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BARBARA J. PARKER, City Attorney, SBN 069722
MARIA BEE, Chief Assistant City Attorney, SBN 167716
"KEVIN MCLAUGHLIN, Supervising Deputy City Attorney, SBN 251477
MICHAEL QUIRK, Deputy City Attorney, SBN 283351
One Frank H. Ogawa Plaza, 6th Floor
Oakland, California 94612
FILED
Telephone: (510) 238-3839, Fax: (510) 238-6500
Email: mquirk@oaklandcityattorney.org
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Attorneys forDefendant,
CITY OF OAKLAND SP 9 202 ke
(also erroneously sued as - CLERyU: ccugourt Sool
OAKLAND POLICE DEPARTMENT) By it OLIVER Deputy
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF ALAMEDA
MILDRED L. OLIVER, Case No. RG19007799
13 Plaintiff, ASSIGNED FOR ALL PURPOSES TO
, JUDGE James Reilly
14 V. DEPARTMENT 25
15 CITY OF OAKLAND, OAKLAND POLICE
DEPARTMENT, AND DOES 1-25,
16 INCLUSIVE, SEPARATELY BOUND EVIDENCE IN
SUPPORT OF DEFENDANT CITY OF
17 Defendants. OAKLAND’S MOTION FOR SUMMARY
JUDGMENT, OR ALTERNATIVE
18 SUMMARY ADJUDICATION
19 Date: December 15, 2021
Time: 9:00 a.m.
20 Dept.: 25
Reservation No: R-2282494
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22 Complaint filed: February 21, 2019
Trial date: January 24, 2022
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27 PUBLIC — REDACTS MATERIALS FROM CONDITIONALLY SEALED RECORD
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EVIDENCE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY RG19007799
JUDGMENT
SEP 2-9 RECD
EVIDENCE
Declaration of Darren Allison
Declaration of Amber Fuller
Declaration of Mary Ann Gonzales
Promotiona! Lieutenant Recruitment 16-PS152-02P
Declaration of Andrew Lathrop
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Letter from CalPERS to the City dated May 15, 2018
Mildred Oliver’s Signed Waiver and Letter requesting same
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Letter from City Physician dated March 27, 2019
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12 4-D Determination of Disability dated May 15, 2019
13 Declaration of Wilson Lau
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15 5-B
16 5-C
17 5-D
18 5-E
19 5-F
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Declaration of Michael Quirk
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First Amended Complaint filed April 23, 2019
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6-B Deposition of Mildred Oliver (Excerpts) and Deposition Exhibits A-C
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6-C Deposition of Donna Hoppenhauer (Excerpts)
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6-D Plaintiff Oliver’s Responses to City’s Special Interrogatories, Set One
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6-E Plaintiff Oliver’s Responses to City’s Form Interrogatories (Employment),
26 Set One
6-F EEOC charge received by EEOC April 25, 2017
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6-G DFEH complaint dated February 22, 2018
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EVIDENCE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY RG19007799
JUDGMENT
6-H | DFEH complaint dated February 21, 2019
6-I | January 15, 2019 Letter from City Administrator to Mildred Oliver
Dated: September 29, 2021
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By
“MICHAEL J. QUIRK, Deputy City Attorney
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Attorneys for Defendant
CITY OF OAKLAND
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EVIDENCE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY RG19007799
JUDGMENT
EXHIBIT 1 a_i
Pea 3 Tabl —a
BARBARA J.PARKER, City Attorney — SBN 069722
MARIA BEE, Chief AssistantCityAttorney — SBN 167716
KEVIN MCLAUGHLIN, Supervising Deputy CityAttorney - SBN 251477
MICHAEL QUIRK, Deputy City Attorney SBN 283351
One Frank H. Ogawa Plaza, 6th Floor
Oakland, California 94612
Telephone: (510) 238-6520 Fax: (510) 238-6500
.Email: mquirk@oaklandcityattorney.org
33244/3110035
Attorneys for Defendant
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CITY OF OAKLAND
(also erroneously sued as
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OAKLAND POLICE DEPARTMENT)
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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10 COUNTY OF ALAMEDA
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MILDRED L. OLIVER, Case No. RG19007799
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Plaintiff, ASSIGNED FOR ALL PURPOSES TO
13 JUDGE James Reilly
Vv. DEPARTMENT 25
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CITY OF OAKLAND, OAKLAND POLICE DECLARATION OF DARREN ALLISON
15 DEPARTMENT, AND DOES 1-25, IN SUPPORT OF DEFENDANT’S
INCLUSIVE MOTION FOR SUMMARY JUDGMENT,
16 OR ALTERNATIVELY SUMMARY
Defendants. ADJUDICATION
17
Date: December 15, 2021
18 Time: 9:00 a.m.
Dept.: 25
19 Reservation No: R-2282494
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Complaint filed: February 21, 2019
21 Trial date: January 24,2022
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DECLARATION OF DARREN ALLISON IN SUPPORT OF DEFENDANT’S RG19007799
MOTION FOR SUMMARY JUDGMENT
DECLARATION OF DARREN ALLISON
I,DARREN ALLISON, declare asfollows:
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1. The facts stated herein are based on my personal knowledge and, ifcalled as a
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witness, Icould and would competently testifythereto.
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2. lam the Assistant Chief of Police for the Oakland Police Department. I have served
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in the Oakland Police Department since 1996.
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3. Among other duties, Ihave served in the Bureau of Field Operations, in Patrol, in
Community Policing, on the Crime Reduction Team, in Special Operations, in Internal Affairs, as an
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Incident Commander, and in the Inspector General’s Office.
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10 4. In August 2016, I was aDeputy Chief of Police, Bureau of Field Operations. In that
1 role, | was a member of the executive team, and thus participated in the department-wide process of
12 planning annual staffing changes and the transfer of OPD personnel to Patrol and other assignments.
13 In 2016, I was more involved with the process than istypical because the Assistant Chief ofPolice
14 was also effectively handling many of the duties of the Chief of Police.
15 5. On August 22, 2016, I attended ameeting régarding OPD personnel returning to
16 Patrol as part of the 2017 “watch change.” Typically, the executive team including deputy chiefs
17 would be present at these types of personnel meetings, and Irecall David Downing, Danielle
18 Outlaw, Oliver Cunningham, John Lois, Donna Hoppenhauer, and Eric Milina as people that were |
19 there and would have attended.
20 6. Every year, including 2016, we have an acute need for sergeants in Patrol,and we
21 consider transferring sergeants forthat reason.
