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HomeMy WebLinkAbout2018-02-07 Merit Appeals Board Minutes Page 1 MEETING OF THE COUNTY OF HAWAI ʻ I MERIT APPEALS BOARD TRANSCRIPT OF PROCEEDINGS held on February 7, 2018, at the Aupuni Center Conference Room, 101 Pauahi Street, Suite 1, Hilo, Hawai ʻ i, 96720, commencing at 9:27 a.m. REPORTED BY: TERI HOSKINS, RMR, CSR #452 ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 2 1 APPEARANCES 2 ACTING CHAIR: 3 DAVID K. S. NAHUINA 4 5 BOARD MEMBERS: 6 LUAHIWA NAMAHOE 7 MITCH TAM 8 WILLIAM CHILLINGWORTH 9 10 ABSENT & EXCUSED: JULIE M. TULANG, CHAIR 11 DEPUTY ATTORNEY GENERAL: 12 JAMES E. HALVORSON, ESQ. 13 14 ALSO PRESENT: 15 GLYNIS YAMADA 16 WILLIAM V. BRILHANTE, JR. 17 LEE LORD 18 WIL OKABE 19 MITCHELL ROTH 20 BARBARA KOSSOW (via videoconference) 21 CLEMENT GUZMAN 22 KELLY MAYNE 23 DANIEL PANG 24 NORA NOMURA, HGEA CONSULTANT 25 MOANA HOKOANA, HGEA UNION AGENT ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 3 1 CONTENTS 2 WITNESS PAGE 3 KELLY MAYNE 4 DIRECT EXAMINATION VIA STATEMENT 31 5 CROSS EXAMINATION BY MR. MUKAI 37 6 REDIRECT EXAMINATION BY MS. NOMURA 41 7 RECROSS EXAMINATION BY MR. MUKAI 45 8 EXAMINATION BY MS. NAMAHOE 46 9 10 DANIEL PANG 11 DIRECT EXAMINATION VIA STATEMENT 47 12 CROSS EXAMINATION BY MR. MUKAI 51 13 REDIRECT EXAMINATION BY MS. NOMURA 56 14 RECROSS EXAMINATION BY MR. MUKAI 60 15 16 CLEMENT GUZMAN 17 DIRECT EXAMINATION VIA STATEMENT 62 18 CROSS EXAMINATION BY MR. MUKAI 72 19 REDIRECT EXAMINATION BY MS. NOMURA 75 20 RECROSS EXAMINATION BY MR. MUKAI 76 21 EXAMINATION BY MR. CHILLINGWORTH 77 22 23 LEE LORD 24 DIRECT EXAMINATION BY MR. MUKAI 81 25 CROSS EXAMINATION BY MS. NOMURA 102 ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 4 1 CONTENTS 2 WITNESS PAGE 3 LEE LORD (continued) 4 EXAMINATION BY MR. TAM 111 5 EXAMINATION BY MS. NAMAHOE 114 6 EXAMINATION BY CHAIR NAHUINA 118 7 EXAMINATION BY MR. HALVORSON 119 8 RECROSS EXAMINATION BY MS. NOMURA 120 9 10 MITCHELL ROTH 11 DIRECT EXAMINATION BY MR. MUKAI 122 12 CROSS EXAMINATION BY MS. NOMURA 134 13 EXAMINATION BY MR. HALVORSON 144 14 REDIRECT EXAMINATION BY MR. MUKAI 145 15 RECROSS EXAMINATION BY MS. NOMURA 147 16 17 WIL OKABE 18 DIRECT EXAMINATION BY MR. MUKAI 150 19 20 BARBARA KOSSOW 21 DIRECT EXAMINATION BY MR. MUKAI 154 22 23 24 25 ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 5 1 CHAIR NAHUINA: Call to order the Merit 2 Appeals Board meeting today, February 7th, 2018, at 3 9:27. 4 Thank everybody for their patience. Thank 5 you, Teri, for coming in so quickly. 6 I ask if there's addendums to the agenda 7 today. 8 None. 9 Any statements from the public? 10 There are no minutes for approval, and there 11 are no communications and, at this time, we have no new 12 business, so we'll move on to unfinished business, 13 which is the hearing. 14 At this time, I will ask the Appellants if 15 they would like an open hearing? 16 MR. GUZMAN: Yes. 17 MR. MAYNE: Yes. 18 CHAIR NAHUINA: Thank you. 19 I would like to introduce the Board Members 20 and our legal counsel. Today Julie Tulang, our Chair, 21 was unable to be here today. I'm David Nahuina, Vice- 22 Chair. I will be serving as Acting Chair in her 23 absence. I ask that Board Members introduce themselves 24 first. 25 MR. CHILLINGWORTH: William Chillingworth. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 6 1 MS. NAMAHOE: Luahiwa Namahoe. 2 MR. TAM: Mitch Tam. 3 MR. HALVORSON: And Deputy Attorney James 4 Halvorson, attorney for the Merit Appeals Board. 5 CHAIR NAHUINA: Thank you. 6 I see that both counsels are present. I 7 would like to ask if you would please introduce 8 yourselves. 9 MR. MUKAI: Thank you. John Mukai, Deputy 10 Corporation Counsel, on behalf of the Office of the 11 Prosecuting Attorney. Also present is Mitch Roth, 12 Prosecuting Attorney; and Lee Lord, also Business 13 Manager from the Office of the Prosecuting Attorney. 14 MS. NOMURA: Hi. Good morning. My name is 15 Nora Nomura. I'm also a consultant with HGEA. I 16 retired after 20 years with the union, and I'm here at 17 the request and with pleasure to represent our 18 bargaining unit members. I'm not counsel but I, 19 certainly, hope in this setting that I can lend 20 assistance to the process. Thank you. 21 MR. GUZMAN: I'm Investigator Clem Guzman 22 from the Hawai ʻ i County Prosecutor's Office. 23 MR. PANG: Hi. Good morning. My name is 24 Daniel Pang with the prosecutor's office, Investigator. 25 MR. MAYNE: Hi. Good morning. My name is ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 7 1 Kelly Mayne. I'm also one of the Investigators from 2 the prosecutor's office. 3 CHAIR NAHUINA: Thank you very much. 4 This hearing is appeals filed by Mr. Clement 5 Guzman, Mr. Kelly Mayne, and Mr. Danny Pang at the Merit 6 Appeals Board meeting held on September 27th, 2017. 7 These three appeals were consolidated with no objection 8 from the parties. 9 The issue in this case has been identified as 10 did Employer, the Office of the Prosecuting Attorney, 11 and the County of Hawai ʻ i violate any statutes, 12 regulations, rules, or personnel policies regarding 13 their recruitment and examination actions concerning 14 their interview and selection procedures/process? If 15 the answer to the above is "Yes," then what remedy can 16 be awarded by the Merit Appeals Board? 17 The Board is in receipt of communication by 18 the County, Communication No. 17-04.07, to discuss the 19 motion to dismiss for lack of jurisdiction. We will 20 take this matter up first. 21 Are the parties prepared to proceed at this 22 time? 23 MR. MUKAI: Yes. 24 MS. NOMURA: Yes, we are. 25 CHAIR NAHUINA: The Board will now hear ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 8 1 oral arguments on this motion. 2 Does either party have any additional 3 evidence? 4 So, County, if you would like to make your 5 oral argument. 6 MR. MUKAI: Thank you. 7 With respect to the appeal of Kelly Mayne, we 8 filed a motion to dismiss based on the Board's lack of 9 jurisdiction in this case. I'm anticipating the 10 argument that what the prosecuting attorney's office 11 did was a recruitment. And so, under 76-14, I would 12 agree that any person can seek remedy under 76-14.1 13 through the Merit Appeals Board, but we need to be 14 careful with making bright-line rules, because in 15 Mr. Mayne's case -- and I will segue into all appellants 16 as a whole -- in Mr. Mayne's case, he did, in fact, seek 17 remedy through the collective bargaining unit; and I've 18 attached as Exhibit F to my motion, and it's a letter 19 dated July 26, 2017, from Ms. Hokoana, union business 20 agent of the HGEA. 21 Now, what's interesting in this submission is 22 if the Board were to turn to the third page where 23 Ms. Hokoana states Article 13. And under Article 13 of 24 the HGEA Unit 13 collective bargaining agreement, there 25 is a remedy to be pursued in the collective bargaining ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 9 1 agreement. It is the exclusive remedy because the 2 collective bargaining agreement is a contract. The 3 contract is between the Employer, the County of Hawai ʻ i, 4 and all counties in Hawai ʻ i and the State to abide by 5 certain rules and regulations. And where there is a 6 remedy provided in the collective bargaining agreement, 7 the Hawai ʻ i Revised Statutes Section 76-14 says that the 8 Merit Appeals Board shall refer to other authority for 9 the grievance procedure under a collective bargaining 10 agreement. 11 Here with respect to Mr. Mayne, he has elected 12 to seek his remedy under the collective bargaining 13 agreement and, rightfully so, because the promotion 14 provision, Article 13, in conjunction with Article 11, 15 provides the only process for him to get his remedy. 16 And so, with regard to Mr. Mayne, I believe the remedy 17 lies within collective bargaining unit exclusively and 18 not with the Merit Appeals Board. Now, as I'm 19 reviewing the case, I realize that the same holds true 20 for Mr. Guzman and Mr. Pang. 21 There are certain things here that are 22 undisputed. It's undisputed that all three members 23 sitting before us are HGEA Bargaining Unit 13 members. 24 It's undisputed. And it's undisputed that -- 25 Mr. Guzman was Investigator V, Mr. Mayne was an ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 10 1 Investigator V, and Mr. Pang was an Investigator IV -- 2 all sought a promotion, a promotion, to an Investigator 3 VI position. It's undisputed. So, under those 4 circumstances, Hawai ʻ i case law and the Hawai ʻ i Revised 5 Statutes, it is clear that the only remedy that they 6 can seek is through the collective bargaining 7 agreement. 8 Now, there's a reference in Ms. Nomura's 9 submission that talks about 76-14.02, which talks about 10 denial or loss of a promotional opportunity. 11 MR. HALVORSON: Just a moment, Mr. Mukai. 12 Are you referring to the document that was just 13 distributed dated February 7, 2018? 14 MR. MUKAI: That's correct. 15 MR. HALVORSON: Glynis, has this been marked? 16 MS. YAMADA: It has not. We just received it 17 today, so there's no number. 18 MR. HALVORSON: So, what would be the next 19 exhibit number in order? 20 MS. YAMADA: It would be 17-04.08. 21 MR. HALVORSON: Did all the Merit Appeals 22 Board Members hear that? 23 MR. CHILLINGWORTH: So, 17-04.08. 24 MR. TAM: Yes. 25 MR. HALVORSON: I want to make sure we all ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 11 1 were literally on the same page. 2 I'm sorry, Mr. Mukai, continue. 3 MR. MUKAI: Okay. So, again, it talks about 4 the loss of a promotional opportunity. Well, again, 5 when you talk about the loss of a promotional 6 opportunity, the remedy, once again, lies exclusively 7 within the collective bargaining agreement. For 8 those -- you're all familiar with, in labor, the 9 collective bargaining agreement is sacred. It is the 10 exclusive remedy for these individuals. And yes, I 11 agree, it's a recruitment; but in certain 12 circumstances, like we have here, it's undisputed that 13 they're seeking a promotion. 14 In the collective bargaining agreement 15 Article 13, it talks about the Rules of Civil Service 16 and how it should be applied. They have a right to 17 challenge the process. And that's what it is; it's a 18 challenge of the process. Was it conducted fairly, et 19 cetera, et cetera? That was done -- that must be done, 20 and the remedy has to be done, pursuant to the 21 collective bargaining agreement. And pursuant to HRS 22 76-14(c)(1), the Board has to defer this. And if there 23 is -- I would caution that if there's any further 24 hearing, it could potentially be violative of HRS 25 Chapter 89, because it would potentially interfere with ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 12 1 the contractual rights that have been entered into 2 between the Employer and the HGEA. 3 Nothing further. 4 And, for the record -- I'm sorry -- I 5 filed the Employer's Motion to Dismiss for Lack of 6 Jurisdiction for all Appellants on -- I believe it was 7 Friday, February...? 8 MS. YAMADA: 5. 9 MR. MUKAI: 5. 10 MS. YAMADA: I'm sorry. Correction. 11 February 2. 12 MR. MUKAI: February 2. I apologize. 13 I would submit that this motion is 14 jurisdictional, so the question of jurisdiction can be 15 raised at any time. Okay. 16 CHAIR NAHUINA: At this time, I would 17 like to allow the Appellants to make their argument. 18 MS. NOMURA: Yes. I would like to speak on 19 behalf of the Appellants on this issue. 20 I did submit something to you, but I do want 21 to -- yes, HGEA did file a grievance on behalf of 22 Mr. Mayne on the issue of promotions. The union 23 contract does contain a promotions article on the basis 24 of seniority. That is its basis. It's not on 25 recruitment and examination, because that is the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 13 1 purview of the merit system, and that's why we're 2 before the Board today. 3 There's no doubt these people have standing 4 in this situation. There was an action by the 5 person -- not a disciplinary action, not a performance 6 evaluation action. This was an action of selection by 7 the County and, in this case, that is your jurisdiction 8 regardless of whether they're civil service employees, 9 bargaining unit members, or members of the public. 10 That is your purview. So, to make the argument that 11 because they're civil service employees and because we 12 have a promotions article, that's their avenue for 13 relief -- that is not true. I can tell you we filed 14 hundreds of promotions articles, and that comes up over 15 and over again. Recruitment exam -- that is civil 16 service. That is the Merit Principle. So, I think to 17 turn it around now and to say that this is properly in 18 the grievance process -- no, we don't agree. 19 MR. MUKAI: If I may briefly respond. We 20 have a letter specifically from Ms. Hokoana that says 21 "We've invoked the grievance process, Article 13." 22 Now, when Ms. Nomura talks about seniority 23 and that this is recruitment, this is specific to these 24 three individuals, and for them, Article 13 provides 25 the remedy -- and I would direct the Board to my ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 14 1 Exhibit A -- seniority wins if everything is equal. 2 But what they are doing, whether it's here or in a 3 promotion grievance arbitration type setting, is 4 challenging the process. 5 Article 13(c) talks about the civil service 6 statute, rules, and regulations. They're saying that 7 the process was flawed. It's nothing that the selectee 8 did or did not do. It's, basically, that the Employer 9 did a process that was flawed. And so, that's the 10 remedy. It is their only remedy under the Hawai ʻ i 11 Revised Statutes and the collective bargaining 12 agreement. 13 CHAIR NAHUINA: And -- 14 MS. NOMURA: Can I respond? 15 CHAIR NAHUINA: Of course. 16 MS. NOMURA: Of course, we can make any 17 argument we want to. Mr. Mukai is making arguments, 18 right now, to sway you to his perspective from the 19 Employer, but that doesn't mean that's going to prevail 20 any more than our arguments that a grievance level is 21 going to mean that we're going to prevail. We make the 22 arguments with whatever facts we have on hand. At the 23 heart of the issue is promotions and seniority. That's 24 it. We may bring in all other issues, but that's what 25 we're dealing with, because that is the limitation of ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 15 1 our contract. 2 Now, when it comes to the Employer's 3 discretion on whether to go with an internal 4 recruitment, whether to go -- that's all the purview of 5 civil service. And we may point out those things in 6 the grievance process, but that doesn't mean that's 7 necessarily a violation of our contract. And that's 8 pointed out time and again. 9 So, I think in this arena, for the Employer to 10 say that they shouldn't be here, that they should be at 11 the griev- -- I don't think that's right. And if you 12 allow this to happen, you will cut off the rights of 13 civil service employees hereon -- and that's wrong. 14 MR. MUKAI: If I may briefly respond. This 15 case is very specific to these individuals. I agree 16 that if this was an open recruitment, yeah -- but, 17 again, we have to be careful of creating these 18 bright-line rules. 19 In this case, it's undisputed that they were 20 an Investigator V, an Investigator V, and Investigator 21 IV, and they sought a promotion to an Investigator VI 22 position. It's undisputed. The remedy is covered by 23 the collective bargaining agreement. That is their 24 sole remedy pursuant to statute and case law in Hawai ʻ i 25 that I have laid out in both motions to dismiss. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 16 1 CHAIR NAHUINA: Would you like to make a 2 statement? 3 MS. NOMURA: I just would like to clarify 4 that this was an open recruitment. This is not an 5 internal recruitment, unless I -- this was an open 6 competitive recruitment. So, there were members of -- 7 the selectee was from outside the jurisdiction. So, I 8 don't think we're arguing an internal recruitment 9 situation where they're all, you know, civil -- they're 10 not all civil service employees that applied. And 11 these are not the only applicants to the position from 12 the Office of the Prosecutor. There were also others 13 who are not here today. 14 So, there are a lot of things, I think, the 15 Board needs to look at in this case; and that's why 16 we're before you. 17 MR. MUKAI: If I may briefly respond. For 18 one thing, the selectee was not a member -- was not 19 from outside the jurisdiction. 20 Number two -- 21 MR. HALVORSON: Where was the selectee from? 22 MR. ROTH: University of Hawai ʻ i at Hilo. 23 MR. MUKAI: University of Hawai ʻ i at Hilo. 24 Now, if the selectee was not selected, I 25 would agree his remedy -- or a non-selected employee ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 17 1 who is not part of the collective bargaining unit 2 agreement, who was not seeking a promotion as these 3 gentlemen are, then they would be properly before this 4 Board; but, specifically, to this case -- no. And they 5 must be deferral. There's Hawai ʻ i Revised Statutes and 6 existing case law. 7 MR. HALVORSON: So, you're not disputing 8 Ms. Nomura's assertion that this was an open 9 competitive recruitment? 10 MR. MUKAI: Yes. 11 MR. HALVORSON: And just to get the facts out 12 on the record, do you know how many applicants there 13 were? 14 MR. ROTH: I think there was -- 15 MR. HALVORSON: And I'm not going to hold you 16 to an exact number. 17 MR. ROTH: 8? 9? 18 MR. LORD: Actually, there was about 12 -- 19 but then, when they were called, only nine of them, or 20 eight of them, wanted to be. 21 CHAIR NAHUINA: Board Members, do you have 22 any questions? Anything? 23 MS. NAMAHOE: Not at this time. 24 MR. HALVORSON: So, if I can ask Mr. Mukai, 25 Ms. Nomura, do you see there being a difference between ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 18 1 a promotion and a recruitment? 2 MR. MUKAI: Absolutely, because in this case, 3 these three individuals were seeking a promotion. I 4 would -- if there were -- we've heard that there were 5 approximately nine individuals who applied for the 6 position. And if they were not in their position 7 seeking a promotion, I would agree that their remedy 8 exists before this Board. But, specifically, for these 9 gentlemen who are covered by the HGEA Unit 13 10 contract, and the reference by Ms. Hokoana in her 11 letter and attachments that specifically talk about 12 promotions -- and she's right; that is their remedy. 13 MR. HALVORSON: So, Ms. Nomura, let me ask 14 you this question. And partly I'm asking these 15 questions because I'm going to have to write the 16 decision, or help write the decision. But is it your 17 position, because this was an open competitive 18 recruitment, that the collective bargaining agreement 19 with regard to seniority would not apply in this case? 20 MS. NOMURA: What we're saying is that we're 21 here today because we felt the recruitment and exam 22 process was flawed; and the remedy we're requesting of 23 this Board, which I think has come up before, is not 24 for a promotion for any of these employees. The remedy 25 we're seeking is that this be redone correctly because ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 19 1 of those flaws that these employees saw. 2 MR. HALVORSON: But assuming that the process 3 was done correctly, are you conceding that the 4 provision with regard to seniority would not apply 5 because they would be comparing their seniority to 6 somebody who is not in the bargaining unit? 7 MS. NOMURA: If there was an issue of 8 seniority, yes, we would take that up with the 9 appropriate employee, and we would pursue a grievance 10 to the point where we got information that, in fact, a 11 violation of the contract did occur. 12 MR. HALVORSON: So, you're saying that even 13 though it was an open competitive recruitment, that the 14 seniority provision could still apply? 15 MS. NOMURA: It might apply but, again, it's 16 a separate issue from -- you know, I don't think it 17 precludes any employee from coming here today. 18 MR. HALVORSON: Okay. And I've got one more 19 question. What's the position of the parties with 20 regard to -- I'm looking at the Unit 13. It's 21 contained in Exhibit A of the motion, Article 13, 22 "Promotions," paragraph C. So, I'm asking the parties 23 what is your position with regard to the fact this 24 exists in the collective bargaining agreement, what 25 effect this has on the motion? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 20 1 MR. MUKAI: Well, that -- it's our position 2 that this provides their exclusive remedy. They have 3 to seek it through the collective bargaining agreement. 4 And Mr. Mayne has already sought that under 5 the collective bargaining agreement. But it applies to 6 each of the individuals. It is specific to them. They 7 are seeking a promotion. Therefore, the promotional 8 provision provides their remedy to challenge the 9 process. 10 MR. HALVORSON: But Mr. Mayne's grievance 11 focused on the seniority issue, not this on 12 particular -- 13 MR. MUKAI: There's a reference to 13. And 14 it cannot be argued that they are seeking promotions. 15 They cannot call it different things and say, "Well, 16 now it's open recruitment, it's seniority." They are 17 seeking a promotion -- it's undisputed -- from Vs and 18 IV to an Investigator VI position; so, the remedy to 19 challenge the process is clear. And that's the 20 County's position. 21 MR. HALVORSON: Ms. Nomura, paragraph C? 22 MS. NOMURA: Again, this article deals with 23 seniority. We know that. We take grievances to the 24 Employer when it's an issue of seniority and a 25 promotion is involved, obviously; but in this case, ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 21 1 whether it's a promotion or not, the issue is that it 2 should have gone to an internal recruitment, which 3 there were inconsistencies or things that were wrong in 4 the process. Those are all issues that are open to 5 anyone, including these employees, who feel that they 6 have been adversely affected by the action. 7 MR. MUKAI: Briefly. Thank you, Ms. Nomura. 8 She's just said it: They're challenging the process. 9 Article 13, Section C in their situation is the 10 exclusive remedy, so the Board must dismiss this case 11 for lack of jurisdiction. 12 MS. NAMAHOE: I, actually, would like to hear 13 from Ms. Hokoana. You were referenced a few times. 14 MS. HOKOANA: Yes. 15 So, I initially did file the grievance on 16 behalf of Kelly Mayne, with the assumption that he was 17 the most senior, and for discovery of what his scores 18 were in the interview. 19 So, based on the information that I received, 20 he was not the most senior, and his scores weren't 21 relatively equal to the selectee. So, therefore, we 22 didn't have a case when it came to the grievance 23 process because we didn't meet the provisions of 24 Article 13; so that's where I had directed Mr. Mayne to 25 move forward with his internal complaint. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 22 1 And that internal complaint now was then 2 filed with regards to the recruitment and examination 3 part of the internal complaint process or procedure and 4 with the remedy of having the recruitment redone as an 5 internal recruitment rather than an open competitive 6 recruitment. So, that would have been the remedy 7 through the internal complaint. The remedy seeked, 8 through the grievance, was based on the fact if he was, 9 in fact, the most senior and had relatively equal 10 scores with the selectee, that the remedy there would 11 be to have him placed -- selected and placed in that 12 position. 13 That's not what we're seeking today. We're 14 not seeking to get any one of these three candidates 15 selected and promoted into the position. What we're 16 seeking is to reveal that the process was flawed in 17 terms of the recruitment and examination. So, we have 18 no real case in the grievance. That wouldn't be the 19 venue for that. 20 MS. NAMAHOE: Thank you. 21 MR. MUKAI: Briefly, Ms. Hokoana talked about 22 challenging the process. And, again, under the 23 collective bargaining unit process, it's clear it's 24 their only remedy. 25 And, if the Board does not dismiss this for ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 23 1 lack of jurisdiction, this is potentially a violation 2 of Chapter 89 for interference with the contractual 3 rights between the bargaining unit and the Employer. 