CLAIM AGAINST THE CITY OF REDLANDS File City of Redlands City Clerk’s Office 35 Cajon Street, Suite 4 P.O. Box 3005 Redlands, CA 92373 DO NOT WRITE IN THIS SPACE [READ THE CLAIM FORM BEFORE BEGINNING. ALL THE INFORMATION YOU PROMIDE SHOULD BE AS COMPLETE AS POSSIBLE. PLEASE TYPE OR PRINT (CLEARLY. YOU MUST FILE YOUR GLAM BY MAIL OR IN PERSON AT THE CITY CLERK'S OFFICE, CLAMS SUBMITTED BY FACSIMILE OR EMALL WILL NOT BE [ACOEPTED. THE CLAM FORM MUST BE SIGNED AND DATED. ATTACH ADDITIONAL SHEETS IF NECESSARY. Geneva Holzer ‘Name of Gaimant Feme Taeprone Nambar c/o 1325 Spruce St., Suite 200 ‘arose ‘Wea Teiephone Naribar Riverside, CA 92507 ‘iy, State, Zp Code ‘ephane Number Address to Which Caimant Wants Notices Sent Wagner Zemmit is LLP. 325 Spruce St., Suits Tame and Firm/Business Name across (951) 686-4800 Riverside, CA 92507 ‘aiepnone Number iy, state, 2 Code When did damage or injury occur? Date_2018- continuous and on going Time Where dia damage or Injury occur? Describe uly. Where appropriate, give street names and addresses and measurements from landmarks. jee Attachment It known, provide names of any Cty employees invoved in the damage orinjury, See Attachment Deseribe in detail how the damage or injury occurred, See Attachment Page 1 of 2Deserive in detail what damage or injury you claim resutod. See Attachment property was damaged, are you th legal owner of the propery?_ See Attachment. \What particular Act or Omission do you claim caused the damage or injuy’?_See Attachment. Was the incident that reuited in damage or injury investigated by law enforcement?___Ifyes, what agency? See Attachment Report ‘Amount claimes for injury, damage, or loss to date (required for ciaims under $10,000); Estimated amount of future injury, damage, or loss (required for caims under $10,000): ‘Total amount of claim (required for claims under $10,000}. S. bamages are between $10,000 and $25,000 (Damages exceed $25,000 ‘Basis for computation of amount ciaimed, or attach copies of al bis, woices, and estimates (required for ciaims under $10,000) (For property damage, to help the City evaluate your caim, please submit two estimates or one paid repair bil for each item): ee Attachment Provide other information that you believe should be considered in reviewing your claim (attach additional sheets if necessa). See Attachment ‘Witnesses to the incident that resulted in the damage or injury: See Attachment Name Adress, Telephone Name Adress, Telephone Name, Address, Telephone “Treating doctors and hospitals: See Attachment — oat ese see reoprone — osteo reatment patos reestoe _ oor oreo sees i ‘Westone one Dennis E. Wagner, Esq. notes WAGNER ZEMMING CHRISTENSEN, LLP Siclon 720 me Paral ace proces: “En geson who, wh ante Gove. ert sound payman 16 tp He Soto ot. ‘Sere wergorveng tobd arose authors alow oy te sara gna an ale! faunlen Sat, ero oscar aGOVERNMENTAL TORT CLAIM AND FEHA CLAIM I was hired on August 13, 2018, as a forensic specialist with the City of Redlands. I had previously worked for the City of Upland and left that job to further my career. immediately noticed tension from my co-workers, Eloise Tankersley, who was a Forensic Specialist; and Julie Salcido, who was a CSO for property and evidence. The tensions between Eloise Tankersley and Julie Salcido toward myself grew into a negative and hostile work environment throughout time. These employees were trying to set me up as an incompetent employee and tried to sabotage me with the department and with the SBSD crime lab, Julie, who oversaw property and evidence, would scrutinize my work as a forensic specialist with what | was collecting and processing. | did not realize why they did not like me but later found out and heard about the rampant sexual harassment and sexual favoritism that existed within the PD. I believe they may have felt I was a threat to their preferential treatment. Julie got a high-ranking officer that she was providing sexual favors to help her in harassing me. My chain of authority was Sgt. Alexander, and then above him was Lieutenant Reiss. Julie acting with the blessing of Lt. Reiss's authority set up a weekly meeting to discuss what | should be collecting in my cases. These meetings would include only Julie, Eloise, and Lt. Reiss to go over my case work and items I collected. This never happened when I was doing my initial training and only happened after I was off training and Julie perceived me asa threat. These meetings were unheard of within other law enforcement agencies and had never happened before at the Redlands Police Department. Throughout the duration of this time, | would frequently express my concerns to Sergeant Alexander and Lt. Reiss of the negative and hostile encounters I would have with these