LDF Files Complaint Against YMCA for Barring Negroes from Membership and Receiving Complete Use of All Facilities
Press Release
September 9, 1968

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Brief Collection, LDF Court Filings. White v. Norfolk Shipbuilding & Drydock Corporation Proposed Consent Decree, 1973. 7f891b05-c99a-ee11-be36-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/e1a50b1c-5fcc-456f-80c8-00ea3471d25f/white-v-norfolk-shipbuilding-drydock-corporation-proposed-consent-decree. Accessed August 19, 2025.
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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION EDWARD D. WHITE et al., individually and on behalf of all others similarly situated, Plaintiffs, v. NORFOLK SHIPBUILDING & DRYDOCK CORPORATION et al., Defendants. ) ) ) ) Civil Action No. 279-72-N PROPOSED CONSENT DECREE TO PRESENT AND FORMER BLACK EMPLOYEES OR APPLICANTS FOR EMPLOYMENT (OR THEIR FAMILY MEMBERS OR ESTATES) OF NORFOLK SHIPBUILDING AND DRY DOCK CORPORATION In May, 1972, Edward D. White and five other persons filed suit in the United States District Court in Norfolk against the Norfolk Shipbuilding and Dry Dock Corporation [N.S.D.D.], the International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers and Helpers of America, and Local 68^ of this International Union. The lawsuit alleged that the company and the unions had dis criminated against black persons in employment. The suit was brought as a class action whereby the plaintiffs represent all present and former black employees and applicants of N.S.D.D. The plaintiffs and the defendants have agreed to settle the case, and have submitted the proposed terms of settlement, called a Consent Decree, to the Court for approval. The Decree will bar all claims of racial discrimination for any thing occurring up to the Court's approval of the settlement. If you object to any of the terms of the proposed Consent Decree or to the manner in which the monetary settlement is proposed to be dis tributed, you must file objections within the next thirty days. If you wish to file objections, they must be put in writing, and must be received within the next thirty days by the Clerk of Court. His name and address are: W. FARLEY POWERS, JR., CLERK United States District Court United States Court House Norfolk, Virginia 23501 Any document you file should state the name of the case and its number: White v. Norfolk Shipbuilding and Dry Dock Corporation, Civil Action No. 279-72-N. A brief description of the terms of settlement follows: 1. The defendants do not admit that they have ever dis criminated and promise that there will be no discrimination in the future. 2. The Decree will bar all claims of discrimination occurring up to the date of the Court's approval of the settlement. -i- 3. Employees in the Labor and Dock Departments will have a continuing opportunity to transfer to Helper positions in other departments. Their seniority will be carried forward, and they will have a right to bump back into their old depart ments in the event of a layoff. See paragraph 4(a ) of the proposed Consent Decree, on p. 3. 4. Laborers, labor helpers and dock helpers with seniority before 1969 will qualify for training programs, with specified maximum time periods for promotion to higher grades for those performing satisfactorily, if they apply for the program within 60 days after receiving notice of it. For employees who have worked substantial amounts of overtime in the past, there are provisions under which they retain certain rights to work overtime in their old departments. See para graphs 4(C) and 4(d ) of the proposed Consent Decree, on pp. 4-5. 5. Laborers will be given an extra 10 cents an hour when they are loaned out to other departments to work under the other departments' supervisors, except where the loan-out is made to avoid a layoff. See paragraph 5 of the proposed Consent Decree, on p. 5. 6. There are provisions intended to ensure that a fair number of blacks will be placed in N.S.D.D.'s better-paying jobs, including apprenticeships. See paragraphs 6 through 8 of the proposed Consent Decree, on p. 6. 7. N.S.D.D. will appoint a person to try to resolve complaints of discrimination. See paragraph 10 of the proposed Consent Decree, on p. 8. 8. Local 684 will establish an Evaluation Committee to review and evaluate all grievances of minority employees. One member will be selected by the minority employees. Every 6 months, Local 684 will submit reports on the disposition of these grievances to the Court. See paragraph 11 of the proposed Consent Decree, on p. 8. 9. Every 6 months, N.S.D.D. will submit progress reports on the implementation of the Decree to the Court. See para graph 16 of the proposed Consent Decree,on p. 10. 10. N.S.D.D. will pay $ 140,000 and the unions will pay $ 40,000 for the monetary settlement of this case. Plaintiffs' costs in litigating this case, providing notice and distributing the proceeds will be paid out of this amount. Costs are tenta tively estimated at $ 18,891.39. Attorneys' fees are 25% of the remainder, tentatively estimated at $ 40,277.15. The sum to be distributed to the class is tentatively estimated at $ 120,831.46. See paragraph 1 of Appendix B to the proposed Consent Decree, on p. 43. 11. Each of the six plaintiffs will receive $ 2,500, but will not be included under paragraphs 12 to 14 below. See paragraph 2 of Appendix B to the proposed Consent Decree, on p. 43. 12. The sum of $ 20,000 shall be used to redress the claims of all class members who filed proof-of-claim forms. This does not include any claim described in paragraphs 13 or 14 below. See paragraph 3 of Appendix B to the proposed Consent Decree, on p. 43. 13. $ 5,000 is the initial allocation to compensate all class members who lost 6 or more months' seniority upon trans ferring departments from 1965 to 1971. No one who does not fit this description will be paid for loss of seniority. See paragraph 5 of Appendix B to the proposed Consent Decree, on p. 44. 14. $ 75,831.46 is the initial allocation to compensate eligible class members who have worked at least 12 months after July 1, 1965 in any combination of the job categories of Laborer, Paint Laborer, Track Laborer, Laborer Helper, Dock Helper, Truck Driver, Janitor or Janitress. To be eligible, a class member who did not file a proof-of-claim form must have worked for N.S.D.D. on or after June 25, 1967. This requirement does not apply to persons who filed proof-of-claim forms. No one who has not worked a total of 12 months after July 1965 will be included. For Dock Helpers, the 12 months has to have been between July 1965 and December 1970. For Laborers, Labor Helpers and Dock Helpers, only class members hired in 1968 or earlier will be included. For the others, date of hire makes no difference. -iii- See paragraphs 6 through 9 of Appendix B to the proposed Consent Decree, on pp. 44-48. 15. $ 5,000 will be set aside as an escrow fund to cover mistakes in calculations, other valid claims, and unexpected costs. Any amount left one year after the Court's approval of the Consent Decree will be distributed equally to the plaintiffs. See paragraph 12 of Appendix B to the proposed Consent Decree, on p. 50. 16. Former employees who did not fi 1 e proof-of-cla:im forms must Inform the attorneys for plaintiffs, in wri ting, that they desire to share in the monetary settlement. If the attorneys for p 1 a.in ti f fs do not recel ve a. required statement wi thin 30 days from today, the former employee will lose his or her right to share in this money. The required statements must be mailed to: RICHARD T. SEYMOUR Attorney at Law 1763 R Street, N. W. Washington, D. C. 20009 See paragraphs 9 and 10 of Appendix B to the proposed Consent Decree, on pp. 48-50. 17. Appendix A to the proposed Consent Decree lists some information about each person to whom it is proposed to dis tribute money, and some information about each person who filed a proof-of-claim form. If there are any errors, a written cor rection must be received by Mr. Seymour within 30 days from today or it will not be considered. 18. If a class member has died, his immediate family or estate are entitled to his share. Notification requirements still apply, but can be satisfied by executors, administrators, adult members of the person's immediate family, or designated beneficiaries of wages owing at the time of death. See para graph 11 of Appendix B to the proposed Consent Decree, on p. 50. -i v- UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION EDWARD D. WHITE, ct al., ) individually and on behalf ) of all others similarly ) situated, ) ) Plaintiffs, ) ) v. ) Civil Action No, 279-72-N ) NORFOLK SHIPBUILDING & DRYDOCK ) CORPORATION, et al., ) ) Defendants. ) CONSENT DECREE Plaintiffs brought this action against Norfolk Shipbuilding N Drydock Corporation (hereinafter the Company) and the International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers & Helpers, AFL-CIO, and Local No. 684 of said International Brotherhood (hereinafter the Unions) pursuant to Title VII of the Civil Rights Act of 1964, as amended by Public Law 92-261 (March 24, 1972), 42 U.S.C. § 2000e et seq., the Civil Rights Act of 1866, 42 U.S.C. § 1981, the National Labor Relations Act, 29 U.S.C. $ 151 et seq., and § 301(a) of the Labor-Management Relations Act, 29 U.S.C. § 185(a). Jurisdiction is vested in the Court by virtue of 42 U.S.C. § 2000e-5(f), 28 U.S.C. § 1343(4), 29 U.S.C. § 1337, and 29 U.S.C. §§ 185(a) and (c). The Company and the Unions expressly deny any violation of Title VII of the Civil Rights Act of 1964, as amended by Public Law 92-261 (March 24, 1972), 42 U.S.C. § 2000e et seq., the Civil Rights Act of i860, 42 U.S.C. § 1981, or any other equal employment law, regulation or order; or the breach of any provision of an applicable collective bargaining agreement. This Decree and consent hereto does not constitute a finding or an admission of any unlawful or discriminatory conduct by the Company or the Unions. WHEREAS, the plaintiffs, the Company and the Unions are desirous of resolving this matter without the time and expense of further liti gation, and the parties have consented to the entry of this Decree, and it appearing to the Court that the entry of this Decree will further the objectives of the aforementioned enactments, and that the 2 Decree fully protects the rights and interests of all employees and applicants for employment, it is ADJUDGED, ORDERED and DECREED, as follows: 1. General A. Pursuant to this Decree, the instant action is entirely resolved as to the Company and the Unions with prejudice to all claims of racially discriminatory employment practices of ail parties plaintiff and with prejudice to such claims of all members of the class represented by plaintiffs (without regard to whether such members are members of the subclasses entitled to share in the award of back pay, as set forth in Appendices A and B to this Decree) against the Company, the Unions and their respective officers, employees, successors and assigns. B. The class represented by the plaintiffs includes all past and present minority employees of the Company; and all past and present minority applicants for employment by the Company. C. This Decree shall not foreclose the rights of any named plaintiff or class member as to discriminatory practices by the Company or the Unions occurring after the entry of this Decree. 2. Monetary Consideration A. In settlement of all claims and costs (including court costs and administrative costs not heretofore paid in proceedings before this Court) the Company agrees to pay a sum of $140,000 and the Unions agree to pay the sum of $40,000 for a total sum of $180,000 for back pay, counsel fees, costs, in full and final settlement of any and all claims, by said plaintiffs or the class they represent, of racial discrimination in employment, occurring up to the effec tive date of this Decree, against the Company, the Unions, their respective officers, employees, successors and assigns. The Company and the Unions by this Decree release each other of any claim of contribution or indemnification. B. The apportionment of the total $180,000 shall be in accordance with the formula and in the manner set forth in the attached Appendices A and B. Distribution of such funds according to such apportionment shall be the responsibility of counsel for the plaintiffs. Counsel for plaintiffs may rely on the accuracy of information compiled by their agents from Company records or furnished by the Company in response to requests for information. Assuming no showing of a lack of good faith, all parties, including their counsel, will not be liable for miscalculations, omissions or errors in apportionment and distribution. Opportunity will be afforded for class members to object to the proposed apportionment and distribution. 