4 So, if the Board is thinking about pursuing this case, 5 I would suggest -- and it's happened in the past, that 6 there's a substantial question about jurisdiction -- 7 that this matter be taken to the Hawai ʻ i Labor Relations 8 Board for their determination of where the jurisdiction 9 is within the Merit Appeals Board. 10 CHAIR NAHUINA: Thank you. 11 Any other questions? 12 MR. TAM: No. 13 MS. NAMAHOE: Not at this time. 14 MR. HALVORSON: I'm going to ask that we 15 deliberate in Executive Session. 16 Can I hear a motion? 17 MR. TAM: I move that we go into Executive 18 Session. 19 MS. NAMAHOE: I second. 20 CHAIR NAHUINA: All in favor say "Aye." 21 (All Board Members responded affirmatively.) 22 CHAIR NAHUINA: Those opposed, same sign. 23 Ayes have it. We will be going into 24 Executive Session. 25 (Executive Session ensued from 9:56 a.m. to ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 24 1 10:16 a.m.) 2 CHAIR NAHUINA: Thank you. It's 10:16. 3 We're out of Executive Session, and I would like to 4 announce that the Board has made a decision. By 5 unanimous decision, the Board has denied the County's 6 motion to dismiss, and we will be hearing this case on 7 its merits. 8 At this time, we would look to ask -- 9 MR. MUKAI: Before we proceed, I would ask 10 that the Board issue a written decision that -- I have 11 to dig up Circuit Court -- 12 MR. HALVORSON: Yes. I will -- been writing 13 that and drafting for the Board's approval a decision 14 in this case. 15 MR. MUKAI: I would ask that the decision be 16 written prior to us proceeding. I have strong feelings 17 against proceeding. I do think it's a violation of 18 Chapter 89 if the Board forces the County to proceed. 19 CHAIR NAHUINA: Your request is duty 20 noted, and the Board is going to decide to continue on 21 with this. 22 MR. MUKAI: Okay. 23 CHAIR NAHUINA: At this time, I would like 24 to ask if there are any additional opening statements 25 to be made. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 25 1 MS. NOMURA: Mr. Chair, I do have an opening, 2 and I didn't write it but it's, basically, what I 3 presented. May I share that with you? 4 CHAIR NAHUINA: Yes. Go ahead. 5 MR. HALVORSON: Ms. Yamada, this would be 6 17...? 7 MS. YAMADA: -04.09. 8 MR. HALVORSON: Thank you. 9 MS. NOMURA: Is it all right to proceed? 10 CHAIR NAHUINA: Yes, please. Thank you. 11 MS. NOMURA: First of all, I have to 12 apologize to Mr. Mayne. I keep mixing up his name. 13 And it's actually Kelly Mayne, and I put Mayne Kelly; 14 so that should be corrected. 15 As we noted previously, the Appellants are 16 civil service employees, and they are in the 17 Investigator IV and V positions covered under Chapter 18 76. And in the Office of the Prosecuting Attorneys, 19 they have appealed to you as a Board to address serious 20 violations to their rights in the recruitment and 21 examination conducted for the Investigator VI position 22 in the department of the Office of Prosecuting 23 Attorney. 24 The Appellants will share their experiences 25 of -- which regarded -- oh, I'm sorry. Is it okay if I ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 26 1 leave it down? 2 MS. YAMADA: Can you hear sufficiently? 3 CHAIR NAHUINA: Yes, we can hear. 4 MS. NOMURA: The Appellants will share their 5 experiences of an interview panel which disregarded the 6 Employer's own established policy, procedures, and 7 guidelines of recruitment. They will share their 8 interview panel composition that was directly in 9 conflict with established guidelines, and the questions 10 did not address the experience needed to perform at the 11 Investigator VI level. 12 This appeal reveals that the recruitment 13 examination process for the Investigator VI vacancy 14 failed to provide recognition of significant past 15 experience of each of these employees. They possessed 16 experience as Investigators IV and V, working in the 17 same office, in the same series of classes, as the 18 vacant position. There was a total disregard of their 19 work experience as current investigators, which 20 provided them the best possible qualification to 21 perform the job at the VI level. 22 Each of the Appellants has significant 23 service time as investigators in this series or in 24 another jurisdiction in a related series; yet, the 25 recruitment process does not credit any of the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 27 1 Appellants for this critical work experience. The 2 Investigator VI recruitment chose to rate on the basis 3 of overall interview responses more than any proven 4 record of ability to do the jobs at a level directly 5 below the vacancy. This is a blatant disregard of the 6 Merit Principle. 7 Each of the Appellants can tell you that they 8 have received satisfactory performance evaluations and 9 have good records of conduct. Civil service in Hawai ʻ i 10 is based on a Merit Principle whereby employees are 11 retained on a demonstrated appropriate conduct and 12 productive performance. It's also intended to build a 13 career service and to provide incentives for competent 14 employees, whether through financial or promotional 15 opportunities. This was not done in this case. 16 The Investigator IV, V, and VI are related 17 classes of the same series, and this classification was 18 last approved by the Department of Human Services in 19 2014. Requirements for the Investigator VI include 23 20 knowledge of and ability to points. Of those, only 21 three are not the same as those required at the 22 Investigator V level. That's how closely related the 23 two classes are. Those three requirements that aren't 24 required at the V level relate to supervision, 25 organization, operation, and working with subordinates. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 28 1 That's understandable, because the only distinction 2 between the V and the VI level is the supervisory 3 responsibilities. However, 20 of the 23 knowledge and 4 abilities required at the Investigator VI level were 5 the same as required for the V level. 19 of those 6 critical knowledge and abilities are required at the IV 7 level. This reflects the close connection in 8 requirements between these classes in the series, which 9 should have been greatly considered in the recruitment 10 process; and that was not considered at all. 11 In the subject recruitment, the Investigators 12 V came into the recruitment process with the knowledge 13 and ability to do 87 percent of the job by virtue of 14 currently performing a job that required them to have 15 this percentage of knowledge and abilities. The 16 Investigator IV had the knowledge and ability to do 83 17 percent of the Investigator VI job. Yet, 83 percent or 18 87 percent credit was not given to these Appellants for 19 the performance of that portion of the Investigator VI 20 vacancy. 21 And what of the applicant who was temporarily 22 assigned to the Investigator VI level? Now, in 23 government, when you are temporarily assigned, you 24 carry out the major portions of that job. In fact, 25 Mr. Mayne did that in a class that is comparatively the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 29 1 same at the state level; yet, there was no credit or 2 recognition for actually doing the job. 3 Each of the Appellants will speak to you 4 today, but given their ability to do the major portions 5 of that Investigator VI job, I think, it's just clear 6 that they should have been given a chance -- and a fair 7 chance in this recruitment process. That is 8 established by the Merit Principle. And that's where 9 we see a gross violation in this recruitment and 10 examination process. 11 With that, I think Mr. Mayne will start. 12 CHAIR NAHUINA: Well -- 13 MS. NOMURA: Oh, I'm sorry. 14 MR. MUKAI: Just very briefly. 15 We believe that the process was conducted 16 fairly. Recruitment is open -- 17 MS. NOMURA: I'm sorry to interrupt, but is 18 it possible for -- I think we're -- it's just a 19 continuation of what I -- 20 CHAIR NAHUINA: Of your opening statement? 21 MS. NOMURA: Yes. Or -- I'm sorry. Maybe 22 I'm -- I'm wrong. Not -- 23 CHAIR NAHUINA: Go ahead. 24 MR. MUKAI: We believe the evidence will show 25 that the process was fair and impartial and that the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 30 1 selection of the individual was proper under the 2 circumstances. In fact, we would submit that the 3 person most qualified for the position was, in fact, 4 awarded the position. And we believe, through the 5 evidence, the documentary evidence and testimony, that 6 the selection of the person was fair, impartial, and 7 done pursuant to the Merit Principles under HRS 76-1. 8 CHAIR NAHUINA: Thank you. I appreciate 9 your opening statements. 10 At this time, I would like to -- the strict 11 Rules of Evidence will not apply in this hearing. 12 However, the Board requests all parties confine 13 themselves to the matters connected with today's 14 hearing and the issues before the Board. If witnesses 15 are used, the opposite parties will be allowed to 16 cross-examine the witness. Members of the Board may 17 also question the witness after the witness's 18 testimony. 19 Are there any questions? Okay. If not, we 20 shall begin. 21 The Appellants shall present your case. 22 MS. NOMURA: Thank you so much. We will 23 start with Mr. -- 24 MR. MAYNE: Mayne. Kelly Mayne. 25 MS. NOMURA: Thank you very much. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 31 1 CHAIR NAHUINA: Mr. Mayne. 2 3 DIRECT EXAMINATION 4 MR. MAYNE: Good morning. I'm here today to 5 question the recruitment and examination process -- 6 MR. HALVORSON: Before you -- 7 CHAIR NAHUINA: Excuse me. 8 MR. MAYNE: Yes, sir. 9 MR. HALVORSON: You need to be sworn in. 10 MR. MAYNE: Ah. 11 CHAIR NAHUINA: I'm sorry. 12 13 KELLY MAYNE, 14 having been first duly sworn to tell the truth, the 15 whole truth and nothing but the truth, was examined and 16 testified as follows: 17 18 CHAIR NAHUINA: Thank you. 19 MR. MAYNE: Thank you. 20 I'm here today to question the recruitment 21 and examination process used by the Office of the 22 Prosecuting Attorney to fill the vacancy for the 23 Investigator VI position, No. 02985. The Investigator 24 VI position should have been filled through the 25 internal recruitment process. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 32 1 The law enforcement investigator job series 2 has extremely limited career advancement opportunities 3 in the civil service system throughout the State of 4 Hawai ʻ i. Rather than fostering promotion from within 5 pursuant to the Merit Principle, the Office of the 6 Prosecuting Attorney conducted an open external 7 recruitment. 8 On March 1st, 2017, the Investigator VI 9 position became vacant following the retirement of a 10 long-tenured County employee. At the time, some of the 11 my co-workers and myself, who were all qualified 12 potential internal applicants, expressed interest in 13 applying for the position. 14 In May 2017, the Office of the Prosecuting 15 Attorney used an external vacancy announcement to 16 recruit for the vacancy, and on June 27, 2017, I 17 interviewed for the vacancy. On July 11th, 2017, 18 Prosecuting Attorney Mitch Roth informed me by 19 telephone that I was not selected for the position. 20 I, subsequently, submitted an internal 21 complaint expressing my concerns regarding the 22 recruitment and examination process to Mr. Roth. My 23 complaint raised the following concerns: The 24 composition of the selected panel, violating the Office 25 of the Prostituting Attorney's interview and selection ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 33 1 procedures for civil service positions policy in many 2 ways. 3 One of the selection panelists, Investigator 4 Patricia Breault's -- job classification was not equal 5 to or higher than the Investigator VI position being 6 filled. This violated the policy's Section 3, 7 "Guidelines for Selection of the Panel," at 8 subparagraph c. Also, the use of two non-departmental 9 employees on the panel, Mr. Adams and Mr. Weber, 10 violated the policy's Section 3 "Guidelines for 11 Selection of the Panel" at subparagraph b. 12 A number of the interview questions that were 13 used related to a specific single reference source. 14 The Policy's Section 3, "Guidelines for Developing 15 Interview Questions and/or Assessment Exercises" of 16 paragraph b, directs that the interview questions be 17 designed to elicit information regarding the 18 applicant's suitability for the position rather than 19 their technical knowledge. 20 The internal complaint recruitment and 21 selection process also violated the Merit Principle as 22 defined by the Hawai ʻ i Revised Statutes as well as the 23 Office of the Prosecuting Attorney's interview and 24 selection procedures for civil service policy. The 25 Merit Principle, in part, states the Merit Principle is ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 34 1 the selection of persons based on their fitness and 2 ability for public employment and the retention of 3 employee based on their demonstrated appropriate 4 conduct and productive performance. It's the purpose 5 of this chapter to build career service in government 6 free from coercive political influences and to render 7 impartial service to the public at all times. The 8 Merit Principle further provides that it's the clear 9 policy of the State that the Human Resources within 10 each jurisdiction provide incentives for competent 11 employees, whether they be financial or promotional 12 opportunities, that encourage continuous improvement to 13 achieve superior performance. 14 On July 26, 2017, I met with Mr. Roth and 15 received written rejection of my internal complaint. 16 Mr. Roth informed me verbally and in writing that the 17 composition of the interview panel had been presented 18 to and approved by the Hawai ʻ i County Department of 19 Human Resources. 20 I asked Mr. Roth why an internal recruitment 21 was not used to fill the Investigator VI vacancy. 22 Mr. Roth stated that an external recruitment was the 23 only way he could fill the position. I stated that 24 pursuant to the Office of the Prosecuting Attorney's 25 policy and the Department of Human Resources policy, he ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 35 1 could have conducted an internal departmental 2 recruitment or an internal county-wide recruitment. 3 Mr. Roth acknowledged that he could have conducted an 4 internal recruitment, but he stated he checked with the 5 Department of Human Resources and they approved the 6 external. 7 During my Step 1 internal complaint process, 8 I contacted my HGEA union agent, Ms. Moana Hokoana, to 9 seek advice. Ms. Hokoana revealed that she would file 10 a Step 1 grievance on my behalf. As part of the 11 grievance process, Ms. Hokoana requested information 12 from Mr. Roth. One of the documents provided by 13 Mr. Roth was the “Request to Fill” form that was 14 submitted by Office of Prosecuting Attorney Business 15 Manager Lee Lord through the Department of Human 16 Resources. This form bears handwritten notes made by 17 Human Resources Manager Gabriella Cabanas. 18 Ms. Cabanas' notes indicate that the justification for 19 selecting an open external recruitment was that there 20 was insufficient interest within the department for the 21 Investigator VI position. 22 Ms. Hokoana specifically asked for the reason 23 to have an external recruitment rather than an internal 24 recruitment with question 8 on the Step 1 grievance 25 dated July 26, 2017. Mr. Roth's response was ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 36 1 "Insufficient interest within the department for chief 2 investigator position." This assertion of a lack of 3 interest for the vacancy was clearly untrue. Mr. Roth 4 contradicted this assertion in his July 26, 2017 5 written response to my internal complaint wherein he 6 states part of his rationale for having an additional 7 non-departmental interview panelist was because he knew 8 that "several of the applicants were from the 9 department." 10 Ms. Hokoana also, specifically, inquired with 11 question No. 20 of the Step 1 grievance dated July 26, 12 2017 if the interview panel had been approved, why the 13 County of Hawai ʻ i Department of Human 14 Resources/Mr. Roth's written response to question 15 No. 20 was "No." Mr. Roth's response directly 16 contradicts the verbal and written responses he 17 provided me on July 26, 2017. Mr. Roth's written 18 response to my internal complaint states in regards to 19 Ms. -- to Investigator Breault, Mr. Adams' and 20 Mr. Weber's presence on the interview panel, "This 21 decision was then approved by the Department of Human 22 Resources prior to the interviews." 23 I've been in continuous government service 24 for over 34 years. I've been a Journeyman Investigator 25 V for over the last 20 years. Nearly one year of that ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 37 1 time I spent as a temporarily assigned Investigator VI 2 for a different agency. This is my first experience 3 with the internal complaint process or a grievance 4 process. I certainly hope that it's my last. I didn't 5 come here to debate my resume or promote any kind of 6 personal agenda. I came here to do the right thing. 7 The only remedy I have requested throughout this whole 8 affair is that an internal recruitment and selection 9 process be conducted in accordance with the Hawai ʻ i 10 Revised Statutes, the County of Hawai ʻ i, and Office of 11 the Prosecuting Attorney's policies. 12 I appreciate your time in listening to me 13 this morning and the time that you devote going through 14 all the information that's been presented for your 15 review. Thank you. 16 CHAIR NAHUINA: Thank you. 17 Cross? 18 19 CROSS EXAMINATION 20 BY MR. MUKAI: 21 Q. Mr. Mayne, my name is John Mukai. I just have 22 a few questions for you. 23 You would agree that the selection of the 24 person to be the Investigator VI at the Office of the 25 Prosecuting Attorney should be the most qualified ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 38 1 applicant? You would agree with me, right? 2 A. I believe that it should have been conducted 3 through an internal recruitment and that the qualified 4 applicants from within the office should have been 5 afforded an opportunity for that. 6 Q. Would you agree with me that the person who 7 is selected, whether it is an internal or open 8 recruitment, should be the best candidate for the 9 position? Would you agree with me? 10 A. Yes. 11 Q. Now, let me ask you a little bit about the 12 people on the interview panel. Do you know who Larry 13 Weber is? 14 A. Yes. 15 Q. Do you know that -- well, what is he? 16 A. He's a civilian. 17 Q. Would you agree that he has knowledge as a 18 Hawai ʻ i County Police Department officer? 19 A. I don't know him that well. I know that he's 20 a retired police officer -- yes. 21 Q. Would you be surprised to know that he headed 22 the Investigative Unit at the Hawai ʻ i County Police 23 Department? 24 A. No. 25 Q. Did you know that? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 39 1 A. I don't think so, but I'll accept that. 2 Q. What about Doug Adams? Do you know who that 3 is? 4 A. I met him at the interview. That's the only 5 time I met Mr. Adams. 6 Q. Would it surprise you that Mr. Adams was a 7 retired colonel of the Army? 8 A. (Shook head). 9 Q. Would it surprise you to know that Mr. Adams 10 was a member of the Ethics Board? 11 A. No. 12 Q. Did you know that? 13 A. No. 14 Q. Do you also know that Mr. Adams was an 15 attorney? 16 A. No. 17 Q. Now, you remember doing an interview, right? 18 A. Correct. 19 Q. And you were asked questions by the panel. 20 Is that correct? 21 A. That's correct. 22 Q. Do you know what your score was relative to 23 the other person or persons? 24 A. Absolutely. 25 Q. Were you No. 1? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 40 1 A. No. 2 Q. Were you No. 2? 3 A. No. 4 Q. Were you No. 3? 5 A. I was No. 8. That's too far down the line. 6 Q. The person selected was a sheriff's deputy at 7 Riverside County Sheriff's Department. Did you know 8 that? 9 A. No, I didn't know that. 10 Sir, that's not why I'm here. I have nothing 11 to say to the selectee. I'm here because I believe 12 that the process that we went through for this hiring 13 was inappropriate -- 14 MR. MUKAI: I will object as nonresponsive. 15 MR. MAYNE: Sir, may I complete -- 16 MR. MUKAI: It's nonresponsive. 17 CHAIR NAHUINA: Mr. Mayne, just answer the 18 questions that are asked, please, on cross examination. 19 MR. MAYNE: All right. Thank you. 20 BY MR. MUKAI: 21 Q. Would it surprise you to know that the 22 selectee from 1988 to 2014 was also a police sergeant 23 at the Colton County, California Police Department? 24 A. No. 25 Q. Did you know that? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 41 1 A. That I knew. 2 Q. Did you know that prior to this appointee 3 being appointed to the Investigator VI position, that 4 this person was also an investigator at the University 5 of Hawai ʻ i at Hilo? 6 A. Yes. 7 Q. Now, again, you would agree with me that the 8 Investigator VI position, it's important in the 9 prosecutor's office, correct? Hawai ʻ i County 10 Prosecutor's Office? 11 A. Yes. 12 Q. Wouldn't you agree with me, then, that the 13 person who was selected should be the best candidate of 14 applicants who were selected? 15 A. Sure. Yes. 16 MR. MUKAI: Okay. Thank you. 17 CHAIR NAHUINA: Thank you. 18 Would you like to redirect? 19 MS. NOMURA: Yeah. I'd like to ask Mr. Mayne 20 some questions. 21 MR. MAYNE: Sure. 22 23 REDIRECT EXAMINATION 24 BY MS. NOMURA: 25 Q. Kelly, given what Mr. Mukai has asked you -- ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 42 1 you know, he's talking about other qualifications that 2 you don't know anything about, or you really don't care 3 about as far as who was selected or -- I think our main 4 concern is the fact that there were some very serious 5 transgressions in the process of this whole 6 recruitment. 7 What I wanted to ask you, though, is that as 8 an investigator in the office, having worked there, you 9 see the importance of working in that office. There 10 are certain procedures, certain ways of handling cases, 11 that you would only know by working in your office. Is 12 that correct? 13 A. That's correct. You certainly would not 14 obtain that experience and that knowledge level within 15 Riverside County, California and -- or even at the 16 University of Hawai ʻ i for whatever short period of time 17 that he happened to be there prior. 18 Q. You have been in the office for how long now? 19 A. I have been in the office since 2005, so I've 20 been there 12 years. 21 Q. Okay. So, you have been through another 22 supervisor -- 23 A. Yes. 24 Q. -- before the current one? 25 A. Yes. That's correct. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 43 1 Q. Okay. And you do see how the job you do is 2 important to have that background before you go to that 3 supervisory level. I mean, you do know what the 4 supervisor does, obviously? You've worked with a 5 supervisor all this time? 6 A. Yes. Yes, that's correct. The judicial 7 circuits are all different throughout the State. My 8 prior employment had the opportunity to work in every 9 single judicial district within the State as well as in 10 the federal system. And every place is going to have 11 their own nuances and ways to do things that are going 12 to be unique to that situation. Locally here is no 13 different from that. 14 Q. You heard me say earlier that as a V, you 15 would have 87 percent of the knowledge and abilities 16 needed to do the VI level job. And I pulled that from 17 the job description -- from the class specs. on which 18 your job description is written. You're familiar with 19 your job description? 20 A. Yes. 21 Q. Have you ever had the employer tell you that 22 you're not doing your job -- 23 A. No. 24 Q. -- right? 25 Have you ever had a notice to improve because ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 44 1 you're not doing your job correctly? 2 A. No. 3 Q. You mentioned, I think, that you even did 4 temporary assignment to the higher level? 5 A. Yes. That's correct. I was with an 6 investigative agency. I was with the State. And that 7 was supervising a group of Investigator Vs. 8 Q. On a statewide basis? 9 A. On a statewide basis that were conducting 10 ongoing criminal investigations. 