ss. state of ohio state of ohio )) ss. county of cuyahoga) now comes harvey s. rosen, ph.d., after...

STATE OF OHIO )) SS.

COUNTY OF CUYAHOGA)

Now comes Harvey S. Rosen, Ph.D., after being duly s

deposes and says:

AUG

1. Affiant is an economist who has been requested to provide an expert opinion in

the case lcnown as State, ex rel. William W. Weaver v. Board of Commiss•ioners of Lake Cotsnty,

Ohio, et al., Ohio Supreme Court, Case No. 08-0697.

2. Affiant's Curriculuni Vitae, which is attached hereto as Exhibit "A", identifies

Affiant's education, work experience and professional writings.

3. Affidavit reviewed and did the following in preparation of his report:

The 2006 Lake County Department salary schedule.The 2008 Lake County Department salary schedule.June 7, 20071etter from Judge William W. Weaver to the Board of Lalce County Commissionersand attached schedules.Interview and conversations with Lake County persomiel.Contract between the Ohio Patrolmen's Benevolent Association and the Lalce County SheriffsDepartment, dated April 1, 2005.Contract between The Communication Workers of America, AFL -- CIO local 4340 and theLake County Sheriff s Department, dated April 1, 2005.

The examination of comparative salary data consisted of three different analyses. The firstanalysis was a validation of the findings reported by Judge Weaver in his June 7, 2007 letterto the board of Lake County Commissioners; the second analysis, the "average analysis"employed a similar method utilized by the Judge's 2007 report; and the third analysis utilizedstatistical regression analysis to analyze intra-department salary differences.

4. Each opinion expressed by Affiairt within the report is to a reasonable degree

of economic and statistical certainty of Aff ant's profession.

5. Affiant's Preliminary Report Concerning the Salary Deficiency Calculations of

the Lake County Juvenile Court is attached hereto as Exhibit "B".

FURTHER AFFIANT SAYETH NAUGIJT.

SWORN TO BEFORE ME and subscribed in inypresence this oU r4^ay of

August, 2008.

NO- ARY PUBLIC

GERALD R. WAI,.Y'OM, AttorneyNOTARY PUBLIC - STATE OF OHIO

My commission has no expiraPion da9®,Suioti 827.03 Q.R.r-

CURRICULUM V1TAE

January 2008Harvey S. Rosen, Ph.D.

Business Address:

Business Phone:

BURKE, ROSEN & ASSOCIATES2800 Euclid Avenue, Suite 300Cleveland, OH 44115(216) 566-9300

E-mailEducation:

[email protected]

B.B.A. Westem Reserve University 1964M.A. Westem Reserve University

University of Califomia Berkeley 1966Ph.D. Case Western Reserve University 1969

Academic Expetience:

196!

1967 - 1969.1969-19731974-19931993- 199411/94- _1999-Present

Lecturer, Western ReserveUniversityLecturer, Cleveland State UniversityInstructor, Cleveland State UniversityAssistant Professor, Cleveland State UniversityAssociate Professor, Cleveland State UniversityRetired Associate Professor•Associate Professor EmeritusAdjunct Associate Professot; John Carroll University

-American Economic Association- National Association of Business Economists

-Ohio Association of Economists and Political Scientists- At Large Representative to the Executive Board 1995-96

Honors and Awards:

- Recipient of United States Government Fellowship for Graduate Education (NDEA), 1966-1969

- Runner-up - Dissertation Fellowship - Federal Reserve Bank of Cleveland, 1968- Omicron Delta Epsilon - Honorary in Economics, 1965- Beta Alpha Psi - Honorary in Accounting, 1964

Court and Governmental AppointmentsoFranklin County Common Pleas Court as Class Economist - Georgia Pacific Litigation 2002Hamilton County Common Pleas Court as Special Master-Bengals Litigation 2001Hamilton County Common Pleas Court as Special Master - A & D Building Litigation 1997Federal Court, Southem Dishict of Ohio - Pfizer Heart Valve 1994Federal Bankmptcy Court, Cincinnati - Eagle- Pitcher Reorganization 1992Hamilton County Common Pleas Court - BASF Chemical Plant Explosion 1992Montgomery County Common Pleas Court - CSX Train Derailment, Mianilsburg, OH 1991Attorney General's Office, State of Ohio -

Innocent Victims of Crime Compensation Program 1983State Court, Kentucky - Beverly I-Iills Supper Club Fire 1980Federal Court, Southern District of Ohio - Beverly Hills Supper Club Fire 1980

Exhibit-1-

G 6 A»

Private Distributions:Cincinnati Pressman LitigationCincinnati Carriers LitigationIndian Creek ElevatorOhio Valley Fireworks

Limited FWnd/Fairvess Hearina Analvsis & Testimony:

Eagle-PitcherAcromedInterneuron (Redux)TelectronicsAmerican Home Products (Pfen-fen)Sulzer MedicaMicrosoft (Consumer Case 2001)UPS EV Settlement (2004)

Articles and Publications:

198419971993-941998

1993 Educational Attainment as a Distributable Asset,Valuine Professional Practices and"Valuing .̀Licenses:^ A Guide For The Matrimonial Practitioner, Edited by Ronald L. Brown; Copyright 1993,Prentice Hall Law & Business, co-authored.

1991 Co-editbr Handbook of Financial Planning for Divorce and Separation, 1992 Suppl`ement;'Ed.'John Wiley &Sons, Inc., New York, NY, with J.F.B.

"Uniform Child SuppotS Guidelines", Financial Plannine forDivorceand Separatioii,Crumbley Apostolov, t' -•

. Ed., second edition. .. . - : . •". ' - .. .. . . , .. , . . . .

: Repnnt; Febrgary.1990; "The Value of a Professional License!' ^^.Family ^Advoc'ate Anierican Bar Association; ^-•1990 " '.the Indiana Judicial Center for distribution and applicationr use bN 1 ith J F B fl 784 V:: y, w . . . o, o . , o.-Summer;19

in a seminarto assist in understanding the valuations in closely-held-corporations.