3. Specific Assignments A. Albert Parker will be promoted to the position of Pusher 1 at the first vacancy or within 60 days after the entry of this Decree, whichever occurs sooner. B. Kenneth Cox will be promoted to the position of helper l/C in whichever of the craft departments has the first vacancy (except Plate & Welding). The position is one that will afford the training opportunity contemplated under Paragraph ;*C of this Decree. If no helper l/C vacancy occurs within 60 days after the effective date of this Decree, then the Company will promptly assign Cox to one of those departments as an additional helper l/C. C. Charles D. White, J. A. Moore and Calvin R. Williams will be placed in the first available vacancies within the handyman 3/C category of the Outside Machine Shop. D. The former employees listed in Appendix C will be sent the letter contained in Appendix D and if determined to have been qualified at the time of initial hire at the Company for placement as handyman 3/C or better will bo given a priority over applicants for such placement. h . Transfer Program A. Notice of Transfer Opportunities. The Company will post a notice at a facility readily available to employees of the Labor and Dock Departments of the continuing opportunity to apply for transfer to Helper positions in other departments. Such notice will indicate that employees so transferring will carry their seniority (calculated from their last date of hire) forward into their new department and will have a bump back right to their old department in case of layoff pursuant to Article IX, Sections 4 and 5 of the Labor Agreement, effective March 7, 1973. These notices will further inform employees who believe they have qualifications for placement into a handyman or higher position that they should advise the Personnel Office of their skills and interests. B. Restoration of Seniority. Seniority of all employees who had their seniority altered as a result of transferring at their own request shall be calculated from their last date of hire. C. Training. To ensure that adequate training opportunities are provided to minority employees who are laborers, paint laborers, track laborers, labor helpers, dock helpers, janitors or janitresses with seniority prior to 1969, the Company agrees as follows: All such minority employees who apply for transfer to trade helper or trade handyman positions within sixty (60) days after being informed by letter of the terms of this provision, will, when assigned to such positions, be afforded training opportunities which will, assuming satisfactory job and training performance, enable them to qualify for promotions on the following time schedule: Handyman 3/C - 12-18 months of active employ ment as a helper after the date of this Decree Mechanic 3/C - 36-48 months of active employ ment as a handyman after the date of this Decree The above letter will be issued within thirty (30) days after the final entry of this Decree. The above time schedule shall not be used to extend the time of an individual's progress if his performance and skills merit faster progression, and the Company shall make appropriate good faith efforts to qualify individuals for promotion within the lesser times stated above. The progress of each trainee under this subsection will be evaluated at six-month intervals, and a copy of this evaluation will be forwarded to counsel for plaintiffs. Individuals who are serving as helper l/C and who are transferred pursuant to this subsection to a helper 2/C position will not have their wage rate reduced unless they thereafter decline promotion to a helper l/C position or fail to qualify for such promotion within one year of the time of their transfer. - 5 - D. Overtime Opportunities. Each eligible minority laborer or helper in the Labor or Dock Departments with seniority prior to 1969, who applies for transfer to a helper position in a trade department within sixty (60) days after being informed by letter of the terms of this provision will, for two years after the date of this Decree or until he becomes a handyman 3/C, whichever occurs sooner, have the option in any overtime preference period as defined hereinafter to share equitably in overtime opportunities in his former depart ment which are not accepted by the employee who performed the same work during the preceding shift. To be eligible for this provision, an employee must have had at least 500 overtime hours in the period 1970-72. Those eligible are listed in Appendix E. In allocating an equitable share of such overtime opportunities in the employee's former department, account will be taken of the overtime opportunities the transferee has had in his new department as well as the overtime opportunities which have been made available to him in his former department. It is further understood that to the extent that an employee exercises his option to share in over time in his former department, he may be required to work overtime in that department on the same basis that he could be required to work overtime in his new department. An overtime preference period shall be the three months period immediately following a calendar quarter after the employee's transfer in which quarter (l) the employee was offered at least 15 percent less overtime than his quarterly average listed in Appendix E and (2) the overtime hours worked in his former department equaled or exceeded 85 percent of the quarterly average of overtime worked in that depart ment in the years 1970, 1971, and 1972. 5. Loan Outs Labor Department employees loaned outside the Labor Department shall receive a premium rate of pay of #.10 per hour where the loan- out is for more than three consecutive working days and the loan-out has not been made in part to prevent the employee's being laid off. In such circumstances, the premium rate shall be payable beginning on the fourth consecutive working day. For purposes of this pro vision, an employee is loaned out only when he is directly subject 6 to supervisors of a department other than the Labor Department. A loan-out does not include the assignment of laborers under a Labor Department supervisor to work in another department. 6. Supervisors A. In filling positions of supervisors in the Labor Depart ment, first consideration shall be given to then current employees in the Department. B. The Company will make a good faith effort to increase the utilization of minority employees as supervisors in all departments., 7. Helper — Laborer Assignments In each year during the life of this Decree, approximately the same ratio of minority to white employees shall be attained in the assignments of new hires made to each of the following positions: trade helper, dock helper, laborer, paint laborer, track laborer, and janitor or janitress, provided that at all times the Company shall be free to make necessary assignments if employees of only one race are presently available for such an assignment and provided further that in determining compliance with this requirement ratios will be based on actual offers of assignments without regard to whether or not the offers were accepted. The company shall not offer trade helper positions to an applicant who has rejected a laborer position within the previous thirty (30) days except where necessary to fill a vacancy and where necessary to meet the assignment ratios provided for in this paragraph. 8. Minority Placement Rates A. Except as provided in paragraph B below, in each year during the life of this Decree, at least 25 percent of the place ments (new hires and promotions) as mechanics in each trade and 25 percent of such placements as handymen in each trade and 25 percent of such placements as apprentices will be minority group members. B. (l) In each year during the life of this Decree the follow ing rates shall apply for the placement (new hires and promotions) of minorities in the positions listed unless the percentage of minorities employed in such positions reaches 20 percent, in which case only the terms of provision 8.A. above will apply: 7 Sheet Metal handyman - 50% Crane Operator - 50% Guard - 33-1/3% Rigger handyman - 33-1/3% (2) With respect to the following positions, the placement rate of minorities (new hires or promotions) will be 50 percent until there is at least one minority employee in the position, in which case only the terms of paragraph 8.A. will apply: Power Plant Operator - Power Plant Maintenance Storeroom Maintenance Machinist Tug and Launch Captain C. The specified minority placement rates in paragraphs 8.A. and 8.B. above are subject to availability of qualified minority persons willing to accept such positions. It shall be a defense and an appropriate excuse that the Company has in good faith sought to recruit a qualified minority person to fill a vacancy, from the sources listed in Appendix F, but does not have a current application of such a person. D. Nothing in this Decree shall be construed to prevent the Company from exceeding the goals of minority placement and utilization set forth above. E. The high school diploma requirement shall not be used to the extent that it precludes reaching the minority placement rate for apprentices. The Company will make its best efforts to assure that minority apprentices are not concentrated in particular depart ments but are widely represented among the different departments covered by the apprenticeship program. 9. Vocational Training The Company agrees to determine the feasibility of further participation in or cooperation with training programs sponsored by public vocational education organizations in the metropolitan Norfolk area. In this connection the Company will offer to nominate Company representatives to vocational craft committees relevant to shipyard work and will notify current employees of offsite training courses that will provide relevant training opportunities outside working hours to the extent such notification will not obligate the Company to compensate the employees for time spent in such training. Tin? Company further agrees to recommend improvements in existing offsite training opportunities for potential applicants and present employees and the establishment of additional training courses or programs relevant to shipyard work to the extent such actions will not obligate the Company to compensate employees for time spent in such training. By September 30, 1973, the Company shall prepare a report on the feasibility of further participation and cooperation in public voca tional training programs. Such a report will give due consideration to all types of training possibilities. The Company further agrees to discuss this subject with counsel for plaintiffs should the latter believe, after receiving the feasibility report, that the Company is not adequately participating in or cooperating with such vocational training programs. 10. EEO Compliance Officer The Company will designate an EEO officer to assure compliance with the terms of this Decree and will post a notice to all employees of this designation. The EEO officer will be authorized to receive employee complaints of discrimination and to investigate and seek resolution of such complaints. 11. Union Monitoring Procedure A. The Local Union agrees to establish and maintain during the life of this Decree, an Evaluation Committee to review and evaluate all grievances of the minority employees of the Compahy. This Com mittee shall consist of the president and vice-president of the Union, a member selected by the minority employees and two other members selected by the Local Union. B. The said Committee shall meet at least quarterly and shall have the responsibility to review and evaluate all grievances of minority employees and to assist the Shop Stewards in resolving these grievances. C. Any minority employee of the Company having a grievance hampered by the action or inaction of his Shop Steward shall have the option of filing his grievance with the president of the Union; pro vided, however, that any such grievance shall be pursued in accordance with the terms of Article XI "Grievance Procedure" of the Labor Agreement. - 9 - D. The Local Union will prepare and submit to the counsel for all parties reports indicating the disposition of grievances of minority employees, commencing on July 1, 1973 and thereafter semi annually. A final progress report will be submitted at least twenty (20) days prior to the expiration of the terms of this Decree. E. The Company and the Local Union shall cooperate with each other in fulfilling their respective obligations under this Decree. 