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					,   .                  Case3:13-cv-03626-NC Document1 Filed08/05/13 Page1 of 22



               Michael E. Cardoza, Esq., (SBN 52264)
               Jacqueline C. Fagerlin, Esq. (SBN 187732)                                FILED ()}
           2
           3
               Tiffany K. O'Connor, Esq. (SBN 232507)
               THE CARDOZA LAW OFFICES, INC.
               1220 Oakland Blvd., Suite 200
               Walnut Creek, California 94596
                                                                                        AUG - 5 2013 .
                                                                                      RICHARD w. WIEKINGP
                                                                                                                    lV
                                                                                                                     I" (
           4   Telephone: (925) 274-2900                                             CLERK, u.s. DISTRICT COURT      I~
                                                                                  NORTHERN DISTRICT OF CALIFORNIA
               Facsimile: (925) 274-2910                                                     OAKLAND
           5   Electronic Mail: jfagerlin@cardolaw.com
           6   Attorneys for Plaintiff
               WILLIAM HOWARD
           7

           8                                      UNITED STATES DISTRICT COURT
           9                                     NORTHERN DISTRICT OF CALIFORNIA                                    4Df1
        u!O
          11
               WILLIAM HOWARD,
                                    Plaintiff,
                                                                      case,l3-            3626 NC
                                                                      COMPLAINT FOR DAMAGES AND
                                                                      INJUNCTIVE RELIEF
          12     vs.
                                                                      JURY TRIAL DEMANDED
          13 CONTRA COSTA COUNTY; DAVID
             LIVINGSTON; SEANFAWELL; TOWN
          14 OF DANVILLE; STEVEN SIMPKINS; and
             DOES 1 through 50, inclusive,
          15
                           Defendants.
          16
          17

          18           COMES NOW Plaintiff WILLIAM HOWARD, who complains of defendants, and each
          19   ofthem, and alleges as follows:
          20                                         JURISDICTION AND VENUE
          21           I.          The jurisdiction ofthis Court is predicated on 28 U.S.C. §§ 1331, 1343 and 1367
          22   and 42 U.S.C. § 1983.
          23           2.          Pursuant to 28 U.S.C. § 139l(b), venue is proper in the Northern District of
          24   California because a substantial part of the events or omissions giving rise to the claim occurred
          25   in this District.
          26                                                    PARTIES
          27           3.          Plaintiff William Howard (hereinafter "Plaintiff") is, and at all times mentioned in
          28   this complaint was, a resident of the town of Danville, county of Contra Costa, state of California.


               Complaint
            Case3:13-cv-03626-NC Document1 Filed08/05/13 Page2 of 22



     At all relevant times herein, Plaintiffwas an individual employed by Defendant Contra Costa
 2 County as a Level II Reserve Deputy Sheriff.
 3          4.       At all times mentioned herein, Defendants Contra Costa County (hereinafter
 4 "CCC"), Defendant Town of Danville (hereinafter "Danville") and DOES 1 through 10, were
 5 public entities, duly organized and existing under and by virtue of the laws of the State of
 6 California. Defendant CCC operates under its authority the Contra Costa County Sheriffs Office.
 7 Defendant Danville operates under its authority the Danville Police Department. Plaintiff is
 8 informed and believes that Defendant CCC provides police services to Defendant Danville.
 9          5.       Plaintiff is informed and believes and thereupon alleges, that at all times relevant
10 herein Defendants David Livingston (hereinafter "Defendant Livingston"), Sean Fawell
11   (hereinafter "Defendant Fawell"), and DOES 11 through 50, and each ofthem, were residents of
12   the State of California and were employed in the county of Contra Costa, state of California.
13          6.       Plaintiff is informed and believes and thereupon alleges, that at all times relevant
14   herein Defendant Steven Simpkins (hereinafter "Defendant Simpkins"), and DOES 11 through 50,
15   and each of them, were residents of the State of California and were employed in the county of
16   Contra Costa, state of California.
17          7.       Plaintiff is informed and believes that Defendants Livingston and Fawell, and
18   DOES 11 through 50, were the sheriff and assistant sheriff, respectively, and employees, agents,
19   servants, policy makers and representatives of Defendant CCC.
20          8.       Plaintiff is informed and believes that Defendant Livingston, as Sheriff of CCC,
21   had supervisory authority and control over Defendant Fawell and DOES 11 through 50.
22          9.       Plaintiff is informed and believes that Defendant Simpkins, and DOES 11 through
23   50, were the sheriff, and employees, agents, servants, policy makers and representatives of
24   Defendant Danville.
25          10.      Each individual defendant is sued in his individual capacity as well as official
26   capacity.
27          11.      At all times relevant herein, Defendants Livingston, Fawell, Simpkins and DOES
28   11 through 50, and each of them, were acting under color of law, to wit, under the color of the

     Complaint                                          2
            Case3:13-cv-03626-NC Document1 Filed08/05/13 Page3 of 22



 1 statutes, ordinances, regulations, policies, customs, practices and usages of Defendant CCC,
 2 Defendant Danville and the State of California. Defendants Livingston, Fawell, Simpkins and
 3 DOES 11 through 50 were acting within the course and scope of their employment with
 4 Defendant CCC and Defendant Danville, and the wrongful acts hereinafter described flow from
 5 the very exercise of their authority.
 6          12.     Each Defendant was also acting as an employee, agent and representative of
 7 each and every other defendant herein, and in doing the acts herein alleged were acting with the
 8 permission, consent, ratification, and authority of their co-defendants.
 9          13.     Plaintiff is ignorant ofthe true names and capacities of Defendants sued herein
10   as DOES 1 through 50, inclusive, and therefore sues these Defendants by such fictitious names.
11   Plaintiff is informed and believes and thereupon alleges, that each of the fictitiously named
12   Defendants is legally responsible, intentionally, negligently, or in some other actionable
13   manner, for the events and happenings hereinafter referred to, and thereby legally caused the
14   injuries, damages, and violations and/or deprivation of the rights hereinafter alleged. Plaintiff
15   will seek leave of Court to amend this complaint and state the true names and/or capacities of
16   said fictitiously named Defendants when the same have been ascertained.
17          14.     Pursuant to Government Code Section 910, Plaintiff filed a Claim for Damages
18   to Defendant CCC in proper form and within the applicable statutory period. Defendant CCC
19   denied the claim, and Plaintiff now brings the within action.
20          15.     Pursuant to Government Code Section 910, Plaintiff filed a Claim for Damages
21   to Defendant Danville in proper form and within the applicable statutory period. Defendant
22   Danville has denied the claim, and Plaintiff now brings the within action.
23                                     GENERAL ALLEGATIONS

