Santa Maria Firefighters IAFF Local 2020 v. Santa Maria Et Al, First Amended Complaint

Case 2:19-cv-01964-DMG-RAO Document 33 Filed 12/23/19 Page 1 of 19 Page ID #:164
1 MICHAEL A. MCGILL (SBN 231613)

mmcgill@adamsferrone.com
2 ADAMS FERRONE & FERRONE APLC
3 4333 Park Terrace Drive, Suite 200
Westlake Village, CA 91361
4 Telephone: (805) 373-5900
Facsimile: (818) 874-1382
5
6 [Counsel for Plaintiffs,
7 SANTA MARIA CITY FIREFIGHTERS UNION,
IAFF LOCAL 2020, et al.]
8
9 [See Signature Block for Additional Plaintiffs]
10
11 UNITES STATES DISTRICT COURT
12 DISTRICT OF CALIFORNIA - WESTERN DIVISION
13
SANTA MARIA CITY Case No. 2:19-cv-01964
14 FIREFIGHTERS UNION, IAFF
LOCAL 2020, JILL HOOVER, CLINT
15 MCINTOSH, ANTHONY MORALES, FIRST AMENDED COMPLAINT
ANTHONY TEVIS, and CHAD FOR DAMAGES AND
16 WENNERSTROM, INJUNCTIVE RELIEF FOR
VIOLATION OF INDIVIDUAL
17 CIVIL RIGHTS AND LIBERTIES
Plaintiffs,
18 vs.
19 CITY OF SANTA MARIA, a public DEMAND FOR JURY TRIAL
agency and/or municipal corporation;
20 LEONARD CHAMPION, individually
and as Fire Chief; JAYNE
21 ANDERSON individually and as
Director of Human Resources; RICK
22 HAYDEN, individually, and as City
Manager; and DOES 1 THROUGH 10,
23
24 Defendants.
25
26
27
28
-1-
FIRST AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE
RELIEF
1 I. INTRODUCTION
2 1. This is an action asserting personal injury claims for victims of illegal
3 retaliation suffered as a result of the Plaintiffs’ lawful expression of individual civil
4 rights, Plaintiffs’ lawful exercise of liberties of free expression, and Plaintiffs
5 lawful participation and engagement in labor, union, and labor activities.
6 II. JURISDICTION AND VENUE
7 2. Plaintiffs’ action is authorized by 42 U.S.C. § 1983, which provides
8 for redress for the deprivation under color of state law of rights secured by the
9 Constitution and the laws of the United States. Jurisdiction is conferred on this
10 Court by 28 U.S.C. § 1343(3), providing for jurisdiction in this Court of suits
11 authorized by 42 U.S.C. § 1983 to redress the deprivation under color of state law
12 of any right, privilege, or immunity secured by the Constitution of the United
13 States, and by 28 U.S.C. § 1343(4), providing for the protection of civil rights.
14 3. Federal supplemental jurisdiction over the state law claims is
15 conferred by 28 U.S.C. § 1367. This Court has authority to provide declaratory
16 and injunctive relief in this case pursuant to 28 U.S.C. §§ 2201 and 2202. Venue is
17 proper in the Central District of California because the wrongs alleged herein
18 occurred within the City of Santa Maria, within the Western Division of the
19 Central District of California.
20 III. PARTIES
21 4. Plaintiffs Jill Hoover, Clint McIntosh, Anthony Morales, Anthony
22 Tevis, and Chad Wennerstrom (hereinafter may be referred to individually as
23 “Plaintiff” or collectively as “Plaintiffs”) are, and at all relevant times unless
24 otherwise mentioned herein, were, employed by Defendant City of Santa Maria in
25 the capacities of Firefighter, Fire Engineer, or Fire Captain. Accordingly,
26 Plaintiffs are entitled to the benefits and protections afforded to them by the Fire
27 Fighter Bill of Rights Act, see CAL. GOV’T CODE, §§ 3250-3263.
28
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RELIEF
1 5. Defendant, City of Santa Maria (may be referred to hereinafter as