12. Term of the Decree This Court retains jurisdiction of this action for a period of four (^) years for the purposes of assuring compliance with this Decree. After that time, the Decree shall be dissolved. At any time that this Decree works an unexpected or undue hardship upon the Company, it may move for appropriate modification, upon thirty (30) days notice to plaintiffs. If there has not been substantial progress in minority utilization in categories aggregating a sub stantial number of positions, this Court, upon motion of plaintiffs, may extend the terms of this Decree to cover those positions for a period not to exceed two (2) years. 13. Complaint Procedure If, at any time during the term of this Decree, any complaints or instances of possible non-compliance come to the attention of plaintiffs, the Company and/or the Union as appropriate shall be notified in writing and permitted to investigate and rectify any complaints. Internal procedures, such as the grievance procedures, may be used to resolve the problem. If the matter is not resolved to the satisfaction of plaintiffs within thirty (30) days of the Company's and/or the Union's receipt of this notice, plaintiffs may move for an appropriate resolution by the Court. This section shall not be construed as a limitation in seeking judicial review after said thirty (30) days. 14. Exclusive Remedy It is agreed that this Consent Decree embodies the exclusive remedy as to the Company and the Unions for any claims of employment discrimination against plaintiffs and the class they represent aris ing prior to the entry of this Decree, and that no other actions will 10 be brought against the Company and the Unions with respect to such claims in any forum, administrative or judicial. 15. Notice A. The Company will provide counsel for plaintiffs with a mailing list for present minority employees and as accurate and complete a list as possible of former minority employees for direct mailing of a copy of this Decree and of Appendices A through E. B. A summary of this Decree, including the proposed method of monetary distribution, will be published once in the Norfolk Journal and Guide and the Virginia Pilot. The text of the notice shall be as set forth in Appendix G hereto. The notice will expressly afford to members of the class, and persons excluded from the class by the definition herein, opportunity to file objections to this Decree, or proposed corrections to the factual information contained in Appendix B, with this Court no later than thirty (30) days following the date of publication of the notices. Promptly following such publication, plaintiffs shall submit' to the Court and to each defen dant herein a certificate attesting to said publication and the dates thereof, and shall submit therewith actual or xeroxed copies of the notices as published. In the absence of any such objections within the aforesaid thirty (30) days, this Decree shall become final without further action by this Court. 16. Monitoring and Reporting A. In connection with implementation of this Decree, the Company will monitor job placements and maintain records. The Company will prepare and submit a copy to counsel for all parties of progress reports commencing January 1, 1972*, and thereafter semi-annually. A final progress report will be submitted to counsel for all parties, at least twenty (20) days before expiration of the terms of this Decree. B. At annual intervals during the life of the Decree, the Company will submit to counsel for all parties a report covering the positions under the Program showing name, race, job classifi cation, employee number and date of employment of all employees of the Company. The Company shall promptly advise counsel for all parties of any changes in the coding systems used to record such informati on. J u d g e K e l l ant U n i t e d S t a t e s D i s t r i c t C o u r t -12- APPENDIX A LISTS OF PERSONS ENTITLED TO SHARE IN THE MONETARY SETTLEMENT In accordance with the provisions of Appendix B, each of the plaintiffs will receive the amount of $2,500 and shall not share under any of the other provisions for distributing the monetary settlement. The remainder of the monetary settlement available for distribution to the class will be distributed according to the following lists. Persons may appear — and share — on more than one list. Page List 1 Persons who filed proof-of-claim forms 13 List 2 Persons who lost six or more months' seniority in transferring departments 27 List 3 Eligible present and former laborers 28 List 4 Eligible present and former paint laborers and track laborers 34 List 5 Eligible present and former labor helpers 35 List 6 Eligible present and former dock helpers 37 List 7 Eligible present and former truck drivers 41 List 8 Eligible present and former janitors and janitresses 42 Note: To be "eligible" in lists 3 through 8, a person must have worked a total of at least twelve months, since July 1965, in any combination of these job categories. In addition, persons who did not file proof-of-claim forms must have worked for N.S.D.D. on or after June 25, 1967. See Appendix B for details. CAUTION: The "estimated amounts of back pay" are only estimations. They may be a little larger or a little smaller. Some taxes may also have to be withheld on part of the amounts involved. Persons marked with an asterisk (*) before their name must send a postcard to the attorneys for the plaintiffs by the deadline or they will lose their rights to receive money, and everyone else's share will increase according ly. If you see any mistakes in this table, notify the attorneys for plaintiffs _as soon as posslble since nothing can be done about the mistake after the final calculations have been made. Check for your name on all lists. -13- 1. LIST OF PERSONS WHO FILED PROOF-OF-CLAIM FORMS The following list shows the best judgment of the attorneys for plaintiffs on the merits of each proof-of-claim form filed in this case. Each person's claim has been given a rating of up to ten points, reflecting the following factors: likelihood that the claim is true, based upon the extensive depositions and voluminous discovery taken herein, degree of economic loss, length of time the alleged discriminations continued, recency of the events involved, factors mitigating the defendants' alleged conduct, problems of proof if the claim had had to have been litigated at trial, and likelihood of success in the event of such litigation. The following list does not include any claims of a type covered in any other lists, but is in addition to any such allocations. Of the total $180,000 settlement, $20,000 has been set aside for the payment of the claims in this list. In the judgment of counsel for plaintiffs, this is an adequate and fair amount of the total settlement to be allocated for these claims. Many of the persons filing proof-of-claim forms did so more to bring facts they considered important to the attention of the Court and of the parties than to seek money for themselves. Without this information, it might not have been possible to reach this settlement, and they are commended for their co-operation. None of the persons who filed a proof-of-claim form is required to send a postcard to counsel for plaintiffs; each is eligible to receive his or her share without any further action on his or her part. The "estimated amounts of back pay" are tentative and may be a little larger or a little smaller. If you see any mistakes in this table, notify the attorneys for plaintiffs as soon as possible since nothing can be done about the mistakes after the final calculations have been made. -14- C AC TT ON: SOME TAXES Ml'ST HE WITHHELD. Estimated Amounts for Claims Points On this List______ 1. Adamson, James E. (230 66 5020) Claims on initial assignment and den ial of apprenticeship application 1 $ 79.68 la. Allen,Eugene C. Did not state any claim — __ Alston, Herbert Apprenticeship claim 1 79.68 3. Alston, Robert L. Facts are not enough to show discrimination 4. Amos, Albert S. All valid claims covered in other lists 5. Andrews, Joan P. No claim stated — — 6. Armstrong, Annie E. Covered on Janitors’ list __ -- 7. Artis, Laurence H. Facts are not enough to show discrimination 8. Askew, Bennie Covered on Laborers' list — — 9. Askew, Bernard Covered on other lists __ — 10. Askew, Crist Facts are not enough to show discrimination 11. Baker, Linwood Sr. Did not state a claim — — 12. Baker, Samuel Facts do not show discrimination — — 13. Barbour, George Did not state a claim __ — 14. Barbour, Jeff III (225 68 5066) Loan-outs and apprenticeship claims 1 79.68 15. Barnard, Pearlie Covered on Dock-Helper list — — 1 6. Barrett, Calvin L. (227 50 5745) Initial assignment claim 2 159.36 17. Batts, Rufus (223 56 0370) Initial assignment claim 1 79 .68 18. Bell, Roland L. Sr. Facts do not show discrimination — — 19. Benson, Albert L. (229 54 2480) Apprenticeship claim 5 398.41 20. Bernard, Paul L. No claim stated Points Estimated Amounts for Claims On this List______ -15- CAUTION: SOME TAXES MUST BE WITHHELD. 21. Billups, Lewis B. Facts do not show discrimination __ — 22. Blowe, Paul D. (224 66 1982) Transfer and apprenticeship claim 1 $ 79.68 23. Bolar, Eddie Facts not enough to show discrimination __ — 24. Boone, Bobby L. Covered in List of Plaintiffs _ _ 25. Bowden, Allen (46l 26 6918) Initial assignment claim 2 159.36 26. Bowers, Junius L. Claim outside a recent enough period — — 27. Boyce, Charles Facts do not show discrimination — _ 28. Boyd, Bruce E. (228 36 2150) Apprenticeship claim 1 79.68 29. Branch, Lorenzo E. (228 80 4705) Initial assignment claim 3 239.06 30. Bright, George L. Facts do not show discrimination — — 31. Brown, Arthur T. Facts do not show discrimination — — 32. Brown, Matthew III (225 56 1736) Racial antagonism claim 3 239.06 33. Brown, Milton L. (228 20 6930) Initial assignment claim; also covered on Truck Drivers' list 1 79.68 34. Brown, Warden E. (512 30 8176) Initial assignment claim 1 79.68 35. Brown, William T. Facts do not show discrimination — _ 36. Bryant, Jahugh (226 22 0265) Initial assignment claim 3 239.06 37. Bryant, James A. (243 20 4940) Claim of failure to promote 10 796.81 38. Bryant, William E., Jr. (246 40 6871) Claim of failure to promote 10 796.81 39. Burke, Elmo Jr. Did not work long enough to share — — 40. Bynum, Jesse J. Facts do now show discrimination — — 41 . Caldwell, Elmer (262 66 5306) Initial assignment claim 1 79.68 42. Calhoun, Huey D. Failure to re-assign after injury 1 79.68 43. Cameron, Lonzia Covered on Laborers' list — — 44. Carroll, William H. Did not state any claim; covered on Laborers' list Points Es tima ted Amounts for Claims On this List __ -16- CAUTION: SOME TAXES MUST BE WITHHELD„ 45. Chamberlain, Ronald G. Did not work long enough to share — — 46. Chatman, Leroy Facts not enough to show discrimination — __ 47. Cherry, Conston A. (230 14 1416) Failure to promote claim 3 $239 .06 48. Chesson, William T. Jr. (228 32 0327) Initial assignment claim 1 79 .68 49. Clinkscales, Henry E. Did not state any claim — — 50. Collin.s, James (254 5^ 6917) Failure to promote claim; also covered on Laborers’ list 2 159.36 51. Collins, Raymond Jr. Initial assignment claim 1 79.68 to Cooper, Louiss R. Facts do not show discrimination 53. Copeland, Coley Jr. (228 52 2562) Claim of occupational disease and failure to re-assign; also covered on Dock Helpers’ list 5 398.41 54. Corprew, Joseph L. Did not work long enough to share 55. Covington, Harold C. Initial assignment and unequal pay claims 1 79.68 56. Cox, Kenneth L. Covered on List of Plaintiffs — — 57. Cradle, William H. Did not work long enough to share — — 58. Crocker, Lloyd W. Did not state a claim — — 59. Cromuel, March Jr. (262 52 7728) Hiring and recall claims 1 79.68 60. Cuffee, Joseph A. Did not state a claim. 61. Cuffee, Ronald B. Did not state a claim. — — 62. Cuffee, Reginald T. Did not state a claim — — 63. Gurney, Milton E. Did not state a claim — — 64. Daniels, Edward B. Covered in Dock Helpers' List — — 65. Daugherty, Marvin (227 72 5730) Initial assignment claim and failure to give lighter work after injury 2 159.36 66. Davis, Valelicch L. (224 66 1962) Failure to re-assign claim 1 79.68 CAUTION -17- : SOME TAXES MUST BE WITHHELD. Points Estimated Amounts for Claims On this List 6 7. Dawkins, Alice Did not state a claim; covered on Janitors’ list — 68. Dawkins, Elford Covered on Dock Helpers’ list — _ _ 69. 