT 1 76. Since RAMIREZ had written her memo in the opposite manner(i.e.,to protect the women 2 who had legitimate claims regarding their treatment under Valentin),RAMIREZ's memo-which spoke to 3 4 the tone and message that the women were trying to communicate-displeased Valentin and was ultimately 5 described by him as "very vanilla". 6 77. In sum, Valentin was upset that the memo failed to provide him with the identifying 7 information so that Valentin could use it later to retaliate against the individual women. 8 9 78. (RAMIREZ is informed and believes that these women have made their own claims against 10 CITY.) 11 79. After RAMIREZ wrote her memo, Valentin went to meet with the women. 12 80. RAMIREZ did not attend that meeting but learned that Valentin simply walked into the room 13 14 accompanied by Rodriguez and Lourdes Ferrer, introduced them to the group and told the women that, if 15 they had any issues with him or anyone in the department,they could report it to either Rodriguez or Ferrer. 16 81. Valentin then turned and left. 17 82. By doing so, Valentin made it abundantly clear that he had no interest whatsoever in 18 19 addressing the real issues set forth in RAMIREZ's memo. 20 83. Rather, Valentin simply said: "If you have a complaint, see these people." 21 84. Valentin's abject lack of leadership at this pivotal moment was a serious blow to the 22 department. 23 24 I. CITY Continued to Unlawfully Retaliate Against RAMIREZ. 25 85. Valentin's demeanor and actions towards RAMIREZ continued to deteriorate and escalate. 26 86. In or around May/June of 2021, a Public Records Act ("PRA") Request was submitted for 27 an email from Sergeant Jim Armstrong to Valentin and others. 28 RAminzv. CITYOFSANTAANA CASL NO. COMPLAINT 1 87. Assistant City Attorney Tamara Bogosian reviewed the PRA and provided RAMIREZ with 2 the document to be released. 3 4 88. The document was then released and printed in a local publication. 5 89. Valentin immediately called a meeting - with an approximate 10-minute notification - to 6 include RAMIREZ, Bogosian, Plotnik and others. 7 90. (This was the first time RAMIREZ had met with Valentin-for any reason-in over one year.) 8 9 91. The obviously-angry Valentin asked why the email had been released. 10 92. RAMIREZ explained that it had been released because it was a responsive public record. 11 93. Despite Bogosian's specific statement to Valentin that she had instructed RAMIREZ to 12 release the document, Valentin became obviously upset with RARMIREZ (not Bogosian), excused 13 14 RAMIREZ from the meeting and then continued the meeting with the rest of the attendees. 15 94. It was evident that RAMIREZ had clearly become Valentin's"fall-guy" - first because she 16 refused to pick a"camp",then because she submitted a memo that did not"rat"on others and then because 17 she refused to withhold properly responsive documents from a PRA request. 18 19 J. CITY Continued to Unlawfully Retaliate Against RAMIREZ. 20 95. Shortly afterwards, although RAMIREZ served as the legally-recognized "custodian of 21 records"for CITY who was legally bound to abide by the PRA, Valentin, in an obvious improper effort to 22 control publicly released information, removed RAMIREZ from the handling of any PRAs that were 23 24 associated with Valentin or his office,the Voice of OC and the POA(or anyone associated with the POA). 25 96. Rather than Valentin following the law (and/or blaming Bogosian for certain decisions), 26 Valentin refused to follow the law,blamed RAMIREZ and began to talk behind RAMIREZ's back, falsely 27 implying to various persons in leadership that RAMIREZ did not know how to do her job. 28 12 RAminzv. CITYOFSANTAANA CASENO. COMPLAINT 1 97. Additionally, Bogosian falsely accused RAMIREZ of attempting to release documents to 2 Serrano and, thereafter, Valentin repeated this false claim at a senior management meeting. 3 4 98. Then, after CITY was sued for failing to release records related to the Brandon Lopez 5 shooting, Sergio Enriquez improperly attempted to blame RAMIREZ for responding - although she had 6 responded in the exact manner that she had been instructed by him. 7 99. Valentin - in a further attempt to improperly"manage' the information provided(or, more 8 9 accurately, not provided)to Serrano - appointed Enriquez to respond to the PRAs. 10 K. CITY Continued to Unlawfully Retaliate Against RAMIREZ. 11 100. Relative to many of the above events,RAMIREZ has been identified as a witness in various 12 other legal matters pending against CITY regarding Valentin's conduct and, to date, has participated in at 13 14 least three separate interviews in which she provided testimony in cases brought by other employees. 15 101. The Fair Employment and Housing Act protects-not only employees who themselves make 16 retaliation, discrimination and harassment claims but - those, like RAMIREZ who: (1) make a charge, 17 testify, assist or participate in any manner in proceedings or hearings under the statute (the "participation 18 19 clause");and/or(2)oppose acts made unlawful by the statute(the"opposition clause"). Government Code, 20 §12940(h). 21 102. CITY's retaliation against RAMIREZ's for her participation in these matters (and for 22 RAMIREZ's expressed opposition to Valentin and CITY's conduct) was clearly additional unlawful 23 24 retaliation and harassment. 25 L. CITY Continued to Unlawfully Retaliate Against RAMIREZ. 26 103. On January 26, 2022, RAMIREZ attended a meeting and Valentin was in the room and he 27 said in front of everyone: "Rita Ramirez, you're still here, huh?", to which RAMIREZ replied: "Yes sir, 28 unless you fired me, and I didn't know about it." 13 RAminzv. CITYOFSANTAANA CASENO. COMPLAINT 1 104. Valentin then said: "I haven't seen your name in lights lately". 2 105. RAMIREZ responded: "Just laying low, sir". 3 4 M. As a Result of CITY's Unlawful Retaliation and Harassment,RAMIREZ was 5 Forced to Take a Leave of Absence. CITY Continued to Retaliate. 6 106. On March 15,2022,RAMIREZ was forced to take a leave of absence as a result of the above- 7 described ongoing treatment. 8 9 107. Although RAMIREZ continued to work part-time from home approving reports and fulfilling 10 certain other responsibilities, she was forced to use her own sick time during this time. 11 108. During this time,CITY,in retaliation,removed the bulk of responsibilities from RAMIREZ 12 (including all PRA requests even though RAMIREZ was not only the official custodian of records but the 13 14 most trained and qualified individual in the police department), only to give her command authority over 15 the CDC/Facilities -with which RAMIREZ had absolutely no experience. 16 109. RAMIREZ learned about this change -not from Valentin himself or from CITY's Human 17 Resources Department but-from a fellow employee who contacted RAMIREZ to ask what had happened. 18 19 110. RAMIREZ told this employee that she had no idea what the employee was talking about. 20 111. The employee then told RAMIREZ that a department-wide email had gone out which 21 publicized the changes in RAMIREZ's job responsibilities. 22 112. (This issue was only addressed after RAMIREZ complained to her direct supervisor and later 23 24 learned that the Police Management Association president met with Valentin.) 25 N. On April 6, 2022, RAMIREZ Made a Formal Written Complaint. 26 113. On April 6,2022,RAMIREZ submitted an Inappropriate Conduct Complaint Report against 27 Valentin to which CITY failed to appropriately respond. 28 114. On May 3, then Deputy Chief Eric Paulson sent the following email to Jason Motsick: 14 RAminzv. CITYoFSANTAANA CA$ENo. COMPLAINT I "Attached to this communication is a performance evaluation for Manager Rita Ramirez.Not 2 knowing if Manager Ramirez will return to work, I wanted to ensure her performance was documented before my retirement next week.For your awareness,Rita's evaluation is not due 3 until July 3rd,but I felt compelled to provide the City with my evaluation/observations of her 4 performance for nine (9) of the 12 months of her rating period." 5 115. Although RAMIREZ is informed and believes that persons specifically substantiated 6 RAMIREZ's claims when interviewed during the "investigation", on August 25, 2022, CITY provided 7 RAMIREZ with a "Notice of Completion of Investigation" which stated, in pertinent part, that "it was 8 9 determined that the allegations were not sustained" and that CITY"determined that no violation of policy 10 occurred." 11 116. However, as later succinctly stated by Serrano following the results of yet another CITY 12 "investigation": 13 14 "Clearly the city has no commitment to provide a discrimination and harassment free workplace, rather quite the contrary. There has been numerous complaints and allegations of cover-up, 15 retaliation, excessive force, corruption, etc. yet every single complaint is dismissed in this fashion. 16 Clearly,this is disheartening and again reasons and evidence why the police department is so toxic 17 and the morale is lower that ever with officers leaving and even looking for career changes. 18 Very, very disappointing!!!" 19 O. On June 20, 2022, RAMIREZ was Constructively Terminated. 20 21 117. On June 20, 2022, RAMIREZ forwarded the following email: 22 "As the City is well aware, I have made a complaint regarding the ongoing harassment, discrimination and retaliation that I have endured.I am also aware that other City employees 23 have made similar complaints and endured similar treatment. In fact, it appears my 24 involvement in these other complaints has also led to additional retaliation against me. 25 Despite the City's knowledge of the above,the situation has escalated to the point where my working conditions have become intolerable.As such, and while I previously loved my job 26 and planned to remain employed for additional years, I certainly wished to end my career 27 under different circumstances. Based on all facts regarding this matter I have no choice but to retire from my position with the City, effective July 7, 2022, as returning to work in the 28 current conditions would be impossible. 15 RAminzv. CITYoFSANTAANA CA$ENo. COMPLAINT I Please forward to me today(via email)my fully-executed Performance Evaluation, sent to 2 you early last month by my supervisor Deputy Chief Paulson prior to his retirement. Please also forward to me today (via email) any necessary documentation to effectuate my 3 retirement. I expect to receive my 5%performance bonus that is due to me on July 3, 2022. 4 Finally, as I have been forced to burn my own time during my forced off absence over the 5 past two months, please confirm today that the City will reimburse me for that time. 6 Please confirm receipt of this email." 7 118. Additionally, CITY refused to both honor RAMIREZ's earned 5%performance bonus and 8 9 to reimburse RAMIREZ for the personal time she was forced to use as a result of Valentin's conduct. 10 119. On July 7, 2022, Claimant was constructively terminated. 11 FIRST CAUSE OF ACTION 12 RETALIATION IN VIOLATION OF LABOR CODE §1102.5 13 14 (Against All DEFENDANTS) 15 120. RAMIREZ realleges Paragraphs 1 through 121 above and incorporates same as though fully 16 set forth herein. 17 121. RAMIREZ,as described more fully above,reported/disclosed to a government agency and/or 18 19 law enforcement agency and/or a person with authority over her or to an employee with authority to 20 investigate,discover,or correct legal violations and/or noncompliance to DEFENDANTS. RAMIREZ had 21 reasonable cause to believe that the information reported/disclosed a violation of state, or federal statute 22 and/or a violation of and/or noncompliance with a local, state and/or federal rule and/or regulation [i.e., 23 24 Penal Code §§186.22, 13670 and Assembly Bill 958 (prohibition of gangs among police officers); 25 Government Code §§12900-12999 (California Fair Employment and Housing Act; Government Code 26 §§12945.2 et seq.);Government Code§§6250 et seq.