IX. Reservation of Rights and Parallel Filings
The Complainant reserves all rights and remedies available under California and federal law in connection with the matters described in this Sworn Retaliation Complaint, including but not limited to the following:
| Authority | Reservation / Status | Cross-Reference |
|---|---|---|
| California Government Code § 8547.10 | Sworn Retaliation Complaint and Protected Disclosure under the California Whistleblower Protection Act, as applied to The Regents under § 8547.11. Under Miklosy v. Regents of the University of California (2008) 44 Cal.4th 876, § 8547.10 supplies a civil damages action where the employee filed the required complaint and the University failed to reach a timely decision; UC’s internal process must also provide a meaningful, non-perfunctory mechanism consistent with due process. Right to civil action and recovery of punitive damages and attorney’s fees expressly reserved. | CH_15 (1994 filing) |
| California Labor Code § 1102.5 | General whistleblower retaliation protection. Right of action reserved. | All Acts |
| California Labor Code § 132a | Workers’ compensation discrimination — criminal misdemeanor. February 19, 2026 crime report filed with LAPD West Los Angeles. WCAB petition contemplated. | CH_13 |
| California Labor Code § 5803 | WCAB continuing jurisdiction over Workers’ Compensation Claim No. 199650445. No WCAB modification order has issued. The Octagon permanent-and-stationary determination of August 8, 2001 has never been revoked. The 2003 settlement obligations — including lifetime paid health insurance and disability income — remain in continuing effect under the Board’s jurisdiction. | CH_06 · chapter_07 |
| 31 U.S.C. § 3730(h) | False Claims Act anti-retaliation. Right of action reserved in connection with the federal Medicare-related conduct documented in the Epilogue. | Epilogue |
| 42 U.S.C. § 1395ss(q)(2)-(3) | Federal Medigap guaranteed-issue rights triggered by April 1, 2026 Certificate of Creditable Coverage. 63-day window. Records integrity preserved in DEVORATOR archive notwithstanding April 7, 2026 portal alteration. | chapter_09 · CMS #7100158 |
| California Penal Code § 13510.9 | Mandatory POST agency reporting of any complaint, charge, allegation, finding, civil judgment, or settlement that could subject a peace officer to certification suspension or revocation under § 13510.8 (SB 2 serious-misconduct grounds). Three POSAD complaints (PUBLIC-26-000212/213/214) acknowledged. Penal Code § 13512 + Title 11 CCR § 1010 agency-audit request transmitted April 27, 2026. | Act I |
| California Evidence Code § 413 | Adverse-inference reservation: where UC fails to produce institutional records within its control, the Complainant will rely on the inference that the records would be adverse to UC’s position. | All Acts |
Litigation hold renewed and extended. The February 9, 2026 written litigation hold and preservation demand (EX 20), originally served on Capt. Jeff Chobanian, is hereby renewed and extended to The Regents of the University of California, the UCLA Compliance Office, the UC Office of the President, the UC Office of General Counsel, the UC Retirement Administration Service Center, the UCLA Police Department, and to every UC employee, agent, contractor, and contracted insurer identified in or pertinent to the matters described in this Sworn Retaliation Complaint. Any destruction, alteration, deletion, or failure to preserve documents, records, files, electronically stored information, emails, database entries, payroll records, budget records, premium-deduction records, claims records, portal records, recorded calls, or any other materials relating to the Complainant or to the matters described herein, after receipt of this notice, may result in adverse inference instructions, spoliation sanctions, and independent tort liability under California law. (See Cedars-Sinai Medical Center v. Superior Court (1998) 18 Cal.4th 1, 11-12; Williams v. Russ (2012) 210 Cal.App.4th 35, 47-48.)
/s/ C.A.H. — Chuck Harold · UCLA PD (Ret.), Badge #341 · April 30, 2026