Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 1 of 55 THE UNITED STATE DISTRICT COURT DISTRICT OF PUERTO RICO

EVANGELINA RIVERA SANTIAGO; RAMON * A RODRIGUEZ CONDE; MARIA J ARCHEVAL * MONTILLA; DORIS CABRERA QUESADA; * CARLOS F RIVERA GONZALEZ; * JONATHAN LEON SANCHEZ; GETHER * BLACO BORRERO; YVETTE LOPEZ RUIZ; ROSA * CINTRO FERNANDEZ; IRMA ELISA SANTIAGO * ISRAEL RODRIGUEZ; EDWIN RIVERA * MARTINEZ; TERESITA CEPEDA BORRERO; * MILAGRO BELLO LUGO; NESTOR SANTIAGO * VILARIÑO; FRANCES MERCADO IRIZARRY; * JORGE RIVERA GARCIA; MIGUEL A. COLON * SALICHS; CAROLYN I. MARIETTI RODRIGUEZ; * ZORAIDA RIVERA MELENDEZ; CARMEN DE * JESUS TORRES; MAYRA RIVERA NAZARIO; * VIRGEN M. ROSAS ECHEVARRIA; ROBERTO * RIVERA RIVERA; PEDRO CEPEDA BORRERO * MILTON G ACOSTA LUCIANO; PALMIRA * TORRES VELAZCO; LIZETTE RUIZ RODRIGUEZ * MABEL BAIGES VALENTIN; MARTA R. LOPEZ * GONZALEZ; DIOSELINE MARTINEZ CINTRON; * DORALES H. VAZQUEZ MARTINES; ADELAIDA * RODRIGUEZ COLON; HECTOR L. ORTIZ * RIVERA; FRANCISCO J. COLON MALDONADO; * JUAN L. RODRIGUEZ RODRIGUEZ; JEANNETE * CALDERON RODRIGUEZ; FELIX MOJICA * DORIS I. FELICIANO; LENNETTE MEJIAS * GINER; MARIA MOURA HENRIQUEZ; JESUS * M. VELEZ DIAZ; CLARA MARITZA PEREZ * TORRES; MILAGROS SANABRIA IRIZARRY; * PRISCILA CINTRON PABON; MARTA ROSA * LOPEZ GONZALEZ; LIZETT MALDONADO * ROSADO ; MIRIAM DEL CARMEN ALICEA * SANTIAGO; MANUEL A. DOMINICCI * DELGUELLA; JESUS M. VELEZ DIAZ; * WALDEMAR RIVERA CASIANO;HARRY VELEZ * MAYORAL; MIGUEL A. VARGAS LARACUENTE * DANIEL SANTIAGO FERNANDEZ; CARMEN * SANTIAGO MELENDEE; DANIEL SANTIAGO * PALMIRA RIOS FELIBERTY; JORGE PEREZ * LUGO; BLAS A. RIVERA VARGAS; JULIO * ANGEL DE JESUS CRUZ; ALEXANDER * MALDONADO OLIVENCIA; ALLEN J GARCIA * MORA; NAIDA MUÑIZ SERRANO; ARIEL * DAVILA BLANCO; JULIO HERNANDEZ * MORALES; ROSA HAYDEE QUINTANA * GUZMAN; NAIDA MUÑIZ SERRANO; WALTER * LUGO RAMOS; MIRMARY RIVERA VEGAS; * Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 2 of 55 FERNANDO FERNANDEZ HERNANDEZ; * JEHNNYOLIVERAS SILVA; RAFAEL * SEPULVEDA RIVERA; RAMON L RIVERA * MUNET; JAVIER LUCIANO TORRES; * CORSINO NAZARIO; HILDA E. * CARTAGENA MEDINA; EDGAR * VELAZQUEZ MONTALVO; ANGEL M. * ALBERTORIO RUIZ; LUIS A. GOMEZ * HERNANDEZ; TANIA S. VEGA COLON; * * * * V * MUNICIPALITY OF PONCE * MARIA MELENDEZ ALTIERI in her personal * and official capacity as Mayor of the * Autonomous Municipality of Ponce; JANICE * GONZALEZ GALARZA in her personal and * official capacity as Director of Human Resources * JOHN DOE; CONJUGAL * PARTNERSHIP OF JANICE GONZALEZ * GALARZA AND JOHN DOE; ELIEZER * VELAZQUEZ QUILES in his personal and * official capacity as City Administrator; JANE * DOE; CONJUGAL PARTNERSHIP OF * ELIEZER VELAZQUEZ QUILES AND JANE * DOE; INSURANCE COMPANY XYZ; JOHN * DOE II * ******************************************* COMPLAINT

TO THE HONORABLE COURT: Comes now the Plaintiffs in the case of caption, by and through the undersigned attorney and very respectfully ALLEGE, STATE AND PRAY:

I. INTRODUCTION:

1. This is a civil rights action brought under 42 U.S.C. sections 1983 and 1988 for deprivation of rights to freedom of speech and freedom of Association, under the First and Fourteenth Amendments to the United States Constitution, for violations of rights of Due Process, and for Attorney’s fees, as well as rights guaranteed by the Constitution and the Laws of

Puerto Rico pursuant to articles 1802 of the Civil Code of Puerto Rico 31 L.P.R.A. Sections 5141 and, LAW 100 29 LPRA sec. 146, and fraudulent actions. The plaintiffs seek declaratory and injunctive relief; back pay; emotional, economic and punitive damages; pre and post judgment interests, reinstatement to regular working hours and salary; lost benefits and reinstatement of benefits; and any other relief which this Court deems just and proper.

2 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 3 of 55 II. JURISDICTION AND VENUE 2. The court has subject matter jurisdiction over the federal claims pursuant to 28 U.S.C. Sections 1331 and 1343

(3) due to the fact that this action arises under the United States Constitution, and Laws of the United States. Subject Matter

Supplemental Jurisdiction over claims asserted under the Laws of Puerto Rico is based upon supplemental jurisdiction pursuant to 28 U.S.C. Section 1367. The federal claims have sufficient substance to confer subject matter jurisdiction to this

Court and the State Law claims arise out of the same nucleus of operative facts as the Federal Claims arise. Venue is proper pursuant to 28 USC Section 1391 (b) as Puerto Rico is the Judicial District where all the relevant facts occurred and where all parties reside.

III. JURY TRIAL DEMANDED 3. All Plaintiffs demand trial by jury in all causes of action.

IV. PARTIES

4. The plaintiffs in the present action are all natural persons, citizens of the United States of America, residents of the Commonwealth of Puerto Rico and received their writing communication in regards to their hourly reduction on or after

June 2, 2014.

5. Evangelina Rivera Santiago (hereinafter Plaintiff Evangelina Rivera), is a Career Employee of MAP whose present position, since January 2009, is Executive Officer by classification and Administrator by Functional Title. She has worked for MAP for 25 years. She has been an excellent employee, and has been responsible and efficient realizing the functions of her position.

6. In 2008 and 2012 Plaintiff Evangelina Rivera ran in primaries under the Popular Democratic Ticket for

Representative in Ponce, she did not win the primaries, and actively campaigned for all members of the Popular Democratic

Party running in general elections. All MAP employees, contractors, Legislative Assemblymen/women, and the mayor knew that she was running for the aforementioned post of Representative, and after her loss actively supported PPD candidates running for various elected posts in Ponce.

7. In the elections 2012, Eliezer Velazquez Quiles, now Confidence Employee of the MAP Mayor, ran for Senator for the Ponce District. He lost his bid to the Honorable Martin Vargas and the Honorable Ramon Nieves, both running under the PPD Ticket in the general elections. He was appointed by the MAP Mayor to the position of City Administrator, after his loss and eventually took over the position of City Administrator, a position which he has held at all relevant times.

Because both Plaintiff Evangelina Rivera and Defendant Eliezer Velazquez were both actively running and involved in

Ponce Politics, they knew each other’s political affiliations.

3 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 4 of 55 8. Santiago Martinez Irizarry former Mayor from Juana Diaz 1992-2000 under the NPP ticket, was contracted through a Professional Services Contract Number 09-22-74 on June 29, 2009, as Director of the Juan Morel Campos

Institute of Music, which paid a total of $1,701.00 monthly for a total of 4 hours a day 4 days a week with a limit of

20,412.00 yearly. The following fiscal year, he signed another contract which added 4 additional hours to his work day and brought up his monthly salary to 2,333.33 monthly, with a limit of 28,000.00 yearly, said contract was assigned the number

2010002295. Although MAP has used alleged economic problems for cutting salaries, Martinez Irizarry’s salary through contract No. 201400041 he is earning $2,280.00 monthly with a yearly total of 27, 360.00. He suffered a cut of 10%.

9. Martinez Irizarry’s job duties are the same as those of Evangelina Rivera, he began working for MAP after she did, she is a career employee, and he works under a professional service contract. His salary was cut by 10% and

Evangelina Rivera’s salary was cut by 47%. She began working for the Juan Morel Campos Institute of Music, in January of 2009.

