Sherrill v. JP Stevens and Company Inc Brief for Appellees
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May 10, 1986

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Brief Collection, LDF Court Filings. Sherrill v. JP Stevens and Company Inc Brief for Appellees, 1986. 35ddfc35-c49a-ee11-be37-00224827e97b. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/6af86afc-1b36-4047-999e-36023a9dda4b/sherrill-v-jp-stevens-and-company-inc-brief-for-appellees. Accessed May 20, 2025.
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IN THE UNITED STATED COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 78-1122 A. C. SHERRILL, Plaintiff-Appellee, and ROBERT H. COSTNER, ROBERT LEE BROOKS and PAUL McLEAN, Plaintiff-Intervenors-Appellees, v. J. P. STEVENS and COMPANY, INC., Defendant-Appellant. Appeal from the United States District Court for the Western District of North Carolina Charlotte Division BRIEF FOR APPELLEES J. LEVONNE CHAMBERS Chambers, Stein, Ferguson & Becton, P.A 951 South Independence Boulevard Charlotte, North Carolina 28202 JACK GREENBERG JAMES M. NABRIT, III LOWELL JOHNSTON 10 Columbus Circle Suite 2030 New York, New York 10019 Attorneys for Plaintiffs. TABLE OF CONTENTS Page QUESTIONS PRESENTED ............................ 1 STATEMENT OF THE CASE ......................... 2 STATEMENT OF THE FACTS ........................ ARGUMENT: I. plaintiffs' Attorneys' Fee Award Should Not Be Reduced Because Of The Failure Of More Class Members To Make Back Pay Claims............. 19 II. The District Court's Award Of $94,200 In Attorney’s Fees To Plaintiffs Was Appropriate Under Title VII And Under The Civil Rights Attorney's Fees Awards Act of 1976 .......................... 23 III. Plaintiffs Should Be Awarded Fees And Costs On This Appeal ........... 34 CONCLUSION ..................................... 35 CERTIFICATE OF SERVICE 36 TABLE OF AUTHORITIES Cases Page Adams v. Weinberger, C.A. No. 3095-70 (D.D.C. 1976) ....................................... 29 Albemarle Paper Co. v. Moody, 422 U.S. 405,415 24 Arenso v. Board of Trade of City of Chicago, 372 F. Supp. 1349 (N.D. 111. 1974) ................ 29 Beazer v. New York City Transit Authority, 558 F .2d 97, 100 (2d. Cir. 1977) .................. 24 Blank v. Talley Industries, 390 F.Supp. 1 (S.D. N.Y. 1975) .......................................... 30 Christianburg Garment Co. v. EEOC, 54 L.Ed. 2d 648, 654 (January 23, 1978) .......................... 24 City of Philadelphia v. Chas. Pfizer Co., F.Supp 454 (S.D. N.Y. 1972) ............................... 29 Colson v. Hilton Hotels Corp., 59 F.R.D. 324 (N.D. 111. 1972) ............................... 30 Illinois v. Harper & Row Publishers, 55 F.R.D. 221 (N.D. 111. 1972) .......................... 30 In re Gypsum Cases, 386 F.Supp. 959 (N.D. Calif. 1974) .......................................... 30 Johnson v. Georgia Highway Express, Inc., 418 F .2d 714, 718 (5th Cir. 1974) ....................... 22 Johnson v. Georgia Highway Express, supra 488 F .2d 714 ................................... 25,33 Kelsey v. Weinberger, C.A. No. 1660-73 (D.D.C. 1975) .......................................... 30 Lindy Bros, of Phila. v. American R & S San. Co., 382 F.Supp 999 (E.D. Pa. 1974) ............ 30 National Association for Mental Health v. Weinberger, 68 F.R.D. 387 (D.D.C. 1975) ......... 29 National Association for Regional Medical Programs v. Weinberger, 396 F.Supp. 842 (D.D.C. 1975) .................................. 29 l i Page Newman v. Avco-Corp., C.A. Nos. 5158 & 4335 (M.D. Tenn. June 3, 1975) .................... 30 NLRB v. J.P. Stevens & Co., 464 F.2d 1326 (2nd Cir. 1972) ............................... 31 NLRB v. J.P. Stevens & Co. Inc., 538 F.2d 1152 (5th Cir. 1976) ............................... 32 Oliver v. Kalamazoo Board of Education, 73 F.R.D. 30 (W.D. Mich., S.C. 1976) ............ 30 Oppenlander v. Standard Oil Co., 64 F.R.D. 597 (D. Col. 1974) ................................ 29 Palmer v. Rogers, 10 EPD ^10,499 (D.D.C. 1975) 29 Parker v. Matthews, 11 EPD ^[10,821 (D.D.C.1976) 25 Rosenfeld v. Southern Pacific Co., 519 F.2d 527 (9th Cir. 1975) .......................... 29 S.E.C. v. W.L. Moody & Co., 363 F.Supp. 481 (S.D. Tex. 1973) .............................. 29 J.P. Stevens v. NLRB. 417 F.2d 533 (5th Cir. 1969) ......................................... 32 J.P. Stevens & Co. v. NLRB, No. 30,391 (2nd Cir., August 31, 1977) ....................... 31 Swann v. Charlotte Mecklenburg Board of Educ., 66 F.R.D. 483 (W.D. N.C. 1975) ............... 22,31 Statutes Civil Rights Attorney's Fees Awards Act of 1976, 42 U.S.C. §1988 ........................ 