|
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 |
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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
I, Patricia Buckley, declare:
1. I am a female who lives in Noble,
Oklahoma. From July 2000 to August 2001,
I worked at the Wal-Mart Supercenter in
Norman, Oklahoma.
2. When I applied at Wal-Mart, I was
pursuing a degree in business management from Moore Norman Technology
Center. I was looking for an opportunity
to develop a career in business management
3. During my interview at Wal-Mart, I told
Assistant Manager Mark that I was interested in management at Wal-Mart and that
I was concurrently seeking my degree in that area. He told me that the only positions available
in the store were cashier or people greeter positions, and that a cashier was a
good place to begin if I wanted to become a manager. He explained to me that the first thing managers
need to learn is how to run the front end of the store, including the cashier,
lay-away and customer service positions.
4. I
took the cashier position believing that it would be a stepping stone to a
management position. Once I learned the
cashier position, I began asking Assistant Manager Mark and Assistant Manager
Landon for training in customer service and lay-away to prepare myself to
become a manager. Although I requested
cross-training repeatedly, I was never provided any training in either of these
areas for the entire year I worked at Wal-Mart.
5. I observed that most of the cashiers at
the Supercenter were female. In
contrast, most of the managers were male.
The Store Manager, the Co-Managers and the majority of Assistant
Managers at my store were male.
6. During my employment at Wal-Mart, I
spoke to Assistant Managers Mark and Landon several times about my interest in
business management. I even noted on my
annual performance appraisal in June, 2001, that I wanted to “move up in the
company.”
7. Despite my interest in a promotion to
the management level, neither Assistant Manager Mark nor Assistant Manager
Landon offered me an opportunity to apply for the Management Training
Program. I never saw any written
information about the program, and during my time at Wal-Mart, I was never even
told that this program existed. I was
given no information concerning how to be promoted to management training, or
what I needed to do to be promoted. To
my knowledge, there were never any positions posted for the Management Training
Program during my employment at Wal-Mart.
I also never saw any written information regarding any prerequisites for
joining management at Wal-Mart.
8. After a year in the cashier position at
Wal-Mart with no opportunity to gain additional knowledge or experience of
store operations, and no encouragement from management, it was apparent that
Wal-Mart was not going to advance me past my current hourly, non-management
position. I terminated my employment
with Wal-Mart in August 2001.
9. I would consider returning to work for
Wal-Mart if I was assured that I would be provided fair opportunities for
advancement, fair wages and a non-discriminatory work environment I have personal knowledge of each and
every fact set forth in the Declaration, and if called to testify as a witness
in this matter, I could and would competently testify to each of these facts.
I
declare under penalty of perjury of the laws of the United States and State of
Oklahoma that the foregoing is true and correct.
This
Declaration was signed by me on ______________________, 2003, at
_______________________.
______________________________
Patricia Buckley
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