Emil Petrossian | Partner
O: (619) 765-4380
[email protected]
VIA ELECTRONIC MAIL
July 8, 2025
Alan Fenstermacher, Esq. [email protected]
Re: Chris Hazeltine adv. City of Poway
Dear Mr. Fenstermacher:
Our law firm represents Chris Hazeltine. As you know, Mr. Hazeltine has been the victim of an unprovoked and unrelenting campaign of harassment, bullying, and defamation at the hands of Tony Blain, a councilmember at the City of Poway (the “City”). To date, Mr.
Blain’s misconduct has resulted in, among other things, specific findings by an independent investigator that Mr. Blain harassed and bullied Mr. Hazeltine by insulting, unjustly criticizing, and engaging in abusive and offensive behavior toward him. In addition, the City has already publicly censured Mr. Blain—the City’s first such reprimand of a sitting city councilmember in the City’s 45 years of existence—and is in the process of censuring him again in light of the above-referenced investigation findings. We understand also that the San Diego County District Attorney’s Office is presently investigating Mr. Blain for possible vote trading and other acts, that he is the subject of a public recall effort, and that the City has sued him for allegedly withholding and destroying public records in violation of California law.
Despite its knowledge of Mr. Blain’s ongoing misconduct, the City has repeatedly failed to stop that misconduct and to protect Mr. Hazeltine from harm. As a result, Mr. Hazeltine has suffered significant injuries, including but not limited to harm to his reputation and severe emotional distress. We reasonably estimate that Mr. Hazeltine’s damages are well into the seven figures, and we believe he has meritorious claims against the City for, at a minimum, defamation, false light invasion of privacy, intentional infliction of emotional distress, hostile work environment/harassment, and negligent supervision.1 What is more, Mr. Blain’s acts are indisputable because they are documented in writing, are memorialized in video recordings, and have been observed by many City employees.
Mr. Hazeltine has instructed us to pursue and enforce his rights and remedies to the fullest extent of the law. Accordingly, the purpose of this letter is to notify the City regarding Mr. Hazeltine’s potential claims and to provide the City with an opportunity to avoid formal 1 As a public entity, the City is vicariously liable for its employees’ tortious conduct committed within the scope of employment. See Cal. Gov’t Code § 815.2. In addition, the City has effectively ratified Mr. Blain’s conduct by failing to prevent or stop it, and is liable to Mr. Hazeltine on that basis as well.
Glaser .1 Wei
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July 8, 2025 Alan Fenstermacher, Esq.
litigation. Mr. Hazeltine is a proud public servant and a faithful City employee, and he intends to remain one. Thus, he wishes to avoid a prolonged and protracted litigation against the City. However, whether formal litigation can be avoided depends on whether and how quickly the City acts to rectify the present situation and to compensate Mr. Hazeltine for the substantial harm he has suffered.
If the City is interested in having a constructive discussion regarding this matter, please contact me at your earliest convenience and no later than the close of business on July 16, 2025. If I do not hear from you by this date, Mr. Hazeltine will assume that the City is not interested in exploring a resolution outside of court, and he will proceed with enforcing his rights and pursuing his remedies against the City without further notice.
Our investigation of this matter is ongoing. This letter is not intended to constitute a full or complete recitation of the facts or issues regarding the above-referenced subject matters. Likewise, nothing in this letter is intended to be, or should be construed as, a waiver, relinquishment, or forfeiture of any of Mr. Hazeltine’s rights, remedies, claims, or contentions, whether at law or in equity, all of which are hereby expressly reserved.
We look forward to your prompt response.
Very truly yours,
Emil Petrossian
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