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. ti 1 §§832.5-832.8 and/or Evidence Code §1043-1046. 2 34. Plaintiffs, and each of them, bring this action on behalf of themselves and 3 all similarly situated officers, seeking injunctive/mandamus relief against Defendants, 4 and each of them, who have violated these sections, to remedy the violation and to 5 prevent future violations of a like or similar nature, including, but not limited to, the 6 granting of a temporary restraining order, preliminary injunction, or permanent injunction 7 prohibiting the Defendants from releasing any confidential peace officer information 8 without full compliance with the law and without providing prior notice to the impacted 9 officers and/or Santa Ana Police Officers Association. 10 35. Plaintiffs Santa Ana Police Officers Association and Doe Officers have 11 sustained ancillary damages by Defendants' action. These damages include, but are 12 not limited to, attorney fees, costs and general emotional distress. 13 36. The duty to obey the law in maintaining confidential peace officer 14 personnel information is a ministerial duty and is not discretionary. By acting, and 15 failing to act, as set forth above, defendants have violated a ministerial duty. The court 16 can issue an order directing the employer to act. 17 37. Plaintiffs have no plain, speedy or adequate remedy under the law. 18 Plaintiffs have attempted to exhaust all administrative remedies to redress the violation 19 of their rights and have made repeated objections and/or complaints regarding the 20 same to no avail. 21 38. Plaintiff requests this court to award ancillary damages pursuant to C.C.P. 22 §1090 and 1095. 23 39. The actions of defendants, and each of them, were arbitrary and 24 capricious and, therefore, Plaintiff is entitled to recover attorneys' fees pursuant to 25 Government Code §800. 26 40. The success of Plaintiffs in this action will result in the enforcement of an 27 important right affecting the public interest in that a significant benefit will be conferred 28 on a large class of persons, that is, public employees, and the necessity and financial 9 COMPLAIN"