1 VINCENT MILLER (SBN 291973)

[email protected]
2 MICHAEL MILLER (SBN 112751)
[email protected]
3 NICK SAGE (SBN 298972)
The Law Offices of Vincent Miller
4 16255 Ventura Boulevard, Suite 625
Encino, CA 91436
5
Telephone: (213) 948-5702
6 Attorneys for Plaintiff LaJuana Haselrig

7 SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE LOS ANGELES COUNTY - CENTRAL DISTRICT
8
LAJUANA HASELRIG, ) CASE NO:
9
)
10 ) COMPLAINT FOR:
) 1) RACIAL DISCRIMINATION IN
11 Plaintiff, ) VIOLATION OF FEHA (CAL. GOV.
) CODE SECTION 12940 et. seq,);
12 v. ) 2) FAILURE TO TAKE ALL
) REASONABLE STEPS TO PREVENT
13 ) DISCRIMINATION IN VIOLATION
COUNTY OF LOS ANGELES, a municipal ) OF FEHA (CAL. GOV. CODE;
14 entity, ALEX VILLANUEVA, an individual, ) SECTION 12940 et. seq,)
JOHN SATTERFIELD, an individual, ) 3) UNLAWFUL RETALIATION:
15 DAVID YOO, an individual, and DOES 1- ) LABOR CODE § 1102.5
10, individuals, ) (WHISTLEBLOWER LAW);
16 ) 4) RETALIATION IN VIOLATION OF
Defendants. ) FEHA (CAL. GOV. CODE SECTION
17 ) 12940 et. seq,);
) 5) INTENTIONAL INFLICTION OF
18
) EMOTIONAL DISTRESS;
19 ) 6) DEFAMATION/SLANDER PER SE
) 7) FALSE LIGHT
20 ) 8) MALICIOUS AND UNLAWFUL
) VIOLATIONS OF THE PUBLIC
21 ) SAFETY OFFICER’S BILL OF
) RIGHTS (POBR) UNDER cal. Gov.
22 ) Code sections 3300-3309.5; FAILURE
) TO COMPLY WITH ONE-YEAR
23 ) STATUTE OF LIMITATIONS
) UNDER Cal Gov. Code 3304;
24
Jury Trial Demanded
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 1

 1 INTRODUCTION

2 1. Plaintiff LaJauana Haselrig is African American, and Defendant Sheriff Alex

3 Villanueva (“Villanueva”) has been and is hostile to Plaintiff based on her race. Villanueva has a
4 long history of making racist, resentful statements toward African Americans including in the
5
media.
6
2. Villanueva has openly expressed his efforts towards his goal of increasing Latino
7
employees at the expense of African American employees, and his anger over his perception that
8
there are too many African Americans employed by LASD, and that there are “enough” African
9
Americans in management at LASD.
10
3. Villanueva also has a huge problem with whistleblowers. Villanueva hates
11
whistleblowers who expose his corruption and he is obsessed with harming those
12
whistleblowers. Whistleblowers are protected by state and federal statutes and are supposed to be
13
safe from retaliation. However, the whistleblowers are not safe in the Los Angeles County
14

15 Sheriff’s Department (“LASD”) from Villanueva’s wrath as they are not protected by the

16 County. Villanueva is viciously over the top vindictive and is his penchant for revenge has been

17 incredibly self-destructive, ironically harming his own self-interests, as well as harming LASD’s

18 ability to protect residents from crime.

19 4. Villanueva has maliciously targeted Plaintiff for being a whistleblower, as she

20 exposed the sheriff’s ongoing corruption and lack of ethics.

21 5. When whistleblowers, like Plaintiff, report misconduct, LASD and Villanueva do
22 not conduct fair and honest investigations into the misconduct. The sheriff and LASD lie about
23
the whistleblowers and try to discredit them with fake allegations, reprimands, and criminal and
24
administrative investigations, conducted with no foundation.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 2

 1 6. There is a stark contrast between the Plaintiff and Sheriff Villanueva. Before

2 being wrongfully terminated by Villanueva, by all objective accounts, Plaintiff was a highly

3 competent and ethical Chief of Court Services Division. Plaintiff holds a Master’s Degree
4 (Emergency Management Administration), and has a long successful 34 year history working for
5
LASD, 3 years on the line in custody, 5 years on the line in patrol (Carson Station) as a deputy, 3
6
years at training bureau, 4.5 years on the line (Compton Station) as a sergeant, 1.3 years on the
7
line in custody as a lieutenant, 5.5 years on the line (West Hollywood Station) as a lieutenant, 2
8
years at Coveted Testing, 1 year at Crime Stoppers, 2.8 years at Central Property and Evidence
9
as a lieutenant, and service as Captain over Court Services Division, Transportation Bureau.
10
Plaintiff has served as Chief of Court Services Division for 3 years, since March 2019, until she
11
was wrongfully terminated by the Sheriff on March 29, 2022.
12
7. In contrast, , Villanueva recently admitted that the Los Angeles County District
13
Attorney (“DA”) convened a criminal grand jury into Villanueva’s obstruction of justice and
14

15 cover up involving Deputy Douglas Johnson’s excessive use of force (the “UOF”), an incident

16 that is at issue here. (Villanueva lied in his statement, falsely stating that Plaintiff and other

17 whistleblowers were the ones being investigated by the DA, rather than Villanueva.)

18 8. The County was recently hit with a $30 million verdict by the jury in the trial

19 revolving around the Kobe Bryant photo sharing scandal and Villanueva’s obstruction of

20 investigation and orders to involved deputies, including Deputy Douglas Johnson, to destroy
21 evidence.
22 9. The Plaintiff repeatedly spoke up about corrupt and unethical conduct in the
23
Villanueva administration. Recently, matters came to a head when Villanueva’s cover up of the
24
UOF came to light in the media.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 3

 1 10. On March 29, 2022, following his regular scheme, Villanueva retaliated against

2 and framed Plaintiff Haselrig, to cover up his criminal conduct and to maliciously harm Plaintiff.

3 11. On March 29, 2022, Villanueva forced Chief Haselrig to end her long illustrious
4 career with LASD. Villanueva pressured Plaintiff to retire, giving her two poisonous “options”:
5
retire immediately without contemplation or be demoted to Captain with her career permanently
6
destroyed under either scenario.
7
12. Ms. Haselrig’s career is over, with her forced retirement, a constructive
8
termination.
9
13. Villanueva retaliated against Plaintiff and other whistleblowers after they exposed
10
Villanueva’s cover up of the use of excessive force on March 10, 2021, by Deputy DOUGLAS
11
JOHNSON (“Johnson”) against an inmate, ENZO ESCALANTE (“Escalante”).
12
14. Villanueva and Defendant JOHN SATTERFIELD (“Satterfield’) framed and
13
defamed Plaintiff. Villanueva and Satterfield engaged in crimes, including obstruction of justice,
14

15 and lied and made statements in print and orally that Plaintiff engaged in crimes, which were

16 actually committed by Satterfield and Villanueva.

17 15. On August 31, 2022, under direction of Villanueva, Defendant Deputy David Yoo

18 (“Yoo”) released a statement defaming Plaintiff, her attorney, and his firm’s other clients, stating

19 that they are criminals trying to avoid prosecution through the filing of their lawsuits. The sheriff

20 continues to be spiteful and vindictive and lie about those who call him out for misconduct.
21 Instead of obsessing over exacting revenge on his imagined political enemies, Villanueva would
22 be better served, and the community would be better served, if the sheriff would instead focus on
23
fighting crime.
24

25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 4

 1 16. It is extreme and outrageous conduct by the sheriff, for him to obstruct justice and

2 cover it up, and then frame his executives for his own misconduct, destroying lives to cover up

3 his crimes.
4 17. The reasons for the sheriff’s misconduct were threefold, to retaliate against the
5
Plaintiff for being a whistleblower on several instances of illegal and other wrongful conduct, to
6
further Villanueva’s cover up of an excessive use of force incident, and to further his goal of
7
reducing the number of African Americans employed by LASD.
8
18. Plaintiff was an excellent employee who calls on the County, after it has done
9
nothing to intervene through the first 3.5 years of the sheriff’s reign, to finally take action and
10
protect her and the other whistleblowers from this madness.
11

12
JURISDICTION AND VENUE
13
19. This Court has jurisdiction over all state causes of action. Venue is proper because
14

15 Defendants are located in the County of Los Angeles, and all the events, actions, or omissions

16 giving rise to these claims occurred in the County of Los Angeles.

17 PARTIES

18 20. Plaintiff LaJuana Haselrig was the Chief of Court Services Divisions in LASD,

19 before being illegal forced out by Villanueva; Chief Haselrig was racially discriminated against

20 and was further targeted for reporting the unlawful conduct of Defendant Sheriff and was
21 retaliated against by the County and the Defendant Sheriff.
22 21. Defendant Los Angeles County is a municipal entity that operates and operated
23
LASD, which is an agency of the County.
24
22. Defendants SHERIFF ALEX VILLANUEVA, John Satterfield, and David Yoo,
25
are employed by LASD and the county and are residents of Los Angeles County. The County is

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 5

 1 liable for all their and all the other LASD employees’ wrongful conduct and the misconduct of

2 all its other employees’ misconduct against the Plaintiff.

4 STATEMENT OF FACTS
5
23. On March 29, 2022, the County of Los Angeles’ Sheriff, ALEX VILLANUEVA
6
(“Villanueva”) ADMITTED THAT HIS ADMINISTRATION COMMITTED CRIMES
7
INCLUDING OBSTRUCTION OF JUSTICE by covering up an incident of excessive use of
8
force. The deputy in the incident used the same maneuver used by Derek Chauvin to murder
9
George Floyd, so it is quite remarkable that the head of the Los Angeles County Sheriff’s
10
Department (“LASD”) admitted that the County of Los Angeles is liable for such wrongdoing,
11
both the excessive force, and the criminal cover up.
12
24. Given this admission of crimes by his administration and the fact that he is the
13
elected leader of the LASD and “the buck stops here” responsible for his administration,
14

15 Villanueva should have resigned immediately after making this confession. Furthermore, it was

16 not his administration that did the cover up; the cover up was done by Villanueva himself.

17 25. Instead of resigning, Villanueva, desperate and panicked for a cover story, turned

18 around and illegally fabricated that the Plaintiff, CHIEF LAJUANA HASELRIG, along with

19 Assistant Sheriff Robin Limon were the ones in his administration who did the cover up instead

20 of him. In an effort to make the frame up of his staff look plausible, Villanueva forced Plaintiff
21 and Ms. Limon out of their jobs.
22 26. Villanueva ordered Plaintiff and Assistant Sheriff Limon to pick between two
23
poisonous options by the end of the business day on March 29, 2022: retire immediately or be
24
demoted. Limon subsequently was demoted four ranks, to lieutenant. Plaintiff was forced retired.
25
Villanueva violated state ordinance and law by sending Undersheriff Murakami to Plaintiff’s

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 6

 1 home to fire her while she was out on medical leave. Under the law, an employee shall not

2 receive discipline, removal of position or demotion while off work due to a job relate injury. But

3 then, following the law is not Villanueva’s strong suit.