"Economic Models of Valuation in Divorce Proceedings;" Financial Planning for Divorce and Separation,

Crumbley Apostolov, Ed. John Wiley & Sons, Inc., with J.F.B.

1987 "Using an Economist in Evaluating Claims," Settling Personal Iniury Insurance Claims in, ProfessionalEducation systems, Ine.,1987, co-authored.

"Valuing Educational Attainment as a Distributable Asset," Exoert Valuation of Professions• The Value ofLaw and Medical Degrees and Licenses Upon Divorce, Edited by Ronald L. Brown, Copyright 1987,

Prentice Hall Law & Business, co-authored.

1986 "Settling Personal Injury Insurance Claims in Michigan," Professional Education Systems. Inc., Eau Claire,Wisconsin, November 5,1986, co-authored.

"Forecasting Enhanced Educational Attainment," Fair$hare Law and Business, Inc.. Harcourt and Brace, Vol.6, May, 1986, co-authored.

1985 "Economic Value of a Professional License," and "Basic Approach to Valuing Closely-Held Corporations,"

Reprinted in Contemporary Matrimonial Law Issues: A Guide to Divorce Economics and Practice, Edited byFoster & Brown, Law & Business, Harcourt, Brace & Jovanovich, New York, 1985.

1984 "Consumption & Family Size;" Proceedings of the Industrial Relations Research Association, Spring, 1984,

co-authored.

Articles and Publications: (Continued)

1984 "The Value of a Professional License," Family Advocate, American Bar Association, Summer, 1984, Vo17,

No. 1.

1983 "Taxes and Compensation for Lost Eamings-A Comment;" The Joumal of Leeal Studies, Vol. 12, No. 1,

January, 1983, co-authored.

"ABC'S of Valuing Closely Held Corporations," FairShare, January 1983. Co-authored

1982 "Pseudo String Arrays," Hewlett Packard Basic Exchanee. Vol. 3, No. 1, Spring, 1982.

1981 "Use of Experts to Establish and Quantify Standard of Living," proceedings of the Education Institute ofAmerican Academy of Matrimonial lawvers, San Diego, Catiforrtia,1981.

1974 "A New Technique for Obtaining Regional Employment Multipliers." Land Economics, January, 1974 co-authored with Vijay Mathur.

"The Monetary Value of a Housewife: A Replacement Cost Approach." American Journal of Economics andSocioloev. January, 1974. Reviewed in Luisella Goldschmidt-Clermont, Unoaid Work in the Iiousehol • Areview of Economic Evaluation Methods. Geneva: International Labor Offtce,1982.

"T'he Use of Statistical Analysis for Performance Review,"'July 1974, in Personal Journali cb-authored withHoward Polster.._, , :, ... . {'•- ^ • •; . . .

1973 "An Econometric Technique vs. Traditional Techniques for Obtaining Regional Employnient-Multipliers: A-Comparative Study," Environment and Plannine. June, 1973.^=%-: '.

1972 "An Econometric Export Base Model: A New Technique" in. London Papeis om ReelonaiScienc ,e 1972; (APublica6on of the Bridsh Section of the Regional Science Association), co-authored with Vijay Mathur.

1969 "A Euro-Dollar Primer," Central Economic Letter, Vol. 8, No35, July, 1969.

"Monetary Policy and Fluctuating Exchange Rates: The Canadian Experience," an abstract. T'he Financial

Review, Spring, 1969.

Speeches and Seminars:2007 Chase Law School, Senrinar in economic Damages1996 Ohio Society of Certified Public Accountants, Cleveland Chapter, Litigation Services Committee, "Damages",

November1996

1996 Trial Skills Tune-Up, Trial Fundamentals for Litigators of all Experience Levels to the Cincinnati BarAssociation and The John W. Peck Cincinnati Chapter Association of the Federal Bar Association, November1996.

1996 Potter StewartInn of Court"Projecting Economic Damages", March 26, 1996.1990 Ohio Personal Injury Damages Seminar. "Working With an Economist" prepared for Professional Education

Systems, Inc., April 1990."Measuring Economic Damages in Wrongful Employment Discharge Cases" for Plaintiff EmploymentLawyer's Association, October 25, 1990.

1988 "The Hedonic Value of Life," to Cleveland Trial Lawyers' Association, November, 1988.

Speeches and Seminars: (Continued)

1987 "Purchasing Power of Ohio Judges,".Prepared for the -Select..Conunittee- at the request of Ohio Judges.

February 27, 1987, co-authored.

"Evaluation of a Business," Ohio Association of Trial Lawvers, February 20, 1987, Columbus, Ohio, with

James Wilsman and J.F.B.

Federal Trial Practice Seminar prepared at the request of Federal Judge Manos, September 11, 1987,Cleveland, Ohio, with J.F.B.

Mock Cross-Exanunation - Cleveland Area Civil Trial Attomeys Association, September 14, 1987.

1987 Ohio State Hearings on Ohio Insurance Crisis Tort Reform - Invited Testimony, April 9, 1987; April 22, 1987;

May 14, 1987.

1986 Ohio State Senate Hearings on Ohio Insurance Crisis Tort Reform - Invited Testimony, March 19, 1986.

1985 "Consumption Patterns by Size of Family and Income", Eastem Economic Association, Pittsburgh, P.A.,

March 1985.

1984 "More Evidence on Consumption by Family Size", Eastern Economic Association, New York, March,1984.

1983 °Consumption by Family Size: a Labor Relations Study", Presented to the Allied Social Science Association,

San Francisco, December 1983.,

"Preliminary Evidence on Consumption by Family Size", Atlantic Economic Society, Philadelphia PAr;.

October,1983.

"A Taxation Algorithm in Personal Injury Awards", EastemEconornic Association, Boston, March 1983.

1982 Discussants on "The Offset Method of Calculating Personal Injury Awards", Ivlid-Westem Economic

Association, Chicago, Apri11982:

"Taxation and Personal Injury Awards as a Result of the Lieoelt Decision.", Eastern Economic Association,

Washington D.C., March 1982.

