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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, Kathleen Schmeida, 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. I worked at three Wal-Mart
stores in Ohio from 1998 through 2001.
In all three stores, I noticed that the policies and practices regarding
hiring, training, and discipline were the same.
3. I began working at Wal-Mart in
Macedonia, Ohio, on May 23, 1998 as an Assistant Manager. Throughout my time at
the Macedonia store, I told my Store Manager, Rodney Bowden, that I was
interested in learning how to make myself promotable because my goal was to
become a Store Manager. In response to my question, Store Manager Bowden told
me that in order to advance I would have to relocate to another state. He also
told me that any additional information on training for advancing within the
Company was “available on a need-to-know basis” and that I did not need to
know.
4. In June of 1999, District Manager Paul
Beno transferred me to the Streetsboro, Ohio Wal-Mart. While at the Streetsboro store I continued
expressing my interest in advancing within the Company, and even wrote my goal
of becoming Store or Co-Manager on my annual performance evaluation. A true and
correct copy is attached hereto as Exhibit A. I spoke with Store Manager
Franklin Cottrill about my goals but never received the additional training I
needed in order to be considered for Co-Manager and Store Manager positions. It
was common, however, for Store Manager Cottrill to provide on-the-job mentoring
and computer training to male Assistant Managers such as Glenn Fry and Jim
(last name unknown). I was not given the
opportunity to participate in these informal mentoring sessions.
5. In May 2000, District Manager Paul Beno
transferred me again to the Wal-Mart in Stow, Ohio. I requested additional training and
information about being promoted to Store Manager from my Store Manager Scott
Bernard but he never followed up with me.
6. In May 2001, I terminated my employment
with Wal-Mart because I was dissatisfied with promotion opportunities.
I declare
under the penalty of perjury of the laws of the United States and State of Ohio
that the foregoing is true and correct.
This
Declaration was signed by me on the
______ of April, 2003, in Ohio.
_____________________________________
Kathleen
Schmeida