4 27. Up through the moment of filing this claim, Sheriff Villanueva continues with his
5
complete disregard for law and ethics, as he further frames his own employees, the
6
whistleblowers, in a desperate effort to avoid scrutiny.
7
28. In addition to trying to pressure Captain Angela Walton to write up a fictional
8
timeline of events to match his lies to the media and committing an additional crime by writing
9
up a fake memo in May 2022 designed to further cover up his actions, Villanueva also has
10
opened a rigged Internal Affairs Bureau investigation into Commander Jose Rios, with a fake
11
allegation that Rios tampered with an (another fake, rigged) investigation into the use of force
12
incident.
13
29. After the video and Villanueva’s cover up of the incident hit the media,
14

15 Villanueva also promoted Anthony Blanchard to Captain in an effort to buy his silence, and get

16 him to commit the crime of perjury, and support his fake story that he did not see the video on

17 the excessive use of force in March 2021. After Villanueva’s cover up was exposed in the media,

18 Villanueva also promoted Steven Ruiz, Assistant Sheriff Limon’s former aide, who hid an early

19 draft of force package of the incident from Assistant Sheriff Limon, and tried to procure her

20 blank stationary, presumably to forge notes from her.

21 30. Villanueva recently admitted in an announcement that the District Attorney has
22 convened a grand jury to investigate Villanueva’s obstruction of justice. Villanueva fabricated
23
that the District Attorney was investigating the whistleblowers, including Plaintiff, rather than
24
himself.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 7

 1 31. It is unknown at this time if Blanchard allowed himself to be pressured by

2 Villanueva into lying under oath to the grand jury and risked going to jail to protect Villanueva.

3 But Villanueva is the target of the grand jury investigation, and the expectation is that he will be
4 indicted by the District Attorney for his misconduct
5
32. Due to the Sheriff’s illegal conduct, But Plaintiff’s long illustrious career in law
6
enforcement is over and illegally destroyed by the County of Los Angeles and its employees.
7
33. Villanueva retaliated against Plaintiff and Limon and other whistleblowers,
8
including Commander Allen Castellano, after they exposed Villanueva’s cover up of the use of
9
excessive force by Deputy DOUGLAS JOHNSON against an inmate, ENZO ESCALANTE.
10
34. Deputy Johnson is the deputy who took photos of Kobe Bryant’s remains after he
11
tragically died in a helicopter crash. The trial in the Kobe Bryant photo scandal was just held and
12
concluded, with a verdict in favor of Plaintiffs, including Bryant’s widow. During the trial, lies
13
by Villanueva and his obstruction of justice in that matter were revealed. Johnson testified in that
14

15 trial about his misconduct there. The jury hit the County for a $30 million verdict, as the County

16 offensively defended itself by embracing Villanueva’s lies about the matter.

17 35. After Johnson took the photos of remains of Kobe Bryant and his daughter, and

18 shared the photos, Villanueva offered a deal: help Villanueva to destroy the evidence and

19 obstruct justice and Villanueva would not give him any discipline for the misconduct. Johnson

20 destroyed the evidence on his phone, deleting the photos. Johnson received no discipline for his
21 actions in this matter.
22 36. Then, between the time Johnson destroyed the photos for Villanueva and March
23
10, 2021, Johnson began to be investigated by LASD’s ICIB for his alleged involvement in a
24
gambling and prostitution ring. However, Villanueva still did not relieve Johnson of duty.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 8

 1 37. If Villanueva had properly disciplined Deputy Johnson, Johnson would not have

2 been at work on March 10, 2021, and a resident would not have been subjected to excessive

3 force.
4 38. On, March 10, 2021, at San Fernando Courthouse, Deputy Johnson engaged in
5
excessive force against inmate Enzo Escalante. Escalante alleges that Johnson assaulted him and
6
that this prompted the inmate to strike Johnson and assault him. Deputy Johnson disputes that he
7
shoved Escalante. What is not in dispute is that after Johnson properly restrained Escalante,
8
Johnson then placed his knee on Escalante’s head and restricted his breathing long after
9
Escalante stopped resisting the deputy. The incident was and is reminiscent of how officer Derek
10
Chauvin had improperly cut George Floyd’s air off. Here, Escalante survived, but the nature of
11
the deputy’s conduct called for a swift criminal and administrative investigation into his conduct.
12
39. On March 10, 2021, Whistleblower Allen Castellano, a Commander, was alerted
13
of the Escalante incident and he, his supervisor, Chief LaJuana Haselrig, the Plaintiff, took all
14

15 the necessary steps to handle the matter promptly and properly. However, Sheriff Villanueva

16 obstructed justice and covered the UOF incident up and retaliated against the Plaintiff and others

17 for blowing the whistle on the illegal conduct.

18 40. One of the reasons why Villanueva is maliciously targeting the Plaintiff is

19 because she has personal knowledge of Villanueva covering up the UOF incident. On March 10,

20 2021, Castellano and Plaintiff asked Assistant Sheriff Limon to view the video on the shared
21 division file, and Ms. Limon agreed the “UOF” by Johnson looked bad and was possibly a crime.
22 Plaintiff asked Ms. Limon to show the video to the sheriff and Plaintiff had staff burn a DVD to
23
show Villanueva. The staff burned the DVD and Plaintiff gave the DVD to Ms. Limon.
24
41. On or about March 15, 2021, Plaintiff handed the DVD for the sheriff to Ms.
25
Limon and watched her walk toward the sheriff’s office.

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 9

 1 42. Villanueva would later lie and claim he did not see the video in March 2021.

2 However, there are 7-8 witnesses to the fact that he saw the video at that time, and he will not

3 escape liability for his crimes and other wrongful conduct.

4 43. On or about March 15, 2021, Limon confirmed to Plaintiff and others that she
5
watched the video with Villanueva and that he agreed the force looked troubling and that he
6
would “handle it,” taking responsibility for the investigation and the required referral to LASD’s
7
ICIB. Except what the Sheriff really meant by “handling it” was to cover it up, as he
8
acknowledged it would look “bad” for him if the video was shown to the media.
9
44. When the video of the UOF was leaked to the media about a year later,
10
Villanueva lied repeatedly about the incident and Villanueva’s role in it.
11
45. We know Villanueva lied here for many reasons, including that he already
12
initiated and concluded a fake Internal Affairs Bureau (“IAB”) investigation into the delays in
13
the UOF being referred for a criminal investigation, and delays in the inmate’s assault case being
14

15 sent to the District Attorney. On March 6, 2022, the sheriff wrapped up the investigation with no

16 finding of wrongdoing by Plaintiff or Limon. Even though the investigation was rigged by the

17 sheriff, the only lie at that time he came up with was that Commander Allen Castellano made a

18 procedural mistake in the investigation that caused delays. Yet, less than 4 weeks later, he

19 suddenly pretended that Plaintiff and Limon did his cover up for him.

20 46. Villanueva framed Plaintiff for his crimes because he wanted to escape liability
21 and to retaliate against the whistleblower Plaintiff.
22 47. Another reason why Villanueva is targeting Plaintiff is there has been a history of
23
the Plaintiff reporting and raising concerns about wrongful conduct, including Villanueva’s habit
24
of retaliating against whistleblowers. Assistant Sheriff Robin Limon documented in a recent
25
lawsuit a dizzying number of incidents where Villanueva abused government power by

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 10

 1 promoting unqualified people to Captain positions even when there were findings against them

2 of serious wrongdoing, and in retaliating against whistleblowers. Limon also documented thefts

3 of government monies where employees are paid by the County but don’t work for the County,
4 instead working on behalf of Villanueva’s re-election campaign. Likewise, Plaintiff has reported
5
and called out the sheriff for retaliation against whistleblowers and other wrongful conduct.
6
48. In addition, the Sheriff has targeted Plaintiff for being African American. The
7
Sheriff has a history of making racist statements in private as well as in public.
8
49. Villanueva has made it clear in public statements that he has racial resentments,
9
engaging in generalizations and false statements about African Americans, and blames African
10
Americans for supposedly holding him back in his career. Villanueva speaks as if he thinks all
11
African Americans held him back. He seeks to pit Latinos against African Americans as if there
12
is a racial contest. In an infamous March 24, 2022, interview, Villanueva complained of looking
13
at a wall of photos of division chiefs at LASD and said, “I counted nine Black division chiefs…
14

15 and I thought to myself, ‘Nine [“blacks] and one [Latinos].” In the same interview, Villanueva

16 complained there were too many black writers at the Los Angeles Times, saying “for every

17 Black reporter, you expect to see four Latino.” In the same interview, Villanueva lied that the

18 “overwhelming majority” of those assaulting Asian victims of hate crimes are “black.”

19 50. Inside LASD, Villanueva is likewise known for racism and bias towards African

20 Americans, calling an African American “knuckle dragger,” and refusing to discipline his
21 Undersheriff Timothy Murakami for calling employees the Japanese language version of the “n”
22 word.
23
51. When Plaintiff expressed to Villanueva that she hoped there would be fairness
24
and opportunity for qualified African Americans to promote in the department, Villanueva
25
dismissively told her that “we have enough of you, [black people].” Villanueva meant that he felt

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 11

 1 there were too many African Americans in management, indicating a bias against African

2 Americans seeking earned promotions. Plaintiff has observed that Sheriff Villanueva simply

3 does not like African American people.

4 52. Early in 2019, Plaintiff witnessed the Sheriff deny the opportunity for a qualified
5
Lieutenant, initials “TS,” to interview for an open captain position, because she was African
6
American, and out of retaliation. Plaintiff objected to the illegal denial of opportunity and
7
reminded the sheriff that the lieutenant met Villanueva’s new prerequisites to interview. In
8
contrast, Lt. Anthony Blanchard did not meet the sheriff’s prerequisites. Yet, Villanueva
9
promoted him to Captain.
10
53. On another occasion, Plaintiff informed the sheriff that LASD is required under
11
the law to give both female and males an opportunity to interview for captain or other positions
12
if they are qualified regardless of race. But Villanueva stated that there were “enough whites
13
promoted.” After reporting on the sheriff’s illegal conduct, Plaintiff was no longer allowed to
14

15 attend the sheriff’s administration meetings.

16 54. Villanueva transferred another lieutenant, initials J.L., apparently because he is

17 African American. J.L. was hired as Undersheriff Timothy Murakami’s aide. However, after J.L.

18 was on the job as the aide for just two days, the sheriff walked into the undersheriff’s office,

19 looked at J.L., and had him removed from the position. Plaintiff informed Villanueva that J.L.

20 was perfectly qualified for the position and there was no legal basis for removing him as the aide.

21 The sheriff ignored the notice by Plaintiff.

22 55. Early on in his reign as sheriff, Villanueva let it be known that he had issues with

23 Court Services Division and wanted to break laws and rules. During several executive staff

24 meetings, (chiefs and above attend weekly meetings), the sheriff would use profanity to discuss

25 his personal vendetta Villanueva brought into office toward the BOS because they had endorsed

his campaign opponent, incumbent Sheriff McDonnell. The sheriff told Plaintiff to break up the
LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 12
 1 Special Operations Unit (SOU). Villanueva argued that the SOU members do not work for the

2 judges or BOS, they work for the Sheriff’s Department and can be reassigned. The sheriff was

3 trying to remove most of the SOU team. Plaintiff pushed back, telling Villanueva that the BOS
4 pays for a portion of the team and LASD can’t remove personnel based on his personal vendetta
5
against the BOS. Commanders Allen Castellano and Dan Dyer and Plaintiff discussed the major
6
problems this would cause the department if they dismantled the SOU unit. Plaintiff refused to
7
dismantle the unit.
8
56. Villanueva threatened on several occasions to “get” whistleblowers for sharing
9
information about his wrongful conduct. Plaintiff reported to the sheriff that it is illegal to
10
retaliate against whistleblowers and argued for him to stop such conduct.
11
57. After Villanueva stated he was looking for revenge on whistleblowers in a
12
teleconference meeting, stating again he would “get” a whistleblower, Plaintiff texted him to
13
stand down, telling him ‘You can’t say that” and to “stop.” Plaintiff then went to Villanueva’s
14

15 office and repeated that he can’t legally say those things and retaliate against whistleblowers.

