Note and documents regarding settlement and payment of $300,000 by Plumas County to ex-CAO, Lucero, in response to a Government Tort Claim.

Settlement with Former Plumas County CAO Raises Transparency Questions
When the Plumas County Board of Supervisors approved a $300,000 settlement with former County Administrative Officer Debra Lucero, the decision was not publicly disclosed at the time it was made. The settlement only became public weeks later through local media reporting following disclosure via public records requests.
Since that initial reporting, additional documents obtained through the California Public Records Act provide greater detail about how the settlement unfolded—and raise new questions about transparency, process, and oversight.
According to records and timelines now available, Ms. Lucero filed a Government Tort Claim with Plumas County on October 13, 2025. The sequence of events that followed illustrates how the claim and settlement progressed:
Timeline of Key Events

•   Oct. 13, 2025 – Former County Administrative Officer Debra Lucero files a Government Tort
  Claim with Plumas County.
•   Oct. 14, 2025 – The Plumas County Board of Supervisors holds a closed session in which the
  Lucero matter is discussed.
•   Oct. 16, 2025 – The Trindel Insurance Fund holds a claims review meeting with Plumas County
  Risk Management. A decision is made to settle Lucero’s claim. An agenda is posted online,
  but no minutes are currently available online.
•   Oct. 17, 2025 – Lucero is notified that the County will settle the claim for $300,000.
•   Nov. 13, 2025 – Board Chair Kevin Goss signs the settlement agreement on behalf of Plumas
  County. There is no public report of the action or vote to the full Board or the public. Goss later told the Plumas Sun that only he and Vice Chair Mimi Hall were informed of the settlement amount.
•   Dec. 8, 2025 – A Public Records Act request is submitted to County Counsel Josh Brechtel seeking the settlement agreement.
•   Dec. 18, 2025 – County Counsel provides a copy of the settlement agreement.
•   Dec. 19 and Dec. 21, 2025 – The settlement agreement is published online.
•   Dec. 21, 2025 – A second Public Records Act request is submitted seeking (1) the Government
  Tort Claim filed by Lucero, and (2) documentation of County funds expended on legal fees
  related to the settlement.
•   Dec. 30, 2025 – County Counsel requests a 15-day extension (to January 15, 2026), citing the
  need for consultation “with another agency having substantial interest” in the request.
•   Jan. 2, 2026 – A Public Records Act request is submitted to Trindel Insurance Fund seeking
  claim-related records, including the Government Tort Claim filed by Lucero.
•   Jan. 12, 2026 – Trindel produces a redacted copy of Lucero’s Government Tort Claim (copy
  attached).
•   Jan. 14, 2026 – Plumas County Counsel produces the same redacted version of the claim in
  response to the Dec. 21, 2025 Public Records Act request. No documentation is provided regarding County funds expended on legal fees related to the settlement.

1
Allegations and Settlement Context
In her October 13, 2025 Government Tort Claim, Lucero presented a list of claims she may assert against the County, individual County employees, and agents acting on behalf of the County, including the following:

1. 1)  retaliation in violation of Labor Code sections 1102.5 and 232.5;
2. 2)  defamation;
3. 3)  breach of employment contract;
4. 4)  breach of implied covenant of good faith and fair dealing;
5. 5)  failure to perform mandatory duty (e.g., investigate complaints, protect whistleblowers, abide by civil service rules, etc.);
6. 6)  negligent hiring, supervision and training;
7. 7)  violations of the Brown Act;
8. 8)  interference with employment in violation of Labor Code section 1050; and,
9. 9)  intentional infliction of emotional distress;
10. 10)  punitive damages against individuals for their oppression, fraud, and malicious conduct.

