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1 appeared with legal counsel. After arriving Serrano was informed that Defendants <br /> 2 Motsick and Carvalho were conducting "fact-finding" regarding allegations they had <br /> 3 been made aware of by a third party. The allegation was that Defendant Ridge had <br /> 4 sexually harassed Serrano. Being caught off guard, Serrano, on advice of counsel, did <br /> 5 not make any statement. It was clear at that point that the City was not protecting <br /> 6 Serrano from retaliation by the other Defendants. <br /> 7 62. Even though Serrano had not filed a complaint against Defendant Ridge, <br /> 8 Defendants feared that Serrano had disclosed or might disclose information of unlawful <br /> 9 activities by Defendant Ridge. <br /> 10 63. As discussed below, it was later learned that approximately a month <br /> 11 earlier Ridge "self-reported" the harassment allegations to Defendant Carvalho and her <br /> 12 subordinate Defendant Motsick. In a letter to the City Council Ridge was careful in her <br /> 13 assertion, making allegations that Serrano had been untruthful and interfered in <br /> 14 investigations, but not specifically denying allegations that she sexual harassed <br /> 15 Serrano. In that same letter to the City Council Ridge violated state law by disclosing <br /> 16 closed session communications with the Council as well as disclosing confidential <br /> 17 personnel information about a peace officer to wit, Serrano. <br /> 18 64. Ridge's disclosures to the City Council reveal that Carvahlo and Motsick <br /> 19 were not simply conducting a fact finding investigation, but were investigating Ridge's <br /> 20 allegations against Serrano who should have been afforded his rights under the Peace <br /> 21 Officers Procedural Bill of Rights. <br /> 22 65. On July 7, 2021, Defendant Ridge, fearing the Serrano would report her <br /> 23 unlawful activities, directed Serrano to refrain from sending any e-mail communications <br /> 24 to her. In essence, Defendant Ridge gave direct orders to the President of the SAPOA <br /> 25 not to contact elected officials or herself with any issues or complaint. <br /> 26 66. On July 9, 2021, Plaintiff filed a Notice of Claim (Gov't Code §910, 910.4) <br /> 27 with Defendants. <br /> 28 67. On or about July 16, 2021, the City of Santa Ana hired the law firm of <br /> 16 <br /> COMPLAINT <br />