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1 unsubstantiated legal claims, threats to `burn the place down' and 'make disclosures <br /> 2 that will hurt people" and asking elected officials to put pressure on the city manager. <br /> 3 Ridge and Carvahlo conspired to release confidential communications to the media in <br /> 4 violation of Penal Code §§832.5- 832.8 and/or Evidence Code §§1043-1046 and/or the <br /> 5 Brown Act. <br /> 6 71. Two days later, even though Ridge had ordered Serrano not to have <br /> 7 contact with her, she attempted to contact Serrano on his personal phone. Serrano <br /> 8 knew better and did not take the call. <br /> 9 72, On July 29, 2021, the City rejected the Government Tort Claim filed <br /> 10 related to the above issues. The City chose not to try to resolve the matter or conduct <br /> 11 investigations prior to issuing the rejection. It appears that the Defendants are intent on <br /> 12 forcing the parties to litigate the City's liability. The use of Ms. Barboza's services is just <br /> 13 to obtain statements in an effort to defend the anticipated lawsuit. <br /> 14 73. The City is believed to have closed its "sexual harassment investigation" <br /> 15 of Defendant Ridge without conducting a single interview and without questioning <br /> 16 Defendant Ridge regarding her alleged illegal and/or harassing conduct. <br /> 17 SAPOA ASSISTS MEMBERS IN FILING COMPLAINTS <br /> 18 74. On July 20, 2021, the SAPOA supported the filing of a citizen complaint <br /> 19 by one of the Association's members against Defendant Valentin alleging retaliation <br /> 20 and creating a hostile working environment for the member that was known to support <br /> 21 the SAPOA/Serrano. The Defendants assigned the investigation to an outside <br /> 22 investigator, but failed to notify the complainant of the outcome of the investigation. <br /> 23 75. On or about August 19, 2021, the SAPOA supported the filing of a citizen <br /> 24 complaint by one of the Association's members against Sgt. Oscar Lizardi for <br /> 25 allegations of engaging in intimidation and threats against a member who Lizardi <br /> 26 believed supported the SAPOA's vote of no confidence against Defendant Valentin. <br /> 27 The Defendants assigned the investigation to an outside investigator, but failed to notify <br /> 28 the complainant of the outcome of the investigation. <br /> 18 <br /> COMPLAINT <br />