11 Q. And did the employer ever tell you that you 12 didn't do a good job then? 13 A. No. 14 Q. Okay. But the employer can tell you that? 15 They can tell you at any time that, "You know what? 16 You need to work on these areas because you're not 17 performing them correctly. You're not doing this 18 aspect of the investigator job correctly"? Isn't that 19 right? 20 A. That's correct. 21 Q. But that has never happened to you? 22 A. Correct. 23 MS. NOMURA: Okay. 24 CHAIR NAHUINA: Thank you. 25 MR. MUKAI: Briefly. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 45 1 RECROSS EXAMINATION 2 BY MR. MUKAI: 3 Q. Mr. Mayne, this was an open recruitment, 4 right? 5 A. Yes, sir. 6 Q. Now, you were offered the opportunity to 7 apply for this position. Is that correct? 8 A. Yes, sir. 9 Q. And Mr. Guzman was also given the opportunity 10 to apply for the position, correct? 11 A. Yes. 12 Q. Same thing with Mr. Pang; he was afforded an 13 opportunity to apply for the position, right? 14 A. I believe so. 15 Q. Now, did it restrict – did, somehow, this 16 restrict you or anyone else within the office from 17 applying for this position? Was there any restriction 18 on you applying for this position? 19 A. No. 20 Q. And, again, you would agree with me that the 21 most qualified person for the position should be 22 selected for the Investigator VI position, right? 23 A. You've asked that. Yes, sir. 24 MR. MUKAI: Thank you. Okay. 25 CHAIR NAHUINA: Thank you. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 46 1 At this time, I would like to ask if the 2 Board has any questions. 3 MR. HALVORSON: No. 4 MS. NAMAHOE: No, but thank you. 5 MR. CHILLINGWORTH: No questions. 6 CHAIR NAHUINA: I have no questions. So, 7 you can proceed with the next witness. 8 MS. NOMURA: Our next witness is Mr. Daniel 9 Pang. 10 CHAIR NAHUINA: Daniel, I'm going to swear 11 you in. 12 MS. NAMAHOE: Wait, wait, wait. I do have 13 one question before we go to Mr. Pang. Sorry. Beg 14 your pardon. Sorry. 15 16 EXAMINATION 17 BY MS. NAMAHOE: 18 Q. Sir, have you ever done supervisory work for 19 the government? 20 A. Yes, I have. 21 Q. So, you have -- only because when I hear about 22 83 and 87 percent, have you ever done the 23 supervisory -- in your resume, do you have supervisory 24 work that would be equivalent to what would be expected 25 out of someone who would be supervising this particular ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 47 1 department? 2 A. Yes. Absolutely. And in the documentation 3 that I provided to you, I have my employment records 4 from my previous agency that documented every time- 5 frame when I was assigned as an Investigator VI, which 6 is the equivalent of this position I'm talking about. 7 MS. NAMAHOE: Thank you. No further 8 questions. 9 CHAIR NAHUINA: Thank you. 10 Would you like to redirect anything based on 11 the question? 12 MS. NOMURA: Not based on that. 13 MR. MUKAI: No. 14 CHAIR NAHUINA: Okay. Thank you. 15 At this time, we will move on, then, with the 16 next witness. And I'm going to swear you in. 17 18 DANIEL PANG, 19 having been first duly sworn to tell the truth, the 20 whole truth and nothing but the truth, was examined and 21 testified as follows: 22 23 DIRECT EXAMINATION 24 MR. PANG: Aloha, everybody. My name is 25 Daniel Pang. I'm an Investigator with the Office of ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 48 1 the Prosecuting Attorney. Short background: I've been 2 11 years with the Department of Public Safety, five in 3 Corrections, six with the Deputy Sheriff, and been 4 employed since May 2015 for the Prosecutor's Office. 5 First off, I want to just say like I'm not 6 here to rant or complain about who got the job or 7 anything. I'm just here about -- I'm just here about 8 the process not being fair and equitable. After 9 working for the State for a total of 14 years this 10 month, I know that if I didn't come forward today, 11 other County employees would not be treated fairly in 12 the future. 13 I submitted to you guys the written documents 14 and the stuff that -- why I thought it was possibly 15 unfair. And you'll notice a lot of documents were 16 signed by administrators and managers to ensure the 17 process would be followed. So, I guess the first thing 18 that was kind of strange to me in this process was it 19 was an external posting; but if you look back at our 20 office, like we always had internal postings, including 21 supervisors' positions, you know, like -- we even had 22 like the IT guy -- the special projects manager is the 23 one that come off the top of my head. All internal 24 recruitment, even though there was only one guy 25 applying was internal. So, that kind of was strange to ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 49 1 me at first. 2 And then, you know, got the letter from -- on 3 May 2nd -- the Request to Fill form stating 4 insufficient interest within the department for chief 5 investigator for the department, you know, initialed by 6 HMC, then just signed for business manager. And that's 7 what they submitted to you guys. You know, for me, 8 like how did they know like nobody would have interest? 9 Nobody ever -- for me, personally, nobody ever asked me 10 if I was interested or not. And I know there was a few 11 of my co-workers that, you know, submitted letters of 12 intent; so, there was interest within the -- just our 13 office. 14 And as for the six, ended up having four -- 15 four of us qualifying. And, you know, like the letter 16 said, the letter -- Request to Fill, it said there was 17 no interest, but we had four applicants, so kind of 18 want to use discrepancy, huh? We went from nobody 19 wanting it to four guys being qualified, so... 20 The second, I don't have a problem with the 21 panel. Just, you know, had four people. And according 22 to the policy, you know, the one dated December 29th, 23 2016, Interview and Selection Procedures for Civil 24 Service Positions, page 3, Section f, "One member may 25 be from outside the department who is knowledgeable ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 50 1 about the position," but there was two guys. There's 2 no doubt about their -- I mean, like Mr. Mukai said, 3 where they work. I have no doubt with that, but, you 4 know, more than two is -- just one, and you have two, 5 that's a big difference. 6 Then on page 6 under the selections -- the 7 guidelines for the selections of the panelists, you 8 know, section b -- a, about the panel, the number of 9 panel members may vary. One panel member may be from 10 other than the department, either internal, external, 11 or (unintelligible); so, I mean, had two guys. You 12 know, can do the math, so... 13 And then my notice of internal complaint 14 filed July 28, 2017, you guys have. The letter -- the 15 letter states the reasons the office violated the 16 policy was because there were several internal 17 applicants, so -- it also states the violation of the 18 policy was approved by Human Resources; however, that 19 is a false statement, because in the other documents 20 you guys had before stated it wasn't approved. And for 21 me, I was kind of wondering like does HR have the 22 approval to just say, "Oh, hey, you can break the 23 policy. That's all right." So, some questions I had. 24 And, if they did, who did they speak to? And if that 25 approval wasn't right, therefore, you can break the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 51 1 policy. It's cool. 2 In closing, I'd like to thank you guys for 3 your guys' time for listen to my statement. You know, 4 I love my job as a prosecuting attorney, and I enjoy 5 serving the community and the County of Hawai ʻ i. I'm 6 not here only for myself, but for all the Hawai ʻ i County 7 employees, to ensure that we have a fair and equitable 8 process. After -- I hope after today we can move 9 on -- move forward in a better and a more positive 10 direction for the County. 11 And I'm asking that, you know, at the end, 12 that this panel redo the hiring process, that we are 13 given a fair and honest chance, that the position 14 should have been open internally to the four of us that 15 applied internally in the beginning, and that we should 16 have -- be given a fair panel that -- provided by the 17 County hiring policies. Thank you, guys. 18 MR. MUKAI: I have a couple questions. 19 20 CROSS EXAMINATION 21 BY MR. MUKAI: 22 Q. Mr. Pang, how long have you been at the 23 Office of the Prosecuting Attorney? 24 A. May 1, 2015. 25 Q. So, two years? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 52 1 A. Yeah. Two-and-a-half, two-and- 2 three-quarters. 3 Q. When you say, well, it's always been 4 external -- or internal posting within the department, 5 that's your experience with two years at the 6 Prosecuting Attorney? 7 A. Well, the last couple promotions for the -- 8 like the special projects and the manager and the IT 9 guy, yeah, was internal. I mean, that's what they said 10 when they get the bulletin, like, "Oh," you know, "good 11 news. So-and-so been elected from the internal 12 recruitment process." That's been my experience that I 13 have so far. 14 Q. So, your experience with the prosecutors is 15 only two years. Is that right? 16 A. Yeah. I mean, over two years. Two-and-a- 17 half years. 18 Q. Two-and-a-half. 19 Now, again, because this was an open 20 recruitment, you could apply, right? You applied? 21 A. Yeah. 22 Q. And there was nothing restricting you from 23 applying, correct? 24 A. No. 25 Q. And you would agree, again, that the best ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 53 1 person for the Investigator VI position should be 2 selected for the position -- fair? 3 A. I don't think that ever came up in my -- in 4 my complaint or my grievance. Wasn't about who was 5 hired. It was about the -- from the beginning, to hit 6 the interview room, way before the four guys wen' 7 question us, I mean, that's the thing I had was like -- 8 I mean, yeah, you knew it was hard no matter what, but 9 from the time that thing wen' post to the time we hit 10 the interview room, that was all wrong already. 11 Q. Well, let me ask you this. When you talk 12 about the interview, do you know where you scored? 13 A. Yeah, probably on the bottom, but I never 14 disputed my scores. I never did come here to say like 15 that. I never did say I deserve the job or I'm 16 complaining who got the job. Yeah, the guy who got the 17 job, he one good brother, but the point is -- my whole 18 thing is from the beginning, when the thing first 19 supposed to be internal to we at the interview, before 20 the first question was even asked, there was a lot of 21 things that was kind of fishy and strange already. So, 22 that was just -- that was -- that's my -- my questions 23 I had. Wasn't about who got the job or what I wen' 24 score, because I not going sit here and puff my 25 chest -- "Hey, brah, I need the job." ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 54 1 Q. Did you tell your union about that? 2 A. I try go through internal complaint 3 because -- 4 Q. No. When you applied for this Investigator 5 VI position, what was your position at the Prosecuting 6 Attorney's Office? 7 A. Investigator IV. 8 Q. You would agree that you went -- if you were 9 selected, it would be a promotion. Is that fair? 10 A. Yeah, probably. 11 Q. Okay. 12 A. From IV to VI, yeah. 13 Q. Okay. 14 MR. MUKAI: If I may ask Mr. Mayne just that 15 one question for the record. 16 CHAIR NAHUINA: Yes. 17 MR. MUKAI: Mr. Mayne, you were an 18 Investigator V. Is that correct? 19 MR. MAYNE: I am Investigator V -- yes. 20 MR. MUKAI: And when you applied for the 21 position of Investigator VI, would that be a promotion 22 for you? 23 Would that be a promotion for you? 24 MR. MAYNE: Yes. 25 MR. MUKAI: And you are an HGEA Bargaining ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 55 1 Unit 13 member. Is that fair? 2 MR. MAYNE: Yes. 3 MR. MUKAI: And were you at the time you 4 applied for the promotion? 5 MR. MAYNE: What is your question, sir? 6 MR. MUKAI: Were you a HGEA Bargaining Unit 7 13 member at the time you applied for the promotion to 8 an Investigator VI position? 9 MR. MAYNE: Yes, sir, I was. 10 MR. MUKAI: And you are currently a 11 Bargaining Unit member of the HGEA Unit 13. Is that 12 correct? 13 MR. MAYNE: Yes, sir. 14 MR. MUKAI: Okay, thank you. 15 BY MR. MUKAI: 16 Q. Mr. Pang, one more question. At the time you 17 applied for this promotion to the Investigator VI 18 position, would you agree with me that you were a 19 member of the Bargaining Unit -- HGEA Unit 13 -- 20 Bargaining Unit 13 member? 21 A. Yeah. 22 Q. And you're still an HGEA Bargaining Unit 13 23 member, correct? 24 A. (Nodded). 25 Q. And based upon your testimony that as an ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 56 1 Investigator IV, the Investigator VI position at the 2 Prosecuting Attorney's Office would be a promotion. Is 3 that fair? Is that true? For you? 4 A. For me? 5 Q. Yes. 6 A. Yeah. 7 MR. MUKAI: Okay. Thank you. I have nothing 8 further. 9 CHAIR NAHUINA: Thank you. 10 Would you like to re... 11 12 REDIRECT EXAMINATION 13 BY MS. NOMURA: 14 Q. So, Daniel, I think when you went through the 15 interview process, there were, you said, already things 16 that were fishy to you. As far as the questions that 17 were asked, did it get to -- any of them actually 18 address your experience as an investigator in the 19 Prosecuting Attorney's Office? Because I talked 20 previously about -- 21 A. Yeah. 22 Q. -- your having 83 percent of the knowledge 23 and abilities required -- 24 A. You know what they asked about the office? 25 If the questioning attorney comes to you and says, "I ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 57 1 need this -- this copy right now, what you going to 2 do?" That's the only -- what I can remember off the 3 top of my head was like the only question pertaining to 4 that was. "If you get someone come to you, 'Hey, I 5 need this copied right now,' as a supervisor, what you 6 going do?" That was the question that I remember being 7 the only thing about what we do. 8 Q. Okay. And as we said, you're Investigator 9 IV, and you applied for the Investigator VI because you 10 met the minimum qualification requirements, right? 11 Obviously -- 12 A. Yes. 13 Q. -- because you were part of the -- 14 A. Yes. 15 Q. -- applicant pool. 16 A. Yes, I met the qualifications. 17 Q. Right. 18 A. I mean, I not here for -- 19 Q. Right. 20 A. -- to debate what he saying, who got the job 21 or the qualifications. It's just about, from the 22 beginning to hit the door was already -- I mean, if you 23 read the letter from my -- the letter I'm referring to, 24 they know already. The office knew they were breaking 25 those two things you mentioned but, then -- yet -- ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 58 1 Q. "Those two mentioned" meaning the internal -- 2 they didn't go internal? 3 A. Yeah. And they said -- they referenced that 4 Human Resources wen' approve. So, my only question was, 5 well, who did 'em? Who -- who in HR wen' approve 'em? 6 And do they have that authority to grant that wish? 7 And if they was, was it in writing? Like, you know, if 8 they say like, "Oh, man over here wen' say can," and 9 poof, that's it, we're done," you know, it's kind of 10 like just stuff that I -- questions I had. 11 Q. Can I ask you to -- I think you referenced 12 the audit report that came out about hiring practices 13 in the County. 14 A. Yeah. 15 Q. Did that come to mind that this was kind of 16 like -- 17 A. Yeah. 18 Q. -- the same thing? 19 A. Yeah, it's kind of. You know, I mean, as I 20 say, with the internal, if you look back, that audit -- 21 you know, the only thing they get at was a lot of 'em 22 was internal. Went straight internal. And cannot 23 prove only had one. A couple of them I know only had 24 one, because I asked the guy, but, I mean, we get -- we 25 had four guys and we went external, but sometimes you ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 59 1 got one guy and two guys and you go internal. You 2 know, to me, if you -- I mean, I not the smartest guy 3 in the room, but if you -- you can kind of figure out 4 who you looking for. 5 Q. And, Daniel, you know, you said you were 6 there from 2015, and that's two-and-a-half years. In 7 that time, did your supervisor or maybe the prosecutor 8 ever tell you that "You know what? You're not 9 performing at the level you should be, so you're not 10 doing this part of the job that you should be doing?" 11 A. Oh, no. I got praises because I'm taking on 12 more work and going outside of -- you know, we doing 13 more -- more proactive investigative work; so, it was 14 more like we getting one compliment, not just, "Hey, 15 good job." It was, "Hey, thank you for helping out and 16 doing more." 17 Q. And your conduct was never in question. You 18 never had a disciplinary action or -- 19 A. No. 20 Q. -- any kind of charge of violating a policy 21 or anything like that? 22 A. No. 23 Q. Okay. Did you feel like, then, this was kind 24 of -- this whole recruitment process was kind of a 25 shibai? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 60 1 A. It could be. I mean, you know, I not going 2 blame -- I not going accuse nobody of nothing but, you 3 know, you add and subtract already and look at the 4 past -- you know, past practices what the County does. 5 I mean, I not going blame anybody because I cannot read 6 their mind, cannot prove that but, you know, it looks 7 like a duck, quacks like a duck, you can kind of make 8 that assumption. 9 CHAIR NAHUINA: Thank you. 10 MR. MUKAI: I have a couple more questions, 11 Mr. Pang. 12 13 RECROSS EXAMINATION 14 BY MR. MUKAI: 15 Q. Do you know who Doug Adams is? 16 A. On the panel. 17 Q. Do you know that he's a member of the Ethics 18 Board? 19 A. I never disagreed on anybody's 20 qualifications. 21 Q. I understand. 22 Okay. Now -- 23 A. I don't think I would ever like question my 24 score, like, "Hey, the thing too old" or "This guy not 25 qualified." I never did say that or implicate that. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 61 1 It was just about the process, about from open 2 recruitment, the letter signed, intent to fill, the 3 people who walk in the door, the letter for denial 4 was -- we know had more guys, which we never have, and 5 we supposed to only have one; we get two. Just stuff 6 like that. I was just, you know, concerned. 7 Q. Mr. Pang, is it against the law for Mr. Roth 8 or the prosecutor to have a open recruitment for the 9 Investigator VI position? 10 A. Well, I don't know the law, if that... 11 Q. Again, you would agree that the person to be 12 selected into the Investigator VI position should be 13 the most qualified, right? 14 A. I don't think I ever questioned that; but 15 yeah, you want the best always. 16 Q. You also mentioned that you're challenging 17 the process, correct? Do you remember testifying to 18 that? 19 A. Yeah. 20 Q. And, again, we go back to you being a 21 Bargaining Unit 13 member, correct? 22 A. Yeah. 23 Q. As an Investigator V -- 24 A. IV. 25 Q. IV. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 62 1 A. IV. 2 Q. -- to be selected into the Investigator VI 3 position would be a promotion, correct? For you? 4 A. I think I answered that one. Yeah. 5 MR. MUKAI: Okay, thank you. I have no... 6 CHAIR NAHUINA: Would you like to 7 redirect? 8 MS. NOMURA: No. I think it's fairly... 9 CHAIR NAHUINA: Thank you. 10 Any of the Board Members have any questions? 11 MR. TAM: None. 12 MS. NAMAHOE: Thank you. 13 MR. CHILLINGWORTH: No questions. 14 MR. HALVORSON: No questions. 15 MS. NOMURA: And, last but not least, we have 16 Mr. Guzman, who is going to present his statement. 17 CHAIR NAHUINA: Mr. Guzman. 18 19 CLEMENT GUZMAN, 20 having been first duly sworn to tell the truth, the 21 whole truth and nothing but the truth, was examined and 22 testified as follows: 23 24 DIRECT EXAMINATION 25 MR. GUZMAN: My name is Clement Guzman. I'm ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 63 1 currently employed as a Investigator V in the Hawai ʻ i 2 County Office of the Prosecuting Attorney. 3 On May 14, 2017, a vacancy for the position 4 of chief investigator was announced, and I subsequently 5 applied for the position. At the time of my 6 application, I possessed nearly 27 years of experience 7 within the State and County of Hawai ʻ i, including 18 8 years of supervisory, managerial, and administrative 9 experience with the State of Hawai ʻ i Department of 10 Public Safety. At the time of my application, I had 11 been employed with the Office of the Prosecuting 12 Attorney for nearly six-and-a-half years, having worked 13 effectively in both the Kona and Hilo offices. 14 At the time of my application, I had been 15 working as an Investigator V, the grade right below the 16 Investigator VI position I was applying for, for over 17 five years. Throughout those five years as an 18 Investigator V, I consistently received favorable 19 performance evaluations, and there was never any 20 expression from management in any area in need of 21 improvement or anything that would suggest 22 unsuitability for advancement to the Investigator VI 23 position. 24 Throughout my career with both the State and 25 County, I cultivated invaluable relationships with ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 64 1 various law enforcement, judicial, social service, 2 labor, and other related agencies throughout the State 3 that are critical to the performance of the duties of 4 the Investigator VI. 5 On June 27th, 2017, I was interviewed for the 6 vacant Investigator VI position. The interview panel 7 consisted of the following individuals: Investigator V 8 Patricia Breault, Victim Witness Program Director 9 Deborah Chai, Mr. Lawrence Weber, and Mr. Douglas 10 Adams. The composition of the interview panel was in 11 violation of the Office of Prosecuting Attorney 12 interview selection procedures for civil service 13 position on the following points: Patricia Breault's 14 Investigator V job classification was not equal to or 15 higher than the Investigator VI position being filled 16 as is required by the interview procedures. Two 17 non-departmental employees, Lawrence Weber and Douglas 18 Adams, were on the interview panel when the procedures 19 allow for only one member to be from outside the 20 department. 21 In addition to the violations concerning the 22 composition of the interview panel, three of the 23 interview questions referred to a specific source, a 24 Gilbert Investigation Manual, that is not generally 25 provided to candidates. The Office of the Prosecuting ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 65 1 Attorney interview and selection procedures for civil 2 service positions guidelines for developing interview 3 questions and/or assessment exercises states that 4 questions should be designed to elicit qualities other 5 than technical knowledge. The questions regarding the 6 Gilbert source suggested inquiry into something that 7 goes far beyond technical knowledge. 8 Hawai ʻ i Revised Statutes Chapter 76-1, Merit 9 Principle, provides for the selection of persons based 10 upon their fitness and ability for public employment 11 and for the retention of employees based on their 12 demonstrated appropriate conduct and productive 13 performance. It was also the purpose of the chapter to 14 build career service in government free from coercive 15 political influences. 16 The chapter provides that in order to achieve 17 these purposes, it is the clear policy of the State 18 that the Human Resources program within each 19 jurisdiction be administered in accordance with the 20 following -- which I'm going to try to skim over 21 because I believe Mr. Mayne already addressed this -- 22 equal opportunity for all in compliance with laws 23 prohibiting discrimination. Impartial selection of 24 individuals for public service, incentives for 25 competent employees within the service, and reasonable ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 66 1 job security for competent employees. 2 The filling of the vacant Investigator 3 VI Chief Investigator position within the Office of the 4 Prosecuting Attorney should have been an internal 5 recruitment. However, an open recruitment was 6 conducted, and the candidate selected came from an 7 outside jurisdiction. Rather than considering 8 promotion -- promoting from within the department, the 9 Office of the Prosecuting Attorney chose to go beyond 10 the jurisdiction of the County of Hawai ʻ i to make its 11 selection. 