1,24 Title VII of the Civil Rights Act of 1964, 42 U.S.C. §2000e et seq., .................... 1,24 42 U.S.C. §1981 ................................ 2 Ill Page Other Authorities Legislative History of the Civil Rights Attorney's Fees Award Act of 1976 (Public Law 94-559 S.2278) S. Rept. at 6. 25 Legislative History, S. Rept. at 2....... 25 S. Rept. at 6 ............................. 28 iv. IN THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 78-1122 A. C. SHERRILL, Plaintiff-Appellee, and ROBERT H. COSTNER, ROBERT LEE BROOKS and PAUL McLEAN, Plaintiff-intervenors-Appellees, v. J. P. STEVENS and COMPANY, INC., Defendant-Appellant. Appeal from the United States District Court for the Western District of North Carolina Charlotte Division BRIEF FOR APPELLEES Questions Presented Did the District Court correctly apply the appropriate standards under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §2000e et seq., and under the Civil Rights Attorney's Fees Awards Act of 1976, 42 U.S.C. §1988, in awarding attorney's fees of $94,200. to plaintiffs in this "across-the-board" class action after they prevailed in a full hearing on the merits, after an unsuccessful appeal therefrom to this Court by defendant, and after second stage back pay proceedings? Statement of the Case Plaintiff A.C. Sherill instituted this action on January 29, 1973. He alleged that the defendant followed practices and policies of discrimination, based on race, against black employees in violation of Title VII and 42 U.S.C. §1981. Specifically, he alleged that defendant limited black employees to certain job positions and departments, excluded black employees, including the plaintiff, from supervisory, maintenance, managerial and clerical positions, harassed the plaintiff because of his efforts to enforce his rights under Title VII and generally denied black employees equal employment opportunities. The action was brought as a class action pursuant to Rule 23(a), (b) (2), FRCP. Plaintiff prayed that the Court enjoin the defendant's racially discriminatory practices, order appropriate affirmative relief and award the plaintiff and the class back pay, costs and reasonable *_/ attorney fees. (8-12) The defendant denied that it discriminated in its em ployment practices and objected to the action proceeding as _*/ Undesignated page references are to Joint Appendix filed with the first appeal of this case, No. 76-1064. 2 **/ a class action. (39-42) By a Memorandum dated August 28, 1973, the Court delayed issuing a final order with respect to the class designation pending completion of discovery. Discovery was directed to proceed as a class action consist ing of all black employees at defendant's Stanley, North Carolina facilities. (72) Pursuant to their motion filed September 19, 1973, (73-75) Robert H. Costner and Robert Lee Brooks were allowed to intervene as plaintiffs and to file a complaint in inter vention (76-78) on October 2, 1973 (82). Paul McLean (74-81, 83-84) was allowed to intervene as a plaintiff by Order, dated February 20, 1975. (85) Defendant answered the complaints in intervention on March 4, 1974. (85-87) The parties undertook extensive discovery, including numerous depositions and inspection and reproduction of all personnel files. The matter was heard on August 28-30, 1974, following which the Court left the record open for receipt of such additional evidence as the parties desired to present. Additional depositions were taken and submitted, including evidence of termination of the employment of one of the intervening plaintiffs (Costner) and three class members (Albert McDowell, Ray McDowell and William Jefferies) which occurred on July 29, 1974, approximately four weeks prior to **/ Defendant also demanded a jury trial. This request was denied following the pre-trial conference on May 22, 1973. 3 the trial. By order of December 19, 1974, the parties were directed to complete discovery and to file all briefs and additional evidence by February 18, 1975. After receiving the additional submissions, including briefs which the parties desired to submit, the Court advised the parties that upon complete review of the evidence it was of the opinion that the plaintiffs should prevail. The Court directed that plaintiffs submit, after consideration by the defendant, proposed find ings of fact and conclusions of law and a proposed order. (118) A class action order was entered on June 18, 1975 with a notice to be served on class members by certified mail and publication. (119-124) In conformity with the order, notice was forwarded to and published for all class members. Plaintiffs submitted