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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 |
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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 |
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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, Julie Donovan,
do hereby 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. I am female.
2. I was
employed by Wal-Mart in the Home Office from August 1996 until November 1997
as a Senior
Buyer.
3. I
graduated from Marymount University college with a
Bachelor’s degree in Fashion
Merchandising
in 1990. Prior to my employment with
Wal-Mart I was in the executive training
program at Macy’s in New York and was later employed by Jamesway, in New Jersey, and Office Depot in Florida.
4. In August 1996, while working at
Wal-Mart’s Home Office in Bentonville, AR I was
told by Ray
Hobbs, Sr. Vice President and General Merchandise Manager, that he was surprised
that I, as a woman, was in such a high position at Wal-Mart, and that it would
be better if I were at home raising a family.
5. During that same time frame I was told
by Mr. Hobbs, that I did not play well with the
“boys” in
the company. Specifically, I was told
that because I did not hunt, fish, or do other typically-male activities, that I
probably would not advance any further with Wal-Mart.
6. I met with Mr
Hobbs for my performance evaluation in approximately October 1997.
We were talking
about the next position I could seek to advance my career and he said I should
not worry
about that, because “you aren’t a part of the boy’s club, and you should raise
a family and stay in the kitchen”
instead of seeking to advance my career.
7. I traveled to Kansas City twice for
company-wide managers’ meetings. I
observed that
approximately
85% of the managers present were men.
When I attended these meetings, there were no other women from the
department attending who I could share a hotel room with, and
thus I had
my own hotel room. Rather than
recognizing that there were simply too few women in positions at my level, Karman Wood, a buyer, made comments to the effect that I
was receiving preferential
treatment because I was a woman.
8. In order for me to engage other
managers or upper level officials in conversation, the
discussion
generally had to be centered around hunting or sports-related topics to gain
their
respect. At one Kansas City managers’ meeting I had to
base my presentation on Monday Night
Football to ensure my credibility with the other male managers.
9. I made informal comments to my
supervisor Vice President and Divisional Merchandise
Manager, Bill Long, about how I was being
treated. He told me to shrug it off and
that I needed
to “have a
thick skin.” I also discussed my
situation with Bill May, a buyer who
is now a Vice
President
at Wal-Mart, and he told me the same thing as Mr. Long.
I declare
under penalty of perjury of the laws of the United States and of the State of
New Jersey, that the foregoing is true and correct. I signed this on April ___, 2003 in _______, New Jersey.
_____________________________
Julie
Donovan