Living Document — Facts and Exhibits Updated as New Evidence Is Received|§ 8547.10 · Policy 1100171
Bruin Watch
Procedural Compliance Verification
California Government Code § 8547.10 · UC Whistleblower Protection Policies 1100563 & 1100171

IV. Adverse Personnel Actions (2025–2026)

IV. Adverse Personnel Actions (2025–2026)

UC Whistleblower Protection Policy 1100563 § B (Definitions) & § C.1.a.ii
“Adverse Personnel Action — A management action taken with respect to a Complainant that affects the Complainant’s existing terms and conditions of employment in a material and negative way.”  |  The Complaint must describe each Adverse Personnel Action, identify the responsible University employee(s), and specify the date or approximate date.

The Adverse Personnel Actions catalogued below were not administrative errors. They were acts taken by sworn California peace officers and UC administrators functioning as state actors under color of authority — within the meaning of 42 U.S.C. § 1983 and 18 U.S.C. § 242 — whose collective conduct has deprived the Complainant of constitutionally protected property interests without notice or hearing, in violation of the Fourteenth Amendment’s Due Process Clause. A protected property interest exists where an independent source — a statute, rule, contract, plan document, or mutual understanding — creates a legitimate claim of entitlement (Board of Regents v. Roth, 408 U.S. 564 (1972)). The constitutional adequacy of the process due is measured by the three-factor test of Mathews v. Eldridge, 424 U.S. 319 (1976) — the private interest at stake, the risk of erroneous deprivation and the probable value of additional procedural safeguards, and the government’s interest. As applied to benefits termination, Goldberg v. Kelly, 397 U.S. 254 (1970), and to public-employment property interests, Cleveland Board of Education v. Loudermill, 470 U.S. 532 (1985), supply the analytical anchors. Institutional liability is governed by Monell v. Department of Social Services, 436 U.S. 658 (1978). The state actors whose conduct is catalogued below include: Captain Jeff Chobanian (Badge #307); Lieutenant James Echols; Lieutenant Richard L. Davis; Chief Craig Valenzuela; Beverly Jeanine Williams-Cook, Benefits Analyst III; and Erin Morse, Benefits/Insurance Supervisor — each acting within the scope of institutional authority, each on a documented written record, each on dates that place their actions in direct temporal proximity to the Complainant’s Protected Disclosures.

The central instrument of that deprivation is the Complainant’s sworn peace officer personnel file — a record protected under California Penal Code § 832.7 and the Pitchess discovery framework; required to be maintained under Government Code § 3306.5(b) and California Code of Regulations Title 8 § 15400.2; subject to the Complainant’s right of inspection and response under POBR Government Code §§ 3305 and 3306; and independently required to be preserved without destruction under California Code of Regulations Title 8 § 10102, which mandates that workers’ compensation claim files where future benefits may be payable “shall not be destroyed” — a requirement that applies here because Workers’ Compensation Claim No. 199650445, settled March 2003 with lifetime paid health insurance and continuing disability income, has never been formally closed, the WCAB has never issued a modification order, and future benefits remain payable under the terms of that settlement and the Octagon Risk Services permanent and stationary determination of August 8, 2001. The Complainant’s personnel file contains the workers’ compensation records, medical releases, and disability classification records required to establish the continuing benefit obligations UC now disputes. Under Title 8 § 10102, that file cannot legally be destroyed. Under Title 8 § 15400.2, it shall not be destroyed. Under the litigation hold of February 9, 2026 (EX 20), it was expressly forbidden from destruction by written legal notice. Three independent legal authorities prohibit its destruction. It may not exist.

That file contains the documentary basis for the Complainant’s true employment classification. Captain Chobanian cited it as the source of the “medically separated on March 1, 1996” determination that denied the Complainant’s CCW and anchored UC RASC’s subsequent coverage termination. Captain Chobanian confirmed in writing that he reviewed the file on August 25, 2023 and again on February 10, 2026 — one day after the Complainant served a written litigation hold on him expressly forbidding its destruction. Fifty-one days after that litigation hold, Lieutenant Echols stated in writing that the agency had received the wrong box and that the Complainant’s files, “if they still exist,” are difficult to locate. The four mutually irreconcilable custody-of-file statements issued between February 24, 2026 and April 1, 2026 — on UCLA PD letterhead, with Captain Chobanian CC’d on each — cannot all be true on the same set of facts. At least one is false. Sworn California peace officers who issue written statements they know to be false regarding a protected personnel file subject to a documented legal hold trigger California Penal Code § 118.1 (false reports by peace officers), § 135 (destruction or concealment of documents subject to legal process), and § 135.5 (concealment of evidence in a public investigation — the Labor Code § 132a crime report of February 19, 2026 and the POSAD complaints PUBLIC-26-000212/213/214 are public investigations within the meaning of § 135.5).

