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1 SPYING <br /> 2 16. In January, 2020, Defendant Valentin began spying on Plaintiff Serrano <br /> 3 and members of the Santa Ana City Council by redirecting copies of all e-mail <br /> 4 communications sent by Serrano to City Councilmember Solorio, from June 2017 <br /> 5 forward, to his office. Defendant Valentin then had the City's IT department put a tracer <br /> 6 on all of Serrano's emails so that they would automatically be copied to Defendant <br /> 7 Valentin. <br /> 8 OTHERINTERFERENCE <br /> 9 17. During the last year and continuing to the present, Defendants have <br /> 10 censored membership communications and/or denied the SAPOA the ability to send <br /> 11 membership communications via the City's e-mail system. <br /> 12 18. Defendant Valentin has engaged in action to advocate for a change of <br /> 13 leadership in the SAPOA and has attempted to interfere with SAPOA elections. Said <br /> 14 action includes, but is not limited to, encouraging candidates to run against Serrano for <br /> 15 the position of Association President, and questioning members' support for Serrano <br /> 16 when they are seeking special assignments and promotions. <br /> 17 COMPLAINTS AGAINST LIEUTENANTS <br /> 18 19. In or about January, 2020, the SAPOA and Serrano were informed of <br /> 19 allegations of misconduct by SAPD Lieutenants/Commanders Jose Gonzalez and <br /> 20 Robert Rodriguez. It was alleged that the two were maliciously spreading rumors <br /> 21 regarding activities of Serrano and the SAPOA. Plaintiffs have information and belief, <br /> 22 and thereon allege, that said actions constitute violations of department policy and <br /> 23 negatively impact the morale of the police department as well as cause division in the <br /> 24 SAPOA. The Plaintiffs met with Defendant Valentin and informed him of the allegations <br /> 25 of misconduct. Valentin appeared dismissive. Since Valentin failed to initiate an <br /> 26 investigation as required by Penal Code §§832.5-832.7, the SAPOA/Serrano reported <br /> 27 the information to Defendant Ridge. Again, no investigation was initiated of the police <br /> 28 commanders nor of Defendant Valentin. <br /> 5 <br /> COMPLAINT <br />