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10/07/2025 Regular & HA
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Correspondence - Non Agenda
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11/13/2025 5:28:21 PM
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City Clerk
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10/7/2025
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1 2. Defendant.CRISTAL GUTIE REZ is an individual residing in the City of Santa Alta, <br /> 2 County of Orange, State of California and, at all times herein, was a police officer employed by <br /> 3 Defendant, CITY OF SANT'A ANA, <br /> 4 3. That Plaintiff is inforined and believes, and thereon alleges that, at all relevant tunes herein <br /> 5 <br /> mentioned,Defendants CITY OF SANTA AN.A is a public entity. Plaintiff timely submitted. <br /> 6 <br /> government claims against said public entities, and each of said claims were denied; either directly or <br /> 7 <br /> 8 by operation of law. Correct copies of the claims are attached as Exhibit L <br /> 9 4. Plaintiff is ignorant of the true names and capacities of defendants sued herein as <br /> 10 DOES 1 through 100,inclusive, and therefore sues said defendants by such fictitious names. Plaintiff <br /> will amead this Complaint to allege them`.true names and capacities when the same are ascertained. <br /> 12 Plaintiff is iufbiniecl and believes, and thereon alleges, that the fictitiously named d6e.ndants are <br /> 13 <br /> legally responsible in sonic manner for the,oecu�rences, injuries,and damages hereinafter alleged, <br /> 14 <br /> S. That Plaintiff,is informed.and believes and thereon alleges that, at all tines herein <br /> 15 <br /> 16 mentioned in this Complaint,defendants were the agents and.employees of their co-defendants, and in <br /> 17 doing the things alleged in ibis Complaint were acting within the course and scope of that agency mid <br /> 18 employment. In the alternative,each defendant authorized,consented to and/or ratified the conduct of <br /> 19 the remaining defendants, and each of there. <br /> 20 6. Defendant, CRI.STAL GUTERREZ and Does 1--50, at all times mentioned was and is a <br /> 21 <br /> City of Santa Ana Police officer. Defendant, CRISTAL Cif.TtERREZ,was on duty,in the course and <br /> 22 <br /> scope of her employment,as a Santa Ana Police officer, Defendant CRISTAL GUTIERREL was <br /> 23 <br /> 24 traveling northbound can Bristol Street in Orange County California,in her marked black acid white <br /> 25 patrol car license plate 1607869. <br /> 26 7, Defendants, CITY OF SANTA ANA,and Does 1-100 are the owners of the marked black <br /> 27 <br /> -2- <br /> 28 Complaint for Damages <br /> i <br /> i <br />
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