The claim names:

1. 1)  Josh Brechtel (County Counsel);
2. 2)  David Hollister (District Attorney);
3. 3)  Sara James (Deputy County Counsel)
4. 4)  Kevin Goss (Chair of Board);
5. 5)  Jeff Engel (Board members);
6. 6)  Dwight Ceresola (former Vice Chair);
7. 7)  Mimi Hall (Vice Chair of Board);
8. 8)  Kristina Rogers (Paralegal);
9. 9)  Julie White (Treasurer-Tax Collector);
10. 10)  Martee Nieman (County Auditor-Controller);
11. 11)  ToddJohns(formerSheriff);and
12. 12)  CynthiaFroggatt,CountyAssessor,

as individuals alleged to have caused the injuries described. Those allegations were not adjudicated in court and are the subject of the $300,000 settlement without findings of liability.
Brown Act Transparency Requirements Not Met
California law permits public agencies to discuss pending litigation in closed session. However, Government Code § 54957.1(a)(2)—a core provision of the Brown Act—requires that when a legislative body approves a settlement in closed session, it must publicly report:

•   The fact that the action was taken
•   The vote or abstention of each member
•   The amount of the payment and
•   Other material terms of the settlement.
  This reporting must occur immediately after the closed session or at the next regular meeting, depending on timing. The Brown Act does not provide an exception when settlements are paid

2
through a risk pool or joint powers authority. Trindel Insurance Fund is a joint powers authority that operates as a self-insurance pool for rural California counties.
Public Interest Implications
The Lucero settlement underscores the importance of statutory transparency requirements and the public’s interest in understanding how significant financial and legal decisions are made by local government. Whether those requirements were fully met in this case remains a matter of public concern. 



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Redacted Claim Form - Final Lucero from Trindell 1.12.25.pdfCLAIM AGAINST THE COUNTY OF PLUMAS
(Pursuant to Government Code §910.4)
NOTICE: All claims must be presented to the County ofPlumas in accordance with Government Code §915.4. Failure to fully complete this form will result in your claim being returned. Plumas County employees are not allowed to provide legal advice. Attach additional pages if needed.
MAIL TO:
Clerk ofthe Board 520 Main St, Rm 309 Quincy, CA 95971

1. Name of Claimant:-
   
2. Date of Birth:
   

4. Mailing Address o f Claimant:
City State Zip 5. Mailing Address where notices are to be sent (ifdifferent than mailing address ofclaimant):
Address City State Zip

1. TelephoneNumberofClaimant:~(=53 =---------
   INFORMATION ABOUT CLAIM
   
2. Incident Date: Month_ A: c ,p. .r. _il_ _ _ Day 16 Year 2025
   
3. Location ofIncident (ifapplicable, include street address, highway number, post mile number, or direction oftravel):
   Please see attachment
   
4. Explain the circumstances that led to the alleged damage or injury (state all facts that support your claim
   and why you believe the County is responsible for the alleged damage or injury. If more space is needed,
   continue on a se~~te page): Please see attac ent
   
5. General description ofthe specific damage, injury, indebtedness, obligation, or loss incurred so far as it may be known at the time o f presenting claim:
   Please see attachment
   

CLAIMANT INFORMATION
--- - -------------------- 3. Gender (circle one):0Maleia?emale
Page 1 of2
Address

1. Dollar amount of claim (if less than $10,000) as of the date of presenting the claim (include the estimated amount of any prospective injury, damage, or loss, insofar as it may be known when claim is presented):$_ _ _______
   
2. If the amount claimed exceeds $10,000, no dollar amount shall be included in the claim. However, please indicate whether the claim would be limited to civil case:OYES 0 NO
   
3. Name(s) of public employee(s) causing the injury, damage or loss, if known:
   Please see attachment
   CLAIMS INVOLVING MOTOR VEHICLES
   
4. Insurance information (complete if claim involves motor vehicle). Has the claim for the alleged
   

damage/injury been filed (or will be filed) with your insurance carrier? 15. Name o f insurance carrier and telephone number (including area code):
D YES O NO
State Zip
Year: -----
Name
Address
Telephone Number City