proposed findings of fact and conclusions of law and a proposed order. Defendant filed objections, following the Court's Memorandum to Counsel of August 8, 1975. (125) The Memorandum scheduled a hearing on the proposals and objections for August 11, 1975. At that hearing the Court received responses from class members and separately reviewed each proposed finding of fact and con clusion of law and each proposal for the order. The Court heard defendant's objections with respect to each proposal and made numerous modifications in the proposed findings of fact, conclusions of law and order. The Court entered its Findings of Fact and Conclusions of Law and Judgment three 4 months later on November 11, 1975. 410 F.Supp 770 (W.D. N.C.) The Court found that defendant discriminated against black employees at its Stanley North Carolina facilities with respect to job assignments, transfers, seniority and promotion to supervisory positions. The Court ordered relief for individual and class members by requiring the company to cease racially discriminatory employment practices and to place affected black employees in their rightful positions. It directed the company to reform its seniority system, afford transfer and training opportunity to qualified employees, and post notices of job vacancies. The Court also ordered defendant to promote or hire black and white employees in equal numbers, subject to the availability of qualified persons, for supervisory, maintenance and clerical positions, until the number of black employees constitutes approximately 15% of the employees in these positions. The company was further required to report semi-annually for two years to the Court the measures it is taking to comply with the decree. Defendant filed a notice of appeal on December, 1975. After hearing oral argument on August 23, 1976, the district court's decision was affirmed by this Court in an unpublished per curiam opinion on January 24, 1977. (J.A. 42) Defendant sought rehearing en banc, and an amended order denying rehearing was filed on March 7, 1978. On May 12, 1977 plaintiffs moved in the District Court 5 for an interim award of counsel fees of $160,740.00; paralegal costs of $11,340.00; and litigation costs and expenses of $6,670.87 (J.A. 46-72) Plaintiffs moved the Court simultaneously therewith to refer the back pay issues in the case to a master. (J.A. -77) During the course of the hearing on back pay claims the parties reached an amicable settlement to conclude the litigation on the merits. (J.A. - 121-22) Eighteen individuals received back pay as a result of that settlement. On September 29, 1977, plaintiffs submitted a supple mental affidavit requesting attorney's fees covering work done after the remand of the case by the Fourth Circuit. (J.A. - 112-15) Defendant submitted no written opposition to plaintiffs' request for an award of attorney's fees. After a hearing on October 12, 1977, the district court made an award on December 5, 1977 of attorney's fees to plaintiffs of $94,200, together with costs and expenses of $7,646.76, and paralegal fees of $8,800.00. (J.A. -125-29) On January 6, 1978, defendant filed their notice of appeal of these awards. (J.A. -130) 6 STATEMENT OF THE FACTS A . General Practices of the Company While this appeal is limited to the issue of the amount of attorneys' fees awarded plaintiffs, we submit that defendant is attempting essentially to relitigate this case on the merits. We have chosen, therefore, to make a detailed statement of facts to protect the record in this matter. We regret having to do so, to the extent it is burdensome to the Court. As of the date of trial, the Company employed approximately 500 employees at the Stanley operation, approximately 35 or 40 of whom were black. (2798-2843) The Company had approximately 65 supervisors in production, including the plant manager and the plan superintendent. Other supervisors were classified as overseers, foremen and sectionmen. Except for one black pro moted to an assistant supervisor's position in 1967 in the warehouse, all supervisors were white. (211-213) Blacks consti tute 17% of the relevant job market. Prior to the effective date of Title VII, basically all black employees were assigned to the warehouse as laborers, lift truck operators or switchers. All white employees were assigned to plant production jobs or to jobs in maintenance or to clerical and managerial positions. (1623-1627) The first 7 black female was hired by the Company in 1965 when two black women were hired into winding. (204) The first black male was moved from the warehouse into a production job in 1963. Two other black