16 Villanueva replied, “but I’m the elect.” Plaintiff told him that he was opening the department up

17 to liability with his threats and retaliation. The Sheriff did not listen to her warnings and

18 eventually Plaintiff would become subject to retaliation herself.

19 58. Regarding the UOF incident, Plaintiff at all times did everything right and made

20 sure to report the wrongdoing of the sheriff after he blocked the investigation into the deputy to
21 hide the video and incident from the public. Plaintiff was informed of the UOF on the day of the
22 incident and watched the video and was troubled by the similarities to the Derek Chauvin/George
23
Floyd incident. As supervisor to Commander Castellano, Plaintiff made sure to stay in the loop
24
and to review and guide Castellano to take all necessary steps to get the matter to ICIB for
25
criminal investigation. Castellano informed Plaintiff on March 10, 2021, and Captain Robert

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 13

 1 Jones was told to consult with ICIB to see if a criminal investigation was warranted. The consult

2 should have happened right away. Jones and his successor in West Bureau, Captain Sanchez,

3 were responsible for making the referral for the consult. Commander Castellano diligently spoke
4 with Captains Jones and Sanchez and instructed both to consult with ICIB. The consult did not
5
happen because Villanueva blocked it and covered it up.
6
59. Plaintiff grew increasingly concerned about Villanueva’s conduct. Plaintiff had
7
witnessed the Sheriff on multiple occasions engage in improper and even illegal conduct.
8
Plaintiff believed that if the Sheriff was delaying the criminal investigation, he was putting
9
residents’ lives at risk. The UOF by Johnson should have been investigated completely and if
10
Deputy Johnson engaged in wrongful conduct, he needed to be held accountable. If this potential
11
method of use of force was being used by other deputies, the Sheriff needed to train them and
12
make sure the practice was stopped.
13
60. The Sheriff has tried to make light of the UOF incident, stating that the inmate did
14

15 not die. However, after Derek Chauvin murdered George Floyd, law enforcement agencies were

16 enlightened about this particular type of use of force used by Chauvin and Johnson. What had

17 been an accepted practice in some agencies in the past was no longer seen as appropriate. Law

18 enforcement agencies now recognized that this tactic could prove to be lethal. Villanueva should

19 have acted on this excessive UOF immediately when Limon showed him the video and protected

20 the County’s residents.

21 61. On June 16, 2021, Castellano and Haselrig discovered that the ICIB consult on
22 the UOF had still not been done and they were alarmed. They also discovered that Captain
23
Sanchez had still not sent to the District Attorney the case on the assault committed by inmate
24
Escalante against Deputy Johnson. Castellano and Plaintiff were also troubled to learn that the
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 14

 1 delays were ordered by someone in the sheriff’s office – and they would later learn this meant it

2 was done by the sheriff himself.

3 62. On June 16, 2021, Plaintiff shared Castellano’s concerns with Assistant Sheriff
4 Limon including about Captain Sanchez refusing to have the case against inmate Enzo Escalante
5
submitted to the District Attorney’s Office for prosecution. Sanchez has admitted that she did not
6
send the case to the district attorney, despite the video being such strong and obvious evidence of
7
the inmate committing assault against the deputy and acknowledging the similarities to Derek
8
Chauvin and George Floyd incident. Sanchez said it would “open a pandora’s box” to send the
9
Inmate’s case to the DA. What Sanchez and Villanueva meant by “pandora’s box”’ is that the
10
video would have made it out to the public, and exposed Villanueva’s cover up of excessive
11
force.
12
63. Under Plaintiff’s supervision and with her review and approval, Castellano at all
13
times followed proper procedures in this matter. Castellano sent the UOF packet back for
14

15 corrections to West Bureau, April 27, 2021, May 4, 2021, June 2, 2021, June 23, 2021, and

16 approved force review on July 13, 2021, only for the efforts of himself, and Plaintiff to be

17 stymied by Villanueva. Believing ICIB had already been consulted, the force review was

18 approved so that IAB could begin their investigation.

19 64. Commander instructed Sanchez to have the assault case against the inmate

20 submitted to the District Attorney. But Sanchez still did not complete this request.
21 65. By July 2021, Castellano and Plaintiff knew it was time to blow the whistle on
22 obstruction of the investigation. Subsequently, in his final UOF package written in July 2021,
23
Castellano created a paper trail of the cover up. In his final report, Castellano noted the
24
irregularities and possible crimes being committed by LASD personnel and supported an
25
investigation into the incident. Castellano hoped his report would alert and jump start a proper

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 15

 1 handling of the Escalante use of force matter. Plaintiff shared the same hope that their blowing

2 the whistle would prompt everything to be righted and be put on proper track, and she reviewed

3 the July 2021 package and signed off on it. However, Castellano’s report did not generate the
4 response they hoped, as Villanueva continued to quash the investigation.
5
66. Sanchez was later transferred out of her position and Captain Angela Walton was
6
transferred in and assumed command of West Bureau in fall, 2021. It was then that Plaintiff and
7
Castellano learned that ICIB was still not consulted and that IAB was trying to complete its
8
investigation. It is now clear that Villanueva instructed West Bureau not to proceed.
9
67. After Walton and Castellano rescued and revived the UOF investigation and had
10
it sent to ICIB finally, in November 2021, Villanueva was enraged and initiated a fake IAB
11
investigation into Castellano. If the sheriff wanted to frame Castellano and the Plaintiff, as well
12
as Assistant Sheriff Limon, he had one year from the incident of March 10, 2021, to conduct and
13
IAB and punish them for any wrongdoing. Under the Public Safety Officers’ Bill of Rights
14

15 (“POBR”) law enforcement agencies have one year from an incident to investigate and impose

16 discipline on a deputy for any wrongdoing. But in this IAB, the sheriff exonerated Plaintiff and

17 Limon by admitting they had done nothing wrong and were to not be subjected to an

18 investigation. And in regard to Castellano, Villanueva accused him of making a procedural

19 mistake, but not that he engaged in a cover up. However, when Villanueva’s obstruction was

20 exposed in March 2022, he would suddenly claim that Plaintiff along with Limon and Castellano
21 engaged in a criminal cover up of the UOF.
22 68. Villanueva regularly uses a certain political tactic against whistleblowers like he
23
did with the Plaintiff. When the whistle is blown, he immediately denies the allegations and
24
moves to cover up the misconduct. Villanueva “flips the script” on the whistleblowers and
25
accuses them of the exact wrongdoing they are reporting on. Villanueva then initiates rigged IAB

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 16

 1 investigations against the whistleblowers and/or announces he has a launched a (fake) criminal

2 investigation into them and denies earned promotions and gives unfair demotions to the

3 whistleblowers. This is what happened with the UOF incident here.

4 69. On or about March 25, 2022, the Los Angeles Times obtained a copy of the video
5
of the excessive use of force against inmate Escalante, gained access to the Castellano’s
6
whistleblower report of July 2021, and ran an exposé of the Villanueva cover up. Villanueva
7
scrambled to do additional cover up with a series of more lies. He lied to the LA Times as he
8
vehemently denied that his administration had engaged in a cover up.
9
70. On the fly Villanueva came up with a bogus story that he only saw the video on
10
November 18, four days before the case was officially approved by ICIB. Villanueva also lied
11
and took credit in the media for the referral to ICIB, but it was referred to ICIB on November 9,
12
2021, nine days before his fake video viewing date.
13
71. Soon after, Villanueva began instructing his staff, including Commander Joseph
14

15 Williams to falsify a timeline to fit his cover up. Williams contacted Captain Walton while she

16 was out on medical leave and tried to elicit her help on behalf of the sheriff to concoct a false

17 narrative. Captain Walton explained that the sequence of events did not occur as the Sheriff has

18 publicly stated, and that the only timeline she could submit, the factual one, did not align with

19 what the Sheriff was claiming.

20 72. Williams then called Captain Walton again to tell her she was being moved out of
21 her command at Court Services Division and did not tell her to what assignment she was being
22 banished to by Villanueva. This was clearly an act of retaliation. This means there have been 5
23
Captains in a little over a year to command West Bureau.
24
73. In addition to lying about the date he first saw the video, Villanueva realized that
25
Castellano’s whistleblower UOF report of July 2021 stated executives above the rank of chief (in

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 17

 1 the sheriff’s office) were directing the UOF investigation. Villanueva looked at those in his

2 office who viewed the video back in March 2021, himself, his Undersheriff, and second in

3 command Timothy Murakami, his Lieutenant Aide Anthony Blanchard, and his Assistant
4 Sheriff, Ms. Limon. While there were two other Assistant Sheriffs, Limon was generally
5
considered as number 3 in command, after Villanueva and Murakami. Villanueva reasoned the
6
smart political move would be to frame Limon, and that he could “kill two birds with one stone,”
7
in light of her other whistleblowing and refusal to engage in wrongful conduct, rather than admit
8
he was the one who made the decision to obstruct justice.
9
74. On March 29, 2022, three days after denying there was any cover up of the
10
excessive force on inmate Escalante, and after IAB investigation was completed, reviewed, and
11
adjudicated with Castellano receiving discipline and Limon and Plaintiff cleared of any
12
wrongdoing whatsoever, Villanueva changed his story again, and admitted his administration
13
engaged in a cover up. This was quite a remarkable admission by the Sheriff in the middle of all
14

15 his lies: that the County of Los Angeles engaged in a criminal cover up of an excessive use of

16 force.

17 75. However, at the same time, in a defamatory frame up, the Sheriff claimed the

18 cover up was done by his staff and not himself. He announced he was acting against two of his

19 officials, Castellano’s supervisor, Chief LaJauna Haselrig, the Plaintiff, and Assistant Sheriff

20 Robin Limon, communicating that they, not he, had engaged in the cover up of the UOF.
21 Villanueva manipulated the media to run photos of Plaintiff and Haselrig, sending the message to
22 the public and their family members that they were disgraced law enforcement officials,
23
criminals.
24
76. While Assistant Sheriff Limon was above the rank of chief, and 3 rd in rank, and
25
was the logical person for Villanueva to unjustly frame for his crimes, Plaintiff was not above

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 18

 1 the rank of chief. However, Villanueva saw an opportunity to kill a third bird, and lower the

2 number of African Americans in the executive ranks, and framed Plaintiff as well. Villanueva

3 continues with his focus on eliminating African Americans from employment. In addition to
4 lowering the number of African Americans at the executive rank, Villanueva has intentionally
5
accepted less African Americans into the police academy in furtherance of his avowed race war
6
against African Americans.
7
77. Since taking office in 2018, Villanueva has been focused more on politics, more
8
on re-election then in fighting crime. And now, he was in the middle of his re-election campaign,
9
and he was ready to do whatever he felt he needed to do to win, even scapegoating his own
10
officials, Limon and Chief Haselrig, for his own corruption. Objective observers inside LASD
11
saw the attacks on Plaintiff for what it was, a ruthless stab in the back in a blatant abuse of
12
power, and the ultimate retaliation against a whistleblower.
13
78. Villanueva demanded Plaintiff and Limon’s immediate retirement, with the option
14

15 of being demoted if they refused. At the moment of retaliating and intimidating Plaintiff with this

16 ultimatum, Villanueva blurted out to Limon that Deputy Johnson was involved in the Kobe

17 Bryant accident scene photo scandal. Villanueva was clearly aware that his destruction of

18 evidence and failure to discipline Johnson for that incident, and the failure to put Johnson out on

19 leave on the other criminal investigation, allowed the UOF against Escalante to occur. And that

20 this would result as he said in the “bad media” he did not need.
21 79. Without being held accountable for over three and a half years of wrongful
22 conduct, Villanueva has acted with impunity, demonstrating he believed he could get away with
23
anything, with no one acting to curb his routine severe abuse of government power. Villanueva
24
maliciously forced Chief Haselrig out of her job. Villanueva constructively terminated the
25
Plaintiff.