2 “City”), is a duly constituted municipal corporation operating under the laws of the
3 State of California, wholly situated in the County of Santa Barbara. The Santa
4 Maria Fire Department (Department) is an operating department within the City.
5 6. Defendant Leonard Champion (“Champion”) is the Fire Chief for the
6 City. As Fire Chief, Champion is a Department Head of the City and is the City’s
7 highest sworn fire and rescue official. Defendant Champion is an official policy-
8 maker for the City and Department with respect to the adverse actions taken and
9 alleged in this complaint. In doing the things alleged herein, Champion along
10 with, and in conjunction with the other Defendants is vested with policy-making
11 authority over the actions alleged in this complaint.
12 7. Defendant Jayne Anderson (“Anderson”) is the Director of Human
13 Resources for the City. In doing the things alleged herein, Anderson along with,
14 and in conjunction with the other Defendants is vested with policy-making
15 authority over the actions alleged in this complaint.
16 8. Defendant Rick Hayden (“Hayden”) was at all relevant times the City
17 Manager for the City. As the City’s lead administrator, Hayden along with, and in
18 conjunction with the other Defendants, is vested with policy-making authority over
19 the actions alleged in this complaint. In doing the things alleged herein, each
20 individual Defendant acted under the color of state law and within the course and
21 scope of his or her employment.
22 9. Defendant DOES 1 through 10 are not known or identified at this
23 time. On information and belief, Plaintiffs allege that each DOE is in some
24 manner responsible for the wrongs alleged herein, and that each such Defendant
25 advised, encouraged, participated in, ratified, directed, or conspired to do, the
26 wrongful acts alleged herein. When the true names and capacities of said
27 Defendants become known, Plaintiffs will seek relief to amend this complaint to
28 show their true identities in place of their fictitious names as DOES 1 through 10.
-3-
RELIEF
1 10. Defendants, and each of them, were the agents, employees and
2 servants of every other Defendant. Defendants acted in the course and scope of
3 said agency, service and employment at all relevant times.
4 IV. FACTS COMMON TO ALL COUNTS
5 11. Plaintiffs were hired by The City and Department. During the relevant
6 times periods, Plaintiffs were active union members of the Association. Further,
7 they comprised the Executive Board Members for the Association. They were
8 elected to these positions by the other members of Association. The Association is
9 the recognized bargaining unit by the City for the classifications of firefighters, fire
10 engineers and fire captain. The Association is charged with representing its
11 members with regard to their employment and labor matters with the City and FD.
12 12. On or about March 25, 2016, interim Fire Chief Scott Kenley
13 proposed that the captain’s exam be opened to persons outside of The Santa Maria
14 Fire Department. This had never been done by the Department. Plaintiffs openly
15 and vocally opposed the notion of going to the outside at that time on the basis that
16 as a matter of past practice, this could not be done without meeting and conferring
17 with the Association. The issue resolved itself at that time when 3 (three) internal
18 candidates successfully promoted to Fire Captain in April of 2016.
19 13. Opening up the process is a matter of public concern. Specifically,
20 opening up the process to external candidates, fails to explore options for
21 increasing the number of qualified internal candidates, and involves hiring
22 individuals who may test well but do not possess vital knowledge of the lay-out of
23 the city, the culture of the department, and the talents of existing personnel that
24 they may supervise. Further, opening up the process to external candidates exposes
25 the City and its citizens to serious damages, including but not limited lost revenue
26 as the result of the extra spending required to hire outside the Department.
27 ///
28
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RELIEF
1 14. As Executive Board members, Plaintiffs have represented numerous