10. MAP Mayor has shown clear preference to a professional service contractor over a career employee, and has punished Evangelina Rivera by cutting her salary by 47%, because Evangelina Rivera belongs to a different political party than does MAP Mayor.

11. Evangelina Rivera has a salary of $4,445.00 gross monthly, a letter dated May 28, 2014, notified that her work hours would be reduced by 3.5 hours daily, and her salary would be reduced to 2,431.00 monthly. She was again notified by letter on May 30, 2014 that about the work and salary reductions, however, those letter were not received by her until

June 2, 2014. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series

2014-2015, upon which this illegal action was based.

12. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not to any particular Plaintiff Evangelina Rivera, which are acts contrary to the law.

13. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

14. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

15. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

16. That co-worker Carmen Martinez Aja and Ida Santos Borrero do the same work that Plaintiff Rivera They are active members of the PNP, however, due to political reasons defendants authorized them t o work 30 hours

4 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 5 of 55 weekly while Plaintiff Rivera work 20 hours weekly.

17. Ramon A. Rodriguez Conde, (hereinafter Rodriguez Conde) Career Employee of MAP, whose present position is Recreation Leader, and whose Monthly Salary is $1,649.00 Gross. Plaintiff Rodriguez Conde was notified on May 28 then on May 30, 2014 that his work hours would be reduced by 3.5 hours daily, and his salary reduced to $874.47 gross monthly. He has worked for MAP for 15 years.

18. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rodriguez Conde, which are acts contrary to the law.

19. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

20. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights. 21. Maria J. Archevald Montilla (hereinafter Archevald) is a Career Employee of MAP and holds the position of

Administrative Assistant V, her gross monthly salary of $1,925.00 was reduced to $1,025.13 monthly. She was notified on

May 28, 2014 that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based.

22. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Archevald, which are acts contrary to the law.

23. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

24. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights. She worked for MAP for 22 years.

25. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

26. Doris Cabrera Quesada (hereinafter Doris Cabrera) is a Career Employee of MAP and holds the position of

Office Clerk II , at the City Clerk’s Office, her gross monthly salary of $1,170.00 was reduced to $628.33 monthly. She was notified on May 28, 2014 that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for a total of 11 years.

27. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and

5 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 6 of 55 not directed particularly to Plaintiff Archevald, which are acts contrary to the law.

28. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

29. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

30. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

31. Carlos F. Rivera Gonzalez (hereinafter Carlos F. Rivera) is a Career Employee of MAP and holds the position of Administrative Assistant V at the Department Citizen’s Services, his gross monthly salary of $1,925.00 was reduced to

$1026.13 monthly. He was notified on May 28, 2014 that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74

Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 14 years.

32. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Carlos F. Rivera, which are acts contrary to the law. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

33. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional Rights.

34. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

35. Jonathan Leon Sanchez (hereinafter Leon Sanchez) is a Career Employee of MAP and holds the position of

Administrative Assistant III, at the Permits Office his gross monthly salary of $1,870.00 was reduced to $977.00 monthly.

He was notified on May 30, 2014 that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 15 years.

36. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Leon Sanchez, which are acts contrary to the law.

37, Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

38. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

6 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 7 of 55 Rights.

39. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

40. Gether Blanco Borrero (hereinafter Gether Blanco) is a Career Employee of MAP and holds the position of

Administrative Assistant I , at the Permit Office, his gross monthly salary of $1,568.00 was reduced to $836.00 monthly.

He was notified on May 30, 2014 that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 13 years.

41. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Gether Blanco, which are acts contrary to the law.

42. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

43. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

44. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

45. Yvette Lopez Ruiz (hereinafter Yvette Lopez) is a Career Employee of MAP and holds the position of Office

Clerk I , at the Reception Area of the Permits Office , her gross monthly salary of $1,492.00 was reduced to $796.00 monthly. She was notified on May 30, 2014 that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series

2014-2015, upon which this illegal action was based. She has worked for MAP for over 10 years.

46. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Yvette Lopez, which are acts contrary to the law.

47. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

48. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

49. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

7 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 8 of 55 50. Rosa Cintron Fernandez (hereinafter Cintron Fernandez) is a Career Employee of MAP and holds the position of Office Clerk I , at the Municipal Clerk’s Office , her gross monthly salary of $1,145.00 was reduced to $673.00 monthly.

She was notified on May 30, 2014 that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for over 10 years.

51. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Cintron Fernandez, which are acts contrary to the law.

52. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

53. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional Rights.

54. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

55. Irma Elisa Santiago Rivera (hereinafter Irma Santiago) is a Career Employee of MAP and holds the position of

Administrative Assistant V , at the Cultural Development Office , her gross monthly salary of $1,803.00 was reduced to

$962.00 monthly. She was notified on May 28, then again on May 30, 2014 that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent

Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for over 10 years.

56. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Irma Santiago, which are acts contrary to the law.

57. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

58. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional Rights.

59. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

60. Israel Rodriguez Torres (hereinafter Israel Rodriguez) is a Career Employee of MAP and holds the position of

Maintenance, at the Health and Wellbeing Department, his gross monthly salary of $920.00 was reduced to $629.00 monthly. He was notified on May 30, 2014 that his work hours would be reduced by 3.5 hours daily, and his salary reduced.

8 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 9 of 55 Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for over years.

61. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Israel Rodriguez, which are acts contrary to the law.

62. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

63. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

64. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

65. Teresita Cepeda Borrero (hereinafter Cepeda Borrero) is a Career Employee of MAP and holds the position of

Sports Supervisor II at the Sports and Recreation Office , her gross monthly salary of $1567.00 was reduced to $836.00 monthly. Her Notification Letter was dated May 30, but was not given to her until June 11, 2014, and stated that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for over 16 years.

66. Although the Director of the Department that Cepeda Borrero worked for, had contact with her all week long, yet did not tell her about the letter, or give it to her. Co Workers in her department, who worked for MAP for a much shorter period than she did, were only affected with 10% cuts and others with 20%. .

67. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Teresita Cepeda Borrero, which are acts contrary to the law.

68. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

69. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional Rights.

70. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

71. Edwin Rivera Martinez (hereinafter Rivera Martinez) is a Career Employee of MAP and holds the position of

Sports and Recreation Office , his gross monthly salary of $1,448.00 was reduced to $724.00 monthly. His Notification

Letter was dated May 30, but was not given to her until June 11, 2014, and stated that her work hours would be reduced by

9 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 10 of 55 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for over 14 years.

72. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rivera Martinez, which are acts contrary to the law.

73. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

74. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

75. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

76. Milagros Bello Lugo (hereinafter Bello Lugo) is a Career Employee of MAP and holds the position of

Secretary III at the Legal Services Office, her gross monthly salary of $1620.00 was reduced to $864.00 monthly. Her notification letter was dated on May 30, 2014, but not given to her until June 3, 2014, said letter stated that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for

MAP for over 10 years.

77. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Bello Lugo, which are acts contrary to the law.

78. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

79. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

80. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

81. Jorge Rivera Garcia (hereinafter Jorge Rivera) is a Career Employee of MAP and holds the position of Permit

Inspector the Permits Office, his gross monthly salary of $1654.00 was reduced to $742.00 monthly. He was notified on

May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification

10 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 11 of 55 contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for over 10 years.

82. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Jorge Rivera, which are acts contrary to the law.

83. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

84. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

85. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

86. Miguel A. Colon Salichs (hereinafter Colon Salichs) is a Career Employee of MAP and holds the position of

Chauffer at the Sports and Recreation Department, his gross monthly salary of $1492.00 was reduced to $795.00 monthly.

He was notified on May 28, then again on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74

Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 31 years.

87. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Colon Salichs, which are acts contrary to the law.

89. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

90. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

91. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

92. Carmen N. De Jesus Torres (hereinafter Carmen De Jesus) is a Career Employee of MAP and holds the position of Clerk Typist (A)III at the Permits Office, her gross monthly salary of $1654.00 was reduced to $884.00 monthly.

She was notified on May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for 27 years.

11 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 12 of 55 93. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Carmen De Jesus, which are acts contrary to the law.

94. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

95. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

96. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

97. Mayra Rivera Nazario (hereinafter Rivera Nazario) is a Career Employee of MAP and holds the position of

Permit Technician at the Permit Office, her gross monthly salary of $1594.00 was reduced to $850.00 monthly. She was notified on May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 16 years.

98. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rivera Nazario, which are acts contrary to the law.

99. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

100. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

101. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

102. Virgen M. Rosas Echevarria (hereinafter Rosas Echevarria) is a Career Employee of MAP and holds the position of Office Clerk I at the Permit Office, her gross monthly salary of $1352.00 was reduced to $721.07 monthly. She was notified on May 28, then again on May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74

Series 2014-2015, upon which this illegal action was based. She has worked for MAP for a total of 12 years.

103. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rosas Echevarria, which are acts contrary to the law.