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 19

 1 80. On April 25, 2022, Commander Castellano filed a tort claim with the County of

2 Los Angeles, confirming all the allegations on the UOF made here by Plaintiff. Villanueva

3 responded by lashing out at Castellano and the Sheriff again lied about the allegations and the
4 timeline of events. Villanueva made more defamatory statements about Plaintiff as well as
5
Limon and Castellano, claiming they all engaged in Villanueva’s cover up of excessive use of
6
force.
7
81. Villanueva also forced his Aide, Blanchard, to go before the cameras with the
8
media to lie for him about when Villanueva first saw the video. But Blanchard mumbled a non-
9
denial denial, confirming that Blanchard recalls and confirms that the video was viewed by
10
Villanueva in March 2021.
11
82. The Sheriff also falsely alleged criminal conduct against a Los Angeles Times
12
reporter, Villanueva’s campaign opponent Eli Vera, and Inspector General Max Huntsman, in a
13
further effort to avoid scrutiny of himself, and intimidate the media and whistleblowers. A day
14

15 after clearly naming the reporter, Vera, and Huntsman as “subjects” of a criminal investigation,

16 the Sheriff lied and said he did not say what he said, even though it is on video.

17 83. Villanueva still continues his corrupt ICIB criminal investigation to try to

18 determine which whistleblower leaked the video to the Los Angeles Times, so the Sheriff could

19 retaliate against the whistleblower, and intimidate other whistleblowers to not come forward. The

20 sheriff instructed ICIB to officially consider Plaintiff, Castellano, Limon, and Eli Vera to be just
21 witnesses to be interviewed for this investigation, but unofficially they are to be considered
22 suspects to be targeted for being whistleblowers.
23
84. On May 4, 2022, Plaintiff filed her tort claim in this matter, alleging
24
whistleblower retaliation and racial discrimination. Soon after, Villanueva engaged in further
25
obstruction of justice by concocting a fake memo, purportedly written by Defendant Chief of

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 20

 1 Staff, Commander John Satterfield. Villanueva backdated the memo to May 1, 2022. The memo

2 was clearly written for purposes of litigation and is not a memo written in the normal course of

3 business. Yet, Villanueva manipulated two media outlets into reporting on the memo as if it was
4 some “leaked LASD” document, which exonerated Villanueva. In truth, the memo does not
5
exonerate Villanueva as it is full of glaring holes, inconsistencies, and deficiencies, designed to
6
trick readers. The memo ultimately reinforces how there was a cover up of a use of excessive
7
force. Satterfield joined Villanueva in the crimes of obstruction of justice and cover up when he
8
wrote this memo.
9
85. The May 2022 memo cannot survive scrutiny by legal authorities. The memo was
10
clearly rushed out of desperation, and the incompetence in the cover up is astounding. On page 6
11
of the memo, Defendants Villanueva and Satterfield claim that Assistant Sheriff Limon could
12
have emailed the video to Villanueva on March 15, 2021, instead of waiting to see him in person
13
and showing it to him on DVD. So, therefore, Limon lied about it. But on page 2 of the memo,
14

15 Villanueva, and Satterfield state that Satterfield showed it to Villanueva for the first time on

16 November 18, 2021, through skype, because the VIDEO WAS TOO LARGE OF A FILE TO BE

17 EMAILED.

18 86. The fraudulent May 2022 memo purportedly written by Satterfield contained

19 several additional defamatory statements about Plaintiff, Limon, and Castellano, as well as

20 Captain Robert Jones, accusing all of them as taking part in a cover up.
21 87. The fraudulent May 2022 memo goes on to acknowledge that there had been a
22 IAB investigation into the delay of the UOF investigation, confirming that Villanueva already
23
did his fake investigation within the 1 year under POBR, concluded in March 2022 and found no
24
wrongdoing by Plaintiff, and Limon, and no cover up by Plaintiff, Limon, Castellano, and Jones.
25
As we know, Villanueva only moved to smear and frame Plaintiff after the UOF video was

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 21

 1 leaked to media at the end of March. Yet, the fraudulent Satterfield memo goes on to further

2 defame Plaintiff stating that, “the apparent failures of leadership. Again, at no time during the

3 entire course of the IAB investigation did A/S Limon ever disclose her prior knowledge of
4 involvement in the incident, or the prior knowledge and involvement of Chief Haselrig.” Limon
5
was never allowed to be interviewed in Castellano's IAB so there is no way she would have been
6
able to disclose her knowledge of the incident. In fact, Limon asked to be interviewed for the
7
IAB and her request was denied. Villanueva knew that Limon would expose his lies on the
8
matter.
9
88. The memo continues from there with a multitude of lies to falsely portray the
10
Plaintiff and the other whistleblowers of “gross” failures in leadership, and corruption.
11
89. In their “conclusion” to the memo, Villanueva and Satterfield lie about the
12
Plaintiff and the other whistleblowers by stating that, “on March 10, 2021, Robin Limon,
13
LaJauna Haselrig, Allen Castellano, and Robert Jones attempted to cover-up the use of force that
14

15 occurred earlier in the day at the San Fernando Court lock-up.” The Defendants also knowingly

16 falsely state that “on November 18, 2021, this attempted cover-up was discovered and halted,

17 when Sheriff Villanueva became aware of this incident and ordered immediate action…” The

18 lies here would be laughable if they did not come up at the expense of human lives, the Plaintiff,

19 and the other whistleblowers, and that the lies were done in furtherance of a crime.

20 90. It should be noted that while the creation of the fake memo is a crime by itself, in
21 the memo, Satterfield, and Villanueva, also make several admissions that implicate them in a
22 crime. For instance, the memo acknowledges that the inmate Escalante had “pain” and “visible
23
head injuries,” had “trouble breathing,” “and sustained injuries to his face and head.” It also
24
states that the “UOF used with the knee appeared to be excessive and unlawful.” In addition, the
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 22

 1 Defendants admit to their own cover up: “The other attempt to ‘cover-up’ occurred on March 10,

2 2021, when the decision was made to bifurcate the UOF incident into two separate reports.”

3 91. The Defendants cannot hide by their pretense that this is a legitimate, official
4 memo that somehow got leaked. The Defendants committed fraud, engaged in defamation, and
5
shopped the document to the media, pretending it was “leaked.” The memo and the claimed
6
procedure did not follow the department’s claim review process, omitted critical information,
7
and fabricated other information. The Defendants drafted and “leaked” the memo to sway public
8
opinion. Now it is a public document on the LASD website, perpetually defaming the Plaintiff
9
and the other whistleblowers. In addition, the document now posted on the LASD website has
10
been altered, with fake, illogical “redactions” done on the document, including hiding the
11
injuries done to Escalante.
12
92. On August 8, 2022, Villanueva engaged in further defamation against the Plaintiff
13
and other whistleblowers, as he violated the District Attorneys confidentiality and posted an
14

15 announcement revealing the District Attorney had convened a criminal grand jury into the

16 handling of the UOF. But rather than telling the truth that he is the suspect and target of the

17 grand jury investigation, Villanueva went on in his statement to engage in further defamation and

18 pretend that he and LASD had done an investigation into the matter and stating that “our

19 investigation indicates that the allegation of misconduct was orchestrated by involved

20 department executives to falsely portray themselves as whistleblowers to avoid discipline, up to

21 and including termination.” Villanueva is quite aware that the whistleblowers did not orchestrate
22 the cover up that he was responsible for doing.
23
93. On August 31, 2022, Villanueva and Defendant Deputy David Yoo lied and
24
engaged in further defamation, suggesting that Plaintiff, as well as the other whistleblowers
25
in the UOF matter, and Plaintiff’s attorney and 12 of his other whistleblower clients are

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 23

 1 criminals trying to avoid prosecution by calling the sheriff out for his misconduct, and that

2 Plaintiff and the other whistleblowers were not performing well in their jobs. Yoo and

3 Villanueva stated that, “…frivolous lawsuits against the department, all which seem to
4 share a common thread: lack of accountability for poor performance by the plaintiffs…
5
demonstrably false statements… avoid accountability or prosecution.”
6
94. Due to Villanueva’s retaliation for Plaintiff being a whistleblower and for
7
reporting and opposing FEHA violations, and violation of Plaintiff’s civil rights and rights under
8
the Public Safety Officers’ Bill of Rights, and defamatory statements, the Plaintiff suffers from
9
extreme emotional distress and huge losses in income. Plaintiff has a damaged reputation due to
10
the frame up by Villanueva and false statements he has made to the media and public. Plaintiff
11
has a logical fear of future retaliation by the Sheriff and the Undersheriff and LASD and her
12
career at LASD and law enforcement is over. Plaintiff subsequently suffers from a loss of
13
substantial future earnings.
14

15 95. The County of Los Angeles is liable for all misconduct and harms against

16 Plaintiff, including for racial discrimination, intentional infliction of emotional distress, because

17 the County ratified all the wrongful conduct. LASD and the County did absolutely nothing to

18 curb the sheriff’s abuse of power, abuse of LASD employees, and abuse of County residents.

19 LASD initiated no investigation into the corrupt practices including rigged IAB and ICIB

20 investigations against Plaintiff, the widely disseminated false statements smearing the Plaintiff
21 and Assistant Sheriff Limon, and Commander Castellano, and the ending of Plaintiff’s career.
22 The County took zero actions to hold the sheriff and LASD accountable for their malicious
23
actions against the Plaintiff. The County has done nothing to protect its employees and residents
24
from the rotting corruption at LASD.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 24

 1 96. The County is liable for the Sheriff’s misconduct. However, the Sheriff is also

2 personally liable for defamation for the malicious false statements he has made about

3 Plaintiff as part of his cover up and to retaliate against Plaintiff for reporting misconduct.
4 The Plaintiff again calls on the Sheriff to immediately cease and desist in making
5
knowingly false statements about the Plaintiff.
6
97. The County’s own Inspector General has made the party admission on behalf of the
7
County that Sheriff Alex Villanueva and County employee Deputy Douglas Johnson may have
8
committed the following violations and/or crimes: 1) The First Amendment of the United States
9
Constitution (See, e.g. Garcetti v. Ceballos, 547 U.S. 41O (2006) (While a public employer can
10
regulate on-duty speech, the 1st Amendment protects some public speech by employees about
11
their employment including the public reporting of misconduct); The Fourth and Fourteenth
12
Amendments of the United States Constitution protect against police seeking charges without
13
probable cause. (See, e.g., Thompson v. Clark, 596 U.S. (2022; The Fourth, Eighth, and
14

15 Fourteenth Amendments to the United States Constitution prohibiting the use of excessive force;

16 California Labor Code section 1102.5 prohibiting an employer from retaliating against

17 employees who report potential violations of law to a governmental agency; California Penal

18 Code section 13670 prohibiting law enforcement gangs, including groups of peace officers who

19 engage in a pattern of on duty illegal behavior or behavior which violates fundamental principles

20 of professional policing, and provides for inspector general investigation; California Penal Code
21 section 13510.8, which provides for decertification of a peace officer who participates in a law
22 enforcement gang or fails to cooperate with an investigation of potential police misconduct after
23
January1, 2022; California Penal Code section 518, which prohibits threatening a public official
24
to influence official duties. In addition to those possible crimes and violations, Plaintiff alleges
25
upon information and belief that Sheriff Villanueva committed other possible crimes and

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 25

 1 violations including obstruction of justice. Villanueva also violated laws against racial

2 discrimination.