22 7. Being transferred to Patrol is not punitive or ademotion. Personnel transferred to
23 Patrol do not lose employee benefits or base pay solely because of the transfer. Patrol is considered
24 “Home Base” for OPD personnel—that is,there isan expectation personnel will be required to
25 return to Patrol at various points in their career due tothe need for experienced personnel in the field,
26 to erisure personnel maintain their core skills,and to give all personnel an opportunity to serve in
27 specialized assignments. Being notified in advance of a transfer to Patrol issomething OPD
28 considers to be beneficial to personnel—as compared to transferring someone immediately, which
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DECLARATION OF DARREN ALLISON IN SUPPORT OF DEFENDANT’S RG19007799
MOTION FOR SUMMARY JUDGMENT
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can happen for some personnel with performance issues—because itgives personnel the opportunity
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to select aPatrol assignment that is conducive to their personal schedule based on criteria such as
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shifttime and days of the week. The purpose of giving personnel advance notice isto minimize
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hardship. Officers or sergeants transferred to Patrol have the same ability to apply for promotional
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opportunities as officers or sergeants out of Patrol.
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8. At the August 22, 2016 meeting, itwas determined thatat least four sergeants would
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be returning to Patrol in2017, one of which was Sgt. Mildred Oliver. The acute need forsergeants
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in Patrol was a factor forthe transfer decisions.
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I declare under penalty of perjury under the laws of the State of California that the
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DECLARATION OF DARREN ALLISON IN SUPPORT OF DEFENDANT’S RG19007799
MOTION FOR SUMMARY JUDGMENT
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BARBARA J.PARKER, CityAttorney ~ SBN 069722
MARIA BEE, Chief Assistant
City Attorney— SBN 167716
KEVIN MCLAUGHLIN, SupervisingDeputy CityAttorney — SBN 251477
MICHAEL QUIRK, Deputy CityAttorney SBN 28335]
One Frank H. Ogawa Plaza, 6th Floor
Oakland, California 94612 oe
Telephone: (510) 238-6520. Fax: (510) 238-6560
Email: mauitk @oaklandcityattorney. org
33244/3110054
Attorneys for Defendant
CITY OF OAKLAND
(also erroneously sued as
OAKLAND POLICE DEPARTMENT)
SUPERIOR COURT OF THE STATE OF CALIF ORNIA
10 COUNTY OF ALAMEDA _|
11 MILDRED L. OLIVER, : Case No. RG19007799. ~
12 Plaintiff, - ASSIGNED FOR ALL PURPOSES TO
. ; JUDGE James Reilly
13 v. DEPARTMENT 25
CITY OF OAKLAND, OAKLAND POLICE DECLARATION OF AMBER FULLER
DEPARTMENT, AND DOES 1-25, IN SUPPORT OF DEFENDANT’S
15 INCLUSIVE, MOTION FOR SUMMARY ,
| JUDGMENT, OR ALTERNATIVELY
16 Defendants. SUMMARY ADJUDICATION
7
Date: December 15,2021
Time: 9:00 a.m.
18 Dept.; 25
Reservation No: R-2282494
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20 Complaint filed: February 21, 2019
Trial date: January 24, 2022
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DECLARATION OF AMBER FULLER. TN SUPPORT OF DEFENDANT” S ; RG19007799
MOTION FOR SUMMARY JUDGMENT
DECLARATION OF AMBER FULLER
I,AMBER FULLER, declare asfollows: |
|. ° The facts statedherein arebased on my personal knowledge and, if called
as a
witness, I could and would competently testifythereto. |
2. [am currently the Acting Human Resources Manager of the Oakland Police
Department (“OPD”).. My officialtitleisPolice Personnel Operations Specialist. [ have worked for
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the City of Oakland (“City”) for over 15 years. [have worked inthe Human Resources Section.
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since April2019.
-3. Part of my dutiesin the OPD Human Resources Section include the supervision of
-gathering-and analysis of salary data required in orderto maintain ortevise OPD personnel
compensation plans. | also supervise responses to internal queriesrégarding compensation and
classificationand assistin analyzing salary data and preparing relatedreports.
| 4. Itisthe practice of my Section to maintain salarydata for current and recently retired
OPD personnel. These documents are kept by the City in theregular course of business, and itwas
the regular course of business forthe City or for an employee or representativeof the City,with
knowledge of the act,event, condition, opinion, or diagnosis, recorded to make the record or to
transmit information thereof to be included in such record; and therecord was made ator near the
time reasonably soon thereafter. I am familiar with the system we use to storethis data,and | am
one of the custodians with access to thisdata and associated documents.
5. Itismy understanding thatformer OPD Sergeant Mildred Oliver has sued the City of
Oakland, and.as part of her lawsuit she alleges-she received a demotion notice and asuspension
without pay.
6. Based on my experience working inHuman Resources, and my familiarity with the
City’s records, |reviewed Sgt.Oliver’s salary and personnel records to determine whether she ever
suffered a demotion. As aresult ofmy review, Ican confirm Sgt. Oliver was never demoted while
she was employed by OPD. Sgt. Oliver’s only suspension without pay occurred from February 28,
2019 toMarch 28,2019. From 2015 to thetime she retiredin May 2019, Sgt.Oliver’s base pay was
never reduced as a resultof ariyof her transfers wighin OPD.
DECLARATION OF AMBER FULLER IN SUPPORT OF DEFENDANT’S RG19007799
‘MOTION FOR SUMMARY JUDGMENT
Ideclare under penalty of perjury under the laws of California that the foregoing istrue
and correct. Executed on this27th day of September 202 |in Oakland, California.
