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1 known by Defendants, but is being withheld pursuant to Penal Code §§832.5-832.8, <br /> 2 Evidence Code §§1043-1046. <br /> 3 7, Defendant David Valentin is the current Chief of Police for the City of <br /> 4 Santa Ana and is charged with the supervision, management of confidential peace <br /> 5 officer files and management of personnel, including personnel investigations and <br /> 6 discipline of employees of the Santa Ana Police Department. Plaintiffs have <br /> 7 information and belief that Valentin participated, supervised and/or was actively <br /> 8 involved in the incident giving rise to this Complaint. <br /> 9 8. Sonia Carvalho is a per se employee of the City of Santa Ana and acts as <br /> 10 the City Attorney for the City of Santa Ana. Plaintiffs have information and belief that <br /> 11 Carvalho directly participated, supervised and/or was actively involved in the incident <br /> 12 giving rise to this Complaint, and took actions, versus provided legal advice, that cause <br /> 13 the confidential records to be disclosed. <br /> 14 9. Defendant Kristin Ridge is the current City Manager for the City of Santa <br /> 15 Ana and is charged with the supervision and management of department heads, <br /> 16 including Defendant Valentin. Plaintiffs have information and belief that Defendant <br /> 17 Ridge participated, supervised and/or was actively involved in the incident giving rise to <br /> 18 this Complaint including the failure to investigate allegations of misconduct against <br /> 19 Defendant Valentin. <br /> 20 10. Defendant, City of Santa Ana, is a Municipal Corporation existing under <br /> 21 the Constitution and the laws of the State of California. The City of Santa Ana, via state <br /> 22 law, resolution, policy and past practice, has afforded sworn members of the Santa Ana <br /> 23 Police Department with the same rights as afforded to sworn peace officers under <br /> 24 Government Code §3300, et seq., and Penal Code §§832.5-832.8. <br /> 25 11. Defendant, Santa Ana Police Department, is a public safety department of <br /> 26 the City of Santa Ana and maintains confidential peace officer personnel <br /> 27 information/materials. <br /> 28 12. Defendant City of Santa Ana City Attorney's office is a department of the <br /> 3 <br /> COMPLAINT - <br />