Judge Richard McDermott

Noted for 9:00 am January 18, 2002

 

 

SUPERIOR COURT OF WASHINGTON

COUNTY OF KING

 

LARRY E. PITTMAN and SYLVESTER        )

PITTMAN, MICHAEL PITTMAN,                )           No.  99-2-52345-8 KNT

TERRANCE A. DAVIS, KEITH KERN,        )

YOLANDA ESKRIDGE, MICHAEL             )           DECLARATION OF JAMES

DAVIS, GREGORY CODY, DAVID             )           GOODE IN OPPOSITION TO 

LISTIOWEL ABRUQUAH, ARTHUR           )           DEFENDANT’S MOTION FOR 

FOREST, NATHAN A. KILCREASE,           )           SUMMARY JUDGMENT TO DISMISS

JOSEPH A. DONKOR, DARREL CODY,     )           PLAINTIFFS MICHAEL PITTMAN,

MARY COLEMAN, ERIC ARHIN,               )           SYLVESTER PITTMAN, RELASHIA

SHABAE DIQUAN, SIDNEY LANIER,        )           SEARLES AND JAMES GOODE AND

RE-LASHIA SEARLES, JAMES GOODE,    )           IN OPPOSITION TO DEFENDANT’S

CURTIS HOLLIS, and BENJAMIN               )           MOTION FOR SUMMARY JUDGMENT

BARNES, individually,                                     )           TO DISMISS PLAINTIFFS ABRUQUAH,

                                                                        )           BARNES, FOREST, KILCREASE AND

                                    plaintiffs,                       )           HOLLIS

            v.                                                         )

                                                                        )

KING’S COMMAND FOODS, INC.,           )

a Washington business corporation,                   )

                                    defendant.                    )

____________________________________)

 

            I, James Goode, declare:

            I am a plaintiff in this case.

            About June 1998, after several conversations with Larry Pittman, I decided to seek employment with King’s Command Foods, Inc.  Larry told me that they were hiring for meat grinders, and some other possible positions.  At that time, I needed a job.

            I went down to the King’s Command facility in Kent, Washington and went to their office.  I requested an application.  They provided me with an application form and I filled it out.  When I went to turn it in, I was told to see Terry Smith.  He was right there.  I handed the application to Mr. Smith.  I asked him about any possibilities for hiring.  He threw the application on a desk without looking at it.  He looked at me, his demeanor was that of an annoyed man.  He looked like he was upset about something.  He told me that he wasn’t hiring and to call back in a couple of weeks.

            I called back by telephone about ten different times over the six month period following that, into the winter of 1998-1999.  Each time I was told that there was no hiring.  Most of the time, I just called back by telephone.

            I was in Kent checking around several employers about jobs possibilities.  I saw several white employees outside the King’s Command facility on a break.  I talked to these people and they told me that there were some white people newly hired working there.  One of them told me that based on what he heard through the “grapevine”, they weren’t hiring any blacks.  These white employees were not hostile to me, they were just telling me what they know.

            I called into the King’s Command by telephone after this incident and was told that they still were not hiring.  I did not bring up what I was told outside their facility.

            The last time that I called into King’s Command was during the winter of 1998-1999.  After being told that they still were not hiring, I decided not to waste any more time pursuing employment with King’s Command.

 

            I certify under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct.

            Respectfully submitted and sworn to, December 17, 2001,

 

                                                                                    _______________________________

                                                                                    James Goode,              plaintiff

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