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1 58. On or about May 27, 2021, Defendant Valentin ordered an investigation of <br /> 2 Serrano based on alleged comments Serrano made in his capacity as the current <br /> 3 President of the SAPOA about a former SAPOA President in October, 2020. The <br /> 4 investigation was opened even though legal counsel for the City of Santa Ana indicated, <br /> 5 in writing that to the extent Serrano's statements were made as a POA President, Mr. <br /> 6 Serrano was not speaking as a police sergeant of the City or the Santa Ana Police <br /> 7 Department, and acknowledged that the City was not able to restrict the conduct of the <br /> 8 POA and/or its President which relate to the administration of the POA as such action <br /> 9 would be a violation of the Meyers-Milias Brown Act. (See Government Code section <br /> 10 3506.5(d).). Counsel for the City acknowledged, therefore, the City was not able to <br /> 11 direct Mr. Serrano to engage or not engage in conduct that is done in his capacity as <br /> 12 President of the POA in relation to the administration of the POA. <br /> 13 59. Evidently, the City of Santa Ana had to pay the former POA President and <br /> 14 his wife approximately $350,000.00, as Defendants had allegedly retaliated against the <br /> 15 former POA President and Defendant Valentin sexually harassed the former POA <br /> 16 President's wife. Thereafter, the former POA President, in an effort to obtain more <br /> 17 money from the City, alleged that Serrano violated the settlement agreement even <br /> 18 though Serrano was not a party to the action or the agreement. On or about October <br /> 19 26, 2020 when the City would not pay any additional money, the former POA President <br /> 20 filed a written complaint against Serrano. <br /> 21 60. It appeared that the City was not going to take action on the frivolous <br /> 22 complaint, but Defendant Valentin and possibly others, in order to further retaliate <br /> 23 against Serrano and the SAPOA, initiated the investigation nine months later. To this <br /> 24 date, Defendants have not notified Serrano of the outcome of the investigation and the <br /> 25 one year statute of limitations has expired. <br /> 26 SEXUAL HARASSMENT ALLEGATIONS <br /> 27 61. On June 16, 2021, Defendants Motsick and Carvalho scheduled a <br /> 28 meeting with Serrano without informing him of the nature of the meeting. Serrano <br /> 15 <br /> COMPLAINT <br />