24          16.     At all relevant times herein, Plaintiffwas a Level II Reserve Deputy with Contra
25   Costa County Sheriffs Office ("CCCSO"). CCCSO is a department of Defendant CCC and is
26   operated and controlled by Defendant CCC. As a Level II Reserve Deputy, Plaintiff could perform
27   general law enforcement assignments while under the immediate supervision of a peace officer who
28   had completed the Regular Basic Course. As a Level II Reserve Deputy Sheriff, and pursuant to

     Complaint                                        3
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 1 California Penal Code§ 830.6(a)(1), Plaintiffs authority as a peace officer "extends only for the
 2   duration of the person's specific assignment." In or about January, 2009, Plaintiff began working as
 3 a per diem deputy for Marine Patrol, a division of the CCCSO.
 4          17.      Deputy Stephen Tanabe ("Deputy Tanabe") is, and at all relevant times mentioned
 5 herein was, a resident of Alamo, California, a sworn police officer, an employee of Defendant CCC,
 6 and acting at all times herein mentioned within the course and scope of his employment, and under
 7 color of state law.
 8          18.      At all times herein mentioned, Christopher Butler ("Butler") was a resident of
 9   Concord, California. Butler was a "Private Patrol Operator" licensed by the State of California
10   Bureau of Security and Investigative Services, license number 14798. Butler operated a business
11   known as "Christopher B. Butler Investigations" doing business as "Butler and Associates Private
12   Investigations" in Walnut Creek, California. Butler was also a sworn police officer of the City of
13   Antioch Police Department.
14          19.      Despite his assignment to Marine Patrol, on or about January 14, 2011, Plaintiff was
15   assigned as the cover officer for Deputy Tanabe from 6:00p.m. to 4:00a.m. on January 15,2011 in
16   the Town of Danville. During this shift, Deputy Tanabe received numerous phone calls from
17   someone whom Deputy Tanabe identified as being his "P.I. friend." During the phone calls, Plaintiff
18   surmised that Deputy Tanabe was receiving information about a possible suspect under the influence
19   of alcohol from the "P.I. friend."
20          20.      Deputy Tanabe drove the patrol vehicle adjacent to a wine bar known as the Vine.
21   Plaintiff and Deputy Tanabe observed an individual, later identified as Mitchell Katz ("Katz"),
22   leaving the Vine in a truck. Deputy Tanabe pulled his patrol vehicle behind Katz's truck and
23   followed Katz for a short distance. At some point while driving, Katz made a right hand tum
24   without using his turn signal. Deputy Tanabe immediately conducted a traffic stop and began
25   performing a DUI investigation of Katz. Deputy Tanabe subsequently arrested Katz for driving
26   under the influence of alcohol. Deputy Tanabe processed Katz at the Danville Police Station. Katz
27   was then transported to the Martinez Detention Facility by another deputy.
28          21.      On February 16,2011, Deputy Tanabe called Plaintiff asking ifhe could visit

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 1 Plaintiff at his home. When Deputy Tanabe stopped by Plaintiffs home around 8:00p.m. that
 2 evening, Plaintiff perceived that Deputy Tanabe was in a highly disturbed and agitated state. Deputy
 3 Tanabe informed Plaintiff that Butler and the Contra Costa County Narcotics Enforcement Team
 4   Assistant Sheriff, Norman Wielsch ("Wielsch") had been arrested by the State of California
 5 Department of Justice. Deputy Tanabe told Plaintiff for the first time that his "P.I. friend" was
 6   Butler. Deputy Tanabe said that the police were going to start an investigation into Deputy Tanabe's
 7 involvement with Butler. Deputy Tanabe expected the police would search Deputy Tanabe's home.
 8 Deputy Tanabe expressed concern about an item he possessed that the police would find when they
 9   searched Deputy Tanabe's home. Deputy Tanabe asked Plaintiffifhe could leave something at
10 Plaintiffs home until things settled down.
11          22.      Deputy Tanabe went out to his vehicle, retrieved an item covered with a
12   black plastic garbage bag and asked Plaintiff to place the item in his attic. Plaintiff felt very
13   uncomfortable with what Deputy Tanabe was asking him to do, but to avoid a confrontation with
14   Deputy Tanabe while he was in his highly disturbed and agitated state, Plaintiff took the item.
15   Plaintiff also needed time to process the information Deputy Tanabe provided to Plaintiff and to
16   determine what course of action to take. Plaintiff did not look in the bag and did not know what the
17 bag contained.
18          23.      On February 17, 2011, Plaintiff decided he had to report the events around Katz's
19   arrest the night of January 14,2011 and Deputy Tanabe's request that Plaintiffleave a black plastic
20   garbage bag containing an unidentified item at Plaintiffs home until things settled down. Plaintiff
21   decided that he would report the aforementioned incidents to Lt. George Wright of Marine Patrol
22   (Plaintiffs commanding officer at the CCSCO) after the holiday weekend.
23          24.      On February 23, 2011, Plaintiff reported Deputy Tanabe's aforementioned conduct
24   to Lt. Wright. Plaintiff was not on duty nor in uniform when he made this report to Lt. Wright.
25   Plaintiff spent several hours reviewing the details of Deputy Tanabe's conduct on January 14, 2011
26   and February 16, 2011 with Lt. Wright. Lt. Wright asked Plaintiff to provide a verbal statement.
27   After Plaintiff completed his statement, Lt. Wright instructed Plaintiffto report to Assistant Sheriff
28   Pascoe at the Field Offices Bureau ("FOB") in Martinez, California. Plaintiff was further informed


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 1 that he would not be working for CCCSO that day.

 2            25.    When Plaintiff arrived at FOB, Assistant Sheriff Pascoe turned Plaintiff over to Sgt.

 3   Paul Beard and Sgt. Jason Vorhauer. Plaintiff was then interviewed again regarding Deputy

 4   Tanabe's conduct. Defendant Vorhauer stated to Plaintiff at the beginning of the interview that he
 5   was being treated as a civilian and not as an employee.

