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I Barboza & Associates to assist Motsick in conducting a personnel investigation into <br /> 2 Serrano's possible allegations of harassment even though Serrano had not made any <br /> 3 such allegations. However, when Plaintiffs tried to determine who retained Barboza, <br /> 4 and whether she was working independently or as an agent/attorney for the City, she <br /> 5 refused to answer. Plaintiffs made the same inquiry of Defendant Motsick on July 21st, <br /> 6 but never received a response. <br /> 7 68. It was later confirmed that Barboza and Associates was hired to provide <br /> 8 legal advice to the City regarding the investigations thus creating an attorney-client <br /> 9 relationship and a duty of Barboza and Associates to find in a manner to protect their <br /> 10 clients. The City specifically prohibited the firm to render any determination about <br /> 11 unlawful discrimination, harassment, violation of public policy or any other violations of <br /> 12 law or statute. Therefore, there was no reason for Serrano to participate in <br /> 13 investigations that could not result in a legal determination. <br /> 14 69. On or about July 19, 2021, Defendant Ridge, trying to minimize her <br /> 15 misconduct and redirect attention from the allegations of misconduct against her, sent a <br /> 16 letter to the Mayor and City Council falsely claiming that all complaints and tort claims <br /> 17 coming from the SAPOA and its members were singularly focused on Serrano's <br /> 18 pension issues. In the letter to the Mayor and City Council Ridge revealed confidential <br /> 19 personnel file information of Serrano in violation of state law. Ridge also tried to defame <br /> 20 Serrano in order to diminish his credibility if he was to come forward with allegations of <br /> 21 sexual harassment. <br /> 22 70. It became clear that Ridge's letter dated July 19, 2021, was meant to <br /> 23 tarnish Serrano and the SAPOA and to be produced to mass audiences. In fact, on <br /> 24 August 3, 2021, the Voice of OC contacted Serrano and advised him that it had been <br /> 25 given copies of the letter and the disciplinary letter which outline allegations against him <br /> 26 by the City Manager and City Attorney. According to the records they were provided the <br /> 27 Voice of OC indicated that both Kristine Ridge and Sonia Carvalho claimed Serrano <br /> 28 had caused harm to the city through his pursuit of higher compensation including filing <br /> 17 <br /> COMPLAINT <br />