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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, 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.
______________________________