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1 79. Ms.Ferrer's handouts stated that both the internal and practical examinations would be held 2 on the same date for each candidate(as was the usual practice)and that a 5-day grievance period would be 3 4 allowed for each interview. Ms. Ferrer also stated that the panel members had yet to be chosen. However, 5 it was understood by department members that, as the panel members would be chosen by Chief Valentin, 6 they would be highly favorable to his preferred candidates (i.e., those in"the Valentin camp.") 7 80. However,Ms. Ferrer informed the candidates that there would be a change in the multiple- 8 9 choice written test which was a departure from past practice. The test would now entirely consist of"in- 10 house" questions written by"subject matter experts" from within the department. No longer would any I I questions from outside vendors such as Donnoe be utilized.As to whom these"subject matter experts"were, 12 how they were selected, or how they obtained their "expertise" was kept a complete mystery and not 13 14 disclosed. Who was formulating these questions, who vetted them for accuracy or correctness, and, most 15 importantly,who had access to them remained a secret. Of course, this just added to speculation about the 16 increasing corruption of the testing process among department members. 17 81. This change in the written test corresponded to a similar recent change in the Corporal written 18 19 test.The Corporal written test had been altered earlier in 2022 to exclude the difficult Donnoe questions and 20 instead consisted entirely of simpler, easier internally-generated questions. 21 82. It became common discussion that the Corporal test was deliberately"dumbed down" to 22 benefit favorable"Valentin camp" candidates. In particular, the test was engineered to be simpler in order 23 24 to directly benefit members of Chief Valentin's favored MET members,thereby enabling them to pass the 25 test and be promoted. As the MET team members were not known to be particularly astute or highly 26 educated,the Corporal test was specifically re-engineered to their lower capabilities. This was particularly 27 relevant with this Sergeant testing process as it now included several MET team candidates including Travis 28 Johnson and Luis Galleana. It appeared a similar dynamic was now being utilized on the Sergeant's test. ao KACAIRISKY v. CFFY OF SANTA ANA CASE No. COMPLAINT