(California Public Records Act),Penal Code§832.7.] 27 In response to the disclosures and complaints initiated by RAMIREZ, DEFENDANTS retaliated against 28 RAMIREZ as more fully described herein. 16 RAminzv. CITYoFSANTAANA CASENO. COMPLAINT 1 122. Because of the retaliation that RAMIREZ faced,RAMIREZ was constructively terminated 2 (i.e., was forced to resign). 3 4 123. DEFENDANTS' treatment of and response to the disclosures, complaints and grievances 5 filed by RAMIREZ was in violation of Labor Code §1102.5. 6 124. RAMIREZ's reporting/disclosure of information was a contributing factor in RAMIREZ's 7 constructive termination. 8 9 125. Asa direct result of DEFENDANTS'actions as alleged above,RAMIREZ suffered harm and 10 injury that was legally (proximately) caused by the conduct of DEFENDANTS. Said harm and injury 11 includes, but is not limited to, special (economic) damages, general (non-economic) damages, litigation 12 costs, future damages and past damages, lost economic earning capacity in future employment endeavors 13 14 and such further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. 15 126. Additionally,as a direct and proximate result of the above-described acts of DEFENDANTS, 16 RAMIREZ has necessarily incurred attorney's fees and costs and she is entitled,per,inter alia,Labor Code 17 §§98.6(b), §1105, 1102.5(f), Code of Civil Procedure §1021.5 and Assembly Bill 1947 to the reasonable 18 19 value of such attorney's fees and costs. 20 SECOND CAUSE OF ACTION 21 RETALIATION IN VIOLATION OF THE 22 FAIR EMPLOYMENT AND HOUSING ACT 23 24 (Against All DEFENDANTS) 25 127. RAMIREZ realleges Paragraphs 1 through 126 above and incorporates same as though fully 26 set forth herein. 27 28 17 RAminzv. CITYoFSANTAANA CA$ENo. COMPLAINT 1 128. Section 12940,et.seq.ofthe California Government Code makes it unlawful for an employer 2 to retaliate against an employee in "terms, conditions or privileges of employment" because of their 3 4 protected status. The Fair Employment and Housing Act("FEHA")protects,not only employees who make 5 a FEHA claim, but also, those who oppose acts made unlawful by the statute and/or testify, assist or 6 participate in any manner in proceedings or hearings. 7 129. As referenced above,DEFENDANTS retaliated against RAMIREZ:(1)for her"opposition", 8 9 "assistance"and/or"participation"in the FEHA claim of others; and(2) for the making of her own FEHA 10 claim. 11 130. As detailed above,DEFENDANTS engaged in an action or a course and pattern or conduct 12 that, taken as a whole, materially and adversely affected the terms, conditions and/or privileges of 13 14 RAMIREZ's employment. 15 131. As also detailed above,RAMIREZ was treated differently by DEFENDANTS because of her 16 protected status [i.e., sex/gender, disability(physical or mental), association with a member of a protected 17 class, family care or medical leave and for engaging in protected activities (participating as a witness in a 18 19 discrimination/harassment complaint, reporting/resisting discrimination/retaliation, requesting/using a 20 disability related accommodation, requesting/using family care and medical leave]. 21 132. As a direct and legal result of the retaliation against RAMIREZ due to her protected status, 22 RAMIREZ suffered harm and injury that was legally (proximately) caused by the conduct of 23 24 DEFENDANTS. Said harm and injury includes,but is not limited to,special(economic)damages,general 25 (non-economic)damages,attorneys'fees[per Government Code§12965(b)],litigation costs,future damages 26 and past damages, lost economic earning capacity in future employment endeavors and such further relief 27 as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. 28 is RAminzv. CITYOFSANTAANA CASENO. COMPLAINT 1 133. In addition to the damages sought above, as a proximate result of DEFENDANTS' actions 2 as alleged above,RAMIREZ will also seek all damages allowed by the Code. Government Code, §12965(c). 3 4 THIRD CAUSE OF ACTION 5 DISCRIMINATION IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 6 (PLAINTIFF Against All DEFENDANTS) 7 134. RAMIREZ realleges Paragraphs 1 through 133 above and incorporates same as though fully 8 9 set forth herein. 10 135. Section 12940,et.seq. ofthe California Government Code makes it unlawful for an employer 11 to discriminate against an employee in "terms, conditions or privileges of employment" because of the 12 protected status. DEFENDANTS engaged in an action or a course and pattern or conduct that, taken as a 13 14 Whole, materially and adversely affected the terms, conditions and/or privileges of RAMIREZ's 15 employment. 16 136. RAMIREZ was treated differently by DEFENDANTS because of her protected status [i.e., 17 sex/gender, disability(physical or mental), association with a member of a protected class, family care or 18 19 medical leave and for engaging in protected activities (participating as a witness in a 20 discrimination/harassment complaint, reporting/resisting discrimination/retaliation, requesting/using a 21 disability related accommodation, requesting/using family care and medical leave]. 22 137. As a direct and legal result of the discrimination RAMIREZ suffered due to her protected 23 24 status, RAMIREZ suffered harm and injury that was legally (proximately) caused by the conduct of 25 DEFENDANTS. Said harm and injury includes,but is not limited to,special(economic)damages,general 26 (non-economic)damages,attorneys'fees[per Government Code§12965(b)],litigation costs,future damages 27 and past damages, lost economic earning capacity in future employment endeavors and such further relief 28 as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. 19 RAminzv. CITYoFSANTAANA CASENo. COMPLAINT I FOURTH CAUSE OF ACTION 2 HARASSMENT IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 3 4 (PLAINTIFF Against All DEFENDANTS) 5 138. RAMIREZ realleges Paragraphs 1 through 137 above and incorporates same as though fully 6 set forth herein. 7 139. The harassment included but was not limited to unwanted and unwelcome comments directly 8 9 to RAMIREZ that were reported to and by RAMIREZ, as further alleged herein above. As further alleged 10 herein above, DEFENDANTS entirely failed to respond as mandated by law. 11 140. The harassing conduct from DEFENDANTS was so severe,widespread or persistent that a 12 reasonable person in RAMIREZ's circumstances would have considered the work environment to be hostile 13 14 and abusive. RAMIREZ considered the work environment to be hostile or abusive. 15 141. DEFENDANTS whether or not named or designated as a Doe was/were a supervisor with 16 actual or reasonably perceived authority over RAMIREZ and engaged in the harassing conduct against 17 RAMIREZ. 18 19 142. RAMIREZ was harmed and DEFENDANTS' conduct was a substantial factor in causing 20 RAMIREZ's harm. 21 143. As a direct and legal result of the harassment RAMIREZ suffered due to her protected status 22 [i.e.,sex/gender,disability(physical or mental),association with a member of a protected class,family care 23 24 or medical leave and for engaging in protected activities (participating as a witness in a 25 discrimination/harassment complaint, reporting/resisting discrimination/retaliation, requesting/using a 26 disability related accommodation, requesting/using family care and medical leave], RAMIREZ suffered 27 harm and injury that was legally(proximately) caused by the conduct of DEFENDANTS. Said harm and 28 injury includes, but is not limited to, special (economic) damages, general (non-economic) damages, ao RAminzv. CITYoFSANTAANA CASENo. COMPLAINT I attorneys' fees [per Government Code §12965(b)], litigation costs, future damages and past damages, lost 2 economic earning capacity in future employment endeavors and such further relief as shown at the time of 3 4 Trial and in excess of the minimal jurisdictional of this Court. 5 FIFTH CAUSE OF ACTION 6 FAILURE TO TAKE CORRECTIVE ACTION 7 IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 8 9 (PLAINTIFF Against All DEFENDANTS) 10 144. RAMIREZ realleges Paragraphs 1 through 143 above and incorporates same as though fully 11 set forth herein. 12 145. DEFENDANTS are suffering/have suffered with a number of lawsuits and complaints 13 14 (including but not limited to the complaints from RAMIREZ) alleging discrimination, retaliation and 15 harassment and putting DEFENDANTS on notice and providing knowledge of the need to eliminate 16 discrimination, retaliation and harassment. 17 146. Under the law, as well as their own policies, DEFENDANTS had an obligation to take 18 19 corrective action to prevent further discrimination, retaliation and harassment of RAMIREZ but failed to 20 do so in violation of Section 12940,et. seq. of the California Government Code. DEFENDANTS failed to 21 conduct proper investigations, failed to turn over the results of these investigations, failed to implement 22 proper policies to prevent discrimination,retaliation and harassment and failed to properly punish those in 23 24 engaged in misconduct to deter further such future actions. 25 147. As a direct and legal result of the treatment RAMIREZ suffered due to her protected status, 26 RAMIREZ suffered harm and injury that was legally (proximately) caused by the conduct of 27 DEFENDANTS. Said harm and injury includes,but is not limited to, special(economic)damages,general 28 (non-economic)damages,attorneys'fees[per Government Code§12965(b)],litigation costs,future damages 21 RAminzv. CITYoFSANTAANA CASENo. COMPLAINT I and past damages, lost economic earning capacity in future employment endeavors and such further relief 2 as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. 3 4 5 WHEREFORE, RAMIREZ prays for Judgment against DEFENDANTS, and each of them, as 6 follows: 7 1. For compensatory damages, including loss of earnings, deferred compensation, bonuses, 8 9 vacation and other employment perquisites and other special and general damages according to proof, 10 2. Damages for pain and suffering and emotional distress; 11 3. Interest, including pre judgment interest, at the prevailing legal rate; 12 4. Attorneys' fees and costs incurred herein; and 13 14 5. Costs of suit; and 15 6. Such further and other relief as the Court deems just and proper. 