12 It is my understanding that the reason for 13 having an open competitive recruitment was based on 14 information that the Office of the Prosecuting Attorney 15 provided to the Department of Human Resources, stating 16 that there was insufficient interest within the 17 department for the Investigator VI position. As has 18 been mentioned before, that is a direct quote from the 19 Department of Human Resources request to fill form for 20 the Investigator VI position under the justification 21 for the open competitive recruitment option. 22 Contrary to what was represented to the 23 Department of Human Resources by the Office of the 24 Prosecuting Attorney, on March 8th, 2017, more than two 25 months prior to the May 14th, 2017 opening date for ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 67 1 applications for the Investigator VI position, I 2 submitted a letter of intent to Prosecuting Attorney 3 Mitchell Roth and First Deputy Prosecuting Attorney 4 Dale Ross stating my intent to apply for the vacant 5 position and noting my aforementioned extensive 6 qualifications for the position. I'm also aware that 7 Investigator V Kelly Mayne here, present today, and 8 Investigator Breault, who subsequently chose not to 9 apply and ended up being placed on the interview panel 10 to choose the Investigator VI, her supervisor, also 11 submitted letters of intent to apply for the position. 12 Clearly, the assertion by the Office of the 13 Prosecuting Attorney that there was insufficient 14 interest within the department for the vacant position 15 was a false assertion and rather was meant to 16 facilitate the department's endeavor to exclude the 17 qualified individuals within the Office of the 18 Prosecuting Attorney in favor of a person of interest 19 hire from outside the jurisdiction. 20 In the course of the appeal of this matter, 21 other issues have been discovered. On July 25th, 2017, 22 I received a written notification from Office of the 23 Prosecuting Attorney Business Manager Lee Lord stating 24 that he had been assigned to conduct an investigation 25 into my Step 1 appeal of this matter. One day later, ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 68 1 in a meeting with Mr. Roth, I received his written 2 response to my Step 1 appeal. And on July 27, 2017, I 3 made a follow-up request to Mr. Roth wherein I 4 requested, amongst other things, a copy of Mr. Lord's 5 written investigation report. 6 August 2nd, 2017, Mr. Roth responded, "It 7 wasn't a formal investigation. Mr. Lord did not give 8 me a formal report. I received information verbally 9 from him. That was all included in my response to your 10 internal complaint." This clearly indicates that the 11 Office of the Prosecuting Attorney administration 12 failed to properly consider and respond to my appeal; 13 and absent -- a written investigative report from 14 Mr. Lord, one is left wondering what exactly Mr. Lord, 15 if anything, did in the 24 hours or less time lapsed 16 between my receipt of the written notification of the 17 investigation and my receipt of Mr. Roth's written 18 response to my appeal which, in Mr. Roth's own words, 19 relied on verbal information given to him by Mr. Lord 20 from his so-called investigation. 21 Secondly, in his response to my Step 1 22 appeal, Mr. Roth, in attempting to justify Investigator 23 Breault's presence on the interview panel and the extra 24 non-departmental employee's presence on interview panel 25 states that both of those matters were approved by the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 69 1 Department of Human Resources. 2 First, approval to violate procedures does 3 not justify violating the procedures. The decision to 4 go ahead and violate the procedures lies solely with 5 Mr. Roth, and a decision to violate the procedures 6 cannot be justified by citing some alleged approval to 7 do so. 8 Furthermore, as has been mentioned before, 9 I'm aware that when a request for information was made 10 on Investigator Mayne's behalf, the Department of Human 11 Resources, asking for verification of the approval 12 given to violate the procedures, the response given was 13 that no approval had been given. 14 Thirdly, on August 8th, 2017, I had a meeting 15 with Deputy Managing Director Barbara Kossow regarding 16 my Step 2 appeal of this matter. During the meeting, 17 she showed me a copy of a document showing the scores 18 of all the candidates interviewed for the vacant 19 Investigator VI position. All names were redacted with 20 the exception of Alan Koaho, the selected candidate, 21 myself, and Investigator Mayne, and Investigator IV -- 22 Daniel Pang -- who is also here present with me. 23 Upon viewing the scores, I noted to 24 Ms. Kossow that the unidentified top score scored 34 25 points higher than Mr. Koaho. A recommendation ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 70 1 memorandum to Mr. Roth and Mr. Ross dated July 1st -- 2 sorry, July 11th, 2017 -- from Ms. Chai, the 3 chairperson of the interview panel, on behalf of the 4 interview panel, recommends Mr. Koaho based on personal 5 references contained in a background investigation 6 while failing to provide any justification for not 7 recommending the top-scoring candidate; and while such 8 justification may not be specifically required, the 9 failure to provide justification for not choosing 10 someone who scored 34 points more than the selected 11 candidate clearly hints at impropriety. 12 Finally, also on July 11, 2017 -- I'm sorry. 13 Also, in the July 11, 2017 recommendation memorandum to 14 Mr. Roth and Mr. Ross, Ms. Chai, on behalf of the 15 interview panel, stated that the panel made a unanimous 16 decision to recommend Mr. Koaho for the position. On 17 the following date, in an Investigations Unit meeting 18 conducted by Investigator Breault -- acting as a 19 temporary assigned Investigator VI -- Investigator 20 Breault verbally stated that she was not in favor of 21 recommending Mr. Koaho for the position. Investigator 22 Breault's statement was witnessed by all Investigations 23 Unit staff members present at that meeting, both in 24 person at the Hilo office and in the Kona office via 25 videoconference. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 71 1 I again note that the recommendation 2 memorandum was written by Ms. Chai and, therefore, the 3 characterization of Mr. Koaho's recommendation as being 4 unanimous is her characterization; however, 5 Investigator Breault's statement that she was not in 6 favor of recommending Mr. Koaho clearly shows that the 7 recommendation was not unanimous. Even further, after 8 stating that she was not in favor of Mr. Koaho's 9 recommendation, all Investigator Breault could say on 10 behalf of Mr. Koaho was that he was personable. 11 Personable, not qualified and certainly not competent, 12 as incompetence has been the overriding theme of 13 Mr. Koaho's time as the chief investigator. So, when 14 Mr. Mukai brings up the subjects of the most qualified 15 candidate being selected, I think we really have to 16 look at who really was qualified. 17 In conclusion, it is abundantly clear that 18 the recruitment and selection for vacant Investigator 19 VI Chief Investigator position within the Office of the 20 Prosecuting Attorney was grossly flawed and 21 unjustifiably violated established policies and 22 procedures. The administration of the Office of the 23 Prosecuting Attorney clearly and deliberately 24 disregarded the Merit Principle and endeavored to 25 exclude highly qualified candidates within the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 72 1 department in favor of a person of interest hire from 2 outside the jurisdiction. 3 It is further clear that the administration 4 of the Office of the Prosecuting Attorney blatantly 5 engaged in dishonest practices in an attempt to justify 6 the flawed process and to achieving its shamefully 7 unethical goal. I am confident that this Merit Appeals 8 Board will see through the smoke screen of corruption 9 that the administration of the Office of the 10 Prosecuting Attorney has put up in this case and 11 rightfully reverse the improper recruitment and 12 selection process in this matter. 13 Thank you for your time here today. 14 15 CROSS EXAMINATION 16 BY MR. MUKAI: 17 Q. Okay, Mr. Guzman, my name is John Mukai. 18 A. Yes. 19 Q. I know we've met. 20 A. Yes. 21 Q. Now, you mentioned that the Merit Principle 22 should apply, correct? 23 A. That is my contention, yes. 24 Q. Okay. And you would agree that civil service 25 statutes should apply, correct? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 73 1 A. Yes. 2 Q. And with regard to your position at the time 3 you applied for the Investigator VI position, you were 4 an Investigator V. Is that correct? 5 A. That's correct. Yes. 6 Q. So, if you had received the Investigator VI 7 position, it would be a promotion in the Prosecuting 8 Attorney's Office, correct? 9 A. Yes, it would. 10 Q. Okay. Now, you also mentioned that you are 11 challenging the process, correct? 12 A. I'm alleging that it was improperly done, 13 yes. 14 Q. Again, civil service statutes, rules, 15 regulations, and procedures should apply, correct? 16 A. Yes. 17 Q. You are a member of the HGEA Bargaining Unit 18 13, correct? 19 A. Yes, I am. 20 Q. You were also a member of the HGEA Unit 13 21 Bargaining Unit at the time you applied for the 22 Investigator VI position, correct? 23 A. Yes, I was. 24 Q. And you are still a member of the HGEA Unit 25 13 Bargaining Unit. Is that correct? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 74 1 A. Yes, I am. 2 Q. In fact, you have HGEA representation here, 3 right, and behind you, fair? 4 correct. Yes. A. That is there anything illegal about having 5 Q. Now, is 6 an open recruitment for the Investigator VI position, 7 do you know? 8 A. No, there is nothing illegal. 9 Q. Now, you are also saying that there are 10 certain rules. Would it surprise you to say that these 11 certain rules and provisions that you cite would also 12 state "where applicable or appropriate"? 13 A. It would not surprise me, and I believe I'm 14 aware of that terminology, yes. 15 Q. Now, again, you were allowed the opportunity 16 for this promotion, correct? 17 A. Yes, I was. 18 Q. There's nothing that restricted you from 19 applying for the position of Investigator VI, which is 20 a promotion, correct? 21 A. No, there was not. 22 MR. MUKAI: Now, you know, I have to raise my 23 motion again. I think right now it is clear on the 24 record that for each of these members, they are covered 25 by the HGEA Unit 13 agreement governing promotions. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 75 1 It's clear on the record now, and I think anything 2 further might be improper and violative, potentially, 3 of HRS Chapter 89. So, again, I renew my motion to 4 dismiss. 5 CHAIR NAHUINA: Thank you. Are you done 6 with your cross examination? 7 MR. MUKAI: Yes. Yes. 8 CHAIR NAHUINA: You are done with your 9 cross examination? 10 MR. MUKAI: Yes. 11 CHAIR NAHUINA: Thank you. 12 Would you like to redirect? 13 MS. NOMURA: I think -- I think Mr. Guzman 14 and all of the -- all three Appellants -- 15 MR. CHILLINGWORTH: Sorry, I can't hear you. 16 MS. NOMURA: I'm sorry. I think Mr. Guzman 17 and all three of the Appellants did speak from the 18 heart as to what they believe happened. 19 20 REDIRECT EXAMINATION 21 BY MS. NOMURA: 22 Q. I guess my question, again, to Mr. Guzman is 23 did you feel that the interview process gave you credit 24 for the experience you had which, according to the 25 class specs., are so intertwined with the Investigator ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 76 1 VI? Did the interview process really get to that 2 experience and the qualifications you had as an 3 investigator in that office? 4 A. No. Absolutely not. 5 MS. NOMURA: Okay. That's all I have. Thank 6 you. 7 CHAIR NAHUINA: Thank you. 8 Mr. Mukai? 9 10 RECROSS EXAMINATION 11 BY MR. MUKAI: 12 Q. Mr. Guzman, you just stated just now again 13 that you believe the process was flawed, correct? 14 A. That's correct. 15 Q. Okay. And, again, for you, this would have 16 been a promotion, correct? 17 A. Yes. 18 MR. MUKAI: Okay. Thank you. I have nothing 19 further. 20 Again, I will once again raise -- I think the 21 record is absolutely clear right now. And I don't 22 think, based on Hawai ʻ i law, you can proceed, so I will 23 once again renew my motion to dismiss. 24 CHAIR NAHUINA: Thank you, Mr. Mukai. We 25 have already ruled on that motion. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 77 1 At this time, do you have any other witnesses 2 you would like to call? 3 MS. NOMURA: I would like to be able to speak 4 with -- is this going to happen? I don't know -- with 5 the prosecutor and -- are they being called as 6 witnesses? Are they going to be available to answer 7 questions? Because I think that's what's missing in 8 here. 9 CHAIR NAHUINA: Mr. Mukai, is it your plan 10 to -- 11 MR. MUKAI: I was going to put on several 12 witnesses on the County's behalf. 13 MS. NOMURA: Then we can wait with our 14 questions. 15 CHAIR NAHUINA: So, at this time, are you 16 resting? 17 MS. NOMURA: Yes. 18 MR. CHILLINGWORTH: Sorry, can I ask a 19 question? 20 CHAIR NAHUINA: Oh, yes. 21 22 EXAMINATION 23 BY MR. CHILLINGWORTH: 24 Q. We haven't established for the record 25 Mr. Guzman was not the top-ranked applicant in this ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 78 1 hiring process. 2 Can we clear that up, Mr. Guzman? 3 A. I was not, but I was highest ranked amongst 4 the internal applicants. 5 MR. CHILLINGWORTH: Okay. Thank you. 6 CHAIR NAHUINA: Any other questions? 7 MS. NAMAHOE: No, thank you. 8 MR. TAM: None. 9 CHAIR NAHUINA: And then, would you like 10 to redirect off of the question? 11 MS. NOMURA: No. 12 Again, I think the ranking of these 13 applicants individually, where they stood in this 14 process, again, we were not -- that wasn't our primary 15 focus. I think the focus was that it was so blatantly 16 unfair in every step of the way that we didn't see any 17 way that you could, you know, validate that this was 18 the best-selected candidate and that, given the breadth 19 of experience that all three of the Appellants had and 20 the question -- the basis of the interview -- I'm 21 sorry. 22 CHAIR NAHUINA: Thank you. I'm going to 23 mention this is not the time for argument here. 24 MS. NOMURA: Okay, sorry. 25 CHAIR NAHUINA: And I actually was amiss, ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 79 1 and I apologize. I should have asked Mr. Mukai if he 2 wanted to redirect off of the question by the Board. 3 MR. MUKAI: No. 4 CHAIR NAHUINA: Thank you. 5 I think this will be a nice time to go to 6 recess and maybe go to lunch. 11:27. 7 Can I entertain a motion for recess? 8 MR. MUKAI: How long? 9 CHAIR NAHUINA: I apologize. It's 11:30 10 now. 12:00? 12:15? 45 minutes? 11 MR. MUKAI: Can you make it 12:30? 12 CHAIR NAHUINA: Yes. 13 MR. MUKAI: Just for scheduling purposes, is 14 there any idea when the Board plans to adjourn for 15 today? 16 CHAIR NAHUINA: I don't know that we set a 17 time. I don't have... 18 MR. TAM: I don't have any time. 19 CHAIR NAHUINA: We've had meetings go 20 beyond 4:00. I can't speak to this one. Is that a 21 possibility for this Board? 22 MS. NAMAHOE: Well, I do need to catch a 23 plane this afternoon, so... 24 CHAIR NAHUINA: So, let's put a -- 25 MS. NAMAHOE: That we end by 3:30. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 80 1 CHAIR NAHUINA: So, 3:30 would be our time. 2 Okay. 3 MS. NAMAHOE: Thank you. 4 MR. TAM: I move that we go into recess. 5 CHAIR NAHUINA: Can I hear a second? 6 MS. NAMAHOE: Second. 7 CHAIR NAHUINA: It is moved and seconded 8 that we move into recess until 12:30. 9 All in favor say "Aye." 10 (All Board Members responded affirmatively.) 11 CHAIRMNAHUINA: Any opposed, same sign. 12 It is moved and seconded that we go into 13 recess. We will reconvene at 12:30. 14 (The hearing adjourned at 11:28 a.m.) 15 CHAIR NAHUINA: We're here to reconvene 16 the hearing. It is 12:35, and we will start off with 17 the County's presentation at this time. 18 MR. MUKAI: Thank you. We would call Mr. Lee 19 Lord as a witness. 20 21 LEE LORD, 22 having been first duly sworn to tell the truth, the 23 whole truth and nothing but the truth, was examined and 24 testified as follows: 25 ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 81 1 CHAIR NAHUINA: Thank you. Proceed. 2 MR. MUKAI: And for the Merit Appeals Board, 3 I will be referring to the County's exhibits which we 4 submitted previously to the witness for Mr. Lord and 5 Mr. Roth's testimony. 6 MR. CHILLINGWORTH: Mr. Mukai, can you ask 7 the witness to spell his last name, please. 8 9 DIRECT EXAMINATION 10 BY MR. MUKAI: 11 Q. Can you spell your last name, please? 12 A. Lord, L-o-r-d. 13 MR. CHILLINGWORTH: Thank you. 14 And I would ask that the court reporter swear 15 the witness. 16 MR. HALVORSON: The Chair did. 17 CHAIR NAHUINA: I've already sworn 18 Mr. Lord in. 19 MR. CHILLINGWORTH: Thank you. 20 BY MR. MUKAI: 21 Q. Mr. Lord? 22 A. Yes. 23 Q. What is your current position? 24 A. I'm the Business Manager for the Prosecutor's 25 Office in the County. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 82 1 Q. And how long have you held that position? 2 A. Since January of 2013. 3 Q. Can you describe for the Board what your 4 duties and responsibilities are at the Prosecuting 5 Attorney's Office. 6 A. I oversee and supervise the fiscal staff of 7 the prosecutor's office, the management information 8 staff, and the human resources clerk, and I direct -- I 9 don't supervise, but I direct Tammy, Mitch's private 10 secretary, in human resources duties also. 11 Q. Okay. Now, prior to your employment at the 12 Prosecuting Attorney's Office, what was your 13 occupation? What did you do? 14 A. My most previous position was as the division 15 manager for the County of Hawai ʻ i for Vehicle 16 Registration and Driver's Licensing. 17 Q. And, again, I guess, can you just briefly 18 describe for the Board what your duties were at the 19 County Motor Vehicle Registration. 20 A. I was there for five years, and I supervised 21 the supervisor of the motor vehicle registration, 22 driver's license, and periodic motor vehicle 23 inspections called safety checks; and I was 24 responsible for the fiscal, the human resources, and 25 the operations side. I, basically, did everything ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 83 1 that needed to be done -- or oversaw and supervised 2 everything that needed to be done as far as operations 3 and human resources. 4 Q. Now, can you take a look at County's Exhibit 5 1. 6 A. Yes. 7 MS. NAMAHOE: 17-04.01? 8 MR. MUKAI: Is that correct? I'm not sure. 9 It's Exhibit 1 to the County. 10 MS. YAMADA: On the tabs. 11 MR. MUKAI: That's correct, 17-04.06. 12 MS. NAMAHOE: 06. Thank you. 13 BY MR. MUKAI: 14 Q. Now, at some point in time, there was a 15 vacancy at the Prosecuting Attorney's Office for an 16 Investigator VI. Is that correct? 17 A. Correct. 18 Q. What happened? Why was there an opening? 19 A. Mr. Dean Sumida previously occupied the 20 position. He retired. 21 Q. Now, with regard to Exhibit 1, can you 22 describe for the Board what this document is. 23 A. The Investigator V, these are the Department 24 of -- County -- sorry -- Department of Human Resources 25 for the County Investigator V. We call them specs. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 84 1 They are the -- it's on the County website maintained 2 at the Human Resources Department. And, basically, it 3 describes for the Investigator VI position the duties, 4 the distinguishing characteristics, examples of duty, 5 minimum qualification requirements, including training 6 and experience, supervisory aptitude, qualification for 7 firearm, license requirement, knowledge of, ability to, 8 and the physical age requirements of the physical 9 effort grouping light. And we would use this to create 10 or revise our job descriptions for the specific 11 positions that we had at our office. And that's what 12 we use it for. 13 Q. Okay. So, basically, what Exhibit 1 is, just 14 describes what the Investigator VI position is. Is 15 that fair? 16 A. At the County, yes. But our job description 17 at our office focuses and revises it a little bit for 18 our office. 19 Q. Okay. Take a look at Exhibit 2. 20 A. This is our organizational chart. 21 CHAIR NAHUINA: Excuse me, Mr. Lord. I 22 don't mean to interrupt. I apologize. I'm going to 23 ask would you like to look at the documents? They are 24 in front of you. You can find them if you would like. 25 The exhibit is right after the green papers in there. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 85 1 MR. LORD: Thank you. 2 CHAIR NAHUINA: Of course. Thank you, 3 Mr. Lord. I apologize for interrupting. 4 MR. LORD: No problem. 5 This is our current -- I don't know if it had 6 been revised at that point in time. This is one of the 7 pages of our organizational chart showing the 8 investigators unit with the Investigator VI at the top, 9 showing that there's two areas, Hilo and Kona, with 10 Investigators IV and V supervised on both sides. This 11 is maintained by us, and then changes need to be 12 approved by the Department of Human Resources. 13 BY MR. MUKAI: 14 Q. Take a look at Exhibit 3. 15 A. Yes. This is our position description for a 16 specific position -- position number is in the top 17 right corner -- 02985, which is the position that was 18 interviewed for, and it describes basic information 19 about the position, where it's at, what the number is, 20 and the major duties and responsibilities, duties 21 summary, description of duties and responsibilities. 22 Last page is the minimum qualification requirements. 23 Once again, the supervisory aptitude, qualification for 24 firearms licenses, knowledge, abilities, physical 25 requirements. And then, the very last page describes ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 86 1 who this position supervises. 2 Q. Okay. Let me ask you, there's been some 3 testimony about certain applicants saying that, "Hey, 4 what about all my prior experience, my skills, and 5 abilities?" Do you have any comment about that? 6 A. When we make up the questions for the 7 interviews for the interview panel and the panel is 8 involved, we are trained by Human Resources to stick to 9 looking at skills, abilities, and experience. So, we 10 have to relate it back to our job description that we 11 have in our office so that our questions are geared 12 towards asking -- you know, are we asking about a 13 skill? Are we asking about ability? Are we asking 14 about experience? 15 Q. And would people have the ability to write 16 about their prior skills, abilities, and experience? 17 A. Yes. Whether it's an internal recruitment or 18 an external recruitment or an external recruitment 19 where people from internal also apply, they have to go 20 on our County website applicant application, and that's 21 where you fill out your previous experience, all your 22 skills, your education, all the information that you 23 want to share with the panel in writing. And then, 24 anyone is also welcome -- I think they can attach their 25 resume there or carry their resume to the interview ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 87 1 panel. 2 Q. Now, take a look at Exhibit 4. Can you 3 describe for the panel what that document is. 4 A. When a position becomes vacant, we, as a 5 Department, need to complete a Request to Fill form. 6 Tammy, Mitch's private secretary, completes this form 7 with the information that we provide to her. It gets 8 reviewed. The department head signs it. And we send 9 it to Human Resources to initiate the whole process of 10 hiring somebody. 11 Q. Now, I see that -- is that your signature at 12 the bottom of Exhibit 4? 13 A. Yes. I had permission in writing to sign for 14 Mr. Roth when he's unavailable. 15 Q. Okay. Now, and it says here -- this would be 16 an open competitive recruitment, right? Do you see 17 that? Right above your signature. 18 A. Yes. 19 Q. Okay. Now, there has been some reference to 20 this sentence regarding insufficient interest within 21 the department for chief investigator position. 22 What does that mean? What happened? 