AMBER FULLER Y
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DECLARATION OF AMBER FULLER IN SUPPORT OF DEFENDANT'S RG19007799
MOTION FOR SUMMARY JUDGMENT
EXHIBIT 3
BARBARA J. PARKER, City Attorney— SBN 069722
MARIA BEE, ChiefAssistant CityAttorney — SBN 167716
KEVIN MCLAUGHLIN, SupervisingDeputy CityAttorney — SBN 251477
MICHAEL QUIRK, Deputy City Attorney SBN 283351
One Frank H. Ogawa Plaza, 6th Floor
Oakland, California 94612
Telephone: (510) 238-6520 Fax: (510) 238-6500
Email: mquirk@oaklandcityattorney.org
33244/3110053
Attorneys for Defendant
ND
CITY OF OAKLAND
(also erroneously sued as
NN
OAKLAND POLICE DEPARTMENT)
CO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
oO
10 COUNTY OF ALAMEDA
ll MILDRED L. OLIVER, Case No. RG19007799
12 Plaintiff, ASSIGNED FOR ALL PURPOSES TO
JUDGE James Reilly
13 V. DEPARTMENT 25
14 CITY OF OAKLAND, OAKLAND POLICE DECLARATION OF MARY ANN
DEPARTMENT, AND DOES 1-25, GONZALES IN SUPPORT OF
15 INCLUSIVE, DEFENDANT’S MOTION FOR
SUMMARY JUDGMENT, OR
16 Defendants. ALTERNATIVELY SUMMARY
ADJUDICATION
17
Date: December 15, 2021
18 Time: 9:00 a.m.
Dept.: 25
19 Reservation No: R-2282494
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Complaint filed: February 21, 2019
21 Trial date: January 24, 2022
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DECLARATION OF MARY ANN GONZALES IN SUPPORT OF DEFENDANT’S RG19007799
MOTION FOR SUMMARY JUDGMENT
DECLARATION OF MARY ANN GONZALES
I,MARY ANN GONZALES, declare as follows:
1. The facts stated herein are based on my personal knowledge and, if called as a
witness, Icould and would competently testifythereto.
2. [ama Human Resource Analyst, currently Acting Senior Human Resource Analyst,
for the City of Oakland, inthe City’s Human Resources Management Department. J have worked
for the City since March 2006. Ihave worked in human resources (“HR”) for 15 years. [have a
bachelor’s degree in Sociology, and have completed various HR training courses including the CPS
HR Consulting - HR Academy. Ihave attended various HR trainings with the International Public
10 Management Association forHuman Resources (IPMA), CPS HR Consulting, and the Western
11 Region Intergovernmental Personnel Assessment Council (WRIPAC).
12 3. As part of my regular duties, Iassist the City’s Human Resources department with
13 the administration ofrecruitment and examination for new employees and promotional opportunities
14 at the City.
15 4. Tam a custodian ofrecords for the City’s Human Resources Department. All
16 exhibits attached to thisDeclaration constitute business records from the City. These documents are
17 kept by the City in the regular course of business, and itwas the regular course of business for the
18 City or for an employee or representative of the City, with knowledge ofthe act, event, condition,
19 opinion, or diagnosis, recorded to make the record or to transmit information thereof to be included
20 in such record, and the record was made at or near the time reasonably soon thereafter.
21 5. Itis the regular practice of my department to keep copies ofpast recruitment postings
22 for promotional opportunities. I am familiar with the system we use to save these postings, and I am
23 one ofthe custodians with access tothese documents. Attached as Exhibit A hereto isa true and
24 correct copy of the February 24, 2016 promotional opportunity for the position of Lieutenant of
25 Police with the Oakland Police Department, which was circulated within the Oakland Police
26 Department.
27 6. Based on my experience working as a Human Resource Analyst forthe City of
28 Oakland and my review of the City’s records, [ am familiar with the examination thatwas
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DECLARATION OF MARY ANN GONZALES IN SUPPORT OF DEFENDANT’S RG19007799
MOTION FOR SUMMARY JUDGMENT
administered for thisparticular promotional opportunity.
7. The City contracts with an outside consultant to design and help administer the
examination. For this examination, stage one consisted of an objective multiple-choice test based on
a reading listprovided to applicants. Stage two involved a series of panel interviews involving a
variety of job-related assessment exercises.
8. Participants in stage two of the examination are graded anonymously. At the
beginning of the examination, each applicant chooses a randomized number which they will be
referred to by throughout the testing and grading process. The City’s Human Resources Department
does not know which name belongs tothe randomized numbers until the testscores are delivered for
10 tabulation by the City’s Human Resources Department.
11 9. The panelists for this examination were not Oakland police personnel. The panelists
12 were law enforcement officers from outside agencies. The stage two panelists independently graded
13 each applicant, not the City. Test results were then relayed to the City’s Human Resources
14 Department upon completion.
15 10. The testwas administered by the City’s Human Resources Department, with
16 assistance from theconsultant.
17 I declare under penalty of perjury under the laws of California that the foregoing 1strue
18 and correct. Executed on this 27th day of September 2021 in San Ramon, California.
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20 Mary. Man Gongalee
MARY ANN GONZAYES
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DECLARATION OF MARY ANN GONZALES IN SUPPORT OF DEFENDANT’S RG19007799
MOTION FOR SUMMARY JUDGMENT
EXHIBIT A
Job Bulletin Page 1 of 6
CITY OF OAKLAND
invites applications for the position of:
Lieutenant of Police (Promotional)
CITY.OF OAKLAND
SALARY: $14,521.95 - $14,521.95 Monthly
$174,263.40 - $174,263.40 Annually
OPENING DATE: 02/24/16
CLOSING DATE: 03/29/16 04:00 PM
THE POSITION:
Salary
$11,803.64 Monthly, $141,643.68 Annually (80 hour schedule)
$12,393.81 Monthly, $148,725.72 Annually (84 hour schedule)
The City of Oakland is recruiting tofill
several Lieutenant of Police positions within the Oakland
Police Department.
Under direction of aCaptain or Deputy Chief, a Lieutenant ofPolice performs administrative,
middle management work involving the direction of an essential, and often large, police activity.A
Lieutenant is directlyresponsible for the efficientmanagement of a Police Service Area, Division,
Section or Watch within the constraints of the Department's policies and procedures. The scope
of work requires an extensive understanding of and an abilitytoimplement the Department's
operating policies.A Lieutenant isexpected to solve major problems as they arise, especially in
the field,with limited recourse to supervision. Working conditions may include field,desk and shift
work. The job requires the exercise of independent judgment. A Lieutenant may supervise
Sergeants, Police Officers and civilianpersonnel.
In accordance with the terms of Sign-up and Examination Eligibility
inthe current Promotional
Memorandum of Understanding between the City of Oakland and the Oakland Police Officers’
Association, thisexamination is open to any member of the Oakland Police Department who has
completed three (3) years ofservice as a Sergeant ofPolice by March 29, 2016.
Qualified Oakland Sergeants of Police may apply by submitting acompleted Notice of Intent form.
This form isavailable inthe Personnel Section of the Police Administration Building, Room 704.
In order to apply for the examination, an original completed Notice of Intent form must be
submitted to the Personnel Section, no later than 4:00 p.m., Tuesday, March 29, 2016.
EXAMPLES OF DUTIES:
See additional information forapplicants below, Example of Work Functions.