women. Lt. Reiss and Sgt. Alexander would do nothing to resolve the issues I was having and instead I was forced to work in this hostile environment. In February 2019 Julie Salcido’s title of CSO was changed to Property and Evidence Technician. I believe she also received additional money as a result. This Property and Evidence Technician position was not advertised or “flown” with an opportunity to compete for the position, but it was given directly to Julie. It was believed Julie was offered this position for providing sexual favors to Lt. Reiss. On April 22, 2019, during a weekly meeting before it started at 14:00 hours I was being harassed by Tankersley and Julie Salcido. The harassment had been ongoing for so long that I filed a hostile work environment complaint that day. I went to Sergeant Alexander's office in tears and felt totally defeated but Sergeant Alexander was not in his office Sergeant Alexander's office is next to Lt. Reiss’s office, and it was not uncommon for Sgt. ‘Alexander to be in Reiss’ office, so I looked in Reiss’s office to see that only Lt. Reiss was in there. I expressed to Lt. Reiss that I could no longer deal or work in this hostile work environment, that no one deserves this terrible treatment from anyone. Unfortunately, due to Lt. Reiss providing Julie special treatment for sexual favors Julie was allowed to further harass me by having these weekly meetings with Reiss and Julie to go over my work load. In these weekly meetings, I felt uncomfortable and felt belittled and humiliated in having to defend my work as Julie or Eloise would say things that were completely untrue about mywork. also had to witness the sexual touching, ing between Julie and Lt. Reiss, including In October of 2019 Eloise Tankersley was terminated from her position as a Senior Forensic Specialist due to the hostile work environment she created for me. My hostile work environment claim was investigated by IA Sgt. Povero. In October 2019, Lt. Reiss was promoted by Chief Catren to Deputy Chief. Julie Salcido was notified by Internal Affairs that she could be disciplined for harassing me. Julie went to Lt. Reiss because she was worried about being disciplined. Reiss told her not to worry, that he would assign one of his friends Sergeant Valenzuela to oversee the discipline and Reiss would have Valenzuela take care of Julie. Come to find out later per a sexual harassment lawsuit Julie filed, they allegedly performed a sexual act that happened ona chair | later discovered semen on. Through the chain of command my discovery of evidence of a sexual assault was covered up and ordered to be destroyed by Deputy Chief Reiss then carried out by Sgt. Alexander and Commander Crane. This evidence | located would have ended my ongoing sexual harassment in the department but instead the corruption and cover up by these police actors allowed it to continue for years. Julie provided a sexual favor (oral sex) to Reiss while they were both on duty so she would get what she wanted, which was not to be disciplined for harassing me Sergeant Valenzuela was in fact assigned the discipline and he then un-sustained Julie's discipline to a lower level. This is known because Deputy Chief Martinez said he reviewed the discipline and saw it was a clear violation of policy/city rules and regulations. Deputy Chief Martinez wondered how Sergeant Valenzuela was un-sustaining some discipline and giving such a light discipline. Deputy Chief Martinez felt it was very unusual and reviewed the discipline with Sergeant Valenzuela and told him he felt the discipline was too light and that Julie clearly violated policy. But Sergeant Valenzuela kept to his agreement with Lt. Reiss because he was ordered by Reiss to keep it to light discipline, and they are good friends. Deputy Chief Martinez had to go to HR to get approval to overturn sergeants Valenzuela’s lenient discipline. This corruption within the police department allowed my to be protected for clearly harassing me because she was providing sexual favors to a Lieutenant. On November 19, 2019, Julie Salcido resigned from her position as Property Evidence Technician. ‘After Julie left, it appears that I now became a target for sexual harassment by Deputy Chief Reiss. He would send me direct messages on Instagram. In these messages he talked about his tattoos and eventually sent me topless photos of himself and his tattoos. He has invited me to go get a tattoo with him on multiple occasions. He invited me out for drinks and out to his stay at his house in Carlsbad. Deputy Chief Reiss frequently calls me his “unicorn”, This is after he came into my office, closed my door, and made me watch a YouTube video titled "Hot and Crazy MATRIX / Cute and Money MATRIX” explaining