16 17 REQUEST FOR TRIAL BY JURY 18 19 RAMIREZ hereby demands a Trial by Jury. 20 21 DATED: October 21, 2022 LAW OFFICE OF LAWRENCE J. LENNEMANN 22 23 24 By: Lawrence J. Lennemann LAWRENCE J. LENNEMANN 25 Attorneys for Plaintiff RITA RAMIREZ 26 27 28 az RAminzv. CITYoFSANTAANA CASENo. COMPLAINT Zuniga, Diana From: Jackie Angel Investor < Sent: Wednesday, April 01, 2026 3:12 PM To: eComment Cc: Durham, Daniel Subject: Re: CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION Valdez Complaint Attachments: Valdez_-_Complaint[)].pdf Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Judith Valdez vs. City of Santa Ana police officer retaliation employment claim "On August 8 2023, Valdez exhausted administrative remedies by causing City to be served with a government claim. City failed to respond to Valdez's government claim which was thereafter denied by operation of law. Additionally on July 28th 2023, Valdez filed a complaint with the California civil rights department and on August 8th 2023, Valdez caused both her complaint and the resulting right to sue notice to be served on City. Retaliation, discrimination, harassment City's Failure to take corrective action Police chief's gang like loyalty tests Physical threats made against employees to pick a side Sexual harassment, condescending behavior from superiors, suffered due to her protected status Covid 19 pandemic created bad blood Poor treatment of women employees in the department under Chief Valentin's leadership City continually unlawfully retaliate against Valdez Wrongfully disciplined and not promoted "Wherefore, Valdez prays for judgment against defendants, and each of them, as follows: For compensatory damages, including loss of earnings, deferred compensation, bonuses, vacation and other employment perquisites and other special and general damages according to proof; Damages for pain and suffering and emotional distress; Interest, including prejudgment interest, at the prevailing legal rate; Attorneys fees and costs incurred herein; and Cost of suit; and Such further and other relief as the court deems just and proper. REQUEST FOR TRIAL BY JURY Valdez hereby demands a trial by jury. Dated October 24, 2023 https://cityofsantaanaca.nextrequest.com/requests/26-719 Request 26-892 Received i April 01, 2026 via web Dear City Clerk, Thank you for the 6 documents requested regarding CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION I noticed two cases were missing file information. Again, I am requesting records public so that anyone can see. CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION cases Frank Rocha v. City of Santa Ana, WCAB Case No.: ADJ15955468; ADJ18623576; ADJ17697034 Stephen Hahm v. City of Santa Ana, WCAB Case No.: ADJ19377542; ADJ19377509; ADJ19885630 Thankyou From:Jackie Angel Investor<jcordova4@msn.com> Sent: Sunday, March 15, 2026 7:21 PM To: eComment<ecomment@santa-ana.org> Subject: CONFERENCE WITH LEGALCOUNSEL—EXISTING LITIGATION Hello, we would like details on these closed session cases and why so many Santa Ana police officers are suing us. https://citVofsantaanaca.nextreguest.com/requests/26-719 CONFERENCE WITH LEGAL COUNSEL— EXISTING LITIGATION Frank Rocha v. City of Santa Ana, WCAB Case No.: ADJ15955468; ADJ18623576; ADJ17697034 B. Stephen Hahm v. City of Santa Ana, WCAB Case No.: ADJ19377542; ADJ19377509; ADJ19885630 A. Anthony Cardenal v. City of Santa Ana, Orange County Superior Court Case No. 30-2022-01293127 B. John Kachirisky v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01348299 C. Nelson Menendez v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01339537 D. Manuel Moreno v. City of Santa Ana, Orange County Superior Court Case No. 30-2024-01372127 E. Rita Ramirez v. City of Santa Ana, Orange County Superior Court Case No. 30-2022-01287702 F. Judith Valdez v. City of Santa Ana, Orange County Superior Court Case No. 30-2023-01359457 From: Jackie Angel Investor <jcordova4@msn.com> Sent: Tuesday, October 8, 2024 11:30:39 AM To: scarvalho@santa-ana.org <scarvalho@santa-ana.org>; anunez@santa-ana.org <anunez@santa-ana.org> Cc: Ryberg, Erinn <Erinn.Ryberg@asm.ca.gov>; eComment <eComment@santa-ana.org> Subject: City of Santa Ana, Formal Complaint Filed - City Attorney Notice Sonia R. Carvalho, FIRED 4) As general counsel to the City 2 Today I was assured you would never be of service to me. After all these years, you offer me nothing, not even a return phone call. As our City Attorney, you can't be bothered. You are hereby put on notice. You are no longer my city attorney. Never did you represent me. {We The People} Never did you provide services for me<. Never did you counsel me or guide me in matters regarding the City of Santa Ana. This is the acknowledgement. -Santa Ana California Frank E. Rocha, a Police Services Dispatcher for the City of Santa Ana in 2024, had a total salary of $9,344.00, with regular pay of$8,639.09 . Total compensation including benefits and pension debt was $16,454.45. Stephen C. Hahm is a Police Officer for the City of Santa Ana, California, with a reported total pay of $337,526.05 in 2024, according to data from Transparent California. His compensation included a high regular salary along with additional pay and benefits typical of law enforcement officers. • 2024 Salary: $337,526.05 2021 Salary: $110,839.50 Anthony Cardenal earned $207,331 in 2017, according to public payroll data from Santa Ana. His job title was listed as a Police Officer. John Kachirisky, a Police Officer for the City of Santa Ana, had a total pay and benefits package of $347,114.56 in 2022 • 2022 (Pension Debt): $92,990.41 • Nelson A. Menendez worked as a Police Officer for the City of Santa Ana, earning a total pay of $196,996.30 which included a regular salary of$112,104.00. His total compensation, including benefits and pension debt coverage, was $361,812.66. • Salary Breakdown (2022): • Total Pay: $196,996.30 • Regular Pay: $112,104.00 • Benefits: $69,745.32 • Pension Debt: $95,071.04 • Manuel Moreno J. earned $432,264 in 2024, according to public payroll data from Santa Ana. His job title was listed as a Police Lieutenant (Rm). 3 • According to public records, Manuel Moreno J.'s salary increased by 38% ($118,565) from 2023 to 2024. • Manuel Moreno J.'s salary was 190% higher than the average and 220% higher than the median salary at Santa Ana in 2024. His salary was 164% higher than the average Police Lieutenant salary in 2024. Judith A. Valdez Police Officer (2020) Regular pay: $107,820.00 Overtime pay: $13,919.75 Other pay: $42,079.52 Total pay: $163,819.27 Benefits: $65,508.11 Pension debt: $68,406.54 Total pay & benefits: $297,733.92 4 Electronically Filed by Superior Court of California, County of Orange, 10/24/2023 03:26:29 Phil. 30-2023-01359457-CU-OE-NJC - ROA#4 - DAVID H. YAMASAKi, Clerk of the Court By R. Gardea, Deputy Clerk. SUMA00 SUMMONS FOR COURT USE Of4LV (SOLO PARA USO DE LA CORTE) (CiTACION JUDICIAL) NOTICE TO DEFENDANT: (AWSO AL DEMANDADO): CITY OF SANTA ANA, an entity of unknown origin; and DOES I - 50, 1zYCLERK Inclusive, �N,40i i "1 5-2 y PMQ: L YOU ARE BEING SUED BY PLAINTIFF: (LO EST,4 DEMANDANDO EL DEMANDANTE): JUDITH VALDEZ, an Individual NOTICEI You have been sued.The court may decide against you without your being heard unless you respond within 30 days.Read the information below. You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff.A letter or phone call will not protect you.Your written response must be in proper legal form if you want the court to hear your case.There may be a court form that you can use for your response.You can find these court forms and more information at the California Courts Online Self-Help Center(www.courtinfo.ca.gov/selfhelp),your county law library,or the courthouse nearest you.If you cannot pay the filing fee,ask the court clerk for a fee waiver farm.If you do not file your response on time,you may lose the case by default,and your wages,money,and property may be taken without further warning from the court. There are other legal requirements.You may want to call an attorney right away.If you do not know an attorney,you may want to call an attorney referral service.If you cannot afford an attorney,you may be eligible for free legal services from a nonprofit legal services program.You can locate these nonprofit groups at the California Legal Services Web site(www.lawhelpcalifornia.org),the California Courts Online Self Help Center (www.courtinfo.ca.govlselthelp),or by contacting your local court or county bar association.NOTE:The court has a statutory lien for waived fees and costs on any settlement or arbitration award of$10,000 or more in a civil case.The court's lien must be paid before the court will dismiss the case. iAVISOf Lo han demandado. Si no responde dentro de 30 dies,la torte puede decidir an su contra sin escuchar su version.Lea la information a continuaci6n. Trene 30 DlAS DE CALENDARIO desputs de que le entreguen esta citacidn y papeles legales pars presenter Una respuesta par escrito en esta corte y hater que se entregue Una copia at demandante.Una Carta o una flamada telefonica no to protegen.Su respuesta par escrito tieee que estar en formato legal correcto si desea que procesen su caso en la torte.Es posible que hays un formulario que usted pueda user pare su respuesta. Puede encontrar estos formuiarios de la torte y mas informaci©n en el Centro de Ayuda de les Cortes de California Mww.sucorte.ca,gov),en la biblioteca de!eyes de su condado o en la torte que le quede mas cerca.Si no puede pagar la cuota de presentacift Aida at secretario de la carte que le de un formularia de exencibn de pago de cuotas.Si no presenta su respuesta a dempo,puede perder el caso par incumplimiento y la Corte le pods quitar su sueldo,diners y bienes sin mas advertencia. Nay otros requisites legales.Es recomendable que flame a un abogado inmediatamente.Si no conoce a un abogado,puede flamer a un servicio de remisi6n a abogadas.Si no puede pager a un abogado, es posible que cumpla con los requisitos pare obtener servicios legales gratuitos de un programa de serWcios legales sin fines de lucro.Puede encontrar estos gropps sin tines de lucro en el sitio web de California Legal Services, 6v%vw.lawhelpcalifornia.or9),en el Centro de Ayuda de las Cores de Califomia,Mm.sucorte.ca.gov)o poniendose en contacto con le Corte o el colegio de abogados locates.A ViSO:Per ley,la carte tiene derecho a reclamar las cuotas y los castes exentos porimponer un gravamen sabre cuaiquierrecuperacion de$10,000 o mas de valor recibida mediante un acuerdo o una concesidn de arbitraje en un caso de derecho civil. Tiene que pagar el gravamen de 1a carte antes de que la torte pueda desechar at caso. The name and address of the court's: North JustiCP CenCcr CASENUMBER' (NzIrnerouefcaso)_ 00-4+)2-=0139=94E7-CU-OE-NIC (El nombre y direccion de la carte es): 1275 North Berkeley Avenue Fullerton, CA 92932 r3al n �!for All P4rf airs I471X�C I< P Judge Craig Griffin -le name.address. and telephone number of plaintiffs attorney, or plaintiff without an attorney, is: (!=l nombre, la direccion yy el n6mero de telf#ono del abogado del demandante o del demandante que no fiene abogado, es).: John A. Girardi,(SEIN.54917)John A.Girardi,APC (310)265-�787 Lawrence J.Lennemann fSBN:134108)Law Office of Lawrence J.Lennemann(310)265-5788 29900 Hawthome Blvd.Rolline Hills Estates CA 90274 DATE: 4- jI DA,:ID H.;'AMA:=AXI, clolrl.of the C�,Urt Clerk,by fjJ�i�"iJ73 Q l U P � ' 0ardea . Deputy (Secretario) (Adjunto) (For proof of service of this summons, use Proof of Service of Summons (form P05-010).) (Para prueba de entrega de esta citation use el formulario Proof of Service of Summons, (POS-010)). NOTICE TO THE PERSON SERVED:You are served [SEAL] 1. as an individual defendant. 