MINIMUM REQUIREMENTS FOR APPLICATION:
The examination willbe administered in two stages. Candidate's must achieve a minimum scale
score of70 ineach stage of the examination to be placed on the eligiblelistforemployment
consideration.
file://oakland/recruitclass/Test/Police%20Department%20(OPD)/Lieutenant.16/2021%20.... 9/12/2021
Job Bulletin Page 2 of 6
Stage I: The firststage ofthe selection process willconsist of an objective multiple-choice test
(weighted 23.7%) based primarily on the reading listincluded with thisannouncement and posted
in the Personnel Section of the OPD, Room 704. The testwill include the following dimensions:
e Knowledge ofPolice Techniques 7.6%
e Knowledge ofAdministrative/Operational Procedures 8.1%
e Knowledge ofLegal Issues 8.0%
Stage Il:The second stage in the selection process willinvolve a variety ofjob-related
assessment exercises (weighted 76.3%) and willinclude the following dimensions:
Leadership 13.0%
Motivational Ability 8.3%
Problem Analysis 9.1%
Judgment/Decision Making 10.3%
Planning/Organization 6.9%
Oral Communication 6.9%
Written communication 7.8%
Interpersonal Skill 7.0%
Composure 7.0%
The City of Oakland reserves the rightto modify the selection process as necessary to conform to
administrative or business necessity. Candidates must achieve a scale score of 70 or more on
each stage ofthe examination inorder to continue in the selection process and to achieve
placement on the eligibility
list.Scoring isbased on Section 4.17 of the Personnel Manual of the
CivilService Board. The examination willbe conducted in accordance with the OPOA
Memorandum of Understanding of July 1,2015.
Stage | ofthe examination is scheduled for Tuesday, April 5, 2016 atthe Human Resources
Management Department, 150 Frank H.Ogawa Plaza, 2nd Floor, in Oakland. Candidates must
bring a picture identificationcard issued by a government agency tobe admitted tothe exam.
Qualified applicants who filea timely Notice of Intent are to report directly to the test site
no laterthan 9:00 a.m.. on the day of the exam. No other written notificationof the
examination willbe provided to applicants unless they are deemed unqualified. After the reporting
time, the entrance to the test willbe closed and no one willbe admitted.
Stage Ilof the examination istentatively scheduled forthe week of May 2, 2016 at the Human
Resources Management Department, 150 Frank H. Ogawa Plaza, 2nd Floor, in Oakland.
Candidates who are successful inStage | ofthe process willbe notified ofthe exact date and time
for Stage Il.
ADDITIONAL INFORMATION FOR APPLICANTS:
Example of the Work Functions: A description ofthe possible events in a working day of a
Lieutenant of Police job is attached. Itisintended to inform potential candidates of the typical
functions performed by a Lieutenant of Police. Itisnot intended to be an exhaustive listof allthe
duties performed, nor allthe knowledge, skillsand abilitiesemployed by a Lieutenant of Police.
The examination may include knowledge, skillsand abilitiesnot covered inthe attached
description.
The purpose of this document isto provide a general understanding of typicalrequirements for
the Lieutenant of Police position. Scenarios which represent situations handled by OPD
Lieutenants required functions for each scenario are described below.
Scenario 1A
Lieutenant Jones is a Watch Commander. A major topic in the most recent Crime Stop meeting
file://oakland/recruitclass/Test/Police%20Department%20(OPD)/Lieutenant.16/2021%20.... 9/12/2021
Job Bulletin Page 3 of 6
was the number of rapes that had occurred in the last month in one of the area neighborhoods.
Lieutenant Jones utilizescrime analysis information todevelop a targeted enforcement strategy to
deal with the crimes. He isscheduled to meet with a community group inthe neighborhood to
discuss the Department's strategy. As he is drivingto the meeting, he sees a person who
matches the suspect's description. This person startsrunning down the street when he sees the
police car.
REQUIRED FUNCTIONS
Identifies problems and secures relevant information. Makes reasoned decisions based on the
analysis ofinformation. Flexible and able to adapt plans or decisions when dealing with new
information. Able to think critically.
Coordinates staffin the implementation of problem-oriented
policing projects. Observes individuals, objects, or events under diverse lighting
conditions. Recognizes objects or individuals from written and oraldescriptions. Depending on
the situation, absorbs information using vision, hearing, and the senses of touch and
smell. Memorizes visual images and translates these cues into narrative descriptions.
Scenario 1B
Lieutenant Jones exitshis vehicle and advises the dispatcher by radio ofhis location and that he
along with a cover officer isin foot pursuit of apossible rape suspect. This suspect isin sight.He
directs officersto establish a perimeter. The suspect runs through backyards, knocking over trash
cans. Lieutenant Jones continues his pursuit. While running, he repeatedly updates the
dispatcher, using a hand-held radio. He callsfor additional resources to set up containment.
REQUIRED FUNCTIONS
Acts quickly and decisively. Enters and exits police vehicle quickly in order to respond to
emergencies. Coordinates and rapidly performs a series ofcomplex operations involving arms,
hands and fingers. Runs some distance with quick stops, starts, and turns.Maneuvers around
objects while running. Works and communicates well under stressful conditions.
Scenario 1C
Lieutenant Jones catches up with the suspect who turns and starts fighting.He applies a control
hold and then pullsthe suspect's hands behind hisback, handcuffs him, and pat searches
him. He raises the suspect to a standing position and guides him tothe nearest street. Other units
have arrived and he hands the suspect over to them.
REQUIRED FUNCTIONS
Uses sense of touch to detect illegalsubstances or weapons concealed on suspects, to apply
handcuffs, and touse complex contro! holds. Exerts appropriate force to restrainindividuals
without causing unintentional injuries.Has the strength to lift,
pulland push an adult of average
weight and torestrain such a person resisting arrest. Reviews reports foraccuracy and
completeness.
Scenario 2A
Lieutenant Smith isan Investigations Lieutenant. She begins the shift by reviewing various
memos, reports, documents and her email. She prioritizesthe items and determines a course of
action for each. Some require immediate handling or distribution,others she saves for processing
laterduring the day. Some may be handled orally while others require that she generate reports
or correspondence. She isparticularly focused on crime reports for a series of armed robberies
that have recently occurred in an Area. She has assigned a team of investigators to focus their
effortson these cases atthe request of the CID Captain.