70. DeBerry, John H., Jr.Initial assignment and failure to promote claims 1 DeLoateh, Franklin R. Covered on Paint Laborers’ List — $ 79.68 71. Dildy, Larry K. (223 72 1279) Initial Assignment and Failure to reassign to avoid layoff 3 239.06 72. Dodson, Daryl (224 70 5743) Discharge claim 2 159.36 73. Dorsey, Norman H. Facts not enough to show discrimination — _ _ 74. Dowdy, John H. (228 36 5603) Discharge for garnishment claim 2 159.36 75. Driver, Rudell Facts not enough to show discrimination — — 76. Dukes, Horace T. Facts not enough to show discrimination — — 77. Dukes, James L. Ill Did not state a claim — — 78. Durham, Carl M. (230 68 5680) Initial assignment claim 1 79.68 79. Eason, Wagus E. Covered on Dock Helpers' list — 80. Edwards, Milton L. Did not state a claim — 81. Elliott, Lloyd C. Apprenticeship claim 1 79.68 82. Elliott, Junius D. Covered on Dock Helpers’ list — — 83. Epps, Doris E. Covered on Janitors’ list — — 84. Evans, Leroy Covered on Laborers' List — 85. Farmer, Ronnelle W. (294 50 3153) Initial assignment claim 1 79.68 86. Faulk, David T. Did not state a claim; covered on Dock Helpers' list — 87. Faulkins, Tom L. Facts not enough to show discrimination — _ _ 88. Felton, Leroy Facts not enough to show discrimination — — 89. Finch, Charles E. (230 44 9536) Discharge claim 1 79.68 90. Flowers, Orren T. Apprenticeship claim 1 79.68 Po ints Estimated Amounts for Claims On this List______ -18- CAUTION: SOME TAXES MUST HP WITHHELD. 9 1 . Fly the, David L. Facts not enough to show discrimination — 92. Ford, Robert (228 34 6058) Unequal pay claim; covered on Dock Helpers' list 93. Ford, Willie L. Facts not enough to show discrimination — 94. Forrest, James A. Did not work long enough to share — 95. Foster, Archie L. Did not work long enough to share — 96. Freeman, Linwood W. Covered on Laborers' list _ _ 97. Fulgham, James L. Failure to promote claim 1 98. Fuller, George E. Did not work long enough to share — 99. Gardner, Freddie Facts do not show discrimination _ _ 100. Garrett, Clarence M. (231 50 0086) Failure to promote claim; also covered on Dock Helpers' list 2 101. Gibbs, Samuel E. Covered on Dock Helpers' list _ _ 102. Gibson, Paul (228 42 7833) Initial assignment claim 2. 103. Giddens, Donald M. Did not work long enough to share — 104. Gilliam, Arthur J. Facts do not show discrimination 105. Gilliam, Milton V. Hiring and failure to promote claims 2 106. Gormandy, Eric It. (227 26 1383) Claim of failure to re-assign to take account of disability 1 107. Gray, George E. Did not work long enough to share _ _ 108. Greene, Alphonso Did not work long enough to share — 109. Griffin, Joseph (231 03 2270) Initial assignment claim 1 110. Griffin, Quince D. Apprenticeship claim 1 111. Guy, Leonard L. (225-46-8707) Failure to promote to supervisory position; also covered on Laborers' list and on Labor Helpers' list 2 112. Hammond, Earl Did not state a claim — 113. Hampton, Earl J. (227 66 5829) Loan-out, apprenticeship and discharge claims; also covered on Laborers' list 7 $159.36 79.68 159.36 159.36 159.36 79.68 79.68 79.68 159.36 557.77 114. 115. 116. 117. 118. 119. 120. 121 . 122. 123. 124. 125. 126. 127. 128. 129. 130. 131 . 132. 133. 134. 135. 136. CAUTION -19- : SOME TAXES MUST BE WITHHELD. Estimated Amounts for Claims Points On this List______ Harris, James E. (246 64 0624) Supervisory promotion and demotion claim also covered on Laborers' list 2 $159.36 Harris, Emery Jr. Facts not enough to show discrimination — — Harris, Samuel Did not work long enough to share — — Harvey, William (231 34 2511) Failure to promote claim 4 318.73 Haskett, William J. (226 56 8362) Failure to promote claim; also covered on Laborers' list 2 159.36 Hill, Joe Lee Facts do not show discrimination — — Hines, Bruce C. Racial antagonism olaim 1 79.68 Hinton, Garland (227 72 5124) Apprenticeship claim 2 159.36 Holliday, David L. (237 70 4028) Apprenticeship and loan-out claims 3 239.06 Holloway, Oliver W. Deceased, no claim shown from records — — Hopkins, Shirley B. (227 50 6206) Initial assignment, unequal pay and antagonism claims 239.06 Howell, Arthur C. Failure to promote claim 2 159.36 Jackson, Cleraith A. Facts do not show discrimination — — -Jackson, Harvey Jr. (228 80 1721) Initial assignment claim 1 79.68 James, Rudolph Did not work long enough to share — — Jamison, Michael Did not work long enough to share — __ Jenkins, J. J. Covered on Laborers' list — — Johnson, Alonza I.. (232 60 6644) Loan-out claim 1 79.68 Johnson, Ira Facts not enough to show discrimination — — -Johnson, Michael (227 66 510b) Discharge claim 1 79.68 -Johnson, Robert A. (230 66 4389) Initial assignment and apprenticeship claims 1 79.68 -Johnson, Ward T. (223 3b 6741 ) Initial assignment claim 1 79.68 -Jones, Don L. ,(230 66 4764) Apprenticeship claim 1 ccr- l Jones, George L. W. Racial antagonism claim 79.68 -20- CAUTION: SOME TAXES MUST BE WITHHELD. Points 138. King, Garland C. No pay loss claimed __ 139. Lamp, James W. (231 34 0345) Promotional claim 1 140. Lancaster, James E. Covered on Dock Helpers' list __ 141. Lassiter, Billy L. Facts not enough to show discrimination 142. Lassiter, Roland C. Did not work long enough to share 143. Lee, Alfred H. (227 56 2666) Failure to promote claim 10 144. Lewis, Charles Most of claim not within a recent enough period; for rest, did not work long enough to share 145. Lewis, Ernest R. Did not state a claim 146. Lindsey, Ellis L. (230 78 6221) Discharge claim 1 147. Lockhart, James T. Claim not within a recent enough period 148. Long, Charlie L. Covered in Dock Helpers' list 149. Lowe, Edward M. Did not work long enough to share 150. Madison, John D. Failure to promote claim 3 151. Madison, Larry D. Covered on Laborers' list; facts on pay claim not enough to show discrimination — 152. Majette, Graham Covered on Laborers' list and on Dock Helpers' list 153. Martin, George W. Covered on Dock Helpers' list 154. Mason, Zollie Jr. Did not work long enough to share — 155. Mathis, Marvin F. Covered on Laborers' list — 156. Mayfield, Augustus (255 60 9231) Layoff and loan out claims; also covered on Laborers' list 1 157. McCoy, Linwood F. Covered on Dock Helpers' list 158. McCoy, Woney Covered on Dock Helpers' list 159. McKinnon, Cezar J. Covered on Dock Helpers' list 160. Miller, Reuben L. (228 20 4067) Failure to promote claim Estimated Amounts for C! On this List a 79.68 796.81 79.68 239.04 79.68 7 557.77 -21- CAUTION: SOME TAXES MUST BE WITHHELD. Estimated Amounts for Claims Points On this List 161. Mitchell, Melvin L. Failure to promote claim; also covered on Dock Helpers* list 2 $ 159.36 162. Mitchell, Morris E. Claims not within a recent enough peri od 163. Mitchell, Roy Initial assignment claim 1 79.68 164. Moore, James A. (219 38 0565) Initial assignment claim 2 159.36 1 6 5. Moore, Quindell G. (241 74 8141) Discharge claim 1 79.68 166. Morgan, Donnie L. Did not work long enough to share 1 6 7. Morgan, Joe Did not work long enough to share 168. Moseley, Glenn K. (225 60 6940) Layoff and discharge claims; also covered under Laborers* list 1 79.68 169. Moss, Alfred D. (227 50 7133) Discharge claim 1 79.68 170. Newby, Eddie L. Facts not enough to show discrimination 171. Newby, William F. Covered on Laborers' list 171a. Newsome, Isaiah Failure to promote claim 5 398.41172. Nixon, Frederick D. (227 56 4129) Initial assignment and failure to promote claims 2 159.36 173. Nixon, Herman R. Did not state a claim 174. O'Neal, Moses (231 44 7482) Loan-out claim; also covered on Laborers' list 1 79.68 175. Owens, Thomas A. No records show discrimination 1 7 6. Parker, Albert L. Covered on Plaintiffs' list . . 177. Parker, Eldridge L. Covered on Laborers' List and on Truck Drivers' list 178. Parker, Jackie R. (229 70 4199) Initial assignment and discouragement of transfer claims 1 79.68 179. Patterson, Robert L. Did not work long enough to share __ 180. Peede, Carlton E. (227 56 4485) Apprenticeship, loan-out and dis couragement of transfer claims; also covered on Laborers' list 3 239.06 181. Peoples, Ethel Covered on Janitors* list — __ 182. Perry, Charles E. Did not state a claim -22- CAUTION: SOME TAXES MUST BE WITHHELD. Estimated Amounts for Points On this List 183. Person, Amos Did not state a claim _ _ — 184. Phillips, Willie E. Covered on Dock Helpers' list — __ 185. Pierce, Clifton E. (228 62 3563) Antagonism claim 2 $159.36 186. Pope, Edmond L. Facts do not show discrimination — — 187. Pitt, Herbert Initial assignment claim 1 79.68 188. Porter, .James H. (241 64 4783) Deprivation of training claim; also covered on Laborers' list 2 159.36 189. Powell, Garfield Covered on Dock Helpers' list — — 190. Powell, Joe L. Jr. Did not file a claim — __ 191. Prayer, Bobby J. (230-68-4242) Loan-out claim; also covered on Laborers' List 1 79.68 192. Pugh, Carlton E. (227-72-4939) Antagonism and discharge claims 7 557.77 193. Ramseur, Anthony (238-34-6315) Initial assignment claim 2 159.36 194. Reid, George Lee Covered on Laborers' List __ __ 195. Reid, Harvey E. Did not work long enough to share __ __ 196. Richardson, Alphonso Covered on Laborers' List 197. Riddick, Cleophus L. Facts not enough to show discrimi nation 198. Riddick, Ernest Failure to re-assign to lighter work when ill; also covered on Laborers' List 3 239.09 Riddick, Obie (223-20-7699) Pay claim; also covered on Dock Helpers' List 1 79.68 Roberts, Columbus (230-18-8802) Loan-out claim 1 79.68 Robinson, Benny A. (227-48-3970) Initial assignment claims 1 79.68 202. Rodgers, Robert L. Did not work long enough to share 203. Roscoe, Horace G. Covered on Loss-of-Seniority List Claims 1 7 9 . 6 8 CAUTION: SOME TAXES MUST BE WITHHELD.-23- Points 2 0 k . Roscoe, Isaiah L. Did not work long enough to share 205. Sanderlin, Henry L. Did not work long enough to share 206. Savage, Gerald Lee Covered on Dock Helpers’ List 207. Sawyer, William (230-66-2986) Failure to reassign when health so required 3 208. Scott, William E., Jr. Did not state a claim 209. Short, Willie C. Covered on Laborers' List; facts as to other claims do not show discrimination within a recent enough period — 210. Simmons, Duke (231-03-7038) Failure to promote claim for period recent enough to allow recovery 2 2 1 1. Simms, Willie R. Covered on Paint Laborers' List 212. Simon, John, Jr. Facts do not show discrimination 213. Simon, Sinclair Facts do not show discrimination 2\k. Slight, Charles E. Covered on Dock Helpers' List 215. Smith, Helen N. (228-52-3369) Antagonism claim 2 216. Southall, Mack, D., Jr. Facts not enough to show discrimination 217. Smith, John E. (238-20-9383) Initial assignment claim 8 218. Sparrow, George R. Facts not enough to show discrimination 218a. Sparrow, Marvin L. Discharge ulaim 3 219. Speight, Joseph C. Covered on List of Plaintiffs 220. Spencer, Clarence Facts not enough to show discrimination 221. Spires, Eugene R. (423-52-5447) Initial assignment claims and recall claim k 222. Spraggins, James E. Covered under Laborers' List 223. Spraggins, Willie L. (230-52-7619) Layoff claim Estimated Amounts for Claims On this List #239.06 159.36 159.36 637.45 239.04 318.73 1 79.68 -24- CAUTION: SOME TAXES MUST BE WITHHELD. Points 224. Spruill, Larry E. Covered on List of Plaintiffs — 225. Steeley, Clarence C. Covered on List of Laborers — 226. Stevens, William H. Covered on List of Dock Helpers — 227. Stevenson, Wylie, Jr. (231-34-1330) Failure to promote claim; also covered on Dock Helpers' List 2 228. Stevenson, Richard 0. Did not work long enough to share — 229. Stevenson, Sylvester (227-12-5995) Initial assignment claim 1 230. Stokley, Joe N. Did not work long enough to share — 231. Stokes, William A. Facts not enough to show discrimination — 232. Stokley, Roy L. Covered on Dock Helpers’ List — 233. Stokley, Willie L. Covered on Dock Helpers' List — 234. Sturdivant, Pursell (251-56-2468) Loan-out claim; also covered on Laborers' List 1 235. Surratt, Charles H. Facts not enough to show discrimination — 236. Sykes, Timothy D. (228-60-8386 Loan-out and apprenticeship claims; also covered on Laborers' List 2 237. Taylor, Leroy I. Facts not enough to show discrimination — 238. Taylor, Randolph (223-72-9104) Claim of recall discrimination and deprivation of training opportunities 1 239. Thompson, Henry L. Facts not enough to show discrimination — 240. Thornhill, Ima J. (045-34-5765) Promotion and layoff claims 1 241. Thornton, Carlton E. Covered on Laborers' List 242. Tilghman, Wesley Covered on Dock Helpers' List — 243- Tillmon, Theodore (432-32-4658) Initial assignment claim 2 244. Tyler, Samuel V. Failure to transfer; also covered on Dock Helpers' List Estimated Amounts for Claims On This List #159.36 79.68 79.68 159.36 79.68 79.68 159.36 1 7 9 . 