The classification stands. The file does not. If the file that Captain Chobanian twice confirmed reviewing is produced, it will establish the Complainant’s classification — one way or the other — and resolve every disputed question in this Sworn Retaliation Complaint. If it is not produced, California Evidence Code § 413 permits the inference that it would be adverse to UC’s position, and Cedars-Sinai Medical Center v. Superior Court, 18 Cal.4th 1 (1998), and Williams v. Russ, 210 Cal.App.4th 35 (2012), permit the presumption that the file, if produced, would support the Complainant’s position. The state actors who issued the classification, confirmed reviewing the file, and then watched it disappear have not explained the contradiction. The Locally Designated Official is respectfully asked to explain it.

The following Adverse Personnel Actions are presented in chronological order. Each identifies the responsible state actor, the date, the management action, and the chapter and exhibit in the Bruin Watch evidentiary record where the action is documented. No new exhibits are introduced; every link points to a record already published in the Bruin Watch series.

Date UC Employee / Agent Adverse Personnel Action Source (already published)
Dec 26, 2025 RASC employee “Robin” Directed execution of UBEN 100 (R10/21) and UBEN 101 (R10/20) on Robin’s representation that Via Benefits enrollment was mandatory for out-of-state retirees. The R10/21 form Robin transmitted was superseded by UBEN 100 (R1/26) which had been published by UC Human Resources in January 2026 and contains a “Voluntary” checkbox in the cancel/de-enroll section. UC’s own current form would have required acknowledgment that the transfer was elective. chapter_01 · chapter_09 · chapter_12
Feb 2, 2026 Joshua Lewis (Via Benefits administrator) Independently confirmed that the Complainant is ineligible for Via Benefits due to permanent disability rating. Lewis stated he would notify UC in writing that the application would not be accepted. UC did not act on this confirmation; UC continued to treat the Complainant as transferred and began the suspension chain that culminated in Williams-Cook’s February 27, 2026 denial. chapter_01
Feb 10, 2026 Capt. Jeff Chobanian (UCLA PD, Badge #307) One day after service of the February 9, 2026 litigation hold (EX 20), Capt. Chobanian wrote: “Based on your last email, I will no longer communicate with you since you have threatened legal action against me.” Termination of communication occurred 1 hour 9 minutes after the Complainant’s formal demand for record reconciliation that same evening. The February 18, 2026 POBR compliance deadline lapsed without production of any of the eight categories of records requested. EX 17a, p. 11 · chapter_05
Feb 24, 2026 Lt. James Echols (UCLA PD) Three custody-of-file statements within a single afternoon, fifteen days after the February 9, 2026 litigation hold and with Capt. Chobanian CC’d on every message. 1:24 PM: file “located.” 2:23 PM: file “located.” 3:04 PM (forty-one minutes later): file “archived” and being “currently searched for.” Custody-collapse on the same file in the same hour. EX 17a, p. 15 · chapter_05
Feb 27, 2026 Beverly Jeanine Williams-Cook, Benefits Analyst III, UC RASC Administrative Review Determination dated two days after the Complainant’s February 25, 2026 radical prostatectomy and during active post-surgical recovery. Used the same superseded UBEN 100 (R10/21) form. Never requested any of the Complainant’s supporting documents. Never addressed any of the six prior RASC filings. Letter contained an incomplete RASC phone number (800-888-826, missing the final digit). Letter postmarked late March; received by the Complainant March 28-29, 2026. EX 23 · chapter_09 · chapter_12
Apr 1, 2026 Anthem Blue Cross (acting at UC’s direction) Certificate of Creditable Coverage issued terminating the Complainant’s coverage effective April 1, 2026 — twenty-nine days before UC’s own stated April 30, 2026 suspension date. No advance notice. The federally required certificate triggered guaranteed-issue rights under 42 U.S.C. § 1395ss(b)(1)(A) and a 63-day window for individual Medigap purchase. chapter_09 · Epilogue
Apr 1, 2026 Lt. James Echols (UCLA PD) Fifty-one days after the February 9, 2026 litigation hold, Lt. Echols wrote: “I did receive a box that should have had your files in it, but it was not the correct box. I am now in the process of tracking down the correct box. It has been quite some time since you worked here so locating your files, if they still exist, is a bit challenging.” Cannot be reconciled with Capt. Chobanian’s prior written statements that he had reviewed the file on August 25, 2023 and February 10, 2026. EX 40 · chapter_05
Apr 7, 2026 Anthem Blue Cross / UC RASC Anthem reinstated coverage following intervention by DMHC and CMS, but back-dated the new coverage period to January 1, 2026, effectively erasing the April 1, 2026 termination event from the accessible portal record and removing the Certificate of Creditable Coverage that triggers federal guaranteed-issue rights. The Complainant has preserved the original April 1, 2026 termination certificate and April 2, 2026 INACTIVE-status screenshots in the DEVORATOR evidence archive. Act III · submitted to CMS #7100158 · DMHC #1409109
Apr 9, 2026 Erin Morse, Benefits/Insurance Supervisor, UC RASC Acknowledgment of Complainant’s grievance with statement that an “up-to-90-day” review window applies. The 90-day window will expire after the close of the Complainant’s 63-day federal Medigap guaranteed-issue window under 42 U.S.C. § 1395ss(q)(2)-(3). The structure forecloses the only federally guaranteed remedy before review concludes. EX 24 · chapter_09
Apr 17, 2026 UCLA Compliance Office Closure of CMP373 by one-paragraph email determination of “no policy violation,” based by the Compliance Office’s own admission on “your complaints and documentation we received from UCLA PD” — the agency whose officers are the subjects of the complaint. No interview of the Complainant. No request for the Complainant’s documentary record. No independent investigation. Issued while the underlying California Labor Code § 132a crime report had remained without UCLA PD response for fifty-seven days. Bruin Watch landing page (CMP373 banner)
Pattern note. Eight of the ten Adverse Personnel Actions catalogued above postdate the February 9, 2026 written litigation hold (EX 20). Six of the ten postdate the February 25, 2026 POSAD complaint filings. Two of the ten postdate the publication of the Bruin Watch series. The temporal alignment between Protected Disclosures (Section III) and Adverse Personnel Actions (Section IV) is documented on UC’s own institutional letterhead.
The violations in the case continue to emerge literally on a daily basis. Therefore, I have not been able to update all chapters with new adverse acts. The following are some recent incidents that define adverse action.

