JOCELYN D. LARKIN (SBN 110817)
THE IMPACT FUND
125 University Avenue
Berkeley, CA 94710
Telephone: (510) 845-3473
Facsimile: (510) 845-3654 / JOSEPH SELLERS
CHRISTINE WEBBER
CHARLES TOMPKINS
JULIE GOLDSMITH
COHEN, MILSTEIN, HAUSFELD & TOLL
West Tower – Suite 500
1100 New York Avenue
Washington, D.C. 20005-3964
Telephone: (202) 408-4600
Facsimile: (202) 408-4699
IRMA D. HERRERA (SBN 98658)
DEBRA A. SMITH (SBN 147863)
EQUAL RIGHTS ADVOCATES
1663 Mission Street, Suite 250
San Francisco, CA 94103
Telephone: (415) 621-0672
Facsimile: (415) 621-6744 / STEPHEN TINKLER
MERIT BENNETT
TINKLER & BENNETT
309 Johnson Street
Santa Fe, New Mexico 87501
Telephone: (505) 986-0269
Facsimile: (505) 982-6698
SHEILA Y. THOMAS (SBN 161403)
EQUAL RIGHTS ADVOCATES
5260 Proctor Avenue
Oakland, CA 94618
Telephone: (510) 339-3739
Facsimile: (510) 339-3723 / DEBRA GARDNER
PUBLIC JUSTICE CENTER
500 East Lexington Street
Baltimore, MD 21202
Telephone: (410) 625-9409
Facsimile: (410) 625-9423
STEVE STEMERMAN (SBN 067690)
ELIZABETH LAWRENCE (SBN 111781)
DAVIS, COWELL & BOWE
100 Van Ness Avenue, 20th Floor
San Francisco, CA 94102
Telephone: (415) 626-1880
Facsimile: (415) 626-2860
Attorneys for Plaintiffs / SHAUNA MARSHALL (SBN 90641)
HASTINGS COLLEGE OF THE LAW
200 McAllister Street
San Francisco, CA 94102
Telephone: (415) 565-4685
Facsimile: (415) 565-4854
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
BETTY DUKES, PATRICIA SURGESON, CLEO PAGE, CHRISTINE KWAPNOSKI, DEBORAH GUNTER, KAREN WILLIAMSON AND EDITH ARANA, on behalf of themselves and all others similarly situated,Plaintiff,
vs.
WAL-MART STORES, INC.,
Defendant
/ Case No. C-01-2252 MJJDECLARATION OF LORRINA LETTERER IN SUPPORT OF PLAINTIFFS' MOTION FOR CLASS CERTIFICATION
I, Lorrina Letterer, declare:
1. I make this statement on the basis of my personal knowledge, and, if called as a witness, could and would testify competently to the facts herein.
2. I am female and a former Wal-Mart Stores, Inc. employee. I worked in the Dekalb, Illinois Wal-Mart from August 2000 to July 2001.
3. Between 1993 and 1996, I had two years of client services experience at a collection agency and had held a cashier position at Filene’s Basement for one year.
4. At Wal-Mart, I was employed as a Cashier from August through November 2000, a Customer Service Manager from November 2000 through July 2001, and a Sales Associate in July 2001.
5. Between 2000 and 2001, my Co-Manager, Dale [last name unknown], actively encouraged me to pursue promotion to management. Co-Manager Dale told me I would excel in a management position; with his encouragement, I decided to pursue the Manager Training Program.
6. While working as a Customer Service Manager, I told my Store Manager, Tom Kehrees, that I was interested in participating in the Manager Training Program. He told me that I needed to gain sales floor experience before being considered for the program. At his recommendation, I left my Customer Service Manager position and took a Sales Associate position in Health and Beauty Aids to gain the suggested experience. In June 2001, I posted an application on Wal-Mart’s computer system for the Department Manager position of the Girls and Boys section. When I did not receive an answer to my application after three weeks, I submitted another. I did not receive a response to either application.
7. In 2001, Lee Murray, the husband of a Customer Service Manager, was hired into the Manager Training Program. Mr. Murray had no previous retail or Wal-Mart experience. Also that year, a male Customer Service Manager, Joe [last name unknown], was placed in the Manager Training Program. Joe, like myself, had held a Cashier position prior to working as a Customer Service Manager. However, despite our similar backgrounds, he was able to enter the Manager Training Program without having to gain sales floor experience.
8. I approached my District Manager [name unknown] in July 2001 regarding my frustration trying to gain promotion to management. Several days later, I told Store Manager Kehrees that I had discussed my concerns with the District Manager; Mr. Kehrees grew angry with me for doing so. A few days after my conversation with Mr. Kehrees, I was told that I was to work as an Assistant to the Department Manager of Health and Beauty Aids. Despite our previously good working relationship, Mr. Kehrees did not speak to me again after my reassignment.
9. Of the ten Assistant Managers in the Dekalb Wal-Mart, only three were female. There were no female Co-Managers at the DeKalb store during my employment with Wal-Mart.
10. Disheartened by my inability to advance to management, I decided to leave Wal-Mart Stores in July 2001, after only one year with the Company.
I declare under penalty of perjury of the laws of the United States and the State of Illinois that the foregoing is true and correct.
This Declaration was signed by me on ______, 2003, in Sycamore, Illinois.
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Declaration of Lorrina Letterer in Support of Plaintiffs’ Motion for Class Certification Case No. C-01-2252 MJJ