what a unicorn is to him and other men. Deputy Chief Reiss would often come into my office, which is in the basement and his office is located on the third floor of the building. During these random visits he would sit down and talk about getting a new tattoo, often lowering his shirt to show his chest, or lifting the sleeves on his arms to show me the areas of where he wantedhis next tattoos. When he was around, I tried to get away from him as fast as I can because he made me feel so uncomfortable. I knew his intentions were sexual in nature to me and he was trying to get with me and was trying to groom me in some fashion. There was no reason for a deputy chief to visit me in the basement. In 2020, during covid the department was forced to lay off many positions. One position that was forced to be laid off was my help, my partner Ruth Samano. During covid being the only Forensic Specialist and having to be on call 24/7 1 was working a lot. I was getting burnt out with the excess of doing property and evidence procedures and having to be on call all the time and I needed a break. During that time, I had asked Sergeant Alexander if | could have a weekend off in August 2020. During one of Deputy Chief Reiss’ many visits into my office he asked if | had any plans for the weekend. I stated that I was going to San Diego with family and friends to recharge and reboot. He asked where I was going, and I said Carlsbad. He then said wow, who said you can leave and not be on call? Deputy Chief Reiss then said he would allow me to have the weekend off since he was also going to be in Carlsbad. Throughout this weekend he contacted me via IG and on how the girl's weekend was going and that he wanted to "meet up.” He contacted me numerous times asking where Iwas at and asked if he could meet up and take us all out to show us a good time. It made me feel so uncomfortable, so | declined his request. I knew his intentions were of a sexual nature. Deputy Chief Reiss’ sexual harassment of me went on for years. In January of 2021 I had shown interest in having the Senior Forensic Specialist title. | had shown interest and became vocal to Sergeant Alexander. At this point in time, ! had years and experience, I had been excelling in my caseload by solving cases based on my forensic skills. [had gone above and beyond by maintaining my forensic duties and helping with property and evidence, Sergeant Alexander stated he would look into it, but I never received any information back on it. During one of Reiss’ many random office visits, ! had expressed my interest again of the Senior Forensic Specialist position because I was qualified for it. Reiss said that it wasn’t that easy to change titles (which it seemed like a flawless easy transition for Julie). Reiss said that he would have to” fly” the position and that it may go to anyone but maybe we could work something out. I was immediately discouraged by his comment and did not go further with him and the position. I felt he was asking for a sexual favor like he did with Julie for me to get the senior forensics position. | later found out the Senior Forensic Specialist position was deleted and completely erased with no knowledge of anyone informing me that it has been deleted. This completely discouraged me because now I have no room for growth in my position or a pay increase as an incentive. Recently, Sergeant Valenzuela while on duty and in uniform came to visit Brian Segers at Rendition Tattoo Shop while I was getting a tattoo on 11/22/22. I don’t know if this was a coincidence or if Brian told Sergeant Valenzuela I was going to be there. Sergeant Valenzuela pulled up a chair to my tattoo table then sat and watched me get a tattoo for two hours. I was in a very vulnerable position as the tattoo I was getting was in the center of my chest leaving some of my body exposed as I had little covering my chest at the time. This made me feel very uncomfortable and even made my husband feel uncomfortable which caused a huge fight between my husband and I later who couldn't believe a Sgt. couldspend that long for no apparent work reason. Shortly after the odd encounter with Sergeant Valenzuela, I was on duty and in uniform when I responded to a crime scene where Sergeant Valenzuela had requested my assistance. When I had completed my scene documentation and was walking back to the unit to leave, Sergeant Valenzuela had followed me back to my unit and asked how my chest tattoo turned out and that he wanted to see it because “it looked good when I was getting it done.” For him to see this tattoo | would have to expose my chest which made me feel uncomfortable as the request was sexual in nature. On December 15, 2022, the department had an annual appreciation