males were transferred to production jobs in 1965. The first black male to be hired into a production job was in 1966. (205-208, 665-666, 903-907, 1623-1627) Subsequently, six or seven blacks were transferred into production jobs and approximately 24 black employees were hired into plant jobs. (2798-2843) Through the date of trial, however, the majority of black employees in any division of the Company were still assigned to and employed in the warehouse. In fact, blacks have never been assigned to any of the managerial and clerical positions, and, as of the date of trial, to 18 of the produc tion and maintenance jobs. (48, 68, 2798-2843, 1623-1627) White employees were not assigned to certain warehouse jobs except on a temporary basis. (48, 67, 2798-2843) Defendant offered no explanation for these practices. (665-666) Defendant has established no objective criteria for the selection or promotion of employees to any of the job positions in production or maintenance, nor for clerical or other sala ried positions. Most of the employees have not finished high school. (2798-2843) Defendant indicated it looks for a good work record and character and an attitude of being willing to 8 work. Defendant offered no standards for determining these qualifications. (177-178, 466-485, 683-703, 1610-1663) While defendant indicated it would prefer some experience for some of the maintenance job positions, it would hire and has hired numerous non-experienced applicants and trained them. (194, 1610-1663) Several high school students with no experience, either before or after completion of high school, have been assigned initially to several of the higher paying job posi tions. (2798-2843) The Company uses department or job seniority (frequently referred to as length of service) for bidding on shift prefer- 1/ ences. Company seniority is used .for determining fring benefits— insurances, vacations, etc. If an employee moves from one job position or department to another, as from the ware house to one of the production jobs or to maintenance, he must forfeit his accumulated seniority in the warehouse and start a new department or job seniority date on the new job. This reduces or eliminates the employee's ability to obtain a prefer- shift. Unless there is no employee in the new department who prefers an earlier shift, the transferring employee must begin on third shift. (173-179, 213-216, 323-324, 1611-1613) This 1/ The Company operates three shifts. Most employees prefer the first shift. 9 policy deters many blacks from transferring because they do not want the third shift. (854) There is no written policy of wage protection for trans ferring employees. Thus, an employee transferring from the warehouse to a production job may also have to take a reduction in pay. (525) The Company did not post vacancies of production, mainte- 2/ nance, supervisory and clerical positions. The employees, therefore, did not know of job openings until they were filled. The standards for job promotions are basically the same as those for initial hiring. For promotions to higher level jobs, the Company indicated that it would consider the work experience of employees, attendance, production and how they get along with others. The Company has no objective standards for determining qualifications and basically leaves the determi nation to the white supervisors. The Company does not maintain lines of progression and employees can transfer or promote into any production and 2/ The Company contends that posting was terminated in 1973. Brief for Defendant-Appellant, pp. 83-84. The Personnel Manager testified that the Company ceased posting job vacancies two years prior to trial in 1974. In any event, all parties agreed that posting was necessary to advise the affected employees of vacancies to which they might transfer. (218-219, 1405, 1581-1583) 10 maintenance job, including the highest paying jobs, without prior work experience- Employees can also promote into the beginning level supervisory job (sectionman) without experience in a prerequisite job. The Company indicated that supervisors in the various departments are generally selected from employees with exper ience on the machines and that generally an employee with the greatest seniority will be considered first. Since black employees have been excluded until recently from production job positions, this practice limits the number of black employees who can be considered for supervisory positions. Additionally, as indicated above, the Company has not consistently followed the practice. There was no showing that the Company's practice of select ing supervisory