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1 representation of sworn and non-sworn employees of the Santa Ana Police Department <br /> 2 in their employment relations with the City of Santa Ana and/or Santa Ana Police <br /> 3 Department. In the sworn ranks the SAPOA represents all sworn officers holding the <br /> 4 ranks of Police Sergeant and below, as well as Correctional Supervisor and below. <br /> 5 2. Plaintiff Gerry Serrano has been since 2016, and now is, the President of <br /> 6 the Santa Ana Police Officers Association and the recognized representative of the <br /> 7 Santa Ana Police Officers Association as that term is used in Government Code <br /> 8 §3502.1. He is also a sworn police officer, holding the rank of Police Sergeant with the <br /> 9 Santa Ana Police Department. <br /> 10 3. Defendant City of Santa Ana is a Municipal Corporation existing under the <br /> 11 Constitution and the laws of the State of California. The City of Santa Ana is a public <br /> 12 agency as that term is defined in Government Code §3501(c). It is a municipal entity <br /> 13 employing public employees and thus, has a mandatory duty to comply with the <br /> 14 provisions of Government Code §3300, et seq., and Government Code §3500, et seq. <br /> 15 4. Defendant Santa Ana Police Department is a department of the City of <br /> 16 Santa Ana and a public safety department, as that terms is used in Government Code <br /> 17 §3309.5. Defendant Santa Ana Police Department is also a public agency, as that term <br /> 18 is used in Government Code §3500, et seq. <br /> 19 5. Defendant Kristine Ridge was and is the City Manager for the City of <br /> 20 Santa Ana, and the direct supervisor/appointing authority of the Chief of Police and <br /> 21 Human Resource Director. Ridge is the person responsible for the operations of the <br /> 22 city, including the overall management of the City. Plaintiffs have information and belief <br /> 23 that Ridge participated in, supervised and/or was actively involved in the incidents <br /> 24 giving rise to this action in both her individual and official capacities. <br /> 25 6. Defendant David Valentin was and is the appointed Chief of Police for the <br /> 26 City of Santa Ana, Santa Ana Police Department. As such he is charged with the <br /> 27 supervision and management of personnel, including personnel investigations and <br /> 28 discipline of employees of the Santa Ana Police Department. Plaintiffs have information <br /> 2 <br /> COMPLAINT <br />