Why this matters
The former city official’s claim puts at the center one of Gloria’s closest advisers: his chief of staff, who has significant input into strategy and implementing the mayor’s policy agenda.
A former top San Diego city official contended she was fired last year in retaliation for her role investigating and disciplining a city employee who was romantically involved with Paola Avila, the chief of staff for Mayor Todd Gloria.
The allegations were laid out in an 11-page letter from Michael Conger, the lawyer for the former official, Alia Khouri, and obtained by inewsource through the Public Records Act.
The March 3 letter to the City Attorney’s Office details Khouri’s claims, and puts Avila — one of Gloria’s closest advisers — at the center. As chief of staff, Avila she has significant input into strategy and implementing the mayor’s policy agenda.
Khouri was a deputy chief operating officer — one of four in the city at the time — who lost her job in December when Gloria restructured his executive team.
Khouri claimed her firing was retaliation by Avila for getting the employee — a woman whose name is redacted in the claim — demoted in the spring of 2024, and starting an ethics investigation against her in 2025.
When the same employee left the city to work in the private sector about a year later, Khouri said she reported complaints that the woman was contacting her former colleagues on behalf of her new employer — conduct that violates city “cooling off” ethics regulations banning former officials from directly lobbying city workers on behalf of their new employer.
On Sept. 15 the City Council approved a $269,000 settlement with Khouri which terse council documents available at the time said was to resolve claims of “wrongful conduct” surrounding her termination.
That was less than the $1 million Conger said Khouri would accept — representing two years’ pay — to not pursue her claims.
Despite the payout, the mayor’s office said in a statement Friday that the events described in Conger’s letter — known as a pre-litigation settlement demand — are unsubstantiated, and in one detail incorrect.
Deputy Chief of Staff Nick Serrano said the employee was not demoted, but applied to a different position. He declined to say what that position was.
Avila and Gloria were not made available for an interview. Avila said in a statement “I am disheartened that these unsubstantiated allegations are resulting in this invasion of my personal privacy, but at no relevant time was I romantically involved with the person referenced.”
The claims from Khouri span 2023 though the end of 2025. Asked to define what the relevant time was, Serrano replied that “There was no wrongdoing any time whether during the period covered by the allegations or otherwise.”
Gloria issued a statement that again noted the claims were not substantiated.
“These allegations were fully investigated, and not substantiated,” the statement said. “I continue to have full confidence in Paola Avila as my Chief of Staff and her ability to ethically, dutifully, and professionally serve the City of San Diego.”
Nearly all claims submitted to the city before litigation starts have not gone through the process of discovery, depositions and evidence accumulation.
The claim says that in September 2023 Khouri got a report that one of her subordinates was the subject of a hostile work environment claim from a co-worker.
That worker, whose name was redacted, said the hostility had gone on for more than a year, and was so bad they suffered from nausea, anxiety and had begun seeing a therapist.
Khouri and Human Resources Director Julie Rasco launched an investigation. The claim says they interviewed several witnesses who gave “very similar” information that substantiated the hostile work environment allegation.
Among the evidence assembled was a recording of the “offensive conduct” by the subject of the probe, the claim said.
Khouri and Rasco concluded that conduct merited getting fired, but instead recommended a demotion sometime around May 2024, the claim letter said.
At that point, Avila got involved. She tried to stop the demotion, and contacted the woman employee and encouraged her to fight the discipline, according to the claim.
“Involvement of the Mayor’s Chief of Staff in a routine personnel matter is highly unusual,” wrote Conger, who has represented numerous city employees in employment claims against the city.
Nonetheless the woman was demoted in May 2024, Conger wrote. The claim then says that she got another job in March 2025 with what appears to be an outside company, whose name is redacted.
In a heavily redacted portion, the claim alleged the former employee used her contacts and relationships in City Hall to “gain advantages” for her new employer.
By the end of summer 2025, the claim contends numerous city employees complained she was “currying undue favor and advantage” for her employer to the “detriment” of the city. It is illegal for former city officials to lobby city employees within a year after they leave the city payroll.
Khouri forwarded these complaints to both the City Attorney and the Ethics Commission. (Ethics Commission Executive Director Bryn Kirvin said the commission does not comment on the existence or non-existence of any investigation.)
Around the same time, Avila and the former employee announced in July 2025 that they were romantically involved, the claim says.
In September 2025, Khouri briefed Gloria on the situation. Then on Nov. 12 the claim said Khouri was summoned to Gloria’s office and told she was being terminated.
When Khouri asked why she was losing her job, Avila — who was in the meeting — interjected comments like “you just need to go,” “you can’t ask questions of the mayor” and “enough of your questions you just have to pack up and leave now.”
Khouri left the city on Dec. 2. Another deputy chief operating officer was let go at the same time as part of what Avila said in an email reported at the time by Voice of San Diego was a “thoughtful, organization-wide realignment.”
The letter from Conger says that Khouri was the victim of both sexual harassment based on sexual favoritism, and unlawful retaliation. It noted that she had received good performance reviews over the years. “There is nothing in Ms. Khouri’s personnel file that hints of any performance issue,” Conger wrote.
The claim says Conger has “abundant evidence” that Avila and the woman had been romantically involved long before they publicly announced it.
“We’re pleased the city was able to resolve this case without the necessity of litigation,” Conger said in an interview.
“She got fired for doing the right thing,” he said of Khouri. “The city needs more people like her.”
Khouri said she did not wish to comment on the settlement.
In aA staff report that accompanied the council’s approval of the settlement, a deputy city attorney wrote the payment was a “business decision” and was not an admission of wrongdoing.
“The City and its representatives disclaim any liability concerning Khouri’s claims,” the report said.
Conger submitted his letter on March 3, and on April 6 the City Council approved the deal in a closed session. The vote was 6-2 with councilmembers Raul Campillo and Vivian Moreno voting no, and Councilmember Kent Lee absent.
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Investigative/Enterprise: In-depth examination of a single subject requiring extensive research and resources.