1981 "Use of Experts to Establish and Quantify Standard of Living," presented at the Education Institute ofAmerican Academy of Matrimonial Lawyers. San Diego, Califomia, March, 1981.

1975 "Litigators, Computer Simulation and the Regulatory Process." (with co-authors) American Bar Association,Section on Litigation, National Institute, New York, New York, February 7, 1975.

1973 "An Econometric Technique vs. Traditional Techniques fot Obtaining Regional Employment Multipliers: AComparative Study," presented at the Monterey meeting of the Western Regional Science Association.Monterey, California, Febmary,1973.

1972 "The Economic Value of an Individual: A Methodology," presented to meetings of the Ohio Academy of

Trial Lawyers.

1971 "An Econometric Export Base Model: A new Technique," (with Mathur) presented at meetings of the BriHsh

Section of Regional Science Association, London, England, August 20, 1971.

Consulfine Exoerience:

1968-1969 Economic Research Consultant. Central National Bank of Cleveland: Prepared newsletter, devised

Cleveland area business index which was published monthly in the bank's newsletter.

1969-Present Called upon to provide economic expertise involving matters of economic damage determination andnteasurement. There have been cases covering business losses, anti-trust proceedings,discrimination, family law, personal injury and wrongful death.

Have appeared and been qualified or been deposed as an expert witness in the states of Ohio,Michigan, Kentucky, West Virginia, Massachusetts, Maryland, District of Columbia, Pennsylvania,Louisiana, California, Rhode Island, Texas, New York, Nevada, Colorado, New Jersey, Illinois,

Virginia, Tennessee, and Puerto Rico.

1995 Reviewer. Financial Practice and Education, Raj Aggarwal, John Carroll University, Editor.Financial Practice and Education has a responsibility to help prospective authors improve the qualityof their research and its presentation. Therefore, the job of the reviewer is both to help the editormake accept/reject decisions and to provide the authors with suggestions for improvement of their

research.Selected Cases:1973 The Thalidoniide Case1975 The Kent State Case1979 The Sinking of the Edmund Fitzgerald1980 The Beverly Hills Supper Club Fire

--- Swine Flu cases for the Justice Department of the Northem District of Ohio1981 Pick 'N Pay Supermarket Anti-Trust Case (Cleveland &Lorain)

Asbestos Litigation (John Manville)1982 The MGM Fire1983 The Thurman Munson Crash

The Hyatt Kansas City CollapseTheAir Florida Cmsh

1984 The Dalkon Shield CaseThe Pan American Crash DisasterThe Bendectin CaseThe Bhopal India Case

1985 The Air Canada Air Disaster1986 The Gander Cases - Arrow Air Disaster1987 The LTV Bankruptcy-Oglebay Norton Case

The May Company-Supermarket Anti-Trust CaseThe Home State Savings and Loan Company CaseThe Femald Nuclear Plant Case

1989 The Cincinnati Pipefitters CaseThe WD40 Cases

1989 The Lockerbie, Scotland Case - Pan Am Flight 1031990 Stark County Toxic Landfill Case

Mianrisburg Train Deraihnent1992 The BASF Explosion

USAir Los Angeles Crash1993 Eagle Pitcher Bankruptcy

Pfizer Heart Valve, US formulaMentor Corporation Breast Implant LitigationUSAir 405 CrashUSAir Beckley, West Virginia Crash

1994 Pfizer Heart Valve Foreign Fracture Panel, Co-Chair

Selected Cases: (Con6nued)

1994 Ernst & Young Age Discrimination Case

1996 The Protection Group (Toledo)1996 Queen Village Pharmacy (Philadelphia)1997 The Pension Benefit Guaranty Corporation (Cincinnati)

Acromed Orthopedic Bone Screw1998 Ohio Valley Fireworks Litigation

Firestone Insurance ClaimTelectronics Corporation- Pacemaker J lead litigation

1999 Bogalusa Chendcal Release- GaylordPhen-Fen Interneuron Corporation

2000 American Home Products Phan-FenLouisiana Smokers Litigation- Scott

2001 Sulzer Medica- Hip Implant Litigation2002 Kodak Employment Case

State Alarm Litigation2003 Worldwide Basketball/NCAA Litigation

Lucent Ponder LitigationP&G/Amway Litigation Michigan CaseThomas Kinkade Media Arts Trademark CaseInternational PaperLamson Sessions ContractG Case . •Dayton Power & Light Shareholder Litigation

2004 World Trade Center/Victims Compensation FundLouisiana Smokers Litigation- Snioke Cessation ProgramUPS EV Settlement

2005 STRS Medco Health Solutions Litigaflon2006 Toshiba Notebook Cover Litigatiop Los Angeles

Hatano, Makiko- Grand Canyon Helicopter Crashlnterstate Diesel- Bosch Trademark CaseKnowlton (Cincinnati Bengals) estate Litigation

2007 P&G Utah .Comair Lexington KY AircrashWR Grace Pension Fund EmployeeLitigationTamaraz- Welding Rod Fumes MDL LitigationRawls- West Virginia Water Litigation LitigationStandard Radio Litigation

2008 Mound SuperFund Real Estate Litigation

BURKE, ROSEN & ASSOCIATES2800 Euclid Avenue, Suite 300, Cleveland, OH 44115

John F. Burke, Jr., Ph.D. Harvey S. Rosen, [email protected]

August 22, 2008

Abraham CantorAttorney at Law9930 Johnny cake Ridge Road, Suite 4FConcord, OH 44060

Re: Lake Countv Juvenile Court

Dear Mr. Cantor:

[email protected]

Exhibit

You,have asked for an analysis of the wage structure of Lake County employees. In particular, you haveasked for a comparative analysis'of the salary structure in the Juvenile Court division compared to thesame or like job titles in other departments. In order to perform the analysis I have reviewed and or reliedupon:

• The 2006 Lake County Department salary schedule.. The 2008 Lake County Department salary schedule.• June 7, 2007 letter from Judge William W. Weaver to the Board of Lake County Commissioners

and attached schedules.• Interview and conversations with Lake County personnel.• Contract between the Ohio Patrolmen's Benevolent Association and the Lake County Sheriffs

Department, dated April 1, 2005.• Contract between The Communication Workers of America, AFL -- CIO local 4340 and the Lake

County SherifPs Department, dated April 1, 2005.

