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1 97. Additionally,Bogosian falsely accused RAMIREZ of attempting to release documents to <br /> 2 <br /> Serrano and, thereafter, Valentin repeated this false claim at a senior management meeting. <br /> 3 <br /> 4 98. Then, after CITY was sued for failing to release records related to the Brandon Lopez <br /> 5 shooting, Sergio Enriquez improperly attempted to blame RAMIREZ for responding - although she had <br /> 6 responded in the exact manner that she had been instructed by him. <br /> 7 <br /> 99. Valentin-in a further attempt to improperly"manage' the information provided(or,more <br /> 8 <br /> 9 accurately,not provided)to Serrano - appointed Enriquez to respond to the PRAs. <br /> 10 K. CITY Continued to Unlawfully Retaliate Against RAMIREZ. <br /> 11 100. Relative to many of the above events,RAMIREZ has been identified as a witness in various <br /> 12 <br /> 13 other legal matters pending against CITY regarding Valentin's conduct and,to date,has participated in at <br /> 14 least three separate interviews in which she provided testimony in cases brought by other employees. <br /> 15 101. The Fair Employment and HousingAct protects-not only employees who themselves make <br /> 16 retaliation, discrimination and harassment claims but - those, like RAMIREZ who: (1) make a charge, <br /> 17 <br /> 18 testify, assist or participate in any manner in proceedings or hearings under the statute (the "participation <br /> 19 clause");and/or(2)oppose acts made unlawful by the statute(the"opposition clause"). Government Code, <br /> 20 §12940(h). <br /> 21 102. CITY's retaliation against RAMIREZ's for her participation in these matters (and for <br /> 22 <br /> 23 RAMIREZ's expressed opposition to Valentin and CITY's conduct) was clearly additional unlawful <br /> 24 retaliation and harassment. <br /> 25 L. CITY Continued to Unlawfully Retaliate Against RAMIREZ. <br /> 26 103. On January 26, 2022, RAMIREZ attended a meeting and Valentin was in the room and he <br /> 27 <br /> 28 said in front of everyone: "Rita Ramirez, you're still here, huh?", to which RAMIREZ replied: "Yes sir, <br /> unless you fired me, and I didn't know about it." <br /> 13 <br /> RAmmzv.CITYOPSANPAANA CASHNo. <br /> COMPLAINT <br />