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I the names of the impacted members/officers, but simply stated that the effected <br /> 2 employees had been notified. As it turned out, when Deputy Chief Paulson claimed, on <br /> 3 behalf and presumably at the directions of Defendants, that all affected employees had <br /> 4 been notified, the statement was not true and appears to have been an intentional <br /> 5 misrepresentation by Defendants to conceal the fact that the notifications to the <br /> 6 effected employees had just begun. <br /> 7 45. The Santa Ana Police Officers Association filed a written complaint with <br /> 8 the Defendant City Manager Kristine Ridge, and Human Resource Director Jason <br /> 9 Motsick requesting that the matter be immediately investigated. Plaintiffs are informed <br /> 10 and believe, and thereupon allege that even though the Defendants were required to <br /> 11 investigate this matter, as a "citizen complaint" pursuant to Penal Code §§832.5-832.7, <br /> 12 Defendants did not investigate nor discipline those city employees responsible for the <br /> 13 violations of law. <br /> 14 46. On or about April 28, 2021, a number of affected officers and the Santa <br /> 15 Ana Police Officers Association, which has a legal right to represent its members in any <br /> 16 and all matters related to their employment with the Santa Ana Police Department, <br /> 17 requested copies of any and all communications regarding PRA#21-289, including all <br /> 18 a-mails between representatives of the City, Police Department and/or Voice of OC and <br /> 19 also requested copies of all records that were produced to the Voice of OC and a list of <br /> 20 the impacted officers. Defendants, as part of an ongoing plan and scheme to <br /> 21 undermine and interfere with the POA's ability to represent its members, denied the <br /> 22 POA's request for copies of the produced records and list of names of impacted <br /> 23 employees. Defendants refused to provide copies of the unlawfully released information <br /> 24 and/or the list of names of the impacted employees. <br /> 25 47. Also on April 28, 2021, Defendants Motsick, Valentin, Ridge and Carvalho <br /> 26 issued a letter wherein they indicated that City was terminating the SAPOA's long <br /> 27 standing ability to send emails to communications to all SAPOA members through the <br /> 28 City's email system. <br /> 12 <br /> COMPLAINT <br />