12 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 13 of 55 104. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

105. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

106. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

107. Roberto Rivera Rivera (hereinafter Rivera Rivera) is a Career Employee of MAP and holds the position of

Executive Officer at the Sports and Recreation Department Development , his gross monthly salary of $3076.00 was reduced to $1641.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance,

74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for over 10 years.

108. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rivera Rivera, which are acts contrary to the law.

109. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

110. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

111. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

112. Pedro Cepeda Borrero (hereinafter Cepeda Borrero) is a Career Employee of MAP and holds the position of

Permit Technician at the Permits Office, his gross monthly salary of $1806.00 was reduced to $963.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 18 years.

113. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Cepeda Borrero, which are acts contrary to the law.

114. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

13 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 14 of 55 115. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

116, The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

117. Osvaldo Cosme Burgos (hereinafter Osvaldo Cosme) is a Career Employee of MAP and holds the position of

Auditor III at the Internal Auditing Office, his gross monthly salary of $2268.00 was reduced to $1210.00 monthly. He was notified on May 28, then again on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series

2014-2015, upon which this illegal action was based. He has worked for MAP for over 10 years.

118. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Osvaldo Cosme, which are acts contrary to the law.

119. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

120. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

121. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

Furthermore, the position which Osvaldo Cosme holds is an extremely important one, he is in charge of insuring that the acts of MAP comply with Laws and regulations as well as to insure that there is no misuse of Public Funds by the MAP.

The lesser amount of hours makes it easier for MAP to act in ways contrary to Law.

122. Milton G. Acosta Luciano (hereinafter Milton Acosta ) is a Career Employee of MAP and holds the position of Administrative Assistant V at the Office of Municipal Businesses Guancha , his gross monthly salary of $2423.00 was reduced to $1292.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance,

74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 28 years.

123. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Milton Acosta, which are acts contrary to the law.

124. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

14 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 15 of 55 125. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

126. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

127. Lizette Ruiz-Rodriguez (hereinafter Lizette Ruiz ) is a Career Employee of MAP and holds the position of

Accountant at the Sports and Recreation Department, her gross monthly salary of $3340.00 was reduced to $1781.87 monthly. She was notified on May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series

2014-2015, upon which this illegal action was based. She has worked for MAP for over 10 years.

128. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Lizette Ruiz , which are acts contrary to the law.

129. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

130. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

131. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

132. Palmira Torres Velazco (hereinafter Torres Velazco ) is a Career Employee of MAP and holds the position of

Administrative Assitant III, her gross monthly salary of $1,870.00 was reduced to $991.00 monthly. She was notified on

May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for a total of 20 years.

133. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Torres Velazco , which are acts contrary to the law.

134. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

135. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

15 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 16 of 55 136. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

137. Carolyn I. Marietti Rodriguez (hereinafter Carolyn Marietti ) is a Career Employee of MAP and holds the position of Administrative Assistant V at the Municipal Tr4ansportation Administration, her gross monthly salary of

$2588.00 was reduced to $1,380.00 monthly. She was notified on May 28, then again on May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for over 10 years.

138. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Carolyn Marietti, which are acts contrary to the law.

139. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

140. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

141. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

142. Zoraida Rivera Melendez (hereinafter Zoraida Rivera ) is a Career Employee of MAP and holds the position of Clerk I at the Permits Office, her gross monthly salary of $1,169.00 was reduced to $653.33 monthly. She was notified on May 28, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for a total of 8 years.

143. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Zoraida Rivera , which are acts contrary to the law.

144. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

145. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

146. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

16 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 17 of 55

147. Marta R. Lopez Gonzalez (hereinafter Marta Lopez) is a Career Employee of MAP and holds the position of

Secretary III at the Municipal Clerks Office, her gross monthly salary of $1517.00 was reduced to $809.47 monthly. She was notified on May 28, then again on May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74

Series 2014-2015, upon which this illegal action was based. She has worked for MAP for a total of18 years.

148. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Marta Lopez, which are acts contrary to the law.

149. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

150. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

151. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

151. Mabel Baiges Valentin (hereinafter Mabel Baiges ) is a Career Employee of MAP and holds the position of

Conservationist at the Permits Office , her gross monthly salary of $1758.00 was reduced to $938.00 monthly. She was notified on May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for a total of 22 years.

152. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Mabel Baiges , which are acts contrary to the law.

153. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

154. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

155. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

156. Doralis H. Vazquez Martinez (hereinafter Doralis Vazquez) is a Career Employee of MAP and holds the position of Administrative Assistant II at the Cultural Development Office, her gross monthly salary of $1406.00 was reduced to $750.00 monthly. She was notified on May 28, then again on May 30, 2014, that her work hours would be

17 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 18 of 55 reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for over 10 years.

157. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and never notified Plaintiff Doralis Vazquez at all, which are acts contrary to the law.

158. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

159. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

160. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

161. Adelaida Rodriguez Colon (hereinafter Adelaida Rodriguez ) is a Career Employee of MAP and holds the position of Receptionist the Municipal Clerks Office, her gross monthly salary of $1392.00 was reduced to $741.87 monthly. She was notified on May 28, 2014, that her work hours would be reduced by 3.5 hours daily, and her salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series

2014-2015, upon which this illegal action was based. She has worked for MAP for approximately 20 years.

162. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Adelaida Rodriguez , which are acts contrary to the law.

163. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

164. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

165. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

166. Dioseline Martinez Cintrón (hereinafter Martinez Cintrón) is a Career Employee of MAP and holds the position of Human Resources Analist III , her gross monthly salary of $2,264.00 was reduced to $1,020.00 monthly. Sh was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 19 years.

18 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 19 of 55 167. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Luis Arroyo, which are acts contrary to the law.

168. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

169. Furthermore, Plaintiff Luis Arroyo informed the HR Director, Janice Gonzalez Galarza, that he, along with another MAP employee suffering from a cut in hours and salary, Milagros Bello Lugo (Plaintiff Bello Lugo), constituted a family nucleus together with their 13 year old daughter. The illegal Ordinance No. 74 Series 2013-2014, in its First Section,

Paragraph I stated that when 2 employees constituted a family nucleus, and both were subject to a workday and salary reduction, the reduction would only apply to the employee with the lesser salary, in this case Plaintiff Luis Arroyo. The HR

Director refused to apply the exception to this family, and refused to entertain his request.

170. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

171, The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

172. Francisco J. Colon Maldonado (hereinafter Francisco Colon) is a Career Employee of MAP and holds the position of Engineer in Training at the Territorial Land Use and Zoning Department, his gross monthly salary of $3,362.00 was reduced to $2,945.00 monthly. He was notified by a Notification Letter dated May 30, 2014, but not given to him until June 2, 2014, that his work hours would be reduced by 7.5 hours weekly, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for approximately 20 years.

173. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Francisco Colon, which are acts contrary to the law.

174. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

175. Furthermore, Plaintiff Francisco Colon’s wife also works at the Municipality and her workday and salary suffered cuts from the illegal ordinance, and although he notified the HR Director, she refused to entertain his request that his salary not be affected in accordance with illegal Ordinance No. 74 Series 2013-2014, in its First Section, Paragraph I which states that when 2 employees constituted a family nucleus, and both were subject to a workday and salary reduction, the reduction would only apply to the employee with the lesser salary. In the present case Plaintiff Francisco Colon’s salary

19 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 20 of 55 was affected. Furthermore, the notification received by Plaintiff Francisco Colon gave an erroneous calculation of his salary after cuts.

176. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights. 177. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

178. Hector L. Ortiz Rivera (hereinafter Hector L. Ortiz ) is a Career Employee of MAP and holds the position of

Administrative Assistant V at the Cultural Development Office, his gross monthly salary of $1925.13 was reduced to

$1026.13 monthly. He was notified on May 28, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74

Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 20 years.

179. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Hector L. Ortiz, which are acts contrary to the law.

180. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

181. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

182. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

183. Juan L. Rodriguez Rodriguez (hereinafter Rodriguez Rodriguez) is a Career Employee of MAP and holds the position of Builder at the La Guancha , his gross monthly salary of $1179.00 was reduced to $629.00 monthly. He was notified on May 28, then again on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series

2014-2015, upon which this illegal action was based. He has worked for MAP for over 10 years.

184. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rodriguez Rodriguez, which are acts contrary to the law.

185. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

186. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

20 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 21 of 55 187. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

188. Felix Mojica Torres (hereinafter Felix Mojica) is a Career Employee of MAP and holds the position of

Maintenance and Conservation Employee at the Permits Office , his gross monthly salary of $1,360.00 was reduced to

$725.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74

Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 20 years.

189. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Felix Mojica, which are acts contrary to the law.

190. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

191. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

192. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

193. Doris I. Feliciano Plata (hereinafter Feliciano Plata) is a Career Employee of MAP and holds the position of

Permits Inspector , her gross monthly salary of $1,1712.00 was reduced to $913.00.00 monthly. She was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 18 years.

194. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Feliciano Plata, which are acts contrary to the law.

195. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

196. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

197. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

21 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 22 of 55 198. Jeannete Calderon Rodriguez (hereinafter Calderon Rodriguez) is a Career Employee of MAP and holds the position of Executive Oficial , her gross monthly salary of $2,698.00 was reduced to $1,438,67 monthly. She was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 24 years.

199. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Calderon Rodriguez, which are acts contrary to the law.

200. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

201. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

202. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

203. Mejias Giner Torres (hereinafter Mejias Giner) is a Career Employee of MAP and holds the position of

Permits Technicians , her gross monthly salary of $1,806.00 was reduced to $963.00 monthly. She was notified on May 30,

2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 24 years.

204. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Mejias Giner, which are acts contrary to the law.

205. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

206. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

207. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

208. Jesus M. Vélez Díaz (hereinafter Vélez Díaz ) is a Career Employee of MAP and holds the position of

Administrative Assistant, his gross monthly salary of $1,450.00 was reduced to $775.00 monthly. He was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification

22 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 23 of 55 contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 23 years.

209. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Vélez Díaz , which are acts contrary to the law.

210. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

211. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

212. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

213. Maria Moura Henriquez (hereinafter Moura Henriquez ) is a Career Employee of MAP and holds the position of Administrative Assistant, hes gross monthly salary of $1,713.00 was reduced to $914.00 monthly. She was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 22 years.

214. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Moura Henriquez , which are acts contrary to the law.

215. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

216. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

217. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

218. Milagros Sanabria Irizarry (hereinafter Sanabria Irizarry ) is a Career Employee of MAP and holds the position of Professional Services at the Permit Offices, her gross monthly salary of $1,923.00 was reduced to $1,027.00 monthly. She was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series

2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 34 years.

23 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 24 of 55 219. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Sanabria Irizarry , which are acts contrary to the law.

220. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

221. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

222. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

223. Nestor Santiago Vilariño (hereinafter Santiago Vilariño ) is a Career Employee of MAP and holds the position of Administrative Assistant V, his gross monthly salary of $1,925.00 was reduced to half monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for over 10 years.

224. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Santiago Vilariño , which are acts contrary to the law.

225. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

226. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

227. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

228. Priscila Cintrón Pabon (hereinafter Cintrón Pabon ) is a Career Employee of MAP and holds the position of

Municipal Supervisor, her gross monthly salary of $1,482.00 was reduced to $790.00 monthly. She was notified on May 30,

2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for over10 years.

229. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Cintrón Pabon , which are acts contrary to the law.

24 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 25 of 55 230. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

231. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

232. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

233. Clara Maritza Perez Torres (hereinafter Perez Torres ) is a Career Employee of MAP and holds the position of Administrative Assistant, her gross monthly salary of $1,507.00 was reduced to $807.00 monthly. She was notified on

May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 19 years.

234. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Vélez Díaz , which are acts contrary to the law.

235. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

236. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

237. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

238. Frances Mercado Irizarry (hereinafter Mercado Irizarry ) is a Career Employee of MAP and holds the position of Supervisor Administrative V, her gross monthly salary of $1,800.00 was reduced to $900.00 monthly. She was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 22 years.

239. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Mercado Irizarry , which are acts contrary to the law.

240. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

25 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 26 of 55 241. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

242. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

243. ,,,,,,, Lizett Maldonado Rosado (hereinafter Maldonado Rosado ) is a Career Employee of MAP and holds the position of Receptionist, her gross monthly salary of $1,392.00 was reduced to $742.00 monthly. She was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 20 years.

244. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Maldonado Rosado , which are acts contrary to the law.

245. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

246. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

247. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

248. Miriam del Carmen Alicea Santiago (hereinafter Alicea Santiago ) is a Career Employee of MAP and holds the position of Oficinista III, her gross monthly salary of $1,343.00 was reduced to $716.00 monthly. She was notified on

May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 23 years.

249. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Alicea Santiago , which are acts contrary to the law.

250. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

251. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

26 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 27 of 55 253. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

254. Marta Rosa Lopez Gonzalez (hereinafter Lopez Gonzalez ) is a Career Employee of MAP and holds the position of Secretary III, her gross monthly salary of $1,517.00 was reduced to $758.00 monthly. She was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 18 years.

255. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Lopez Gonzalez, which are acts contrary to the law.

256. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

257. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

258. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

259. Manuel A. Dominicci Deguellas (hereinafter Dominicci) is a Career Employee of MAP and holds the position of Electrician Assistant, his gross monthly salary of $1,413.00 was reduced to $754.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for over 10 years.

260. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Dominicci , which are acts contrary to the law.

261. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

262. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

263. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

27 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 28 of 55 264. Jesus M. Vélez Díaz (hereinafter Vélez Díaz ) is a Career Employee of MAP and holds the position of

Administrative Assistant, his gross monthly salary of $1,450.00 was reduced to $775.00 monthly. He was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 23 years.

265. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Vélez Díaz , which are acts contrary to the law.

266. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

267. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

268. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

269. Harry Vélez Mayoral (hereinafter Velez Mayoral) is an Employee of MAP and holds the position of

Assistance Plummer , his gross monthly salary of $1,070.00 was reduced to $379.96.00 monthly. He was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 4 years.

270. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Vélez Mayoral, which are acts contrary to the law.

271. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

272. Velez Mayoral was transfer from a in regular position to transitory position without his consent.

273. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

274. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

275. Waldemar Rivera Casiano (hereinafter Rivera Casiano) is an Employee of MAP and holds the position of

Oficinista I, his gross monthly salary of $1,186.00 was reduced to $632.96.00 monthly. He was notified on May 30, 2014,

28 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 29 of 55 that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 8 years.

276. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rivera Casiano, which are acts contrary to the law.

277. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

278. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

279. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

280. Daniel Santiago Fernandez (hereinafter Santiago Fernandez) is a Career Employee of MAP and holds the position of Worker , his gross monthly salary of $1070.00 was reduced to $628.00 monthly. He was notified on May 30,

2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 7 years.

281. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Santiago Fernandez, which are acts contrary to the law.

282. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

283. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

284. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

285 Palmira Rios Feliberty (hereinafter Rios Feliberty) is a Career Employee of MAP and holds the position of

General Worker Services , her gross monthly salary of $1170.00 was reduced to $628.00 monthly. She was notified on

May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 12 years.

29 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 30 of 55 286. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rios Feliberty, which are acts contrary to the law.

287. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

288. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

289. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

290. Carmen Santiago Melendee (hereinafter Santiago Melendez) is a Career Employee of MAP and holds the position of Maintenance and Conservation Employee , her gross monthly salary of $1070.00 was reduced to $628.00 monthly. She was notified on May 30, 2014, that her work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series

2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 15 years.

291. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Santiago Melendee, which are acts contrary to the law.

292. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

293. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

294. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

295. Miguel A Vargas Laracuente (hereinafter Vargas Laracuente) is a Career Employee of MAP and holds the position of Operator Heavy Equipment , his gross monthly salary of $1258.00 was reduced to $671.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 26 years.

296. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Vargas Laracuente, which are acts contrary to the law.

30 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 31 of 55 297. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

298. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

299. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

300. Jorge Perez Lugos (hereinafter Perez Lugo) is a Career Employee of MAP and holds the position of Operator

Heavy Equipment , his gross monthly salary of $1172.00 was reduced to $628.00 monthly. He was notified on May 30,

2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for over 10 years.

301. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Perez Lugo, which are acts contrary to the law.

302. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

303. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

304. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees,

without regard to the rights of career employees who have property rights in their employment.

305. Alexander Maldonado Olivencia (hereinafter Maldonado Olivencia) is a Career Employee of MAP and holds the position of Construction Employee, his gross monthly salary of $1172.00 was reduced to $625.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for over 10 years.

306. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Maldonado Olivencia, which are acts contrary to the law.

307.Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

31 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 32 of 55 308. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

309. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

310 Allen J Garcia Mora (hereinafter Garcia Mora) is a Career Employee of MAP and holds the position of

Worker Construction , his gross monthly salary of $1172.00 was reduced to $628.00 monthly. He was notified on May 30,

2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for over 10 years.

311. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Garcia Mora, which are acts contrary to the law.

312. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

313. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

314.. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

315 Julio Angel de Jesus Cruz (hereinafter de Jesus Cruz) is a Career Employee of MAP and holds the position of

Electrician , his gross monthly salary of $818.00 was reduced to $720.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 12 years.

316. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff de Jesus Cruz, which are acts contrary to the law.

317. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

318. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

319. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular

32 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 33 of 55 employees, without regard to the rights of career employees who have property rights in their employment.

320 Blas A. Rivera Vargas (hereinafter Rivera Vargas) is a Career Employee of MAP and holds the position of

Operator Heavy Equipment, his gross monthly salary of $1172.00 was reduced to $628.00 monthly. He was notified on

May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 12 years.

321. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rivera Vargas, which are acts contrary to the law.

322. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

323. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

324. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

325. Ariel Davila Blanco (hereinafter Davila Blanco) is a Career Employee of MAP and holds the position of

Worker , his gross monthly salary of $1240.00 was reduced to $628.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 17 years.

326. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Davila Blanco, which are acts contrary to the law.

