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I that Valentin was aware of the incident and that it involved allegations of criminal 2 conduct towards juveniles by off-duty SAPID officers. 3 28. SAPOA/Serrano complained to Defendants about Valentin's and 4 Rodriguez's attempts to cover up alleged criminal conduct by officers who supported 5 Defendant Valentin pointing out that this conduct amounted to conspiring to commit a 6 criminal act. It is believed that it wasn't until June, 2021, after multiple complaints and 7 requests for investigations by the SAPOA, that Defendants initiated an investigation of 8 two of the three responding officers. The third responding officer was given a special 9 assignment on Lizardi's specialized team. In July, 2021, the Department initiated an 10 Internal Affairs investigation of one of the off-duty officers, but not Lizardi, who was the 11 ranking officer amongst the off duty personnel involved in the incident. 12 29. On information and belief, Plaintiffs allege that Defendants have refused 13 to initiate an investigation of Deputy Chief Rodriguez and/or Defendant Valentin. 14 PENSION ISSUE 15 30. In October, 2020, the Defendants inquired of CalPERS as to the propriety 16 of including a premium pay, called "Confidential" received by Serrano while on paid 17 release time to serve as the SAPOA President in the calculation of his pension. It is 18 believed that the City had never inquired about this issue with any prior SAPOA 19 President. When it appeared that there might be a question regarding the inclusion of 20 the premium in the calculation of Serrano's pension, the City and SAPOA reached an 21 agreement acceptable to Ca1PERS. However, because Serrano continued to carry out 22 his duty to represent the Association and its members, activity that is clearly protected 23 under the law, Defendants failed and refused to take the necessary steps to resolve the 24 issue. 25 F'PPC COMPLAINT 26 31. In November, 2020, Sonia Carvalho, believed to be acting on her own 27 personal vendetta and without City Council approvalsent a request to the California Fair 28 Political Practices Commission seeking a finding that Serrano, as the SAPOA 8 COMPLAINT