2. Q as the person sued under the fictitious name of(specify): 3. on behalf of(specify):�/17'y 0G4� Iv�7f� 171JP i under: CCP 416.10(corporation) CCP 416.60(minor) `in it n letflL# Q CCP 416.20(defunct corporation) CCP 416.70(eonsenfatee) CCP 416.40(association or partnership) CCP 416.90(authorized person) other(specify)- 4.154 by personal delivery on (date):�Joyglxlff�'z 1i 2-4,2--3 Page,of 9 Form Adapted for Mandatory use SUMMONS Code of Civil Procedure§§412 20,455 Judicial Council ofcaliforniaCffi wwwcourBnro.ca.gov SUM-100[Rev,July 1,20091 www.ceil.com SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE FOR COURT USE ONLY STREET ADDRESS: 1275 N.Berkeley Ave F 1 L E D MAILING ADDRESS: 1275 N.Berkeley Ave SUPERIOR COURF OF CALIFORAYA CITY AND ZIP CODE:Fullerton 92838 GOUN1Y OF ORANGE BRANCH NAME: North Justice Center PLANTIFF:Judith Valdez Nov 6, 2023 DEFENDANT:City of Santa Ana Clerk of the Coun Short Title:VALDEZ VS.CITY OF SANTA ANA By:R.Gardan,Deputy CASE NUMBER: NOTICE OF HEARING 30-2023-01359457-CU-OE-NJC CASE MANAGEMENT CONFERENCE Please take notice that a(n), Case Management Conference has been scheduled for hearing on 04/05/2024 at 09:30:00 AM in Department N17 of this court, located at North Justice Center. Plaintiff(s)IPetitioner(s) to provide notice to all defendants)/respondent(s). Parties who file pleadings that add new parties to the proceeding must provide notice of the Case Management Conference to the newly added parties. QIEPQRXA�M- Friar to your hearing date.:.please cluck the Court's website for the most current instructions regarding how to appear for your hearing and access services that are available to ansiver}our questions. civil matters-https kyw%voccourts.org media-relations.ci%-il_html Probate.Xlental Health- https: vi'%rx _occourts.org media-relations Probate-mental-health_html Appellate Division- https.. Avivw.occourts_org,media-relations appeals-records.html [P!tl I&N- E.motes de la fecha de su audiencia, v1site el sitio web de la Corte para sabor codes son las instrucciones Innis actuales Para partieipar era la audiencia y tenet acceso a los seivicios dispolriibles para responder a sus preyguuntas. Casos Civiles-https: xA-►%rx .occourts.org media-relations civil-html Ca%o+ de probate y Salud l-lental - Lnps: .tiy-iiy_occourts_org media-relations prolate-mental-health.html Division de apelaciones- hops: Nvwx`-.occourts.org media-relations.appeals-records.html Q `. N I-RO T'rudc naky 0u6n t6a cfka qu;-v , vul 16n+a kip tra trang mpg c4a t6a&a do b4t nhtl!ng hirdne din zndl nh t vei cich ra hAu phiin t6a efia qua vj v t4p cSnln nhOng d'ch vq hi4a cd M RIM dip nhftg Chic mac c4a qu'vi Vain W Din Su-https: t-%-a�-x-.occourts_org media-relations.cn-il.htinl Than Tuc Ali Chik.Urc Khde Tinh Thin-httpz:. 1;-%yNv.occourts.org,media-relations probate-mental-health_html Ban ph4c thAtxa- https: avwmoccourts_org,media-relations appeals-records-html Clerk of the Court, By: Deputy NOTICE OF HEARING Page:1 SUPERIOR COURT OF CALIFORNIA, COUNTY OFORANGE North Justice Center 1276 N. Berkeley Ave Fullerton 92838 SHORT TITLE: VALDEZ VS, CITY OF SANTA ANA CASE NUMBER: CLERK'S CERTIFICATE OF SERVICE BY MAIL 30-2823-01369467-CU-OE-NJC I certify that I am not a party to this cause. I certify that a true copy of the above Notice of Hearing has been placed for collection and mailing so as to cause it to be mailed in a sealed envelope with postage fully prepaid pursuant to standard court practices and addressed as Indicated below. The certification occurred at F llu erton , California, on 11106/2023. Following standard court practice the mailing will occur at Sacramento, California on 1110712023. Clerk of the Court, by: � � C%LhAm--'-,yDeputy LAW OFFICE OF LAWRENCE J, LENNEMANN,APC JOHN A. GIRARDl, APC 29900 HAWTHORNE BOULEVARD 29900 HAWTHORNE BOULEVARD ROLLING HILLS ESTATES, CA 90274 ROLLING HILLS ESTATES, CA 90274 i CLERK'S CERTIFICATE OF SERVICE BY MAIL Page:z V31013a(June 2004) Code of Civil Promdure,§CCPio13(a) i I Electronically Filed by Superior Court of California, County of Orange, 10/24/2023 03:26:29 PM. 30-2023-01359457-C1l-OE-N.IC- ROA#3 - DAVID H. YAMASAKI, Clerk of the Court By R. Gardea, Deputy Clerk. CM-010 ATTORNEY OR PARTY WITHOUT ATTORNEY(Name,State Bernumber,and addmsa): FOR COURT USE ONLY J014N A.GIRARD1 (SBN 54917))OHN A,GTRAR.DL APC LAWRENCE J LENNEMANN(SBN 134108)LAW OFFICE OF LAWRENCE J LENNEMANN 29900 HAWTHORNE BOULFVARD ROLLING HILLS ESTATES,CA 90274 TELEPHONE No,. (310)265-5788 FAX NO.(Opfiona!): E-MAILADDRESS lennemannle@gmaiLmm ATTORNEY FOR(Namaj PLAINTIFF SUPERIOR COURT OF CALIFORNIA,COUNTY OF ORANGE STREETADOREW North Justice Center MAILING ADDRESS: 1275 North Berkeley Avenue GTY AND?JP CODE: Fullerton,CA 92832 BRANCH NAME: CASE NAME; JUDITH VAI.DE7.an Individual CITY OF SANTA ANA,an cntity of unknown origin;and DOES I -50,Inclusive CIVIL CASE COVER SHEET Complex Case Designation CASE NUMBER: 30=2023-0 1n94S7_CLI.OE-NJC Ca Unlimited ®Limited ®Counter [Joinder (Amount (Amount demanded demanded is Filed with first appearance b defendant �uoaE: pp Y Judge Craig Griffin exceeds$25,000) $25 000 or less) (Cal. Rules of Court rule 3.402 DEPT.. Items 1-6 below must be con lets see Instructions on page . 1. Check one box below for the case type that beat describes this case, Auto Tort Contract Provisionally Complex Civil Litigation BAuto(22) (Breach of contracUwarrenty(06) (Cal.Rules of Court,rules 3.400-3,403) uninsured motorist(46) Rule 3.740 collections(09) Antitrust/Trade regulation(03) Lather PIIPQlWD(Personal in)urylProperty Other collections(09) Construction defect(10) Damage/Wrongful Death)Tort Insurance coverage(18) Mass tort(40) Asbestos(04) Other contract(37) Securities litigation(28) Product liability(24) Real Property Environmentalrroxlc tort(30) Medical malpractice(45) LZI Eminent domainllnverse Insurance coverage claims arising from the Other PVPDAND(23) condemnation(14) above listed proVsioneily complex case Wrongful eviction(33) types(41) PI/Business tortlunfalr business practice(07) Nan• PQlWD(other)Tort E]Othsr real property(26) Enforcement of Judgment Business Civil rights(08) Unlawful Detalner ZI Enforcement of Judgment(20) Defamation(13) Commercial(31) Miscellaneous Civil Complaint Fraud(16) Residential(32) RICO(27) Intellectual property(19) d Drugs(38) E30ther complaint(not specified above) (42) Professional negligence(25) Judicial Review Miscellaneous Civil Petition Other non-PIIPDAND tort(35) Asset forfeiture(05) Partnership and corporate governance(21) Em loyment Petition re:arbitration award(11) E30ther petition(Trot specified above) (43) Wrongful termination(3e) Writ of mandate(02) Other employment(IS) Other Judicial review(39) 2, This case ® Is ®Is not complex under rule 3,400 of the California Rules of Court. If the case Is complex,mark the factors requiring exceptional Judicial management: a. Large number of separately represented parties d. E3 Large number of witnesses b. �Extensive motion practice raising difficult or novel e. Coordination with related actions pending in one or more Issues that will be time-consuming to resolve courts in other counties, states,or countries,or in a federal c, [J Substantial amount of documentary evidence court f, ©Substantial postjudgment judicial supervision 3, Remedies sought(check all that apply); a. Urnonetary b, nonmonetary;declaratory or Injunctive relief c. 0 punitive 4. Number of causes of action (specify),, (5)FIVE; 1)RETALIATION IN VIOLATION OF LABOR CODE§1102,5.,2)FEHA,3)Discrimination 5, This case [I Is M]Is not a class action suit, 6. If there are any known related cases, file and serve a notice of related case. (You may use form CM-01 5.) Date; October 24,2023 LAWRENCE J.LENNEMANN r--�-� (TYPE OR PRINT NAME) (SIGNAT OR�ATTORN PARTY) NOTICE e Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed under the Probate Cade,Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3 220.)Failure to file may result In sanctions. a File this cover sheet in addition to any cover sheet required by local court rule. a If this case is complex under rule 3.400 et seq, of the California Rules of Court,you must serve a copy of this cover sheet on all other parties to the action or proceeding. e Unless this is a collections case under rule 3,740 or a complex case, this cover sheet will be used for statistical purposes only. Frxrri Ada tad for Matigltory uba Cal.Rul@�®®! o rr��Iaa 30 3.p 0 3.49D- 403,3 74pp; dIc ounGItal aiorfll Il■CEB1agemW CIVIL CASE COVER SHEET Cal. [a`n9ortlael2,iutlleleT dmfnletrafliCn atd, 10 C1r 01j�l ey 5slpEambar 1.�02t1 wwwsoun th v ceb.Com 'MF.�C 90 CM-010 INSTRUCTIONS ON MOW TO COMPLETE THE COVER SHEET To Plaintiffs and Others Filing First Papers. If you are filing a first paper(for example,a complaint)in a civil case,you trust complete and file,.along with your first paper,the Civil Case Cover Sheet contained on page 1.This information will be used to compile statistics about the types and numbers of cases filed.You must complete items 1 through 6 on the sheet.In item 1,you must check one box for the case type that best describes the case.If the case fits both a general and a more specific type of case listed in item 1, check the more specific one.If the case has multiple causes of action,check the box that best indicates the primary cause of action. To assist you in completing the sheet,examples of the cases that belong under each case type in item 1 are provided below.A cover sheet must be filed only with your initial paper.Failure to file a cover sheetwith the first paper filed in a civil case may subject a party, Its counsel,or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court. To Parties in Rule 3.740 Collections Cases, A"collections case"under rule 3.740 is defined as an action for recovery of money owed in a sum stated to be certain that is not more than$25,000,exclusive of interest and attorney's fees,arising from a transaction in which property,services,or money was acquired an credit.A collections case does not include an action seeking the following:(1 tort damages,(2�punitive damages,(3)recovery of real property, (4)recovery of personal property,or(5 a prejudgment writ a attachment.The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general time-for-service requirements and case management rules,unless a defendant files a responsive pleading.A rule 3.740 collections case will be subject to the requirements for service and obtaining a judgment in rule 3.740. To Parties in Complex Cases, In complex cases only,parties must also use the Civil Case Cover Sheet to designate whether the case is complex.If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court,this must be indicated by completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex,the cover sheet must be served with the complaint on all parties to the action.A defendant may file and serve no later than the time of its first appearance a joinder in the plaintiff's designation,a counter-designation that the case is not complex,or,if the plaintiff has made no designation, a designation that the case is complex. CASE TYPES AND EXAMPLES Auto Tort Contract Auto(22)-Personal Injury/Property Breach of ContractfWarranly(06) Provisionally Complex Civil Litigation(Cal. DamageMkongful Death Breach of RentallLease Rules of Court Rules 3.400-3.403) Uninsured Motorist(46) (ifthe Contract (not unlawful detainer Antitrust/Trade Regulation(03) case involves an uninsured or wrongful eviction) Construction Defect(10) motorlstclaim subject to ContractlWarranty Breach-Seller Claims Involving Mass Tort(40) Plaintiff (not fraud or negligence) Securities Litigation(28) Instha of uto) his item Negligent Breach of Contract/ EnvironmentallToxic Tort(30) instead ofAuta) Wain Insurance Coverage Claims Other PIIPDfWD(Personal lnjuryl Other BreachWarranty fContractiWarranty (a)ising from provisfonallycomplex Tort Property DamageWrongful Death) Collections(e.g.,money owed,open case type listed above) (41) book accounts)(09) Enforcement of Judgment Asbestos(04) Collection Case-Selfer Plaintiff Enforcement of Judgment(20) Asbestos Property Damage Other Promissory Note/Collections Abstract of Judgment(Out of Asbestos Personal Injury/ Case County) Wrongful Death Insurance Coverage(not provisionally Confession of Judgment (non- Product Liability(not asbestos or complex)(1 B) domestic relations) toxlcJenWorimental) (24) Auto Subrogatlon Sister State Judgment Medical Malpractice(45) Other Coverage Administrative Agency Award Medical Malpractice- Other Contract(37) (not unpaid taxes) Physicians&Surgeons Contractual Fraud PetitionlCertiflcatlon of Entry of Other Professional Health Care Other Contract Dispute Judgment on Unpaid Taxes Malpractice Real Property Other Enforcement of Judgment Other PI/PD/WD(23) Eminent Domain/Inverse Case Premises liability(e.g.,slip Condemnation(14) Miscellaneous Civil Complaint and falo Wrongful Eviction(33) RICO(27) Intentional Bodily Injury/PDIWD Other Real Property(e.g.,quiet title)(26) Other Complaint(not specified (e.g.,assault,vandalism) Writ of Possession of Real Property above) (42) Intentional Infliction of Mortgage Foreclosure Declaratory Relief Only Emotional Distress Quiet Title Injunctive Relief Only(non- Negligent Infliction of Other Real Property (not eminent harassment) Emotional Distress domain,landlordAenant,or Mechanics Lien Other Pi1PDIWD foreclosure Other Commercial Complaint Non-PIIPDIWD(Other)Tort Unlawful Detainer) Case (non-torfMon-complex) Business Torl/Unfair Business Commercial(31) Other Civil Complaint Practice(07) (non4ort/non-complex) Rights( g.,discrimination,Civil Ri Drugs Residential(32) Drugs(36) (if the case involves illegal Miscellaneous Civil Petition false arrest)(not civil drugs,check this item;otherwise, Partnership and Corporate harassment) (08) report as Commercial orRes/dendal) Governance(21) Defamation(e.g.,slander,fibel) Other Petition(not specffed Judicial Review (13) above)(43) Fraud(16) Asset Forfelture(05) Civil Harassment Intellectual Property(19) Petition Re:Arbitration Award(11) Workplace Violence Professional Negligence(25) Writ of Mandate(02) Elder/Dependent Adult Legal Malpractice Wr€-Administrative Mandamus Abuse Other Professional Malpractice Wrii-Mandamus on Limited Court Election Contest Case Matter (not medical orlegal) Writ-Other Limited Court Case Petition for Name Change Other Non-PUPDf WD Tort(35) Review Petition for Relief from Late Claim Employment Other Judicial Review(39) Other Civil Petition Wrongful Termination(36) Review of Health Officer Order Other Employment(15) Notice of Appeal-Labor Commissioner Appeals CM:D1 [Rev. epi er 1,z OCE Er,seMki CIVIL CASE COVER SHEET naQe2orz ceb.com WEMA Electronically Filed by Superior Court of California, County of Orange, 10/2412023 03:26:29 PM. 30-2 23-01359457-CU-OE-NJC- ROA#2- DAVID H. YAMASAKI, Clerk of the Court By R. Gardea, Deputy Clerk. 