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1 74. KACHIRISKY would have to study and prepare much more thoroughly than candidates in <br /> 2 <br /> "the Valentin camp" (i.e., Lizardi) because he would have to perform exceptionally well just to be <br /> 3 <br /> 4 considered. Meanwhile, candidates in "the Valentin camp" (i.e., Lizardi) would only require minimal <br /> 5 preparation and were guaranteed to succeed simply by showing up. <br /> 6 75. The announcement became official in early January and KACHIRISKY applied again for the <br /> 7 <br /> position. KACHIRISKY also submitted an updated Enhanced Resume. <br /> 8 <br /> 9 76. The rumor spreading through the department was that Chief Valentin and his command staff <br /> 10 had already created a Sergeant's list (with the top three candidates on the final list to be, in order: (1) <br /> 11 Johanna Lizardi; (2) former MET Corporal Travis Johnson; and(3) current MET Corporal Luis Galleana) <br /> 12 <br /> and that the civil service testing process was simply a"formality". <br /> 13 <br /> 14 77• The testing process was announced by Senior Human Resources Analyst Lourdes Ferrer. Ms. <br /> 15 Ferrer is situated on the 4t' Floor of the police department within the Human Resources Division near <br /> 16 Valentin's office.While Chief Valentin's command staff and supervisors refer to Ms.Ferrer as an impartial <br /> 17 <br /> detached city employee, since she is privy to the corrupt practices of Chief Valentin-particularly in recent <br /> 18 <br /> 19 promotional processes related to the Lieutenant and Captain positions-she knowingly operates/colludes in <br /> 20 the improper human resources processes. <br /> 21 78. Ms.Ferrer stated through written materials(as well as via a verbal"orientation"presentation <br /> 22 <br /> on January 4, 2023)that the testing process would be nearly identical to the process in 2020. There would <br /> 23 <br /> 24 be a written multiple-choice test of possibly 90 to 100 questions,the two internal interview panels, and an <br /> 25 external interview panel. In fact, it was quickly apparent that Ms. Ferrer's handout regarding the testing <br /> 26 process was the same used in 2020 because she neglected to even change the previous date to the current <br /> 27 <br /> date, still using"September 2020."This was the first of many indications that this Sergeant testing process <br /> 28 <br /> was being hastily assembled and pushed through as quickly as possible. <br /> 19 <br /> KACAIItISKY v. CFFY OF SANTA ANA CASE NO. <br /> COMPLAINT <br />