23 A. I know -- this was signed, I believe, by 24 Gabriella Cabanas -- Cabanas -- and my recollection at 25 the time was Gabriella called Tammy to ask why it was ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 88 1 an open recruitment at this point in time; and we 2 provided her the information that we had only received 3 two written requests to be considered by the time this 4 was being filled out. One was from Pat Breault, who 5 verbally told us she did not want to be considered, and 6 then we did also receive an e-mail from one of our 7 internal applicants to Tammy who said, "I'm interested 8 in the position. What happens if I'm on vacation when 9 it gets announced?" And Tammy responded to make sure 10 that he would be included. 11 So, at the time, we only had two applicants, 12 one who had submitted an actual letter and one who we 13 knew he was interested because of the information in an 14 e-mail, which wasn't really a request. 15 Q. And was one of these that expressed interest 16 to Mr. Roth directly, was it Mr. Guzman? 17 A. Mr. Guzman sent in a letter to Mr. Roth, 18 which is how I think we always instruct internal 19 people, if they're interested, to express their 20 interest is to write it down and send it in. 21 Q. So, Mr. Mayne's e-mail was not to Mr. Roth. 22 Is that fair? 23 A. No. That was to Tammy Kaniho. 24 Q. And for the -- I'd like -- I don't know if -- 25 I don't think it's part of my exhibit, but I would like ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 89 1 to submit it next in order. It might be one of the 2 appellants' submissions. And I would like to submit 3 this as next in order. 4 MR. HALVORSON: Is it already in evidence? 5 MR. MUKAI: It might be. I think Mr. Mayne 6 may have submitted this. 7 MR. MAYNE: I can't see from here what -- it 8 probably is. 9 MR. MUKAI: Yeah. 10 MR. MAYNE: Yeah, that was me. 11 MR. MUKAI: But you submitted this? 12 MR. MAYNE: Yeah. 13 MR. MUKAI: So, it is part of the record. 14 MR. HALVORSON: It was part of Mr. Mayne's -- 15 MR. MAYNE: Yes, sir. 16 MR. HALVORSON: -- submission? 17 What number is it in? 18 MR. MAYNE: My submissions are not tabbed out. 19 I'm sorry. But I did have a cover letter that has the 20 letter of my attachments, so it's listed as that. 21 MR. HALVORSON: It may not have been tabbed, 22 but what is your submission number? 23 MR. MAYNE: Oh, I'm sorry. 24 MR. HALVORSON: What tab are you looking at? 25 MR. MAYNE: This is tab Communication No. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 90 1 17-05, and then it's the sub-tab attachment 10. 2 CHAIR NAHUINA: Transition Planning? 3 MR. MAYNE: No. It's part of -- it's the 4 third page down under tab 10. There's five pages under 5 tab 10. 6 MS. NAMAHOE: Found it. 7 CHAIR NAHUINA: Dated Tuesday, March 7th, 8 2017, 8:45 a.m.? Is that the small print? 9 MR. MUKAI: I think it's 8:08. 10 MR. LORD: This one here? 11 MR. HALVORSON: Let's make sure we're on -- 12 which communication number are we looking at? 17-what? 13 MR. MUKAI: Mr. Mayne's submission. 14 MR. MAYNE: 17-05. 15 MR. HALVORSON: That doesn't -- 16 MS. NAMAHOE: 17-05. 17 MR. MAYNE: No. 10. 18 CHAIR NAHUINA: It's all the way in the 19 front, the appellants'. 20 MR. HALVORSON: Gotcha. 21 MS. NAMAHOE: And this is entitled "Regarding 22 Investigator VI Position." Is this the e-mail? Is 23 that what it is? 24 MR. MAYNE: Yes. 25 MR. TAM: So, this is dated March 7th, 2017? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 91 1 MR. MAYNE: Yes, sir. 2 MS. NAMAHOE: 8:41. 3 CHAIR NAHUINA: Okay, that's the one. 4 MR. MAYNE: And mine is -- 5 CHAIR NAHUINA: So, it's tab 10? 6 MR. MAYNE: Yes. 7 CHAIR NAHUINA: That one right there. I 8 believe that one. 9 MR. MAYNE: And then, mine is the complete 10 e-mail string. The message that Mr. Mukai just showed 11 me was my outline with the first question, okay, 12 initiating the string. 13 MS. NAMAHOE: About what happened -- 14 MR. MAYNE: Correct. 15 MS. NAMAHOE: -- if you go out -- 16 MR. MAYNE: Because I was out on vacation for 17 a while. 18 MR. HALVORSON: Okay. I think we've got it 19 identified. 20 BY MR. MUKAI: 21 Q. Now, on the second page of Exhibit 4, what is 22 that? 23 A. On the Request to Fill? 24 Q. Correct. 25 A. We shared and confirmed with the Human ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 92 1 Resources Department, and it's required on the Request 2 to Fill -- what desired experience and skill set is, 3 including the special recognition requirements, 4 familiarity with, must have, must be able, and 5 experience with for this position specifically. 6 Q. Take a look at Exhibit 5. And can you 7 describe for the Board what this document is? 8 A. Yes. This is the interview and selection 9 procedures for civil service positions specifically for 10 the Office of the Prosecuting Attorney, including 11 policies, applicability, definitions, appointing 12 authority, designation procedures -- it goes on for a 13 while -- guidelines for conducting an interview, 14 guidelines for selection of the panelists, guidelines 15 for developing interview questions, and assessment 16 exercises. 17 Q. Now, take a look at Exhibit 6. Can you 18 describe for the Board what this document is. 19 A. This is the Department of Human Resources 20 procedures for filling civil service positions for 21 recruitment and -- for the recruitment examination. 22 So, we have to follow these also for the County-wide 23 procedures. These apply to all departments. 24 Q. I'm sorry, Mr. Lord. Back on Exhibit 5 -- 25 and I'd like to direct you to page 6 of Exhibit 5 -- ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 93 1 there is some testimony that said that Pat Breault -- 2 is that her name? 3 A. Yes. 4 Q. -- doesn't qualify to be a panelist. Now, 5 can you address that? 6 A. One of the guidelines that we look at is, 7 under Guidelines for Selection of the Panelists -- and 8 if I look at letter c, when a County employee serves on 9 the panel, his/her job classification shall be equal to 10 or higher than that of the position being filled unless 11 it is determined by the appointing authority that this 12 is not practical. 13 Q. And do you have any reason to -- do you know 14 why Ms. Breault was, in fact, put on the panel? 15 A. Yes. We had a supervisor within the 16 prosecuting office who has lots of experience 17 interviewing and knows the process, who could be the 18 panel chair, and we needed somebody from within the 19 investigator unit to be on the panel because they know 20 exactly, kind of, what goes on as far as skills and 21 experience; and Pat Breault was currently, at that 22 point in time, serving as the -- she was TAing into the 23 Investigator VI position, and she at that point in time 24 was not applying for the position. 25 Q. Okay. Now, when you say "Ms. Breault was ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 94 1 TAing into the position, do you have any idea how long? 2 Was it like one day or two days that she TAd into the 3 position? If you can recall. 4 A. You -- I don't know -- my -- I don't know. 5 My guess would be that from the time Mr. Sumida left 6 the position, she was TAing there, but I don't know 7 that for a fact. 8 Q. That's fine. 9 There's also been some questioning that oh, 10 you should only have one person from outside. Do you 11 have any thoughts on that? 12 A. Yes. On the same page 6, under "Guidelines 13 for Selection of Panelists," the letter B says the 14 panel should include a fair representation of ethnic 15 groups and gender, to the extent possible, that are 16 most knowledgeable of the position. The number of 17 panel members may vary. One panel member may be from 18 outside the department either internal or external to 19 the County. One panel member may be the immediate 20 supervisor of the position. 21 Q. Does it say anything about, well, you have to 22 have one panel member from the outside. That's it. 23 End of story? 24 A. No. 25 Q. Take a look at Exhibit 6. We were just on ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 95 1 that. I apologize for going back, but on Exhibit 6, 2 can you describe for the Board what this document is? 3 A. As I said, this is the County-wide Department 4 of Human Resources recruitment and examination 5 sections, filling of civil service positions -- 6 procedures that all departments have to follow, 7 including policy, definitions, responsibilities, 8 Department of Human Resources. I believe that's it. 9 Q. Okay. Take a look quick look at Exhibit 7. 10 If you can just describe for the Board what this 11 document is. 12 A. I am not sure where it's -- which state law 13 book this is from, but these are the, I believe, 14 state-wide rules that we have to follow for 15 examinations -- for scope and character of examinations 16 for interviews, including disqualification of 17 applicants, conduct of examinations, rating of 18 examinations, notification of examination result, 19 administrative review of examination ratings, changes 20 in examination rating, custody and protection of 21 examination material, records and reports of 22 examinations. And it ends where subchapter 4 starts. 23 Q. Okay. Now, take a look at Exhibit 8. Can 24 you describe for the Board what Exhibit 8 represents. 25 A. This is the job posting that Human Resources ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 96 1 creates from our Request to Fill that they disseminate 2 -- however they disseminate it. 3 Q. So, did the Prosecuting Attorney's Office 4 create Exhibit 8, if you know? 5 A. No. I believe Human Resources creates this 6 using the information we provide. 7 Q. Take a look at Exhibit 9. 8 Before we get there, at some point in time, 9 there was a panel. That is correct? 10 A. Yes. 11 Q. And what is the purpose of this panel? 12 A. The purpose of the panel is to assess the 13 skills, experience, and abilities of applicants that 14 have been deemed appropriately to be -- and to provide 15 that recommendation for Mr. Roth to then make a 16 decision upon. 17 Q. What is Exhibit 9? 18 A. Prior to a panel starting interviews, we want 19 to make sure they're trained. And we're required by 20 Human Resources to make sure they're trained, so we 21 review a couple documents. This is one document just 22 talking about what their role is as an interview 23 panelist and that they won't discuss anything outside 24 of our interview panel process. It also includes the 25 protected classes as we cannot include in our ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 97 1 assessment or in any of our notes when assessing an 2 applicant. 3 Q. Now, with regard to the panel members, does 4 the Prosecuting Attorney's Office just say, "Here's my 5 panel. That's it. I'm running with this," or did you 6 seek input or comments from the Department of Human 7 Resources, if you can recall? 8 A. I recall I -- Mr. Roth told me who the 9 make-up of the panel would be, and I asked him -- I 10 said, "We need to make sure, with the two outside panel 11 members, that Human Resources is okay with that." So, 12 I asked Mr. Roth to contact Human Resources. 13 He reported within a day, I believe, that he 14 spoke to Waylen Leopoldino at Human Resources, and 15 Waylen reported that he approved, you know, and said it 16 was okay to have the two outsiders on the panel and 17 that having Pat Breault on the panel was also 18 appropriate. 19 Q. Now, with regard to Exhibit 9, is it fair to 20 say that each member of the panel reviewed and signed 21 this document? 22 A. Yes. The panel chair is required to make 23 sure that everyone knows what is on here and sign it 24 and included all four signatures here. 25 Q. Okay. What is Exhibit 10? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 98 1 A. This is the brochure regarding the employment 2 discrimination, which describes the protected classes 3 and how, in an interview, it's not okay to discuss 4 those protected classes for any of the applicants. And 5 then it goes into exactly what it means by those 6 things, such as disabilities, marital status, 7 education, race, color, religion, age -- those types of 8 things. 9 And then -- go ahead. 10 Q. So, is this document, Exhibit 10, given to 11 every one of the panel members? 12 A. No. There's one, and we give the panel time 13 for each one to ensure that they're reading it. 14 Q. Take a look at Exhibit 11. What is this 15 document? 16 A. This is the specific affirmation from each of 17 the panel members, that by participating in the 18 interview, they have received a copy of the employment 19 discrimination pamphlet and reviewed its contents. And 20 there's one for each of the four panel members. 21 Q. Now, what is Exhibit 12? 22 A. These are the questions that are asked of 23 each applicant that -- the panel member gets a set of 24 these questions for each interview. So, each panel 25 member gets one set for each interviewee, and it ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 99 1 includes, on the left-hand side, the category of the 2 question, the question itself, the rating guide, and 3 the scores on the right. And then, the last page is 4 where they compile their scores for the individuals -- 5 for one individual. 6 Q. Okay. Now, I understand that you were not 7 involved in the actual selection of the person selected 8 to interview -- as the Investigator VI. Is that fair? 9 A. Correct. 10 Q. So, did Mr. Roth or anyone at the prosecutor's 11 office ever tell you that "We had it out" or "We don't 12 want to hire Clement Guzman”? 13 A. No. 14 Q. Did Mr. Roth or anyone at the prosecutor ever 15 say or tell you, "We don't want to hire Kelly Mayne”? 16 A. No. 17 Q. Did anyone at the prosecutor's office ever 18 say -- did Mr. Roth ever say, "I don't want to hire" -- 19 "Don't hire Daniel Pang"? 20 A. No. 21 Q. Take a look at Exhibit 31. And what is this 22 document? 23 A. The rules of the interview process require us 24 to document from the panel chair to the department 25 head -- in this case to the prosecutor -- why the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 100 1 recommended selected applicant is recommended. 2 Q. Did you have any role in Exhibit 31? 3 A. My role was to make sure it gets done and 4 filed correctly, which I direct Tammy where to file it, 5 and I also direct the panel chair that they are -- they 6 are not supposed to talk about why they didn't select 7 other panelists. You know, we're not supposed to 8 degrade other people or write negative stuff, just 9 focus on "Why did you select this person?" And if 10 there's -- somebody else is selected that wasn't the 11 number one panelist, there's rules to follow, but they 12 don't include that in here. That's a verbal report to 13 Mr. Roth. 14 Q. Now, there's some testimony by Mr. Guzman 15 that says you were supposed to do an investigation. 16 What happened? Why didn't you do your investigation? 17 What was that all about? 18 A. I believe he was referring to his initial 19 internal complaint. And I believe I was probably the 20 one who said I would do an investigation. After I 21 spoke to Lee Botelho at the Human Resources Department, 22 who assists us with labor relations from the HR 23 Department, she told me it's not -- it's not an 24 investigation; it's not a formal investigation. And 25 so, I -- Mr. Guzman asked for specific documents and ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 101 1 information. I gathered up those documents the same 2 day I got the notice of an internal complaint, and I 3 provided that information to Mr. Roth. 4 Q. Okay. So, you never did an investigative 5 report or anything like that, right? 6 A. No. I gave a verbal report to Mr. Roth that 7 I had collected all the information that Mr. Guzman was 8 requesting. 9 Q. So, you never really did an investigation. Is 10 that fair? 11 A. Not a formal investigation. That's something 12 different from Human Resources. 13 Q. Okay. So, Mr. Lord, based on your 14 involvement in this process, would you say that somehow 15 the process was flawed -- the way it was done? 16 A. No. I believe we followed all the rules that 17 we were expected to follow to the T. 18 MR. MUKAI: Thank you. I have nothing 19 further. 20 CHAIR NAHUINA: Thank you. 21 At this time, would you like to 22 cross-examine? 23 MS. NOMURA: Yes. 24 . . . 25 . . . ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 102 1 CROSS EXAMINATION 2 BY MS. NOMURA: 3 Q. Mr. Lord, based on your experience both in 4 the Prosecuting Attorney's Office and previously in 5 DMV, I think you said you have experience with 6 recruitment, and you have been through this process 7 before, so you're an expert kind of in that field? 8 A. Yes, I have a lot of experience. Yes. 9 Q. Okay. So, you're looking at fashioning a 10 recruitment whereby it will be fair because you're 11 looking at the Merit Principle and you want to select, 12 as we heard previously, the person most fit for the 13 job, so you did consult the class specs for the VI. 14 Did you also look at the rest of the series? 15 A. I think we looked at the V because most of 16 our staff are V and that's who they're supervising. 17 Q. Right. 18 A. I did look at those specs., yes. 19 Q. Did you notice, when you looked at the V -- 20 MS. NOMURA: And just for the record, I 21 thought the V was included in the exhibit, and I see 22 that it's not, so we would like to have the panel have 23 access to the V and the IV as well, because I did make 24 some statements about the relationship between those 25 classes. So, if we can provide that. Sorry, I don't ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 103 1 have it in my documents. 2 MR. LORD: Can I clarify? I'm sorry. I said 3 I looked at the specs. That was your question. 4 BY MS. NOMURA: 5 Q. Right. 6 A. I looked at the job description for the V in 7 our office, in our department. I don't believe I went 8 back and looked at the specs. at the County, no. 9 Q. Okay. Because if you look the specs. -- I'm 10 just sharing what I see -- there is a really close 11 relationship because it's in the same series, right? 12 And you're familiar with series -- 13 A. Yes. 14 Q. -- in the County jurisdiction, as in any of 15 the state jurisdictions, there is a really close 16 relationship. And as I stated, you know, in just my 17 review of the document, there are like 23 points in the 18 knowledges and abilities, and the V has 20 of them 19 required at their level, and the IV has 19 required. 20 So, the vast majority. 21 A. Uh-huh. 22 Q. So, where in the interview process was that 23 taken into account? Was there any kind of points given 24 for the fact that these applicants already were doing 25 this portion of the job? Do you know what I'm saying? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 104 1 It's like, hey, if I worked as an investigator doing 2 that job and the difference between the job I have and 3 the supervisor was the supervisory part, I understand 4 you're going to have to look at -- hey, who has the best 5 qualifications for the supervisory part, but in the 6 vast majority of the job, it's like, hey, I'm doing it 7 already, so where do I get credit for that? Or where, 8 I guess, in the interview process is there some kind of 9 acknowledgment? I don't see that, so maybe you can 10 share that with me. 11 A. My understanding is that yes -- many of the 12 duties are the same. And when I -- I believe that 13 that's the majority of the interview process and 14 purpose is to ask the questions so that we can look at 15 those who are doing the same job for longer periods of 16 time or less periods of time and using their responses 17 to the skills, experience, and ability. That's what 18 the panel has to decide, who's showing the best ability 19 to apply and use those skills as closest to the expert 20 for what we're looking for. 21 Q. But, Mr. Lord, when you're asking those 22 questions, you're asking someone what they're saying 23 they're going to do, right -- 24 A. Uh-huh. 25 Q. -- versus knowing what they're going to do in ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 105 1 the job. And wouldn't you say if somebody is doing the 2 vast majority of that job, as these applicants were -- 3 because it's verified through their job performance 4 ratings that they're doing the job -- and their class 5 specs. require them to have, as I said before, that vast 6 majority of the knowledge and ability to do the job of 7 the VI, wouldn't that be something you would have to 8 figure in? Because, otherwise, I could come in there 9 and tell you whatever you want to hear, but you have no 10 idea of what the person will actually do on the job. 11 In this case, you know what they do on the job. 12 They're doing it for you. 13 CHAIR NAHUINA: Ms. Nomura, can I ask, is 14 there a question here for Mr. Lord? 15 MS. NOMURA: There is. 16 BY MS. NOMURA: 17 Q. Where was that accounted for in this 18 interview process -- or this examination process? 19 A. I'm really not sure what the question is, 20 once again. So, where is their experience accounted 21 for in this process and their abilities? 22 Q. Can I explain? 23 MR. HALVORSON: Let him -- let him -- 24 MS. NOMURA: Okay. 25 CHAIR NAHUINA: Mr. Lord, are you asking ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 106 1 for clarification from Ms. Nomura? 2 THE WITNESS: Yes. 3 CHAIR NAHUINA: Ms. Nomura, would you 4 please restate your question. 5 BY MS. NOMURA: 6 Q. The VI level and V level and IV level are 7 very close in knowledge and abilities required at each 8 of those levels. The VI level, it requires a majority 9 of the knowledge and abilities required at the V and 10 the IV level. So, where in the interview process for 11 the VI -- how do you capture the fact that someone has 12 done those things in their job, in their previous 13 position? 14 A. Okay. So, when everybody that applied had to 15 apply, you go on the website and you have to fill out 16 an application and describe all your experience, all of 17 your education, and all of your jobs that you have 18 done. So, you list it all there and you write it all 19 down. And we encourage people to write everything that 20 you have ever done down there. So that's number one. 21 And then, number two, in the interview, when 22 we're asking the questions, I feel it becomes inherent 23 in their answer, and that's what I've been trained by 24 Human Resources, to look for that experience in those 25 things. That's what we have to rely on; because if ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 107 1 there's -- if I have knowledge of an outsider, I -- but 2 that's where we look at their experience. Just like 3 this applicant that might be working in the office has 4 to share all that information through that process, so 5 does this one that is not from the office. And that's 6 where we see it. That's what the interview process is 7 about. 8 Q. So, the number one step you talked about was 9 to qualify for the interview. Is that correct? 10 A. Yes. 11 Q. Because all of the skills that they put down 12 and experience that they put down is used to determine 13 whether they qualify? 14 A. Right. But the panelists also look at that 15 to see their experience because it's all listed there. 16 They have to list all their education and what their 17 duties were in those jobs and what their jobs were. 18 Q. Right. My question is what weight is 19 afforded that level of experience? 20 MR. MUKAI: Object to the form of the 21 question. I don't know if he would even know what 22 weight each panel member gave. 23 MS. NOMURA: Okay. I'll change the -- 24 BY MS. NOMURA: 25 Q. Was there any weight given to that ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 108 1 experience? 2 A. Absolutely. 3 We were told by Human Resources to look at 4 every applicant fairly, through fair eyes, hear what's 5 on the application and the duties and responsibilities 6 that they come to the table with, hear what they have 7 to say and how they answer the question, and correspond 8 them fairly and equally. 9 Q. So, in the interview process, in those 10 questions, you had, you know, what you were looking 11 for, I think, as I saw the questions and what were the 12 answers you were looking for. 13 A. Suggested answers, yes. 14 Q. Right. 15 So, if someone said, "I did it," does that 16 count for anything? 