lunch for those who had been recently recognized by the department. I was selected as employee of the year as well as recognized for several cases due to my forensic work involving certain cases. Earlier in the day I had responded to a call of an unresponsive 9-year-old juvenile. A Chaplain from our department had also responded to comfort the grieving family. These scenes are always especially hard for me, as I have lost a child myself. During the appreciation lunch event | saw the Chaplain that was at the scene previously. He was sitting next to Deputy Reiss, and I wanted to talk to him and thank him for the beautiful prayer that he said for the family, as it touched my heart because I understood what pain the family was going through. I walked over to the Chaplain and said thank you for saying such a beautiful prayer, he then said Geneva, nothing I said was remotely powerful as what you had told those grieving parents and that they will remember the words that had I spoke forever. Deputy Chief Reiss then joined the conversation by said, “she’s a fucking Unicorn man.” Feeling immediately uncomfortable and embarrassed by Deputy Chief Reiss’s comment, | then excused myself. In December of 2019, | located evidence that would have and should have exposed Reiss and his ongoing sexual harassment of females. This exposure of Reiss was reported to Sgt. Alexander and Commander Crane and then was covered up by them to never be found. Evidence of a crime or misconduct on duty was covered up by these individuals. This cover-up, hiding, and destruction of evidence should have put an end to my sexual harassment by Reiss back in 2019 but it lasted for 3+ more years, from December of 2019 to January of 2023. The inaction of Alexander and Crane and the department allowed Reiss to continue to harass me and [ am sure other female employees. | believe Leslie Martinez for sure was retaliated against by Reiss. What I located in December of 2019, was a chair in the evidence vault that was from Julie's main desk. I stood on this chair to put evidence away then went to wipe off my footprints. When I went to wipe off the footprints, | saw what I knew was semen stains. | tested the chair, and it was positive for semen. I reported it to my Sergeant at the time, Kyle ‘Alexander. He said after I told him “what do you want me to do?” He then said he would get back to me. Alexander took a day to get back to me and told me get rid of or destroy the chair, I hesitated and so he then said, cut the sample and keep that and get rid of the chair. He told me to not be descriptive in my report and to send the report and photos of the chair directly to him over email. He told me not to put anything in our evidence system photo wise and don't put the report into our report system. What Sgt. Alexander told me to do was done this way so no one knew about it, and it would never be discovered by anyoneelse. Come to find out this event was never reported up my chain of command or Sergeant ‘Alexander's chain of command except to Commander Crane. Deputy Chief Martinez can confirm this information as he never knew about the chair as it was never reported to him. At the time Deputy Chief Martinez should have been in Sgt. Alexander and Commander Crane's chain of command but they instead most likely reported to Deputy Chief Reiss due to friendship and loyalty. In January of 2023, Sgt. Patrick Leivas asked me about the chair evidence and if [had any knowledge of it.I told him everything that happened. Due to a potential cover up and corruption of the information, I believe Sgt. Leivas reported it to multiple law enforcement authorities and an investigation was started into what happened. Deputy Chief Reiss was placed on admin leave. Ilater found out years after the chair was discovered and after Reiss was put on admin leave in January of 2023. Martinez was notified that Reiss was told about this chair in 2019 and Reiss ordered this chair to be destroyed so it could never be discovered. Sergeant ‘Alexander and Commander Crane covered this evidence up so it could not be discovered at the order of Reiss to further protect him which allowed Reiss to continue to harass me and others. On January 30th Deputy Chief Reiss was put on administrative leave. Several Officers and detectives were in the break room of the annex. I walked into the break room so that | could refill my water bottle when Corporal Frisch looks at me and says did you do this, you're the “head hunter,” I looked at him in disbelief and stated that I had nothing to do with the Deputy Chief going on admin leave. | felt embarrassed due to this statement being said in front of other department members. On February 8, 2023 I was working in my office when Chief Catren