6 8 -25- c au t i o n : SOME TAXES MUST BE VITIfHELi). Points 2'*5. Vaughn, Alvester, Jr. (223-56-0857) Initial assignment and failure to promote claims 2 2^6. Ward, David Covered on Laborers’ List and on Labor Helpers' List — 247. Ward, Dewey It. Did not work long enough to share — 248. Waters, Lloyd T. Did not work long enough to share — 249. Whidbee, Roger L. Facts not enough to show discrimi nation — 250. White, Edward B. Racial antagonism claim 1 251. White, Edward D. Covered on List of Plaintiffs 252. White, J. Alexander Covered on Dock Helpers' List — 253. Whitehurst, Luther A., Jr. (243-42-2490) Initial assignment claim 1 254. Whitehurst, Melvin R. Covered on Dock Helpers' List 255. Wiggins, Cecil Initial assignment claim not within a recent enough period; is covered on Laborers' List and on Truck Drivers' List .— 256. Wilkins, Patrick E. (230-68-6397) Apprenticeship claim 1 257. Williams, Calvin R. Did not state any claim — 258. Williams. Charlie A. Covered on Laborers' List 259. Williams, Donnell R. (238-72-9237) Initial assignment claim 1 260. Williams, Elwood N. (243-42-7409) Racial antagonism claim 1 261. Williams, James L. Did not work long enough to share — 262. Williams, Leroy (231-09-7351) Allocation of work claim 1 263. Williams, Luther B. Did not work long enough to share 264. Williams, Mamie W. (228-20-3081) Layoff claim; also covered on Janitors' List 8159.36 Es(i ma ted Amounts for Claims On 'Hiis hist______ 79.68 79.68 79.68 79.68 79.68 79.68 1 79.68 CAUTION; SOME TAXES MUST BE WITHHELD. Estimated Amounts for Claims Points On This List______ 265. Williams, Martha D. (231-09-2914) Layoff,recall and discharge claims 6 i 478.09 266. Williams, Roland (241-48-5202) Failure to promote claim; also on Dock Helpers’ List 2 159.36 267. Williams, Wesley T. Covered on Laborers’ List — — 268. Williams, William H. (225-28-3159) Discouragement of transfer; also covered on Dock Helpers' List 1 79.68 269. Wilson, Edward Leon Did not work long enough to share — — 270. Wilson, Frank L. Did not work long enough to share — — 271. Winborne, Delmus D. (225-74-8938) Apprenticeship; layoff and antagonism claims 2 159.36 272. Winfield, Henry L. Facts not enough to show discrimi nation during the short period of time employed 273. Winnegan, Wardell (229-30-5i*49) Failure to promote claim 2 159.36 274. Winslow, James, Jr. Did not work long enough to share — — 275. Wood, Lawrence (229-5^-1051) Loan-out and failure to promote claims; also covered on Laborers' List 5 398.41 276. Young, Arthur Did not work long enough to share TOTAL: 251 8 20,000.00 -27- LIST 2 Black Persons Who Lost Six or More Months Transferring Departments (Excluding Other With Less Than Six Months Lost) ' Seniority in Transfers Name Months’ Seniority Lost on Transfer Estimated Minimum Amounts of Back Pa Albert Amos 65 $217.39 *C. Baker 16 53.51 *Dallas Battle 16 53.51 *P. K. Boykins 24 80.27 C . R . Brown 7 23.42 R. L. Cherry 13 43.48 *Howard S. Claggion 14 46.82 James Collins 89 297.66 *C. Copeland 21 70.23 Eddie Cox k2 140.47 H. A. Farrell kO 133.78 *George Foy 23 76.92 M. L. Futrell 83 277.59 *Walton B. Heckstall 13 43.48 *W. J. Hill 125 418.06 A. C. Howell 56 187.29 *Roosevelt Johnson 15 50.17 *John L. Kelly 33 110.37 *Mitchell 0. Mack 30 100.33 L. D. Madison 27 90.30 *Daniel Mann 17 56.86 Augustus Mayfield 13 43.48 R. L. Owens 35 117.06 *W. H. Reich 10 33.44 J. R. Robertson kk 147.16 S. N. Robinson 39 130.43 H. G. Roscoe 31 103.68 *R. R. Roscoe 23 76.92 J. McC. Ruffin 115 384.62 R. L. Ruffin 115 384.62 *J. E. Smith 61 204.01 R. L. Stancil 17 56.86 R. D. Stokley 60 200.67 V. L. Tolliver 12 40.13 Wesley T. Williams 29 96.99 A. McC. Wilson 11 36.79 J. M. Winfield 41 13 7.12 *J. Wright, Jr. 70 234.11 TOTAL MONTHS 1,495 $5,ooo!oo CAUTION: SOME TAXES MUST BE WITHHELD -28- 3. LIST OF PRESENT AND FORMER LABORERS ELIGIBLE TO SHARE IN THE BACK PAY SETTLEMENT FOR TIME WORKED AS LABORERS See Appendix B for an explanation of the means used to determine which present and former laborers are eligible to share in the back pay settlement for the time they worked as laborers, and the means used to calculate their share. CAUTION: The "estimated amounts of back pay" are only estimations. It may be a little larger or a little smaller. Persons marked with an asterisk (*) before their name must send a postcard to the attorneys for plaintiffs by the deadline or they will lose their rights to receive money, and everyone else’s share will be increased accordingly. If you see any mistakes in this table, notify the attorneys for plaintiffs as soon as possible since nothing can be done about the mistake after the final calculations have been made. Check for your name on other lists as well. Name Social Security Number *Adams, George Westley, Jr. 122-40-6923 Alston, Stanley, Jr. 240-60-2816 Amos, Albert 224-40-1608 Askew, Bennie-^/ 224-54-5087 Askew, Bernard 227-48-4697 Anderson, James Roosevelt 224-54-5408 ♦Baker, C. 230-07-1363 ♦Battle, D. 237-50-2474 *Batts, T.E. 224-50-2660 ♦Beale, R.S. 226-22-6729 Beamon, Jerry 239-48-8290 ♦Berger, L.C. 224-34-8959 ♦Biggs, W.H. 239-28-3200 Total Months Worked As Laborer From July 1965 To April 1973 Amount Earned During This Period Estimated Back Pay For Time Worked As Laborers 45 $ 1 6,901.66 *233.67 76 33,553.33 463.88 14 6,723.30 92.95 88 41,722.00 576.81 80 34,703.46 479.78 49 1 9,165.71 264.97 16 9,019.41 124.69 15 5,841.59 80.76 63 24,900.66 344.25 14 3,903.15 53.96 76 35,428.70 489.80 14 4,332.43 59.90 12 4,045.68 55.93 j JIncludes time spent as janitor. CAUTION: SOME TAXES MUST BE WITHHELD. CAUTION; SOME TAXES MUST BE WITHHELD. -29- Name Social Security Number *Blue, Lionel 231-44-5882 Blunt, Charles Fulton 228-09-2045 *Boone, A.L. 238-48-7856 Booth, Alpheus Thower 227-26-5555 Bostic, Charles Edward 411-26-4158 *Boston, W.R. 237-62-7531 *Bowers, Lonnie L. 228-62-1778 *Bowman, B.F. 228-64-0886 *Bowser, E. 240-68-0505 *Boykins, P.K. 225-56-0832 *Brock, A. 227-48-4005 Brock, Richard Oliver 228-36-5783 Brown, Curtis 226-34-0460 Brown, Harvey 245-07-4891 Brown, James Samuel 225-12-5152 *Brown, L.K. 248-26-4144 Brown, Oscar 263-60-6107 Brown, Serge 227-12-6115 *Burgess, F.M. 243-40-6280 Burrell, Ernest 229-10-7134 Butler, Tommie Lee 224-40-1786 *Bynum, A.E. 231-72-0461 Cameron, Lonzia 237-22-5662 Carroll, William Henry 241-40-4911 Cherry, Joseph Edward 238-20-8328 Cherry, Roosevelt L. 243-50-0115 *Chisolm, J.F. 249-36-5713 *Claggion, H.S. 228-60-7984 Collins, James 254-54-6917 *Copeland, A. 226-40-7813 Cox, Ernest Linwood 229-44-1068 *Dale, C.M. 246-40-8224 *Davis, J. 227-50-6746 *Davis, R.C. 223-52-5314 *Duke, H. 231-01-1487 Dunston, Raymond 231-09-7613 Eason, Willis Augustus, Jr. 238-48-8865 *Etheridge, B. 246-54-5712 Evans, Leroy 231-10-3189 Farrell, Henry Alexander 225-60-6193 *Fenderson, L. 224-30-5614 *Fisher, J.R. 231-34-0376 *Foy, G. 230-52-6400 *Franklin, C.D. 226-56-8366 Total Months Worked As Laborer From July 1965 To April 1973 Amount Earned During This Period Estimated Back Pay For Time Worked As Laborers 28 # 10,697.73 #147.90 94 48,059.13 664.42 48 1 5,037.33 207.89 94 36,719.11 507.64 44 14,892.87 205.89 3 1,084.89 15.50 65 26,574.78 367.40 36 12,147.25 167.94 46 1 3,155.49 181.87 25 10,429.95 144.19 66 24,514.65 338.92 76 41,810.48 578.03 86 39,700.39 548.86 94 50,719.70 701.20 94 43,558.03 602.19 53 1 7 ,969.43 248.43 1 399.75 6.05 80 44,273.42 612.08 34 21,033.00 290.78 94 47,285.90 653.73 80 35,061.25 484.72 20 6,221.89 86.02 61 28,094.51 388.41 94 43,824.78 605.88 77 33,248.51 459.66 22 8,129.52 112.39 32 1 2,060.44 166.74 23 7 ,451.91 103.02 42 20,719.59 286.45 48 18,884.89 261.08 82 29,096.71 402.26 52 18,249.67 252.30 46 18,779.08 259.62 42 15,949.85 220.51 47 24,576.04 339.76 64 37,075.00 512.56 39 1 7 ,663.10 244.19 2 505.71 7.49 54 26,103.14 360.88 33 1 3,773.53 190.42 11 4,176.40 57.74 34 13,303.88 183.93 14 5,586.30 77.23 21 8,100.12 111.98 CAUTION': SOME TAXES MUST BE WITHHELD. -30- Name Social Security Number Total Months Worked As Laborer From July 1965 To April 1973 Amount Earned During This Period Estimated Back Pay For Time Worked As Laborers Freeman, John Henry 239-07-8723 54 8 28,480.41 #393.74 Freeman, Linwood Willie 231-26-6665 54 30,911.04 427.35 Freeman, William E. 231-07-9312 54 22,710.22 313.97 Futre.l 1 , Moncure Lazurs 231-40-3912 33 12,940.50 178.90 Gabriel, Hezekiah 237-20-4936 78 39,679.20 548.57 *Gallop, L . M . 238-78-9013 31 12,516.73 173.04 'Goldman, W., Jr. 227-32-1359 32 12,851.52 177.67 *Goodman, W . T . 223-44-3796 67 28,980.19 400.65 Gordon, Edward J. 228-52-4854 51 22,166.29 306.45 Gray, Butler G. 248-14-3086 25 10,670.7s 147.52 *Gri f fin, D.E., Jr. 238-72-9649 42 13,211.54 182.65 *Griffin, D.H. 241-48-5211 47 18,201.42 251.64 Griffin, Mi ttet 239-42-6876 78 40,554.88 560.67 Guy, Leonard Louis 225-46-8707 75 44,827.97 619.75 Hampton, E. J. 227-66-5829 36 10,986.68 151.89 Harris, J.E. 246-64-0624 45 17,628.78 243.72 Harris, Joseph Lonsfels 239-44-5648 94 40,900.31 565.45 Harris, Luke, Jr. 224-26-0992 25 12,474.84 172.47 Haskett, William J. 226-56-8362 12 3,579.21 49.48 Hawkins, Lee Wesley 227-50-5494 40 15,223.24 210.46 *Hayes, J .F. 225-68-6448 19 6,370.93 88.08 ♦Heekstall, W.B. 226-34-2009 14 4,827.61 66.74 *Henderson, E. 242-60-1082 32 12,661.35 175.04 *Hil1, W. J. 231-10-0386 14 6,295.00 87.03 Holliday , Jay Connie 231-18-8771 26 9,639.37 133.26 *Hunter, R.R. 227-42-7245 22 17,112.28 236.58 Hunter, Walter Benjamin 228-20-8032 49 20,502.64 283.45 *Huskey, W.A., Jr. 229-22-8692 30 10,618.32 146.80 Jacobs, Junius 249-34-5096 93 55,404.58 765.97 James, Jessie 227-52-2756 80 41,739.89 577.05 Jenkins, James Thomas 223-56-4925 63 28,498.75 394.00 Jenkins, Jessie Joshua Sylvester 223-63-5964 60 33,193.15 458.90 *Jennings , R.W. 230-66-4402 22 4,693.57 64.89 Johnson, John Richard, Jr. 245-20-6280 14 4,853.91 6 7.11 Jones, Alvin 227-50-7213 36 18,287.89 252.83 *Jones, C .P. 231-09-0328 74 22,998.45 317.95 Jones, George Columbus 229-30-4201 46 23,595.10 326.20 *Jones, T 227-14-6134 72 28,858.82 398.97 Jordan, Arteal 227-50-5271 64 26,216.56 362.44 *King, L. 225-58-3069 19 6 ,262.79 86.58 *Lancaster, R. 238-28-0491 28 8,959.49 123.87 Lee, Robert Edward 230-56-2225 92 40,982.64 566.59 Lewis, C 231-01-3825 16 1,829.69 25.30 CAUTION; SOME TAXES MUST BE WITHHELD. Name Lynch, Willie P. MeClaud, James Edward "McClease, John Henry McOleese, Frederick Hazeitt Madison, Alien Harold Madison, L.D. Majette, G. ''■Mann, D.W. Marrow, James E. "Mason, G. Mathis, M.F. Mayfield, A. *Mayo, C .V . "Mitchell, II.L. Moseley, Glenn Kirby Newby, William Franklin Newton, Amos *01(18, P.J. O'Neal, Moses Parker, Eldridge Parker, Louis Peede, Carlton Eugene *Peede, T.D. "Peele, E. Perkins, Allen Wendell *Perry, H. "Pittman, C.L., Jr. "Pittman, M.A. "Pitts, J.H. Porter, J.H. Prayer, Bobby J. "Prayer, E., Jr. Pritchard, William Oliver Proctor, Will Reid, Charlie Edward Reid, George Lee Richardson, Alphonso Riddick, Augustus Riddick, E. "Riddick, W.E. Roberts, Columbus Robertson, J.R. Robinson, Robert Lee Robinson, Samuel Nathaniel Total Months Worked As Laborer -31- Social From Security 1965 Number Apri July To 1 1973 223-56-269'* 37 229-22-5652 28 231-26-1577 87 225-52-7336 95 227-68-5730 55 223-64-5889 29 238-70-2^50 2 228-20-2596 15 228-32-5690 46 228-60-9853 52 221-20-9777 13 225-60-9231 14 223-52-3^89 35 228-36-7020 23 225-60-6950 22 253-16-0355 74 239-56-3618 57 223-72-4582 32 231-44-7482 84 231-35-5165 4 223-34-2791 39 227-56-5585 26 225-58-3356 29 251-16-3919 50 230-56-1627 82 23I-IO-O9IO 67 225-60-8876 37 230-58-7526 9 254-18-5519 25 251-65-5783 16 230-68-5252 61 230-56-2212 12 225-58-4155 74 705-16-5359 14 212-28-5836 25 228-36-6575 64 227-68-6555 60 231-50-0673 79 231-07-0391 15 706-07-5151 67 230-18-8802 69 225-58-3329 55 225-52-8769 13 223-60-2750 18 Amount Earned During This Period Estimated Back Pay For Time Worked As Laborers 9 1 5,635.92 8202.35 9,171.89 126.80 35,556.36 576.36 43,928.64 607.31 1 5,653.25 216.41 11,017.70 152.32 1,079.27 14.92 5,307.47 73.38 18,457.53 255.18 17,148.38 237.08 4,626.85 63.97 6,068.97 83.90 12,858.99 177.78 7 ,659.97 105.90 8,272.89 114.37 37,398.53 517.03 23,454.38 325.26 1 2,688.79 175.42 44,132.30 610.30 1,293.38 