4 THE WRONGFUL CONDUCT COMMITTED BY THE DEFENDANTS HAS BEEN

5
CONTINUOUS AND ONGOING
6
98. All of the acts of violation of state laws and policies, making false statements,
7
demotion, and retaliation are timely under the continuing violation doctrine because,
8
commencing in 2019 and continuing through the filing of this complaint, the Defendants
9
subjected the Plaintiff to a series of adverse actions that were similar-in-kind, i.e., were
10
motivated by the same discriminatory or retaliatory animus, even if otherwise different actions,
11
occurred with reasonable frequency, and did not acquire permanence at the earliest until the
12
Plaintiff filed her complaint here. Defendants therefore remain liable for this entire course of
13
conduct, including acts predating any statutory period in as much as at least one, and, here,
14

15 many, of the acts occurred within the statutory period.

16 99. Sheriff Alex Villanueva is employed by the County of Los Angeles, in the Los

17 Angeles County Sheriff’s Department. Villanueva serves as the head of LASD and is the top

18 spokesperson for the Department. Villanueva is responsible for managing, supervising, and

19 disciplining all employees in the Department including LASD deputies.

20 100. Sheriff Villanueva is the supervisor of the Plaintiff and is responsible for
21 investigations of unlawful conduct. Villanueva is also obligated to take disciplinary action for
22 misconduct and to protect deputies, including the Plaintiff, against threats, intimidation, and
23
retaliation in all forms.
24
101. Plaintiff is informed and believes and thereupon alleges that Defendants, whether
25
individual, corporate, associate or otherwise, are unknown to Plaintiff at this time, who therefore

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 26

 1 sue said Defendants by such fictitious names. Plaintiff will amend this complaint to show their

2 true names and capacities, together with appropriate charging language, when such information

3 is ascertained. Plaintiff will file DOE amendments, and/or ask leave of court to amend this
4 Complaint to assert the true names and capacities of these Defendants when they have been
5
ascertained.
6
102. Plaintiff is informed and believes, and upon, such information and belief alleges,
7
that each Defendant designated as a DOE was and is in some manner, negligently, wrongfully, or
8
otherwise responsible and liable to Plaintiff for the injuries and damages hereinafter alleged and
9
that Plaintiffs’ damages as herein alleged were proximately caused by their conduct.
10
103. Plaintiff is informed and believe, and thereupon alleges, that at all times material
11
herein that the Defendants, including the Doe Defendants, each and all of them, were the agents,
12
servants and employees, or ostensible agents, servants or employees of Defendant County of Los
13
Angeles, who owns, controls, supervises, manages and is responsible for the Los Angeles
14

15 County Sheriff’s Department, and the County of Los Angeles is therefore directly and

16 vicariously liable for the conduct of LASD, its top official, Sheriff Villanueva, John Satterfield,

17 and other employees, all of the Defendants were acting within the course and scope of said

18 agency and employment or ostensible agency and employment, except on those occasions when

19 Defendants were acting as Principals, in which case, said Defendants, including Defendant

20 County, and each of them, were negligent in the selection, hiring and use of the other
21 Defendants.
22 104. Plaintiff has complied with and/or exhausted any applicable claims, statutes
23
and/or administrative and/or internal remedies and/or grievance procedures or are excused from
24
complying therewith. Plaintiff filed a government claim with the County of Los Angeles on May
25
4, 2022. The Plaintiff applied for and was timely issued a Right-to-Sue Notice. Accordingly,

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 27

 1 Plaintiff has timely exhausted her administrative remedies. True-and-correct copies of Plaintiff’s

2 Right-to-Sue Notice is attached to this complaint.

4 FIRST CAUSE OF ACTION FOR

5
RACE DISCRIMINATION IN VIOLATION OF THE CALIFORNIA FAIR
6
EMPLOYMENT AND HOUSING ACT
7
(AGAINST DEFENDANT COUNTY OF LOS ANGELES)
8
105. Plaintiff re-alleges and incorporates herein by reference the preceding 104
9
paragraphs, as if fully set forth herein.
10
106. In relevant part, California Government Code section 12940(a) provides that it
11
shall be unlawful for an employer to discriminate against an employee in the terms and
12
conditions of his employment because of his race or ethnicity.
13
107. Plaintiff Chief of Court Services Division LaJuana Haselrig is an African
14

15 American targeted for her race by Villanueva and LASD and is thus at all times mentioned

16 herein in the protected class of persons, i.e., a race, and engaged in protected activities

17 contemplated by Government Code sections 12940, et. seq.

18 108. Plaintiff is informed and believes that the Defendant County and Sheriff

19 Villanueva treated her adversely based on her race and for reporting and speaking out against

20 wrongful and discriminatory treatment based on her race, and for generally attempting to protect
21 and secure her rights under FEHA.
22 109. As part of the discrimination, Villanueva has made it clear in public statements
23
that he has a racist chip on his shoulder, racial resentments, engaging in generalizations and false
24
statements about African Americans, and blames African Americans (the entire African
25
American race) for supposedly holding him back in his career. On March 24, 2022, in a media

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 28

 1 interview, Villanueva claimed that the “overwhelming majority” of those assaulting Asian

2 victims of hate crimes are “black.” This is false. Villanueva also seeks to pit Latinos against

3 African Americans as if there is a racial contest. In the same infamous interview, Villanueva
4 complained of looking at a wall of photos of division chiefs and said, “I counted nine Black
5
division chiefs… and I thought to myself, ‘Nine [“blacks] and one [Latinos].” In the same
6
interview, Villanueva complained there were too many black writers at the Los Angeles Times,
7
saying “for every Black reporter, you expect to see four Latino.”
8
110. In addition, inside LASD, Villanueva is likewise known for racism and bias
9
towards African Americans, calling an African American “knuckle dragger,” and refusing to
10
discipline his Undersheriff Timothy Murakami for calling employees the Japanese language
11
version of the “n” word.
12
111. Villanueva is waging a race war against African Americans. Villanueva has
13
engaged in grand scale racial discrimination against African Americans seeking employment as
14

15 deputies. Villanueva rigged the hiring process to hire more Latino deputies aimed clearly at the

16 expense of African Americans applicants, to, in Villanueva’s mind, to cause a more favorable

17 Latino to African American ratio.

18 112. Further, when Plaintiff expressed to Villanueva that she hoped there would be

19 fairness and opportunity for qualified African Americans to promote in the department,

20 Villanueva dismissively told her that “we have enough of you [black people]” meaning enough
21 African Americans in management, indicating a bias against African Americans seeking earned
22 promotions. Plaintiff has observed that Sheriff Villanueva simply does not like African
23
American people.
24
113. Villanueva has also made racist statements about blocking promotions of “white”
25
people.

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 29

 1 114. Villanueva separately retaliated against the Plaintiff for being a whistleblower

2 reporting his crimes. But there is no question that race was also a substantial motivating factor

3 here as well. But for Plaintiff being black, Villanueva would not have taken such malicious
4 actions towards her. As corrupt and unethical as it was to frame Assistant Sheriff Limon, there
5
was a certain logic for the sheriff to engage in this tactic. The cover up came from above the rank
6
of chief, and Limon was third in line and the other upper ranking official other than undersheriff
7
Murakami and Villanueva who saw the UOF video in March 2021. However, the sheriff
8
included Plaintiff in the frame up to punish her for being a whistleblower and to eliminate an
9
African American from the executive ranks at LASD.
10
115. FEHA defines “employer” broadly to encompass “any person regularly
11
employing five or more persons, or any person acting as an agent of an employer, directly or
12
indirectly.” California Government Code § 12926(d). Here, the Defendant County was the
13
employer of the Plaintiff, and the individual Defendant Sheriff Villanueva is an agent of the
14

15 Defendant County. As set forth above, the Defendant County discriminated against the Plaintiff

16 because of her race and ethnicity. Defendants engaged in illegal, intentional discrimination, as

17 the Plaintiff was treated differently than deputies of other races and was subjected to adverse

18 employment actions. Plaintiff regularly complained to the Defendant County regarding

19 discrimination, but Defendant allowed the discrimination to continue.

20 116. Plaintiff Haselrig is informed and believes that the County discriminated against
21 her based on her race and for reporting and speaking out against wrongful and discriminatory
22 treatment based on her race, speaking out against improper conduct, and for generally attempting
23
to protect and secure her rights and rights of others under the FEHA.
24
117. Early in 2019, Plaintiff witnessed the Sheriff deny the opportunity for a qualified
25
Lieutenant, initials “TS” an opportunity to interview for an open captain position, because she

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 30

 1 was African American, and out of retaliation. Plaintiff objected to the illegal denial of

2 opportunity and reminded the sheriff that the lieutenant met his new prerequisites to interview.

3 118. On another occasion, Plaintiff informed the sheriff that LASD is required under
4 the law to give both female and males an opportunity to interview for captain or other positions
5
if they are qualified regardless of race. But Villanueva stated that there were “enough whites
6
promoted.” After reporting on the sheriff’s illegal conduct, Plaintiff was no longer allowed to
7
attend the sheriff’s administration meetings.
8
119. Sheriff Villanueva transferred another lieutenant, initials J.L., apparently because
9
he is African American. J.L. was hired as Undersheriff Timothy Murakami’s aide. However,
10
after J.L. was on the job as the aide for just two days, the sheriff walked into the undersheriff’s
11
office, looked at J.L., and had him removed from the position. Plaintiff informed Villanueva that
12
J.L. was perfectly qualified for the position and there was no legal basis for removing him as the
13
aide. The sheriff ignored the notice by Plaintiff.
14

15 120. The sheriff constructively terminated the Plaintiff because he harbored racial

16 animus towards her for being black.

17 121. At all times herein mentioned, the Defendant County had actual and/or

18 constructive knowledge of the discriminatory conduct levied against the Plaintiff by the

19 Defendant. Moreover, such retaliation, and discriminatory conduct was also condoned by the

20 Defendant County.
21 122. As a direct, foreseeable, and proximate cause of Defendants’ discriminatory,
22 retaliatory conduct and failure to act, Plaintiff suffered humiliation, embarrassment, anxiety,
23
mental anguish, and symptoms of extreme distress.
24
123. Plaintiff was a Chief of Court Services Division and by all objective accounts a
25
highly qualified employee of LASD. Defendant destroyed Plaintiff’s career at LASD.

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 31

 1 Subsequently, Plaintiff has lost substantial future income.

2 124. As a further legal result of the above-described conduct of Defendants, Plaintiff

3 has and will continue to incur attorneys’ fees and in costs amount according to proof.
4 125. Defendants’ actions were ratified by managing agents, and were willful,
5
malicious, fraudulent, and oppressive, and were committed with wrongful intent to harm Plaintiff
6
in conscious disregard of her rights.
7
126. Plaintiff timely exhausted administrative remedies.
8

9
SECOND CAUSE OF ACTION FOR
10
VIOLATION OF THE CALIFORNIA FAIR EMPLOYMENT & HOUSING ACT –
11
FAILURE TO TAKE ALL REASONABLE STEPS TO PREVENT DISCRIMINATION
12
(AGAINST DEFENDANT COUNTY OF LOS ANGELES)
13
127. Plaintiff re-alleges and incorporates herein by reference the preceding 126
14

15 paragraphs, as if fully set forth herein.