 6            26.    After the interview, Sgt. Beard and Sgt. Vorhauer followed Plaintiff to his home

 7   to collect the unidentified item in the garbage bag that Deputy Tanabe had given to Plaintiff. Sgt.

 8   Beard and Sgt. Vorhauer opened the package in Plaintiffs presence.

 9            27.    On March 4, 2011 Deputy Tanabe was arrested and his house was searched based on

10   an affidavit prepared by Sgt. Vorhauer.

11            28.    On March 9, 2011, Plaintiff was named in a news article on page one in a newspaper

12   published by the San Francisco Chronicle regarding Deputy Tanabe and the "dirty DUI's". Dirty

13   DUI's was a term used by Deputy Tanabe and Butler to describe Butler hiring co-conspirators to

14   assist in determining if a "target" male, usually the husband of his female client, would drink alcohol

15   in a quantity sufficient to exceed the legal limit to drive an automobile. Once the "target" male had

16   been observed to consume this amount of alcohol likely to exceed the legal limit to drive, Butler

17   would tip off Deputy Tanabe. Deputy Tanabe would arrest the "target" for driving under the

18   influence and Butler would compensate Deputy Tanabe. This is what occurred the night of the Katz

19   arrest. In the media reports, Plaintiff was identified as the person who reported Deputy Tanabe to

20   Defendant CCC regarding the Katz arrest. Numerous other news articles and television news

21   broadcasts regarding the dirty DUI's and identifying Plaintiff by name followed over the next several

22   weeks.

23            29.    Over the next several weeks, Plaintiffs peers continued to talk about Deputy

24   Tanabe's arrest of Katz and Plaintiff reporting Deputy Tanabe for the alleged dirty DUI's. Plaintiffs

25   peers criticized Plaintiff for trying to ruin the career of a respected and well-liked sheriff deputy.

26   Plaintiff was told he could not talk to anyone about Deputy Tanabe and the arrest of Katz, so

27   Plaintiff was not able to explain to his peers the truth about what actually happened.

28            30.    On or about April13, 2011, Plaintiff received a telephone call from Sergeant Roxane


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 1   Gruenheid of Volunteer Services at CCCSO that they had received a sealed envelope from

 2   the Law Offices of James McGrail. Plaintiff asked Sergeant Gruenheid to forward the envelope to

 3   him and told her that depending on the contents, he may need guidance with the situation. On or

 4   about April 16, 2011, Plaintiff received the envelope that Sergeant Gruenheid had forwarded.

 5   Enclosed in the envelope was a subpoena for Plaintiff to attend Katz's DMV hearing. Plaintiff

 6   emailed Sergeant Gruenheid with his concerns of having to provide a sworn statement that might

 7   adversely affect the criminal investigation surrounding Deputy Tanabe and the arrest of Katz.

 8   Sergeant Gruenheid responded that as far as she was concerned, Plaintiff was "on [his] own." On or

 9   about April 20, 2011, Plaintiff also received an email from Lieutenant Dan Hoffman advising

10   Plaintiffthat he would not be receiving legal advice from anyone in Volunteer Services. Plaintiff felt

11   isolated from CCCSO.

12          31.      On or about April 30, 2011 Plaintiff was advised by CCCSO that he had been

13   removed from the schedule for his shift that day. It was the first time that had ever happened in the

14   eighteen (18) years he had worked for CCCSO.

15          32.      On or about May 8, 2011, Plaintiffwas scheduled to work a ten (10) hour shift as

16   the cover officer for Deputy Mike Berry. Deputy Berry arrived two (2) hours late without making an

17   attempt to notify Plaintiff, Deputy Berry was very hostile towards Plaintiff and then sent Plaintiff

18   home two (2) hours early. Plaintiff continued to feel isolated and ostracized from CCC SO.

19          33.      On or about May 27, 2011, the Marine Patrol's work schedule was published for the
20   week, and for the first time since Plaintiff began working with the Marine Patrol, he had not been

21   assigned a single day of work.

22          34.      On or about June 22, 2011, Plaintiff received a phone call from the office of

23   Defendant Fawell advising Plaintiff that Defendant Fawell wanted to meet with him at 10:00 a.m.

24   Given the hostile treatment of CCC SO towards Plaintiff, Plaintiff asked what the purpose of the
25   meeting was to determine whether Plaintiff needed to have legal representation with him. Plaintiff

26   also stated he would not attend the meeting until after he had consulted with an attorney. Instead of

27   a response, Lieutenant Hoffman was immediately dispatched to Plaintiffs home in full uniform and
28   in a marked vehicle to escort Plaintiff to the meeting. When he got to Defendant Fawell's office,


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 1   Plaintiff was left standing outside the office for fifty (50) minutes before Defendant Fawell met with

 2   him. Once inside Defendant Fawell's office, Defendant Fawell advised Plaintiff that the purpose of

 3   their meeting was to address his role in the Katz arrest. Defendant Fawell continued, stating, "if you

 4   were a regular, I would have fired your ass." After several more statements similar to this,

 5   Defendant Fawell advised Plaintiff that he was no longer allowed to work in Marine Patrol and had

 6   been reassigned to "Civil". It is Plaintiffs understanding that Reserve Deputies are never assigned

 7   to the Civil division. Plaintiff is informed and believes that a reassignment to the Civil division was

 8   a demotion. Defendant Fawell then instructed Lieutenant Hoffman to take Plaintiff to "Civil" before

 9   driving him home.

10          35.      Lieutenant Hoffman instead took Plaintiff directly home, complaining that his work

11   schedule had suffered because Plaintiff had not driven himself, told Plaintiff that people like him

12   were not supposed to ask the Commander the purpose of a meeting, and stated, "I know Tanabe and

13   I like him, and I don't know you at all."

14          36.      On or about July 6, 2011, Plaintiffbegan his assignment in the Civil division, but

15   was not to report to work until July 12, 2011. On July 12, 2011, Plaintiff was advised by the new

16   Lieutenant of the Civil division, Lieutenant Christensen, that Plaintiff would not be paid per diem for

17   his services in the Civil division as he had for his services in the Marine Patrol. This was the first

18   Plaintiff was hearing of this, and at that point it became clear to Plaintiff that he had received a

19   demotion.