17.88 1 5,372.20 212.52 8,625.95 119.24 11,763.70 162.63 18,121.01 250.52 25,974.82 359.10 27,843.95 384.94 13,725.97 189.76 3,571.65 48.00 10,949.52 151.38 7,773.85 107.47 26,823.00 370.83 3,537.29 48.90 35,377.82 475.27 5,111.50 70.67 13,555.77 187.41 29,283.55 404.85 25,337.57 350.29 38,706.85 535.12 3,975.59 55.95 29,315.81 405.29 32,600.18 450.70 26,101.27 360.85 5,269.70 72.85 5,002.56 69.16 CAUTION: SOME TAXES MUST BE WITHHELD. -32- Name Social Security Number Total Months Worked As Laborer From July 1965 To April 1973 Amount Earned During This Period Estimated Back Pay For Time Worked As Laborers *Rogers, <J. 249-16-6927 40 $ 1 4,253.51 $ 197.06 Ro.seoe, Horace Gene 223-58-9206 17 6,123.37 89.66 *Roscoe, R.R., Jr. 2311-56-0780 16 6,038.96 83.99 Ruffin, J. McC. 227-48-4619 55 27,412.58 378.98 Ruffin, R.L. 223-44-3956 55 27,923.80 386.05 *Scott, J.W. 227-38-39^5 36 15,272.37 211.14 Sharp, Ernest 229-42-4891 57 37,320.38 515.95 *Shaw, M. 230-18-7692 33 8,858.66 122.47 Short, Willie C. 229-54-4966 13 4,148.23 57.35 Sills, Jesse James 227-14-5817 48 30,513.40 421.85 *Simon, 0. , Jr. 225-60-8391 12 6,723.93 92.96 Skinner, Melvin Leon 224-50-5918 73 35,307.34 488.12 Smith, Calvin T. 229-42-6937 60 30,790.96 925.69 *Smith, J.E. 227-46-3038 63 39,163.97 472.32 *Speight, C. 238-56-5758 82 23,204.44 320.80 Spellman, James 230-14-1290 48 28,462.74 393.50 Spraggins, Elisha Tune 228-50-3059 23 12,161.75 168.14 Spraggins, James E. 229-52-4843 56 23,167.12 320.29 *Spruill, C.E. 223-44-7141 10 4,180.86 57.80 Stancil, Robert Lee 241-40-5442 19 7,212.86 99.72 Steeley, Clarence Cecil 228-20-2360 28 8,875.76 122.71 Stokley, Renzie Darling 246-54-7459 43 17,273.12 238.80 Sturdivant, Pursell 251-56-2468 70 29,671.27 410.21 *Surratte, F.J. ClClLfN1COC)in-3*Cl 36 10,794.50 199.23 *Swinton, A. 251-03-8304 12 5,807.32 80.29 Sykes, Timothy Dale 228-60-8386 36 13,652.32 188.74 Thorne, Boyce 245-16-3885 93 42,732.45 590.78 Thornton, C.E. 238-78-9001 10 7,148.87 98.83 *Tillar, J.E. 227-26-5264 52 1 6,229.76 224.38 *Toeny, J. 422-46-8068 29 10,467.59 144.71 *Towe, R.E., Jr. 225-56-0802 12 3,726.07 51.51 Trotman, John 231-07-0819 94 37,679.98 520.93 Turner, Henry 229-09-8353 86 A6,819.38 647.28 Walker, Ernest E. 225-36-0430 89 96,091.91 636.53 Walton, Dempsey, Jr. 228-36-1504 94 38,969.90 538.76 *Walton, M. 230-22-1309 33 9,424.18 130.29 Wa rd, D . 225—2b—7666 11 3,251.49 44.95 *Webb, L.W. 237-30-2368 23 7,963.09 103.18 ‘White, F. 244-52-0577 16 6,198.82 85.70 *White, W. 242-22-0443 36 20,927.39 289.32 ''Whitehead, T.M. 230-46-4234 12 6 ,372.57 88.10 Whitten, Calvin Vinson 227-46-7414 86 39,023.65 539.50 Wiggins, Cecil 227-14-7931 3 1,393.52 21 .34 CAUTION; SOME TAXES MUST BE WITHHELD. -33- Social Total Months Worked As Laborer From July Amount Earned Estimated Back Pay For Time Security 1965 To During Worked As Name Number April 1973 This Period Laborers Williams, Charlie Alphonso 118-30-332/1 89 37,505.27 518.51 Williams, George M. 242-50-4407 94 40,392.79 558.43 *Wil liams, J.C. 238-46-1863 46 20,590.56 284.66 Williams, James Elliott 225-60-6559 49 25,904.91 358.14 *Williams, P. 238-40-5517 42 20,046.28 277.14 Williams, Percy 238-36-5516 94 37,016.11 511.75 Williams, Raleigh, Jr. 243-28-3395 37 14,721.97 203.53 Williams, Wesley Theodious 224-44-7448 16 5,694.84 78.73 Wilson, Ralph 719-14-4828 13 4,655.95 64.37 *Wilson, R.E. 230-56-0067 42 13,465.78 186.16 Wilson, Samuel 230-07-1060 32 11,836.57 163.64 Wilson, William Augustus 227-50-5705 71 42,720.48 590.61 Winfield, J.M. 225-58-3940 41 16,428.92 227.13 *Wood, J.A. 228-32-3419 52 18,172.60 251.24 Wood, Lawrence 229-54-1051 . 66 3 7,727.26 521.58 Totals; 9173 43,992,985.5'! $55,204.64 -34- 4. LIST OF PRESENT AND FORMER PAINT AND TRACK LABORERS ELIGIBLE TO SHARE IN THE BACK PAY SETTLEMENT FOR TIME WORKED AS LABORERS See Appendix B for an explanation of the means used to determine which present and former laborers outside of the labor department are eligible to share in the back pay settlement for the time they worked as laborers, and the means used to calculate their share. CAUTION: The "estimated amounts of back pay" are only estimations. It may be a little larger or a little smaller. Persons marked with an asterisk (*) before their name must send a postcard to the attorneys for plaintiffs by the deadline or they will lost their rights to receive money, and everyone else's share will be increased accordingly. If you see any mistakes in this table, notify the attorneys for plaintiffs as soon as possible since nothing can be done about the mistake after the final calculations have been made. Check for your name on other lists as well. Social Security Number Total Months Worked As Laborers From July 1965 To April 1973 Amount Earned During This Period Estimated Back Pay For Time Worked As Laborers Outside of the Labor Dept. ♦Cohen, Willie A. 248-92-5233 14 $ 5,609.69 $. 54.29 Deloatch, Franklin Roosevelt 227-44-5575 27 10,746.14 104.00 ♦Fisher, J.E. 230-40-2754 14 9,962.19 96.22 *Hill, W.J. 231-10-0386 48 19,738.91 191.03 Johnson, John Richard, Jr. 245-20-6280 20 10,376.52 100.42 O'Neal, M. 231-44-7482 5 2,055.86 19.94 ♦Morning, L.J. 238-09-6138 55 17,826.00 172.53 *Person, E.L. 231-16-0119 17 9,211.77 89.15 Proctor, Will 704-16-4359 48 19,413.18 187.88 Sawyer, Claude 237-74-1616 34 13,824.01 133.79 Simms, W.R. 225-56-2613 21 12,322.81 119.20 ♦Spruill, Cleveland 227-38-3605 27 8,895.61 86.09 Totals: 336 months #139,963.29 #1 ,559.60 CAUTION: SOME TAXES MUST BE WITHHELD. -35- CAUTION: SOME TAXES MUST BE WITHHELD. 5. LIST OF PRESENT AND FORMER LABOR HELPERS ELIGIBLE TO SHARE IN THE BACK PAY SETTLEMENT FOR TIME WORKED AS LABOR HELPERS See Appendix B for an explanation of the means used to determine which present and former labor helpers are eligible to share in the back pay settlement for the time they worked as labor helpers, and the means used to calculate their share. CAUTION: The "estimated amounts of back pay" are only estimations. It may be a little larger or a little smaller. Persons marked with an asterisk (*) before their name must send a postcard to the attorneys for plaintiffs by the dead line or they will lose their rights to receive money, and everyone elsefs share will be increased accordingly. If you see any mistakes in this table, notify the attorneys for plaintiffs a£ soon as possible since nothing can be done about the mistake after the final calculations have been made. Check for your name on other lists as well. Name Alston, Stanley, Jr. Askew, Bernard Baker, McConnell Beamon, Jerry Brock, Richard Oliver Brown, Curtis Butler, Tommie Lee Dunston, Raymond Eason, Willis Augustus, Jr. Freeman, John Henry Guy, Leonard Louis James, Jessie *Lee, William Me. McCloud, James E. Roberts, Columbus *Roscoe, R.R., Jr. Social Security Number Total Months Worked As Labor Helpers From July 1965 To April 1973 240-60-2816 18 227-48-4697 8 243-50-7408 15 239-48-8290 18 228-36-5783 18 226-34-0460 8 224-40-1786 7 231-09-7613 18 238-48-8865 20 239-07-8723 40 225-46-8707 7 227-52-2756 14 226-36-3663 24 229-22-5652 42 230-18-8802 25 230-56-0780 4 Amount Earned During This Period Estimated Back Pay For Time Worked As Labor Helpers $ 8,061.73 $ 44.59 3,779.10 20.90 9,679.18 53.54 12,035.54 66,57 12,012.53 66.44 4,416.22 24.43 3,457.46 1 9 .12 9 ,693.50 53.61 22,463.24 124.20 27,326.48 151.14 6,056.08 33.50 8,518.36 4.7.12 8,807.01 48.71 1 6,700.92 92.34 1 4,491.95 80.16 618.97 3.42 -36- CAUTION: SOME TAXES MUST BE WITHHELD. Name *Simon, A. Smith, Calvin T. Smith, William Penn Turner, Henry Whitten, Calvin Vinson Williams, James Elliott Wilson, William Augustus Wood, Lawrence Social Security Number Total Months Worked As Labor Helpers From July 1965 To April 1973 227-58-1693 14 229-42-6837 18 245-05-6325 9 8 227-48-7414 8 225-60-6559 8 227-50-5705 8 229-5^-1051 8 Totals: 367 Amount Earned During This Period Estimated Back Pay For Time Worked As Labor Helpers $ 5,802.18 $ 32.09 10,802.64 59.75 6,244.61 34.54 4,969.75 27.49 4,417.78 24.43 4,644.66 25.69 10,377.88 57.40 3,539.30 19.58 1218,917.07 $1,210.76 -37- 6. LIST of p re se n t a n d f o r m e r doc k h e l p e r s e l i g i b l e TO s ha re in t h e bac k pay s e t t l e m e n t for t i m e w o r k e d a s d o c k h e l p e r s See Appendix B for an explanation of the means used to determine which present and former dock helpers are eligible to share in the hack pay settlement for the time they worked as dock helpers, and the means used to calculate their share. CAUTION: The "estimated amounts of hack pay" are only- estimations. Tt may he a little larger or a little smaller. Persons marked with an asterisk (*) before their name must send a postcard to the attorneys for plaintiffs by the deadline or they will lose their rights to receive money, and everyone eise's share will be increased accordingly. If you see any mistakes in this table, notify the attorneys for plaintiffs a_s soon as possible since nothing can be done about the mistake after the final calculations have been made. Check for your name on other lists as well. Name *Alford, E.B. Armstrong, Embria Hamilton *Barber, H.L. *Barber, J. *Barber, T. Barnard, Pearlie Lee Blow, Wesley Eugene Boone, Wrillie Booth, Joseph *Boston, W.R. *Branch, U. Branch, Willie Brinkley, Curtis Mayo Brite, Lenial Mertis Total Months Worked As Social Securi ty Number Dock Helpc rs From July 1965 To Dec. 1970 228-38-2592 31 239-20-8034 47 227-56-4567 25 224-50-0389 13 228-36-0869 43 229-54-1383 13 225-42-1067 41 223-52-2633 29 227-56-2674 26 237-62-7531 9 224-66-2192 29 223-60-3517 36 244-62-5493 31 243-42-2455 31 Amount Earned During This Period Est i ma ted Back Pay For Time Worked As Dock Helpers 8 13,212.57 73.07 20,180.20 111.60 10,733.36 59.36 2,435.09 13.47 17,712.49 97.95 6,282.04 34.74 18,342.40 101.43 12,515.95 69.21 10,167.75 56.23 2,382.97 13.18 10,898.98 60.27 15,903.30 87.95 16,284.35 90.05 19,788.57 109.43 CAPTION: SOME TAXES MUST BE WITHHELD. CAUTION: SOME TAXES MUST BE WITHHELD. -38- Name Social Security Number Total Months Worked As Dock Helpers From July 1965 To Dec. 1970 Amount Earned During This Period Estimated Back Pay For Time Worked As Dock Helpers Brown, Charles Roland 719-07-1182 18 0 5 ,253.45 9 29.05 *Brown, James 228-64-0771 22 4,644.55 25.68 Brown, Lorenzo Preston, Sr. 409-14-7794 41 18,287.88 101.13 Brown, Oscar 263-60-6107 19 12,231.29 6 7.64 *Cleveland, W.G. 260-68-9497 23 9,233.87 51.06 *Copeland, A.J., Jr. 224-54-2019 19 4,827.18 26.69 Copeland, Coley, Jr. 228-52-2562 36 1 3,622.78 75.33 *Copeland, P.S. 223-60-4971 21 9,349.82 51.71 Daniels, Edward B. 225-28-7925 16 9,420.79 52.10 Dawkins, Elford, Jr. 223-44-7260 15 4,532.11 25.06 Eason, Wayne Randolph 240-62-6670 21 10,828.61 59.88 Elliott, J.D. 227-50-5760 36 17,585.68 97.25 *Etheridge, B. 246-54-5712 20 7,118.91 39.37 *Evans, M.V. 244-48-3131 58 21,449.80 119.62 *Evans, W. 223-44-5488 12 4,810.00 26.60 *Evans, W.F. 238-46-6297 26 14,075.13 77.84 Faulk, David Thomas 224-50-1734 48 24,644.65 136.29 *Faulk, J.R. 225-46-9041 20 9,067.89 50.15 Ford, Robert, Jr. 228-34-6058 21 12,907.05 71.38 Garrett, Clarence Monroe 231-50-0086 19 8,250.15 45.62 Gee, Leo 241-28-3543 29 14,414.19 79.71 Gibbs, Samuel E. 245-20-0331 31 15,230.84 84,23 *Griffin, B., Jr. 237-60-8315 15 7,914.60 43.77 Griffin, Ervin Roland 240-56-5076 21 12,470.78 68.96 Griffin, McRay 241-40-2516 37 23,322.79 128.98 Griffin, William R. 243-38-8870 37 22,840.12 126.31 *Hargrove, R.H. 223-60-4916 28 10,573.03 58.47 *Henderson, E. 242-60-1082 22 9 ,827,62 54.35 *Hike, S.J. 226-22-3110 31 15,095.74 83.48 *Hinton, George H. 242-50-4316 20 9,813.52 54.27 *Hogans, M.I. 243-40-2633 12 3,899.50 21.56 Hopson, Robert Earl 224-50-5496 13 7 ,029.65 38.87 Hopson, William Ruffin 225-46-8949 14 7,490.03 41.42 ^Howard, J.M. 224-50-3883 44 17,874.97 98.85 *Jackson, J.E. 231-44-5956 35 1 4,645.07 80.99 *Jenkins, H. 230-22-4619 13 3,848.52 21.28 Johnson, William Amos 225-20-4626 59 3 7,174.36 205.57 Johnson, Willie Lee 226-40-9822 29 1 6,567.38 91.62 *Jones, V.A. 230-58-9554 34 1 2,257.88 67.79 Kirby, Ditarine 226-22-5878 29 1 1 ,999.60 66.36 Lancaster, James E. 239-28-2976 40 24,177.08 133.70 CAUTION: SO.ME TAXES MUST DE WITHHELD -39- Name Social Security Number Total Months Worked As Dock Helpers From July 1965 To Dec. 1970 Amount Earned During This Period Estimated Back Pay For Time Worked As Dock Helpers *Laurey, W.J. 228-52-3907 19 $ 7 ,523.99 * 41.61 Long, Charlie Lee 229-22-7779 31 16,276.14 90.01 Long, William Andrew 241-34-7092 53 24,386.18 134.86 *Lovick, J.F. 220-09-0302 41 14,398.17 79.62 McCoy, Linwood Franklin 239-40-4758 31 1 6,395.70 90.67 McCoy, Woney 24 3-42-036'! 