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1 perform a public duty enjoined by law. <br /> 2 74. Defendants knowingly and intentionally interfered with and/or restrained <br /> 3 Plaintiffs in response to a public records request that Defendants knew or should have <br /> 4 know were protected from release due to the records constituting and/or containing <br /> 5 confidential peace officer personnel file information, <br /> 6 75, Plaintiffs, and each of them, bring this action on behalf of themselves and <br /> 7 all similarly situated officers, seeking injunctive/mandamus relief against Defendants, <br /> 8 and each of them, who have violated these sections, to remedy the violation and to <br /> 9 prevent future violations of a like or similar nature, including, but not limited to, the <br /> 10 granting of a temporary restraining order, preliminary injunction, or permanent injunction <br /> 11 prohibiting the Defendants from concealing information requested by the Association. <br /> 12 76. Plaintiffs Santa Ana Police Officers Association and Doe Officers have <br /> 13 sustained ancillary damages by Defendants' action. These damages include, but are <br /> 14 not limited to, attorney fees, costs. <br /> 15 77. The duty to obey the laws set forth in Government Code §3500, et seq., is <br /> 16 a ministerial duty and is not discretionary. By acting, and-failing to act, as set forth <br /> 17 above, defendants have violated a ministerial duty. The court can issue an order <br /> 18 directing the employer to act. <br /> 19 78. Plaintiffs have no plain, speedy or adequate remedy under the law. <br /> 20 Plaintiffs have attempted to exhaust all administrative remedies to redress the violation <br /> 21 of their rights and have made repeated objections and/or complaints regarding the <br /> 22 same to no avail. <br /> 23 79. Plaintiff requests this court to award ancillary damages pursuant to C.C.P. <br /> 24 §1090 and 1095. <br /> 25 80. The actions of defendants, and each of them, were arbitrary and <br /> 26 capricious and, therefore, Plaintiff is entitled to recover attorneys' fees pursuant to <br /> 27 Government Code §800. <br /> 28 81. The success of Plaintiffs in this action will result in the enforcement of an <br /> 16 <br /> COMPLAINT <br />