2 members when they have had conflicts, issues and grievances with the City and
3 Department. Plaintiffs, as Association leaders, have consistently engaged in
4 numerous protected activities, which included, but were not limited to: (1)
5 speaking out at meetings about matters of public concern as well as matters
6 relating to the efficiency and sustainability of the City, the workforce, and the
7 Department; (2) filing, propounding, and providing assistance for, legally protected
8 actions, non-exclusively including grievances, unfair labor charges, and arbitration
9 requests; and (3) speaking to the public about matters that are unfair, unjust,
10 inequitable and illegal that relate to the competency of management and ability to
11 render proper fire and rescue services. At all times, Plaintiffs’ position and
12 participation on the Executive Board rendered their activities protected under state
13 and federal law, including, but not limited to, the California and United States
14 Constitutions.
15 15. The idea of opening the testing to outside candidates was raised again
16 on January 17, 2017, by the newly appointed permanent Chief Champion. Again,
17 Plaintiffs opposed the idea citing a well-established practice. By opening up the
18 process to external candidate, it exposes Plaintiff Association and the citizens of
19 Santa Maria to serious harm due to the lack of knowledge required for a person
20 serving in a supervisory position in the Department. A candidate from the outside
21 would be unaware of the institutional knowledge required of the position. The
22 concerns that Plaintiffs expressed were outside of their ordinary course of
23 employment.
24 ///
25
26
27
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RELIEF
1 16. The relationship between the Executive Board and Champion has
2 progressively deteriorated, as Champion has failed to honor and live up to many of
3 his promises, and has engaged in dishonest and unethical behavior, alienating most
4 of the sworn members of the Department. Champion’s leadership or lack thereof,
5 has negatively impacted the day-to-day morale of the rank and file firefighters and
6 has tarnished the reputation of the once nationally-acclaimed agency. These
7 failures came to a head when the Association opposed Champion’s decision to
8 open the testing process up to external candidates. There are legitimate concerns
9 about bringing in candidates that are not from within the system. This is not a
10 scenario where Plaintiffs were simply attempting to look out for their own
11 members; Plaintiffs were looking out for the citizens of The City. These candidates
12 would not have the requisite information to properly conduct their jobs such as
13 knowing the City, the practices of the Department, and the personnel.
14 17. On or about January 25, 2017, Plaintiffs each received an email from
15 Champion in which Champion stated that he was going to move forward with
16 opening the Captains promotional testing to outside candidates and gave the date
17 of February 22, 2017 as the date he planned to post the testing. This came after
18 numerous attempts by Plaintiffs to discuss the issue with Champion.
19 18. Plaintiffs Morales and Hoover happened to be at a conference of the
20 International Association of Firefighters (IAFF) with Chris Mahon (Mahon) a
21 representative from the California Professional Firefighters (CPF), the California
22 arm of the IAFF. CPF is a labor organization in California with over 100 fire
23 agencies in membership. They exist for the mutual benefit of their fire fighter
24 members in matters of legislation, labor relations, politics and training amongst
25 other matters. As a result of conversations with Plaintiffs, Mahon suggested that
26 they try to work with Champion, but if that failed, have CPF broadcast a “Do Not
27 Apply” notice via email alert to CPF members advising them that the matter was
28 being handled contrary to law by Champion and recommending that the CPF
-6-
RELIEF
1 members not apply for the test. In an act of solidarity and mutual support for CPF
2 members, of which Plaintiffs were and is, CPF has routinely broadcast such notices
3 to its members to keep professional fire fighters aware of the illegal actions of
4 certain administrations and agencies. These broadcasts are made to the potential
5 applicants for this position and the other professionals within CPF.
6 19. During the monthly Labor/Management meeting on February 1, 2017
7 Plaintiffs expressed opposition verbally and in writing to opening of the testing
8 process and stated their position that Champion had to meet and confer with
9 Association before moving forward. Champion, without advanced notice to
10 Plaintiffs, publicly posted the job opening on February 10, 2017, 12 (twelve) days
11 before his previously stated date. Champion was well-aware that he was required
12 to meet and confer with Plaintiffs but unilaterally made the decision to post
13 without meeting and conferring.
14 20. This action caught Plaintiffs by surprise and they turned back to CPF
15 for help. CPF then prepared the email alert and sent it out to its members on
16 February 21, 2017. The email alert was to inform potential applicants that the
17 decision to open up the testing process to the outside was not only dangerous
18 situation that the applicant would be under but also due to the fact that Champion
19 sent out the broadcast without following the proper protocol.
20 21. On or about February 27, 2017, Champion sent a memorandum to all
21 members of the Department expressing his dismay over the CPF alert, calling it
22 “disingenuous” and a discredit to the department.
23 22. On or about March 17, 2017, one day after the test (or the next day
24 that they returned to work) Champion, in an act of retaliatory behavior, sent notices
25 to individual Plaintiffs, who comprised the entirety of the Executive Board of the
26 Association, stating that they were under investigation “Regarding a publication of
27 a post discouraging external applicants from applying for employment with the
28 City at the Fire Captain rank, an action with potentially serious consequences for
-7-
RELIEF
1 the City, including but not limited to restricting the City’s ability to fill open
2 positions with the best possible candidates.” The notice further threatened that they
3 could face disciplinary action, including termination. They were also informed of
4 the interview dates. This was in clear retaliation for Plaintiffs engaging in protected
5 union activity, activity in which Plaintiffs cannot be investigated for engaging.
6 Defendants opening an investigation into Plaintiffs for clearly malicious and
7 retaliatory reasons was meant for the purpose of chilling Plaintiffs into staying
8 quiet in the future for any similar acts. Defendants were aware of the effect that
9 opening an investigation into Plaintiffs’s activities would have on Plaintiffs’
10 personnel files and ability to get a raise or promotions.
11 23. Prior to the date of the interviews, counsel for Plaintiffs sent a letter
12 placing the investigator and the City and Fire Department on notice that they were
13 violating the rights of Plaintiffs. It also stated that they were infringing on such an
14 obvious right that they would not enjoy the benefit of qualified immunity in the
15 event that the Local took legal action against them. The interviews were
16 temporarily delayed. Defendants were well-aware that they were violating
17 Plaintiff’s rights due to their response letter where counsel for the City
18 acknowledged that an employer must exercise great caution when investigating
19 matters of the exercise of speech and expression.
20 24. The interviews were set and took place on May 22, 2017. On July 6,
21 2017, Champion sent a memorandum to the executive board members informing
22 them that no charges were being sustained against them.
23 25. On or about April 9 and 10, 2018, Plaintiffs and Defendants City and
24 Champion attended a Public Employee Relations Board (PERB) hearing regarding
25 Defendants’ failure to meet and confer. It was during this hearing that Champion
26 testified under penalty of perjury that the decision to investigate Plaintiffs for their
27 constitutional rights to speak out against the unlawful practice of Champion was
28 made by himself, Hayden and Anderson.
-8-
RELIEF
1 26. The actions taken by Champion, Hayden, and Anderson are contrary
2 to how any other promotion has been taken. Theirs actions are in bad faith, they
3 are malicious and reckless. Defendants have retaliated against Plaintiffs due to
4 their protected activities, including, but not limited to, their being Executive Board
5 Members of the Association and associational activities, their political activities, as
6 well as their right to seek redress, and his right to file a grievance under the
7 grievance procedure.
8 27. In doing the things alleged to have been done here, Defendants
9 violated, including but not limited to, Plaintiffs rights under 42 U.S.C. 1983. As a
10 direct result of Plaintiffs exercising their constitutional rights to free speech and
11 participating in labor, organizational, social and political activities as a member
12 and Executive Board member of the Association, Defendants took the adverse
13 actions against them. Absent said protected speech, Plaintiffs would not have
14 suffered adverse employment actions, and would not have been injured.
15 Investigations such as the ones proposed by Champion stay in their personnel file.
16 There are additional statutory, common law, and constitutional provisions which
17 Defendants have violated, all by engaging in the aforementioned actions. These
18 additional provisions are included in this claim, whether they are expressly
19 mentioned or not.
20 28. In doing the things alleged in this complaint, Defendants acted with
21 malicious intent to violate Plaintiffs’ rights, or at least in conscious, reckless, and
22 callous disregard of Plaintiffs’ rights and to the injurious consequences likely to
23 result from a violation of said rights. General and special damages are sought
24 according to proof.
25 29. Plaintiffs claim damages from the Defendants including all damages
26 arising from the aforementioned violations is undetermined, but as will be
27 determined in Court. Plaintiffs’ damages exceed $25,000 and this matter would be
28 an unlimited filing.
-9-
RELIEF
1 V. CAUSES OF ACTION
2 COUNT ONE
3 42 U.S.C. § 1983
4 Against Fire Chief Champion
5 30. Plaintiffs hereby incorporate each and every preceding paragraph as
6 though set forth in full here.
7 31. Champion has deliberately harassed, discriminated and retaliated
8 against Plaintiffs by investigating them for no other reason other than to retaliate
9 for Plaintiffs’ Association activity.
10 32. In doing the things alleged herein, Defendants, and each of them,
11 violated the rights of Plaintiffs under the First and Fourteenth Amendments to the
12 United States Constitution to free expression and to petition the government.
13 Specifically, Defendants have taken the aforementioned action against Plaintiffs in
14 direct retaliation for, and in response to their various protected activities, some of
15 which have been described herein. There are of course additional activities which
16 have not been included in this claim. The acts and omissions of Defendants, and
17 each of them, were done by Defendants under color of state law in their capacity as
18 a municipality chartered under state law, and as policy making authorities to which
19 Defendant City delegated its governing powers in the subject matter areas in which
20 these policies were promulgated or decisions taken or customs and practices
21 followed.
22 33. These allegations, as well as any reasonable inferences from them,
23 must be taken as true, and, if they are taken as true, they clearly show that the
24 adverse actions taken against Plaintiffs were taken by individuals whose actions
25 represent official policy. Here, it is without dispute that Champion possessed the
26 requisite authority to implement the alleged adverse employment actions.
27 ///
28
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RELIEF
1 34. The various acts of intimidation, reprisal, retaliation, suppression