31 22,466.16 124.24 McKinnon, Cezar, Jr. 241-24-9454 29 15,164.37 83.86 Majette G. 238-70-2450 29 1 2,046.69 66.62 *Marshall, D.D. 230-58-5163 25 9,754.95 53.95 *Martin, G.W. 229-22-9657 16 7,172.56 39.66 *Martin, W.K. 231-01-1198 38 15,445.48 85.41 Mitchell, Melvin Lee 226-34-4603 31 15,540.49 85.94 *Mitehell, O.E. 223-52-6271 15 6,686.67 36.98 *Mitchell, S. 23S-46-9616 27 17,580.53 97.22 *Moseley, J., Jr. 238-64-3269 16 6,406.75 35.43 *0’Neal, F. 242-14-6208 19 4,981.65 27.55 *Peterson, Q. 230-46-4654 20 8,069.98 44.63 Phillips, Willie Edwards 243-64-7272 41 23,615.84 130.60 *Pittman, M.A. 230-58-7426 5 1,488.73 8.66 *Pope, William L. 223-38-6935 31 14,117.92 78.07 *Porter, W.B. 223-34-4984 14 4,237.30 23.43 Powell, Garfield 238-56-7318 25 1 3,049.63 72.16 *Rattler, Melvin Lee 227-72-5901 38 16,376.64 90.56 Riddick, Obie 223-20-7644 42 20,026.11 110.74 *Roach, B. 246-44-1489 65 41,411.80 229.01 Savage, Gerald Lee 225-62,4663 20 8,123.72 44.92 *Simmons, J.R. 245-54-0831 63 25,951.47 143.5 1 *Skeeter, Frederick 230-07-3222 16 4,040.78 22.35 Slight, Charles E. 224-40-2656 23 12,230.20 67.63 Smith, Eugene Fields 228-34-9711 4 6 23,253.94 128.59 Smith, Velma 250-30-4979 27 00vOt-'Nt-~ 95.76 *Spruill, C.E. 223-44-7141 7 3,156.41 17.46 Stevens, William Henry 224-30-8368 15 8,161.81 45.14 *Stevenson, C. 227-48-4945 31 1 5,800.56 87.38 Stevenson, Wylie, Jr. 231-34-1330 26 1 3,115.24 72,53 *Stiff, J.C. 228-62-2400 20 8,206.64 45.38 Stokley, Melvin McClese 067-32-7050 19 6,485.20 35.86 Stokley, Roy Lee 241-34-6768 56 24,506.82 135.52 Stokley, Willie Lee 237-60-7705 30 12,641.04 69.91 Sykes, Cad 231-34-1607 27 1 7 ,159.95 94.90 CAUTION: SOME TAXES MUST BE WITHHELD. - 40- Name Social Security Number Total Months Worked As Dock Helpers From July 1965 To Dec. 1970 Amount Earned During This Period Estimated Back Pay For Time Worked As Dock Helpers ♦Sykes, J.L. 228-36-5046 24 * 7 ,437.97 $ 41.13 ♦Teamer, A.K. 231-01-2193 45 17,318.98 95.77 Telfair, R.L. 243-20-1097 20 6,942.04 38.39 Tilghman, Wesley 243-44-0551 31 14,563.35 80.54 *Towe, R.E., Jr. 225-56-0802 1 840.25 5.15 Walton, Sherman Lee 223-48-4470 31 18,029.26 99.70 Ward, David 225-28-7668 8 1 ,919.62 11.05 ♦Washington, M.G. 247-34-0961 63 26,398.39 145.98 White, Earl Junior 240-56-5017 31 20,115.63 111.24 ♦White, G.L. 228-18-7623 21 7,642.79 42.27 White, James Alexander 241-48-5364 31 1 7 ,561.37 97.11 ♦White, J.D. 225-09-5313 37 19,548.29 108.10 ♦White, J.L. 224-38-8801 27 10,439.20 57.73 ♦White, R.L. 228-32-3613 27 10,412.69 57.58 White, Samuel, Jr. 231-50-0324 29 1 3,220.31 73.11 Whitehurst, Melvin R. 229-22-4780 51 25,019.09 138.36 ♦Whitfield, J.F. 228-20-3279 22 11,427.17 63.19 ♦Wiggins, E.M. 225-09-7238 17 5,023.81 27.78 ♦Williams, B. 239-48-9146 23 7 ,273.61 40.22 Williams, Ernest 243-20-2330 65 37,514.79 207.46 Williams, James Aaron 243-42-0774 31 1 6,964.51 93.81 ♦Williams, M. 243-52-8009 27 9,824.16 54.33 Williams, Roland 241-48-5202 31 16,584.10 91.71 Williams, William Harris 225-28-3159 70 33,787.86 186.85 ♦Wilson, J. 225-07-2934 38 17,573.70 97.18 ♦Wolfe, J., Jr. 227-50-5036 19 5,888.88 32.57 ♦Wright, J., Jr. 229-42-7432 45 26,003.11 143.80 3531 $1 ,657,701.43 #9 ,167.3 7 41- CAUTION; SOME TAXES MUST BE WITHHELD, 7 LIST OF PRESENT AND FORMER TRUCK DRIVERS ELIGIBLE TO SHARE IN THE BACK PAY SETTLEMENT FOR TIME WORKED AS TRUCK DRIVERS See Appendix B for an explanation of the means used to determine which present and former truck drivers are eligible to share in the back pay settlement for the time they worked as truck drivers, and the means used to calculate their share. CAUTION: The "estimated amounts of back pay" are only estimations. It may be a little larger or a little smaller. Persons marked with an asterisk (*) before their name must send a postcard to the attorneys for plaintiffs by the dead line or they will lose their rights to receive money, and everyone else's share will be increased accordingly. If you see any mistakes in this table, notify the attorneys for plaintiffs as_ soon as possible since nothing can be done about the mistake after the final calculations have been made. Check for your name on other lists as well. Total Months Worked As Truck Estimated Name Social Security Number Drivers From July 1965 To April 1973 Amount Earned During This Period Back Pay For Time Worked As Truck Drivers *Baker, Cecil 230 07 1363 22 $ 6961.59 $ 67.37 Brown, Milton L. 228 20 3930 94 49329.ll 377.91 Bryant, J. C. Jr. 225 22 6573 16 6451.09 62.93 *Cherry, L. L. 228 62 0948 14 3910.76 37.85 ^Christmas, R. E. 227 68 3780 13 3498.00 33.85 *Copeland, R. H. 231 34 1840 79 24010.27 232.37 Cox, Eddie 426 32 4729 33 16321.61 157.96 Davis, John L. 223 52 4155 94 51886.78 502.04 *Elford, Charlie O'Neal 259 07 7733 79 37752.48 365.37 *Futrell, Moncure Lazurs 231 40 3912 61 28430.28 275.15 Gaddy, Haywood A. 225 60 5955 20 10575.45 102.35 Gordon, Lee Roy 231 10 7602 94 51157.37 495.10 *Hamlin, B. C. 231 10 8220 71 90562.79 392.57 Holley, Ashley 231 39 3924 57 29656.58 287.02 *Hunter, A. J. 225 42 2664 32 15832.28 153.23 *Moore, Eugene 231 40 2519 74 41248.56 399.20 Norfleet, Estes 230 74 3241 29 12724.61 123.15 Parker, David Arthur 231 50 0843 74 33777.69 326.90 Parker, Eldridge 231 34 4165 41 18120.34 175.37 *Simon, Osburn Jr. 225 60 8391 7 2920.41 28.26 Stancil, Clyde Lee 227 52 4670 19 10260.65 99.30 Stancil, Robert Lee 241 40 5442 73 40890.75 395.79 Taylor, L. A. 227 58 9043 36 17678.86 171.10 *Vann, L. S. 224 38 9263 20 7739.58 74.90 *Warren, J. H. Jr. 240 5'* 1110 33 13118.06 126.96 Wiggins, Cecil 227 14 7931 82 40885.91 395.69 ^Williams, J. 0. 249 52 5575 12 3085.98 29.87 Totals: 1,279 $61878 7 .7 3 $59S8 .51 -42- 8. LIST OF PRESENT AND FORMER JANITORS/JANITRESSES ELIGIBLE TO SHARE IN THE BACK PAY SETTLEMENT FOR TIME WORKED AS JANITORS/JANITRESSES See Appendix B for an explanation of the means used to determine which present and former janitors/janitresses are eligible to share in the back pay settlement for the time they worked as janitors/janitresses, and the means used to calculate their share. CAUTION: The "estimated amounts of back pay" are only estimations. It may be a little larger or a little smaller. Persons marked with an asterisk (*) before their name must send a postcard to the attorneys for plaintiffs by the deadline or they will lose their rights to receive money, and everyone else's share will be increased accordingly. If you see any mistakes in this table, notify the attorneys for plaintiffs aŝ soon as possible since nothing can be done about the mistake after the final calculations have been made. Check for your name on other lists as well. Total Months Name Social Security Number Worked As Janitors/ Janitresses From July 1965 To April 1973 Amount Earned During This Period Estimated Back Pay For Time Worked As Janitors/ Janitresses Armstrong, Annie E„ 238-78-7861 33 $ 14,224.85 § 196.66 Baker, McConnell 243-50-7408 8 '4,848.90 67.04 *Barnes, F. P. 230-22-0773 13 1,847.56 25.68 Dawkins, Alice Leach 248-22-7641 39 13,588.27 187.86 Epps, Doris Wyatt 227-26-3782 69 25,917.31 358.31 *Fenderson, L. 224-30-5614 13 7 ,676.55 106.13 McClaud, James Edward 229-22-5652 24 10,050.90 138.95 Peoples, Ethel 225-^6-9233 26 6,514.29 90.06 *Pittman, M. I. 231-26-5132 26 9 ,954.62 137.62 Smith, William Penn 2^5-05-6325 76 39,619.52 547.74 *Walden, J. J, 224-38-6886 29 13,111.30 181.26 Williams, Mamie Wyatt 228-20-3081 43 1 5,948.26 220.49 Wilson, Joyce Little 225-56-4997 54 18,769.51 259.49 Wilson, Samuel 230-07-1060 62 28,086.22 388.29 Totals: 515 §210,158.06 *2,905.58 CAUTION: SOME TAXES MUST BE WITHHELD. -43- APPENDIX B DISTRIBUTION OF THE MONETARY SETTLEMENT 1• Of the total monetary settlement of $180,000, the amount of $'«0,277.15 is allowed for attorneys’ fees for counsel for plain tiffs, and the amount of $18,891.39 is tentatively allowed as their costs. This is based upon the affidavit of counsel for plaintiffs. Some expenses are tentative, and provisions for adjustment are set forth at the end of this Appendix. 2. The amount available for distribution to the class is tenta tively set at $120,831.46. Of this amount, $15,000 shall be distri buted to the named plaintiffs in equal amounts, and they shall not share under any other provisions for distributing the monetary settlement. Apart from the named plaintiffs, all other class mem bers may share under all provisions for distributing the monetary settlement for which they are eligible. 3. The sum of $20,000 shall be used to redress the claims of class members who filed proof-of-claim forms, apportioned in the manner set forth in Appendix A, List 1. This list does not include types of discrimination covered by the other lists in Appendix A. 4. Lists 2 through 8 in Appendix A show the initial estimated amounts of back pay for various persons. These amounts are not yet definite because some former employees who did not file proof-of- claim forms will lose their right to receive their shares on lists 2 through 8 unless they write to counsel for plaintiffs, and the card, letter or notice is received by the deadline. The writing requirement is explained in paragraph 10 below. Since some persons will have died or moved away, and nobody will send in the written notice for them, and since some persons will not respond for other reasons, a number of persons will lose their rights to receive the shares on lists 2 through 8. The amounts forfeited will be added together and distributed to the remaining persons on these lists, in proportion to the total share of each person on the combined lists 2 through 8. - A A - Initial Apportionments and Estimated Amounts of Back Pay 5. The initial sum of $5,000 shall be used to estimate the compensation of class members who lost six or more months' seniority upon transferring departments from 1965 to 1971 in the manner set forth in Appendix A, List 2, in proportion to the number of months' seniority lost. If class members transferred departments more than once, all transfers in which six or more months' seniority was lost are included for the purpose of calculating months lost. 6. The initial sum of $75,831.^6 shall initially be ap portioned in the following manner among these six sub-classes. "Eligibility"is defined in paragraph 9 . 1) For eligible class members for time spent working as Laborers, the initial sum of $55,204.6A, to be divided among them in proportion to their earnings as Laborers from July 1965 to April 1973. Each member's earnings should be multiplied by a factor of .013825 to arrive at his estimated share of back pay for membership in this sub class. Plaintiffs' best approximation of earnings is shown in Appendix A, List 3, which also shows the estimated shares of each eligible Laborer. 2) For eligible class members for time spent working as Paint Laborers or Track Laborers, the initial sum of $1 ,35*4.60 to be divided among them in proportion to their earnings in such jobs from July 1965 to April 1973. Each member's earnings should be mul tiplied by a factor of .009678 to arrive at his estimated share of back pay for member ship in this sub-class. Plaintiffs' best approximation of earnings is shown in Appendix A, List >\, which also shows t.ho estimated shares of each eligible Paint Laborer and Track Laborer. 3) For eligible class members for time spent as Labor Helpers, the initial sum of $1,210.76, to be divided among them in proportion to their earnings in such jobs from July 1965 to April 1973. Each mem ber’s earnings should be multiplied by a factor of .005530 to arrive at his esti mated share of back pay for membership in this sub-class. Plaintiffs’ best approxi mation of earnings is shown in Appendix A, List 5, which also shows the estimated share of each eligible Labor Helper. 4) For eligible class members for time spent working as Dock Helpers, the initial sum of $9,167.37, to be divided among them in proportion to their earnings in such jobs from July 1965 to December 1970. Each mem ber's earnings should be multiplied by a factor of .005530 to arrive at his estimated share of back pay for membership in this sub class. Plaintiffs' best approximation of earnings is shown in Appendix A, List 6, which also shows the estimated share of each eligible Dock Helper. 5) For eligible class members for time spent working as Truck Drivers, the initial sum of $5,988.51, to be divided among them in proportion to their earnings in such jobs from -46- July 1965 to April 1973. Each member’s earnings should be multiplied by a factor of .009678 to arrive at his estimated share of back pay for membership in this sub-class. Plaintiffs’ best approximation of earnings is shown in Appendix A, List 7, which also shows the estimated share of each eligible Truck Driver. 