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1 71. As the list neared expiration, only one candidate (Daniel Padron)remained on the list and <br /> 2 <br /> various irregularities began to arise.Although Chief Valentin had assured Officer Padron that every attempt <br /> 3 <br /> 4 would be made to promote him from the list, shortly before the list expired, Sergeant Alex Lopez (the <br /> 5 Adjutant to Chief Valentin)informed Officer Padron that the list expired and that he would not be promoted <br /> 6 due to a lack of any Sergeant vacancies.Officer Padron-then disfavored by"the Valentin camp"-had been <br /> 7 <br /> allowed to"die on the list." <br /> 8 <br /> 9 72. Then, approximately two weeks after expiration of the 2020 Sergeant list, Chief Valentin <br /> 10 announced that Sergeant Rosa Ponce De Leon would be promoted to the position of Lieutenant. This <br /> 11 promotion - clearly expected by Chief Valentin - created a Sergeant vacancy. It became well known <br /> 12 <br /> throughout the department that Chief Valentin did this deliberately because he had another specific candidate <br /> 13 <br /> 14 in mind for the position of Sergeant:Johanna Lizardi,wife of Valentin's main confidant and MET member <br /> 15 then-Lieutenant Oscar Lizardi. However, in order to promote Johanna Lizardi, a new Sergeant testing <br /> 16 process would have to be conducted. <br /> 17 <br /> K. The December 2022 Sergeant Promotional: <br /> 18 <br /> 19 73. In mid-December 2022, Human Resources Captain Enrique Esparza emailed an <br /> 20 announcement that the Sergeant's Testing Process was to begin soon.This caused tremendous stress among <br /> 21 potential testing candidates,including KACHIRISKY, as the department was beginning the testing process <br /> 22 <br /> during the holidays for only one potential vacancy that was already unofficially slated for Johanna Lizardi. <br /> 23 <br /> 24 (It was also unusual for the department to suddenly embark on an extensive and costly selection process for <br /> 25 one vacancy when it typically would wait for additional openings before commencing such an ordeal.) <br /> 26 Moreover,this placed undue added stress on those candidates deemed opposed to"the Valentin camp"such <br /> 27 <br /> as KACHIRISKY. <br /> 28 <br /> 18 <br /> KACAIRISKY v. CFFY OF SANTA ANA CASE No. <br /> COMPLAINT <br />