1 JOHN A. GIRARDI, State Bar No. 54917 JOHN A. GIRARDI, APC 2 29900 Hawthorne Boulevard Rolling Hills Estates, CA 90274 3 (310) 265-5787 Telephone j ohn(a-),j ohngirardi law.com 4 LAWRENCE J. LENNEMANN, State Bar No. 134108 5 LAW OFFICE OF LAWRENCE J. LENNEMANN, APC 29900 Hawthorne Boulevard 6 Rolling Hills Estates, CA 90274 (310) 265-5788 Telephone 7 1ermemann1e@g_rnail.com 8 Attorneys for Plaintiff JMITH VALDEZ 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA I I COUNTY OF ORANGE Assigned for All Purposes 12 Judge Craig Griffin JUDITH VALDEZ, an Individual ) CASE NO.: 30-2023-01359457-Gt1-4E-NJC 13 ) PLAINTIFF JUDITH VALDEZ'S COMPLAINT 14 ) FOR: Plaintiff, )15 (1)RETALIATION IN VIOLATION OF LABOR ) CODE §1102.5; 16 vs. } (2) RETALIATION IN VIOLATION OF THE ) FAIR EMPLOYMENT AND HOUSING ACT; 17 } (3) DISCRIMINATION IN VIOLATION OF 18 ) THE FAIR EMPLOYMENT AND HOUSING CITY OF SANTA ANA, an entity of unknown } ACT; 19 origin; and DOES I - 50, Inclusive, ) (4) HARASSMENT IN VIOLATION OF THE 20 } FAIR EMPLOYMENT AND HOUSING ACT; AND 21 } (5) FAILURE TO TAKE CORRECTIVE 22 Defendants. } ACTION IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 23 24 REQUEST FOR JURY TRIAL 25 Plaintiff Judith Valdez ("VALDEZ" or "Plaintiff'), with knowledge as to her own acts and based 26 27 upon information and belief with regard to all other matters,by and through her attorneys of record,alleges: 28 111 111 VALDEZ V, CiTY OF SANTA ANA CASE No. COMPLAINT 1 1. VALDEZ is an individual who,at all times relevant herein,was employed by Defendant City 2 of Santa Ana("CITY"or"DEFENDANT") as a Police Officer at CITY's business office(s)located in the 3 4 County of Orange, State of California. 5 2. VALDEZ alleges that CITY is a municipality doing business in the County of Orange, State 6 of California. The Santa Ana City Council,as the governing body of the City of Santa Ana,acts,represents, 7 and implements policy on the behalf of CITY. 8 9 3. Defendants CITY and DOE Defendants 1 through 50 are hereinafter sometimes collectively 10 referred to as "DEFENDANTS". 11 4. On August 8,2023,VALDEZ exhausted her administrative remedies by causing CITY to be 12 served with a Government Claim. CITY failed to respond to VALDEZ's Government Claim which was 13 14 thereafter denied by operation of law. Additionally on or about July 28,2023,VALDEZ filed a Complaint 15 with the California Civil Rights Department and,on August 8,2023,VALDEZ caused both her Complaint 16 and the resulting Right-to-Sue Notice to be served on CITY. 17 5. VALDEZ is presently not aware of the true names and/or capacities of Defendants DOES 18 19 1 through 50,inclusive, and therefore sues said Defendants by such fictitious names.VALDEZ is informed 20 and believes and upon such information and belief alleges that said fictitiously named Defendants are 21 directly and proximately responsible for the injuries and damages alleged herein.VALDEZ will amend this 22 Complaint to allege the true names and capacities of said fictitiously named Defendants when, and if, 23 24 ascertained. 25 111 26 111 27 111 28 111 2 VALDHZ v.Cm OF,SANTA ANA CASSNO, COMPLAINT 1 6. VALDEZ is informed and believes,and upon such information and belief alleges,that,at all 2 relevant times,each and every Defendant was a principle,agent,employer,employee,manager,supervisor, 3 4 officer,shareholder and/or owner of each and every other Defendant,and each and every act and/or omission 5 of each and every Defendant occurred by and through the governing body and/or management of the 6 Defendant and within the course and scope of such agency anal/or employment and/or was approved and/or 7 ratified by the acts and/or omissions of each and every other Defendant. 8 9 FACTUAL BACKGROUND 10 A. In November 2009, VALDEZ Began Her Career with CITY and, Thereafter, 11 Repeatedly Received Outstanding Performance Evaluations,was Promoted and 12 Received No Non-Retaliatory Discipline. 13 14 7. On November 9, 2009,VALDEZ began her career with the City as a Police Officer. 15 8. During VALDEZ's almost 14 years of service in law enforcement,VALDEZ has been a loyal 16 and hard-working employee who received consistent"Outstanding"performance evaluations. 17 9. In or about February of2018,VALDEZ was promoted to Detective. 18 19 10. In or about February of 2019, VALDEZ was promoted to Corporal. 20 11. Other than the retaliatory discipline at issue herein, VALDEZ has never been disciplined. 21 12. Despite this, as set forth herein in detail,VALDEZ suffered retaliation,discrimination and 22 harassment due to circumstances entirely unrelated to her performance and was unlawfully disciplined and 23 24 not promoted. CITY's discrimination,harassment and retaliation against VALDEZ violates California law, 25 CITY's own Municipal Code and policies and procedures and VALDEZ's civil service rights. 26 111 27 1I1 28 111 3 VALOIIZ V, CITY OF SANTA ANA CASENG. COWLAINT 1 B. Soon-to-be-Former Chief Valentin and CITY's "Gangs/Camps". 2 13. As CITY is well aware from numerous complaints and from other publicly-filed lawsuits(i.e., 3 4 Rita Ramirez v. City of Santa Ana;Anthony Cardenal v. City of Santa Ana, Nelson Menendez v. City of 5 Santa Ana, Manuel Moreno v. City of Santa Ana), although an effective police department functions as a 6 whole, it has been a common recent practice (and the subject of much ongoing discussion and concern 7 between CITY's police department personnel) for Chief Valentin(and others at his behest) to attempt to 8 9 force personnel to choose between two"gangs"or"camps"-what is referred to as"the Valentin camp"or 10 what Chief Valentin perceives to be the other "gang"/"camp" allegedly led by then-Police Association 11 ("POA")President Gerry Serrano. 12 14. VALDEZ is perceived by Chief Valentin(and those acting on his behalf)as not being part 13 14 of"the Valentin camp"and is, thus,perceived as being part of what is referred to as "the POA camp". 15 15. Chief Valentin has been repeatedly accused of not simply allowing but fostering these 16 "camps"within CITY's Police Department, 17 16. Additionally, Chief Valentin has been repeatedly accused of actively 18 19 retaliating/discriminating against or harassing those who did not choose to be in his "camp" and of 20 retaliating/discriminating against or harassing those who chose to even associate with those perceived to be 21 in the other"camp". 22 17. It is also common knowledge that those perceived to be in the"Valentin camp"-even those 23 24 who repeatedly and significantly violate laws, statutes, regulations and policies - are not 25 charged/investigated/disciplined for such conduct while those not perceived to be in the"Valentin camp" 26 (especially those who stand up against the "Valentin camp"'s wrongful acts) are routinely 27 charged/investigated/disciplined for far less egregious purported"misconduct." 28 111 4 VALDRZV.CITYpBSANTAANA CAS6NIo. COMPLAINT 1 18. Despite the numerous complaints of this unlawful conduct over the years,CITY has allowed 2 this conduct to continue. 3 4 19. Despite the above-alleged conduct of Chief Valentin(and the myriad of claims and lawsuits 5 arising out of his conduct), VALDEZ is informed and believes that Chief Valentin has communicated to G CITY that he will also be suing CITY for perceived retaliation,harassment and hostile work environment. 7 C. The Major Enforcement Team ("MET"), the Culichi Town Incident and 8 9 Disparate Discipline. 10 20. MET is a SWAT-like team"created" in January of 2020 by Chief Valentin. 11 21. persons associated with MET are considered to be part of"the Valentin camp"and receive 12 extreme and obvious favoritism from Chief Valentin,regarding both promotions and lack of discipline. 13 14 22. For sake of example, a very public and disturbing incident involving the alleged August 9, 15 2000 sexual assault by off-duty CITY police officerls at the Culichi town restaurant - and the resulting 16 cover-up by Chief Valentin and those acting at his direction- was recently addressed in a May 24, 2023 17 complaint made by Commander Manuel Moreno,an unredacted copy of which was released by CITY and 18 19 included as an attached link in investigative journalist Ben Camacho's June 2 t,2023 article entitled"Santa 20 Ana Police Department Delays Investigation of a Child Sexual Assault by an Off-Duty Officer by More than 21 Half a Year, Commander Alleges." 22 23. In fact,when the wife of one of the officers involved in the Culichi Town incident discussed 23 24 her husband's concern regarding the incident, VALDEZ immediately disclosed same to Commander 25 Moreno. 26 24. VALDEZ is informed and believes that not only were the officers involved in the Culichi 27 28 Town Incident not disciplined but they have received multiple promotions. 111 s VALDU V.OTY OF SANTA ANA CASHNO. COMPLAW 1 25. There are various additional examples including officers (considered part of"the Valentin 2 camp")who have committed significantly more serious violations than VALDEZ(see below)but who have 3 4 received significantly less discipline(i.e.,now-Commander Oscar Lizardi-instead of being disciplined for 5 being involved in the Culichi Town Incident as well as other serious misconduct complaints-was rewarded 6 with an unprecedented meteoric rise from Sergeant to Commander; officers who were arrested for Driving 7 Under the Influence received shorter suspensions than VALDEZ and were even allowed to utilize their 8 9 vacation time instead of serving their suspensions without pay, etc.). 10 D. September of 2020, 11 26, In September of 2020,during the COVID-19 Pandemic,an on-line Women Leaders in Law 12 Enforcement conference tools place. 13 14 27. Since the conference was virtual, Sergeant Rosa Ponce De Leon requested and received 15 permission from Training Sergeant Garry Couso to host a group of women(including VALDEZ)at Sergeant 16 Ponce de Leon's residence so that the women could watch the Conference together. 