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1 Defendants have not even attempted to investigate these claims. Therefore, Plaintiffs <br /> 2 have exhausted all administrative remedies related to the FFDE. <br /> 3 91. Additionally, even though Serrano had been removed from Administrative <br /> 4 Leave, the locker assigned to him by the Police Department was secured so Serrano <br /> 5 could not access it. It was visible to any person that walked into the locker room that the <br /> 6 locker was still being secured by the Department. <br /> 7 92. Plaintiffs request a jury trial on all non-mandamus relief. <br /> 8 93. Plaintiff has no plain, speedy or adequate remedy under the law. <br /> 9 Pursuant to Government Code Section 3309.5, Plaintiff need not pursue any <br /> 10 administrative remedy in order to address this problem; thus, Plaintiff is excused from <br /> 11 or has exhausted his administrative remedies. This court is given initial jurisdiction over <br /> 12 this matter pursuant to Government Code §3309.5. <br /> 13 94. To the extent facts, incidents and/or issues described above were learned <br /> 14 and/or occurred after Plaintiffs' filed their Government Tort Claim, Plaintiffs only seek <br /> 15 mandamus and/or injunctive relief to cure the violations and prevent future violations of <br /> 16 a similar nature. Once Plaintiffs has processed and/or the Defendants rejected any <br /> 17 such supplemental claim, Plaintiffs will amend this Complaint accordingly. <br /> 18 VENUE AND JURISDICTION <br /> 19 95.Venue is proper in the Superior Court of the State of California, for the County of <br /> 20 Orange in that the underlying acts, omissions, injuries and related facts and <br /> 21 circumstances giving rise to the present action occurred in the City of Santa Ana, <br /> 22 County of Orange, California. This Court has jurisdiction over the present matter <br /> 23 because, as delineated within this complaint, the nature of the claims and amount in <br /> 24 controversy meet the requirements of jurisdiction in the Superior Court. This Court is <br /> 25 empowered with initial jurisdiction to entertain suits brought pursuant to California <br /> 26 Government Code §3300, et seq., and for traditional mandamus action. <br /> 27 FIRST CAUSE OF ACTION <br /> 28 Against All Defendants <br /> 22 <br /> COMPLAINT <br />