16 128. Defendant failed to take all reasonable steps necessary to prevent the

17 aforementioned discrimination to which Plaintiff was subjected in violation of California

18 Government Code Section 12940(k). The County knew that Plaintiff belonged to a protected

19 class (African American) and that she was treated differently than other officials who were of a

20 different race.
21 129. Sheriff Villanueva has made blatantly racist statements in the media as well as in
22 the workplace. The County has long been on notice of his virulent racism.
23
130. The conduct, statements and acts described herein were an ongoing part of a
24
continuing scheme and course of conduct. Defendant County knew the substance of the above-
25
described facts and circumstances and ratified the wrongs and injuries mentioned herein when it

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 32

 1 was in its ability to prevent, remedy and/or correct these wrongs. Defendant continued to ratify

2 and refused to remedy the aforementioned conduct, notwithstanding the fact that its officials,

3 supervisors and/or managing agents knew or reasonably should have known, and know or
4 reasonably should know, of the conduct and its unlawful motivations.
5
131. As a direct and proximate result of Defendant’s conduct, Plaintiff has suffered
6
special damages in the form of lost earnings, benefits and/or out of pocket expenses in an amount
7
according to proof at the time of trial. As a further direct and proximate result of Defendant’s
8
conduct, Plaintiff will suffer additional special damages in the form of lost future earnings,
9
benefits, and/or other prospective damages in an amount according to proof at the time of trial.
10
132. As a further direct and proximate result of Defendant’s conduct, Plaintiff has
11
suffered mental and emotional pain, distress and discomfort, and damages to her occupational
12
reputation, all to the detriment and damage in amounts not fully ascertained but within the
13
jurisdiction of this court and subject to proof at the time of trial. The Defendant County allowed
14

15 and sanctioned and supported discrimination of the Plaintiff up to the point of the Plaintiff’s life

16 and career in LASD being destroyed.

17 133. Plaintiff was forced out of her job and career and constructively terminated by

18 LASD and the County.

19 134. In engaging in the conduct alleged herein, Defendant acted maliciously toward

20 Plaintiff, with conscious disregard for her known rights and with the intention of causing, and/or
21 willfully disregarding the probability of causing, unjust and cruel hardship to Plaintiff Haselrig.
22 135. Plaintiff is entitled to costs and reasonable attorneys’ fees pursuant to California
23
Government Code section 12965(b).
24

25
THIRD CAUSE OF ACTION FOR

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 33

 1 UNLAWFUL RETALIATION: LABOR CODE § 1102.5

2 (WHISTLEBLOWER LAW)

3 (BY PLAINTIFF AGAINST DEFENDANT COUNTY OF

4 LOS ANGELES)
5
136. Plaintiff re-alleges and incorporates by reference the allegations in the preceding
6
135 paragraphs.
7
137. Cal. Labor Code § 1102.5 prohibits retaliation against any employee for
8
disclosing information, or because the employer believes that the employee disclosed or may
9
disclose information, to a government or law enforcement agency, or to a superior in the
10
employer's organization, so long as the employee has reasonable cause to believe that the
11
information discloses a violation of law or regulation. This statute reflects the “broad public
12
policy interest in encouraging workplace whistleblowers to report unlawful acts without fearing
13
retaliation.” Green v. Ralee Eng. Co. (1998) 19 Cal.4th 66, 77-78.
14

15 138. The Court in Yanowitz v. L'Oreal USA, Inc. and held that “In determining whether

16 there was an adverse employment action to show discrimination or retaliation, courts look at the

17 totality of circumstances and not just at each isolated act. (Yanowitz v. L'Oreal USA, Inc. (2005)

18 36 Cal.4th 1028, 1055 (“we need not and do not decide whether each alleged retaliatory act

19 constitutes an adverse employment action in and of itself.”); Adverse employment actions can

20 include demotions, reassignments, refusals to promote, unwarranted evaluations, tolerating

21 harassment by co-workers, reprimands and/or suspensions. (Yanowitz, supra, 36 Cal.4th at 1061.)
22 "Minor or relatively trivial adverse actions or conduct by employers or fellow employees that,
23
from an objective perspective, are reasonably likely to do no more than anger or upset an
24
employee cannot properly be viewed as materially affecting the terms, conditions, or privileges
25
of employment and are not actionable, but adverse treatment that is reasonably likely to impair a

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 34

 1 reasonable employee's job performance or prospects for advancement or promotion falls within

2 the reach of the antidiscrimination provisions of ‚ [the FEHA]." (Id. at 1054-1055.) "[A] hostile

3 work environment can constitute [an] ‚ adverse employment action." (Id. at 1054.)
4 139. “The retaliatory motive is ‘proved by showing that plaintiff engaged in protected
5
activities, that his employer was aware of the protected activities, and that the adverse action
6
followed within a relatively short time thereafter.’ The causal link may be established by an
7
inference derived from circumstantial evidence, ‘such as the employer's knowledge that the
8
[employee] engaged in protected activities and the proximity in time between the protected
9
action and allegedly retaliatory employment decision.’ (Morgan v. Regents of University of Cal.
10
(2000) 88 Cal.App.4th 52, 69.) [ Zibli v. City of Los Angeles, 2019 WL7753387 (2019)]
11
140. Plaintiff repeatedly spoke out about illegal conduct and refused to carry out
12
practices and acts that would have been rule and law violations. The Plaintiff pushed back
13
against the sheriff’s discriminatory statements and hiring practices and his expressed intent to
14

15 break the law and retaliate against whistleblowers. Villanueva threatened on several occasions to

16 “get” whistleblowers for sharing information about his wrongful conduct. Plaintiff reported to

17 the sheriff that it is illegal to retaliate against whistleblowers and argued for him to stop such

18 conduct.

19 141. The Plaintiff resisted and spoke out about the sheriff’s criminal conduct, including

20 the offense of obstruction of justice, in Villanueva’s efforts to block a criminal investigation into
21 an excessive use of force and to cover it up. Plaintiff spoke out about and stopped Villanueva’s
22 efforts to violate rules and laws in relation to the Court Services Division, as Villanueva sought
23
to remove most of the SOU team, based on his vendetta against the BOS. Plaintiff refused to
24
dismantle the unit.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 35

 1 142. Plaintiff grew increasingly concerned about Villanueva’s criminal conduct. When

2 the sheriff was exposed in the media for obstructing justice in the Escalante matter, Villanueva

3 framed and defamed the Plaintiff and forced her out of her career.
4 143. The Defendants retaliated against the Plaintiff for disclosing violations of or
5
noncompliance with County, state and/or federal labor laws to person(s) with authority over her
6
and/or to other employees who had authority to investigate, discover, or correct the violations or
7
noncompliance, which they had reasonable cause to believe had taken place.
8
144. At all times herein mentioned, the Defendant County had actual and/or
9
constructive knowledge of the retaliatory conduct levied against the Plaintiff by Villanueva. The
10
County ratified the conduct of its employees as it gave no discipline and did no intervention to
11
stop any of the wrongful actions of the employees.
12
145. The Defendant destroyed Plaintiff’s career at LASD, and she was constructively
13
terminated.
14

15 146. As a direct, foreseeable, and proximate cause of Defendants’ retaliatory conduct

16 and failure to act, Plaintiff suffered humiliation, embarrassment, anxiety, mental anguish, and

17 symptoms of extreme distress.

18 147. As a further legal result of the above-described conduct of Defendants, Plaintiff

19 has and will continue to incur attorneys’ fees and in costs amount according to proof.

20 148. Defendants’ actions were ratified by managing agents, and were willful,
21 malicious, fraudulent, and oppressive, and were committed with wrongful intent to harm Plaintiff
22 in conscious disregard of her rights.
23
149. Plaintiff timely exhausted administrative remedies.
24

25
FOURTH CAUSE OF ACTION FOR

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 36

 1 RETALIATION IN VIOLATION OF FEHA

2 (CAL. GOV. CODE SECTION 12940 et. seq,)

3 (BY PLAINTIFF AGAINST DEFENDANT COUNTY

4 OF LOS ANGELES)
5
150. Plaintiff re-alleges and incorporates by reference the allegations in the 149
6
preceding paragraphs.
7
151. “[I]n order to establish a prima facie case of retaliation under the FEHA, a
8
plaintiff must show (1) he or she engaged in a “protected activity,” (2) the employer subjected
9
the employee to an adverse employment action, and (3) a causal link existed between the
10
protected activity and the employer's action. Once an employee establishes a prima facie case,
11
the employer is required to offer a legitimate, nonretaliatory reason for the adverse employment
12
action. (Yanowitz v. L'Oreal USA, Inc. (2005) 36 Cal.4th 1028, 1042) [Zibli v. City of Los
13
Angeles, et.al 2019 WL 7753387 (Cal.Super.) (2019)]
14

15 152. At all times mentioned herein, Government Code § 12940, et seq. was in full

16 force and effect and was binding upon Defendants. Said law requires Defendants to refrain from

17 retaliating against an employee for reporting discriminatory employment practices prohibited

18 under FEHA.

19 153. At all times mentioned, Plaintiff engaged in protective activities contemplated by

20 Government Code § 12940, et seq. Plaintiff is informed and believes that Defendants, and each
21 of them, retaliated against her for reporting and speaking out against wrongful and
22 discriminatory, harassing, and retaliatory treatment based on race, ethnicity, and national origin,
23
speaking out against improper conduct, and for generally attempting to protect and secure rights
24
of others under FEHA.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 37

 1 154. Defendants created and allowed to exist a pattern of illegal and discriminatory

2 hiring practices and fraudulent acts and retaliated against Plaintiff when she spoke out about

3 racial discrimination.
4 155. During Plaintiff’s tenure as Chief of Court Services Division, she has witnessed
5
and endured abusive, racist, and sexist language used by the Sheriff. This language has been used
6
to describe various Department members employees, elected and appointed officials, and
7
members of the public. Villanueva blocked any disciplinary action toward Undersheriff
8
Murakami when he was caught using the Japanese equivalent of the “n” word towards other
9
employees. Villanueva expresses animosity toward African Americans, blaming “them” for
10
holding him back in his career. Villanueva told Plaintiff “We have enough of you’ [black people)
11
in executive positions in LASD. Villanueva has actively worked to lessen the number of African
12
Americans as executives and as new deputies working in LASD.
13
156. Defendants created and allowed to exist a hostile work environment and retaliated
14

15 against Plaintiff based on her speaking out about the discriminatory and harassing employment

16 practices of the Defendant. Such retaliation was in violation of Government Code § 12940, et

17 seq. and the public policy embodied therein.

18 157. At all times herein mentioned, the Defendant County had actual and/or

19 constructive knowledge of the retaliatory conduct levied against the Plaintiff by Sheriff

20 Villanueva. Moreover, such retaliation, and discriminatory conduct was also conducted and/or
21 condoned by the Defendant County. The County, through its leadership ratified the
22 discriminatory, and retaliatory conduct of its employees, as there was no intervention by the
23
County to fairly investigate the allegations made by the Plaintiff, and no employees of LASD
24
were held accountable for their wrongful actions.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 38

 1 158. As a direct, foreseeable, and proximate cause of Defendants’ retaliatory conduct

2 and failure to act, Plaintiff suffered loss of salary, and other injury, including humiliation,

3 embarrassment, anxiety, mental anguish, depression, and extreme emotional distress.

4 159. Plaintiff was forced out of her job and career and was constructively terminated
5
by LASD.
6
160. As a result of Defendants’ wrongful conduct, Plaintiff was forced to retire as
7
Chief of Court Services Division. Plaintiff was illegally terminated and her long career in law
8
enforcement is over and illegally destroyed by Defendant County of Los Angeles and its
9
employees. Plaintiff suffers from a loss of substantial future earnings.
10
161. As a further legal result of the above-described conduct of Defendants, and each
11
of them, Plaintiff has and will continue to incur attorneys’ fees and in costs amount according to
12
proof.
13
162. Defendants’ actions were ratified by managing agents, and were willful,
14

15 malicious, fraudulent, and oppressive, and were committed with wrongful intent to harm Plaintiff

16 in conscious disregard of his rights.