personnel from production employees is essential for the successful and safe operation of the Company. (177-213, 407-411, 560-567, 683-798, 773-780, 1007-1023, 1592-1613) With the exception of the one black assistant supervisor in the ware house, no black employee has been promoted to a supervisory position, although the Company offered the position to four black employees after plaintiff Sherrill complained. (211-213, 843-844, 931) 11 In addition to the on-the-job training for production, maintenance and supervisory employees, the Company maintains two training programs to prepare employees to move into super visory positions. One of the programs is operated out of the Greensboro, North Carolina regional office of the Company. The other is operated at the Stanley facilities. The Company offered no objective standards for selecting employees for the training programs. Several white supervisors trained through the programs, some with less seniority than incumbent blacks. No black has ever been selected for either of the training pro grams (199-211, 407-411, 560-567, 731-733, 757-758, 1592-1596, 1974-1979) nor has the Company advised the black employees of the training programs. The Company agreed that there are quali fied black employees for the programs but stated it does not know why blacks have not been selected. (1977, 2410) B. Facts Relating to the Named Plaintiffs and Class Members. Plaintiff Sherrill was employed by the Company in 1967 as the first black spinning doffer. He left the Company in 1967 but returned in 1968. In 1969, he began efforts to promote to a supervisory job position or to other positions such as an oiler or on a machine in order to improve his ability to promote to a section job. He was denied a supervisory position in 1969, 1970 and February and March of 1971. He heard of another supervisory 12 vacancy in July, 1971, and requested consideration for a super visory position. When he failed to get this position, he complained and wrote a letter to management in which he indicated that the Company was depriving him and other blacks of consider ation for supervisory positions because of their race. This was the first instance of a black challenging the racially discrim inatory practices of the Company. Following receipt of this letter, management began a number of meetings which were threatening and intimidating to plaintiff Sherrill. He was called into a meeting in July, 1971, with several management officials. His supervisors later called him into a meeting at night and engaged in a heated argument with him. White employees began to harass and threaten him with bodily harm. These incidents continued through December 10, 1971, when he was again called into a meeting with management and several supervisors. At this meeting, management asserted that he had not been harassed, alleged that he was lying and suggested that he was working a two week notice to leave his employment. The plaintiff was not allowed to explain the various harassing and intimidating incidents. He denied that he had told anyone of a two week termination notice and was generally intimidated and forced to leave his employment. (220-222, 241- 254, 283-285, 354-367, 3079-3081) 13 The Company did not evaluate plaintiff Sherrill for any of the section jobs filled during his employment. After this action was filed, the Company attempted some post evaluation efforts and indicated that the white employees promoted in February or March, 1971, had more experience in winding than plaintiff Sherrill; that the employee promoted in July, 1971, had experience on an old spinning machine while Sherrill worked on a newer spinning machine and that other whites who were pro moted had experience in their particular departments. Even with respect to these employees, the Company offered no objec tive criteria for making these determinations. It had promoted white employees to section jobs with no previous experience and at no time offered plaintiff Sherrill an opportunity to train in one of the training programs for subsequent promotion to a section job. It had no explanation for its failure to place the 3/ plaintiff in a training program. After being denied a section job, plaintiff Sherrill requested a leave to train as an over-the-road truck driver for the Company. He was denied leave for this purpose although the 3/ Defendant argues in its Brief that it should not have to place the plaintiff in a training program when it had no vacancy in a supervisory position. No vacancy in a supervi sory position existed, however, for whites placed in the train ing programs. They simply trained up to 18 months or more