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1 City of Santa Ana and employees attorneys as employees of the City. Plaintiffs have <br /> 2 information and belief that the City Attorney's office participated, supervised and/or was <br /> 3 actively involved in the incident giving rise to this Complaint and took actions, versus <br /> 4 provided legal advice, that cause confidential records to be disclosed. <br /> 5 13. At all times herein mentioned, DOES I-X, inclusive, were the agents, <br /> 6 servants and employees of Defendant, City of Santa Ana and/or Santa Ana Police <br /> 7 Department, and in doing the things hereinafter alleged, were acting within the scope of <br /> 8 their authority as such agents, servants and employees with the permission and <br /> 9 consent of Defendants. Plaintiffs will amend the Complaint to allege true names and <br /> 10 capacities of DOES I-X, inclusive when ascertained. <br /> 11 FACTS GIVING RISE TO ACTION <br /> 12 14. On or about February 25, 2021, a purported reporter with the Voice of OC <br /> 13 (an online nonprofit media source) sent to the City Attorney for the City of Santa Ana <br /> 14 and Santa Ana Police Department, Sonia Carvalho, directly, a request for public <br /> 15 records seeking, among other things a spreadsheet or breakdown of how many <br /> 16 employees at the Santa Ana Police Department have been put on paid administrative <br /> 17 leave between 01/01/2016 and 2125/2021. The PRA request included a request for Ms. <br /> 18 Carvalho to provide the reasons for the employees being put on paid administrative <br /> 19 leave and a breakdown of total costs to the City of Santa Ana incurred by paid <br /> 20 administrative leave for Santa Ana Police Department employees between 01/01/2016 <br /> 21 and 2/25/2021. <br /> 22 15. On or about March 26, 2021, without prior notice to the involved <br /> 23 employees and/or without complying with Penal Code §§832.5-832.8 and/or Evidence <br /> 24 Code §1043-1046, the City Attorney's office, the City of Santa Ana, under the <br /> 25 supervision of Defendant Ridge and/or the Santa Ana Police Department, under the <br /> 26 supervision of Defendant Valentin, intentionally and purposely produced confidential <br /> 27 records from the involved officers' personnel files. It is believed that this disclosure <br /> 28 included, but was not limited to the disclosure of data that identified the individual <br /> 4 <br /> COMPLAINT <br />