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r <br /> I County of Orange, California. This Court has jurisdiction over the present matter <br /> 2 because, as delineated within this complaint, the nature of the claims and amount in <br /> 3 controversy meet the requirements of jurisdiction in the Superior Court. This Court is <br /> 4 empowered with initial jurisdiction to entertain suits brought pursuant to traditional <br /> 5 mandamus action. <br /> 6 2. Plaintiffs request a jury trial on all non-mandamus relief. <br /> 7 3. Plaintiffs have exhausted all his/her//its administrative remedies, and/or <br /> 8 exhaustion would be futile under Briley v. City of West Convina (2021) 66 Cal.App.5th <br /> 9 119, as there is no ability to challenge the actions of Defendants in this case; therefore <br /> 10 Plaintiffs assert that he/she/they have exhausted all administrative remedies required of <br /> 11 him/them. <br /> 12 4. Plaintiff timely and properly filed a Notice of Government Tort Claims with <br /> 13 the City of Santa Ana for the action described herein, and said claim was rejected on or <br /> 14 about June 15, 2021, without objections or claims of insufficiency. <br /> 15 PARTIES <br /> 16 5. At all times herein mentioned, Plaintiff SANTA ANA POLICE OFFICERS <br /> 17 ASSOCIATION (hereinafter "POA, "Association," or collectively, with Doe Officers, <br /> 18 referred to as "Plaintiffs") was and is the recognized employee organization consisting <br /> 19 of all non-management Santa Ana Police Department employees. Its primary purpose <br /> 20 is the representation of its members, including Doe Officers in their employment <br /> 21 relations with the Santa Ana Police Department and the City of Santa Ana, The POA <br /> 22 brings this action on behalf of itself and Doe Officers and all similarly situated <br /> 23 employees of the Santa Ana Police Department. <br /> 24 6. Plaintiff Doe Officers are employed by the Santa Ana Police Department <br /> 25 as a sworn, full time police officer for the City of Santa Ana, Santa Ana Police <br /> 26 Department and as such were and are to be afforded all of the rights under Penal Code <br /> 27 §§832.5-832.8 and/or Evidence Code §§1043-1046, state law, City and/or Police <br /> 28 Department resolution, policy and past practice. The true identity of the does officers is <br /> 2 <br /> COMPLAINT <br />