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In court documents, the city said of the judge's finding of bias: "Under the Court's faulty analysis, any rational jury would necessarily find that the City deliberately used facially neutral exams to suppress black employment even as it conducted a targeted multi-million-dollar minority recruitment campaign, enlisted Columbia University to study methods of maximizing FDNY diversity, increased the minority composition of its other uniformed services, engaged an expert with a mandate to design an improved exam, and devised a panoply of other devices to diversify the FDNY's ranks"