until a vacancy occurred. (407-410, 560-567, 1592-1596, 1974-1979) 14 Company had granted leave for more than the period requested by the plaintiffs to other employees for personal reasons. Prior to and after plaintiff Sherrill's efforts, Thomas McCorkle, a black employee, attempted to promote to better paying positions in production and to supervisory posi tions. He transferred from the warehouse to a production job and had to begin a new job or department seniority date. He took training courses and was qualified for a section job. White employees with less seniority and experience were pro moted over him. (1315-1400) In fact, he was not even considered for several of the section jobs that were vacant during the term of his employment nor advised of or offered a position to train in one of the training programs. (1315-1400, 2508-2537) He was offered a section job after leaving the Company and after plaintiff Sherrill had instituted this proceeding. Between 1955 and the date of trial, the Company had promoted approximately 20 employees to section jobs, approxi mately 5 to the second level supervisory rank of overseer, two ±/ to foreman positions, 3 to fixer positions and 2 to oiler 4/ Fixers assist sectionmen in doing minor repairs on operating machines. Major repairs are done by maintenance employees. (445-703, 1935-1945) The Company offers as an excuse for not promoting plaintiff Sherrill to one of the 15 positions. With the exception of the four blacks offered section jobs after plaintiff Sherrill's complaint, no black has been offered or considered for a section job or for one of the training programs. (1923-1977, 2802, 2807, 2809, 2816, 2821, 2826) Plaintiff Costner was employed by the Company in 1949 and assigned with the other black employees to the warehouse. He sought a transfer to a production job in 1967 and after trans ferring was required to take a new seniority date. He could not successfully bid on a preferable first shift because of his new seniority date and went back to the warehouse in order to work first shift. He lost all accumulated seniority and had a seniority date of 1967. (320-339) Plaintiff Brooks was hired by the Company in 1967 and assigned to one of the lowest paying jobs in the plant. He 4/ (continued) winding supervisory positions that he did not have experience on the winding machine. After Mr. Saul Rudisell, a fixer, testi fied that a sectionman would not need such experience since the fixer would do the repairs on the machines, the Company later offered evidence that a fixer was not assigned to the particular shift of winding section foreman position about which plaintiff Sherrill complained. It offered no evidence, however, how the white supervisors with no prior experience and no fixers assigned to their departments were able to repair the machines which the Company contended was critical. (2409-2410) The white employees were simply trained on the job. Plaintiff Sherrill was denied this opportunity. 16 tried to promote to a better paying job position and to be assigned to a better shift. After being denied these requests, he transferred to a first shift job in the warehouse and made efforts to return to the plant in a better paying job position. He quit the Company in 1973 because the Company denied him an opportunity to promote into better paying job positions. (1176-1216) Plaintiff McLean was assigned to a warehouse job in 1966. He was hired on work release. He was not offered a job in pro duction. He wanted a better job position in production but did not know of the openings. As with other employees in the ware house, he would have to relinquish his accumulated seniority to transfer into a production job. (1279-1312) Black women were not hired by the Company until 1965. Practically all women are assigned to the winding department in the various plants and are not considered for supervisory positions. The Company suggested that women were not strong enough to do the supervisory jobs. It offered no evidence to validate this position. (1946, 2020-2031) The Court found that the practice of the Company of assign ing black employees to the warehouse and requiring that they relinquish accumulated seniority in order to promote to better paying job positions and in failing to post for job vacancies 17 and to provide wage protection perpetuated the prior practices of discrimination against blacks. The Court also found that the Company discriminated against black employees who were hired after 1965 and limited to employment in the warehouse; that the Company discriminated against plaintiff Sherrill and other black employees in denying them