The examination of comparative salary data consisted of three different analyses. The first analysis wasa validation of the findings reported by Judge Weaver in his June 7, 2007 letter to the board of LakeCounty Commissioners; the second analysis, the "average analysis" employed a similar method utilizedby the Judge's 2007 report; and the third analysis utilized statistical regression analysis to analyze intra-department salary differences.

Validation of the 2007 Report

An independent examination of intra-department salary differences utilizing the Lake County DepartmentSalary Schedule for 2006, the same data available and used by Judge Weaver and his June 7, 2007letter, was undertaken. Judge Weaver's study consisted of selected department comparisons. Forexample, a comparison was made of average salaries for Corrections Officers employed by the Sheriff'sDepartment and those by the Juvenile Court. Most, but not all, of the comparisons were of employeeswith six years or less seniority. Averages were computed of both salary and seniority. An adjustment forseniority differences was applied and the difference in salary computed. The Judge reported thesedifferences on page 2 of his June 7 letter. The Judge's letter addressed salary differences for: clerks infour different departments, Corrections Officers, bailiffs, finance department account clerks, and probationofficers. Judge Weaver reports lower average salaries for all employees of the Juvenile Court for allcomparisons except Probation Officers. The largest salary deficiency was for Corrections Officers andClerks of the Juvenile Court compared to the Sheriff's office.

In order to validate the Judge's conclusions statistical regression analysis, a different methodology, wasemployed using the 2006 Salary Schedule. Statistical regression analysis is the method of choice bymost economists and statistical analysts for analyzing statistical relationships between different variables. •In this case, it was hypothesized that salaries of individual employees are a function of their longevity with

Telephone: (216) 566-9300 Facsimile (216) 566-0927

the Lake County, the department they work in and their job title as found in the salary schedule. Thesame departmental comparisons in the judge's study were made. Individual salaries were then regressedagainst longevity in the respective department's to determine whether or not the Department variablewould confirm a salary difference or not. A negative sign is indicative of lower salaries in the JuvenileCourt Departments and a positive sign indicates higher salaries. As can be seen in the summary table ofthis report, the resuRs confirmed Judge Weaver's findings. These results are found in the two columnslabeled 2006. The first column summarizes the results found in Judge Weaver's letter and the secondcolumn the regression results. The strongest statistical results were found in the comparison between theJuvenile Correction Officers versus the Sheriff's Correction Officers. The Judge's study reported adeficiency for this group of $8,638 on average, whereas the regression analysis of the same datarecorded $8,889 deficiency. The results were statistically significant and reliable. Even though many ofthe other departments were not statistically significant, the sign indicating a deficiency in Juvenile Courtdepartments was negative and of similar magnitude to the Judge's findings.

Average Analvsis of 2008 Salary Data

A second analysis performed utilized the same technique used by the Court in their 2007 study. That isintra-departmental averages were computed and department comparisons were made. In this analysisemployees were divided into 6 groups of five year seniority intervals reflecting longevity differences. Thisdiffered from the Judge's study in that most of the comparisons in that study were for employees with iessthan 6 years or less seniority. Averages were computed for each of the longevity groups and were thencompared to the same departmental breakdowns contained in the Judge's report. The results of thisanalysis are contained in the first section of this report. A graph of each Departmental comparison is alsopresented. It can readily be seen from the graphs which departments and which seniority gtoups hadhigher average salaries. For example, the average salary for Corrections Officers in the Juvenile CourtDivision with zero to five years longevity had an annual average wage of $25,065 compared to $39,093for Correction Officers in the Sheriff's Department. The graphed salary line for the Sheriff's Departmentexceeds the Juvenile Court wage line for each seniority group for all Corrections Officers with 15 years orless seniority. Juvenile Corrections Officers catch up in the fourth group (16-20 years of seniority) andthen exceed Sheriff's Department Correction Officers whose salaries are capped at approximately$41,642 per annum. Because some of the sample sizes were small and not all departments containedemployees in each seniority group, leaving many gaps, regression analysis as utilized in the validation ofthe 2007 study was applied to the 2008 salary schedule.

Rearession Analysis of 2008 Salary Data

Regression analysis was applied to the 2008 salary data and the results are presented on the Summarytable for each of the departmental comparisons. All of the departmental comparisons revealed salarydeficiencies in each of the departments. Even though the Juvenile Court Division still has salarydeficiencies in all of the comparative departments there have been some improvements from the 2006survey in all of the other departmental comparisons except for Corrections Officers. The overall averagesalary deficiency for Corrections Officers, after adjusting for seniority, actually increased from the 2006survey to $9,375. The results for this department were statisticaNy significant and reliable. Even thoughmany of the other departments were not statistically significant, the results were still negative for theJuvenile Court departments indicative of a salary deficiency.

Monies Needed to Eliminate Deficiencies

Finally, you have asked for my opinion as to the sums of money that would be required to eliminate thesalary deficiencies for the Juvenile Court employees who were below the averages found in thedepartmentai comparisons. In determining the total amount of money required to eliminate salarydeficiencies it is not possible to simply add up each of the departmental comparisons, as doing so woulddouble count the Juvenile Clerks. Since the same Juvenile clerks were used in the three differentdepartment comparisons (Sheriffs Clerks, Probate Clerks, and Clerk of Courts) only one of the three canbe included in the total. For the purposes of the above stated opinion the Clerk of Courts finding wasincluded. My findings indicate that it would require approximately $446,217 to bring individuals below

group averages for their seniority to the average paid the same or similar job titles in other departments.Of that amount, about 90% of the dollar deficiency is accounted for by the salary deficiency of JuvenileCorrection Officers which also covers about half of the employees sampled.Turnover Costs

Salary deficiencies between Departments can create certain economic inefficiencies. Non-compeddvesalaries can make it more difficult to recruit new and retain existing employees, thereby increasing laborforce turnover. Excessive turnover can be costly to an enterprise. It has been estimated that turnovercosts can be as much as 25% of the salary of the departing employee. Costs associated with advertising,interviewing, verifying credentials, and job training all increase costs and may produce a less productiveworkforce. Workers who are even experienced require time to learn new systems and to integrate intothe new employment environment. In addition, high turnover can affect remaining employee morale, jobsatisfaction and job performance. The determination of turnover rates and comparisons were not withinthe scope of this report. Even so the impact on Lake County of excessive turnover in any division shouldnot be ignored and should be examined.