327 Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

328. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

329. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

330. Julio Hernandez Morales (hereinafter Hernandez Morales) is a Career Employee of MAP and holds the position of Worker, his gross monthly salary of $1240.00 was reduced to $626.00 monthly. He was notified on May 30,

33 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 34 of 55 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 11 years.

331. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Hernandez Morales, which are acts contrary to the law.

332. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

333. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

334. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

335. Naida Muñiz Serrano (hereinafter Muñiz Serrano) is a Career Employee of MAP and holds the position of

Data Processor, her gross monthly salary of $1682.00 was reduced to $841.00 monthly. She was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 23 years.

336. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Muñiz Serrano, which are acts contrary to the law.

337. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

338. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

339. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

340. Rosa Hydeé Quintana Guzmán (hereinafter Quintana Guzmán) is a Career Employee of MAP and holds the position of Oficinista IV , her gross monthly salary of $1295.00 was reduced to $637.00 monthly. She was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 15 years.

34 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 35 of 55 341. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Quintana Guzman, which are acts contrary to the law.

342. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

343. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

344. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

345. Walter Lugo Ramos (hereinafter Lugo Ramos) is a Career Employee of MAP and holds the position of

Maintenance Shop Director , his gross monthly salary of $1712.00 was reduced to $548.00 monthly. He was notified on

May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 35 years.

346. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Lugo Ramos, which are acts contrary to the law.

347. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

348. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

349. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

350. Fernando Fernandez Hernandez (hereinafter Fernandez Hernandez) is a Career Employee of MAP and holds the position of Electrician , his gross monthly salary of $1243.00 was reduced to $656.00 monthly. He was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 15 years.

351. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Fernandez Hernandez, which are acts contrary to the law.

35 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 36 of 55 352. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

360. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

361. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

362. Mirmary Rivera Vegas (hereinafter Rivera Vega) is a Career Employee of MAP and holds the position of

Technician , her gross monthly salary of $1545.00 was reduced to $226.45 monthly. She was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of13 years.

363. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Rivera Vega, which are acts contrary to the law.

364. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

365. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

366. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

367. Jehnny Oliveras Silva (hereinafter Oliveras Silva) is a Career Employee of MAP and holds the position of

Maintenance Conservation , her gross monthly salary of $1179.00 was reduced to $628.00 monthly. She was notified on

May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. She has worked for MAP for a total of 12 years.

368. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Oliveras Silva, which are acts contrary to the law.

369. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

36 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 37 of 55 370. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

371. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

372. Ramon L. Rivera Munet (hereinafter Rivera Munet) is a Career Employee of MAP and holds the position of

Construction Supervisor , his gross monthly salary of $1468.00 was reduced to $528.00 monthly. He was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 21 years.

373. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Rivera Munet, which are acts contrary to the law.

374. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

375. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

376. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

377. Javier Luciano Torres (hereinafter Luciano Torres) is a Career Employee of MAP and holds the position of

Oficinista III, his gross monthly salary of $1300.00 was reduced to $693.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 12 years.

378. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Lugo Ramos, which are acts contrary to the law.

379. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

380. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

37 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 38 of 55 381. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

382. Rafael Sepulveda Rivera (hereinafter Sepulveda Rivera) is a Career Employee of MAP and holds the position of Supervisor II , his gross monthly salary of $1828.00 was reduced to $975.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 11 years.

383. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Lugo Ramos, which are acts contrary to the law.

384. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

385. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

386. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

387. Corsino Nazario Alvarez (hereinafter Nazario Alvarez) is a Career Employee of MAP and holds the position of Asistant Administrative V , his gross monthly salary of $2855.00 was reduced to $1,522.00 monthly. He was notified on

May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 16 years.

388. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Nazario Alvarez, which are acts contrary to the law.

389. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

390. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

391.The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

38 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 39 of 55 392. Angel M. Albertorio Ruiz (hereinafter Albertorio Ruiz) is a Career Employee of MAP and holds the position of Driver Heavy Equipment , his gross monthly salary of $1,179.00 was reduced to $629.00 monthly. He was notified on

May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 11 years.

393. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Albertorio Ruiz, which are acts contrary to the law.

394. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

395. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

394. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

395. Luis A Gomez Hernandez (hereinafter Gomez Hernandez) is a Career Employee of MAP and holds the position of Maintenance Shop Director , his gross monthly salary of $1070.00 was reduced to $629.00 monthly. He was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 14 years.

396. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Gomez Hernandez, which are acts contrary to the law.

397. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

398. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

399. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

400. Edgar Velazquez Montalvo (hereinafter Velazquez Montalvo) is a Career Employee of MAP and holds the position of Engineer , his gross monthly salary of $3,046.00 was reduced to $2,437.00 monthly. He was notified on May

30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification

39 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 40 of 55 contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 16 years.

401. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Velazquez Montalvo, which are acts contrary to the law.

402. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

403. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

404. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

405. Tania S. Vega Colon (hereinafter Vega Colon) is a Career Employee of MAP and holds the position of Data

Operator I , her gross monthly salary of $1,1250.00 was reduced to $444.00 monthly. She was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 12 years.

406. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Vega Colon, which are acts contrary to the law.

407. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

408. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

409. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

410. Hilda E. Cartagena Medina (hereinafter Cartagena Medina) is a Career Employee of MAP and holds the position of Administration Assistant V , her gross monthly salary of $1,860.00 was reduced to $961.00.00 monthly. She was notified on May 30, 2014, that his work hours would be reduced by 3.5 hours daily, and his salary reduced. Said written notification contained various errors, including the citation of an inexistent Ordinance, 74 Series 2014-2015, upon which this illegal action was based. He has worked for MAP for a total of 18 years.

40 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 41 of 55 411. The MAP then began to send letters correcting, via Fe de Errata, directed to all MAP employees in general and not directed particularly to Plaintiff Cartagena Medina, which are acts contrary to the law.

412. Said notification letters and subsequent letters, were all signed by Eliezer Velazquez and not the Mayor, another illegal act.

413. The MAP did not exhaust all other measures of reduction in areas not restricted by law and Constitutional

Rights.

414. The Ordinance permitted the reduction of work hours and salary of Career, transitory, and irregular employees, without regard to the rights of career employees who have property rights in their employment.

DEFENDANTS

415. The Municipality of Ponce is an Autonomous Municipality according to Law 81 of August 30th 1991, seg. amed. known as Law Autonomous Municipality of Puerto Rico, and according to said law the Municipality of Ponce have the capacity to be sued and be sue.

. 416. Defendant Maria Melendez Altieri (hereinafter Defendant Mayor) is a natural person as that term is used in the text of the Statute and is an active member of the New Progressive Party (NPP) and at the time of the facts, held the elected position of

Mayor of MAP from 2008 until present, due to re election in 2012. She is the first NPP Mayor of Ponce since 1989 when Rafael

Cordero Santiago became mayor, and as such holds policy and decision making authority within the MAP. She has the authority in law to, and is, being sued in both her official and personal capacities. She is a very active member of the NPP and ran for Mayor of

Ponce, as a candidate for the NPP. At all relevant times, defendant Mayor of Ponce was acting under color of law and pursuant to her authority conceded by the Law.

417. Defendant Janice Gonzalez Galarza is a natural person as that term is used in the text of the Statute and is a militant member of the NPP, and at the time of the facts, held position the Human Resources Director of MAP (Hereinafter Defendant

Gonzalez Galarza, she was hired by the Mayor of Ponce, as Human Resources Director, in October of 2013, She has maintained that position during the time of the facts and presently. At all relevant times, Defendant Gonzalez Galarza was acting under color of law and pursuant to her authority as a Confidence Employee of the MAP as Director of Human Resource. She is an ultra fanatical member of the NPP and lost her bid for Mayorship of the Municipality of Guayanilla in the 2008 and 2012 elections running under the

NPP ticket.

418. Defendant Eliezer Velazquez, is a natural person as that term is used in the test of the Statute and is a militant member of the NPP, and at the time of the facts, held the position of City Asministrator of MAP (Hereinafter Defendant Velazquez), he was hired by the Defendant Mayor in 2013 and has maintained that position during the time of the facts and presently. At all relevant

41 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 42 of 55 times, Defendant Velazquez was acting under color of law and pursuant to his authority as a Confidence Employee of the MAP. He is a fanatical member of the NPP, and was hired by Defendant Mayor after he lost in his election bid for Senator running under the NPP ticket in 2012.

419. Defendant John Roe is a natural person as that term is used in the text of the Statute and is currently the legal spouse of co- defendant Janice Gonzalez Galarza and arising from their marital union is a liable. John Roe benefits from the salary of

Gonzalez Galarza and benefited from it at the time of the facts.

420. Defendant SLGOR is the conjugal legal partnership composed of Janice Gonzalez Galarza and John Roe and benefits from her salary at the time of the facts..

421. Defendant Jane Doe (hereinafter Jane Doe) is a natural person as that term is used in the text of the Statute and is currently the legal spouse of co- defendant Eliezer Velazquez and arising from their marital union is a liable. Jane Doe benefits from the salary of Velazquez Galarza and benefited from it at the time of the facts.