consideration for and assignment to supervisory positions and the various training programs for the supervisory positions; that the Company harassed and forced plaintiff Sherrill to leave his employment because of his efforts to exercise his rights under Title VII; and that the black employees who had transferred to production jobs with loss of seniority were being deprived of equal employment opportunities. On the basis of these findings, the Court found that the action could properly be maintained as a Rule 23(a), (b)(2) class action. The class was certified as: "all black applicants for employment, black employees and former black employees who, since July 2, 1965, have been and who continue to be affected by the Com pany's racially discriminatory employment practices. The class was further subdivided into: (a) black employees hired before July 2, 1965, who continued in employment subsequent to July 2, 1965; (b) black employees hired subsequent to July 2, 1965 who have continued to be assigned to job positions in the warehouse or shipping department; (c) black employees initially assigned to the warehouse who have been per mitted to transfer to production jobs but were required to start a new seniority date; and (d) black employees who were initially assigned to production jobs at any time subsequent to July 2, 1965, who have been or may be affected by defendant's racially discriminatory employment practices." 18 ARGUMENT I PLAINTIFFS' ATTORNEYS' FEE AWARD SHOULD NOT BE REDUCED BECAUSE OF THE FAILURE OF MORE CLASS MEMBERS TO MAKE BACK PAY CLAIMS. Defendant has appealed the award of attorneys' fees in this case because only 18 members of the class made claims for back pay. Their argument is that since only a few members of the class actually made claims for back pay, the problems at the Stanley facilities were not serious, and this class action was "fruitless" and "unnecessary." Defendant’s position is untenable and frivolous. We can only engage in the most idle speculation about the motivations of class members who chose not to press claims for back pay, because the record before this Court is barren of any guidance on these issues. Indeed, in the District Court defendant failed even to file a brief in opposition to plaintiffs' motion for attorneys' fees, and the issues being argued in this Court are being raised for the first time. In the absence of any contrary evidence, such as record of testimony of class members who declined to seek back pay, rather than assume the class relief was unnecessary, we should assume just as readily that those members of the class who did not file back pay claims may have been afraid to, failed to understand the notices spelling out the procedure 19 or how their claims might be proven, or some similar reasons. The only hard evidence of the "necessity"of this class action to eliminate employment discrimination at the defendant1s Stanley facility is in the decision of the district court in favor of plaintiffs, on the merits, and this Court's virtual summary affirmance of that decision. In reviewing the district court's opinion, this Court stated: 5/ The court found that Stevens discriminated against black employees at its Stanley, North Carolina facilities with respect to job assignments, transfers, seniority, and promotion to supervisory positions. The court ordered relief for individual and class members by requiring the company to cease racially discriminating employment practices and to reinstate several employees. It directed the company to reform its seniority system, afford transfer and train ing opportunity to qualified employees, and 5/ We submit that a number of class members who would have been entitled to back pay left the company and found other employment in the area, at substantially higher pay. Thus they were not entitled to back pay. For example, William Jeffries and Albert McDowell made no back pay claims and declined reinstatement because they had found higher paying jobs elsewhere; likewise, Robert Brooks and John Brown had found higher paying employment elsewhere. Also, in con testing back pay claims based on the failure to promote, such as that of McDowell, defendant applied experience requirements which plaintiffs weren't able to meet because of prior discrimination. 