V. Contributing Factor — Causality

V. Contributing Factor — Causality

The contributing-factor showing rests on three independent and convergent grounds:

1. Temporal proximity. Under Lawson v. PPG Architectural Finishes, Inc., 12 Cal.5th 703 (2022), one-day temporal proximity between protected activity and adverse action is sufficient to establish contributing-factor causation under California’s whistleblower burden-shifting framework. The Bruin Watch record documents one-day proximity (February 9, 2026 litigation hold → February 10, 2026 Capt. Chobanian termination of communication), fifteen-day proximity (February 9, 2026 litigation hold → February 24, 2026 Echols custody-collapse), and fifty-one-day proximity (February 9, 2026 litigation hold → April 1, 2026 Echols “wrong box” statement) on UCLA PD letterhead. (See Act III, chapter_05.)

2. Workers’ compensation predicate — California Labor Code § 132a. The Complainant’s Workers’ Compensation Claim No. 199650445 (Date of Injury February 16, 1996) was settled in March 2003, I was paid DDI up to 2015. The Octagon Risk Services permanent and stationary determination of August 8, 2001 establishing a 6¾% permanent disability rating has never been revoked, modified, or superseded by any medical authority or by the Workers’ Compensation Appeals Board. Under California Labor Code § 5803, the WCAB retains continuing jurisdiction. No WCAB modification order has ever issued. Capt. Chobanian’s August 25, 2023 CCW denial expressly cited the Complainant’s “medically separated on March 1, 1996” status — the date of the industrial injury — as the basis for denial. The 2025-2026 Adverse Personnel Actions are part of a continuing pattern of action premised on, and adverse to, a workers’ compensation classification that has never been lawfully modified. (See CH_13; chapter_07; chapter_09.)

3. Institutional notice spanning thirty-one years. The original Government Code § 8547.10 complaint of July 5, 1994, addressed to UC President Jack W. Peltason and Chancellor Charles E. Young under penalty of perjury and copied to the Bureau of State Audits and the Los Angeles Times, placed The Regents on actual notice of the Complainant’s status as a statutory whistleblower. Every UC employee who took action affecting the Complainant’s terms and conditions of employment after July 5, 1994 was, at minimum, on constructive notice of that protected status under the doctrine that institutional knowledge is imputed to its agents. (See Schödinger’s UC Retiree, CH_15.)

4. Direct notice to UC’s Chief Compliance & Audit Officer — no response. On November 9, 2021, the Complainant’s attorney Edgar A. Saenz, Esq. transmitted a formal four-page audit request by certified mail and by email to Alexander Bustamante — UC’s Senior Vice President and Chief Compliance & Audit Officer — at his confirmed UCOP institutional address, with CC to counsel and BCC to the Complainant. The letter identified the Complainant as “a former UCLA peace officer and whistleblower” and made four specific requests: an audit of the workers’ compensation and disability income case; an audit to determine what personally identifiable information was breached during UC data breaches; an audit of internal records lost during UC computer system upgrades; and reversal of UC’s 2015 conversion of the Complainant’s disability income to service retirement. Contact was made through three independent channels on the same date: certified mail, institutional email, and LinkedIn connection requests to Bustamante, Matthew Hicks, and Erin Pressman. No acknowledgment, response, investigation, or referral was ever received through any channel from Bustamante, Hicks, Pressman, or from anyone at the University of California. Bustamante — a former LAPD Inspector General (2011-2017) and former Assistant United States Attorney prosecuting civil rights violations under 42 U.S.C. § 1983 (2002-2011) — held the institutional position with direct responsibility to act and the personal expertise to recognize what the letter described. His non-response constitutes a violation of UC Whistleblower Policy 1100171, a violation of UC Regents Policy 7503, and a statutory failure under Government Code § 8547.10(b), which mandates that designated officials “shall” investigate upon receipt of a complaint. The November 9, 2021 transmittal placed UC’s Chief Compliance & Audit Officer — the institutional head of the very office that on April 17, 2026 closed CMP373 against the Complainant without independent investigation — on documented actual notice of every fact UC subsequently weaponized in the 2025-2026 Adverse Personnel Actions. Every UC employee who acted adversely after November 9, 2021 acted with notice imputed from the Chief Compliance Officer’s confirmed receipt and willful non-response. (See FACT 48 — November 9, 2021 Audit Request to Bustamante.)