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1 officers involved; a clear violation of Penal Code §832.7(d). <br /> 2 16. Defendants Carvalho, Valentin, Ridge, City of Santa Ana and/or the Santa <br /> 3 Ana Police Department are aware that peace officer personnel records are confidential <br /> 4 and exempt from disclosure. <br /> 5 17. On or about April 21, 2021, Deputy Chief of Police Eric Paulson, on behalf <br /> 6 of Defendant Valentin, conceded in a letter to the Voice of OC that confidential peace <br /> 7 officer personnel had been produced to the Voice of OC, including, but not limited to <br /> 8 the names of the officers in connection with administrative investigations. Deputy Chief <br /> 9 Paulson requested that the confidential records be returned. <br /> 10 18. Plaintiff are informed and believe, and thereupon allege that after the <br /> 11 Voice of OC, on or about April 22, 2021, refused to return the confidential records, <br /> 12 Defendants failed to take any action to force the Voice of OC to return the documents. <br /> 13 19. On or about April 27, 2021, Defendants started notifying certain of the <br /> 14 impacted officers of the unlawful actions by Defendants. The Notification did not advise <br /> 15 the impacted employees of what specific information had been released nor provided <br /> 16 notification of any rights they may have. The notices also did not indicate if the <br /> 17 Defendants would be taking further action to enforce the employees' rights. <br /> 18 20. Also on or about April 27, 2021, Deputy Chief Paulson informed the Santa <br /> 19 Ana Police Officers Association of the Defendants' unlawful disclosure of confidential <br /> 20 peace officer information of members of the Santa Ana Police Officers Association. <br /> 21 The notification of Defendants' unlawful action did not identify the POA of the names of <br /> 22 the impacted members/officers, but simply stated that the effected employees had been <br /> 23 notified. <br /> 24 21. As it turned out, when Deputy Chief Paulson claimed, on behalf and <br /> 25 presumably at the directions of Defendants, that all effected employees had been <br /> 26 notified, the statement was not true and appears to have been an intentional <br /> 27 misrepresentation by Defendants to conceal the fact that the notifications to the <br /> 28 effected employees had just begun. <br /> 5 <br /> COMPLAINT <br />