17 A. If they just sat there and said "I did it" in 18 an interview, that really doesn't count for much at 19 all. 20 Q. Despite the fact that you know they did it? 21 A. Right. Because somebody that works at -- I'm 22 just making this up -- McDonald's or another place 23 outside our agency could come in and say "I did it" 24 also; and in the interview, we're taught by Human 25 Resources to look at the answers and how they're ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 109 1 answering. And maybe – so, I do know what these guys 2 have done before and how great they are at their job, 3 but that would be unfair at times to the McDonald's guy 4 if the McDonald's guy didn't write it down and put it 5 there, and all of a sudden I'm just not counting that, 6 or I would start counting that because I know from 7 outside where the McDonald's guy is and I start scoring 8 him higher for something he didn't write down or talk 9 about. We're not allowed to do that. 10 Q. Okay. You talked about 31, the justification 11 of the selectee. 12 A. From Ms. Chai, yes. 13 Q. Right. 14 So, you said, I think, that you didn't have 15 anything to do with the justification. Is that 16 correct? 17 A. No, I just -- I instructed her how to write 18 the letter -- not how to write the letter -- what the 19 letter is required to have. 20 Q. Okay. So, it talks about -- I'm just trying 21 to understand this better because it talks about the 22 candidate with the highest -- I'm looking at the third 23 or fourth line down. "Because we felt he understood 24 what this position entailed and believe that he had the 25 leadership skills necessary to supervise the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 110 1 Investigator Unit as well as the investigative skills. 2 His answers were thoughtful, thorough, and showed a 3 high work ethic, integrity, and commitment to 4 community." 5 So, these are the kinds of attributes that 6 the panel got as a result of answers that this person 7 was given? 8 A. I believe so. 9 Q. In the case of the Appellants, you know what 10 their history is; you've seen it in the job performance 11 reviews. I guess I'm trying to weigh how that fits in 12 there, these answers versus what you've seen people 13 actually perform -- I guess I'm still asking the same 14 thing. I don't see how this justifies the selection 15 when you have people who have actually done the job. 16 A. I don't think I can answer that question. 17 It's Mr. Roth's decision. He's the one that uses this 18 information. He might be able to answer it better. 19 MS. NOMURA: Thank you. 20 CHAIR NAHUINA: Mr. Mukai, do you have any 21 redirect? 22 MR. MUKAI: Oh, no. Thank you. 23 CHAIR NAHUINA: So, at this time, do the 24 Board Members? 25 . . . ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 111 1 EXAMINATION 2 BY MR. TAM: 3 Q. I had a question about why it was a open 4 recruitment versus internal. It's my understanding, 5 according to what is in front of us, there was 6 insufficient interest in the position? Is that 7 correct? 8 A. That's what Gabriel Cabanas wrote, correct. 9 Q. And I think you testified that there were two 10 inquiries prior to that decision? 11 A. There was one written notification to 12 Mr. Roth saying, "I'm interested in the position," and 13 then there was one e-mail that alluded to "I'm 14 interested in this position," and then there was a 15 third letter that was retracted before we did this 16 recruitment. 17 Q. Okay. And, in your opinion, how many 18 applicants or interest would you have needed in order 19 for this to be a closed recruitment, considering you 20 have, what, eight positions in -- eight investigators? 21 Seven investigators? 22 A. Twelve. 23 Q. Twelve. 24 So, just curious how many -- you had three, 25 and then one later retracted, but I think that person ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 112 1 retracted after, right? 2 A. Yes. 3 Q. So, at the time, you had three applicants 4 and -- or possible applicants. 5 A. No. We had one that wrote a letter and one 6 who alluded to it in an e-mail at that point in time 7 when the paper went to Human Resources to open up the 8 interview process. 9 Q. I think the e-mail was about that person going 10 on vacation -- 11 A. Yes. 12 Q. -- what would happen, right? 13 A. So -- 14 Q. And that was in March? 15 A. Yes. 16 Q. And the recruitment -- the decision to make 17 it a closed -- open recruitment was May? 18 A. Yes. 19 And as far as your answer goes, I don't think 20 I have an answer. Every one has been different, and 21 it's at the discretion and pleasure of the department 22 head and/or the prosecutor whether it's open or closed. 23 Q. Okay. 24 A. So, I would have to probably call Lee Botelho 25 at Human Resources that was asking me is there a ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 113 1 specific number because I have never heard a specific 2 number either way. 3 Q. And you may not be qualified to answer this, 4 but if an external applicant is hired, is that 5 considered a promotion? 6 A. No. 7 MR. TAM: No. 8 Okay, thank you. No other questions. 9 CHAIR NAHUINA: Did you have something 10 more? You had a second thought. Did you want to 11 finish your thought? 12 MR. LORD: I don't -- I'm not -- I said no, 13 I'm not sure if somebody comes from the State -- you 14 know, from outside, if it's from the police department 15 and they're an investigator there and they come to our 16 office, is that a promotion? I think if they are 17 already in the County, it is. I'm not sure if somebody 18 coming from the State or the federal government, and 19 they carry all of their benefits and sick time with 20 them to our office when they come in, I would have to 21 call Human Resources and ask if that's a promotion or 22 not. 23 MR. TAM: Thank you. 24 MR. MUKAI: I think for the record, for 25 example, Mr. Lord talked about someone coming in from ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 114 1 the police department, and say he's a police officer or 2 whatever. It's -- it's a potential cross-bargaining, 3 so, they are not -- it would not be considered to 4 promote as these individuals would be. 5 MR. TAM: But if it's an open recruitment, 6 how is that considered a promotion if they're following 7 the same process as an external applicant? 8 MR. MUKAI: Okay. For the external 9 applicant, it is a recruitment. I agree. If the 10 person who was selected was not one of these -- say one 11 of these gentlemen was selected to the position, the 12 person who was denied does not have the bargaining unit 13 right, so that person would have a right -- and I would 14 agree -- in that situation would be able to have his 15 appeal heard at the Merit Appeals Board. 16 MR. TAM: Okay, thank you. 17 CHAIR NAHUINA: Any other questions? 18 MS. NAMAHOE: Just a few. 19 20 EXAMINATION 21 BY MS. NAMAHOE: 22 Q. Okay. I just wanted to get clear that in 23 order of high scores to low -- that one, the scores came 24 as a result of the matrix that's in the back here that 25 we were looking at. Is that correct? Who created that ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 115 1 matrix? 2 A. It's the responsibility of the panel chair, 3 but she delegated Tammy Kaniho -- the panel chair 4 usually does -- to make the actual document on the 5 computer, and then the panel chair signs off that -- 6 yes, those were the scores. 7 Q. Okay. So, it's from this matrix that we 8 learned earlier -- I heard -- and I just wanted to get 9 it clear for my ears -- there was a top candidate, then 10 34 points later, there was Mr. Koaho, and then there 11 were the Appellants in various degrees, with Mr. Guzman 12 at the top of that? Is that correct? 13 A. Yes. I didn't count if it was 34 after the 14 top score and Mr. Koaho but, yes, I believe that's in 15 general, yes. 16 Q. So top, Koaho, and then in order -- 17 A. Yes. 18 Q. And I'm just trying to remember. 19 MS. NAMAHOE: You said you were No. 8? 20 MR. MAYNE: Correct. Yes. 21 BY MS. NAMAHOE: 22 Q. Okay. I did have another question here about 23 the interpretation of the Guidelines for Selection of 24 Panelists which was in the Section 5 that you had 25 alluded to earlier, Guidelines for Selection of ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 116 1 Panelists, Section B and Section C, because I'm trying 2 to understand, one, the composition of the interviewing 3 panel and, two, I'd like to know that you said that 4 that panel was cleared through Mr. Leopoldino from HR, 5 right? 6 A. That's what Mr. Roth told me, yes. 7 Q. Okay. So, I just want -- so the panel should 8 include -- Section B, the panel should include a fair 9 representation of ethnic groups and gender, to the 10 extent possible, that are most knowledgeable of the 11 position. And so, the four panelists here had some 12 knowledge of this type of position. Whether they 13 worked -- whether they performed this position in the 14 prosecutor's office or not, all four of these panelists 15 had knowledge of what that position would entail -- a 16 VI would entail, right? An Investigator VI? That was 17 how they were chosen. The number of panel members may 18 vary. One panel member may be from outside the 19 department, either internal or external to the County. 20 And so, you took that one as a generic noun, 21 not as a numeric ceiling? 22 A. Yes. 23 Q. That's how you understood that? 24 So, it didn't -- so the reason why I'm asking 25 that is because when I read this sentence, "one panel ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 117 1 member may be," I'm seeing that as a singular term. 2 I'm not seeing that as a broad noun, which is typical 3 for third-party English. Then I would expect "Panel 4 members may be from outside the department" versus "One 5 panel member may be from outside, either internal or 6 external to the County." Is that what you took to 7 Mr. Leopoldino to get clarified -- 8 MR. ROTH: Yes. 9 BY MS. NAMAHOE: 10 Q. -- and then he was the one who signed off to 11 say -- 12 MR. ROTH: I'll answer that if... 13 BY MS. NAMAHOE: 14 Q. Okay. One panel member may be the immediate 15 supervisor of the position, but in this case, none of 16 the four panel members were either immediate 17 supervisors, and two were outside of the County. 18 MR. ROTH: That's not exactly correct. 19 MS. NAMAHOE: Okay. 20 MR. ROTH: I'll explain that in a few 21 seconds. 22 MS. NAMAHOE: All right. Because I'm -- 23 thank you. 24 CHAIR NAHUINA: Thank you. 25 MR. CHILLINGWORTH: Thanks. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 118 1 CHAIR NAHUINA: I have one. 2 MR. HALVORSON: Go ahead. 3 4 EXAMINATION 5 BY CHAIR NAHUINA: 6 Q. Okay. I think you commented that there were 7 two people who showed interest, and I'm just curious, 8 how was the interest solicited? I mean, how did he 9 know to send an e-mail? How was it done? How was it 10 done in this case? 11 A. And I'm not sure I -- usually it's verbal, 12 but in the past three years, we have been sending out 13 e-mails and informing people. But if it was to be an 14 internal recruitment and it was decided it was going to 15 be internal, Mr. Roth sends out an e-mail saying "Anyone 16 interested in internal recruitment, please let me 17 know." These people sent their written interest in the 18 position prior to any posting of the position at all. 19 Q. So, is it possible that there were other 20 people interested beyond these two? 21 A. It's possible. If they were, they all had -- 22 I believe everyone knew that you need to let us know if 23 you're interested. 24 CHAIR NAHUINA: Thank you. 25 . . . ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 119 1 EXAMINATION 2 BY MR. HALVORSON: 3 Q. There was some allusion to this before, but 4 how many total applicants did you have? 5 A. That we interviewed was nine. 6 Q. No, total applicants. 7 A. Twelve. 8 Q. And you ended up interviewing only nine? 9 A. Yes. The other three, when they were finally 10 contacted, had either gotten another job or decided 11 they didn't want to move to Hawai ʻ i or turned down the 12 interview. 13 Q. So, none of the 12 that initially applied were 14 found not qualified? 15 A. Correct. 16 Of those 12? 17 MR. ROTH: That were forwarded to us. 18 MR. LORD: That were forwarded to us. Yes, 19 our department didn't disqualify any of the 12 that 20 were referred to us. 21 BY MR. HALVORSON: 22 Q. So, there may have been additional applicants 23 received by HR? 24 A. By HR. They look at do they meet the minimum 25 requirements -- skills and requirements before they ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 120 1 refer them to us. And, if somebody doesn't meet the 2 minimum requirements, then they don't get referred to 3 us, and they have a chance to appeal that and offer 4 more information to Human Resources. 5 Q. But you have no idea if there were any such 6 people? 7 A. No. We just get the 12 that they approved to 8 send to us. 9 Q. So, all the 12 you got were qualified? 10 A. Yes. 11 MR. HALVORSON: Okay. thank you. 12 CHAIR NAHUINA: Thank you. 13 At this time, last chance, County. 14 MR. MUKAI: I have no further questions for 15 Mr. Lord. 16 17 RECROSS EXAMINATION 18 BY MS. NOMURA: 19 Q. Yes, I do -- based on Mr. Tam's question about 20 the people who did ask to be considered for the 21 position. And I think it was clarified to some extent, 22 but I wanted to ask if the Employer got notification 23 from others or heard of others, they could have gone to 24 an internal recruitment at that point, right? 25 MR. MUKAI: Object to the form of the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 121 1 question. That misstates all -- 2 MS. NOMURA: I'm sorry. 3 BY MS. NOMURA: 4 Q. I'm just asking could they have changed their 5 mind and gone internal? 6 A. Whether it's an internal or external 7 recruitment is always at the pleasure of the 8 prosecutor. 9 MS. NOMURA: Okay. 10 CHAIR NAHUINA: Thank you. 11 MR. PANG: I've got a question. 12 MR. MUKAI: He can't ask a question. 13 MR. PANG: You asked if we had a question for 14 Mr. Lord. 15 MR. HALVORSON: You can ask your attorney. 16 BY MS. NOMURA: 17 Q. The question is whether you sent out an e-mail 18 about any interest on this position to your staff. 19 A. I don't -- I don't believe we did. It was 20 not an internal recruitment. Everyone knew that Dean 21 had left. That's what prompted people who were 22 interested to send us interest. But when the decision 23 was made it was going to be external, there was no 24 reason to send an e-mail out. 25 MS. NOMURA: Okay. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 122 1 CHAIR NAHUINA: Thank you. 2 Your next witness would be Mr. Roth? 3 4 MITCHELL ROTH, 5 having been first duly sworn to tell the truth, the 6 whole truth and nothing but the truth, was examined and 7 testified as follows: 8 9 DIRECT EXAMINATION 10 BY MR. MUKAI: 11 Q. Please state your name for the record, 12 please. 13 A. Mitchell Roth. 14 Q. What is your position? 15 A. I am the Prosecuting Attorney for the County 16 of Hawai ʻ i. 17 Q. And how long have you held that position? 18 A. As the elected prosecuting attorney, five 19 years now. 20 Q. Okay. Let's just start out with this. Why 21 is it that the person who was selected -- person who 22 scored the highest was not selected? 23 A. So -- 24 Q. If you know. 25 A. I do know. What I do as a matter of practice ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 123 1 is I have a panel that does the interviews. The panel 2 comes back with a recommendation, and I think every 3 time I've gone with the recommendation of the panel to 4 make it, you know, clear that I am not, you know, 5 trying to influence who gets selected. In this case, 6 my understanding was that the person that had the 7 highest score also was not from Hawai ʻ i, was living in 8 New York, that he was a liquor investigator is what I 9 understood; but the panel recommended this person for 10 the reason they state in that letter, which is 31. 11 I want to make a correction, though. The 12 person that we did select and has been in the position 13 for the last six months was not from outside the 14 jurisdiction; it was from inside the jurisdiction. 15 So... 16 Q. When you say "inside the jurisdiction" -- 17 A. He was from Hawai ʻ i. He was from this island. 18 He was living on this island. He was working on this 19 island at that time. 20 Q. Now, let's talk a little bit about the panel. 21 It seems like, according to the Appellant, these panel 22 members were just guys off the street, McDonald's 23 workers; and I don't know what they're talking about. 24 Can you explain to the Board who each 25 individual was and what their background and knowledge ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 124 1 indication was? 2 A. Sure. 3 Let me start with the two from outside. One 4 was Larry Weber, who was a major in the police 5 department. He had prior experience as the captain in 6 the investigations unit. We felt that it was important 7 that we had someone with police investigative 8 experience on this -- on this panel. And so, that was 9 one of the reasons that we had him. 10 Doug Adams is a retired lieutenant colonel 11 from the Army. He is a local attorney, has knowledge 12 of the law, and he was also a member of the County 13 Ethics Board. And he and his wife write leadership 14 books. I thought it was really important that we have 15 someone with really good leadership skills to pick the 16 next leader of the investigative unit. 17 Deborah Chai is a -- she's the head of our 18 Victim Witness Unit. She has extensive experience 19 working with investigators in our office. Oftentimes 20 they will do interviews with the witnesses, the victim, 21 victim witness counselor, and attorney, and the 22 investigator; so, she has experience working with 23 investigators and knows, kind of, what they need to do. 24 As a policy, if I'm hiring for a position, I 25 try to have someone – generally, it's going to be the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 125 1 leader of that unit is going to be interviewing. At 2 that time, Pat Breault was TAd into the SAVI -- the 3 Investigator VI position, so she was technically at the 4 level -- the same level as the position that was being 5 hired into. There was a question on that, and so I 6 went to Waylen Leopoldino, and what Waylen did is we 7 went into his office, he pulled up the -- our 8 procedures that we provided, and we went through that 9 question. It said, "where applicable." I don't know 10 if you have the wording there. We felt that because she 11 was at the VI level, even in that TA position, she's 12 hiring to a -- into that position, and also because it 13 was important to have an investigator on that who knew 14 what the investigators did; it was important to have 15 her or someone in that ability to do that. So that's 16 why -- that's why we chose her. 17 Q. And then, I think there's one more. Oh, you 18 did talk about Ms. Breault. 19 A. Yes. She was the last one I was talking 20 about. 21 Q. Now, let's talk about these guidelines that 22 you talked to Human Resources about. And I'm 23 specifically referring to -- 24 A. What number? 25 Q. -- Exhibit 5, page 6. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 126 1 So, what happened on -- it was more informal 2 than anything. I was hoping that Gabriella was there. 3 She wasn't there. Waylen was there, and he pulled it 4 up. Waylen, to my understanding, was a manager at HR 5 at the time. He looked, and it's page 6. Is that 6 correct? 7 Q. Uh-huh. 8 A. We read through, we looked through it, and I 9 think you'll see when the -- a County employee serves 10 on the panel, his or her job classification should be 11 equal to or higher than that of the position being 12 filled unless it is determined by the appointing 13 authority, which is me, that this is not practical. 14 Wouldn't have been practical to have someone outside -- 15 in my opinion, at that time, wouldn't have been 16 practical to have somebody outside the investigative 17 unit hiring this position, especially in light of the 18 fact that we had someone TAing into that position, was 19 at that level, and was not going to be applying for 20 that position. 21 Q. And can you describe for the Board how long 22 Ms. Breault was TAing into the position of Investigator 23 VI at the Prosecuting Attorney's Office? 24 A. So, I think Dean Sumida officially left the 25 office on February 21st. I'm not sure if he took a ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 127 1 couple of weeks off prior to that. So, she probably 2 would have been TAd into that position at that time. 3 But somewhere in February, until the new investigator 4 was hired six months ago, she was in that position. 5 And at the time of the interview, there were several 6 months that she had already been in that position. 7 Q. Now, there was some discussion or some 8 testimony -- I think there was some questions about a 9 person's previous experience, the descriptions, their 10 prior experience, if these people were Investigator Vs, 11 "We've done everything, so why not just take me?" Why 12 not take them? What -- what -- 13 A. So -- 14 Q. Would you respond to that? 15 A. -- you know -- and this -- I'll say it. This 16 case has had me do a lot of soul-searching. I believed 17 at that time that one of these guys probably -- one of 18 the four people from my office who applied, when I 19 found out who was going for it, I thought that we would 20 probably get one of those guys. 21 When the scores were so -- there was such a 22 big disparity between the top group and the group from 23 the office, I could have made a decision to hire way 24 down lower, but that would have definitely created a 25 situation that the Merit Appeals Board -- because I ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 128 1 wasn't going by, one, my policy that we have, two, I 2 think the County policy that talked about the levels 3 there. So, I think that was another thing. 4 I think the other thing that was built into 5 here are the actual questions that were asked during 6 the interview. And I think the questions -- if you 7 look at them in No. 12, I think it gave the three 8 investigators here maybe an unfair advantage, so I was 9 really quite surprised that their scores came out the 10 way they did. 11 Q. So, let me ask you this. And I would direct 12 your back to Exhibit 12. 13 A. Okay. 14 Q. For example, look at the first question and, 15 I guess, all the questions as a whole. And if you can 16 describe for the Board what these questions represent 17 in terms of the need and the qualifications and skills 18 required for the Investigator VI position. 19 A. I think all of these go to, you know, your 20 knowledge, skills, their ability to lead. The first 21 question, for example: This position is for an 22 Investigator VI/Supervisor within the Prosecutor's 23 Office. What do you see as the primary role of the 24 prosecutor? Having again -- they are looking -- we're 25 looking for knowledge of the prosecutor's role and ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 129 1 function being in the office. I figured that these 2 guys would have pretty much an unfair advantage on that 3 question. 4 Interest in position is the second -- goes to 5 the second: Why are you interested in this position? 6 How does it meet your long-term goals? General skills, 7 work style, ability to handle stress. What are three 8 of your strengths? How do you think this will be 9 utilized as Investigator VI/Supervisor in the 10 Investigative Unit? Again, these are things that goes 11 to their skills, but they should have an advantage. 12 What are your weaknesses? What have you done to 13 compensate for them? If you felt overwhelmed by the 14 work, how would you handle the situation? 6: A deputy 15 prosecuting attorney brings you a disk with pictures on 16 it at 3:00 p.m. for trial tomorrow. The deputy tells 17 you they need to be produced ASAP. How do you feel, 18 and what do you do? Again, this goes to, you know, 19 normal questions. 20 I'm going to skip down because I think the 21 questions that they had the biggest problem with in 22 their response today were those relating to Gilbert. 23 Gilbert is a national authority. But if you look at 24 14, for example, according to Gilbert -- okay, the 25 investigator must be persistent to a degree beyond that ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 130 1 of an average person. Persistence can be defined as 2 continue in the face of opposition or refusing to give 3 up when faced with an adverse situation. The overall 4 task of an investigator is not easy, particularly when 5 confronted with a difficult case. Here's the call of 6 the question. It's not asking you to know about 7 Gilbert. It's not asking you about specialized skills. 