20          37.      On or about July 31, 2011, Plaintiff and his wife worked the raffle at the Sheriffs

21   Annual BBQ, which they had done for the fourteen (14) years prior. While Plaintiff was on the

22   stage, just prior to the raffle beginning, Defendant Fawell approached Plaintiff and accused Plaintiff

23   of having a lack of team spirit and of having a borderline disrespectful demeanor. Defendant Fawell

24   then quizzed Plaintiff about his assignment in the Civil division, and stated that he was "keeping an

25   eye on" Plaintiff.

26          3 8.     On or about August 11, 2011, Plaintiff was advised by Volunteer Services that even

27   though he had been transferred to the Civil division, Plaintiff could still volunteer at Marine Patrol

28   for special events when additional deputies were needed, but under no circumstances would he be


     Complaint                                           8
             Case3:13-cv-03626-NC Document1 Filed08/05/13 Page9 of 22



 1 permitted to receive per diem pay.
 2          39.       On or about August 17,2011, Plaintiff visited the Court Security division ofthe
 3 CCSCO to talk to a Sergeant Gregory who had told Plaintiff when he left Court Security for Marine
 4 Patrol that if he ever wanted to return, he would be welcomed back. However, when Plaintiff
 5 walked into the Court Security office, he was approached by four or five deputies who, upon finding
 6 out who Plaintiff was stated, "so you're the rat dirty DUI guy." This prompted the other deputies to
 7   say other derogatory remarks to Plaintiff. Plaintiff left because of the hostility and realized that he
 8 would not be able to return to Court Security without being harassed by other deputies.
 9          40.       Throughout the next several months, Plaintiff continued to endure a similar type of
10   harassment from other deputies within CCCSO. In the Civil division, Plaintiff was forced to work
11   alone and other employees kept their distance from Plaintiff once they learned it was Plaintiff who
12   had reported Deputy Tanabe.
13          41.       On or about April12, 2012, at the request of Plaintiff, Plaintiff met with Defendant
14   Livingston. Plaintiff complained about the harassment and retaliation he was experiencing because
15   of Plaintiff's report about Deputy Tanabe, but Defendant Livingston ignored Plaintiff's complaints.
16   Instead, Defendant Livingston told Plaintiff that he should consider himself"lucky" that he hadn't
17   been dismissed and suggested writing a letter of apology for being involved in the dirty DUI' s.
18   Defendant Livingston ended the meeting by telling Plaintiff that he was "too sensitive" and "needed
19   to grow thicker skin."
20          42.       On or about June 8, 2012, Defendant Livingston called Plaintiffto inform him that
21   he had been removed from the Sheriff's Annual BBQ team that Plaintiff had been a part of for the
22   fifteen (15) years prior.
23           43.      On or about August 13,2012, Plaintiff received a phone call from Sergeant Hebert
24   instructing Plaintiff that he needed to report to Volunteer Services. Plaintiff asked the purpose of
25   being called in and Sergeant Hebert replied that he did not know the reason but advised Plaintiff he
26   should be prepared to tum in his gear. Plaintiff told Sergeant Hebert that he would not attend such a
27   meeting without his lawyer present. Later, Captain Burton called and told Plaintiff that the purpose
28   of the meeting was to hand Plaintiff a letter. Plaintiff and Captain Burton then scheduled a time to


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 1   meet so Plaintiff's attorney could attend the meeting as well.

 2          44.      On or about August 14, 2012, Plaintiff and his attorney, Matthew Pavone, went

 3   to Volunteer Services to meet with Captain Burton. Plaintiff was handed a sealed envelope which

 4   contained a termination letter dated August 6, 2012. Captain Burton advised that there would not be

 5   a hearing regarding Plaintiff's termination, and that the decision to terminate came from the "highest

 6   level" and was "not reversible".

 7                                 FIRST CLAIM FOR RELIEF
                            VIOLATION OF CIVIL RIGHTS. 42 U.S.C. § 1983
 8                    (Against Defendants Livingston, Fawell and Does 11 through 50)

 9          45.      Plaintiff hereby realleges and incorporates each and every allegation set forth in

10   paragraphs 1 through 44 though fully set forth herein.

11          46.      In doing the acts complained of herein, Defendants Livingston, Fawell and/or Does

12   11 through 50, inclusive, acted under color of law and/or in conspiracy with public officials acting

13   under color of state law, to deprive Plaintiff of certain constitutionally protected rights, including,

14   but not limited to:
15                   a.       The right to engage in free speech guaranteed by the First Amendment to the
16                            United States Constitution. Plaintiff, acting as a whistleblower, spoke on a

17                            matter of public concern as a citizen. Plaintiff was harassed and retaliated

18                            against for exercising his free speech rights.

19                   b.       The right of due process guaranteed by the Fifth and Fourteenth

20                            Amendments to the United States Constitution and article I, section 7,
21                            subdivision (a) of the California Constitution. Plaintiff was not afforded a

22                            "name-clearing" hearing after his termination from Defendant CCC.

23                   c.       Plaintiff was deprived of rights, privileges, and immunities under the

24                            Fourteenth Amendment to the United States Constitution and the laws of
25                            the State of California, in particular, the rights to be free from arbitrary
26                            action of the government and conduct from an officer that is deliberately
27                            indifferent and shocks the conscious, under the Fourteenth Amendment to
28                            the United States Constitution. Plaintiffwas arbitrarily harassed and


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 1                            retaliated against for exercising his rights.
 2          47.      As a direct and proximate result of Defendants' actions as described herein,
 3 Plaintiff is entitled to recover all damages provided for the violation of these rights and his
 4   injuries, including but not limited to, general and special damages according to proof, costs of
 5 suit, and attorney's fees under 42 U.S.C. § 1988.
                                                                          ,
 6          48.      Plaintiff is informed and believes and thereupon alleges that the conduct of
 7 Defendants Livingston, Fawell and/or Does 11 through 50, and/or each of them, was intentional,
 8 malicious, oppressive, and/or done with a conscious or reckless disregard for the rights of
 9 Plaintiff.     Plaintiff is also entitled to recover punitive damages against Livingston, Fawell and/or
10   DOES 11 through 50.
11          WHEREFORE, Plaintiff prays for damages against Defendants Livingston, Fawell
12   and/or Does 11 through 50, and each of them, as set forth below.
13                                   SECOND CLAIM FOR RELIEF
                             VIOLATION OF CIVIL RIGHTS. 42 U.S.C. & 1983
14                            (Against Defendant CCC and Does 1 through 10)

