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I Violation of Government Code 43500, et seq. <br /> 2 96. Plaintiffs Santa Ana Police Officers Association and Gerry Serrano for a <br /> 3 First Cause of Action against all Defendants for violations of Government Code §3500, <br /> 4 et seq., re-allege paragraphs 1-95, above, and further allege as follows: <br /> 5 97. Government Code §3502 provides, in pertinent part, public employees shall <br /> 6 have the right to form, join, and participate in the activities of employee organizations of <br /> 7 their own choosing for the purpose of representation on all matters of employer- <br /> 8 employee relations. <br /> 9 98. Government Code §3502.1 provides that "No public employee shall be <br /> 10 subject to punitive action or denied promotion, or threatened with any such treatment, <br /> 11 for the exercise of lawful action as an elected, appointed, or recognized representative <br /> 12 of any employee bargaining unit." <br /> 13 99. Government Code §3503 provides, in pertinent part, that "Recognized <br /> 14 employee organizations shall have the right to represent their members in their <br /> 15 employment relations with public agencies." <br /> 16 100. Government Code §3504 provides, in pertinent part, that the scope of <br /> 17 representation shall include all matters relating to employment conditions and <br /> 18 employer-employee relations, including, but not limited to, wages, hours, and other <br /> 19 terms and conditions of employment. <br /> 20 101. Government Code §3506 provides that "Public agencies and employee <br /> 21 organizations shall not interfere with, intimidate, restrain, coerce or discriminate against <br /> 22 public employees because of their exercise of their rights under Section 3502." <br /> 23 102. Government Code §3506.5 provides, in pertinent part, that a public agency <br /> 24 shall not do any of the following: (a) Impose or threaten to impose reprisals on <br /> 25 employees, to discriminate or threaten to discriminate against employees, or otherwise <br /> 26 to interfere with, restrain, or coerce employees because of their exercise of rights <br /> 27 guaranteed by this chapter; (b) deny to employee organizations the rights guaranteed to <br /> 28 them by this chapter; (d) dominate or interfere with the formation or administration of <br /> 23 <br /> COMPLAINT <br />