entered my office. He shut the door and walked over to my desk. He asked how I was doing, and I said that I was doing ok. He said Geneva, | am sorry, but I had no idea this was going on. (This being the reference to Reiss and my discovery of the chair in 2019). Chief Catren expressed that he acknowledges that from the beginning of when I was hired with Tankersley and Salcido's harassment, to losing my partner in 2020 and now having to be involved with this that he knew I didn’t have it easy and that he was sorry. The chief appeared nervous because he kept rubbing his head, and he kept shaking his head and kept expressing that he had no idea this was happening and that if he did know he would have stopped this long ago. I did not believe him because I know that he and Reiss are good friends and throughout his time with the department, Reiss was rewarded. I believe Chief Catren and others always covered up Reiss’ bad behavior. The conversation continued that the Chief stated that if anything else came up, or ifanyone asked me to do anything that I felt uncomfortable about, I should go straight to him. Catren said people will be held accountable for all of this, and this failure to report. On February 16th I went upstairs to Sergeants Leivas’ office with Ruth Samano to resolve technical issues that we had been having with our payroll. In the office were Sgt P. Leivas, Ruth Samano and Jimmy Nguyen Ruth, Patrick and Jimmy were all working on thecomputer, and I was off to the side. Corporal Jeff Frisch walks from the detective bay area to Sgt. P Leivas’ office, looks at me and says “Hey, you got my boss fired” in a loud voice referencing Sgt. Alexander being placed on Admin leave. At this point | am now getting, frustrated by the ongoing comments, and I said to Jeff that no, | did not get anyone fired. Jeff stated that Commander S. Crane went to briefings and was advising patrol that Sgt. Alexander had been placed on administrative leave. Commander Crane advised that the FBI was involved and that there was an outside company doing the IA portion of the investigation. He said they can place anyone on admin leave should they see it ft. Jeff said that Commander Crane was so upset that he was saying that it was unfair, not right and that he could be next and was in tears. Jeff said he went to Sergeant Alexander’s house the night prior and that Sgt Alexander had shown him the letter of his dismissal. The letter stated he was on admin leave for the handling of evidence and the order that was given to him not to talk to anyone about the investigation. Jeff looked at me and said the evidence that you found is what caused Sgt. Alexander to be placed on admin leave. I was in total disbelief and felt attacked by his, allegation making it seem to be this was all my fault. | started to fear that other members of the staff would retaliate against me, treat me differently or be angry with me, | then turned away from Jeff and geared my attention to the reason why I had gone to the sergeants, office. When we were done, I then expressed my concerns with Jeff's comment to Set. Leivas and he advised me that he would address the issue. I later spoke with Jeff and told him that I was upset about the whole situation, but that unfortunately we were all caught in this ugly web. Jeff was always aware of the hostile work environment that | had to endure with Tankersley and Salcido. He had mentioned to me that he follows Tankersley, and Salcido on social media and that they both still continued to talk badly about me on social media. He said if he was to find it, he would screenshot the negative social media posts so I could see them. Later Sgt. Leivas advised me that he told Deputy Chief Martinez about the comment that Jeff had made. Sgt Leivas called Jeff and told him that he is not allowed to talk to me like that knowing that | am a witness that is involved with an ongoing investigation situation, I felt relieved that Sgt. Leivas had handled the situation immediately. On Tuesday February 21st Deputy Chief Martinez requested me to go to his office. He stated that he had heard about Jeff's comment and that it was clear retaliation. Deputy Chief Martinez expressed how sorry he was that I had received comments like that from Jeff, and that will no longer happen from him, or that if it happens again from someone else, to let him know. On the 22nd Jeff came into my office and asked if we were ok, | said yes, 1 am, I told him his comment bothered me. I said anyone could take a comment like that wrong, he said he was sorry, he didn’t remember what he said, but that if he did say something that offended me, that he was sorry but said again that he didn’t remember what he said. (On Thursday February 23rd I was having