My findings are detailed in this report. If you have any questions, please do not hesitate to call me.

Harvey S. Rosen, Ph.D. forBurke Rosen and AssociatesEconomists

JFB:HSR:IpEnclosures

Prelimin.ary Report

concerning the

Salary Deficiency Calculations

of

Lake County Juvenile Court

Prepared for

Mr. Abraham CantorAttorney at Law

Prepared by:

Harvey S. Rosen, Ph.D.John F. Burke, Jr., Ph.D.

Economists

August 22, 2008

Summary Sheet2

ob Classification

$ to FJiminateSalary Disparity

Based onAverages

$ to EliminateSalary Disparity

Based onRegressions

A. Correction Officers $ 378,907 $ 375,000

B. Probate Clerks * $ 7,056 $ 1,613

0. Sheriff Clerks * $ 56,502 $ 20,738

D. Clerk of Courts * $ 19,283 $ 11,835

E. Prosecutor Support ** $ 8,702 $ 6,162

F. Water Department $ 23,164 $ 12,755

G. Bailiffs $ 28,259 $ 29,680

H. Probation Officers $ 11,066 $ 36,308

Total*** $ 446,217 $ 458,985

* Please note that the comparisons made In the Probate Clerks, Sheriff Clerks, & Clerk of Courts categoriescontain the same employees from the Juvenile Court.Please note that the comparisons made in the Prosecutor Support & Water Department categoriescontain the same employees from the Juvenile Court.The Total includes figures from A, D, E, G, and H.

3Table 1: Schedule Showing a Comparison between Lake County Sheriffs and Juvenile Court Corrections Offcers.

Lon evit SherlfPs Corrections Officers Juvenile Court Corrections Officers

AverageAverage Average Average Average Wage Percentage

From To Wage Longevlty Count Wage Longevity Count Difference Difference

0 5 $ 39,093 3.15 38 $ 25,065 1.51 24 $ 14,028 64.12%6 10 $ 41,242 8.22 25 $ 34,439 8.98 4 $ 6,803 83.50%11 15 $ 41,642 13.15 6 $ 31,013 11.76 1 $ 10,629 74.48%16 20 $ 41,642 18.46 18 $ 41,675 18.18 4 $ .(34) 100.08%21 25 $ 41,642 23.03 4. $ 48,763 23.03 2 $ (7,121) 117.10%

.91 35

Correction Officer Comparison

1

$60,000

$50,000

$40,000

$30,000

$20,000

$10,000

2 3 4

Longevity

5

« Sheriffs Dept.Wages

.-Juvenile CourtL Wages

Note: Sequence Numbers represent individual employees rather than their names for privacy purposes.

4Table 1: Schedule Showing a Comparison between Lake County SherifPs and Juvenile Court Corrections Officers (Cont.).

Seq. No. Group Job TitleAnnualized

Salary

$ toEliminateDifference

828 0-5 JUVENILE CORRECTIONS OFFICER $ 23,712 $ 15,381829 0-5 JUVENILE CORRECTIONS OFFICER $ 25,106 $ 13,987750 0-5 JUVENILE CORRECTIONS OFFICER $ 26,295 $ 12,798793 0-5 JUVENILE CORRECTIONS OFFICER $ 26,295 $ 12,798726 0-5 JUVENILE CORRECTIONS OFFICER $ 27,810 $ 11,283824 0-5 JUVENILE CORRECTIONS OFFICER $ 23,566 $ 15,526825 0-5 JUVENILE CORRECTIONS OFFICER $ 22,880 $ 16,213781 0-5 JUVENILE CORRECTIONS OFFICER $ 22,734 $ 16,358778 0-5 JUVENILE CORRECTIONS OFFICER $ 22,734 $ 16,358752 0-5 JUVENILE CORRECTIONS OFFICER $ 26,295 $ 12,798813 0-5 JUVENILE CORRECTIONS OFFICER $ 23,005 $ 16,088764 0-5 JUVENILE CORRECTIONS OFFICER $ 24,667 $ 14,426780 0-5 JUVENILE CORRECTIONS OFFICER $ 26,316 $ 12,776761 0-5 JUVENILE CORRECTIONS OFFICER $ 22,277 $ 16,816747 0-5 JUVENILE CORRECTIONS OFFICER $ 22,277 $ 16,816 "729 0-5 JUVENILE CORRECTIONS OFFICER $ 26,476 $ 12,616819 0-5 JUVENILE CORRECTIONS OFFICER $ 25,331 $ 13,762790 0-5 JUVENILE CORRECTIONS OFFICER $ 24,398 $ 14,694765 0-5 JUVENILE CORRECTIONS OFFICER $ 22,734 $ 16,35B795 0-5 JUVENILE CORRECTIONS OFFICER $ 25,331 $ 13,762727 0-5 JUVENILE CORRECTIONS OFFICER $ 22,734 $ 16,358749 0-5 JUVENILE CORRECTIONS OFFICER $ 33,530 $ 5,563807 0-5 JUVENILE CORRECTIONS OFFICER $ 28,396 $ 10,697745 0 -5 JUVENILEC6RRECTIONSOFFICER $ 26,666 $ 12;427768 6-10 JUVENILE CORRECTIONS OFFICER $ 33,504 $ 7,739770 6-10 JUVENILE CORRECTIONS OFFICER $ 38,712 $ 2,531785 6-10 JUVENILE CORRECTIONS OFFICER $ 31,908 $ 9,334B31 6-10 JUVENILE CORRECTIONS OFFICER $ 33,634 $ 7,609798 11 -15 JUVENILE CORRECTIONS OFFICER $ 31,013 $ 10,629759 16-20 JUVENILE CORRECTIONS OFFICER $ 40,830 $ 811803 16 -20 JUVENILE CORRECTIONS OFFICER $ 41,392 $ 250808 16 -20 JUVENILE CORRECTIONS OFFICER $ 38,298 $ 3,344

$ 378,907 Total

Note: Sequence Numbers represent Individual employees rather than their names for privacy purposes.

