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1 20. On or about June 8, 2021, Plaintiffs filed an official complaint regarding <br /> 2 the commanders' actions and the failure to investigate the allegations with Defendant <br /> 3 Motsick. Motsick also refused to initiate an investigation of the commanders and <br /> 4 Defendant Valentin. <br /> 5 PERB COMPLAINT <br /> 6 21. In or about February, 2020, the SAPOA filed an Unfair Practice Charge <br /> 7 with the Public Employment Relations Board (PERB) alleging that the City of Santa Ana <br /> 8 had interfered with, intimidated, attempted to restrain and coerce members of the <br /> 9 Association and Gerry Serrano. The City informally resolved the matters, so the SAPOA <br /> 10 withdrew the charge. <br /> 11 CAMPAIGN SIGNS <br /> 12 22. In April, 2020, Plaintiffs reported the theft of campaign signs related to a <br /> 13 recall of Santa Ana City Councilmember Iglesias. One of the identified suspects was <br /> 14 the City Council person herself. The SAPOA learned that a Police Commander directed <br /> 15 the investigating officer to alter his report so that the City Council person would not be <br /> 16 listed as the suspect. The Plaintiffs reported the Police Commander's actions to <br /> 17 Defendant Valentin. <br /> 18 23. Instead of investigating the unlawful actions of the Police Commander, <br /> 19 Valentin ordered his Internal Affairs commander and investigators to conduct an <br /> 20 investigation of Serrano. <br /> 21 24. When the Plaintiffs obtained a video recording showing the former City <br /> 22 Council person stealing the campaign signs, Defendant Valentin, Defendant Carvalho <br /> 23 and other private attorneys employed by her firm, directly and through Valentin's <br /> 24 supporters pressured the Orange County District Attorney's office to open a criminal <br /> 25 case against Serrano. When the District Attorney's office rejected Valentin's pressures <br /> 26 Valentin became upset. With the help of Defendant Carvalho and her private law firm, <br /> 27 he began a lengthy letter and meeting campaign in which he chastised the District <br /> 28 Attorney's decision and knowingly included false information in the communications <br /> 6 <br /> COMPLAINT <br />