REQUIRED FUNCTIONS
Clearly understands OPD administrative and operational
Preview
— eo | e (nec BARBARA J. PARKER, City Attorney, SBN 069722 MARIA BEE, Chief Assistant City Attorney, SBN 167716 "KEVIN MCLAUGHLIN, Supervising Deputy City Attorney, SBN 251477 MICHAEL QUIRK, Deputy City Attorney, SBN 283351 One Frank H. Ogawa Plaza, 6th Floor Oakland, California 94612 FILED Telephone: (510) 238-3839, Fax: (510) 238-6500 Email: mquirk@oaklandcityattorney.org WO Attorneys forDefendant, CITY OF OAKLAND SP 9 202 ke (also erroneously sued as - CLERyU: ccugourt Sool OAKLAND POLICE DEPARTMENT) By it OLIVER Deputy so SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA MILDRED L. OLIVER, Case No. RG19007799 13 Plaintiff, ASSIGNED FOR ALL PURPOSES TO , JUDGE James Reilly 14 V. DEPARTMENT 25 15 CITY OF OAKLAND, OAKLAND POLICE DEPARTMENT, AND DOES 1-25, 16 INCLUSIVE, SEPARATELY BOUND EVIDENCE IN SUPPORT OF DEFENDANT CITY OF 17 Defendants. OAKLAND’S MOTION FOR SUMMARY JUDGMENT, OR ALTERNATIVE 18 SUMMARY ADJUDICATION 19 Date: December 15, 2021 Time: 9:00 a.m. 20 Dept.: 25 Reservation No: R-2282494 21 22 Complaint filed: February 21, 2019 Trial date: January 24, 2022 23 24 25 26 27 PUBLIC — REDACTS MATERIALS FROM CONDITIONALLY SEALED RECORD 28 l EVIDENCE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY RG19007799 JUDGMENT SEP 2-9 RECD EVIDENCE Declaration of Darren Allison Declaration of Amber Fuller Declaration of Mary Ann Gonzales Promotiona! Lieutenant Recruitment 16-PS152-02P Declaration of Andrew Lathrop | Letter from CalPERS to the City dated May 15, 2018 Mildred Oliver’s Signed Waiver and Letter requesting same 10 Letter from City Physician dated March 27, 2019 ll 12 4-D Determination of Disability dated May 15, 2019 13 Declaration of Wilson Lau 14 5-A 15 5-B 16 5-C 17 5-D 18 5-E 19 5-F 20 Declaration of Michael Quirk 21 First Amended Complaint filed April 23, 2019 22 6-B Deposition of Mildred Oliver (Excerpts) and Deposition Exhibits A-C 23 6-C Deposition of Donna Hoppenhauer (Excerpts) 24 6-D Plaintiff Oliver’s Responses to City’s Special Interrogatories, Set One 25 6-E Plaintiff Oliver’s Responses to City’s Form Interrogatories (Employment), 26 Set One 6-F EEOC charge received by EEOC April 25, 2017 27 6-G DFEH complaint dated February 22, 2018 28 1 EVIDENCE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY RG19007799 JUDGMENT 6-H | DFEH complaint dated February 21, 2019 6-I | January 15, 2019 Letter from City Administrator to Mildred Oliver Dated: September 29, 2021 SN NN By “MICHAEL J. QUIRK, Deputy City Attorney So Attorneys for Defendant CITY OF OAKLAND Oo 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 EVIDENCE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY RG19007799 JUDGMENT EXHIBIT 1 a_i Pea 3 Tabl —a BARBARA J.PARKER, City Attorney — SBN 069722 MARIA BEE, Chief AssistantCityAttorney — SBN 167716 KEVIN MCLAUGHLIN, Supervising Deputy CityAttorney - SBN 251477 MICHAEL QUIRK, Deputy City Attorney SBN 283351 One Frank H. Ogawa Plaza, 6th Floor Oakland, California 94612 Telephone: (510) 238-6520 Fax: (510) 238-6500 .Email: mquirk@oaklandcityattorney.org 33244/3110035 Attorneys for Defendant NHN CITY OF OAKLAND (also erroneously sued as YN OAKLAND POLICE DEPARTMENT) co SUPERIOR COURT OF THE STATE OF CALIFORNIA Oo 10 COUNTY OF ALAMEDA 11 MILDRED L. OLIVER, Case No. RG19007799 12 Plaintiff, ASSIGNED FOR ALL PURPOSES TO 13 JUDGE James Reilly Vv. DEPARTMENT 25 14 CITY OF OAKLAND, OAKLAND POLICE DECLARATION OF DARREN ALLISON 15 DEPARTMENT, AND DOES 1-25, IN SUPPORT OF DEFENDANT’S INCLUSIVE MOTION FOR SUMMARY JUDGMENT, 16 OR ALTERNATIVELY SUMMARY Defendants. ADJUDICATION 17 Date: December 15, 2021 18 Time: 9:00 a.m. Dept.: 25 19 Reservation No: R-2282494 20 Complaint filed: February 21, 2019 21 Trial date: January 24,2022 ~ 22|. 23 24 25 26 27 28 1 DECLARATION OF DARREN ALLISON IN SUPPORT OF DEFENDANT’S RG19007799 MOTION FOR SUMMARY JUDGMENT DECLARATION OF DARREN ALLISON I,DARREN ALLISON, declare asfollows: WN 1. The facts stated herein are based on my personal knowledge and, ifcalled as a WwW witness, Icould and would competently testifythereto. & 2. lam the Assistant Chief of Police for the Oakland Police Department. I have served vw in the Oakland Police Department since 1996. NN 3. Among other duties, Ihave served in the Bureau of Field Operations, in Patrol, in Community Policing, on the Crime Reduction Team, in Special Operations, in Internal Affairs, as an Oo Incident Commander, and in the Inspector General’s Office. o 10 4. In August 2016, I was aDeputy Chief of Police, Bureau of Field Operations. In that 1 role, | was a member of the executive team, and thus participated in the department-wide process of 12 planning annual staffing changes and the transfer of OPD personnel to Patrol and other assignments. 13 In 2016, I was more involved with the process than istypical because the Assistant Chief ofPolice 14 was also effectively handling many of the duties of the Chief of Police. 15 5. On August 22, 2016, I attended ameeting régarding OPD personnel returning to 16 Patrol as part of the 2017 “watch change.” Typically, the executive team including deputy chiefs 17 would be present at these types of personnel meetings, and Irecall David Downing, Danielle 18 Outlaw, Oliver Cunningham, John Lois, Donna Hoppenhauer, and Eric Milina as people that were | 19 there and would have attended. 20 6. Every year, including 2016, we have an acute need for sergeants in Patrol,and we 21 consider transferring sergeants forthat reason. 