15          49.       Plaintiff hereby realleges and incorporates each and every allegation set forth in
16   paragraphs 1 through 48 though fully set forth herein.
17          50.       Plaintiff is informed and believes and thereon alleges that at all times mentioned in
18   the complaint, Defendants Livingston and Fawell and/or Does 11 through 50, inclusive, were acting
19   under the direction and control of Defendant CCC and/or Does 1 to 10. Defendants CCC and/or
20   Does 1 to 10 were responsible for making policies for the Contra Costa County Sheriff's Office.
21   Defendants Livingston and Fawell and/or Does 11 through 50, inclusive, were acting under color of
22   law and pursuant to either official policy or the practice, custom, and usage of Defendants CCC
23   and/or Does 1 through 10.
24          51.       Plaintiff is informed and believes and thereon alleges that acting under color of law,
25   by and through its policy-makers, Defendants CCC and/or Does 1 through 10 intentionally,
26   knowingly, recklessly, or with deliberate indifference to the rights of Plaintiff, failed to instruct,
27   supervise, control and/or discipline, on a continuing basis, Defendants Livingston and Fawell and/or
28   Does 11 through 50, inclusive, in the performance of their duties to refrain from retaliating against


     Complaint                                           11
              Case3:13-cv-03626-NC Document1 Filed08/05/13 Page12 of 22



     Plaintiff for having exercised his constitutionally protected rights as alleged herein.

 2            52.    Defendants CCC and/or Does 1 through 10, had knowledge of or, had it diligently

 3   exercised its duties to instruct, supervise, control, and discipline on a continuing basis, should have

 4   had knowledge that the wrongs that were done, as heretofore alleged, or other unlawful or

 5   unconstitutional acts were going to be committed. Defendants CCC and/or Does 1 through 10, had

 6   power to prevent or aid in preventing the commission of said wrongs, could have done so, and

 7   intentionally, knowingly, or with deliberate indifference to the rights of Plaintiff failed or refused to

 8   do so.

 9            53.    Defendants CCC and/or Does 1 through 10, directly or indirectly, under color oflaw,

10   approved or ratified the unlawful, deliberate, malicious, reckless, and wanton conduct of Defendants

11   Livingston and Fawell and/or Does 11 through 50, heretofore described.

12            54.    Plaintiff is informed and believes and thereon alleges that the damages sustained as

13   alleged herein were the direct and proximate result of said customs, policies, patterns and/or

14   practices of deliberate indifference in the training, supervision and/or discipline of members of

15   Defendants CCC and/or Does 1 through 10.

16            55.    As a direct and proximate result of Defendants' actions as described herein,

17   Plaintiff is entitled to recover all damages provided for the violation of these rights and his

18   injuries, including but not limited to, general and special damages according to proof, costs of

19   suit, and attorney's fees under 42 U.S.C. § 1988.

20            WHEREFORE, Plaintiff prays for damages against Defendants CCC and/or Does 1

21   through 10, and each ofthem, as set forth below.

22
                                    THIRD CLAIM FOR RELIEF
23                        VIOLATION OF CIVIL RIGHTS. 42 U.S.C. & 1983
                     (Against Defendants Livingston, Fawell and Does 11 through 50)
24
              56.    Plaintiff hereby realleges and incorporates each and every allegation set forth in
25
     paragraphs 1 through 55 though fully set forth herein.
26
              57.    Plaintiff is informed and believes and thereon alleges that at all times mentioned in
27
     the complaint, Defendants Livingston, Fawell and/or Does 11 through 50, inclusive, were acting
28
     under color of law as sheriff and commanding officers of Defendant CCC and/or Does 1 to 10,

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 1 respectively.

 2           58.     Plaintiff is informed and believes and thereon alleges that Defendants Livingston,
 3   Fawell and/or Does 11 to 50 were responsible for making and implementing policies, practice,
 4   custom and usage for the Contra Costa County Sheriffs Office. Implementation includes, but is not
 5   limited to, training, instruction, supervision, and discipline.

 6           59.     Plaintiff is informed and believes and thereon alleges that acting under color oflaw,

 7   by and through its policy-makers, Defendants Livingston, Fawell and/or Does 11 to 50 intentionally,

 8   knowingly, recklessly, or with deliberate indifference to the rights of Plaintiff, failed to instruct,

 9   supervise, control and/or discipline, on a continuing basis, employees and agents of the Contra Costa

10   Sheriffs Department in the performance of their duties to refrain from retaliating against Plaintiff for

11   having exercised his constitutionally protected rights as alleged herein.

12           60.     Defendants Livingston, Fawell and/or Does 11 to 50, had knowledge of or, had they
13   diligently exercised its duties to instruct, supervise, control, and discipline on a continuing basis,

14   should have had knowledge that the wrongs that were done, as heretofore alleged, or other unlawful

15   or unconstitutional acts were going to be committed. Defendants Livingston, Fawell and/or Does 11

16   to 50, had power to prevent or aid in preventing the commission of said wrongs, could have done so,

17   and intentionally, knowingly, or with deliberate indifference to the rights of Plaintiff failed or refused

18   to do so.

19           61.     Defendants Livingston, Fawell and/or Does 11 to 50, directly or indirectly, under

20   color of law, approved or ratified the unlawful, deliberate, malicious, reckless, and wanton conduct
21   of agents and employees ofthe Contra Costa County Sheriffs Department, heretofore described.

