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4)Submission of the City of Prior Lake in Response to the Order of Judge <br />Solum dated 11/6/95; and <br />5)Amended Response to Court’s Order of November 6, 1995. <br />Plaintiffs also incorporate by reference in their response the following documents; <br />1)Plaintiffs ’ Post Trial Memorandum on Remedies and Damages, filed and <br />served on July 28, 1995; and <br />2)Plaintiffs ’ Reply Brief on Remedies and Damages, filed and served on August <br />15, 1995. <br />Plaintiffs respectfully request that the Court consider these two documents as part of this <br />response. <br />BACKGROUND <br />The tests utilized in the MPRS battery are heavily based on exclusive use of tests of <br />cognitive abilities. While such tests are of value in police officer selection, there are attributes <br />other than cognitive ability that are also valid for use in selection of police officers, and which <br />have been used to mitigate the adverse impact of cognitive tests while contributing to improved <br />validity by measuring qualities important to the job that are not measured by cognitive tests. <br />In the past ten years there have been significant changes in the types of tests being used <br />for entry level police officer hiring. Advances in psychological testing and in the use of <br />biographical (life history) questions have provided alternatives that have been used to supplement <br />cognitive testing for police officer Jobs. In addition, there have been advances in the use of <br />video-based tests for police officer selection. <br />These alternatives were not in use seventeen years ago when the MPRS testing <br />procedures were developed, but they are in use today. Video-based tests, such as the Front <br />52111