5Table 2: Schedule Showing a Comparison between Lake County Probate Clerks and Juvenile Court Clerks.

Lon evit Probate Clerks Juvenile Caurt Clerks

Ave°rageAverage Average Average Average - Wage Percentage

From To Wage Longevity Count Wage Longevity Count Difference Difference

0 5 $ 24,522 3.10 7 $ 30,138 3.05 7 $ (5,617) 122.91°/u6 10 $ 30,187 10.91 1 $ 26,659 7.73 2 $ 3,528 88.31%

8 9` Please note that either Lake County or Juvenile Court do not have employees in each longevity couplet.

Therefore, no comparison can be made for those couplets.

Probate Court Clerks

$40,000

^ $30,000

m $20,000^

¢ $10,000

$-1 2

Longevity

$ toSeq. Annualized EliminateNo. Group Job Title Salary Difference

937 6-10 DEPUTYCLERK $ 26,659 $ 3,528797 6-10 DEPUTY CLERK $ 26,659 $ 3,528

$ 7,056 Total

-+ Probate Court-w-Juvenile Court


6Table 3: Schedule Showing a Comparison between Lake County SherifPs Clerks and Juvenile Court Clerks.

Lonoevitv Sherifrs Department Clerks Juvenile Court Clerks

Average Average Average AverageAverage

Wage PercentageFrom To Wage Longevity Count Wage Longevity Count Difference Difference

0 5 $ 32,947 1.97 2 $ 30,138 3.05 7 $ 2,809 91.47%6 10 $ 38,189 8.51 6 $ 26,659 7.73 2 $.11,530 69.81%11 15 $ 36,941 14.64 3 $ 44,211 15.91 1 $ (7,270) 119.68"/0

11 10

` Please note that either Lake County or Juvenile Court do not have employees in each longevity couplet:Therefore, no comparison can be made for those couplets.

Sheriff's Clerks

drn

0

ma

$50,000

$40,000

$30,000

$20,0004

$10,000

I 2

Longevity

3


773 0-5 DEPUTY CLERK $ 25,527 $ 7,420777 0-5 RECEPTIONIST $ 27,734 $ 5,213818 0-5 ACCOUNTCLERK $ 26,873 $ 6,074734 0-5 DEPUTY CLERK $ 25,527 $ 7,420746 0-5 CLERK $ 25,631 $ 7,316937 6-10 DEPUTY CLERK $ 26,659 $ 11,530797 6-10 DEPUTY CLERK $ 26,659 $__ 11,530

$ 56,502 Total

-+- Sheriff s Department-e-Juvenile Court


7Table 4: Schedule Showing a Comparison between Lake County Clerk of Courts and Juvenile Court Clerks.

Longevitv Lake County Clerk of Courts Juvenile Court Clerks

Average Average Average AverageAverageWage Percentage

From To Wage Lorigevity Count Wage Longevity Count Difference Difference

0 5 $ 28,933 2.50 4 $ 30,138 3.05 7 $ (1,206) 104.17%6 10 $ 29,615 8.30 5 $ 26,659 7.73 2 $ 2,956 90.02%11 15 $ 32,974 13.48 7 t 44,211 15.91 1 $ ( 11,237) 134.08%26 30 $ 50,898 26.65 2 $ 51,666 27.09 1 $ (769) 101.51%

18 11

' Please note that either Lake County or Juvenile Court do not have employees in each longevity couplet.Therefore, no comparison can be made for those couplets.

Clerk of Courts

1

$60,000

$50,000

$40,000

$30,000

$20,000

$10,000

2 3

Longevity

4

$ toSeq. Annualized EliminateNo, Group Job Title Salary Difference

773 0-5 DEPUTYCLERK $ 25,527 $ 3,405777 0-5 RECEPTIONIST $ 27,734 $ 1,199818 0-5 ACCOUNT CLERK $ 26,873 $ 2,059734 0-5 DEPUTY CLERK $ .25,527 $ 3,405746 0-5 CLERK $ 25,631 $ 3,302937 6-10 DEPUTY CLERK $ 26,659 $ 2,956797 6-10 DEPUTY CLERK $ 26,659 $ 2,956

$ 19,283 Total

-+- Lake County-e-Juvenile Court


8Table 5: Schedule Showing a Comparison between Lake County Prosecutor Support and the Juvenile Court Finance Department.

Lonaevity Lake County Prosecutor Suooort Juvenile Court Finance Deoartment



0 5 $ 28,793 2.12 11 $ 26,873 1.98 1 $ 1,920 93,33%6 10 $ 32,743 8.42 . 5 $ 29,352 7.46 2 $ 3,391 89.64%

16 3

` Please note that either Lake County or Juvenile Court do not have employees in each longevity couplet.Therefore, no comparison can be made for those couplets.

Prosecutor Support

$40,000

^ $30,000

$20,000

Qf

$10,000

$-1

Longevity

2

Seq. Annualized$ to

EliminateNo. Group JobTitie Salary Difference

818 0-5 ACCOUNT CLERK $ 26,873 $ 1,920784 6-10 1NTAKESECRETARY $ 30,625 $ 2,119786 6-10 SECRE - GEN OFFICE $ 28,080 $ 4,663

$ 8,702 Total

+-Lake CountyProsecutorSupport

^ Juvenile Crt.Finance Dept.