22 7. Being transferred to Patrol is not punitive or ademotion. Personnel transferred to 23 Patrol do not lose employee benefits or base pay solely because of the transfer. Patrol is considered 24 “Home Base” for OPD personnel—that is,there isan expectation personnel will be required to 25 return to Patrol at various points in their career due tothe need for experienced personnel in the field, 26 to erisure personnel maintain their core skills,and to give all personnel an opportunity to serve in 27 specialized assignments. Being notified in advance of a transfer to Patrol issomething OPD 28 considers to be beneficial to personnel—as compared to transferring someone immediately, which °2 DECLARATION OF DARREN ALLISON IN SUPPORT OF DEFENDANT’S RG19007799 MOTION FOR SUMMARY JUDGMENT ® e can happen for some personnel with performance issues—because itgives personnel the opportunity — to select aPatrol assignment that is conducive to their personal schedule based on criteria such as WNW shifttime and days of the week. The purpose of giving personnel advance notice isto minimize WY hardship. Officers or sergeants transferred to Patrol have the same ability to apply for promotional FSF opportunities as officers or sergeants out of Patrol. A 8. At the August 22, 2016 meeting, itwas determined thatat least four sergeants would DBD be returning to Patrol in2017, one of which was Sgt. Mildred Oliver. The acute need forsergeants NSN in Patrol was a factor forthe transfer decisions. CO o Sl or FOE EF Fe © — Ke HH = >> YH o> NNNY EE = NO EO YN SO I declare under penalty of perjury under the laws of the State of California that the YH foregoing is true and correct. Executed on this 27th day of September, 2021 inOakland, ©, YH OR California. NHN Eo NO [oye mW DECLARATION OF DARREN ALLISON IN SUPPORT OF DEFENDANT’S RG19007799 MOTION FOR SUMMARY JUDGMENT ) BARBARA J.PARKER, CityAttorney ~ SBN 069722 MARIA BEE, Chief Assistant City Attorney— SBN 167716 KEVIN MCLAUGHLIN, SupervisingDeputy CityAttorney — SBN 251477 MICHAEL QUIRK, Deputy CityAttorney SBN 28335] One Frank H. Ogawa Plaza, 6th Floor Oakland, California 94612 oe Telephone: (510) 238-6520. Fax: (510) 238-6560 Email: mauitk @oaklandcityattorney. org 33244/3110054 Attorneys for Defendant CITY OF OAKLAND (also erroneously sued as OAKLAND POLICE DEPARTMENT) SUPERIOR COURT OF THE STATE OF CALIF ORNIA 10 COUNTY OF ALAMEDA _| 11 MILDRED L. OLIVER, : Case No. RG19007799. ~ 12 Plaintiff, - ASSIGNED FOR ALL PURPOSES TO . ; JUDGE James Reilly 13 v. DEPARTMENT 25 CITY OF OAKLAND, OAKLAND POLICE DECLARATION OF AMBER FULLER DEPARTMENT, AND DOES 1-25, IN SUPPORT OF DEFENDANT’S 15 INCLUSIVE, MOTION FOR SUMMARY , | JUDGMENT, OR ALTERNATIVELY 16 Defendants. SUMMARY ADJUDICATION 7 Date: December 15,2021 Time: 9:00 a.m. 18 Dept.; 25 Reservation No: R-2282494 19 20 Complaint filed: February 21, 2019 Trial date: January 24, 2022 21 22 23 24 25 26 27 28 | DECLARATION OF AMBER FULLER. TN SUPPORT OF DEFENDANT” S ; RG19007799 MOTION FOR SUMMARY JUDGMENT DECLARATION OF AMBER FULLER I,AMBER FULLER, declare asfollows: | |. ° The facts statedherein arebased on my personal knowledge and, if called as a witness, I could and would competently testifythereto. | 2. [am currently the Acting Human Resources Manager of the Oakland Police Department (“OPD”).. My officialtitleisPolice Personnel Operations Specialist. [ have worked for NN the City of Oakland (“City”) for over 15 years. [have worked inthe Human Resources Section. nN since April2019. -3. Part of my dutiesin the OPD Human Resources Section include the supervision of -gathering-and analysis of salary data required in orderto maintain ortevise OPD personnel compensation plans. | also supervise responses to internal queriesrégarding compensation and classificationand assistin analyzing salary data and preparing relatedreports. | 4. Itisthe practice of my Section to maintain salarydata for current and recently retired OPD personnel. These documents are kept by the City in theregular course of business, and itwas the regular course of business forthe City or for an employee or representativeof the City,with knowledge of the act,event, condition, opinion, or diagnosis, recorded to make the record or to transmit information thereof to be included in such record; and therecord was made ator near the time reasonably soon thereafter. I am familiar with the system we use to storethis data,and | am one of the custodians with access to thisdata and associated documents. 5. Itismy understanding thatformer OPD Sergeant Mildred Oliver has sued the City of Oakland, and.as part of her lawsuit she alleges-she received a demotion notice and asuspension without pay. 6. Based on my experience working inHuman Resources, and my familiarity with the City’s records, |reviewed Sgt.Oliver’s salary and personnel records to determine whether she ever suffered a demotion. As aresult ofmy review, Ican confirm Sgt. Oliver was never demoted while she was employed by OPD. Sgt. Oliver’s only suspension without pay occurred from February 28, 2019 toMarch 28,2019. From 2015 to thetime she retiredin May 2019, Sgt.Oliver’s base pay was never reduced as a resultof ariyof her transfers wighin OPD. DECLARATION OF AMBER FULLER IN SUPPORT OF DEFENDANT’S RG19007799 ‘MOTION FOR SUMMARY JUDGMENT Ideclare under penalty of perjury under the laws of California that the foregoing istrue and correct. Executed on this27th day of September 202 |in Oakland, California. AMBER FULLER Y 3 DECLARATION OF AMBER FULLER IN SUPPORT OF DEFENDANT'S RG19007799 MOTION FOR SUMMARY JUDGMENT EXHIBIT 3 BARBARA J. PARKER, City Attorney— SBN 069722 MARIA BEE, ChiefAssistant CityAttorney — SBN 167716 KEVIN MCLAUGHLIN, SupervisingDeputy CityAttorney — SBN 251477 MICHAEL QUIRK, Deputy City Attorney SBN 283351 One Frank H. Ogawa Plaza, 6th Floor Oakland, California 94612 Telephone: (510) 238-6520 Fax: (510) 238-6500 Email: mquirk@oaklandcityattorney.org 33244/3110053 Attorneys for Defendant ND CITY OF OAKLAND (also erroneously sued as NN OAKLAND POLICE DEPARTMENT) CO SUPERIOR COURT OF THE STATE OF CALIFORNIA oO 10 COUNTY OF ALAMEDA ll MILDRED L. OLIVER, Case No. RG19007799 12 Plaintiff, ASSIGNED FOR ALL PURPOSES TO JUDGE James Reilly 13 V. DEPARTMENT 25 14 CITY OF OAKLAND, OAKLAND POLICE DECLARATION OF MARY ANN DEPARTMENT, AND DOES 1-25, GONZALES IN SUPPORT OF 15 INCLUSIVE, DEFENDANT’S MOTION FOR SUMMARY JUDGMENT, OR 16 Defendants. ALTERNATIVELY SUMMARY ADJUDICATION 17 Date: December 15, 2021 18 Time: 9:00 a.m. Dept.: 25 19 Reservation No: R-2282494 20 Complaint filed: February 21, 2019 21 Trial date: January 24, 2022 22 23 24 25 26 27 28 1 DECLARATION OF MARY ANN GONZALES IN SUPPORT OF DEFENDANT’S RG19007799 MOTION FOR SUMMARY JUDGMENT DECLARATION OF MARY ANN GONZALES I,MARY ANN GONZALES, declare as follows: 1. The facts stated herein are based on my personal knowledge and, if called as a witness, Icould and would competently testifythereto. 