1. Policy Number:_ _ _ _ _ _ _
   
2. Are you the registered owner:□YES
   
3. Amount of deductible: $- - - - - - -
   
4. Make:___ _ ____ Model:_ __ _ __
   

D NO
Section 72 ofthe Penal Code provides that a personfound guilty ofsubmitting afraudulent claim may be punished by imprisonment in the County Jail or State Prison, and/or by the imposition ofafine up to
$10,000.00.
Sign•~ : laimant, or by some person legally authorized to submit this claim on your behalf. 'f»1⁄4-lu_,t__u8-- Jo- I?•2.$
Signature Date
1;ebr-a l-uLe,r-D
Printed Name o f Person Completing Claim
Page 2 of2
October 13, 2025
Clerk ofthe Board 520 Main St, Rm 309 Quincy, CA 95971
Re: LUCERO, DEBRA, ATTACHMENT TO CLAIM AGAINST THE COUNTY OF PLUMAS
To Whom It May Concern:
Please accept this attachment to Claim Against the County of Plumas form.
General Description of the Events
The County of Plumas ("County") hired Debra Lucero as the County Administrative Officer ("CAO") on September 6, 2022. Ms. Lucero came to the County with 20+ years experience interacting with county agencies and nonprofits and signed a binding agreement, which was draftedandpresentedtoherbytheCounty. BasedupontheagreementandtheCounty'sstatusas Ms. Lucero's employer, the County is legally bound to engage in the implied covenant of good faith and fair dealing in its employment contracts and dealings with County employees. The County has failed to meet these obligations, as set forth more fully below.
On February 5, 2023, Ms. Lucero outlined, in her first CAO Report to the County's Board of Supervisors ("Board"),.numerous financial irregularities related to the County's accounting practices. This included mishandling of the transient occupancy tax (TOT) revenue, including $574,296 improperly placed in the treasurer-tax collector's budget; a backlog of invoices; failure to reconcile cash; insufficient and untrained staff; same external annual audit staff for 15 years; lack of updated financial policies and procedures; monthly treasurer reports not done since 2021; late investment reporting, and no annual investment policy since April 2022 - all which Ms. Lucero reported to the Board, bringing to its attention the legal and financial risks she had identified. Ms. Lucero then spent several months reviewing County finances and existing financial processes before recommending to the Board that it hire the Clifton, Larson & Allen (CLA) accounting firm to dig into the various issues and processes and catch-up work in the Treasurer's office and create better workflow between the Auditor-Controller and Treasurer-Tax Collector. The Board approved the request. In May 2023, CLA began to review processes and procedures and make recommendations.
On June 22, 2023, The Board instructed County Counsel,
On September 9, 2023, Ms. Lucero made a request to the Auditor-Controller regarding the audit of two sub-funds equaling almost $5 million belonging to the Sheriff and District Attorney. Monies were being swept annually into these funds and the external auditor would move the
Claim Against the County of Plumas
Re: Attachment to GC Form, Lucero, Debra October 13, 2025
Page 12
monies into a fund called "Public Protection" however it was really unspent general fund (GF) money that should have returned to the GF. There were also questions regarding DA funds for the Alternative Sentencing Program that appeared to be commingled with GF monies.
On October 6, 2023, a demand letter was sent to Plumas County Treasurer-Tax Collector by Feather River College (a County investment pool member), requesting an immediate accounting of earned interest for fiscal year 2022/2023, as well as their earned interest for the quarter ended September 30, 2023.
On November 1, 2023, Ms. Lucero received a merit increase. Prior to her merit increase, Ms. Lucero had not received any complaints about her work performance or other deficiencies and nothing is noted in her official personnel file.
On November 17, 2023, Ms. Lucero was asked to fill the Interim HR Director position as Director Nancy Selvage was indicted on felony charges - filed by the DA on 11/16/24 related to a
1090 violation.
The DA attempted to support his false accusations by asserting there was a link between Ms. Lucero and indicted HR Director Selvage, insisting the two were friends. He repeated the "friendship" falsehood for months, stating this in letters, the local online newspaper and at board meetings. This action combined with other public aggressions, involving County governance and the budget, caused Ms. Lucero to file a harassment claim against the DA.
On February 20, 2024, Ms. Lucero submitted a formal complaint against the DA, David Hollister. This was done in a public meeting as the DA is an elected official. The choice to make the complaint public was to be Ms. Lucero's but unknown to her (she was out of town at a Trindel Insurance meeting), the Interim County Counsel Brechtel, along with the Clerk of the Board, Allen Hiskey, put the item on open session.
On March 5, 2024, Ms. Lucero was accused, in a Board meeting, by DA Hollister of malcing the complaint against him to "interfere" with a specific case, referring to the Nancy Selvage case. He said he didn't want to be in the same situation as the Sheriffor the Treasurer-Tax Collector and stated, "No elected official is safe (in Plumas County)" - inferring Ms. Lucero somehow made them unsafe by simply doing her job and carrying out instructions from the Board.
On April 2, 2024, Ms. Lucero, at the request of the Board, prepared a memo to the State Controller's Office outlining the various fmancial issues and improper procedures at the County. The Board was considering asking the state to intervene in its financial issues and discussion ensued at the April 2, 2024 public meeting. The memo addressed the considerable outlay offunds - $1.4 million over two to three years - to update its financial processes and catch up on work that had hindered the timely filing of required financial statements and audits. It also addressed the work done to date and the processes and procedures recommended.
Claim Against the County of Plumas
Re: AttachmenttoGCForm,Lucero,Debra October 13, 2025
Page 13
On May 15, 2024, the hostile workplace investigation of Ms. Lucero's claims about the DA was concluded. The investigator did not interview any witnesses, not even the DA, himself. He concluded that while none of the allegations and evidence supported a prim.a facie case of violation of County policies and procedures, the Board may consider the following actions:

1. Direct his office (through the County Counsel) to conclude the present inquiry as it does not meet prim.a facie standards. (Ms. Lucero disagreed with this fmding as she is a 64-year- old Latina woman.)
   
2. Amend existing policies and procedures to address specific behaviors alleged by the CAO. As an option, the Board may further define abusive conduct to be an independent cause and not dependent on an underlying fmding ofa protected class.
   
3. Provide training on workplace conduct, roles and responsibilities and policies to staff.
   
4. Direct our office (through the County Counsel) to conduct further fact-fmding, as
   determined and defined by the Board in terms of scope and issues.
   The suggestions for better governance or additional fact-finding were not followed nor was
   

the Scope of Work Interim County Counsel prepared released although all privilege had been waived by the Board's presentation of the matter in open session. Overall, the evidence reflects that the County failed to abide by its mandatory duty to fully, fairly, and timely respond to Ms. Lucero's complaints. The County likewise failed to protect Ms. Lucero as a whistleblower and protected class member.
On June 11, 2024, results of Ms. Lucero's complaint against the DA were released to the public. The Board gave up its privilege on the report and the DA's letter, however the Scope of Work by Interim County Counsel Brechtel was not released although it was requested by Ms. Lucero and a public member. Mr. Brechtel stated publicly that it was his right to not release this document.
On June 18, 2024, seven days after the report was released, hostilities escalated toward Ms. Lucero as evidenced by an "Open Letter to the Plumas County Board of Supervisors and Plumas County Residents" signed by David Hollister, District Attorney; Todd Johns, Sheriff; Cindie Froggatt, Assessor; Martee Nieman Graham, Auditor; Julie White, Treasurer Tax Collector; and Mimi Hall, Supervisor-Elect, arguing that the budget prepared by the CAO showed a, "void ofthe experienced budgetary leadership required for such a task" and "sounding the alarm that the county is facing an existential crisis that is a threat to its sheer survival", requesting the Board to step in. This letter clarifies what appeared to be retaliation against Lucero for uncovering fiscal deficiencies and activities that were unethical and likely illegal on the part of some Plumas County elected officials. The "Open Letter" was sent to the local online newspaper THE PLUMAS SUN by Ms. Hall and subsequently published. County employees and officials made untrue public statements about Ms. Lucero in her official capacity as County Administrator. The County did not investigate these claims and Ms. Lucero was not admonished nor disciplined as a result of these untrue statements.
Claim Against the County of Plumas
Re: AttachmenttoGCForm,Lucero,Debra October 13, 2025
Page 14
On August 29, 2024, Ms. Lucero met with Supervisor Elect Hall who brought up a series ofquestions regarding a large-scale ENGIE energy contract the county had entered into. An email chain ensued between the two over the next few days involving attorneys on the project and Interim County Counsel Brechtel. Ms. Hall maintained that the County purchasing policy had not been followed by Ms. Lucero who then referred Ms. Hall to the attorneys on the project.
On August 31, 2024, Ms. Lucero received an email from Supervisor-Elect Hall questioning whether the ENGIE energy contract met public noticing and hearing requirements and cast doubt on whether it was done legally by Ms. Lucero. Ibis sparked an email chain between Ms. Hall, Ms. Lucero and attorneys on the project.
On September 3, 2024, Mr. Brechtel put forth is own application for the County Counsel position on closed session in a potential conflict of interest. Ibis type of action is done by the HR Director or, in this case, Ms. Lucero.
Additionally, the DA had continually tried to link Ms. Lucero to Ms. Selvage's case. On information and belief, the County did not conduct an investigation into Ms. Lucero's claims, in violation of their mandatory duty to investigate. County employees and officials made untrue public statements about Ms.Lucero in her official capacity as County Administrator about this. TheCounty did not investigate these claims and Ms. Lucero was not admonished nor disciplined as a result of these
untrue statements.
Claim Against the County of Plumas
Re: Attachment to GC Form, Lucero, Debra October 13, 2025
Page 15
On October 22, 2024, Ms. Lucero (in her role as Interim HR Director) was made aware through an unrelated social services investigation
On November 4, 2024, Ms. Lucero sent Mr. Brechtel's proposed contract back with changes.
On December 3, 2024, Ms. Lucero received a very positive evaluation, signed by a member o f the County Board o f Supervisors, that gave her high praise and noted her positive contributions, work ethic and performance in line with herjob duties. Ms. Lucero requested 40 hours of additional vacation time as compensation for 1.5 years of doing two jobs - the CAO job for which she was hired and the Interim HR Director position. Her merit increase was retroactive to November 11, 2024 - her permanent hire date. Up to and including this period, Ms. Lucero was not disciplined in any capacity.