8 It's saying to what end should an investigator persist 9 in his investigation? If you listen to that question, 10 all of the answers are given to you according to 11 Gilbert, what's in there. 12 Q. Now, for the Board's information, again, what 13 is Gilbert? 14 A. He's kind of a national -- a national 15 authority on investigative skills. Kind of like for 16 attorneys, we have Black's Law Dictionary, Herman 17 Winchell on Evidence for those in Hawai ʻ i, Bowman on 18 Evidence. The questions about Gilbert, you don't have 19 to have specialized knowledge about Gilbert so much as, 20 you know, what you need to know as an investigator. 21 Q. Okay. Do you know if any other law 22 enforcement agencies use or rely on Gilbert? 23 A. My understanding is these questions actually 24 came from the Hawai ʻ i County Police Department as part 25 of their assessments for their investigators. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 131 1 Q. Now, at some point, you were made aware of 2 the selectee. Is that correct? 3 A. Yes. 4 Q. I direct your attention to Exhibit 31. 5 A. Yes. 6 Q. Before I ask you questions on Exhibit 31, 7 have you ever deviated from the recommendation of the 8 panel? 9 A. Not -- not that I can recall. 10 Q. Again, back to Exhibit 31. Can you describe 11 for me what this document is. 12 A. This is the recommendation letter from the 13 panel for the people that we selected to do this work. 14 And I -- you know, I just want to say we try to make 15 this, again, as transparent as possible and as fair as 16 possible. 17 Q. Okay. Based on what the panel tells you, 18 they didn't select Mr. Guzman, right? 19 A. That's correct. 20 Q. And they never selected Mr. Mayne? 21 A. That's correct. 22 Q. And they never selected Mr. Pang. Is that 23 correct? 24 A. That's correct. 25 Q. Now, let me ask you this. Did you have it ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 132 1 out for Mr. Guzman? 2 A. I did not. 3 Q. Did you have it out for Mr. Pang? 4 A. Did not. 5 Q. Same question with Mr. Mayne. 6 A. Did not. 7 Q. Did you ever tell anyone you don't want them 8 hired as the Investigator VI? 9 A. I did not. 10 And let me just take that one step further. 11 If that was the recommendation of the panel, to hire 12 these guys, both of these guys, I would have happily 13 done that. Happily done that. 14 Q. Now, the gentleman selected was Koaho? 15 A. Alan Koaho. 16 Q. Is he a personal friend? 17 A. At that time, I didn't really know him at 18 all. I've met him -- to be fair and completely honest, 19 I met him at a community event one time, and he came up 20 and introduced himself to me. And that was probably 21 maybe six months before all this happened. 22 MS. NAMAHOE: Not to interrupt, but I need to 23 know, because I have read it so many times as Koaho. 24 Is it Kaoho or Koaho? 25 MR. ROTH: K-o-a-h-o. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 133 1 MR. MUKAI: I'm sorry? 2 MS. NAMAHOE: Means new Koa tree. All right. 3 Sorry. I just -- go on. 4 MR. MUKAI: Thank you. 5 BY MR. MUKAI: 6 Q. Based on the process that your office did as 7 prosecuting attorney, do you believe that the selection 8 of Mr. Koaho -- 9 MS. NAMAHOE: Koaho. 10 MR. MUKAI: Yes. 11 BY MR. MUKAI: 12 Q. -- was fair with the circumstance? 13 A. I believe it was very fair under the 14 circumstances. 15 MR. MUKAI: Okay, thank you. I have nothing 16 further. 17 CHAIR NAHUINA: At this time, I would want 18 to suggest we take a recess before cross. And can I 19 hear a motion? 20 MS. NAMAHOE: I make a motion we go into 21 recess. 22 CHAIR NAHUINA: Second? 23 MR. CHILLINGWORTH: Second. 24 CHAIR NAHUINA: All in favor say "Aye." 25 (All Board Members responded affirmatively.) ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 134 1 CHAIR NAHUINA: All opposed, same sign. 2 It's been offered and seconded that we take a 3 recess. We'll take a ten-minute recess before cross 4 examination. 5 MS. NOMURA: Thank you. 6 (Recess ensued from 1:47 p.m. to 1:57 p.m.) 7 CHAIR NAHUINA: Thank you. It's 1:57, and 8 we'll come out of recess and continue with the hearing. 9 At this time, I would like to invite the 10 Appellants' cross examination. 11 MS. NOMURA: Thank you. We just have a few 12 questions for Mr. Roth. 13 14 CROSS EXAMINATION 15 BY MS. NOMURA: 16 Q. I think Mr. Lord said in his testimony that 17 he -- or that Mr. Roth sent out an e-mail asking for 18 anybody who was interested in the position -- 19 A. I don't -- I think we -- we -- yeah. So, what 20 happens generally, if it's internal, we will send 21 something out. This generally comes from my 22 secretary -- will send, you know, a letter out, or from 23 our HR specialist she'll send something out. So, 24 there's generally a letter comes out when it's just an 25 internal. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 135 1 Q. 2 When it's an internal recruitment? 3 A. When it's an ex- -- when it's open, we also 4 send something out stating that. 5 Q. But it didn't happen in this time? 6 A. It happens every time. When there's a 7 recruitment out, that letter always goes out. 8 Q. Okay. Because -- 9 A. So, let me make sure we're talking about the 10 same letter. 11 Q. Yeah. 12 A. So, any recruitment, whether it's for a 13 position in our office, whether it's -- so there's 14 three different levels, right? You have internal, 15 internal County, I guess, and then internal -- or -- 16 you know, open recruitment. 17 So, whenever there's a recruitment that is 18 open, there will be an e-mail that goes out. So, if 19 it’s a recruitment, for example, for Parks, that -- you 20 know, we send that out -- HR sends -- that will go out. 21 If there's a recruitment for a position in our office, 22 there will definitely be that recruitment that will go 23 out. 24 But I think you're asking something 25 different, so I want to make sure we're talking about 26 the same thing. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 136 1 Q. No, I think we just wanted to clarify whether 2 you send out an e-mail soliciting anybody to apply if 3 they're interested. 4 A. So, I -- again, whenever there's an HR 5 recruitment -- I think maybe Mr. Guzman can explain. 6 Q. Right. 7 But I thought there was a comment about an 8 e-mail. I thought there was a comment about an e-mail 9 going out to staff to let them know about the 10 possibility that they can -- or soliciting. 11 A. So, occasionally, there are -- when 12 internals -- you know, that sometimes will happen. And 13 I can't say it happens all the time, but there's 14 something like that. When somebody leaves, we send a 15 letter to the staff basically saying that somebody has 16 left the office as well. That did happen. 17 I'm not sure if a letter -- be more 18 specific -- if a letter saying, "Hey, does anybody want 19 to apply for the investigator supervisor?" go out. Did 20 that go out? I'm not sure that happened. 21 Q. No, we're not talking about a letter. We're 22 asking about an e-mail. 23 A. Right. And when I'm saying "letter," I'm 24 talking about an e-mail. We currently send everything 25 by e-mail. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 137 1 Q. And you're saying that didn't happen in this 2 case? 3 A. Not to my knowledge. 4 Q. When we talked about the Request to Fill form 5 and there was an indication that there was an interest 6 in the department, I think you explained that there 7 were only two people who expressed interest in the 8 position at that point? 9 A. So, when you talk about the form, I know that 10 Mr. Lord handles more of the HR stuff. So, at that 11 time, I think we did have something from Mr. Guzman. 12 We had something -- an e-mail that we saw earlier from 13 Kelly Mayne to Tammy Kaniho, my secretary, and then Pat 14 Breault had -- at one point, to my understanding, she 15 put something in, but then she decided she was not 16 going to go forward with that. 17 Q. Okay. So, if you had -- I'm asking. Did you 18 have four internal applicants? 19 A. We had four internal applicants get 20 interviewed. 21 Q. At the point in time that you knew there were 22 four applicants, internal applicants, why wouldn't you 23 go to an internal recruitment? 24 A. So, at that time, there were four people on 25 the list that we got from HR. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 138 1 Q. Yes. So, why didn't you go from an open to an 2 internal? 3 A. I don't know if we can do that once we put it 4 out. Once we have those names come in and everybody 5 else has been -- I don't know if we can go from an 6 external to an internal. 7 Q. I appreciate that. 8 But, in any case, I wondered why you didn't 9 consider that. Because I think I remember you saying 10 twice that if they had been -- it had been an internal 11 and they were on the list, that you would have gladly 12 picked from one of them. 13 A. Let me say this. I think what I said -- just 14 clarification -- if they were chosen from the group 15 that got interviewed as the top candidate, or even if 16 they were in that range of really close, I probably 17 would have gladly picked them. 18 Q. So, you didn't have any problem with going 19 internal recruitment? 20 MR. MUKAI: Object to the form of the 21 question. I think it's argumentative, misstates 22 evidence, and I think it's -- 23 MS. NOMURA: Tell me how to ask the question. 24 MR. ROTH: Let me see if I can answer -- let 25 me see -- I wouldn't have had any problem selecting if ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 139 1 they were chosen. 2 BY MS. NOMURA: 3 Q. Right. Okay. So, you could have gone to the 4 internal recruitment? 5 A. I -- 6 MR. MUKAI: Objection. This is asked and 7 answered. 8 CHAIR NAHUINA: I don't believe that that 9 was the question that you asked. 10 MS. NOMURA: Okay. 11 CHAIR NAHUINA: So, maybe you want to 12 reform the question so he can answer it specifically. 13 BY MS. NOMURA. 14 Q. Why didn't you go internal? 15 A. You know, I think that's probably a really 16 good question. At the time, I was listening to, you 17 know, what was going on in HR. I know that we had some 18 letters, you know, some of the things that we looked 19 at, that there was only a certain number of people that 20 put interest in. And it's easier to get the process 21 going than have to go back and forth. 22 I had a -- Mr. Mayne talked about a 23 conversation that he had with me, and it really made me 24 think about that, and I subsequently went internal, and 25 I had to reevaluate again whether I was going to do ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 140 1 that because it was very possible that we weren't 2 going to get enough people. And keeping our office 3 fully staffed is an issue, but it takes a long time. 4 So, initially, let's put it out there. Let's get the 5 best person or the most -- the person with the most 6 merit, the most capable person for the job. I guess 7 that's my best way of answering that question. 8 Q. Ultimately, do you decide whether -- 9 A. Ultimately, the decision comes to me, yes. 10 Q. Did you ever tell the panel that you 11 preferred to hire one person over another person? 12 A. Absolutely not. Absolutely not. And -- 13 Q. You didn't talk to anyone about that? 14 A. Not about who they selected. I wanted the 15 best person out of there. And, again, I was kind of 16 surprised -- you know, looking at it, I was surprised 17 that -- the scores and where our people scored on that. 18 And I expected them to be at the top. 19 Q. You talked about the interview questions. Do 20 you agree, though, that people have different 21 communication skills, and do you agree that in some 22 cases, the person who maybe communicates the best 23 answers may not actually be the one that's doing the 24 best job? Is that a possibly? 25 A. Can you restate that question? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 141 1 Q. Yeah. 2 Is it possible that somebody interviews very 3 well but doesn't have experience to actually do the 4 job? 5 A. Is that possible? Yeah, that possible. If I 6 didn't have to go through the HR rules and everything, 7 I may have been doing it a little bit differently; but 8 we try to follow our rules, you know, the best we can. 9 Q. As far as you know, was there any credit 10 given to these employees for having done the vast 11 majority of the duties required of this job? 12 A. Do they get separate credit compared to 13 everybody else? 14 Q. Other than their answers on the interview. 15 A. I think I have to go with their answers on 16 the interview. The fact they qualified for the 17 position is -- you know, they get that credit, and 18 then, like I said, if they were in a position with 19 their scoring, if they came, you know, pretty high, I 20 probably would have went to that level. 21 Q. But, again, just to clarify, their scoring 22 was based completely on their answers to interview 23 questions? 24 A. I don't know if I can say completely or not. 25 To a great extent. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 142 1 Q. Can I ask to what extent, then? 2 A. I would say at least 90 percent. 3 Q. And the 10 percent was on... 4 A. I think there's some other stuff that -- when 5 I look at the letter -- because the highest person -- 6 if you look in here, the highest person didn't get 7 offered the position. The highest person wasn't 8 selected by the panel. And, you know, I think, in 9 looking at this, there's maybe some questions that that 10 person communicated -- just what you're saying, they 11 communicated really well the answers, but it didn't 12 come off as, you know, what the panel was looking at. 13 Q. How was that determined? 14 A. That's the panel. The panel made that 15 decision. 16 Q. So, you're not sure how they determined that? 17 A. Well, according to their letter that they 18 sent me, it kind of states the reasons. And you read 19 that earlier. 20 Q. Right. 21 So, it didn't raise any question in your mind 22 that, based on what the panel said, as far as the 23 interview, there was no doubt in your mind that it was 24 appropriate to hire the selectee? 25 A. We did hire -- hire this person. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 143 1 I believe that you have got to trust the 2 people you put in there to do the position. They were 3 on a panel. They had to make a decision. They made a 4 decision. I looked at some of the things and said, you 5 know -- so I had some questions, "How come," you know, 6 "this guy had a higher score?" for example. 7 Q. Okay. If you look at the score -- I think 8 this is Exhibit 19 -- those show the scores of each of 9 the interviewees. And I guess the question is where is 10 that 10 percent we're talking about? 11 A. So -- and this is why, you know, it's hard 12 for me to give a number. The numbers are here. It 13 shows you what the scores were. The highest score was 14 348, but the one that the panel came up with was 314. 15 So, they had discretion. So, it's not 100 percent. 16 They can't just say, "Okay, highest score wins." 17 They have to have that discretion to, you know, 18 look at who was most fit for that job and not just 19 go by a set of numbers. 20 Q. So, if the panel were to say, "I like this 21 person better," that's it? That would be justification 22 enough for you, or... 23 A. No. You know, you look at the letter. They, 24 actually, have to articulate reasons -- so it's not, you 25 know, I'm just saying "Okay, I'm going to take ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 144 1 numbers." It's not just, "This guy dressed the nicest" 2 or something like that. They have to articulate a 3 reason for me to look at something that's outside that 4 score as well. And it's interesting because on this 5 panel, that's what they did; they came up with some 6 reasons on why they believed that this person was the 7 most fit for -- you know, most applicable position, had 8 most merit. 9 Q. But you can't quantify that? 10 MR. MUKAI: Objection, asked and answered. 11 MR. ROTH: I don't think we can quantify it. 12 MS. NOMURA: Okay. Thank you. 13 CHAIR NAHUINA: All right. Thank you. 14 Would you like to -- does the Board have any 15 questions? 16 MR. TAM: None. 17 MS. NAMAHOE: None. 18 MR. CHILLINGWORTH: None. 19 CHAIR NAHUINA: I have none. 20 MR. HALVORSON: I just want to clarify one 21 thing just to determine... 22 23 EXAMINATION 24 BY MR. HALVORSON: 25 Q. You mentioned that the applicant was from ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 145 1 this jurisdiction. By that, you meant from the island 2 of Hawai ʻ i? 3 A. Yeah. He was living on the island; he was 4 working on the island. 5 Q. You weren't referring to the term of art used 6 in collective bargaining where the jurisdictions are 7 State of Hawai ʻ i, various counties, Hawai ʻ i Health 8 System Corporation? Those are all considered 9 different jurisdictions. 10 A. Okay. No, I was -- 11 Q. You were using a generic term? 12 A. A generic term. And I think, by the way -- 13 it's my belief he's also -- he was at that time an HGEA 14 member, too. 15 Can I just state one other thing? Well, I'll 16 let my attorney... 17 18 REDIRECT EXAMINATION 19 BY MR. MUKAI: 20 Q. Okay, Mr. Roth, you mentioned you've got to 21 state one more thing. Can you again describe for the 22 Board -- I know this is a tough process. Your office 23 is being accused of now rigging this whole process and 24 fixing it, corruption. I heard the term "corruption." 25 What do you think about all that? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 146 1 A. I was trying to make this as fair, as 2 transparent, as possible. If you look at the people 3 that I put on this -- you know, this panel, I -- you 4 know, I haven't heard any critiques about, you know, 5 the character/the quality of people. You know, having 6 an ethics, you know, officer on the board to make sure 7 that, you know, nothing funny is being done, I think 8 that was kind of important. I wanted to have a fair 9 process because the position of the investigative 10 supervisor is important to the office and important to 11 our County; so, I wanted to get the best and the most 12 merit-based, I guess that secret word you have there. 13 And, you know, I got to say I've had 14 committees -- and these investigators know that not 15 everybody in my office sometimes will side with me on 16 things. When I ran for election, I had people that 17 were on the other side, one of which was the previous 18 investigative supervisor. I put him on those panels 19 even after, and there wasn't a single decision that he 20 made that I went against. 21 I think it's important that you have a fair 22 process, and that's what I try to do. 23 MR. MUKAI: Okay. 24 CHAIR NAHUINA: Thank you. 25 MS. NOMURA: One question for Mr. Roth. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 147 1 RECROSS EXAMINATION 2 BY MS. NOMURA: 3 Q. I'm referring to Communication No. 17-04.02. 4 And this was in Mr. Mayne's appeal. It's a response to 5 questions -- I guess it's one, two, three, four, five, 6 six pages in, and it's question No. 20. The question 7 is: Was the panelist approved by the County of Hawai ʻ i 8 Department of Human Resources? 9 And the answer to that question is found 10 further down. 11 MR. MUKAI: Ms. Nomura -- 12 MR. ROTH: Where are you? 13 MR. MUKAI: -- I'm sorry, where are you? 14 MS. NOMURA: Mr. Mayne's submittal. 15 MR. MUKAI: Okay. 16 MS. NOMURA: And it's in response to the 17 grievance that was filed on Mr. Mayne's behalf. 18 MR. ROTH: I'm sorry. So what number is it? 19 MR. MUKAI: No. 20. 20 MS. NOMURA: Yeah, question No. 20. 21 MR. ROTH: I don't have a question. I 22 just... 23 MS. NAMAHOE: 17-04.02? Which page? Because 24 it's voluminous. 25 MS. NOMURA: It's actually one, two, three, ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 148 1 four, five, six, seven -- the seventh question. 2 MS. NAMAHOE: Thank you. 3 MR. ROTH: So -- 4 BY MS. NOMURA: 5 Q. And after that comes your answer. 6 A. Okay. 7 Q. And I just want to verify that your answer is 8 "No." 9 A. So, let me clarify. When I talked to 10 Mr. Leopoldino, I didn't say no, I'm going to pick Pat 11 Breault; I'm going to pick Deborah Chai; I'm going to 12 pick, you know, Doug Adams; I'm going to pick Larry 13 Weber. I just asked them if this is okay. And he 14 brought the procedures. We looked them up. And 15 that's -- so the panelists -- that is correct -- the 16 names of panelists, no, that wasn't approved. 17 MS. NOMURA: Thank you. 18 CHAIR NAHUINA: Any redirect? 19 MR. MUKAI: No, thank you. 20 CHAIR NAHUINA: So, at this time, do you 21 have any more witnesses -- 22 MR. MUKAI: Yes. 23 CHAIR NAHUINA: -- you would like to call? 24 MR. MUKAI: Can we take a quick break? I'm 25 just going to -- can we go off the record? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 149 1 CHAIR NAHUINA: Do we need to have a 2 motion? 3 At this time, we're off the record. 4 (Off the record.) 5 CHAIR NAHUINA: Back on the record. It's 6 2:19. 7 MR. MUKAI: We call Wil Okabe. 8 MR. HALVORSON: I think this is already in 9 the record. 10 MR. MUKAI: Probably, but just for the 11 panel's -- so... 12 MR. HALVORSON: So, we don't have to fumble? 13 MR. MUKAI: Right. 14 I'll call Mr. -- 15 MR. HALVORSON: Glynis, what number is that? 16 MS. YAMADA: 17-04.10. 17 MR. HALVORSON: Thank you very much. 18 CHAIR NAHUINA: Thank you. 19 20 WIL OKABE, 21 having been first duly sworn to tell the truth, the 22 whole truth and nothing but the truth, was examined and 23 testified as follows: 24 25 ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 150 1 DIRECT EXAMINATION 2 BY MR. MUKAI: 3 Q. Please state your name for the record, 4 please. 5 A. Wil Okabe, Managing Director for the County. 6 Q. Now, Mr. Okabe, at some point in time, you 7 were tasked with reviewing Mr. Roth's decision at the 8 Prosecuting Attorney's Office regarding the selection 9 of the Investigator VI. Do you remember that? 10 A. Yes. 11 Q. And can you describe -- well, let me ask you 12 what do you do at the County of Hawai ʻ i? 13 A. Managing director is in charge of all 14 departments in the County. The mayor has instructed me 15 to do all complaints and all personnel issues in the 16 County. Everything. 17 Q. Now, with regard to Mr. Daniel Pang, who 18 applied for the Investigator VI position at the Office 19 of -- the Prosecuting Attorney's Office, at some point 20 in time, do you remember doing a review of the 21 Prosecuting Attorney's Office and its process regarding 22 the selection of the Investigator VI position? 23 A. Yes. 24 Q. And can you briefly describe for the Board 25 what it is you did? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 151 1 A. By the time it gets to my office, it has gone 2 through a certain process; so, I think they meet with 3 the department first, and then after the department 4 comes to the managing director to render any decisions 5 in regards to, if we concur with the person who is 6 making the complaint, or if we want to just refer it to 7 the Merit Appeals Board. 8 So, if that were the case, I just was able to 9 just make some calls in regards to HR and to find out 10 if the process was fair and to be sure that the 11 employee was given an opportunity to apply for the 12 position. 13 Q. Now, take a look at the County's exhibits, 14 County 1 through 13. If you could just take a look 15 through that. And I would ask if those were documents 16 that you believe you reviewed. 17 A. Yes. There was a lot of material in this 18 particular case. But I would just like to add, you 19 know, when we took over -- myself -- Harry Kim and 20 myself took -- December 5th, we had made some changes 21 with regards to the hiring process of the County. So 22 as far as trying to look at the process, making sure 23 that the people did the -- whoever did the interview, 24 we required them to go through some training and 25 ensuring that the process was basically fair. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 152 1 So, in this case, as I'm listening to it on 2 the outside now, you know, there was a lot of words 3 that were being used. There was no person of interest 4 from the mayor's office in regard to this particular 5 complaint. 6 Q. Did you see any corruption? 7 A. No. That -- when I heard that today, that 8 concerns me because this administration has done 9 everything we could to try to make sure that the 10 process was fair. Now, I'm very concerned about that. 11 And -- 12 Q. Now, it's not like you met and re-interviewed 13 everybody who applied, right? 