2 and/or restraint exercised by Defendants against Plaintiffs have created a chilling
3 effect on their legitimate, political, social and organizational speech by creating
4 fear, hesitation, hostility, and other destructive responses. It has also created a
5 chilling effect on potential members from joining the Association and the
6 Association from defending its members. By retaliating against members for
7 openly defending themselves against a policy that could potentially harm citizens,
8 it has created an atmosphere of fear surrounding union activities.
9 35. It was or should have been plainly obvious to any reasonable policy
10 making official of the City that the acts and omissions of Defendants as alleged
11 herein, taking singly or in conjunction, directly violated and continued to violate
12 Plaintiffs’ clearly established constitutional and statutory rights. In doing the
13 things alleged herein, Defendants, and each of them, violated the rights of the
14 Plaintiffs under the First and Fourteenth Amendments to the United States
15 Constitution to free expression, association and assembly. Defendants acted with
19 according to proof. Punitive damages are sought against the individual defendants,
21 COUNT TWO
22 42 U.S.C. § 1983
23 Against Rick Hayden
26 37. Hayden has deliberately harassed, discriminated and retaliated against
27 Plaintiffs by investigation them for no other reason than to retaliate for Plaintiffs’
28 Association activity.
-11-
RELIEF
5 direct retaliation for, and in response to his various protected activities, some of
12 followed.
16 represent official policy. Here, it is without dispute that Hayden possessed the
20 effect on their legitimate, political, social and organizational speech by creating
21 fear, hesitation, hostility, and other destructive responses. It has also created a
27 making official of City that the acts and omissions of Defendants as alleged herein,
28 taking singly or in conjunction, directly violated and continued to violate
-12-
RELIEF