17 28. However,later that day,Commander Matthew Sorenson contacted Sergeant Ponce De Leon 18 19 and ordered her and all the other women involved to report to the station the next day. 20 29. The women reported to the station and were advised to go into one of the classrooms. 21 30. As there was no computer set up for the video conference(and none of the computers in the 22 23 room worked), at one point all of the females were sitting in front of a small laptop watching the video 24 conference. 25 31. Commander Sorenson made it a point to give the females in the room a verbal"counsel"and 26 tell them how the week would go. 27 32. After a couple of hours,they were ordered to wait in the Chiefs conference room since none 28 of the classroom's audio/visual equipment were functioning. 6 V ALDFV V.CITY OF SANTA ANA CASE No. COMPLAINT 1 33. Deputy Chief Enrique Esparza entered the room and reprimanded the women who had done 2 nothing improper. 3 4 34. The women were then ordered to participate in the remaining portion of the conference from 5 the police station. 6 35. Needless to say,this conduct-coupled with CITY's sexist reference to the event at Sergeant 7 Ponce de Leon's residence as a"pajama part'- created a lot of bad feelings. 8 9 36. At some point in time,the women asked now-former CITY Police Administrative Manager 10 Rita Ramirez (who has filed her own Superior Court Complaint for retaliation, discrimination and 11 harassment against CITY) to attend the remainder of the conference with them at the station. 12 37, After the conference was over,the women began to discuss how poorly both sworn and non- 13 14 sworn women in the police department were being treated.under Chief Valentin's leadership. 15 38. VALDEZ is informed and believes that,as soon as Chief Valentin learned of this discussion, 16 he ordered Ms. Ramirez to write a"memo" regarding the discussions - not so that he could address the 17 important issues -but so that he could learn who said what to whom and retaliate against them. 18 19 39. On September 11,2020,Ms.Ramirez did as ordered and submitted her 3-page memo which 20 described the "topics of discussion" as; 21 "The language used towards females versus males such as tone, demeanor, verbiage and 22 condescending behavior"; 23 "Double standards in regards to the way women are treated in general"; 24 "Retaliation for speaking up. If a woman complains then they are being `emotional"'; and 25 26 "If a woman makes a`mistake'then the mistake is magnified or highlighted throughout their career and used against them." 27 11l 28 111 VAL uzv.Wy OH SANTA ANA CASHNo. COMP[.AW 1 40. This memo also detailed how the women discussed that"this type of behavior is the`culture' 2 of the department and appears to be condoned by leadership";"how [Chief Valentin] is perceived to be 3 4 supportive of this type of behavior"; and that this behavior"starts at the top." 5 41. As referenced above,VALDEZ is informed and believes that the"memo"Ms.Ramirez was 6 ordered to write was actually expected to "rat out"to Chief Valentin which woman dared to question his 7 actions. 8 9 42. Since Ms. Ramirez wrote her memo in the opposite manner(i.e.,to protect the women who 10 had legitimate claims regarding their treatment under Chief Valentin),Ms.Ramirez's memo-which spoke 11 to the tone and message that the women were trying to communicate - did not go over well with Chief 12 Valentin and, as detailed in Ms. Ramirez's Complaint, led to significant retaliation against Ms. Ramirez. 13 14 43. VALDEZ is informed and believes that Chief Valentin was upset that the memo failed to 15 provide him with identifying information so that he could use it to retaliate against the individual women. 16 44. Later that day,Chief Valentin walked into the conference room with Assistant Chief Robert 17 Rodriguez and Human Resources Analyst Lourdes Ferrer, introduced them to the group and advised that, 18 19 if the women wished to file a complaint,they were to go through the"proper channels"and report it to one 20 of these other two persons. 21 45. Chief Valentin then turned around and left. 22 46. At that point in time, no one in the room wanted to file a complaint. 23 24 47. Rather,they simply wished to speak to Chief Valentin about how things could be handled 25 differently and improved. 26 48. However, Chief Valentin refused to speak with the women and had left the room. 27 28 49. In doing so, Chief Valentin made it abundantly clear that he had no interest in addressing these very real and important issues. s VALDP.Zv, MY OPSANTAANA CASENO. COMPLAINT 1 50. Chief Valentin's lack of leadership at this pivotal moment was a serious blow to CITY's 2 Police Department. 3 4 E. October of 2020. 5 51. In October of 2020, VALDEZ applied to promote to Sergeant. 6 52. The process consisted of a written exam,a practical application interview,a resume interview 7 and an external interview. 8 9 53. Both Deputy Chief Enriguez and Commander Sorenson were on the interview panel. 10 54. VALDEZ was advised that she had"failed"both the practical application interview and the 11 resume portion. 12 55. However,for various reasons,VALDEZ is informed and believes that she performed as well 13 14 as (or better than)those individuals who passed. 15 56. VALDEZ is also informed and believes that she"failed"because both Deputy Chief Enriguez 16 and Commander Sorenson were upset about VALDEZ's activities discussed above. 17 57. Indeed,the only two females that"failed"were VALDEZ and Elizabeth Granados-two of 18 19 the women who were involved in the Women Leaders in Law Enforcement conference incident. 20 F. February of 2021. 21 58. In February of 2021,VALDEZ was interviewed regarding the incident at the Women Leaders 22 in Law Enforcement conference - not by an outside investigator but, rather,by Ms. Ferrer who had been 23 24 directly involved in the incident which she was purportedly"investigating." 25 59. During VALDEZ's brief approximately 15-minutes interview,VALDEZ stated,inter alia, 26 that;(1)all involved felt Chief Valentin could have acted in a significantly more productive and professional 27 28 manner; and(2) Chief Valentin simply telling the women to "go through the proper channels" and"file a complaint" communicated his clear disinterest in this important issue. 9 VALDEZv.CITY OFSANTAANA CmRNo. COMPLAINT 1 60. Additionally,since Chief Valentin had ordered Ms.Ferrer to conduct the interview,VALDEZ 2 is informed and believes that Ms. Ferrer provided Chief Valentin with the sum and substance of her(and 3 4 the other women's)interviews because,since that time,Chief Valentin(and those acting on his behalf)have 5 continued to retaliate against her/them. 6 G. May 2021.. 7 61. VALDEZ applied to for the Corporal position in the Police Department's Backgrounds unit, 8 9 headed by Commander Sorenson. 10 62. Although VALDEZ had already been a Corporal for two years and had cross trained and had 11 a clear understanding of the position,it was given to a junior Corporal with hardly any experience in the field 12 as a supervisor, 13 14 H. Summer 2021. 15 63. In or about this time,Chief Valentin hired then-USC Director of Public Safety Alma Burke 16 to moderate multiple meetings with the Police Department's sworn officers to discuss the issues that the 17 females are experiencing at the department,both positive and negative. 18 19 64. The room was divided by individuals who were in"the Valentin camp"and those who were 20 trying to stay under the radar due to fear of retaliation from Chief Valentin and those acting on his behalf. 21 65. The female officers were advised that their comments and concerns would be provided in 22 report-form to Chief Valentin with recommendations. 23 24 66. However,the officers were also specifically told that the comments and concerns addressed 25 in the report would be confidential(i.e,,the names of the persons malting comments would not be reported 26 to Chief Valentin). 27 111 28 to VALDEZV, MIT OFSAN7AANA CAMNo. COMPLAINT 1 67. Indeed, in an attempt to have the females speak honestly without fear of retaliation, 2 Moderator Burke repeatedly mentioned to all the females that any comments and concerns would not be 3 4 repeated to other members of the Police Department. 5 68. While Moderator Burke ultimately wrote a report and provided it to Chief Valentin,none of 6 the involved female officers received a copy of the report or were informed of the report's conclusions or 7 recommendations. 8 9 69, However,contrary to the promised confidentiality,it soon became common knowledge that 10 the female officers' comments were shared with command staff who,presumably,shared these comments 11 with Chief Valentin. 12 I. November 2021. 13 14 70. It has been a long-standing custom, tradition and well-established courtesy within CITY's 15 Police Department that,if and when an officer wishes to sign up for a certain patrol team,the potential team 16 member contacts the team's corporal and/or sergeant to let the supervisor know that the potential teammate 17 is interested in that specific team so that,inter alia,the supervisor/s can provide the potential member officer 18 19 with expectations for the team. 20 71. Despite this well-known custom,tradition and courtesy,inNovember of 2021,VALDEZ was 21 notified that an anonymous complaint had been initiated against her(via an anonymous complainant) for 22 her actions in line with same. 23 24 72. VALDEZ later learned that the complaint was initiated by then-MET Corporal Luis Galeana. 25 73. Then-MET Corporal Galeana initiated the complaint-not on behalf ofhimself-but on behalf 26 of two female officers who had advised both of their supervisors (one of them being then-MET Corporal 27 28 Galeana)that they did not want to file a complaint against VALDEZ. 111 VALD133Z V.Cri'Y OF SANTA ANA CME No, COMP)AIM 1 74. Then-MET Corporal Galeana had also been advised by Commander Julian Rodriguez that 2 there was no need for a Memo to be submitted as the "issue"had already been resolved. 3 4 75. In fact,three different Watch Commanders (Commander Rodriguez, Commander Andrew 5 Alvarez and Commander Jason Viramontes)were aware of the incident involving VALDEZ and all three 6 agreed that the issue had been handled(i.e.,resolved)and that there was no need to move forward with any 7 formal Memo. 8 9 76. However, then-MET Corporal Galeana failed to follow orders and took it upon himself to 10 write the anonymous letter and to place it in the Internal Affair mailbox. I I J. September 2022. 12 77. On September 15,2022,VALDEZ received a Memo entitled"Administrative Investigation- 13 14 Notification of Interview" advising VALDEZ that CITY's Police Department was conducting an 15 investigation into the following alleged events: 16 "During the sign-ups process for the 2022 patrol year,in November 2021, it is alleged two officers 17 were denied their choice of signing up for your patrol team. It is farther alleged you may have contacted them after they had already signed up for your team,told them the spots they chose were 18 saved for other officers,and directed them to chose[sic]another patrol team.It is further alleged you 19 may have denied the two officers their right to sign up for their preferred patrol team due to gender or other perceived characteristics. 20 The Department Policies you may have violated[sic]put is not limited to is[sic]:Department Policy 21 320.5.1 (Laws Rules and Orders), Department Policy 320.3.2 (Supervisor Responsibilities), and 22 Policy 320.5.3 (Discrimination, Oppression, or Favoritism)." 23 78. Putting aside for a moment the irony that VALDEZ was being investigated for violations for 24 these policies-while those in"the Valentin camp"repeatedly engaged in actual"discrimination,oppression 25 26 or favoritism"and routinely violated numerous other much more significant and serious law,regulations and 27 policies - there is no dispute that VALDEZ's purportedly "improper" conduct was routinely permitted, 28 practiced and encouraged by other police supervisors. 