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I with the District Attorney's office. <br /> 2 25. As part of the April, 2020, efforts to wrongfully bring a criminal case <br /> 3 against Serrano, Defendants used department resources, including the Internal Affairs <br /> 4 unit, to draft memoranda with adverse comments about Serrano. Serrano was never <br /> 5 informed by Defendants of the internal investigation or memoranda, and Defendants <br /> 6 failed to allow Serrano to review the adverse comments. It is further believed, to the <br /> 7 extent that Defendants have initiated an Internal Affairs investigation, the investigation <br /> 8 was not completed within one year of notice of the allegations of misconduct nor has <br /> 9 Plaintiff Serrano been notified of any proposed discipline or outcome of the <br /> 10 investigation during that one year period. Defendants intentionally concealed the <br /> 11 information regarding this investigation and the related memoranda from Plaintiffs. <br /> 12 CULICHI TOWN COVER-UP <br /> 13 26. On August, 2020, on-duty SAPD officers responded to a call for service at <br /> 14 the Culichi Town Restaurant. The call involved allegations that off-duty SAPD officers <br /> 15 had sexually battered two underage girls that were at the restaurant. The officers <br /> 16 response was caught on body worn cameras and the victim's family produced a video <br /> 17 of the incident that showed off-duty police sergeant Oscar Lizardi as being present and <br /> 18 possibly involved in the incident. A Police Commander reported the incident to then IA <br /> 19 Commander, and now Deputy Chief, Robert Rodriguez. Rodriguez is believed to be a <br /> 20 close friend of Lizard. He denied the Commander's request for the incident to be <br /> 21 investigated. <br /> 22 27. On or about September 2, 2020, a request for public records was made <br /> 23 for information related to the call including the Incident Detail Report, copy of the 911 <br /> 24 emergency calls and/or non-emergency line calls, and police dispatch radio traffic audio <br /> 25 files related to the incident (Incident No. 200805316). Defendant Valentin, on <br /> 26 September 24, 2020, denied, in total, the PRA request in order to cover up the <br /> 27 misconduct of his IA Commander and one of his closest allies (Lizardi) asserting that <br /> 28 the records could not be released because they involved juveniles. This demonstrated <br /> 7 <br /> COMPLAINT <br />