Claim Against the County of Plumas
Re: Attachment to GC Form, Lucero, Debra October 13, 2025
Page 16
On December 6, 2024, Ms. Lucero again asked the Board leadership for an investigation into Mr. Brechtel's August 30, 2024 email. Nothing happened. On information and belief, the County did not conduct an investigation into her claims, in violation of their mandatory duty to investigate. County employees and officials made untrue public statements about Ms. Lucero in her official capacity as County Administrator. The County did not investigate these claims and Ms. Lucero was not admonished nor disciplined as a result ofthese untrue statements.
On December 10, 2024, During a public Board of Supervisors meeting, Interim County Counsel Brechtel stated that the Board had decided to "farm out" the County Counsel position. He said, "I applied for that position and was given a conditional offer back in October. At this time, the Board of Supervisors is going to farm out my position so I will not be the permanent County Counsel."
On December 17, 2024, DA Hollister made an appearance at the Board meeting to cast doubt on the ENGIE energy project process which received final approval by the Board at its 9/3/24 meeting in a 4-1 vote. He reiterated many of Supervisor-Elect Hall's concerns which had been addressed by external attorneys and by Interim County Counsel Brechtel in an exchange of emails.
On January 7, 2025, Ms. Lucero made another official request to investigate
On information and belief, the County did not conduct an investigation into her claims, in violation of their mandatory duty to investigate. On that same day, Supervisor-Elect Mimi Hall was sworn in as Vice Chair in a Brown Act Violation. Ms. Lucero believes that the County engaged in a pattern and practice ofviolating the Brown Act and has continued to violate the Brown Act. As such,the violations are ongoing and accruing.On this same day, Ms. Hall questioned Ms. Lucero's award of 40 hours of vacation time. The item was pulled and never addressed. On information and belief, the County failed to abide by its mandatory duty to fully, fairly, and timely investigate and respond to Ms. Lucero's complaints. The County likewise failed to protect Ms. Lucero as a whistleblower. Additionally, Ms. Lucero was never awarded the 40 hours of vacation time agreed upon by the Board prior to Ms. Hall's term of office. Ms. Hall should have recused herself from the conversation as she was not yet seated as a supervisor when the December 3, 2024 evaluation of Ms. Lucero was made by the
Board, awarding her 40 additional hours o f vacation time.
On January 7, 2025, DA Hollister filed a complaint against Ms. Lucero - an ethics violation involving an ENGIE-sponsored dinner at a statewide conference that was legally reportable on her 700 form (not due until April 1, 2025). He also registered complaints about violating the County's purchasing policy. Previously and prior to this complaint, Ms. Lucero complained about the DA' s conduct and .
Claim Against the County of Plwnas
Re: AttachmenttoGCForm,Lucero,Debra October 13, 2025
Page 17
On January 8, 2025, Ms. Lucero received a phone call by Ashu Jain, a representative of ENGIE - an energy vendor who was attending a statewide conference ofcounty officials. Mr. Jain told Ms. Lucero that Chair Kevin Goss had said the DA plans to indict Ms. Lucero on "something to do with violating the purchasing policy."
On January 10, 2025, Ms. Lucero called Board Chair Goss to ask him about Mr. Jain's claims that the DA is planning to indict her on something related to the energy project and purchasing policy. Mr. Goss responded that the DA is "Just blowing smoke."
On January 13, 2025, Ms. Lucero complained to the Board of Supervisors about Interim County Counsel Josh Brechtel and other County employees, and Mimi Hall, now a Board of SupervisorsMember. On information and belief,the County failed to abide by its mandatory duty to fully, fairly, and timely investigate and respond to Ms. Lucero's complaints. The County likewise failed to protect Ms. Lucero as a whistleblower.
On January 13, 2025, Deputy County Counsel Sara James filed an EEOC complaint against Ms. Lucero in an email to the Board. Previously and prior to this complaint,
On January 21, 2025, Ms. Lucero was scheduled for a self-requested performance evaluation (Item SA). On the Friday before the January 2ist board meeting, Interim County Counsel Brechtel added three exposure to litigation items under SC. Mr. Brechtel asked to take Item SC first and Ms. Lucero was asked to leave the room.
Ms. Lucero never returned to closed session because