422. Defendant SLGOR I is the conjugal legal partnership composed of Janice Gonzalez Galarza and John Roe and benefits from her salary at the time of the facts..

423. SLGFF is the conjugal legal partnership created between Joe Foe and Flo Foe and benefits from the salary of Joe Foe.

424. Insurance companies XYZ are the Insurance companies which carry the policies of the MAP and which offer coverage for actions of the present nature.

425. John Doe II 1 is the fictitious names of any persons who acted in common concert with any and or all defendants to cause the violations to the laws contained in the law suit and who have caused injury to Plaintiffs.

V. FACTUAL ALLEGATIONS

426. On November 7, 2008, general elections were held in Puerto Rico. These elections included elections for Mayors of

Municipalities, including Ponce. Prior to the November 2008 elections, the mayors from 1989 had run under the Popular Democratic

Party (hereinafter PPD) ticket. The mayoral candidate running under the New Progressive Party (hereinafter NPP) ticket was Maria

Melendez, who won the election.

427. Accordingly, on January 7, 2009, at 12:01 a.m. Defendant Mayor took office as the Mayor of Ponce.

428. In January 2009, Defendant Mayor changed the composition of the positions of Trust Employees, and as of today the majority of those positions are held by active members of the NPP. Defendant Mayor, also contracted the Professional Services of staunch members of the NPP . However, due to property interests in their employment, career employees were not replaced at that time.

42 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 43 of 55 429. In November of 2012, Defendant Mayor ran as an Incumbent for the Mayorship of Ponce, and again won the elections.

During her two terms, Defendant Mayor would give employment, either through Trust Employee Positions or Professional Service

Contracts to defeated NPP candidates, who had run for political office. One such person is the defeated mayoral candidate for the

Municipality of Guayanilla, Defendant Janice Galarza who ran under the NPP ticket. In October of 2013, she was appointed as the

Human Resources Director for the Municipality of Ponce.

430. In the 2012 general elections, the composition of the Municipal Legislature also changed, and the majority of those voted into the Municipal Legislature were members of the NPP.

431. After being defeated in the election for Senator, Defendant Velazquez was hired as a City Administrator by Defendant

Mayor.

432. The Municipal Legislature of MAP approved Ordinance Number 74 series 2013-2014 upon the promotion of the same by the Mayor of Ponce, which activated a plan of reduction of work hours using as its base Ordinance Number 58 series 2005-2006 Layoff plan. Both Ordinances are illegal, due to the fact that Ordinance Number 58 calls for the adverse employment action against employees based not on their seniority but rather on their identities and job performance.

Ordinance Number 74 is illegal as it uses as it base Ordinance Number 58, to determine which employees would have reduced work hours, it is also illegal as no State of Emergency was declared before its implementation.

433. Since the 2009-2010 Budget, the MAP under the Administration of the Defendants has given salary raises and raises to payment under service contracts each year to their employees including Transitory Employees and Contractors under Professional Service Contracts.

434. The 2014-2015 MAP budget was reduced by approximately 12 million dollars the prior year because the

Defendants had irresponsibly and illegally inflated budget ítems (partidas).

435. The implementation of Ordanince 74, supra was put into effect without any declaration of a Fiscal Crises, or any unbiased economic study that established the need to reduce the work hours of the Plaintiffs.

436. The implementation of Ordinance 74, supra was implemented in an illegal manner because its implementation treated employees, such as Plaintiffs, associated with the PDP in a manner which was different than the treatment different to employees who supported the NPP. Many Plaintiffs who were career employees with more seniority had their hours cut while NPP affiliated employees were either left unaffected or had less hours cut, with no studies that justified the disparity of treatment. The new ordinance left the Directors of Departments, who are all Trust Employee’s of the Defendant Mayor, and fanatical NPP activists the option of choosing which employees under them to be exempt from the work hour reduction plan, with no justification required.

43 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 44 of 55 437. Ordinance 58, in itself is an illegal ordinance as it orders that the Identity of each employee be given to the

Mayor; and furthermore, it authorizes the layoffs and cutting of hours of employees based, not on their seniority, but rather their job performance, which thus requires a hearing before adverse employment actions are taken against an employee.

438. That the 2014-2015 Budget was approved on June 13, 2014, and the Defendants in said Budget claimed to have over 400 transitory employees, and over 50 confidence employees, none who have the same propietary rights over their employment as a career employee has.

439. The Defendants illegally, through the application of Ordinance 74, supra, reduced the hours of the transitory employees in the same way that they reduced the hours of the career employees although the Career Employees have propietary rights over their employment and the Transitory Employees do not.

440. The Municipal Legislature of MAP approved Ordinance Number 74 series 2013-2014 upon the promotion of the same by the Mayor of Ponce, which activated a plan of reduction of work hours using as its base Ordinance Number 58 series 2005-2006 Layoff plan. Both Oridnances are illegal, due to the fact that Ordinance Number 58 calls for the adverse employment action against employees based not on their seniority but rather on their identities and job performance.

Ordinance Number 74 is illegal as it uses as it base Ordinance Number 58, to determine which employees would have reduced work hours, it is also illegal as no State of Emergency was declared before its implementation. Furthermore,

Ordinance was imposed in an arbitrary manner, which affected PPD employees, while NPP candidates were not affected and/or were not as harshly affected.

441. Since the 2009-2010 Budget, the MAP under the Administration of the Defendants has given salary raises and raises to payment under service contracts each year to their employees including Transitory Employees and Contractors under Professional Service Contracts.

442. The 2014-2015 MAP budget was reduced by approximately 12 million dollars the prior year because the

Defendants had irresponsably and illegally inflated budget ítems (partidas).

443. The implementation of Ordanince 74, supra was put into effect without any declaration of a Fiscal Crises, or any unbiased economic study that established the need to reduce the work hours of the Plaintiffs, and treated career employees who are identified as PPD party supporters, differently than NPP party supporters.

444. The implementation of Ordinance 74, supra was implemented in an illegal manner because its implementation treated employees, such as Plaintiffs, associated with the PDP in a manner which was different than the treatment different to employees who supported the NPP. Many Plaintiffs who were career employees with more seniority had their hours cut while NPP affiliated employees were either left unaffected or had less hours cut, with no studies that justified the disparity

44 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 45 of 55 of treatment. The new ordinance left the Directors of Departments, who are all Confidence Employee’s of the Mayor, and fanatical NPP activists the option of choosing which employees under them to be exempt from the work hour reduction plan, with no justification required.

445. Ordinance 58, in itself is an illegal ordinance as it orders that the Identity of each employee be given to the

Mayor; and furthermore, it authorizes the layoffs and cutting of hours of employees based, not on their seniority, but rather their job performance, which thus requires a hearing before adverse employment actions are taken against an employee.

446. That the 2014-2015 Budget was approved on June 13, 2014, and the Defendants in said Budget claimed to have over 400 transitory employees, and 50 confidence employees none who have the same propietary rights over their employment as a career employee has.

447. The Defendants illegally, through the application of Ordinance 74, supra, reduced the hours of the transitory employees in the same way that they reduced the hours of the career employees although the Career Employees have proprietary rights over their employment and the Transitory Employees do not.

448. The Defendants failed to properly notify Career employees of the illegal reductions, and the notification of reduction letters were signed by Defendant Velazquez, though he has no authority to fire or hire or reduce the hours of employees.

VI. FIRST CLAIM FOR RELIEF Under 42 U.S.C. SECTION 1983 (Political Discrimination, Violation of Freedom of Speech and Association)

449. All above mentioned Plaintiffs allege and incorporate by reference as though fully set forth herein the allegations set forth in all previous Paragraphs.

450. After the passing of Ordinance 74, supra MAP mayor was directly involved with both the reviewing of personnel files, and the notification process. She had knowledge of the identities of the employees who filled each position, and knew which employees had been hired by the previous two administrations. She made individualized decisions about which employees would have their hours and salaries reduced.

451 All defendants named in this complaint are militant members of the NPP party, and have actively participated in concert amongst themselves, and under color of authority in a chain of events which culminated with the harassment, and arbitrary illegal reduction of work hours and salaries and benefits of all Plaintiffs, and the refusal to reinstate them to their regular hours, salaries and benefits, due to the fact that plaintiffs political affiliations were different than those of all defendants.

452. If Plaintiffs shared defendants political beliefs their work hours, salaries and benefits would not have been reduced, as NPP employees and contractors hired by MAP mayor have either not have had their hours reduced or have

45 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 46 of 55 suffered minimal reduction of work hours, and have been exempted from these punishments. Were it not for their political affiliation, and their association with previous administrations of the MAP Plaintiffs would not have had their work hours, salaries, and benefits drastically, arbitrarily, and illegally reduced.

453. Plaintiffs were all public career employees of the MAP who could not be harassed, demoted, constructively discharges, have their hours illegally reduced, have their salaries and benefits reduced, refused reinstatement to regular work hours, based on their identities and based on their political affiliation or due to exercising their Constitutional Rights to

Freedom of Expression and Freedom of Speech and Association under the First Amendment of the United States

Constitution.