14 A. No. 15 Q. Okay. So, what was your conclusion in terms 16 of what the prosecuting attorney did in its hiring of 17 the Investigator VI position? 18 A. In my opinion, I thought that everything was 19 done professionally, and I felt that the process was 20 done fairly. And I felt that the next process was 21 going to -- because this has happened before -- that I 22 reviewed some complaints, and it was our office who 23 decided if it was going to sustain the recommendation 24 by the prosecutor's office. 25 Q. Okay. Now we're going to hand you what has ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 153 1 been marked next in order. I think it's already in 2 evidence, but just for the panel's information, I've 3 handed out to the union as well as panel members what's 4 been marked as an exhibit already. It's an 5 August 17th, 2017 letter. 6 What is this letter? 7 A. This is a letter that -- it's basically a 8 standard letter. It's informing the party that we 9 concur with the decision made by the department and 10 that if the Complainant had a disagreement, they could 11 proceed to go to the Merit Appeals Board. 12 Q. And that's your signature? 13 A. Yes. 14 MR. MUKAI: Okay, thank you. I have nothing 15 further. 16 CHAIR NAHUINA: Thanks. 17 Ms. Nomura, do you care to cross-examine? 18 MS. NOMURA: No questions. 19 CHAIRMNAHUINA: Board Members? Any 20 questions? 21 MS. NAMAHOE: None. 22 MR. TAM: None. Thank you. 23 MR. CHILLINGWORTH: None. 24 CHAIR NAHUINA: I have none. 25 Thank you very much. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 154 1 MR. MUKAI: Okay, thank you. 2 We would call Ms. Barbara Kossow. 3 CHAIR NAHUINA: Barbara Kossow. 4 (Whereupon Ms. Kossow was called on the 5 speaker phone.) 6 CHAIR NAHUINA: Hello, Barbara. This is 7 David Nahuina. I'm the Chair. I'd like to swear you 8 under oath today. 9 (Whereupon Chair Nahuina attempted to 10 administer the oath to Ms. Kossow.) 11 MR. TAM: She might not be able to hear you. 12 CHAIR NAHUINA: Barbara, can you hear me? 13 Barbara, can you hear me? 14 MS. KOSSOW: Yeah, I can hear you now. 15 CHAIR NAHUINA: Okay. 16 17 BARBARA KOSSOW, 18 having been first duly sworn to tell the truth, the 19 whole truth and nothing but the truth, was examined and 20 testified as follows: 21 22 DIRECT EXAMINATION 23 BY MR. MUKAI: 24 Q. Ms. Kossow? 25 A. Yes. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 155 1 Q. This is John Mukai. I just have some 2 questions for you. 3 Could you please -- she's been sworn? 4 CHAIR NAHUINA: Yes, she has. 5 BY MR. MUKAI: 6 Q. Ms. Kossow, could you please describe for the 7 Merit Appeals Board your name and your position? 8 A. Okay. Barbara Kossow, Deputy Managing 9 Director. 10 Q. And can you briefly describe for the Board 11 what your duties are? 12 A. My duties are pretty much anything that is 13 assigned to me by the mayor to handle, so... 14 Q. Okay, I understand. 15 Now, at some point in time -- and to make 16 this go quicker, I'm going to ask about both Mr. Guzman 17 and Mayne at the same time. 18 Ms. Kossow, at some point in time, you were 19 involved in the review of the prosecuting attorney's 20 hiring of an Investigator VI. Is that correct? 21 A. Yes. 22 Q. And do you remember at some point meeting 23 with Mr. Clement Guzman? 24 A. Yes. 25 Q. And it appears that on the same date, you met ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 156 1 with Mr. Kelly Mayne? 2 A. Yes. 3 Q. Can you briefly describe for the Board what 4 steps you took or what you did in your review of the 5 prosecuting attorney's decision regarding the hiring of 6 the Investigator VI position? 7 A. Okay. I received the file regarding both 8 gentlemen, and I called -- I called Human Resources 9 before I started reviewing it, and I needed to know 10 what the guidelines were and if we were in compliance 11 with the guidelines. So, that's the reason why I called 12 HR. 13 Q. And for the same -- see, you're not here, but 14 I believe you -- did you review the County's Exhibits 1 15 through 13 in your review of the process? 16 A. Yes. 17 Q. It is not like you went in and did your own 18 interview of any of the prospective applicants. Is 19 that correct? 20 A. That's correct. 21 Q. What did you find after you performed your 22 review of the hiring of the Investigator VI by the 23 Office of the Prosecuting Attorney? 24 A. Okay. So, you're asking me after I reviewed 25 the paperwork and also my talking with both gentlemen? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 157 1 Q. Yes. 2 A. Okay. When I went through the process, I 3 could not see that we -- that anything was out of line. 4 I also reviewed the test scores. Of course, I didn't 5 see any names. And I had discussions with both 6 gentlemen regarding that part of it and listening to 7 them talk about this particular investigation. 8 Q. With respect to Mr. Guzman, did you find that 9 the Office of the Prosecuting Attorney did anything 10 improper regarding the process or the selection of the 11 Investigator VI position? 12 A. No, I didn't see that. 13 Q. And, in fact, on August 10, 2017, you wrote a 14 letter to Mr. Guzman, and that details your review. Is 15 that correct? 16 A. That's correct. 17 Q. And for the Board and for the opposing side, 18 I have made this available as either the next exhibit 19 in order, or it is probably in evidence. 20 Same question with regard to Kelly Mayne. 21 A. Uh-huh. 22 Q. After your review of the prosecuting 23 attorney's selection of the Investigator VI, did you 24 believe that there was anything proper with regard to 25 Mr. Mayne's complaint to you? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 158 1 A. Okay. You said "improper," right? 2 Q. Yeah, was there anything improper after your 3 review -- 4 A. No. 5 Q. -- of what the prosecutor -- 6 A. No. 7 Q. After -- 8 A. No. 9 Q. -- what the prosecuting attorney did? 10 The answer is "No," right? Is that correct? 11 A. No. That's correct. 12 Q. And, in fact, on August 10, 2017, you also 13 wrote a letter to Mr. Mayne, which -- 14 A. Correct. 15 Q. And this letter details your review of what 16 the prosecuting attorney's actions were in the 17 selection of the Investigator VI position. Is that 18 fair? 19 A. Yes. 20 MR. MUKAI: Okay, that's it. I have nothing 21 further. 22 MR. HALVORSON: Again, just to make sure the 23 record is clear, the two documents you just submitted, 24 I guess, would be next in order? They would be 25 17-04.11 -- ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 159 1 MS. YAMADA: Correct. 2 MR. HALVORSON: -- and 1704.12? 3 MS. YAMADA: Well, I have 1704.10 for the 4 Daniel Pang -- 5 MR. HALVORSON: Right. 6 MS. YAMADA: -- letter, and so the Kelly Mayne 7 letter would be 17-04.11. 8 MR. HALVORSON: And then the Guzman letter 9 would be? 10 MS. YAMADA: The Guzman letter would be .12. 11 MR. HALVORSON: .12. Okay. 12 And I think you're right. I think they are 13 already in evidence, but since you put it again, I want 14 to make sure we have a number, so... 15 CHAIR NAHUINA: Thank you. 16 MS. NOMURA: Are we still on? 17 CHAIR NAHUINA: Yes, we are. 18 MS. NOMURA: I don't have anything. 19 CHAIR NAHUINA: Thank you. 20 Any questions by the Board? 21 MR. TAM: No. 22 MS. NAMAHOE: No. 23 CHAIR NAHUINA: I have none. 24 MR. MUKAI: I have nothing. 25 Ms. Kossow, thank you. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 160 1 MS. KOSSOW: Yes, thank you. 2 MR. MUKAI: That's it. 3 CHAIR NAHUINA: At this time, do you have 4 anything further? 5 MR. MUKAI: No. 6 CHAIR NAHUINA: At this time, do you have 7 any rebuttal evidence? 8 MR. MUKAI: No. 9 MS. NOMURA: We would like to say something. 10 MR. HALVORSON: We're just talking about 11 evidence. 12 CHAIR NAHUINA: Just evidence. And you 13 will have the opportunity for closing. 14 MS. NOMURA: And I do have the specs. for the 15 V and the IV. 16 CHAIR NAHUINA: Would you like to enter 17 that? 18 MS. NOMURA: Yes. 19 CHAIR NAHUINA: So, that would be -- you 20 would like to introduce them as an exhibit? 21 MS. NOMURA: Yes. 22 CHAIR NAHUINA: Did you make copies? 23 MR. HALVORSON: Did you make copies? 24 CHAIR NAHUINA: Did you make copies? 25 MS. YAMADA: I can make copies now. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 161 1 MR. HALVORSON: Well, in the interest of 2 time, maybe you can just show them to Mr. Mukai. 3 MS. NOMURA: I don't think there's any 4 dispute. It is what it is. 5 MR. HALVORSON: We can clean up the record 6 later by putting in copies, but please show them to 7 Mr. Mukai. 8 MS. NOMURA: Sure. 9 MR. MUKAI: I don't have any objection. 10 CHAIR NAHUINA: All right. We need to 11 have a number for that. Glynis? 12 MS. YAMADA: So, the investigator specs. for 13 what item? 14 MS. NOMURA: IV and V. 15 MS. YAMADA: IV would be Communication .13, 16 and then the V position would be .14. 17 CHAIR NAHUINA: Thank you. 18 Is there any additional evidence or exhibits 19 to be entered into the record at this time? 20 MS. NOMURA: No. 21 CHAIR NAHUINA: Then we'll be moving into 22 closing arguments. And the Appellants -- you will be 23 presenting first. 24 MS. NOMURA: Thank you. 25 You know, I think what we've presented today ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 162 1 is that there were real considerations that should have 2 been made for employees who were working -- I told you 3 that it's such a -- it's such a close relationship in 4 the classification of the jobs that there's no way that 5 you can completely ignore that in the process. I know 6 the scores go to the interview process, but there 7 should be something in there other than asking 8 questions to give the employee or the applicant, who 9 happens to be an employee, credit for actually having 10 done the majority portions of the job. And that's 11 lacking. 12 Mr. Roth stated that he could have gone -- 13 that was his discretion -- he could have gone to an 14 internal recruitment. And that would have been fair. 15 He stated twice that he would have picked one of these 16 applicants, internal applicants, if that internal 17 recruitment had occurred. So, the question is why 18 didn't he? Why didn't he do that? And that's the 19 basis. 20 We've seen a lot of things that we questioned 21 as whether it was fair, whether it was appropriate, in 22 the panel designation -- not who the panel -- I know 23 Mr. Mukai has said a couple of times it wasn't somebody 24 from McDonald's. We never, ever intimated that we had 25 a problem with the persons who were on the panel. It ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 163 1 was strictly on the process and procedures that were 2 outlined by the County and by the department on who 3 should have been on the panel. And that, I think, is a 4 serious consideration, that there were two people from 5 outside the department, there was one person who was at 6 the same level as the applicants -- who was really 7 selecting her boss. So, you know, those are real 8 inconsistencies that shouldn't just be brushed aside. 9 The fact that, you know, they had a document 10 that shows that the persons were not -- they weren't 11 adequate -- there wasn't adequate interest from within 12 the department -- and that was wrong. There turned out 13 to be four applicants. I think at any point, the 14 department could have chosen to go internal, and that 15 would have been fair. So, we didn't see things 16 happening that should have happened, if this was a fair 17 interview and selection process. 18 So, that is the concern of each of the 19 applicants here. You know, they're just trying to get 20 what they thought was supposed to happen in the civil 21 service -- the opportunity for advancement. Yeah, they 22 were allowed the opportunity to apply, but if they're 23 not given credit for the work that they've been 24 performing, if they're not even given that, the civil 25 service merit system means nothing as far as in the ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 164 1 area of recruitment. And that's where this action was 2 so wrong. 3 For that reason, we're asking -- we're really 4 appealing -- to you to redo this, to make it right. 5 We'd like a new interview, a new selection process, 6 based on an internal complaint recruitment that we feel 7 should have been done that would have answered all the 8 questions we're here with today. 9 Now, it shouldn't be based on today and who 10 applies today. It should have been who applied at that 11 point in time, who applied internally at that point in 12 time, and for the department to look at these people as 13 the most qualified for that job and give them credit 14 for that as is their due in the merit system. We're 15 not saying they have to hire one person, that one 16 person should be promoted, but they should have been 17 given a fair opportunity. That didn't happen. Not in 18 this case. So, we're asking a redo going back to that 19 point in time, and the four people who internally 20 applied for the position, they should be considered and 21 an interview process should be held. There is some 22 urgency to this because there's a list. They are 23 eligible for this list now. That expires in May. So 24 it has to happen -- if it's going to be fair, it has to 25 happen before that. That's what we're asking for. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 165 1 That's one thing. 2 The other thing is this is -- you know, it 3 took a lot, I think, for these people to come to you, 4 because they're going up against their department. And 5 not to say anything against Mr. Roth or -- that is not 6 the point, but it's really difficult for a subordinate 7 to speak out against his boss, much less the big boss, 8 but they were willing to do it because they really 9 believe this is wrong. And when they came to the union 10 and explained their case, we believed that it was 11 wrong. I really feel that this is something that 12 should not have happened. So, we ask that you take care 13 of it, but also that we want to convey that we hope 14 that there isn't any kind of retaliation against these 15 employees for coming forward because that would really 16 send a message to people not to come to you, and we 17 don't want that to happen. And we're not accusing the 18 department of anything, but it's just something, I 19 think, that has to be said because they are speaking 20 out against their bosses, and we know that shouldn't 21 happen, but sometimes it does. So, we really ask 22 that -- we want to make that statement and -- you know, 23 make it to the department, that we would hope that 24 there isn't any kind of retaliation against the 25 employees or any kind of adverse action as a result of ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 166 1 this. 2 But beyond that, we thank you for your time, 3 and we hope you really will consider this in the way 4 that it should be. Thank you very much. 5 MR. MUKAI: Okay. Briefly. Thank you. 6 Ms. Nomura just talked about challenging the 7 process. The union, HGEA, looked at it; they want to 8 challenge the process. Again, the process is via the 9 collective bargaining agreement. That's the reason 10 she's here. They have union representation. They 11 should have gotten it through the promotion provision 12 under the collective bargaining agreement. 13 The problem in a case like this is if the 14 person who has been selected is now told, "Oh, by the 15 way, you're out. You're out now," it's not fair. That 16 is not how this process works. That's why we have the 17 collective bargaining agreement. 18 Now let's talk a little bit about selection 19 of the best available candidate. The evidence is 20 clear. Pursuant to HRS 76-1, the Merit Principle is 21 the selection of persons based on their fitness and 22 ability for public employment and is based on their 23 demonstrated conduct and performance. And it's also 24 about discrimination in the examination and the 25 appointment. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 167 1 The selection is impartial -- and it was 2 impartial. The prosecuting attorney has discretion 3 whether or not to submit it to internal or external 4 recruitment. And what happened at the time, there was 5 only one letter from Mr. Guzman saying, "I have 6 interest in the position." There was also an e-mail to 7 the secretary saying, "Let me know when this position 8 opens up." And another investigator withdrew their 9 application for the Investigator VI position. Under 10 these circumstances, it is more than reasonable to open 11 up the recruitment to an external recruitment. In 12 fact, there were 12 candidates that were screened and 13 met the minimum qualifications and eligible to 14 participate in the interview process. 15 The interview process was fair. Doug Adams' 16 testimony is -- he's a former investigator with HPD. 17 MR. ROTH: Weber. 18 MR. MUKAI: I'm sorry. Mr. Weber was a 19 former investigator with HPD -- I'm sorry, I can't read 20 my notes -- and retired as an investigator. He 21 provides (unintelligible) and provides a basis to 22 evaluate each person who interviewed for the position. 23 There's nothing that prohibited these three gentlemen 24 from applying. In fact, they were urged to apply. You 25 heard Mr. Roth say, "I wish one of them would have ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 168 1 gotten it." 2 Mr. Roth does not play politics and favor -- 3 and that's clear. He recommended -- he was recommended 4 to another individual by an unbiased board who 5 conducted the interviews and evaluation of all the 6 candidates and, unfortunately, they were not selected. 7 Mr. Adams is the Ethics Board person; so, 8 obviously, there is going to be nothing untoward or 9 illegal going on. The word "corruption" -- you know, 10 basically, after review of this case and my review of 11 what happened, I think it's just offensive to the 12 County to make that assertion. The process was fair, 13 and the Merit Appeals Board is urged to render a 14 decision accordingly. 15 CHAIR NAHUINA: Thank you. 16 Ms. Nomura, do you have a rebuttal argument 17 in closing? 18 MS. NOMURA: No. I think I said enough. 19 Thank you. 20 CHAIR NAHUINA: Thank you, both parties. 21 This hearing is ended. The Board will now enter into 22 deliberations. Thank you very much. 23 Do I need a motion for Executive Session? 24 MR. TAM: I move that we enter into Executive 25 Session. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 169 1 MS. NAMAHOE: Second. 2 CHAIR NAHUINA: It is moved and seconded 3 that we go into Executive Session for deliberations. 4 All those in favor say "Aye." 5 (All Board Members responded affirmatively.) 6 CHAIR NAHUINA: All those opposed, same 7 sign. 8 Move into Executive Session. 9 (Executive Session ensued from 2:48 p.m. to 10 3:16 p.m.) 11 CHAIR NAHUINA: Thank you very much. It 12 is 3:16, and we are back out of Executive Session. 13 As the Chair, I would like to recommend 14 denial of the appeal. Do I hear a motion? 15 MR. CHILLINGWORTH: Mr. Chairman, I move that 16 the consolidated appeals of Mr. Guzman, Mr. Mayne, and 17 Mr. Pang be denied. 18 MR. TAM: I second. 19 CHAIR NAHUINA: It's moved and seconded. 20 All those in favor say "Aye." 21 (All Board Members responded affirmatively.) 22 CHAIR NAHUINA: All opposed, same sign? 23 Motion carries. 24 MR. HALVORSON: For the parties, a written 25 decision will be issued shortly. It will be available ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 170 1 for your review. 2 When I say "shortly"... 3 MR. MAYNE: Thank you. 4 MR. PANG: Thank you. 5 MR. GUZMAN: Thank you. 6 (The Appellants and Ms. Nomura exited the 7 room.) 8 CHAIR NAHUINA: At this time, we're going 9 to move on to unfinished business. 10 We have a request to reschedule our hearing 11 March 21st. 12 MR. MUKAI: I can represent to the Board that 13 Mr. Makaio called me. He is also in receipt, and he is 14 not -- as I said, I will not be available, I think, 15 from the period April 18 through the 26th, or something 16 like that; but he is agreeable to May, whenever the 17 Board meets in May. And I said I can make that 18 representation and that he not show up -- Mr. Makaio. 19 MS. NAMAHOE: There's a high likelihood I 20 will not be able to make any date of May because it is 21 a strong open enrollment time for me, some of my 22 (unintelligible). 23 MR. HALVORSON: Do you want to meet on 24 Saturday or Sunday? 25 MS. NAMAHOE: Right? ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 171 1 Just May is a difficult month. 2 MR. MUKAI: Okay, that's fine. I leave it up 3 to the Board whether you schedule it in May. 4 CHAIR NAHUINA: As I look at my schedule, 5 the first two weeks of May are better for me -- are 6 okay for me. The last two weeks I cannot. 7 MR. CHILLINGWORTH: So, early May? 8 CHAIR NAHUINA: Early May. Are you open? 9 MR. TAM: Right now, I am. 10 CHAIR NAHUINA: The 1st through the 8th. 11 May Day is the 1st. 12 MR. TAM: What day? Oh, we're looking at a 13 Tuesday? 14 CHAIR NAHUINA: Tuesday, yes. 15 MR. TAM: Oh, Tuesday is tough for me. 16 CHAIR NAHUINA: We should go the second, 17 right? The second Wednesday? Glynis? 18 MR. TAM: It's usually the second Wednesday, 19 right? 20 MS. YAMADA: Yes. 21 CHAIR NAHUINA: That would be the 9th, 22 back on tradition. 23 Will we have a place -- 24 MS. YAMADA: Normally, MAB meets the third 25 Wednesday -- ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 172 1 CHAIR NAHUINA: Oh, third Wednesday. 2 MR. HALVORSON: But that's getting into your 3 difficulty. 4 CHAIR NAHUINA: That is, so -- 5 MR. TAM: We can do May 9th. 6 CHAIR NAHUINA: May 9th? 7 MR. TAM: Yeah. 8 MS. NAMAHOE: I cannot. 9 CHAIR NAHUINA: We'll have quorum. We 10 will. May 9th. 11 All right, so let's schedule that for May 12 9th. 13 MS. YAMADA: Location to be determined. 14 And deadline? 15 CHAIR NAHUINA: Deadline for submission 16 two weeks prior, so that will take us April 25th. 17 MR. TAM: Good. 18 MR. HALVORSON: Submission of exhibits and 19 witness lists? 20 MR. TAM: Yes. 21 CHAIR NAHUINA: Yeah. 22 MR. HALVORSON: Glynis, will you make sure 23 that the Appellant knows about that? 24 MS. YAMADA: I'll send him a certified 25 letter, as well as to Mr. Mukai. ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 173 1 CHAIR NAHUINA: Any other... 2 So, I just want to announce our scheduled 3 meeting dates. Merit Appeals Board will convene 4 meetings on the follows dates: We have special 5 meetings, Merit Appeals Board, on Monday, February 12th 6 at 9:00, Puna Conference Room. Also, on Thursday, 7 February 15th, at -- excuse me, there is a correction. 8 Monday, February 12th will be at 10:00, right? And 9 then Thursday, February 15th, is at 9:00 in the Puna 10 Conference Room, County Building, 25 Aupuni Street. 11 And on Wednesday, February 21st, 2018 at 10:00 at the 12 Department of Human Resources conference room. 13 Any other additions? 14 MR. TAM: Nope. 15 MS. YAMADA: Just a question. What time will 16 the hearing be for Mr. Makaio on May 9th? 17 CHAIR NAHUINA: 9:00. 18 MR. HALVORSON: 9:00. 19 CHAIR NAHUINA: 9:00. 20 Any other unfinished business? 21 Do I hear a motion to adjourn? 22 MR. CHILLINGWORTH: So moved. 23 MS. NAMAHOE: Seconded. 24 CHAIR NAHUINA: Moved and seconded. 25 All those in favor say "Aye." ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 174 1 (All Board Members responded affirmatively.) 2 CHAIR NAHUINA: Opposed, same sign. 3 Motion carried. Meeting adjourned. And it's 4 3:23. 5 (The Merit Appeals Board meeting concluded at 6 3:23 p.m.) 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Page 175 1 STATE OF HAWAII 2 ss. 3 COUNTY OF HAWAII 4 5 I, TERI HOSKINS, a certified court 6 reporter in the State of Hawaii, do hereby certify 7 that the foregoing pages are a true and correct 8 transcription of the proceedings in the above matter. 9 10 Dated this 22nd day of February, 2018. 11 12 13 R, CSR No. 452 14 15 16 17 18 19 20 21 22 23 24 25 ISLAND COURT REPORTING & TRANSCRIPTION SERVICES (808) 933-9800 Ms. Teri Hoskins, Certified Court Reporter, transcribed the aforementioned proceedings of the Merit Appeals Board at its meeting held on February 7, 2018. Glynis Yamada, Secretary, Merit Appeals Board, had incorporated some minor formatting/housekeeping revisions throughout the transcript. (The following individuals were also present at the meeting: Mitchell Roth, Barbara Kossow, Clement Guzman, Kelly Mayne, Daniel Pang,Nora Nomura, and Moana Hokoana.) Respectfully Submitted, lit /I Ina; Glynis Yamada, Secretary APPROVED: David K. S. Nahuina, Acting Chair Merit Appeals Board