6) For eligible class members for time spent working as Janitors or Janitresses, the initial sum of #2,905.58, to be divided among them in proportion to their earnings in such jobs from July 1965 to April 1973. Each member’s earnings should be multiplied by a factor of.013825 to arrive at his or her estimated share of back pay for member ship in this sub-class. Plaintiffs’ best approximation of earnings is shown in Appen dix A, List 8, which also shows the estimated share of each eligible Janitor or Janitress. 7. The following is a brief summary of the basis on which the formulas are derived: 1) Customarily, totally unskilled persons are assigned upon hiring to one of the covered job categories or to jobs as helpers in the trade departments. 2) Prior to January 1, 1969, there were strong racial patterns in initial assignments whereby whites were assigned to jobs as helpers in the trade departments and unskilled blacks were assigned to one of the covered job categories. 3) After January 1, 1969, these raeial patterns of initial assignment ended with respect to jobs as helpers in the trade departments and jobs as Laborer and Dock Helper. Even after January 1, 1969, however, most persons initially assigned to the jobs of Paint Laborer, Track Laborer, Truck Driver, Jani tor and Janitress have been black. *0 Persons who were initially assigned as hel pers in the trade shops have a much greater chance of promotion to skilled job cate gories than persons initially assigned to the jobs of Laborer, Truck Driver, Janitor and Janitress. Until December, 1970, Dock Helpers had relatively little chance for promotion to skilled job categories; after January 1, 1971, however, their opportunities for promotion to skilled job categories became as great as those of helpers in the trade departments. Labor Helpers have relatively little chance for promotion to skilled job categories. Paint Laborers and Track Laborers have a greater chance for promotion to skilled job categories than laborers. 5) Pay rates for these various unskilled entry- level job categories are different. Paint Laborers and Track Laborers have always earned the same rate of pay as Laborers; Dock Helpers, Labor Helpers and Kfelpers in the trade depart ments have always earned the same rate of pay; Laborers have customarily earned 190 to -48- 250 an hour less than Helpers of the same class; Labor Helpers are made so by promo tion and are thus unlike other entry-level Helpers; Truck Drivers have customarily earned 90 to 100 an hour less than Helpers of the same class; Janitors and Janitresses customarily earn 190 to 200 an hour less than Helpers first class. 8. The factors applied to earnings in the various covered job categories are different, in order to take account of the differing economic values of these jobs to the persons in them. The factors bear the approximate proportion of 10 to 7 to 4: Laborers, Janitors and Janitresses at 10; Truck Drivers, Paint Laborers and Track Laborers at 7; Dock Helpers and Labor Helpers at 40 The factors set forth at pp. hh to 46 above take proper account of these differing economic values. Eligibility Requirements for Lists 3 Through 8 of Appendix A 9. The standards for determining the eligibility of class members to share under the six earnings-based formulas set forth above and in lists 3 through 8 of Appendix A are as follows: 1) To be eligible to share in any of lists 3 through 8 of Appendix A, a class member must have worked a total of at least twelve months after July 1965 in any combination of the job categories of Laborer, Paint Laborer, Track Laborer, Labor Helper, Dock Helper, Truck Driver, Janitor or Janitress. For Dock Helpers, the twelve months must have been between July 1965 and December 1970. 2) To be eligible to share under any of lists 3 through 8 of Appendix A, a class member who did not file a proof-of—claim form must have -49- worked for N.S.D.D. on or after June 25, 1967, If a class member who did file a proof-of- claim form left N.S.D.D. before this date, he or she will still share on lists 3 through 8. 3) With respect to the jobs of Laborer, Labor Helper and Dock Helper, a class member must have been hired before January 1, 1969 — in 1968 or before. For class members hired before January 1, 1969 whose employment was terminated before satisfying the twelve- month requirement and who were subsequently rehired in the same job category or any other job category covered in lists 3 through 8 of Appendix A, subsequent months will be included to help meet the twelve-month require ment only if both of the following conditions are met : that the date of rehire is before January 1, 1970 and that the period from the date of separation to the date of rehire is no longer than a year. For class members hired before January 1, 1969 who were promoted to job categories not covered in lists 3 through 8 of Appendix A, and subsequently demoted or transferred to one of the covered job categories, all months spent in the covered job categories will be included for the purpose of satisfying the twelve-month requirement. 4) Date of hire is irrelevant for class members working in the jobs of Paint Laborer, Track Laborer, Truck Driver, Janitor or Janitress, as long as the twelve-month requirement is met. 50- The Requirement That Some Former Employees Send a Written Notice to Counsel for Plaintiffs in Order To Preserve Their Right to Share 10. Each class member who did not file a proof-of-claim form and who was not still employed by N.S.D.D. as of April, 1973 — as shown by the data processing tape furnished by N.S.D.D. to counsel for plaintiffs — will lose his or her right to share in the monetary settlement unless counsel for plaintiffs receives a postcard or other writing indicating a desire to share, no later than thirty days after the publication of notice herein or no later than the final calculation of the shares of class members, whichever occurs later. The notice must be sent to: RICHARD T. SEYMOUR Attorney at Law 1763 R Street, N. W. Washington, D. C. 20009 1 1 . When plaintiffs mail copies of the proposed Consent Decree to class members, they shall include a properly addressed, stamped return postcard in the copies going to class members required to give written indication of their desire to share. No present employee, and no present or former employee who filed a proof-of-claim form, is required to take any further action. Provisions Regarding Deceased Class Members 12. The shares of deceased class members may be paid to the persons, if any, who were designated by the class member on N.S.D.D. records to receive any wages owing at the time of death. If there is no such designation in any instance, the class member's share may be paid to his or her estate, and it may be mailed to any member of the class member's immediate family. Counsel for plaintiffs will not be required to search probate records to deter mine the identity of any executors or administrators but shall, where the share is paid to an estate rather than to the beneficiary of wages owing at the time of death, notify the members of the -51- class member’s immediate family to whom the check is sent that the check should be given to the executor or administrator. Any member of the immediate family, executor, administrator, or beneficiary of wages owing at the time of death may send in any required indication of desire to share. Escrow Fund 13. The sum of $5,000 shall be set aside as an escrow fund to cover the claims of persons affected by any mistake in the apportionments set forth in Appendix A, by excusable failure to send to counsel for plaintiffs a timely required notification of their desire to receive their share, by other meritorious claims for relief, and to cover out-of-pocket costs not known at the time of final calculations and initial distribution to class members, or incurred thereafter. Counsel for plaintiffs shall act as trustee for the class in making determinations to dis burse funds from this amount, but any distribution of $A00 or more to a class member, and any amount whatsoever for costs, must be approved in advance by the Court. Any class member disagreeing with the determination of counsel for plaintiffs with respect to his or her claim will have the right to appeal to the Court within fifteen days for a different determination. 1A. if any estimate of costs turns out to have been too high, but this is not learned before the final calculation and initial distribution of class members' shares, the excess shall be added to the $5,000 set aside. If any funds set aside remain undistributed on the first anniversary of the approval of this Consent Decree, and no determination on any claim for class mem bers is pending, the Court shall be notified of the amount involved and it shall be distributed equally among the named plaintiffs. If the amount remaining is $3,000 or more, the advance approval of the Court is required; if less, advance approval is not required. -52- Adjustments for Costs 15. Because some of the costs tentatively allowed in the amount of $18,891.39 reflect estimations, it is likely that adjustments to the amount allowed for costs must he made. The following procedures shall apply to such adjustments: If the amount allowed for costs is increased or decreased hy the Court prior to the final calculation of the shares of class members, the share of each individual class member (but not the shares of the named plaintiffs) will be adjusted in proportion to its size. If the amount allowed for costs is increased or decreased thereafter, adjustments shall be made only with respect to the above-described $5,000 escrow fund. - 53- a p p e n d i x c List of Former Employees to Receive Letter Contained in Appendix D Beasley, Samuel William, Branch, Paul Leon Gibbs, Lorenzo Grier, Cassonova Pernell Gordon, Waverly Spellman, James, Jr. West, Christopher E. Bell, Edward McKinley Miller, Walter Glenn Hagans, James I. White, Lois Laster Boone, Alonza, Jr. Artis, Robert Lee Carey, Floyd Edward Newby, Eddie Leon Wilborn, B. N., Jr. Winstead, R. L. Norman, M. V. Hightower, L. A. Roberts, J. 0. Paige, W. A. Williams, J. Johnson, F. E. Long, J. L., Jr. Jr. Twine, M. Hargraves, M. Wr. Hart, M. Perdue, R. W. Woodley, Edwin Weaver, C. Herring, Sylvester Townes, D. M. Dowtin, F. M. Gray, J. A. Gray, M. S. Ridley, E„ Ridley, M, E. Swinton, A. Stokley, H. L. Morris, W. H. Williams, Morris Harris, C. Lindsey, H. L. Locker, R. A. Barrow, D. Branch, Lorenzo E. Dildy, Larry K. Bynum, Jesse J. APPENDIX D Text of Letter to Send Former Employees ________ Specified in Appendix C________ Dear Former Employee: Norfolk Shipbuilding & Drydock Corporation has recently been reviewing records of some of its former employees in order to determine if there were some who had skills that could be used more advantageously for future expansions in the work of the Company. If you would be interested in future employment with the Company, you are requested to complete the attached form and forward it to the Company within 30 days. At our mutual convenience, we will arrange an interview that would assist in determining whether you had a skill level that would enable you to be placed as a handyman at the Company. If you have expressed an interest and have been found qualified, you will be notified on a priority basis when openings occur. Badge 7482 7311 7560 7525 7501 7630 7681 7391 7423 7470 7487 7367 7535 7435 7439 7521 7672 7667 7340 7584 7464 7618 7327 7598 7499 7414 7355 7607 7475 7572 7457 7494 7361 7534 7599 7461 7448 7432 -54- APPENDIX E List of Persons Eligible to Take Advantage of Overtime Provisions in Paragraph 4D Average Quarterly Name Overtime Hours Harris, J. L. 51 Prayer, B. J. 52 Lee, R. E. 52 Duns ton, Raymond 55 Wood, Lawrence 59 Burrell, Ernest 51 Cherry, J. E. 68 Pritchard, W. 0. 75 Cox, K. L. 76 McCleese, F. H. 81 Thorne, Boyce 68 Roberts, Columbus 76 Blunt, C. F. 67 Skinner, M. L. 78 Newby, W. F. 85 Reid, G. L. 93 Griffin, Millet 105 Smith, C. T. 110 James, Jesse 128 Walker, E. E. 129 Williams, J. E. 129 Brown, Serge 136 Jenkins, J. J. S. 146 Askew, Bennie 151 Brown, Curtis 151 Turner, Henry 154 Freeman, J. H. 160 Sturdivant, D. W. 188 Sharp, Ernest 189 Freeman, L. W, 160 Brock, R. 0. 139 Beamon, Jerry 118 Whitten, C. V. 83 Jacobs, Junius 211 Askew, Bernard 87 Williams, Percy 43 Brown, J . S . 65 Carroll, W. H. 51 I