454. The conduct and acts of all defendants in illegally harassing, implementing an illegal ordinance, illegal reduction of work hours, salary, and benefits .

455. Defendants implemented an illegal ordinance that authorized them to target certain employees based, not on their seniority or employment status, but rather on their identity and their performance.

456. Plaintiffs are all members of the Municipal Association Employees Union Steel Workers (hereinafter

UNION) , and were hired, contracted, retained and/or given permanency under PPD Mayors who had held office from 1989 up until 2008. Defendants have targeted Plaintiffs as they are believed to be PPD party members and/or supporters. The

Defendant Mayor has stated both privately and publically that the only employees who gave her problems were the

Association employees and they were all Populetes, a derogatory term used to identify PPD members and supporters. Thus the ultimate authority at the MAP had identified Plaintiffs as PPD supporters/members.

457. The Mayor, Defendant Galarza, Defendant Velazquez together with Confidence Employees holding Director

Positions, identified employees by names of each employee and their positions, and dates of hire which allowed them to target Career employees hired under previous administrations. The regorinazation plan was not a bonafide government regorinazation plan, but rather an illegal one, as no consideration was given to seniority nor the property rights over each

Plaintiffs employment. Defendants acted under color of authority in the identification, targeting, discriminating against each employee.

458. Defendants implemented the aforementioned illegal reorganization plan with the purpose of targeting and politically discriminating against those employees who were hired before Defendant Mayor was elected, because those employees were recruited when the opposing political party was in power, and thus associated with the PPD and identified as supporters of the PPD.

46 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 47 of 55 459. All Plaintiffs are members of the “Union” . On several occasions before the creation and implementation of

Ordinance the Defendant Mayor has declared that the “Union” members were trouble makers because they were all

“Populetes” a derogatory term used to describe members of the Popular Democratic Party.

460. The Mayor had told Plaintiff Mayra Rivera Nazario, that she was a populate and that the other career employees were populates and were problematic.

461. Defendant Mayor has continuously labeled and targeted employees who are associated with the PPD. She has labeled them as trouble makers, populetes, politiqueros, machistas and cowards. She has harassed them verbally because they belong to a different party than she does, and she has done so under color of authority.

462. Defendant Mayor has implemented an ordinance that is illegal in order to further target and punish Plaintiffs, whom she assosiciates with the PPD. She has cut their salaries and hours claiming that there is no money to pay them, yet people she has hired and/or contracted under her administration have suffered either no or minimal salary, hours, and benefit cuts. Although Defendant Mayor has alleged that there was not enough money to pay for employees regular working hours, she has continued to hire new NNP members as employees, and contract NPP supporters under Professional

Service Contracts. She has committed these acts under color of authority.

463. Defendant Mayor and Defendant Galarza and Defendant Velazquez identified which employees were hired before Defendant Mayor was elected, and targeted those employees for hour, wage, and benefit cuts, in hopes that they will quit their jobs so that they may be replaced with NPP supporters. These Defendants have committed these acts under color of authority.

464 On October 2013, Defendant Janice Galarza was hired as Human Resources Director of MAP. She was appointed a

Confidence Employee by the Ponce Mayor, she is a fanatical NPP activist, who ran under the NPP ticket and at all pertinent times was acting under color of authority.

465. Although the Ordinance stated that if two employees were components of a family unit, only one would be affected by the reorganization, the employees who requested such consideration were denied or merely ignored by the

Defendant Galarza who was responsible for implementing exemptions for those employees. Defendant Galarza has committed these acts under color of authority.

466. Defendant Galarza, as Human Resources Director had the obligation to protect employee Plaintiffs from harassment and discriminatory and illegal acts. However, because the Plaintiffs are associated with a different political party than she is, she has refused to protect them, and has rather furthered and participated in the illegal and discriminatory acts against Plaintiffs.

47 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 48 of 55 467. Defendant Galarza, without the authority to do so, changed the date of effectiveness for the hour, wage, and benefit cuts to an earlier date, with no notification. She did so in order to retaliate against Plaintiffs for protesting her discriminatory actions.

468. Defendant Mayor and Defendant Galarza in their letter of notification stated that the employees could apply for welfare and food stamps; however, when many did they did not qualify.

469. Defendant Velazquez is the City Administrator, and does not have the authority in law to fire, hire, demote, or reassign employees much less to cut their work hours, salaries and benefits. However, he has signed the notification letters, and has included false information in said letters to justify his actions, and to cause further damages to Plaintiffs in order to punish them and discriminate against them because he associated them with a different political party than the one in which he belonged to.

470. All defendants named in this complaint are militant members of the NPP party and actively participated in concert among themselves in a chain of events which culminated with the illegal reduction of hours of Plaintiffs, harassment and arbitrary reduction of hours of employment, refusal to reinstate Plaintiffs regular hours and salary due to the fact that Plaintiffs’ political affiliation was different than theirs and all defendants acted under color of law at all relevant times; although Plaintiffs performed their jobs at levels that met everyone’s expectations, including their superiors, the excellent quality of Plaintiffs’ work is the reason that they worked for MAP for many years and received promotions.

471. Plaintiffs were public career employees, who did not formulate public policy and who could not be harassed, demoted, constructively discharged, fired, have their hours and salary and benefits reduced, refused reinstatement and refused rehiring due to their political affiliations or due to the exercising of their Constitutional right to freedom of expression and freedom of association under the First Amendment of the United States Constitution.

472. On May 30, 2014, Defendant Mayor of Ponce signed and approved Ordenanza Number74 serie 2013-2014 which she promoted to the Municipal Legislature and which was approved by the Municipal Legislature of Ponce on May

29, 2014, by members of said body who were all elected to their posts running as members of the NPP. Said Ordinance activated a work hour reduction, by implementing Ordinance 58 Series 2005-2006 Titled Lay Off Plan or in Spanish “Plan de Cesantías”, which in itself authorizes Layoffs and Reduction of Hours based on the identities of employees and their productivity which makes the Plan illegal as it only uses seniority as an alternative. Based on the implementation of this lay off plan only members of the Popular Democratic parties named by previous administrations would have their hours cut, and employees who belong to the NPP would not have their hours cut.

48 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 49 of 55 473. The implementation of the Odinance has directly affected the Constitutional and Statutory Rights of the

Plaintiffs, as it treats them differently than other employees with less seniority, who belong to a different political party then they do and who support the Municipal Legislature and the Mayor of Ponce and the NPP.

474. The conduct and acts of all defendants in illegally identifying, targeting, harassing, illegally cutting work hours, salary and benefits and not reinstating a regular 40 hour work week, salary and benefits due to their political affiliation, and the exercising of

Freedom of Speech and Association is a violation of Plaintiffs’ rights under the First Amendment of the United States Constitution.

475. Plaintiffs were hired under the municipal administration of a PPD Mayor. The Defendant Mayor, all employees in the

MAP, not to mention in the Department where each worked, including their supervisors, and program directors had clear knowledge that Plaintiffs were hired, contracted, retained and/or given permanency under prior PPD administrations.

476. Plaintiffs are all members of the “Union”, which Defendant Mayor has stated was full of troublemaking populetes.

477. Plaintiffs personnel files included dates of hire and that they were members of “Union”, which gave Defendant Mayor,

Defendant Galarza, and Defendant Velazquez clear knowledge that they were hired under PPD administrations and thus were identified as populetes.

478. By reason of the foregoing, Defendant Mayor, Defendant Galarza, and Defendant Velazquez have all subjected all Plaintiffs to the deprivation of their First Amendment rights and are liable in damages to all Plaintiff under 42

U.S.C. Section 1983.

479. Defendants all contributed to the harassment and discrimination campaign against Plaintiffs by passing and implementing illegal ordinances which permitted the identification and targeting of employees hired under prior PPD administrations, and for labeling these employees as politiqueros and populetes, and by, illegally cutting their work hours, salaries and benefits, and replacing them with NPP affiliated employees and contractors, by reducing hours, wages, and benefits on a date before the illegal hour, wage, and benefit reductions were to occur, by refusing to exempt married couples; and for treating them differently than employees not affiliated with the PPD, condoning harassment, by implementing an illegal wage/hour/benefit reduction program that would target and cause harm to employees who were hired under previous

PPD administrations. Each Defendant used his respective position to discriminate against and harass all Plaintiffs, under color of the law, and to attempt to constructively fire Plaintiffs because Defendants believed their political affiliations were different then their own, and are negligent and/or acted with malice or total disregard for Plaintiffs’ civil, constitutional and contractual rights.

49 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 50 of 55 480. By reason of the aforementioned acts of political discrimination, defendants have subjected Plaintiffs to the deprivation of their First Amendment rights afforded by the United States Constitution and is liable in damages to Plaintiff

Santiago under 42 U.S.C. Section 1983.

