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1 67. After the conference was over, several of the attendees and RAMIREZ began to have a 2 discussion about how poorly women(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 a "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 18 71. RAMIREZ's memo also detailed how the women discussed that"this type of behavior is the 19 bculture' 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 23 73. Additionally,while Valentin loves to give lip service to the phrase"one team,one mission", 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 28 was actually expected to report back to Valentin regarding who said what to whom so the women at issue could be"dealt with" (i.e.,RAMIREZ had been expected to"rat out"the women). Ip RAMMMV,CITYOFSANI'AANA CASHNO, COMPLARU