17 163. Plaintiff timely exhausted administrative remedies by applying for and being

18 issued the Right-to-Sue Letter.

19

20 FIFTH CAUSE OF ACTION FOR INTENTIONAL

21 INFLICTION OF EMOTIONAL DISTRESS
22 (BY PLAINTIFF AGAINST DEFENDANTS COUNTY OF
23
LOS ANGELES AND SHERIFF ALEX VILLANUEVA, DOES 1-10)
24
164. Plaintiff re-alleges and incorporates by reference the allegations in the 163
25
preceding paragraphs.

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 39

 1 165. "The elements of the tort of intentional infliction of emotional distress are: ' "(1)

2 extreme and outrageous conduct by the defendant with the intention of causing, or reckless

3 disregard of the probability of causing, emotional distress; (2) the plaintiff's suffering severe or
4 extreme emotional distress; and (3) actual and proximate causation of the emotional distress by
5
the defendant's outrageous conduct...." Conduct to be outrageous must be so extreme as to
6
exceed all bounds of that usually tolerated in a civilized community. 'The defendant must have
7
engaged in 'conduct intended to inflict injury or engaged in with the realization that injury will
8
result.' (Christensen, supra, 54 Cal.3d at p. 903) (Potter v. Firestone Tire & Rubber
9
Co. (1993) 6 Cal.4th 965, 1004.)
10
166. Severe emotional distress means " 'emotional distress of such substantial quality
11
or enduring quality that no reasonable [person] in civilized society should be expected to endure
12
it. (Potter v. Firestone Tire & Rubber Co. (1993) 6 Cal.4th 965, 1004.)
13
167. Here, the Defendants’ conduct meets all the elements of an action for Intentional
14

15 Infliction of Emotional Distress, as the Defendants acted intentionally or recklessly towards the

16 Plaintiff; the Defendants’ conduct toward the Plaintiff was extreme and outrageous; the

17 Defendants’ actions were the cause of the Plaintiff’s emotional distress; and the Plaintiff suffered

18 extreme emotional distress.

19 168. The Workers’ Compensation preemption doctrine does not apply here to release

20 the County from liability, the Plaintiff was discriminated against based on race and because the
21 County ratified all the wrongful conduct. LASD and the County did absolutely nothing to curb
22 the sheriff’s abuse of power, abuse of LASD employees, and abuse of County residents. LASD
23
initiated no investigation into the sheriff’s wrongful conduct and took zero actions to hold the
24
sheriff and LASD accountable for what they did to Plaintiff. The County ratified the conduct by
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 40

 1 failing to properly investigate the work environment for years and continuously failed to hold the

2 wrongdoers accountable for their conduct.

3 169. In addition, the conduct which gives rise to this cause of action, and which is
4 described above violates FEHA and statutory whistleblower protections and therefore
5
contravenes public policy.
6
170. The wrongful conduct against Plaintiff rises above mere insults and indignities
7
and rises to the level of extreme and outrageous. When the sheriff was caught obstructing justice
8
with the leak of the video of excessive force to the media, Sheriff Villanueva first denied that he
9
engaged in a cover up. Then, shortly after, Villanueva reversed course and admitted that his
10
administration, and therefore the County of Los Angeles, engaged in crimes, covering up the
11
excessive force incident. However, to cover for his own culpability, Villanueva then
12
outrageously, without any investigation or evidence, smeared the Plaintiff and Assistant Sheriff
13
Limon, and lied that they were the ones who obstructed justice and committed the cover up.
14

15 Villanueva led the public and Plaintiff’s family to believe that Plaintiff was a disgraced law

16 enforcement official forced out of her job due to her corruption.

17 171. In order to retaliate against and discredit the whistleblower Plaintiff, Villanueva

18 destroyed her career and life. This was all done in public view and with full awareness of all who

19 worked for LASD. Yet, no one from the County intervened to protect its employee, the Plaintiff

20 from this malicious, monstrous act by the sheriff.

21 172. Any reasonable person, any member of the public would see the misconduct of
22 Defendant Villanueva as crazy, extreme, outrageous and a shock to the conscience. Instead of
23
upholding the law and department policies, protecting the whistleblowers, conducting a fair and
24
honest investigation into the claims made by the whistleblowers, the sheriff framed the Plaintiff
25
and destroyed the highly qualified Plaintiff’s career and life.

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 41

 1 173. Defendant Villanueva’s conduct was ruthlessly willful and utterly beyond the

2 standards of decency and would be seen as such by any reasonable person.

3 174. Defendants Villanueva and the Los Angeles County knew and certainly should
4 have known that their outrageous conduct would cause any person in society, including the
5
Plaintiff, extreme emotional distress. Defendants’ conduct did cause Plaintiff to suffer from
6
extreme distress, tortuous mental anguish, intense and ongoing insomnia and anxiety, panic
7
attacks, and depression.
8
175. The Plaintiff remains extremely emotionally distressed by the wrongful conduct
9
of Defendant Villanueva and other LASD employees. Defendant Villanueva was acting under
10
agency of the County, which is vicariously liable for infliction of emotional distress directed at
11
the Plaintiff.
12
176. In engaging in the conduct alleged herein, Defendant Villanueva acted
13
oppressively, maliciously, fraudulently, and/or outrageously toward the Plaintiff, with conscious
14

15 disregard for her known rights and with the intention of causing, and/or willfully disregarding

16 the probability of causing, unjust and cruel hardship to the Plaintiff.

17 177. The Plaintiff has timely exhausted administrative remedies.

18

19 SIXTH CAUSE OF ACTION FOR

20 DEFAMATION/SLANDER AND LIBEL PER SE

21 (BY PLAINTIFF AGAINST DEFENDANTS COUNTY OF LOS ANGELES,
22 SHERIFF ALEX VILLANUEVA, JOHN SATTERFIELD, DOES 1-10)
23
178. Plaintiff re-alleges and incorporates by reference the allegations in the preceding
24
177 paragraphs.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 42

 1 179. Cal. Civil Code § 46(i)(iii)(v) provides that slander is a false and unprivileged

2 publication, orally uttered, and also communications by radio or any mechanical or other means

3 which: charges any person with crime, or with having been indicted, convicted, or punished for
4 crime; tends directly to injure him in respect to his office, profession, trade or business, either by
5
imputing to him general disqualification in those respects which the office or other occupation
6
peculiarly requires, or by imputing something with reference to his office, profession, trade, or
7
business that has a natural tendency to lessen its profits; or which, by natural consequence,
8
causes actual damage.
9
180. Defamation is an invasion of the interest in reputation. The tort involves the
10
intentional publication of a statement of fact that is false, unprivileged, and has a natural
11
tendency to injure or which causes special damage. (Civ. Code, §§ 45, 46; 5 Witkin, Summary of
12
Cal. Law (9th ed. 1988) Torts § 471, pp. 557-558.) Publication means communication to some
13
third person who understands the defamatory meaning of the statement and its application to the
14

15 person to whom reference is made. Publication need not be to the "public" at large;

16 communication to a single individual is sufficient. (Cunningham v. Simpson (1969) 1 Cal. 3d

17 301, 306 [81 Cal. Rptr. 855, 461 P.2d 39]; 5 Witkin, Summary of Cal. Law, supra, Torts, §§ 471,

18 476, pp. 557-558, 560-561.) (Smith v. Maldonado (1999) 72 Cal. App. 4th 637, 645 [85 Cal.

19 Rptr.2d 397])

20 181. Here, as part of Defendant Villanueva’s cover up, he maliciously lied and framed
21 Plaintiff and told the media and public, a national audience, that Plaintiff committed
22 Villanueva’s crimes and other misconduct, that she did the cover up and obstruction of justice
23
that Defendant Villanueva himself did. Defendant Villanueva is personally liable for defamation,
24
and the County is vicariously liable for his conduct.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 43

 1 182. In May 2022, Defendant Chief of Staff, Commander John Satterfield joined

2 Villanueva in committing crimes related to the UOF. Satterfield signed his name to what he

3 knew to be a fake memo designed to cover up Villanueva’s obstruction of justice and to further
4 frame the Plaintiff. Villanueva backdated the memo to May 1, 2022. The memo was clearly
5
written for purposes of litigation and is not a memo written in the normal course of business.
6
Yet, Villanueva and Satterfield manipulated two media outlets into reporting on the memo as if it
7
was some “leaked LASD” document, which exonerated Villanueva. In truth, the memo does not
8
exonerate Villanueva as it is full of glaring holes, inconsistencies, and deficiencies, designed to
9
trick readers. The memo ultimately reinforces how there was a cover up of a use of excessive
10
force. Villanueva and Satterfield lie in the memo that Plaintiff engaged in the cover up and
11
committed gross management mistakes. There is zero possibility that the Defendants thought
12
their statements in this ludicrous memo were true.
13
183. In August 2022, Villanueva inappropriately revealed confidential information in a
14

15 post online and within LASD and announced that the District Attorney General convened a

16 grand jury investigation into the obstruction of justice on the UOF. In that post, Villanueva

17 engaged in further defamation, lying that he had done some internal investigation, and found

18 wrongdoing by the Plaintiff and the other whistleblowers. Villanueva made it look like Plaintiff

19 was the subject of the grand jury. Villanueva knows he is the target, the suspect and subject, as

20 he committed the crimes.

21 184. As a result of the Defendants’ frame up of Plaintiff her reputation is destroyed and
22 Plaintiff’s career in law enforcement is over. Chief Haselrig was illegally forced out and her
23
career beyond LASD is also over since Villanueva and Satterfield maliciously lied and framed
24
her with false statements and brutally retaliated against her.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 44

 1 185. Due to Defendants’ frame up, false, and malicious defamatory statements

2 published and made verbally and in writing to the media, within LASD, and the public against

3 Plaintiff, her reputation was severely damaged. Plaintiff suffers from a loss of substantial future
4 earnings.
5
186. Defendants knew that the statements were blatantly false at the time they made
6
them, as he maliciously sought out to destroy Plaintiff’s reputation as part of the Defendants’
7
retaliation.
8
187. The statements constitute Slander Per Se and Libel Per Se of Plaintiff and
9
damaged her in her trade, profession, and occupation.
10
188. The aforesaid defamatory statements made by Alex Villanueva and John
11
Satterfield were and are false and malicious and not privileged. Defendants made said statements
12
knowing the falsity thereof.
13
189. Defendants made the aforesaid defamatory statements with the intent to injure
14

15 Plaintiff’s good name and reputation and to interfere with her employment.

16 190. The aforesaid defamatory statements have harmed Plaintiff’s reputation; such

17 statements tend to injure and injured Plaintiff in her occupation. Plaintiff’s future employment

18 prospects have been destroyed. Plaintiff suffered general and actual damages, including

19 exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of

20 this Court, and which will be proven at trial.

21 191. Defendants’ false statements not only were a substantial factor in causing harm to
22 Plaintiff’s professional reputation and career, but also caused her shame, mortification, and hurt
23
feelings.
24
192. Defendants published their false statements with malice intended to injure
25
Plaintiff.

