2022-11-22 DE 2829 MCSO-MELENDRES - PENZONE NOTICE PURSUANT TO PARAGRAPH 338 OF COURTS NOVEMBER 8 2022 ORDER(9697344.1).PDF

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tMary R. O’Grady, 011434 
Kristin L. Windtberg, 024804 
Joshua J. Messer, 035101 
OSBORN MALEDON, P.A. 
2929 North Central Avenue, Suite 2100 
Phoenix, Arizona  85012-2793 
(602) 640-9000 
mogrady@omlaw.com  
kwindtberg@omlaw.com 
jmesser@omlaw.com  
Attorneys for Defendant Paul Penzone 
IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF ARIZONA 
 
Manuel De Jesus Ortega Melendres, on 
behalf of himself and all others similarly 
situated; et al., 
 
 
Plaintiffs, 
and 
 
United States of America, 
 
Plaintiff-Intervenor, 
  
vs. 
 
Paul Penzone, in his official capacity as 
Sheriff of Maricopa County, Arizona, et 
al., 
 
Defendants.
No. CV-07-2513-PHX-GMS 
 
 
SHERIFF PAUL PENZONE’S 
NOTICE PURSUANT TO 
PARAGRAPH 338 OF COURT’S 
NOVEMBER 8, 2022 ORDER  
 
 
 
 
  
In accordance with Paragraph 338 of the Court’s November 8, 2022 Order, Sheriff 
Paul Penzone hereby notifies the Court that the cost to the Maricopa County Sheriff’s 
Office (“MCSO”) of a budgeted PSB sworn sergeant position for one year is $191,415.12.  
This amount is calculated using the mid-range salary for an MCSO sworn sergeant 
position, along with the associated mandatory retirement contributions, employer taxes, 
and the cost of benefits paid by MCSO in connection with such a position.  This amount 
does not include any recruitment or hiring costs.  MCSO, like other law enforcement 
Case 2:07-cv-02513-GMS   Document 2829   Filed 11/22/22   Page 1 of 2

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agencies subject to the County’s merit selection rules, does not hire sworn sergeants 
laterally from outside of the organization because the merit selection rules do not provide 
for the lateral hiring of ranked sworn officers.  As a result, when a sworn sergeant joins 
the PSB, MCSO does not incur any additional recruiting or hiring costs.  This amount also 
does not include additional training costs because although sergeants who are transferred 
into PSB receive on-the-job training from their superiors, MCSO cannot reasonably assign 
a specific cost to this training.  Further, because PSB sergeants are required to attend the 
same formal trainings as all other MCSO sergeants, MCSO does not incur any additional 
PSB-specific training cost when a sergeant is transferred in to the PSB from another 
division within the agency. 
Dated this 22nd day of November, 2022. 
 
OSBORN MALEDON, P.A.
 
 
 
By s/  Kristin L. Windtberg 
 
 
Mary R. O’Grady 
 
Kristin L. Windtberg 
 
Joshua J. Messer 
 
2929 North Central, Suite 2100 
 
Phoenix, Arizona  85012-2793 
Attorneys for Defendant Paul Penzone
 
9693461 
Case 2:07-cv-02513-GMS   Document 2829   Filed 11/22/22   Page 2 of 2