2. [ama Human Resource Analyst, currently Acting Senior Human Resource Analyst, for the City of Oakland, inthe City’s Human Resources Management Department. J have worked for the City since March 2006. Ihave worked in human resources (“HR”) for 15 years. [have a bachelor’s degree in Sociology, and have completed various HR training courses including the CPS HR Consulting - HR Academy. Ihave attended various HR trainings with the International Public 10 Management Association forHuman Resources (IPMA), CPS HR Consulting, and the Western 11 Region Intergovernmental Personnel Assessment Council (WRIPAC). 12 3. As part of my regular duties, Iassist the City’s Human Resources department with 13 the administration ofrecruitment and examination for new employees and promotional opportunities 14 at the City. 15 4. Tam a custodian ofrecords for the City’s Human Resources Department. All 16 exhibits attached to thisDeclaration constitute business records from the City. These documents are 17 kept by the City in the regular course of business, and itwas the regular course of business for the 18 City or for an employee or representative of the City, with knowledge ofthe act, event, condition, 19 opinion, or diagnosis, recorded to make the record or to transmit information thereof to be included 20 in such record, and the record was made at or near the time reasonably soon thereafter. 21 5. Itis the regular practice of my department to keep copies ofpast recruitment postings 22 for promotional opportunities. I am familiar with the system we use to save these postings, and I am 23 one ofthe custodians with access tothese documents. Attached as Exhibit A hereto isa true and 24 correct copy of the February 24, 2016 promotional opportunity for the position of Lieutenant of 25 Police with the Oakland Police Department, which was circulated within the Oakland Police 26 Department. 27 6. Based on my experience working as a Human Resource Analyst forthe City of 28 Oakland and my review of the City’s records, [ am familiar with the examination thatwas 2 DECLARATION OF MARY ANN GONZALES IN SUPPORT OF DEFENDANT’S RG19007799 MOTION FOR SUMMARY JUDGMENT administered for thisparticular promotional opportunity. 7. The City contracts with an outside consultant to design and help administer the examination. For this examination, stage one consisted of an objective multiple-choice test based on a reading listprovided to applicants. Stage two involved a series of panel interviews involving a variety of job-related assessment exercises. 8. Participants in stage two of the examination are graded anonymously. At the beginning of the examination, each applicant chooses a randomized number which they will be referred to by throughout the testing and grading process. The City’s Human Resources Department does not know which name belongs tothe randomized numbers until the testscores are delivered for 10 tabulation by the City’s Human Resources Department. 11 9. The panelists for this examination were not Oakland police personnel. The panelists 12 were law enforcement officers from outside agencies. The stage two panelists independently graded 13 each applicant, not the City. Test results were then relayed to the City’s Human Resources 14 Department upon completion. 15 10. The testwas administered by the City’s Human Resources Department, with 16 assistance from theconsultant. 17 I declare under penalty of perjury under the laws of California that the foregoing 1strue 18 and correct. Executed on this 27th day of September 2021 in San Ramon, California. 19 20 Mary. Man Gongalee MARY ANN GONZAYES 21 22 23 24 25 26 27 28 3 DECLARATION OF MARY ANN GONZALES IN SUPPORT OF DEFENDANT’S RG19007799 MOTION FOR SUMMARY JUDGMENT EXHIBIT A Job Bulletin Page 1 of 6 CITY OF OAKLAND invites applications for the position of: Lieutenant of Police (Promotional) CITY.OF OAKLAND SALARY: $14,521.95 - $14,521.95 Monthly $174,263.40 - $174,263.40 Annually OPENING DATE: 02/24/16 CLOSING DATE: 03/29/16 04:00 PM THE POSITION: Salary $11,803.64 Monthly, $141,643.68 Annually (80 hour schedule) $12,393.81 Monthly, $148,725.72 Annually (84 hour schedule) The City of Oakland is recruiting tofill several Lieutenant of Police positions within the Oakland Police Department. Under direction of aCaptain or Deputy Chief, a Lieutenant ofPolice performs administrative, middle management work involving the direction of an essential, and often large, police activity.A Lieutenant is directlyresponsible for the efficientmanagement of a Police Service Area, Division, Section or Watch within the constraints of the Department's policies and procedures. The scope of work requires an extensive understanding of and an abilitytoimplement the Department's operating policies.A Lieutenant isexpected to solve major problems as they arise, especially in the field,with limited recourse to supervision. Working conditions may include field,desk and shift work. The job requires the exercise of independent judgment. A Lieutenant may supervise Sergeants, Police Officers and civilianpersonnel. In accordance with the terms of Sign-up and Examination Eligibility inthe current Promotional Memorandum of Understanding between the City of Oakland and the Oakland Police Officers’ Association, thisexamination is open to any member of the Oakland Police Department who has completed three (3) years ofservice as a Sergeant ofPolice by March 29, 2016. Qualified Oakland Sergeants of Police may apply by submitting acompleted Notice of Intent form. This form isavailable inthe Personnel Section of the Police Administration Building, Room 704. In order to apply for the examination, an original completed Notice of Intent form must be submitted to the Personnel Section, no later than 4:00 p.m., Tuesday, March 29, 2016. EXAMPLES OF DUTIES: See additional information forapplicants below, Example of Work Functions. MINIMUM REQUIREMENTS FOR APPLICATION: The examination willbe administered in two stages. Candidate's must achieve a minimum scale score of70 ineach stage of the examination to be placed on the eligiblelistforemployment consideration. file://oakland/recruitclass/Test/Police%20Department%20(OPD)/Lieutenant.16/2021%20.... 