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1 President, engaged in a conflict of interest by negotiating a side letter agreement <br /> 2 related to the pension issue. As the City Council was scheduled to approve the <br /> 3 resolution of the pension issue, Carvalho made multiple inquiries to the FPPC for an <br /> 4 opinion letter finding Serrano was engaging in an unethical conflict of interest. <br /> 5 Ultimately, the FPPC found that Serrano did not engage in any conflict of interest nor <br /> 6 did his actions give rise to an unethical conflict of interest. It is believed that Carvalho <br /> 7 was acting on her own and with the sole purpose of personally interfering with the <br /> 8 SAPOA/Serrano and/or with intent to harm Serrano. <br /> 9 FEMALE DISCRIMINATION COMPLAINTS <br /> 10 32. In or about November, 2020, SAPOA/Serrano informed Defendant Ridge <br /> 11 that there was ongoing discrimination against female employees in the Department. <br /> 12 Plaintiffs described an incident involving female officers' attendance at a conference <br /> 13 regarding leadership issues for women in law enforcement and the Chief's behavior <br /> 14 towards those female employees. Defendant Ridge did not open an investigation into <br /> 15 the matter until months later when it was statutorily too late to take disciplinary action <br /> 16 against Defendant Valentin or his subordinates. <br /> 17 33. After Plaintiffs informed Defendant Ridge of the discrimination and <br /> 18 harassment of the female officers, Defendant Valentin ordered a "preliminary <br /> 19 assessment" in order to cover up his and his staff's misconduct. The Human Resource <br /> 20 representative that appeared with him when he confronted the female officers <br /> 21 conducted the investigation. The female officers were ordered to appear for <br /> 22 interrogations. They were not provided any information as to the nature of the <br /> 23 investigation. When they appeared for interrogation, the HR Representative read from a <br /> 24 transcript, indicated that she was going to prepare a report that only went to Valentin, <br /> 25 and then questioned the females about the female's actions and did not have any <br /> 26 preset questions about Chief Valentin's, DC Esparza's or other police commander's <br /> 27 actions. <br /> 28 34. On information and belief, it is alleged the Valentin lied to Defendant <br /> 9 <br /> COMPLAINT <br />