22           62.     Plaintiff is informed and believes and thereon alleges that the damages sustained as

23   alleged herein were the direct and proximate result of said customs, policies, patterns and/or

24   practices of deliberate indifference in the training, supervision and/or discipline of members of

25   Defendants CCC and/or Does 1 through 10.

26           63.     As a direct and proximate result of Defendants' actions as described herein,

27   Plaintiff is entitled to recover all damages provided for the violation of these rights and his

28   injuries, including but not limited to, general and special damages according to proof, costs of


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           Case3:13-cv-03626-NC Document1 Filed08/05/13 Page14 of 22



 1 suit, and attorney's fees under 42 U.S.C. § 1988. P1aintiffis also entitled to recover punitive
 2   damages against Livingston, Fawell and/or DOES 11 through 50.
 3          WHEREFORE, P1aintiffprays for damages against Defendants Livingston, Fawell
 4   and/or Does 11 through 50, and each of them, as set forth below.
 5                                   FOURTH CLAIM FOR RELIEF
                                            Violation of Statute
 6                                 California Labor Code Section 1102.5
                                 (Against Defendants CCC and Does 1 to 50)
 7

 8          64.      Plaintiff hereby realleges and incorporates herein by reference each and every
 9   allegation contained in paragraphs 1 through 63 of this complaint with the same force and effect as if
10   plead at length herein.
11          65.      California Labor Code section 1102.5(b) provides that: "An employer may not
12   retaliate against an employee for disclosing information to a government or law enforcement agency,

13   where the employee has reasonable cause to believe that the information discloses a violation of state
14   or federal statute, or a violation or noncompliance with a state or federal rule or regulation."
15          66.      Plaintiff disclosed to Defendant CCC details to the Katz arrest, Deputy Tanabe's
16   involvement in the Katz arrest and Deputy Tanabe's statements to Plaintiff and Deputy Tanabe's
17   conduct on February 16, 2011 as alleged herein.
18          67.      After Plaintiff reported the unethical and unlawful conduct of Deputy Tanabe,
19   Plaintiff was subjected to ongoing and continual retaliation, including, but not limited to: verbal
20   abuse, intimidation, threats and ostracism amounting to harassment; failure to redress the harassment

21   Plaintiff was subjected to by law enforcement for reporting Deputy Tanabe; undue scrutiny of

22   Plaintiff's work performance; Defendants' demotion of Plaintiff; and Defendants' termination of
23   Plaintiff's employment.
24          68.      Plaintiffs reporting Deputy Tanabe's unethical and unlawful conduct to law
25   enforcement was the motivating reason for the retaliatory conduct by Defendants towards Plaintiff.
26          69.      As a direct and proximate result of the foregoing conduct, Plaintiff suffered the
27   loss of wages, salary, benefits and additional amounts of money Plaintiffwould have recovered if
28   Defendants had not terminated Plaintiffs employment. As a result of such conduct, Plaintiff has


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              Case3:13-cv-03626-NC Document1 Filed08/05/13 Page15 of 22



     suffered damages in an amount according to proof.
 2            70.    As a further direct and proximate result of the foregoing conduct, Plaintiff

 3   suffered the loss of employment-related experience and opportunities, in an amount according to
 4   proof.

 5            71.    As a further direct and proximate result of the foregoing conduct, Plaintiff has

 6   suffered humiliation, mental anguish, outrage, emotional and physical distress, and has been injured

 7   in mind and body, in that he also suffered severe trauma to his nervous system, a loss of sleep, and
 8   problems with concentration, in an amount according to proof.

 9            72.    As a further direct and proximate result ofthe foregoing conduct, Plaintiff has

10   incurred and will continue to incur attorneys' fees according to proof.

11            WHEREFORE, Plaintiff prays for damages against Defendants, and each of them, as set

12   forth below.

13                                 FIFTH CLAIM FOR RELIEF
                    NEGLIGENT HIRING, RETENTION, SUPERVISION, TRAINING
14                         (Against All Defendants and Does 1 through 50)

15            73.    Plaintiff hereby realleges and incorporates each and every allegation set forth in

16   paragraphs 1 through 72 though fully set forth herein.

17            74.    Plaintiff is informed and believes, and thereupon alleges, that Defendants and/or
18   Does 1 through 50, and each ofthem, owed the public in general, and Plaintiff in particular, a
19   duty to use reasonable and due care in carefully selecting, retaining, and supervising their agents

20   and/or servants and/or employees, including Deputy Tanabe.

21            75.    Plaintiff is informed and believes, and thereupon alleges, that prior to the events

22   described herein above, Defendants and/or Does 1 through 50, and each of them, had actual

23   and/or constructive notice of the propensities of Deputy Tanabe to commit the above described

24   acts and to abuse his position and authority, and failed to take reasonable steps to prevent same,

25   in complete disregard of the rights of the public in general and of Plaintiff in particular.

26            76.    Plaintiff is further informed and believes, and thereupon alleges, that Defendants

27   and/or Does 1 through 50, and each of them, had a duty to supervise their staff, agents, and
28   employees, including Deputy Tanabe, because it placed them in a unique position of trust,


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            Case3:13-cv-03626-NC Document1 Filed08/05/13 Page16 of 22



 1 confidence, and authority, under which the public in general, and Plaintiff in particular, should
 2 suppose themselves to be safe from witnessing the crime of a police deputy and not suffering
 3 harassment and retaliation for witnessing and reporting said crime to law enforcement.
 4          77.     Plaintiff is further informed and believes, and thereupon alleges, that Defendants
 5 and/or Does 11 through 50, owed Plaintiff a duty to continuously review and evaluate the
 6 competency and fitness of their agents and/or servants and/or employees, and to insure that their
 7 agents and/or servants and/or employees are fit and competent for the tasks for which they were
 8 hired.
 9          78.     Plaintiff is informed and believes, and thereupon alleges, that by hiring and
10   employing Deputy Tanabe to a position of trust and special authority with the public,
11   Defendants and/or Does 1 through 50, and each of them, held Deputy Tanabe out to the general
12 public in general and to Plaintiff in particular, as competent and trustworthy.
13          79.     Plaintiff is informed and believes, and thereupon alleges, that Defendants and/or
14   Does 1 through 50, and each of them, so negligently and/or carelessly, and/or recklessly, and/or
15   in any other actionable manner, failed to properly ensure the character, quality, ability, fitness
16   and competence of their servants, agents, and employees, including Deputy Tanabe.
17          80.     Plaintiff is further informed and believes, and thereupon alleges, that Defendants
18   and/or Does 1 through 50, and each ofthem, failed to monitor and supervise their agents,
19   servants, and employees, including Deputy Tanabe and/or Defendant Does 11 through 50, in
20   order to reasonably insure that the public in general, and Plaintiff in particular, would be
21   protected from wrongful conduct.
22          81.     Defendants and/or Does 1 through 50, and each of them, negligently and
23   carelessly hired, employed, retained, trained, supervised, assigned, controlled, and negligently
24   and carelessly failed to adequately discipline Deputy Tanabe, even though Defendants and/or
25   Does 1 through 50, and each ofthem, knew, or in the exercise of reasonable diligence should
26   have known, that Deputy Tanabe had a propensity for committing crimes and were otherwise
27   unfit to be given the responsibilities of deputy sheriffs and/or police officers. Nevertheless,
28   Defendants and/or Does 1 through 50, and each of them, negligently, carelessly, recklessly,