9Table 6: Schedule Showing a Comparison between the Lake County Water Dept. and the Juvenile Court Finance Dept.

Longevity Lake CounN Water Deoartment Juvenlle Court Flnance Denartment



0 5 $ 31,450 ' 2.12 8 $ 26,873 1.98 1 $ 4,576 85.45%6 10 $ 38,646 9.30 2 $ 29,352 7.46 2_ $ 9,294 75.950/o

10 3

' Please note that either Lake County or Juvenile Court do not have employees in each longevity couplet.Therefore, no comparison can be made for those couplets.

WaterlFinance Dept.

$50,000

$40,000rntti

$30,000a^rn;°_ $20,000d

$10,000

1

Longevity

2


818 0-5 ACCOUNT CLERK $ 26,873 $ 4,576784 6-10 INTAKE SECRETARY $ 30,625 $ 8,022786 6-1g SECRET - GEN OFFICE $ 28,080 $ 10,566

$ 23,164 Total

-^ Lake CountyWater Dept.

^ Juvenile Crt.FinanceDept.

Note: Sequence Numbers represent Individual employees rather than their names for privacy purposes.

Table 7: Schedule Showing a Cotnparison between LakeCounty Bailiffs and Juvenile Court Bailiffs.10

Longevitv Lake County Bailiffs Juvenile Court Bailiffs

Average Average Average AverageAverageWage Percentage


0 5 $ 37,752 1.87 1 $ 42,974 2.94 2 $ (5,222) .113.83'.66 10 $ 34,543 8.10 5 $ 42,085 9.40 2 $ (7,542) 121.83%21 25 $ 59,381 25.77 1 $ 37,299 21.36 1 $ 22,082 62.81%

7 5

` Please note that either Lake County or Juvenile Court do not have employees in each longevity couplet.Therefore, no comparison can be made for those couplets.

$70,0D0I M 1

$60,000

$50,000ro$40,000 ^ Lake County

^ $30,000 ^. ^+Juvenile Court.

Q $20,000

$10,000

1 2

Longevity


938 0-5 IV D-BAILIFF $ 33,949 $ 3,803810 6-10 BAILIFF $ 32,169 $ 2,373748 21 -25 BAILIFF/CLERK $ 37,299 $ 22,082

3

$ 28,259 Total


11Table 8: Schedule Showing a Comparison between Lake County Probation Officers and Juvenile Court Probation Officers.

Lon evi Lake Countv Probatlon Qfficers Juvenile Court Probation Officers



16 20 $ 24,636 16.97 1 $ 44,510 19.53 3 $ (19,874) 180.67%21 25 $ 51,574 23,26 1 $ 49,446 22.63 5 $ 2,128 95.87%

2 8

" Please note that either Lake County or Juvenile Court do not have employees in each longevity couplet.Therefore, no comparison can be made for those couplets.

Probation

$60,000

$50,000

$40,000

$30,000

$20,000

1 2

Longevity


766 21 -25 PROBATION OFFICER $ 49,127 $ 2,447800 21 -25 PROBATION OFFICER $ 49,877 $ 1,697904 21 -25 PROBATION OFFICER $ 48,112 $ 3,462906 21 -25 PROBATION OFFICER $ 48,112 $ 3,462

$ 11,066 Total

--*-- Lake County

--®--Juvenile Court


Table 9: Schedule Showing Juvenile Court Salary Deficiency for Correction Officers.

SUMMARY OUTPUTSherifPs Correction Officers All- 2006 Data

Regression StatisticsMultiple RR SquareAdjusted R SquareStandard ErrorObservations

0.820.670.66

$3,115.77106

ANOVA

dfRegressionResidualTotal

2103105

Coefficients

Intercept $36,222.91Department Variable -$8,888.60Longevity Variable $363.07

SS MS . F

2006332561.94 1003166280.97 103.33999927982.33 9708038.66

3006260544.27

Standard Error t Stat P-value

494.97 73.18 0.00

807.14 -11.01 0.0042.00 8.65 0.00

SUMMARY OUTPUTSherifPs Correction Officers Atl- 2008 Data

Regression StatisticsMultiple R 0.87R Square 0.75

Adjusted R Square 0.75Standard Error $3,261.01Observations 132

ANOVA

df SS MS F

Regn;sslon 2 4154907117.94 2077453558.97 195.36

Residual 129 1371809999.19 10634186.04Total 131 5526717117.13

Coefficients Standard Error t Stat P-value

Intercept $36,680.8 510.32 71.88 0.00Department Variable -$9,375.0 628.47 -14.92 0.00

Longevity Variable $406.6 40.73 9.98 0.00

12

* The number of Juvenile Court employees in this category is 40.

Table 10: Schedule Showing Juvenile Court Salary Deficiency for Probate Clerks.

SUMMARY OUTPUTProbate Court Clerks- 2006 Data


0.640.420.25

$1,073.6810

ANOVA

drRegression 2Residual 7Total 9

CoefrcientsIntercept $24,133.93Department Variable -$1,464.64Longevity Variable $132.16

SUMMARY OUTPUTProbate Court Clerks <8 years 2008 Data

Regression StatisticsMultiple R 0.40R Square 0.16Adjusted R Square 0.01

Standard Error $4,092.98Observations 14

ANOVAdf

Regression 2

Residual 11Total 13

CoefficientsIntercept $25,236.88Department Variable -$230.42Longevity Variable $3,272.85

ss MS5726604.74 2863302.378069576.12 1152796.59

13796180.85

F

13

2.48

Standard Error t Stat P-value643.73 37:49 0.00694.18 -2.11 0.07157.88 0.84 0.43

SS MS35754473.47 17877236.74

184277261.93 16752478.36220031735.40

F1.07

Standard Error t Stat P-value2132.66 11.83 0.00472.95 -0.49 0.642251.76 1.45 0.17


Table 11: Schedule Showing Juvenile Court Salary Deficiency for Sheriff Clerks.