A — January 2026: Silent Removal of $727.48 Premium Deduction

UC SILENTLY REMOVES THE $727.48/MONTH PREMIUM DEDUCTION FROM THE COMPLAINANT’S PENSION

During the month of January 2026, the University of California internally processed the removal of the $727.48 monthly premium deduction for UC High Option Supplement to Medicare PPO coverage from the Complainant’s UC Retirement Annuity pension calculation. No notice of any kind was provided. No letter was sent. No UCRAYS portal message was posted. No telephone call was made. The Complainant did not request the change, did not authorize the change, was not informed of the change, and had no mechanism by which to discover the change other than by examining his bank deposit on the first of the following month. Since the 2015 conversion, the pension deduction had been the sole mechanism by which the Complainant’s premium reached Anthem; the Complainant had never had the ability to pay Anthem directly. UC’s unilateral removal of the deduction created a manufactured non-payment default that UC and Anthem subsequently used as the asserted basis for the April 1, 2026 termination of coverage. The premium-deduction removal is a unilateral modification of an established personnel/payroll arrangement, executed without notice, without consent, and without any predicate event in the Complainant’s conduct — and is independently an Adverse Personnel Action within the meaning of Policy 1100563 § B that materially and negatively affected the Complainant’s existing terms and conditions of employment-derived benefits.