111 12 VALD&v.CffYOFSANTAANA CASSNO, COMPLAINT 1 79. Indeed,repeated reference was made to same by various witnesses during CITY's resulting 2 "investigation." 3 4 K. November 2, 2022. 5 80. VALDEZ was notified via a Memo that Chief Valentin "concur[ed] with Commander 6 Gonzalez's SUSTAINED findings for violating Department Policy 320.3.2(d)Supervisor Responsibilities 7 (The unequal or disparate exercise of authority on the part of a supervisor toward any member for malicious 8 9 or other improper purposes.)." 10 81. As a result, Chief Valentin recommended that VALDEZ receive discipline of a "50-hour 11 SUSPENSION without OP TIONS [sic]", i.e., without pay. 12 82. This resulting discipline was clearly retaliatory as: (1)VALDEZ is aware of various persons 13 14 (who predominately- if not all-fall within"the Valentin camp")who have committed gross violations of 15 policy and law and who have not only not been similarly punished(much less even charged or investigated) 16 but who have actually received various promotions;and(2)V ALDEZ is aware of various persons who have 17 been told by supervisors not to sign up for certain teams because there was already a set group of people that 18 19 were going to be on certain teams who were never changed, investigated or disciplined. 20 L. December 2022. 21 83. An inquiry was submitted to Internal Affairs regarding then-MET Corporal Galeana's failure 22 to report a use of force which was caught on Body-Worn Camera. 23 24 84. Prior to the inquiry being submitted,Assistant Chief Robert Rodriguez advised supervisors 25 that then-MET Corproral Galeana's failure to do his job was merely a"training issue". 26 111 27 llr 28 111 13 VALDEZ V.CSTYOF SANTA ANA CASENO. ' COA'Immur 1 85. Then-MET Corporal Galeana was purportedly "investigated" (for the above serious 2 misconduct involving three policy violations caught on camera) and, while the outcome of CITY's 3 4 "investigation" is not publicly known, not only was there has been no public discipline (i.e., demotion, 5 suspension, etc.) but, in July of 2023,then-MET Corporal Galena was actually promoted to Sergeant. 6 M. December 2022. 7 86. VALDEZ appeared at a Skelly meeting with Chief Valentin, the Assistant Chief and the 8 9 Internal Affairs Commander at which time VALDEZ presented bullet points addressing the obvious flaws 10 in CITY's"investigation"of the claims against her,pertinent notes taken from the audio interviews and text 11 messages written by one of the complainants. 12 87. VALDEZ is informed and believes that CITY essentially ignored the information provided. 13 14 N. January 2023. 15 88. On January 18, 2023, VALDEZ applied for the sergeant promotional. 16 89. By this time,VALDEZ had been a patrol Corporal for four years and had acquired extensive 17 experience relevant to the sergeant position. 18 19 O. January/February 2023. 20 90. On January 26, 2023, one week after VALDEZ applied for promotion, CITY decided to 2t impose VALDEZ's suspension. 22 23 91. VALDEZ served her suspension-without pay-on January 26,January 27,February I and 24 February 2, 2023. 25 92. In January 2023,VALDEZ took and passed the written sergeant test. 26 93. In February, VALDEZ participated in and passed the practical application. 27 28 94. About a week later,VALDEZ interviewed for the enhanced resume portion. 11I 14 VALDHZ V.CITY OF SANTA ANA - CAsr No, COMPLA NT 1 95. Although VALDEZ felt she did extremely well during this interview, at the very end, 2 Commander Roland Andrade (viewed as pro-Valentin) asked VALDEZ about her recently-imposed 3 4 discipline. 5 96. VALDEZ responded that,per the advice of her union attorney,she was unable to discuss that 6 subject as her discipline was potentially subject to the appeals process. 7 P. ]February 2023. 8 9 97. On February 27, 2023, despite VALDEZ's above-referenced consistent "Outstanding" 10 Performance Evaluations, VALDEZ was told that she had"failed"the sergeant promotional process. 11 98. When VALDEZ met with the panel members,they each told her that she failed because of 12 her already-served discipline-discipline of which CITY was indisputably aware prior to her competing in 13 14 the promotional. 15 99. Not surprisingly, despite having less experience and being less qualified, at the top of the 16 Sergeant promotional list was Johanna Lizardi, wife of"Valentin camp"member Oscar Lizardi. 17 100. In,fact,now-Commander Oscar Lizardi,despite his involvement in Culichi Town and despite 18 19 being the subject of various serious misconduct complaints, was rewarded by Chief Valentin with an 20 unprecedented meteoric post-Culichi Town incident rise from Sergeant-to-Commander. 21 101. The February 2023 promotional outcome confirms that this favorable treatment has also been 22 afforded to Oscar Lizardi's wife, Johanna. 23 24 Q. July 2023. 25 102. VALDEZ applied for the MET Corporal Position. 26 103. ]-laving worked different suppression teams,as well as vice/narcotics as a detective,and after 27 28 working as a Corporal for over four years, VALDEZ's experience made her the best candidate for the position. is VALpBLv. CITY OFSANTAANA CMEM. COWLAIITr 1 104. However,VALDEZ was notified by Commander Sorenson that CITY had decided to go with 2 a junior corporal with less than a year of supervisory experience. 3 4 105. Commander Sorenson told VALDEZ that if he could have put a condition of SWAT 5 experience required on the job bulletin memo,he would have,but that he was told not to do so. 6 106. Commander Sorenson also told VALDEZ that a detective corporal spot would be opening 7 soon in the Sex Crimes Unit. 8 9 107. Notably,as VALDEZ has not worked sex crimes,she was unsure why he would mention that 10 particular unit as a fit for her. 11 108. However,the Sex Crimes Unit is comprised of multiple females. 12 R. Post-August 2023 Government Claim and DFEH Complaint Service on CITY. 13 14 109. Following VALDEZ's August 2023 service of her Government Claim and DFEH Complaint 15 on CITY, Chief Valentin has continued to retaliate against her (i.e., via his childish acts designed to 16 evidence his contempt by publicly ignoring her). 17 110. Additionally,in September 2023,Assistant Police Chief Robert Rodriguez ordered Sergeant 18 19 Matt Wharton to change VALDEZ's yearly evaluation reflect her discipline and ordered him to change the 20 score from a 5 to a 2, in essence continuing to retaliate against VALDEZ for already-served discipline. 21 111. In sum, as a result of CITY's ongoing retaliation,discrimination and harassment remaining 22 widespread and unaddressed, VALDEZ has suffered significant damage. 23 24 FIRST CAUSE OF ACTION 25 RETALIATION IN VIOLATION OF LABOR CODE §1102.5 26 (Against All DEFENDANTS) 27 2$ 112. VALDEZ realleges Paragraphs 1 through 11 f above and incorporates same as though fully set forth herein. 16 VALDEZ V. CYf'Y OF SAN7A ANA CASEM. COMPLAW 1 113. VALDEZ,as described more fully above,reported/disclosed to a government agency and/or 2 law enforcement agency and/or a person with authority over her or to an employee with authority to 3 4 investigate,discover,or correct legal violations and/or noncompliance to DEFENDANTS. VALDEZ had 5 reasonable cause to believe that the information reported/disclosed a violation of state, or federal statute 6 and/or a violation of and/or noncompliance with a local, state and/or federal rule and/or regulation [i.e., 7 Government Cade §§12900-12999 (California Fair Employment and Housing Act; Government Code 8 9 §§12945.2 et seq.;Penal Code§§186.22, 13670 and Assembly Bill 958(prohibition of gangs among police 10 officers); Child Abuse and Neglect Reporting Act.IPenal Code §§11164 et. seq) (police officers are 11 mandated reporters); Penal Code §§118, 127, 136.1 (perjury, suborning perjury, witness 12 tampering/intimidation);City of Santa Ana.Municipal Code and Santa Ana Police Department Policies.]Tn 13 14 response to the disclosures and complaints initiated by VALDEZ, DEFENDANTS retaliated against 15 VALDEZ as more fully described herein. 16 114. Because of the retaliation that VALDEZ faced, VALDEZ was wrongfully disciplined and 17 not promoted. 18 19 115. DEFENDANTS' treatment of and response to the disclosures, complaints and grievances 20 filed by VALDEZ was in violation of Labor Code §1102.5. 21 116. VALDEZ's reporting/disclosure of information was a contributing factor in VALDEZ's 22 suffering of adverse employment actions. 23 24 117. Asa direct result of DEFENDANTS'actions as alleged above,VALDEZ suffered harm and 25 injury that was legally (proximately) caused by the conduct of DEFENDANTS. Said harm and injury 26 includes, but is not limited to, special (economic) damages, general (non-economic) damages, litigation 27 28 costs, future damages and past damages, lost economic earning capacity in future employment endeavors and such further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Count. 17 vAmRz v.CaY of SAN,A ANA CASH No. COMPLAW 1 118. Additionally,as a direct and proximate result ofthe above-described acts of DEFENDANTS, 2 VALDEZ has necessarily incurred attorney's fees and costs and she is entitled,per,inter alia,Labor Code 3 4 §§98.b(b), §1105, 1102.5(f), Code of Civil Procedure §1021.5 and Assembly Bill 1947 to the reasonable 5 value of such attorney's fees and costs. 6 SECOND CAUSE OF ACTION 7 RETALIATION IN VIOLATION OF THE 8 9 FAIR EMPLOYMENT AND DOUSING ACT 10 (Against All DEFENDANTS) 11 119. VALDEZ realleges Paragraphs 1 through 118 above and incorporates same as though fully 12 set forth herein. 13 14 120. Section 12940,et.seq.ofthe California Government Code makes it unlawful for an employer 15 to retaliate against an employee in "terms, conditions or privileges of employment" because of their 16 protected status. The Fair Employment and.Housing Act("FEHA")protects,not only employees who make 17 a FEHA claim, but also, those who oppose acts made unlawful by the statute and/or testify, assist or 18 19 participate in any manner in proceedings or hearings. 20 121. As referenced above, DEFENDANTS retaliated against VALDEZ because she: (1) 21 participated as a witness in a discrimination or harassment complaint; and/or (2) reported or resisted any 22 form of discrimination or harassment. As detailed above, VALDEZ was treated differently by 23 24 DEFENDANTS (i.e.,retaliated against)because of same. 25 122. As detailed above,DEFENDANTS engaged in an action or a course and pattern of conduct 26 that, taken as a whole, materially and adversely affected the terms, conditions and/or privileges of 27 VALDEZ's employment. 28 Ill is VALDEZv.CI'ITYoFSANTAANA CASENO. COMPI.ATNT 1 123. As a direct and legal result of the retaliation against VALDEZ due to her protected status, 2 VALDEZ suffered harm and injury that was legally(proximately)caused by the conduct of DEFENDANTS. 3 4 Said harm and injury includes,but is not limited to, special(economic)damages, general(non-economic) 5 damages,attorneys' fees [per Government Code §12965(b)] and such further relief as shown at the time of 6 Trial and in excess of the minimal jurisdictional of this Court. 7 124. In addition to the above damages,as a proximate result of DEFENDANTS'actions as alleged 8 9 above,VALDEZ will also seek all damages allowed by the Code. Government Code, §12965(b), (c). 10 THIRD CAUSE OF ACTION 11 DISCRIMINATION IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 12 (PLAINTIFF Against All DEFENDANT'S) 13 14 125. VALDEZ realleges Paragraphs 1 through 124 above and incorporates same as though fully 15 set forth herein. 