9/12/2021 Job Bulletin Page 2 of 6 Stage I: The firststage ofthe selection process willconsist of an objective multiple-choice test (weighted 23.7%) based primarily on the reading listincluded with thisannouncement and posted in the Personnel Section of the OPD, Room 704. The testwill include the following dimensions: e Knowledge ofPolice Techniques 7.6% e Knowledge ofAdministrative/Operational Procedures 8.1% e Knowledge ofLegal Issues 8.0% Stage Il:The second stage in the selection process willinvolve a variety ofjob-related assessment exercises (weighted 76.3%) and willinclude the following dimensions: Leadership 13.0% Motivational Ability 8.3% Problem Analysis 9.1% Judgment/Decision Making 10.3% Planning/Organization 6.9% Oral Communication 6.9% Written communication 7.8% Interpersonal Skill 7.0% Composure 7.0% The City of Oakland reserves the rightto modify the selection process as necessary to conform to administrative or business necessity. Candidates must achieve a scale score of 70 or more on each stage ofthe examination inorder to continue in the selection process and to achieve placement on the eligibility list.Scoring isbased on Section 4.17 of the Personnel Manual of the CivilService Board. The examination willbe conducted in accordance with the OPOA Memorandum of Understanding of July 1,2015. Stage | ofthe examination is scheduled for Tuesday, April 5, 2016 atthe Human Resources Management Department, 150 Frank H.Ogawa Plaza, 2nd Floor, in Oakland. Candidates must bring a picture identificationcard issued by a government agency tobe admitted tothe exam. Qualified applicants who filea timely Notice of Intent are to report directly to the test site no laterthan 9:00 a.m.. on the day of the exam. No other written notificationof the examination willbe provided to applicants unless they are deemed unqualified. After the reporting time, the entrance to the test willbe closed and no one willbe admitted. Stage Ilof the examination istentatively scheduled forthe week of May 2, 2016 at the Human Resources Management Department, 150 Frank H. Ogawa Plaza, 2nd Floor, in Oakland. Candidates who are successful inStage | ofthe process willbe notified ofthe exact date and time for Stage Il. ADDITIONAL INFORMATION FOR APPLICANTS: Example of the Work Functions: A description ofthe possible events in a working day of a Lieutenant of Police job is attached. Itisintended to inform potential candidates of the typical functions performed by a Lieutenant of Police. Itisnot intended to be an exhaustive listof allthe duties performed, nor allthe knowledge, skillsand abilitiesemployed by a Lieutenant of Police. The examination may include knowledge, skillsand abilitiesnot covered inthe attached description. The purpose of this document isto provide a general understanding of typicalrequirements for the Lieutenant of Police position. Scenarios which represent situations handled by OPD Lieutenants required functions for each scenario are described below. Scenario 1A Lieutenant Jones is a Watch Commander. A major topic in the most recent Crime Stop meeting file://oakland/recruitclass/Test/Police%20Department%20(OPD)/Lieutenant.16/2021%20.... 9/12/2021 Job Bulletin Page 3 of 6 was the number of rapes that had occurred in the last month in one of the area neighborhoods. Lieutenant Jones utilizescrime analysis information todevelop a targeted enforcement strategy to deal with the crimes. He isscheduled to meet with a community group inthe neighborhood to discuss the Department's strategy. As he is drivingto the meeting, he sees a person who matches the suspect's description. This person startsrunning down the street when he sees the police car. REQUIRED FUNCTIONS Identifies problems and secures relevant information. Makes reasoned decisions based on the analysis ofinformation. Flexible and able to adapt plans or decisions when dealing with new information. Able to think critically. Coordinates staffin the implementation of problem-oriented policing projects. Observes individuals, objects, or events under diverse lighting conditions. Recognizes objects or individuals from written and oraldescriptions. Depending on the situation, absorbs information using vision, hearing, and the senses of touch and smell. Memorizes visual images and translates these cues into narrative descriptions. Scenario 1B Lieutenant Jones exitshis vehicle and advises the dispatcher by radio ofhis location and that he along with a cover officer isin foot pursuit of apossible rape suspect. This suspect isin sight.He directs officersto establish a perimeter. The suspect runs through backyards, knocking over trash cans. Lieutenant Jones continues his pursuit. While running, he repeatedly updates the dispatcher, using a hand-held radio. He callsfor additional resources to set up containment. REQUIRED FUNCTIONS Acts quickly and decisively. Enters and exits police vehicle quickly in order to respond to emergencies. Coordinates and rapidly performs a series ofcomplex operations involving arms, hands and fingers. Runs some distance with quick stops, starts, and turns.Maneuvers around objects while running. Works and communicates well under stressful conditions. Scenario 1C Lieutenant Jones catches up with the suspect who turns and starts fighting.He applies a control hold and then pullsthe suspect's hands behind hisback, handcuffs him, and pat searches him. He raises the suspect to a standing position and guides him tothe nearest street. Other units have arrived and he hands the suspect over to them. REQUIRED FUNCTIONS Uses sense of touch to detect illegalsubstances or weapons concealed on suspects, to apply handcuffs, and touse complex contro! holds. Exerts appropriate force to restrainindividuals without causing unintentional injuries.Has the strength to lift, pulland push an adult of average weight and torestrain such a person resisting arrest. Reviews reports foraccuracy and completeness. Scenario 2A Lieutenant Smith isan Investigations Lieutenant. She begins the shift by reviewing various memos, reports, documents and her email. She prioritizesthe items and determines a course of action for each. Some require immediate handling or distribution,others she saves for processing laterduring the day. Some may be handled orally while others require that she generate reports or correspondence. She isparticularly focused on crime reports for a series of armed robberies that have recently occurred in an Area. She has assigned a team of investigators to focus their effortson these cases atthe request of the CID Captain. REQUIRED FUNCTIONS Clearly understands OPD administrative and operational