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1 and belief that Valentin participated in, supervised and/or was actively involved in the <br /> 2 incidents giving rise to this action in both his individual and official capacities. <br /> 3 7. Sonia Carvalho was and is a private attorney employed by the law firm of <br /> 4 Best Best and Krieger LLP, and is the appointed and/or contracted City Attorney for the <br /> 5 City of Santa Ana. Plaintiffs have information and belief that Carvalho participated in, <br /> 6 supervised and/or was actively involved in the incidents giving rise to this action in both <br /> 7 her individual and official capacities, and that she acted outside the scope of her duties <br /> 8 as an attorney when engaging in acts described below. <br /> 9 8. Defendant Jason Motsick was and is the appointed Human Resource <br /> 10 Director for the City of Santa Ana and is charged with the supervision and management <br /> 11 of personnel, including personnel investigations and discipline of employees of the <br /> 12 Santa Ana Police Department. Plaintiffs have information and belief that Motsick <br /> 13 participated in, supervised and/or was actively involved in the incidents giving rise to <br /> 14 this action in both his individual and official capacities. <br /> 15 9. At all times herein mentioned, DOES I-X, inclusive, were the agents, servants <br /> 16 and employees of Respondent, City of Santa Ana and/or Santa Ana Police Department, <br /> 17 and in doing the things hereinafter alleged, were acting within the scope of their <br /> 18 authority as such agents, servants and employees with the permission and consent of <br /> 19 Respondents. Claimant will amend the Complaint to allege true names and capacities <br /> 20 of DOES I-X, inclusive when ascertained. <br /> 21 GENERAL FACTS <br /> 22 10. Serrano became President of the SAPOA in 2016 and has served <br /> 23 continuously in the position. <br /> 24 11. When seeking appointment as Chief of Police, Defendant Valentin sought <br /> 25 out and received the support of Serrano and the SAPOA. Later, when the SAPOA and <br /> 26 Serrano sought wages and benefits for the SAPOA membership and/or opposed <br /> 27 Valentin on matters of concerns to the Plaintiffs, Valentin's demeanor and working <br /> 28 relationship with Plaintiffs became adversarial. <br /> 3 <br /> COMPLAINT <br />