Terry M. Goldberg* Bradley C.

Gage*
LAW OFFICES

GOLDBERG & GAGE Milad Sadr

1\ Pnnnur:ihl p o l' Pru lcssiona l Law Comorntions

*A PROFESSIONAL LAW CORPORATION

~--------,~~------~
*A PROFESSIONAL LAW CORPORATION

23002 VICTORY BOULEVARD - WOODLAND HILLS, CA 91367- (818) 340-9252 - FAX (818) 340-9088
Email: ll!.o ldb crg'a ]w !ldbc rga.ndg;u:,c.t:ol11 Email: bgage(a)gold bcrgand.gage.co rn

April 25, 2017

Via Cettified Mail, Retu1n Receipt Requested

City of Baldwin Park 7016 2710 0000 8464 1841
City Clerk
14403 E. Pacific Ave.
Baldwin Pk, CA 91706

Re: Government Claim

Dear Sir or Madam:

Please consider this a notice of governmental claim.

A. NAME OF THE CLAIMANTS:

David Salcedo

B. ADDRESS TO SEND ALL NOTICES:

Law Offices of Goldberg & Gage, 23002 Victory Blvd., Woodland Hills, CA 91367.

C. THE DATE, PLACE AND OTHER CIRCUMSTANCES OF THE OCCURRENCE

OR TRANSACTIONS WHICH GIVE RISE TO THE CLAIMS ASSERTED:

The plaintiff was hired as Chief of Police for the City of Baldwin Park Police Department
March 13, 2017. Before being hired, Chief Salcedo was promised that he would remain a chief
for a long time and that he would receive pay increases. Defendants then failed to honor that
promise giving rise to a claim for Promissory estoppel - breach of promises of increased pay and
long term employment. In detrimental reliance on those promises Chief Salcedo gave up a
Captain's job at Inglewood PD.

Chief Salcedo was provided a written contact for his employment as the Chief. Hence,
ther wrongful termination of Chief Salcedo without cause is a breach of contract
(written/implied)
Government Claim
April 25, 2017
Page 2

The reason for the wrongful termination includes whistleblower retaliation. City
Councilman Ricardo Pacheco asked Chief Salcedo to engage in illegal or unethical activities
including but not limited to:

1. A request by Pacheco to dismiss a truancy ticket against a minor girl.

2. Pacheco wanted Chief Salcedo to tow away a truck with a large political banner
containing the face of Pacheco with donkey ears and big nose. The banner said "Stop,
Stop, Stop Ricardo pacheco CORRUPT politician" as well as showing Pacheco's face
next to a flag with the ears and nose described above. Pacheco cited a Baldwin Park
Ordinance for commercial trucks prohibiting them from parking and advertising a
business. However, Chief Salcedo explained to Councilmember Pacheco that the
Ordinance was not applicable because the truck was not advertising a business.
Moreover, the City was already believed to be in litigation for enforcingits ordinance.
Chief Salcedo also advised Pacheco that the City could not legally do anything because it
would impact the First Amendment Rights of the truck driver.

3. Pacheco was also concerned that Prestige Auto had the same sign up. Pacheco wanted
Chief Salcedo to have Code Enforcement check the auto shop and provide Pacheco with
an update. The implication was that Pacheco wanted trumped up charges against the auto
shop, which Chief Salcedo refused to implement causing pacheco angry. This occurred
on or about the day of termination (Wednesday April 19, 2017.)

4. In the media it was reported that Pachco said Chief Salcedo could not lead the police
department which was why he changed the vote from seeking Chief Salcedo to asking to
eliminate him. However, there was no notice, no evaluation, and no notice of
deficiencies in the Chiefs work performance .. (The vote to bring in Chief Salcedo was 3
to 2. The vote to eliminate him without cause was also 3-2 with Pacheco being the only
ne to change his position.),

5. Plaintiff also questioned the amount paid to the City Attorneys Office

Employees of the City the day afer termination ransacked the office of Chief Salcedo,
searching his special effects in violation of the Peace Officer's Bill of Rights, Items confiscated
included a memorandum written against a Captain who was about to be investigated. That
Captain has since been promoted and the investigation against him ended.

Further, Chief Salcedo's resume with personal information was released to the media in
violation of Penal Code 832.7 and the POBR.

D. GENERAL DESCRIPTION OF THE INJURY, DAMAGE OR LOSS INCURRED.

General, special (economic and non economic) damages without limitations : damages for
potential medical treatment; psychological treatment; psychiatric treatment; loss of earnings
opportunities and future earning opportunities; loss of reputation; embarrassment and
humiliation. Attorneys fees, and future attorneys fees, litigation costs and experts charges all in
a sum to be proven at time of trial and such other damages as presented at trial. Plaintiff also
Government Claim
April25, 2017
Page 3

suffered job loss, lost employment opportunities. Lost reputation, damages to reputation, and
such other damages as determined at time of trial.

E. NAME OF PUBLIC EMPLOYEES CAUSING THE INJURY, DAMAGE OR

LOSS TO COMPLAINANTS INCLUDE BUT ARE NOT LIMITED TO THE
FOLLOWING:

Ricardo Pacheco, City Council Member.

F. THE AMOUNT OF CLAIMED DAMAGES EXCEEDS $10,000 AND

JURISDICTION WILL BE PROPER IN LOS ANGELES SUPERIOR COURT.

If you contend this is not the proper location for a Governmental Claim, please advise of
the proper address. Further, if defendant contends there are any administrative claims or
remedies not pursued by complainant, please advise so that we can fulfill any administrative
remedy requirements now. Thank you.

Very truly yours,

Law Offices of Goldberg & Gage
A Partnership of Professional Law--orptlr-a.t'
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