481. As a direct and proximate result of defendants’ continuous violations of Plaintiffs’ First Amendment rights, plaintiffs have sustained severe injuries and pray judgment against defendants jointly and severely for lost benefits, and wages, they have a proprietary interest over their positions and thus their salaries and benefits, pursuant to both the United

States and Puerto Rico Constitutions, as well as to interests over the aforementioned lost benefits, in an amount no less than

Two Million Dollars ($2,000,000.00) for all Plaintiffs..

482. Given that the law was clearly established at the moment that all Defendants engaged in the deliberate, discriminatory and unlawful violations of Plaintiffs’ rights under the United States Constitution, defendants’ conduct constitutes reckless disregard for plaintiffs’ constitutional rights for which all Plaintiffs are entitled to punitive damages in an amount no less than Five Million Dollars ($5,000,000.00).

483. Moreover, as a result of all the defendant’s discriminatory actions, Plaintiffs lives have been severally altered and affected, due to the fact that their principal sources of income was jeopardized and grossly affected due to their political associations and beliefs, Plaintiffs have suffered and continues to suffer deep mental pain and emotional anguish which is estimated in a sum no less that Five Million Dollars ($5,000,000.00)., plus interest, attorneys; fees, costs and such other and further relief as justice may require.

484. Finally due to the illegal, arbitrary, discriminatory actions and harassment which are all continuous, by defendants towards Plaintiffs, they must be ordered to desist from such behavior, and put Plaintiffs back to work at 40 hours per week, and allow them the same wages benefits received before the implementation of the illegal wage reduction ordinance.

485. All Defendants spouses who are and/or were legally married to defendants at the time of the facts, benefitted from all defendants salaries and are thus liable to Plaintiffs for the discriminatory acts of their spouses.

486. All Defendants Conjugal Legal Partnerships composed of Defendants and their spouses presently and/or at the time of the facts benefitted from the Salaries of all defendants and are thus liable to Plaintiffs for the actions of defendants.

487. John Does 1, is liable to Plaintiffs as they have, under color of authority conceded to them by their positions, contributed to the harassment, discrimination, illegal hour, wage, and benefits reduction of all Plaintiffs because he is affiliated to a different political party than he believes that they are.

50 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 51 of 55

VII. SECOND CLAIM FOR RELIEF (Violation of Plaintiff’s Fourteenth Amendment Due Process Rights)

488. Plaintiffs reproduce and reaffirm as if alleged herein each and every one of the preceding allegations.

489. Plaintiffs are all career employees and each holds a property right over his/her position in the MAP, and could and cannot be arbitrarily, discriminatorily demoted, or have their work hours, wages, and benefits reduced for reasons other than their performance which was excellent, yet all defendants in violation of Plaintiffs' due process rights under the Fourteenth Amendment of the United States Constitution arbitrarily and discriminatorily reduced all Plaintiffs’ work hours, wages, and benefits but based on their political beliefs.

490. Ordinance Number 58 series 2005-2006 Layoff plan. Both Oridnances are illegal, due to the fact that

Ordinance Number 58 calls for the adverse employment action against employees based not on their seniority but rather on their identities and job performance. Ordinance Number 74 is illegal as it uses as it base Ordinance Number 58, to determine which employees would have reduced work hours, it is also illegal as no State of Emergency was declared before its implementation. Furthermore, Ordinance was imposed in an arbitrary manner, which affected PPD employees, while

NPP candidates were not affected and/or were not as harshly affected.

491. Defendants under color of law, created Ordinance No. 74 to reduce all Plaintiffs work hours and salaries, which would also adversely affect their benefits such as retirement, sick leave, bonuses, and vacation leave, and put into danger their Social Security Benefits as well, due to the fact that hours and salaries accrued are now minimal.

492. Defendants used Ordinance No. 74, supra to implement Ordinance Number 58, a layoff plan. Ordinance

Number 58, allowed for the layoffs and other adverse employment actions not to be based on seniority; but rather on employee performance, and permitted decision makers to have a list of employees and the positions which they held.

Because performance and identity were considered, each employee who suffered adverse employment actions had the right to an informal hearing to defend their performance. No informal hearing was ever offered to them, and their hours, salaries and benefits were arbitrarily reduced.

493. Not once under the NPP Administration was Plaintiff notified that he had the right to an informal hearing, and once their hours were reduced Defendant Mayor continued to hire and concede Professional Service Contracts to members of her own party, though Plaintiffs were more qualified than their replacements and had many more years of experience in their jobs.

494.The Commonwealth of Puerto Rico through the Law 81, supra authorizes the Municipal Legislature to create ordinances, thus the creation of an ordinance is legal. The Municipal Legislatures as authorized by the Commonwealth,

51 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 52 of 55 create ordinances. The creation of Ordinances are legal and authorized; however, in the present case what was authorized violated the Constitutional Rights of all Plaintiffs; and the actions of Defendant Mayor and the Municipal Legislators who approved the Ordinance were foreseeable as when there is a change in the composition of elected officials, the rates of violations to Constitutional Rights by those officials skyrockets as can be seen in case filings before this Honorable Court, the Honorable First Circuit Court of Appeals, and the Honorable State Court. So although the passing of an Ordinance is authorized, it was foreseeable that Political Discrimination would ensue.

. 495. Defendants’ personnel actions alleged in the present complaint were continous and under color of law, and made with blatant disregard to Plaintiffs’ Fourteenth Amendments Due Process Rights, as a career employee of the MAP.

496. The conduct and acts of all defendants named in this complaint resulted in the illegal reduction of salaries, hours, and benefits, as well as refusal to reinstate full hours, salaries, and benefits; harassment and retaliation is due to

Plaintiffs affiliation with the prior PPD administrations, and constitute violations of their due process rights under the

Fourteenth Amendments of the Constitution of the United States.

497. As a result of the willful violation of plaintiffs’ and continuous Constitutional rights under the United States

Constitution, all Plaintiffs are entitled to complete restitution of the positions, their full time hours, full time salaries, and benefits including but not limited to raises, bonuses, and fringe benefits they would have received if their hours would not have been illegally reduced at the MAP.

498. The salary and benefits alone is estimated in an amount no less than One hundred thousand Dollars

($100,000.00) for every month that passes by.

499. Plaintiffs are also entitled to injunctive relief enjoining defendants from further discrimination, harassment, and retaliation against them because of their Political Association and their beliefs now and in the future.

VIII. THIRD CLAIM FOR RELIEF

(Punitive Damages)

504. Plaintiffs reproduce and reaffirm as if alleged herein each and every one of the preceding allegations.

505. The above described unlawful acts of all defendants were willful, wanton, malicious oppressive and/or with reckless disregard or delivered indifference to Plaintiffs’ Constitutional Rights, which Defendants knew were contrary to the law, for which Plaintiffs are entitled to punitive damages in the amount of no less than FIVE MILLION DOLLARS

$5,000,000.00 .

52 Case 3:15-cv-01731-CCC Document 1 Filed 05/31/15 Page 53 of 55 IX. FOURTH CLAIM FOR RELIEF (Political Discrimination under Law 100 of Puerto Rico)

506. Plaintiffs reproduce and reaffirm as if alleged herein each and every one of the preceding allegations.

507. The discriminatory termination, constructive discharge and/or non re-employment of all Plaintiffs of the basis of their political beliefs by the part of all defendants constitute an open violation of the Constitutional Rights guaranteed to

Plaintiffs by the Constitution and the Laws of Puerto Rico.

508.. Pursuant to Puerto Rico’s Law 100 29 LPRA sec. 146, plaintiffs are all entitled to a sum equal to twice the amount of the pecuniary, back pay, their job back and moral damages claimed in the present complaint.

X. FIFTH CLAIM FOR RELIEF

(Attorneys Fees 42 U.S.C. 1988 and State Laws)

509. 42 U.S.C 1988 is applicable to the present case due to the fact that violations under 42 U.S.C. 1983 and 1985 have occurred. It is requested that This Honorable Court impose upon Defendants a reasonable amount according to the law for Attorneys fees under 42 usc 1988.

510. Under State Laws Defendants are liable for the payment of Attorneys Fees and the Appearing Party requests that an additional amount be imposed upon Defendants in the present case.

XIII PRAYER FOR RELIEF:

1. WHEREFORE, PLAINTIFFS PRAY TO THIS COURT TO ORDER: A. Reistatement of Plaintiffs to their positions including their salaries and benefits. B. Back pay, double pay, double damages, bonuses and benefits to each Plaintiffs. C. Emotional damages to for all Plaintiff in an amount not less than Two million dollars ($2,000,000.00). D. Punitive Damages in an amount of Five Million Dollars ($5,000,000.00). E. Attorneys Fees, cost and prejudgment and post judgment interests. F. Any other remedy that this Honorable Courts deems just and proper.

Respectfully submitted in Ponce to San Juan, Puerto Rico this 31st of May 2015.

JRAF LAW FIRM P.S.C. P.O. BOX-7498 PONCE P.R. 00732 TEL. (787) 651-6909 FAX: (787) 651-6957

S/JUAN P. RIVERA ROMAN JUAN P. RIVERA ROMAN USDC:210906

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