Ms. Lucero was not informed as to why she was being put on Admin Leave and was unaware ofthe complaints by the DA and Ms. James until sometime during the official investigation. On information and belief, the County failed to abide by Brown Act laws governing specific complaints or charges brought against an employee by another person or employee in closed session. The employee shall be given written notice ofhis/her right to have complaints or charges heard in open session at least 24 hours in advance and must be provided an opportunity to rebut the allegations before action is taken.
Claim Against the County ofPlumas
Re: Attachment to GCForm,Lucero,Debra October 13, 2025
Page 18
In retaliation for various complaints by Ms. Lucero about County employees, officials, and alleged unlawful County practices, the County Board of Supervisors, acting in their official capacity and as the employer of Ms. Lucero, . Up to this date, Ms. Lucero had not been counseled or disciplined about her job performance and/or any alleged misconduct. More, the County had not investigated Ms. Lucero's voluminous claims. In fact, the County, instead, investigated DA Hollister's complaint and Ms. James' complaint. The results of that investigation were never released to Ms. Lucero although a request was made multiple times.
On April 16, 2025, in retaliation for various complaints by Ms. Lucero about County employees, officials, and alleged unlawful County practices, the County Board of Supervisors, acting in their official capacity and as the employer of Ms. Lucero, terminated Ms. Lucero and notified her that her employment contract would be terminated.
Ms. Lucero does not believe that her termination or the termination ofher employment contract was made in good faith, much less for
cause or fault.
On June 23, 2025, Ms. Lucero was notified by the California Secretary of State that her voter registration in Plumas County had been canceled although Ms. Lucero had not canceled her voter registration and still owned a home in Plumas County. She later learned that the Clerk- Recorder had purged her record "accidentally."
On July 16, 2025, Ms. Lucero contacted Plumas County HR Department to verify the end date of her health insurance in order to coordinate enrolling in Medicare on her birthday. Mr. Brechtel responded that all communications needed to go through her attorney but verified Ms. Lucero's insurance was good through Sept. 1, 2025.
On July 28, 2025, Ms. Lucero received a notification from CalPERS that her insurance was canceled. Additionally, one ofher physicians notified her that her insurance had been turned down. She made an inquiry to CalPERS and learned a "re-determination letter" had been sent by Plumas County HR retroactive to 5/31/2025. A CalPERS senior analyst said that on July 23, 2025, Plumas County did"...something in the system" that triggered the automated CalPERS cancellation letter.
Claim Against the County of Plumas
Re: Attachment to GC Form, Lucero, Debra October 13, 2025
Page 19
This incident caused several days ofworry and concern to Ms. Lucero who actively worked with CalPers to get reinstated due to her medical issues.
On August 27, 2025, Ms. Lucero was negatively portrayed in a Plumas Sun article detailing the award of $175,000 in attorney's fees to the Treasurer-Tax Collector. Supervisor Jeff Engel stated, 'We here today because of five people's misjudgment, three of which are no longer with the county,' said Engel, in an apparent reference to Selvage, Lucero and Hagwood, the article stated.
Since Ms. Lucero's unlawful termination, Ms. Lucero has been unable to find employment due to the public misrepresentations made by County employees and agents.
Throughout her tenure as the County Administrator, Ms. Lucero "blew the whistle" and publicly noted and/or complained about various County practices, many ofwhich violated the law and policy, including record keeping, finances, and violating public transparency laws.
On information and belief, and direct review of published statements, County employees and/or agents and/or parties acting on behalf of, the behest of, and in conspiracy with publicly defamed Ms. Lucero by making untrue statements about her that any person would have reasonable understood the statement to be about Ms. Lucero, that the statements were known to be false and/or their veracity was not reasonably investigated, and/or the statements were not hyperbole.
On information and belief, and based on the actions and omissions committed against Ms. Lucero, the County failed to hire, train, and supervise its employees, specifically regarding responding and investigating complaints by employees, protecting whistleblowers, ensuring Brown Act compliance, hostile workplace considerations, among other things.
The parties at issue acted with extreme, offensive, and outrageous conduct with behavior that went beyond the bounds of decency and that would shock a reasonable person. Their conduct was intended to cause emotional distress and/or done with reckless disregard ofthe likelihood that their conduct would, and in fact did, cause severe emotional distress.
The following is a list of claims Ms. Lucero may assert against the County and other individual County employees and agents acting on behalf of the County; however, it is not comprehensive and is not required to be comprehensive for purposes of this Government Tort Claim:

1. 1)  retaliation in violation of Labor Code sections 1102.5 and 232.5;
   
2. 2)  defamation;
   
3. 3)  breach of employment contract;
   
4. 4)  breach of implied covenant o f good faith and fair dealing;
   
5. 5)  failure to perform mandatory duty (e.g., investigate complaints, protect whistleblowers, abide by civil service rules, etc.);
   
6. 6)  negligent hiring, supervision and training;
   

Claim Against the County o f Plumas
Re: AttachmenttoGCForm,Lucero,Debra October 13, 2025
Page 110
violations ofthe Brown Act;
interference with employment in violation of Labor Code section 1050;
7)
8)
9)
10)punitive damages against individuals for their oppression, fraud, and malicious conduct.
intentional infliction of emotional distress; and
General Description of the Iniuries
Ms. Lucero has sustained, and continues to sustain, economic injuries in the form of lost wages, lost earning capacity, lost future wages, medical expenses, lost retirement and other benefits, relocation costs, among other things.
Ms. Lucero has sustained, and continues to sustain, non-economic damages in form of ongoing pain and suffering, emotional distress, reputational harm, loss of consortium, loss of enjoyment of life, among other things.
Ms. Lucero intends to seek punitive damages against individual County Defendants.
Ms. Lucero intends to seek attorney's fees and costs, and damages for ongoing and accruing injuries in an amount according to proof.
Parties Causing Iniuries
Ms. Lucero is currently unaware ofall parties who have caused the injuries and will proceed under Jane and John Doe. However, current known parties include the following:

1. 1)  Josh Brechtel (County Counsel)
   
2. 2)  David Hollister (District Attorney)
   
3. 3)  Sara James (Deputy County Counsel)
   
4. 4)  Kevin Goss (Chair o f Board)
   
5. 5)  Jeff Engel (Board member)
   
6. 6)  Dwight Ceresola (former Vice Chair of Board)
   
7. 7)  Mimi Hall (Vice Chair of Board)
   
8. 8)  Kristina Rogers (County Counsel Paralegal)
   
9. 9)  Julie White (Treasurer-Tax Collector)
   
10. 10)  Martee Nieman (County Auditor-Controller)
    
11. 11)  Todd Johns (former Sheriff)
    
12. 12)  Cynthia Froggatt (County Assessor)
    
13. 13)  Marcy DeMartile (County Clerk-Recorder)
    
14. 14)  Allen Hiskey (County Clerk of the Board)
    

Damage Amount Claimed
The damages exceed $25,000.00 and will not be presented as a limited civil claim.