a conversation with my partner Ruth Samano about Jeff's comment and that Sgt. Alexander was placed on admin leave. She had mentioned a very important detail that I found to be interesting, She stated that shortly after the chair was discovered that she was working and sitting in our forensic office when ‘Sgt. Alexander and Deputy Chief Reiss came into the office. She then said that bothAlexander and Reiss walked into our forensic lab room and that they were "looking around”. This was odd since they have never both just wanted to see the lab. This behavior is odd due to my time being employed with the department, neither of them have ever had gone into the lab to just "look around” so this was uncommon and very unusual. She then said "are you guys looking for the chair? " And she said that they both looked odd in her response, then Deputy Chief Reiss said surprisingly, "You know about the chair?" She said yes, and it's not here, Then they both left abruptly and no longer wanted to see our lab. | believe they were looking for the chair / fabric to find and destroy it, but | had stored it in the vault in a secure location to maintain that it would not go missing and or be destroyed. On 3/1/23 an emergency meeting was held with the announcement of Chief Catren medically retiring, although the chief appeared to be in good health. In the same meeting it was announced that Deputy Chief Reiss was officially retiring as well on 3/3/23. I was subjected to sexual harassment on a continuous and on-going basis since the start of my employment. I have been subjected to discrimination in that I did not agree to provide sexual favors for advancement but instead tried to advance by just doing my job as best that I could. That I believe that I have been retaliated against over the course of my career, wrongfully targeted as a potential threat to others who were obtaining favors and preferences in the work place for trading sexual activities. Retaliated for reporting wrongdoing and providing information recently that was provided years earlier and hidden by persons with knowledge of the wrongful and/or illegal activities. That I have been injured over the years in enduring the stress of a wrongful and hostile work place and subjected to the sexual comments and innuendo of Reiss and its presumed that such conduct was known and condoned by the City and the Department. I believe that had people done their jobs back in 2019 that | would not have had to endure the treatment and comments of Reiss who had power over my position. | am aware of how other women have been treated by the department when a complaint has been made. I believe that | have claims under FEHA for discrimination, sexual harassment and retaliation. | believe that I have a claim for sexual harassment and retaliation under California law including Labor Code 1102.5. | have sustained damages that are within the jurisdiction of the Superior Court of the State of California. Witmesses/Parties: 1. R.Samono 2. J. Prisch 3. L. Martinez 4, Sgt. Leivas 5. Deputy Chief Martinez 6. _L.Falconieri 7. S.Crane 8 J. Nguyen 9. Chief Catren 10. Deputy Chief Reiss11. Sgt. Alexander 12, Julie Salcido 13. Eloise Tankersley 14. Esteban Valenzuela ‘The information that is contained herein exists from my own personal knowledge from conversations with others , and from documents that exist. All information is believed to be true and accurate to the best of my ability to present these events.PROOF OF SERVICE STATE OF CALIFORNIA. ) }ss: COUNTY OF RIVERSIDE ) I, the undersigned, declare: 1am employed in the County of Riverside, State of California. I am over the age of 18 {years and not a party to this action; my business address is 1325 Spruce Street, Suite 200, Riverside, California 92507. On the date written below, I served the document named below on the parties indicated below, in the following manné J Gy Personal Service) I am familiar with this office's practice for the personal service of documents, I caused said document(s) to be delivered by hand to the offices of the addressee. DOCUMENT: PARTIES SERVED: Charles M. Duggan, Jr jeanne Donaldson. City Manager City Clerk City of Redlands of Redlands 300 E State St., Suite 690 300 E State St., Suite 690 Redlands, CA 92373-5235 Redlands, CA 92373-5235 ‘Yvette Abich Garcia Elizabeth Marin, Manager City Attorney Human Resources City of Redlands City of Redlands 300 E State St., Suite 690 300 E State St., Suite 690 Redlands, CA 92373-5235 Redlands, CA 92373-5235 J (STATE) 1 dectare under penalty of perjury under the laws of the State of California, United State of America that the above is true and correct to the best of my knowledge. Executed on March 16, 2023 at Riverside, California. KCl seca phe ——— nel