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 45

 1 193. Plaintiff is entitled to punitive damages against Defendants Villanueva and

2 Satterfield.

3 SEVENTH CAUSE OF ACTION FOR

4 FALSE LIGHT
5
(BY PLAINTIFF AGAINST DEFENDANTS COUNTY OF LOS ANGELES,
6
SHERIFF ALEX VILLANUEVA, JOHN SATTERFIELD, DAVID YOO, DOES 1-10)
7
194. Plaintiff re-alleges and incorporates by reference the allegations in the preceding
8
193 paragraphs.
9
195. As part of Defendant Villanueva’s cover up, he maliciously lied and framed
10
Plaintiff and put her in a false light to make it look like she engaged in a criminal act when in
11
truth Villanueva himself did the cover up. Defendant Villanueva is personally liable for putting
12
the Plaintiff in a false light.
13
196. In March 2021, Sheriff Villanueva saw video of an excessive use of force against
14

15 an inmate Enzo Escalante. Villanueva blocked the matter from being sent for criminal

16 investigation as part of his cover up and obstruction of justice.

17 197. On or about March 25, 2022, the Los Angeles Times ran an exposé of the

18 Villanueva cover up.

19 198. On March 29, 2022, 3 days after denying there was a cover up of the excessive

20 force on Escalante, and after the IAB investigation had been completed, reviewed, and
21 adjudicated with the Castellano receiving discipline, Villanueva changed his story once again,
22 and admitted his administration engaged in a cover up.
23
199. At the same time, in a defamatory frame up, the Sheriff claimed the cover up was
24
done by his staff and not himself. He announced he was taking action against two of his staff,
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 46

 1 Plaintiff, who was Castellano’s supervisor, and Assistant Sheriff Limon, communicating that

2 they, not he, had engaged in the cover up and improper handling of the UOF.

3 200. Defendant Villanueva demanded Plaintiff and Limon’s immediate retirement,

4 with the option of being demoted if they refused. Defendant Villanueva maliciously demoted
5
Assistant Sheriff Limon by several ranks and forced Plaintiff Haselrig out of her job, to cover up
6
his own role, and to retaliate against the whistleblowers.
7
201. Villanueva painted for the public, media, Plaintiff’s family members, and LASD
8
employees, the false picture of Plaintiff being an unethical disgraced public official, a criminal.
9
202. In May 2022, Defendant Chief of Staff, Commander John Satterfield joined
10
Villanueva in committing crimes related to the UOF, and further defamed Plaintiff with a
11
fraudulent memo. The memo was clearly written for purposes of litigation and is not a memo
12
written in the normal course of business. Villanueva and Satterfield manipulated two media
13
outlets into reporting on the memo as if it was some real, official “leaked LASD” document.
14

15 Villanueva and Satterfield lie in the memo that Plaintiff engaged in the Defendants’ cover up and

16 committed gross management mistakes.

17 203. In August 2022, Villanueva announced online that the District Attorney convened

18 a grand jury investigation into the obstruction of justice on the UOF. Villanueva lied that there

19 had been an internal investigation that found wrongdoing by the Plaintiff. Villanueva made it

20 look like Plaintiff was the target/subject of the grand jury.

21 204. On August 31, 2022, Villanueva and Defendant Deputy David Yoo lied to make it
22 appear Plaintiff and her attorney are criminals trying to avoid prosecution and stated that, “…
23
frivolous lawsuits against the department, all which seem to share a common thread: lack of
24
accountability for poor performance by the plaintiffs… demonstrably false statements… avoid
25
accountability or prosecution.”

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 47

 1 205. Due to Defendant Villanueva’s frame up, and his and Satterfield’s false

2 statements made to the media and the public against Plaintiff, her reputation was destroyed.

3 Defendants constructively terminated the Plaintiff. And Plaintiff’s ability to further her career
4 outside of LASD was destroyed due to her being putting in a false light by the Defendants.
5
Plaintiff suffers from a loss of substantial future earnings.
6
206. Defendants knew that the statements were blatantly false at the time they made
7
them, as they maliciously sought out to destroy Plaintiff’s reputation as part of the Defendants’
8
retaliation.
9
207. The aforesaid defamatory statements made by the Defendants were and are false
10
and malicious and not privileged. Defendants made said statements knowing the falsity thereof.
11
208. Defendants made the aforesaid defamatory statements with malice and with the
12
intent to injure Plaintiff’s good name and reputation and to interfere with her employment
13
209. Defendants’ false statements not only were a substantial factor in causing harm to
14

15 Plaintiff’s professional reputation and career, but also caused her shame, mortification, and hurt

16 feelings.

17 210. Defendants published their false statements with malice intended to injure

18 Plaintiff.

19 211. The aforesaid defamatory statements have harmed Plaintiff’s reputation; such

20 statements have a tendency to injure and have injured Plaintiff in her occupation, her future
21 business and employment prospects have been severely harmed, and Plaintiff will have to incur
22 substantial expense, in order to redress the harm she has suffered, all to Plaintiff’s general and
23
actual damages, including exemplary and punitive damages (against Villanueva and Satterfield),
24
in an amount which far exceeds the jurisdictional minimum of this Court, and which will be
25
proven at trial.

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 48

 1

2 EIGHTH CAUSE OF ACTION FOR

3 MALICIOUS AND UNLAWFUL VIOLATIONS OF THE PUBLIC SAFETY

4 OFFICERS’ BILL OF RIGHTS (POBR) UNDER GOVERNMENT CODE SECTIONS 3303
5
AND 3304; FAILURE TO COMPLY WITH THE ONE YEAR STATUTE OF LIMITATIONS
6
UNDER GOVERNMENT CODE SECTION 3304 (POBR)
7
(AGAINT DEFENDANT COUNTY OF LOS ANGELES, AND ALEX
8
VILLANUEVA, DOES 1-10)
9
212. Plaintiff repeats and reallege as though fully set forth herein and incorporates by
10
reference all the allegations in preceding 211 paragraphs.
11
213. Government Code section 3304(d) reads as follows “(d) (1) Except as provided in
12
this subdivision and subdivision (g), no punitive action, nor denial of promotion on grounds
13
other than merit, shall be undertaken for any act, omission, or other allegation of misconduct if
14

15 the investigation of the allegation is not completed within one year of the public agency’s

16 discovery by a person authorized to initiate an investigation of the allegation of an act, omission,

17 or other misconduct. In the event that the public agency determines that discipline may be taken,

18 it shall complete its investigation and notify the public safety officer of its proposed discipline by

19 a Letter of Intent or Notice of Adverse Action articulating the discipline that year, except as

20 provided in paragraph (2) The public agency shall not be required to impose the discipline within
21 that one-year period.”
22 214. Defendant County of Los Angeles, acting by and through its authorized agents,
23
officers, and representatives, maliciously violated Government Code 3304 by intentionally
24
violating the strict one-year Statute of Limitations of POBR.
25

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 49

 1 215. Sheriff Villanueva’s notices to discipline and the discipline imposed on Plaintiff

2 were made in bad faith, for improper purposes and were malicious and designed to cause

3 maximum injury to Plaintiff. The County intentionally violated the law and Plaintiff’s due
4 process rights; the County cannot argue that its leaders were merely negligent or reckless.
5
216. Villanueva obstructed justice and covered up an act of excessive use of force by a
6
deputy using the maneuver used by Officer Derek Chauvin to murder George Floyd. When the
7
efforts of Plaintiff and others got past the delays caused by Villanueva and the matter was finally
8
properly referred for a criminal investigation, Villanueva blamed the whistleblowers for the
9
delays in the investigation. Villanueva struck back at Commander Castellano for him having
10
integrity and initiated an IAB investigation into him in November 2021.
11
217. Under POBR, Villanueva had a one-year deadline to charge Plaintiff and the
12
others for negligence or wrongful conduct and to discipline them for it, by March 10, 2022. On
13
March 6, 2022, Villanueva had a written reprimand issued to Castellano, falsely claiming that
14

15 Castellano had made a mistake in the investigation and that this caused the delays that were

16 actually caused by Villanueva.

17 218. Later, in March 2022, after the door closed on Villanueva being able to legally

18 discipline the Plaintiff, Villanueva was exposed in the media and by whistleblowers for having

19 obstructed justice and for his cover up the use of excessive force. Without doing any

20 investigation, and with zero evidence to support him, Villanueva suddenly announced that
21 Plaintiff and Assistant Sheriff Limon were the ones who covered up the excessive force and
22 disciplined them by forcing them out of their jobs.
23
219. Villanueva violated state ordinance and law by sending Undersheriff Murakami to
24
Plaintiff’s home to fire her while she was out on medical leave. Under the law, an employee shall
25
not receive discipline, removal of position or demotion while off work due to a job relate injury.

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 50

 1 220. Defendant Villanueva’s attempt to discipline the Plaintiff are violations of

2 important provisions of the Public Safety Officers’ Bill of Rights, Government Code sections

3 3000- 3315. Pursuant to the language of Government Code 3309.5 (a) it is unlawful. As a further
4 direct and proximate result of Defendants’ conduct, Plaintiff has suffered mental and emotional
5
pain, distress and discomfort, and damages to her occupational reputation, and loss of wages, all
6
to her detriment and damage in amounts not fully ascertained but within the jurisdiction of this
7
court and subject to proof at the time of trial.
8
221. In engaging in the conduct alleged herein, Defendants acted maliciously toward
9
Plaintiff, with conscious disregard for his known rights and with the intention of causing, and/or
10
willfully disregarding the probability of causing, unjust and cruel hardship to Plaintiff.
11
222. As a further direct and proximate result of Defendants’ conduct, Plaintiff has
12
suffered mental and emotional pain, distress and discomfort, and damages to his occupational
13
reputation, all to his detriment and damage in amounts not fully ascertained but within the
14

15 jurisdiction of this court and subject to proof at the time of trial.

16 223. Plaintiff is entitled to costs and reasonable attorneys’ fees pursuant to California

17 Government Code section 12965(b).

18 224. Plaintiffs are informed and believe that each of said violation is punishable by the

19 maximum fines permitted by Government Code section 3309.5(e) in addition to those actual

20 damages he sustained.
21 225. Plaintiffs is entitled to $25,000 penalties levied against Villanueva and the County
22 for each malicious charge by the Defendant.
23

24
PRAYER FOR RELIEF
25
WHEREFORE, Plaintiff prays that the Court:

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 51

 1 1. For special damages for the Plaintiff, including but not limited to, lost earnings,

2 benefits and/or out-of-pocket expenses in an amount according to proof at the time of trial, all in

3 an amount set forth above and/or according to proof at the time of trial;
4 2. For Plaintiff further special damages, including but not limited to, lost future
5
earnings, benefits and other prospective damages in an amount set forth above and/or according
6
to proof at the time of trial, in the minimum of $5 million.
7
3. For Plaintiff general damages, including for pain and suffering, in an amount set
8
forth above and/or according to proof at the time of trial, and at a minimum of $10 million;
9
4. For interest: Pre-Judgment and Post-Judgment at the maximum legal rate;
10
5. For costs of suit; and attorney’s fees under FEHA, Civil Code § 1021.5, 42 U.S.C.
11
§ 1988, and any other applicable law;
12
6. The Plaintiff further prays that this Court grant such other and further equitable
13
relief as it may deem just and proper.
14

15

16
September 6, 2022
17 THE LAW OFFICES OF VINCENT MILLER
18
________________________________________
19
VINCENT MILLER, Attorney for Plaintiff
20

21
JURY TRIAL DEMAND
22
Plaintiff demands a jury trial on all issues so triable.
23

24

25 DATED: September 6, 2022

THE LAW OFFICES OF VINCENT MILLER

LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 52
 1

2 __________________________________

3 By VINCENT MILLER
Attorney for Plaintiff LaJuana Haselrig
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LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 53

 1

5 EXHIBIT A
6 RIGHT TO SUE LETTER
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LAJUANA HASELRIG v. COUNTY OF LOS ANGELES, ET AL. pg. 54