16 126. Section 12940,et.seq. ofthe California Government Code makes it unlawful for an employer 17 to discriminate against an employee in "terms, conditions or privileges of employment" because of the 18 19 protected status. DEFENDANTS engaged in an action or a course and pattern or conduct that,taken as a 20 whole,materially and adversely affected the terns,conditions and/or privileges ofVALDEZ's employment. 21 127. VALDEZ was treated differently by DEFENDANTS because of her protected status [i.e., 22 sex/gender, association with a member of a protected class] and for engaging in protected activities 23 24 (participating as a witness in a discrimination/harassment complaint, reporting/resisting 25 discrimination/retaliation). 26 11l 27 11l 28 19 VALDFZv, CrTYOFSANTAANA CASENO. COWLATNT 1 128. As a direct and legal result of the discrimination VALDEZ suffered due to her protected 2 status, VALDEZ suffered harm and injury that was legally (proximately) caused by the conduct of 3 4 DEFENDANTS. Said harm and injury includes,but is not limited to,special(economic)damages,general 5 (non-economic)damages,attorneys'fees[per Government Code§12965(b)]and such further relief as shown 6 at the time of Trial and in excess of the minimal jurisdictional of this Court. 7 FOURTH CAUSE OF ACTION 8 9 HARASSMENT IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 10 (PLAINTIFF Against All DEFENDANTS) 11 129. VALDEZ realleges Paragraphs 1 through 128 above and incorporates same as though fully 12 set forth herein. 13 14 130. The harassment included but was not limited to unwanted and unwelcome comments directly 15 to VALDEZ that were reported to and by VALDEZ, as further alleged herein above. As further alleged 1.6 herein above,DEFENDANTS entirely failed to respond as mandated by law. 17 131. The harassing conduct from DEFENDANTS was so severe,widespread or persistent that a 18 19 reasonable person in VALDEZ's circumstances would have considered the work environment to be hostile 20 and abusive. VALDEZ considered the work environment to be hostile or abusive. 21 132. DEFENDANTS whether or not named or designated as a Doe was/were a supervisor with 22 actual or reasonably perceived authority over VALDEZ and engaged in the harassing conduct against 23 24 VALDEZ. 25 133. VALDEZ was harmed and DEFENDANTS' conduct was a substantial factor in causing 26 VALDEZ's harm. 27 Ill 28 111 20 VALD LV.Crry of SANTA ANA CASENO, COMPLAINT 1 134. As a direct and legal result of the harassment VALDEZ suffered due to her protected status 2 [i.e., sex/gender, association with a member of a protected class and for engaging in protected activities 3 4 (participating as a witness in a discrimination/harassment complaint, reporting/resisting 5 discrimination/retaliation)],VALDEZ suffered harm and injury that was legally(proximately)eausedby the 6 conduct of DEFENDANTS. Said harm and injury includes, but is not limited to, special (economic) 7 damages, general(non-economic) damages, attorneys' fees [per Government Code §12965(b)] and such 8 9 further relief as shown at the time of Trial and in excess of the minimal jurisdictional of this Court. 10 FIFTH CAUSE OF ACTION 11 FAILURE TO TAKE CORRECTIVE ACTION 12 IN VIOLATION OF FAIR EMPLOYMENT AND HOUSING ACT 13 14 (PLAINTIFF Against All DEFENDANTS) 15 135. VALDEZ realleges Paragraphs 1 through 134 above and incorporates same as though fully 16 set forth herein. 17 136. DEFENDANTS are suffering/have suffered with a number of lawsuits and complaints 18 19 (including but not limited to the complaints from VALDEZ) alleging discrimination, retaliation and 20 harassment and putting DEFENDANTS on notice and providing knowledge of the need to eliminate 21 discrimination, retaliation and harassment. 22 137. Under the law, as well as their own policies, DEFENDANTS had an obligation to take 23 24 corrective action to prevent further discrimination,retaliation and harassment of VALDEZ but failed to do 25 so in violation of Section 12940, et. seq. of the California Government Code. DEFENDANTS failed to 26 conduct proper investigations, failed to turn over the results of these investigations, failed to implement 27 proper policies to prevent discrimination,retaliation and harassment and failed to properly punish those in 28 engaged in misconduct to deter further such future actions. 21 VALDEZ V. CITY OF SANTA ANA CASBNO. 1 138. As a direct and legal result of the treatment VALDEZ suffered due to her protected.status, 2 VALDEZ suffered harm and injury that was legally(proximately)causedby the conduct of DEFENDANTS. 3 4 Said harm and injury includes,but is not limited to, special(economic)damages,general(non-economic) 5 damages,attorneys' fees [per Government Code§12965(b)] and such further relief as shown at the time of 6 Trial and in excess of the minimal jurisdictional of this Court. 7 8 9 WHEREFORE,VALDEZ prays for Judgment against DEFENDANTS,and each ofthem,as follows: 10 1. For compensatory damages, including loss of earnings, deferred compensation,bonuses, 11 vacation and other employment perquisites and other special and general damages according to proof; 12 2. Damages for pain and suffering and emotional distress; 13 14 3. Interest, including pre judgment interest, at the prevailing legal rate; 15 4. Attorneys' fees and costs incurred herein; and 16 5. Costs of suit; and 17 6. Such further and other relief as the Court deems just and proper. 18 19 20 REQUEST FOR TRIAL BY JURY 21 VALDEZ hereby demands a Trial by Jury. 22 23 24 DATED: October 24, 2023 LAW OFFICE OF LAWRENCE J. LENNEMANN 25 26 By: Lawrence J. Lennemann 27 LAWRENCE J. LENNEMANN Attorneys for Plaintiff JUDITH VALDEZ 28 zz VALmz V,0TY of SANTAANA CA89NO. COMPLAINT Becerra, Alexis From: Ann Frazier < Sent: Thursday, April 2, 2026 7:13 PM To: eComment Subject: One Broadway Plaza Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Dear Mayor and City Council, Please do not approve One Broadway Plaza. It would not benefit the people of Santa Ana. It does not include affordable housing, it would cast a literal and figurative shadow across a swath of the city, create more complicated traffic patterns and negatively impact our community especially the Willard neighborhood. Our city, the second oldest in the county, has beautiful architecture in our historical buildings both residential and commercial. This behemoth which would stand nearly 500 feet does not add the charm of Santa Ana and, in fact, distracts from our unique neighborhoods' appeal. Perhaps Mr. Harrah should consider building a tower in a more conducive area like near the airport. Consider the fact that the Reagan Building is 176 feet tall while one of the tallest in the county near the Spectrum is 323 feet. One Broadway Plaza would rise nearly 500 feet into our skyline. The land at 10th and Broadway is better suited for a park as a place for the surrounding neighborhood to relax and enjoy outdoor space without a towering, unnecessary edifice blocking their sun and sky. Also, I have lived in Santa Ana most of my life and I appreciate our diverse community and our distinct neighborhoods. I was here in and voted against this building. Most of our current citizens did not have the opportunity to express their opinion on this structure. Furthermore, some people who voted in favor of it no longer live here. I think it should be up to the voters to decide if Santa Ana wants this monstrosity. Don't let private interest sway you from doing the right thing. Thank you for all you do for our city. Make the right choice by voting no against this unnecessary skyscraper. In appreciation, Ann Curley Frazier Ward 3 1 Becerra, Alexis From: Jackie Angel Investor < Sent: Tuesday, April 7, 2026 8:23 AM To: eComment Subject: Re: Settlement and Release Agreement 12/20/24 re: 2525 Main Street Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. From:Jackie Angel Investor< Sent:Thursday, March 6, 2025 3:06:54 PM To: dianefradkin@hotmail.com < Subject: Settlement and Release Agreement 12/20/24 Dear Ms. Fradkin, I am writing to inquire about the Settlement and Release Agreement between "Santa Ana Citizens for Responsible Development" and "AC 2525 Main LLC" entered into as of December 20, 2024. Where does the $15,000 settlement payment go? I am requesting City Charter section regarding contracts with developers specifically the part where it lists consequences of unlawful action, redress and the process to null and void contracts, plus the blacklisting procedure of those developers from doing business in the city whom have been found to have violated state law. Redevelopment Department Specifically, the resulting action City of Santa Ana took against Local developer Ryan Ogulnick is being fined for violating state law by allegedly laundering campaign money and failing to disclose the original source of over $300,000 spent on mailers in the 2018 Santa Ana election. Developer Ryan Ogulnick during the Nov. 19 2024 Santa Ana City Council meeting. Thank You, Jackie Cordova Santa Ana Residents Against Corruption i Flores, Dora From:Tom Frazier <tcfaqmdgov@gmail.com> Sent:Tuesday, April To:eComment Subject:Non-Agenda Item ONE BROADWAY PLAZA Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Dear Mayor and City Council Members, I am writing to you today to express my opposition to the proposed One Broadway Plaza (OBP) project. The proposed project does not benefit or serve the current residents of Santa Ana nor the future Santaneros and would alter the historic landscape and architecture of our city. A 37 story luxury apartment complex/high end commercial development will not serve the overwhelming working class residents of Santa Ana. The 600 plus units, consisting primarily of studio and one bedroom apartments, will be unaffordable to the vast majority of our population. The Five Star roof-top restaurants, the "Tavern on the Green", and a Whole Foods style grocery store would be out of reach and not benefit the current neighborhoods of Willard, French Park, Lacy, Logan, and French Court. I strongly encourage all of you to walk these neighborhoods and discuss their feelings on this matter. Further, the families and students of the schools in close proximity to the OBP proposed project should be interviewed and have their concerns taken into consideration. OBP would not appear to serve the future residents of Santa Ana and would likely only benefit the people able to afford to occupy the tower. Despite Harrah's dream of appealing to the Irvine and Newport Coast residents for relocating to OBP, the obvious future demographic of Santa Ana is going to continue to be majority latino and working class. It would be difficult for the 600 plus residents of the tower to sufficiently support the proposed businesses on the project site let alone benefiting businesses in downtown. The historic landscape and architecture of Santa Ana would be compromised by the OBP project. The 37 story glass tower would dwarf our landmark water tower - reaching a height nearly three times as high. The proposed 2,400 space-8 story-above ground parking structure would disturb the historic architecture in the area and be an ugly and unwelcoming eye sore to the entrance to the downtown district (take a look at the parking structures north of the 22 freeway near Grand Ave. that serve the hospital complex and the parking structure off of the 57 freeway near Katella Ave. for an idea of what this might look like). The One Broadway Plaza tower is essentially a middle finger to the surrounding neighborhoods and to the city as a whole. I am all for responsible development - the OBP is not a project that would benefit our city. Do you want this tower to be your legacy? Remember your Santa Ana roots. Vote this project down if and when it is presented to you and push for responsible city serving developments. Thanks. Tom Frazier Ward 3 60 plus resident of Santa Ana 35 year Union member (Retired Teamster) 1