10 COUNT THREE
11 42 U.S.C. § 1983
12 Against Jayne Anderson
15 43. Anderson has deliberately harassed, discriminated and retaliated
16 against Plaintiffs by investigation them for no other reason than to retaliate for
17 Plaintiffs’ Association activity.
22 direct retaliation for, and in response to his various protected activities, some of
28
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RELIEF

2 followed.
6 represent official policy. Here, it is without dispute that Anderson possessed the
10 effect on their legitimate, political, social and organizational speech by createing
11 fear, hesitation, hostilitity, and other destructive responses. It has also created a
17 making official of the City that the acts and omissions of Defendants as alleged
18 herein, taking singly or in conjunction, directly violated and continued to violate
28
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RELIEF
1 COUNT FOUR
2 42 U.S.C. 1983
3 Against Defendant City of Santa Maria
6 49. Under current City policy and practice, the Fire Chief is delegated the
7 final policy making authority with regard to imposing discipline.
8 50. To that end, when exercising his authority, Champion acted pursuant
9 to official policies as well as longstanding practices or customs of the City that
10 grant and delegate him authority with respect to implementing discipline against a
11 firefighter. In addition, Champion possessed final policymaking authority from the
12 City with respect to discipline and performance of officers, as when carrying out
13 these actions, acted as a final policymaker for the City. See Ninth Circuit Manual
14 of Model Civil Jury Instructions, 9.5. See also Lytle v. Carl, 382 F.3d 978, 983
15 (9th Cir. 2004) (“For a person to be a final policymaker, he or she must be in a
16 position of authority such that a final decision by that person may appropriately be
17 attributed to the [City].”). Pursuant to policy and practice, their actions are
18 properly attributable to the City.
19 51. As a direct result of the Plaintiffs exercising their constitutional rights
20 to free speech and participating in labor, organizational, social and political
21 activities as members and leaders of the Association, Defendants took the adverse
22 actions against them. Absent said protected speech, Plaintiffs would not have
23 suffered adverse employment actions, and would not have been injured.
26 effect on his legitimate political, social and organizational speech by creating fear,
27 hesitation, hostility and other destructive responses. It has also created a chilling
28 effect on potential members from joining the Association and the Association from
-15-
RELIEF
1 defending its members. By retaliating against members for openly defending