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           Case3:13-cv-03626-NC Document1 Filed08/05/13 Page17 of 22



 1   and/or with a reckless disregard for the public safety, including Plaintiff, employed and

 2   supervised Deputy Tanabe and/or Defendant Does 11 through 50, and assigned them to duties

 3   which enabled each of them to commit crimes, proximately causing severe injuries to Plaintiff.

 4          82.      As a direct and proximate result of the above described conduct, Plaintiff

 5   sustained injuries and damages alleged herein.

 6          WHEREFORE, Plaintiff prays for damages against Defendants and/or Does 1 through

 7   50, and each of them, as set forth below.

 8                                   SIXTH CLAIM FOR RELIEF
                  VIOLATION OF CIVIL RIGHTS. CALIFORNIA CIVIL CODE & 52.1
 9                 (Against Defendants CCC, Livingston, Fawell and Does 1 through 50)

10          83.      Plaintiff hereby realleges and incorporates each and every allegation set forth in

11   paragraphs 1 through 82 though fully set forth herein.

12          84.      As alleged above in this complaint above, Defendants retaliated against Plaintiff

13   for reporting the unethical and unlawful conduct of Deputy Tanabe to law enforcement.

14          85.      In doing the acts and/or omissions as alleged heretofore in this complaint, in

15   violation of California Civil Code section 52.1, Defendants CCC, Livingston, Fawell and Does

16   1 through 50 subjected Plaintiffto the violation ofhis rights under the United States and/or

17   California Constitutions, including, but not limited to:

18                   a.      The right to engage in free speech guaranteed by the First Amendment to the

19                           United States Constitution. Plaintiff, acting as a whistleblower, spoke on a

20                           matter of public concern as a citizen. Plaintiff was harassed and retaliated

21                           against for exercising his free speech rights.

22                   b.      The right of due process guaranteed by the Fifth and Fourteenth

23                           Amendments to the United States Constitution and article I, section 7,

24                           subdivision (a) ofthe California Constitution. Plaintiff was not afforded a

25                           "name-clearing" hearing after his termination from Defendant CCC.

26                   c.      Plaintiff was deprived of rights, privileges, and immunities under the

27                           Fourteenth Amendment to the United States Constitution and the laws of

28                           the State of California, in particular, the rights to be free from arbitrary


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          Case3:13-cv-03626-NC Document1 Filed08/05/13 Page18 of 22



 1                           action of the government and conduct from an officer that is deliberately
 2                           indifferent and shocks the conscious, under the Fourteenth Amendment to
 3                           the United States Constitution. Plaintiff was arbitrarily harassed and
 4                           retaliated against for exercising his rights.
 5                  d.       The rights guaranteed by California Labor Code section 1102.5 to be free
 6                           from retaliation.
 7          86.     The retaliatory acts of Defendants CCC, Livingston, Fawell and Does 1 through
 8   50 described herein, include but are not limited to, threats, coercion, ostracism, denial of
 9   employment opportunities, denial of official information, undue scrutiny of work performance,
10   denial of continued employment, denial of a retaliation free work environment, and knowingly

11   making false, misleading or malicious statements which were reasonably calculated to harm or
12   destroy the reputation, authority or official standing ofPlaintiff, culminating in the termination
13   of Plaintiff's employment.
14          87.     The conduct of Defendants Livingston, Fawell and Does 11 through 50 described
15   above was done within the course and scope oftheir employment, agency and/or service with
16   Defendant CCC and/or Does 1 through 10, and under color of their authority, and Defendant

17   CCC and/or Does 1 through 10 are, therefore, vicariously liable for same under Government
18   Code§§ 815.2 and 820.
19          88.     As a result of said Defendants' violation of Plaintiff's rights, Plaintiff incurred
20   damages and continues to incur damages, as alleged in this complaint. As a proximate result of
21   the wrongful acts of Defendants, in addition, Plaintiff is entitled to recover a statutory civil

22   penalty of $25,000 against each Defendant. Plaintiff also seeks an award of reasonable

23   attorney's fees as determined by the Court.
24          89.     The aforementioned acts of Defendants Livingston, Fawell and/or Does 11
25   through 50 were done by them knowingly, intentionally, and maliciously, for the purpose of
26   harassment, oppression, and inflicting injury upon Plaintiff, and in reckless, wanton, and callous

27   disregard of Plaintiff's safety, security, and Civil Rights. By reason thereof, Plaintiff claims
28   exemplary and punitive damages from Defendants Livingston, Fawell, and Does 11 through 50


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          Case3:13-cv-03626-NC Document1 Filed08/05/13 Page19 of 22



 1   in an amount according to proof at trial.

 2          WHEREFORE, Plaintiff prays for damages against Defendants, and each of them, as set

 3   forth below.

 4                                 SEVENTH CLAIM FOR RELIEF
                    NEGLIGENT HIRING, RETENTION, SUPERVISION, TRAINING
 5                    (Against Defendants CCC, Livingston and Does 1 through SO)
 6          90.      Plaintiffhereby realleges and incorporates each and every allegation set forth in

 7   paragraphs 1 through 89 though fully set forth herein.
 8          91.      Defendants CCC, Livingston, and/or Does 1 through 50, and each of them,

 9   negligently and carelessly hired, employed, retained, trained, supervised, assigned, controlled,

10   and negligently and carelessly failed to adequately discipline Defendants Fawell and/or Does 11

11   through 50, even though Defendants CCC, Livingston and/or Does 1 through 50, and each of

12   them, knew, or in the exercise of reasonable diligence should have known, that Defendants

13   Fawell and/or Does 11 through 50 had a propensity for harassing and retaliating against persons

14   who report crimes of other law enforcement officers and were unfit to be given the

15   responsibilities of deputy sheriffs and/or police officers. Nevertheless, Defendants CCC,

16   Livingston and/or Does 1 through 50, and each ofthem, negligently, carelessly, recklessly,

17   and/or with a reckless disregard employed and supervised Defendants Fawell and/or Does 11

18   through 50, and assigned them to duties which enabled each of them to harass and retaliate

19   against persons who report crimes of other law enforcement officers, proximately causing

20   severe injuries to Plaintiff.
21          92.      On or about April 12, 2012, at the request of Plaintiff, Plaintiff met with Defendant

22   Livingston. Plaintiff complained about the harassment and retaliation he was experiencing because

23   of Plaintiffs report about Deputy Tanabe, but Defendant Livingston ignored Plaintiffs complaints.