SUMMARY OUTPUTSheriffs Clerks- 2006 Data


0.980.970.96

$1,200.1910

ANOVA

dfRegression 2Residual 7Total 9

CoefficientsIntercept $33,420.23

Department Variable -$10,952.67Longevity Variable $212.85

SUMMARY OUTPUT

Sheriff Clerks -.6yrs or less 2008 dataRegression Statistics

Multiple R 0.62R Square 0.39Adjusted R Square 0.18

Standard Error $5,957.44Observations 9

ANOVA


CoefficientsIntercept $27,594.30Department Variable -$3,456.37Longevity Variable $1,931.46

SS MS

298727648.18 149363824.0910083275.05 1440467.86

308810923.24

F103.69


SS MS

135035777.89 67517888.94212946519.75 35491086.63347982297.64

F

1.90


14


Table 12; Schedule Showing Juvenile Court Salary Deficiency for Clerk of Courts.

SUMMARY OUTPUTClerk of Courts 6 yrs or less- 2006 Data

Regression Statistics

15

Multiple R 0,70R Square 0.49Adjusted R Square 0.39Standard Error $1,612Observations 13

ANOVA

df SS MS FRegression 2

Residual 10 '

Total 12

25150634.2425988570.4551139204.69

12575317.122598857.045

4.838787552

Coefficients Standard Error t Stat P-value


890.75921.70174.93

27.89-2.551.15

0.000.030.28

SUMMARY OUTPUTClerk of Courts All- 2008 Data

Regression StatisticsMultiple R 0.70R Square 0.48Adjusted R Square 0.46Standard Error $3,230.63Observations 54

ANOVAdf SS MS F

Regression 2 498720334.98 249360167.49 23.89

Residual 51 532285756.33 10436975.61Total 53 1031006091.31

Coefficients Standard Error t Stat P-valueIntercept $27,478.92 907.15 30.29 0.00

Department Variable -$1,690.67 1401.49 -1.21 0.23Longevity Variable $376.98 63.62 5.93 0.00


Table 13: Schedule Showi^Juvenile Court Salary Deficiency for Prosecutor Support.

SUMMARY OUTPUTProsecutor Support- 2006 Data


ANOVA


CoefficientsIntercept $27,480:53

Department Variable -$5,664.29Longevity Variable $473.38

SUMMARY OUTPUTProsecutor Support 6 yrs orless- 2008 Data


0.960.920.91

$450.9814

ANOVA

dfRegression 2

Residual 11Total 13

CoefficientsIntercept $27,399.69Department Variable -$2,054.06Longevity Variable $678.31

SS MS

138010543.87 69005271.9323711758.95 1823981.46

161722302.82

F

37.83


SS MS

27314016.10 13657008.052237199.58 203381.78

29551215.68

F67.15


16


17Table 14: Schedule Showing Juvenile Court Salary Deficiency for the Water Department.

SUMMARY OUTPUTWater Department Account Clerks- 2006 Data


0.970.940.92

$1,272.1210

ANOVAdf

RegressionResidualTotal

279

CoefficientsInterceptDepartment VariableLongevity Variable

$29,346.95-$8,004.40

$772.63

SS MS

169076257.34 84538128.6711328089.80 1618298.54

180404347.14

52.24


SUMMARY OUTPUT

Water Department Account Clerks 10 or less- 2008 Data


0.950.900.88

$1,195.1512

ANOVA

df

Regresslon 2

Resldual 9Total 11

CoefficientsIntercept $29,977.23Department Variable -$6,377.53Longevity Variable $818.08

SS MS F119672242.00 59836121.00 41.8912855429.52 1428381.06

132527671.52



Table 15: Schedule Showing Juvenile Court Salary Deficiency for Bailiffs.

SUMMARY OUTPUTCommon Pleas Court Bailiffs- 2006 Data


18

Multiple R 0,51R Square 0.26Adjusted R Square -0.11Standard Error $11,338.40Observatlons 7

ANOVA

df ss MS F

Regression 2Residual 4Total 6

178741675.32514237405.15692979080.47

89370837.66128559351.29

0.70

Coefficients Standard Error t Stat P-valueIntercept $36,132.58Department Variable -$9,247.26Longevity Variable $603.10

7554.599526.16

595.39

4.78-0.971.01

0.010.390.37

SUMMARY OUTPUTCommon Pleas Court Bailiffs All- 2008 Data

Regression StatisttcsMultiple R 0.46R Square 0.22Adjusted R Square -0.18Standard Error $11,950.93Observations 7

ANOVA

df SS MS F

Regression 2 157482088.40 78741044.20 Q.55

Residual 4 571299242.03 142824810.51Total 6 728781330.43

Coefficients Standard Error t Stat P-valueIntercept $36,893.20 8804.21 4.19 0.01Department Variable -$7,420.10 9978.56 -0.74 0.50Longevity Variable $611.76 625.10 0.98 0.38


Table 16: Schedule Showing Juvenile Court Salary Deficiency for Probation Officers.

SUMMARY OUTPUTProbation Officers All- 2006 Data


19

Multiple R 0.82R Square 0.67Adjusted R Square 0.64Standard Error $5,343.97Observations 24

ANOVA

df SS MS F

Regresslon 2

Residual 21Total 23

1210550752.84599717711.28

1810268464.13

605275376.4228557986.25

21.19

Coefficients Standard Error I Stat P-value


1956.182691.88

140.25

16.26-2.656.38

0.000.010.00

SUMMARY OUTPUTProbation Officers All- 2008 Data


ANOVA

df SS MS FRegression 2 1467015214.86 733507607.43 11.75Residual 26 1623505314.37 62442512.09Total 28 3090520529.23

Coefficients Standard Error t Slat P-value

intercept $34,676.72 4240.48 8.18 0.00

Department Variable -$2,420.54 3724.11 -0.65 0.52

Longevity Vadable $620.75 183.24 3.39 0.00


ss. state of ohio state of ohio )) ss. county of cuyahoga) now comes harvey s. rosen, ph.d., after...

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