B — February 11, 2026: Williams-Cook Concealment-by-Fiduciary Call

BENEFITS ANALYST III BEVERLY JEANINE WILLIAMS-COOK PERSONALLY CALLED THE COMPLAINANT AND CONCEALED MATERIAL FACTS BEARING ON IMMINENT LOSS OF MEDICAL COVERAGE

At 3:07 PM Pacific on February 11, 2026, Beverly Jeanine Williams-Cook, Benefits Analyst III, UC RASC, telephoned the Complainant in her official capacity. During that call Williams-Cook did not disclose that UC had already removed the $727.48 monthly premium deduction from the Complainant’s pension; did not disclose that Anthem Blue Cross was no longer receiving the Complainant’s monthly premium; did not disclose that the Complainant’s UC High Option Supplement to Medicare coverage was at risk of cancellation for non-payment; did not disclose any of the four mutually inconsistent termination dates that would subsequently appear in the record (April 1, April 30, May 1, and the unwritten internal-system date). Each of these facts was within Williams-Cook’s actual or constructive knowledge as the assigned Benefits Analyst III on the Complainant’s account. Each was material to the Complainant’s ability to take protective action. The Complainant was at the time recovering from cancer surgery scheduled for February 25, 2026, was undergoing cardiac treatment and neurological care, and was substantially dependent on continuous medical coverage. Concealment of material facts by a UC fiduciary acting in her official capacity, on a UC-initiated call, fourteen days before the Complainant’s cancer surgery, constitutes an Adverse Personnel Action distinct from and additional to the February 27, 2026 Administrative Review Determination Williams-Cook subsequently issued.

C — March 28-29, 2026: Williams-Cook Letter Mailed Late with Defective Phone Number

MARCH 28-29, 2026 — WILLIAMS-COOK ADMINISTRATIVE REVIEW DETERMINATION ARRIVES THIRTY DAYS AFTER ITS PRINTED DATE WITH A DEFECTIVE CONTACT TELEPHONE NUMBER

The Williams-Cook Administrative Review Determination is dated February 27, 2026. The Complainant did not receive the determination until on or about March 28-29, 2026 — approximately thirty days after its printed date. The Complainant has retained the envelope. The determination contains a contact telephone number that is incomplete: “800-888-826” — missing the final digit of the actual number, 800-888-8267. The determination requested no documents from the Complainant; addressed none of the Complainant’s six prior RASC filings; and directed the Complainant exclusively to Via Benefits without disclosing the Complainant’s federal Medigap guaranteed-issue rights under 42 U.S.C. § 1395ss(q)(2)-(3). The thirty-day mailing delay materially compressed the Complainant’s window to respond to a determination that itself stated the Complainant’s coverage would be suspended on April 30, 2026 — leaving the Complainant approximately thirty days, rather than the sixty days reflected in the printed date, to perfect any response. The defective contact telephone number — printed on a written determination issued by a UC Benefits Analyst III on UC institutional letterhead — independently impeded the Complainant’s ability to contact UC RASC by the channel UC itself designated for that purpose. The combination of late mailing, defective contact information, omission of any document request, omission of disclosure of federal guaranteed-issue rights, and direction to a Via Benefits pathway for which the Complainant had already been declared ineligible by UC’s own contracted administrator constitutes an Adverse Personnel Action under Policy 1100563 § B.

D — April 30, 2026 to May 1, 2026

The University of California has, as of April 30, 2026, removed my medical coverage and as of May 1 shorted my pension income — income of a documented permanently disabled peace officer, a documented 32-year whistleblower, a cancer patient, and a cardiac patient — simultaneously, without prior written notice, without a hearing, and without lawful authority under 42 U.S.C. § 1395ss(q)(1), California Labor Code § 5804, or UC Gold Book GO 21-02 § 1700.1(b)(1).

UC stopped deducting my premium in January 2026 without notice. UC then used the resulting non-payment — which UC itself manufactured — as a contributing basis for the termination of my coverage. UC then reinstated my coverage after regulatory intervention. UC then entered a phantom pay stub dated April 1, 2026 showing negative $727.48 — the exact amount of the premium UC had stopped collecting — with no gross income, no deductions, and no explanation. UC then applied that entry against my May 1, 2026 pension payment. I did not fail to pay my premium. I had no mechanism to pay it other than the deduction UC controlled and UC unilaterally stopped.

/s/ C.A.H. — Chuck Harold · UCLA PD (Ret.), Badge #341 · April 30, 2026

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