2 themselves against a policy that could potentially harm citizens, it has created an
3 atmosphere of fear surrounding union activities.
6 United States Constitution to free expression, association and assembly.
8 direct retaliation for, and in response to the various protected activities of
9 Plaintiffs.
10 54. Based upon information and belief, the acts and omissions of
11 Defendants, and each of them, were done by Defendants under color of state law
12 and as final policy making authorities to which Defendant City delegated its
13 governing powers in the subject matter areas in which these policies were
14 promulgated or decisions taken or customs and practices followed. The acts and
15 omissions described above were taken by the City’s official policy makers as
16 members charged with such responsibility.
18 making official of City that the acts and omissions of Defendants as alleged herein,
19 taking singly or in conjunction, directly violated and continued to violate
21 things alleged herein, Defendants acted with malicious intent to violate Plaintiffs’
22 rights, or at least in conscious, reckless, and callous disregard of Plaintiffs’ rights
23 and to the injurious consequences likely to result from a violation of said rights.
24 General and special damages are sought according to proof. Punitive damages are
25 sought against the individual defendants, according to proof.
26 ///
27
28
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RELIEF
1
2 VI. PRAYER
3 WHEREFORE, Plaintiffs pray:
4 1. For general, special, compensatory, statutory, exemplary and punitive
5 damages according to proof;
6 2. For costs of suit;
7 3. For attorney’s fees as permitted by law; and
8 4. For any and all other appropriate relief the Court deems necessary.
9 VII. DEMAND FOR JURY TRIAL
10 Plaintiffs hereby demand a jury trial under rule 38 of the Federal Rules of
11 Civil Procedure, and rule 38-1 of the Local Rules of the Central District of
12 California.
13 Dated: December 23, 2019 Respectfully Submitted,
14 ADAMS FERRONE & FERRONE, APLC
15
/s/ MICHAEL A. MCGILL
16 MICHAEL A. MCGILL (SBN SBN 231613)
17
[Counsel for Plaintiffs SANTA MARIA CITY
18 FIREFIGHTERS UNION, IAFF LOCAL 2020,
19 JILL HOOVER, CLINT MCINTOSH,
ANTHONY MORALES, ANTHONY TEVIS, and
20 CHAD WENNERSTROM]
21
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RELIEF
1 PROOF OF SERVICE
2
3 I am employed in the County of Los Angeles, State of California. I am over
4 the age of 18 and not a party to the within action; my business address is 4333 Park
5 Terrace Dr., Ste. 200, Westlake Village, CA 91361.
6 On Monday, December 23, 2019, I served the foregoing document described
7 as:
8 FIRST AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE
9 RELIEF FOR VIOLATION OF INDIVIDUAL CIVIL RIGHTS AND
10 LIBERTIES on all interested parties in this action on the attached service list by
11 the following transmissions.
12 X By Mail. I caused such envelope to be deposited in the mail at Westlake
13 Village, California. The envelope was mailed with postage thereon fully prepaid. I
14 am "readily familiar" with this firm's practice of collection and processing
15 correspondence for mailing. It is deposited with the U.S. Postal Service on that same
16 day in the ordinary course of business. I am aware that on motion of party served,
17 service is presumed invalid if postal cancellation date or postage meter date is more
18 than 1 day after the date of deposit for mailing in affidavit.
19 X By Email to all interested parties in this action on the attached service list.
20 EXECUTED on Monday, December 23, 2019 at Westlake Village, California.
21 I DECLARE under penalty of perjury under the laws of the State of California
22 that the above is true and correct, and that I am employed in the office of a member
23 of the bar of this Court at whose direction the service was made.
24
25
26 /s/ RENEL SALONGA
RENEL SALONGA
27
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RELIEF
1 MAILING, FACSIMILE, EMAIL AND E-FILE SERVICE LIST

2
3 Jesse J. Maddox, Esq.
jmaddox@lcwlegal.com
4 LIEBERT CASSIDY WHITMORE
5 5250 N. Palm Avenue, Suite 310
Fresno, CA 93704
6
7 Via Email and U.S. Mail
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RELIEF

Santa Maria Firefighters IAFF Local 2020 v. Santa Maria Et Al, First Amended Complaint

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Case 2:19-cv-01964-DMG-RAO Document 33 Filed 12/23/19 Page 1 of 19 Page ID #:164

1 MICHAEL A. MCGILL (SBN 231613)

1 5. Defendant, City of Santa Maria (may be referred to hereinafter as

1 14. As Executive Board members, Plaintiffs have represented numerous

1 34. The various acts of intimidation, reprisal, retaliation, suppression

1 Plaintiffs’ clearly established constitutional and statutory rights. In doing the

1 these policies were promulgated or decisions taken or customs and practices

1 defending its members. By retaliating against members for openly defending

1 MAILING, FACSIMILE, EMAIL AND E-FILE SERVICE LIST

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