24   Instead, Defendant Livingston told Plaintiff that he should consider himself"lucky" that he hadn't

25   been dismissed and suggested writing a letter of apology for being involved in the dirty DUI's.

26   Defendant Livingston ended the meeting by telling Plaintiff that he was "too sensitive" and "needed

27   to grow thicker skin."
28          93.      By the actions and/or inactions described herein, Defendants Livingston and/or


     Complaint                                         19
          Case3:13-cv-03626-NC Document1 Filed08/05/13 Page20 of 22



 1 Does 11 through 50, negligently, carelessly, recklessly, intentionally, and/or in any other
 2 actionable manner, failed to stop or prevent the harassment and retaliation of Plaintiff.
 3          94.     The conduct of Defendants Livingston, and/or Does 11 through 50
 4   described herein above was done within the course and scope of their employment, agency,
 5 and/or service with Defendants CCC and/or Does 1 through 10, and under color of their
 6 authority, and Defendants CCC and/or Does 1 through 10, are, therefore, vicariously liable for
 7 same under Government Code §§ 815.2 and 820.
 8          95.     As a direct and proximate result of the above described conduct, Plaintiff
 9 sustained injuries and damages alleged herein.
10          WHEREFORE, Plaintiff prays for damages against Defendants CCC, Livingston and
11   Does 1 through 50, and each ofthem, as set forth below.
12                                 EIGHTH CLAIM FOR RELIEF
                     INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
13                   (Against Defendants CCC, Livingston, Fawell and Does 1 to 50)
14          96.     Plaintiff hereby realleges and incorporates each and every allegation set forth in
15   paragraphs 1 through 95 though fully set forth herein.
16          97.     Plaintiff is informed and believes, and thereupon alleges, that the conduct
17   described herein was outrageous, and done with the intent of causing, or with reckless disregard
18   to the probability of causing, severe emotional distress, and did actually cause Plaintiff to suffer
19   humiliation, mental anguish, and emotional and physical distress.
20          98.     Plaintiff alleges that by doing the acts described herein above, Defendants
21   misused and took advantage of their authority. Plaintiff further alleges that said Defendants
22   were only able to violate Plaintiffs rights, harass, demote and terminate Plaintiff, due to the
23   authority of the positions they held.
24          99.     The conduct of Defendants Livingston, Fawell, and/or Does 11 through 50
25   described above was done within the course and scope oftheir employment, agency and/or
26   service with Defendant CCC and/or Does 1 through 10, and under color of their authority, and
27   Defendant CCC and/or Does 1 through 10 are, therefore, vicariously liable for same under
28   Government Code§§ 815.2 and 820.


     Complaint                                        20
          Case3:13-cv-03626-NC Document1 Filed08/05/13 Page21 of 22



 1          100.    As a proximate result of the afore-described acts of Defendants, Plaintiff has
 2 suffered humiliation, mental anguish, and emotional and physical distress, and has been injured
 3 in mind and body, from the time of the incident to the present, and into the foreseeable future,
 4 by, but not limited to, experiencing and suffering from the following: anguish, depression,
 5 humiliation, nervousness, grief, anxiety, worry and shock from Defendants' conduct in an amount to
 6 be proven at trial.
 7          101.    As a further proximate result of the acts alleged above, Plaintiff was required to
 8 and did employ physicians and/or psychologists to examine, treat, and care for Plaintiff, and
 9 incurred additional medical expenses for medical bills and other incidental expenses. Plaintiff
10 is informed and believes that he will incur additional medical expenses, the exact amount of
11   which is currently unknown.
12          102.    The aforementioned acts of Defendants were done by them knowingly,
13   intentionally, and maliciously, for the purpose of harassment, oppression, and inflicting mental
14   suffering upon Plaintiff, and in reckless, wanton, and callous disregard of Plaintiffs rights. By
15   reason thereof, Plaintiff claims exemplary and punitive damages from said Defendants in an
16   amount according to proof at trial.
17          103.    As a direct result of the wrongful conduct described herein, Plaintiff was hurt
18   and injured in his health, strength, and activity, sustaining, among other injuries, injury to his
19   body and person, shock, and injury to his nervous system, all of which injuries have caused and
20   continue to cause Plaintiff great mental, physical, and nervous pain and suffering. As a result of
21   such injuries, Plaintiff has suffered general damages in an amount according to proof.
22          WHEREFORE, Plaintiff prays for damages against Defendants CCC, Livingston, Fawell
23   and/or Does 1 through 50, and each of them, as set forth below.
24                                    DEMAND FOR JURY TRIAL
25          104.    Plaintiffs hereby demand trial of this matter by jury.
26                                                PRAYER
27          WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, as
28   follows:


     Complaint                                        21
         Case3:13-cv-03626-NC Document1 Filed08/05/13 Page22 of 22



 1         1.      For general damages against all Defendants according to proof;

 2         2.      For special damages against all Defendants according to proof;

 3         3.      For punitive and exemplary damages against Defendants CCC, Livingston,

 4                 Fawell and Does 1 through 50 according to proof;

 5         4.      For interest at the legal rate on all sums due;

 6         5.      For reasonable attorney's fees as allowed by law and according to proof;

 7         6.      For costs of suit and expert fees pursuant to applicable statutes;

 8         7.      For injunctive relief ordering reinstatement Plaintiffs employment with Contra

 9                 Costa County Sheriffs Office.

10         8.      For such other and further relief as the court deems just and proper.

11

12   Dated: August 5, 2013                               THE CARDOZA LAW OFFICES, INC.

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