Hon.
Richard McDermott
Hearing Date: January 25
, 2002
SUPERIOR COURT OF WASHINGTON FOR KING
COUNTY
|
LARRY PITTMAN, et al., Plaintiffs v. Defendant |
No. 99-2-52345-8KNT DECLARATION OF mary coleman in opposition to defendant's motion for summary judgment |
I, Mary Coleman, declare:
I have read the Defendant's Motion for Summary Judgment to dismiss me. I have also read Defendant's responses to First Set of Interrogatories Propounded by Plaintiffs.
Defendants stated that I had no record to support my claim that I filled out three or four applications for the line-end position. But they stated in several of their documents that they did not keep copies of the applications for promotions. So they can't prove that I did not. I have witnesses who will state that I did apply. I also applied for red meat in writing. At a minimum, Keith Kern and Larry Pittman will witness that I applied for line end several times and that I applied for red meat. I also found a 9/30/99 application of mine for line end pack off. This is attached.
I only got the line end position after the law suit started. I worked for approximately six years without getting this promotion. I have read declarations made by Katie Lemur and Denise Haynes who say that they got promoted to line end before me and that I knew more than they did and I helped train them. So I had the experience and the seniority for that position. I think that leaves out both as factors. So I conclude that race was a factor.
In Defendant's Motion to dismiss me, they take a long time to describe my prison sentence and what I was charged with. I don't see what this has to do with my job at King's Command. I had already quit my job. I don't think it's right for them to bring this up and I don't think it has any relevance.
I told in my deposition about the way Kirk McCoy talked to me and all the blacks. Like he was always angry and resentful toward us. Sometimes it ruined my whole day. I complained to the union about it. They said they were setting up arrangements to have Kirk and Tim--the night shift manager--take anger management classes. I don't know if it ever happened. But because it was the way they talked to all of us blacks, I think it was racial. What else could it be?
The racial slurs at King's Command were made at the black men. I know that Keith Kern was called nigger everyday and had things thrown at him and he had to take a lot of racial abuse. So did Larry Pittman. They went a little easier on the black women, but that doesn't mean that it wasn't a racially abusive environment. It was.
When I quit, I was just fed up with the way I was treated. The way I was always yelled at. The way the other black workers were treated. And the way they promoted whites over me and other blacks and pretended they had reasons for it. It made me feel hopeless.
Even in the Motion to dismiss me, they say that others who were promoted over me had no issues with discipline. Well the basis for promotion is experience and seniority--not discipline. Even while we are in the middle of this suit, they are still making up stories to justify their discriminatory practices.
In October or September of 2000, I* was running my line and we ran out of boxes and I went to Kirk McCoy and he said that wasn't my job and he then said I should go home. He kept on harassing me. I then went to Alan Watson, the shop steward, and then we got the Union Representative. They went to get David Horn. He was yelling and harassing me. He still hadn't taken anger management. I was just trying to do my job.
Sometime in 1999 I was in the lunchroom with Darrell Cody and Kirk McCoy came in and commented loudly "what is this, the run for the border!" referring to the Mexican workers at the table. They were offended by this but too afraid of losing their jobs to say anything.
In one other instance I was in the lunchroom talking to one of the maintenance workers and Kirk McCoy was in there and he was talking loudly that "What's the deal with the Martin Luther King Holiday. Why should we have a day to celebrate the king of Martin Luther King. We should have a day for James Earl Ray". I was shocked. It was just the way the management ran the place.
The foregoing is made under penalty of perjury under the laws of the State of Washington.
DATED this 14th day of January 2002.
___________________________
Mary Coleman
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