20 post notices of job vacancies. The court also ordered Stevens to promote or hire black and white employees in equal numbers, subject to the avail ability of qualified persons, for supervisory, maintenance, and clerical positions, until the number of black employees constitutes approximately 15% of the employees in these positions. The Court . . . required the company to report semiannually for two years measures it is taking to comply with the decree. [T]he district court's findings of fact are sustained by the record, and there is no basis for setting them aside as clearly erroneous. In its applications of the law to the facts, the court committed no error. Cf. Patterson v. American Tobacco Co., 535 F.2d 257 (4th Cir. 1976); Robinson v. Lorillard Corp. 444 F .2d 791 (4th Cir. 1971). (J.A. 43-44). This summary by this Court of the far-reaching relief ordered by the district court makes it apparent that defendant has understated the benefits derived by the class from the lawsuit. The district court's order not only afforded transfer opportunities and the chance to recover back pay to past victims of discrimination, but also assures to present and future black employees equality of treatment 6/ in hiring, job assignment, transfer and promotional opportunities. 6/ There is already evidence that the affirmative relief granted in this case has opened the way to the assignment of blacks to non-traditional jobs (See Appendix A - names with asterisks) free of the blatant discrimination of the recent past. 21 That a court only afforded plaintiffs this kind of non- pecuniary, injunctive relief has never been held to bar or to diminish the attorneys fee to a prevailing plaintiff under VTitle VII, or under the Civil Rights Attorney's Fees Award 8/ Act of 1966, or by analogy, in school desegregation litigation, 9/ where the recovery is invariably non-pecuniary in nature. ^6/ contd. Moreover, while defendant was willing to enter into a settlement of this matter prior to trial, the terms of that settlement would not have included the kind of complete relief ordered by the district court, such as reinstatement of Sherrill; transfer rights of blacks in warehouse jobs with red circling; and goals for assignment of blacks to management positions and clerical jobs. At the same time defendant was not moving independently to comply with Title VII, or to cure the effects of past discrimination. In addition, there were also many class members with viable back pay claims who had not yet left the company for better jobs, and their claims would not have been paid under the terms of settlement proposed by defendant. It is clear that had plaintiffs' counsel entered into such a settlement they would have breached their fiduciary duty to the class. 7/ As to Title VII the Fifth Circuit states in Johnson v, Georgia Highway Express, Inc.,418 F.2d 714, 718 (5th Cir. 1974), Although the court should consider the amount of damages, or back pay awarded, that consideration should not obviate court scrutiny of the decision's effect on the law. If the decision corrects across- the-board discrimination affecting a large class of an employer's employees, the attorney's fee award should reflect the relief granted. 8_/ The legislative history of the Civil Rights Attorney's Fees Awards Act makes this abundantly clear: It is intended that the amount of fees awarded under [the 1976 Act] be governed by the same standards which prevail in other types of equally complex federal litigation, such as antitrust cases and not be reduced because the rights involved may be non pecuniary in nature. S. Rept. at 6. 9/ Swann v. Charlotte Mecklenburg Bd. of Education, 66 F.R.D. 483 TW.D. N.C. 1975) 22 ARGUMENT II THE DISTRICT COURT'S AWARD OF $94,200 IN ATTORNEY'S FEES TO PLAINTIFFS WAS APPRO PRIATE UNDER TITLE VII AND UNDER THE CIVIL RIGHTS ATTORNEY'S FEES AWARDS ACT OF 1976 Upon the conclusion of this Court's review of the district's decision on the merits, plaintiffs filed a motion seeking an interim attorneys' fee award and costs. (JA-46). Aside from litigation expenses and costs of $6,670.87, and paralegal costs of $11,340.00, plaintiffs sought attorneys' fees of $160,740.00. The latter was actually based on 1,071 hours at the rate of $75 per hour, or $80,370.00, multiplied by a factor of 2.0. Plaintiffs sought the multiplier to take into account, "inter alia, the complexity and contingency of the case, the results obtained, the expertise of plaintiffs' counsel, the fact that plaintiffs counsel have had to wait years in order to receive their fee." (JA-58) The district court did not act on plaintiffs' motion until the conclusion of back pay proceedings. At that point plaintiffs submitted a supplemental affidavit seeking attorneys' fees for an additional 273.10 hours related to proceedings on remand, including back pay proceedings, and 40 additional hours for estimated time to be spent in litigation, for a total of 313.10 additional hours. (JA-114-115), with the multiplier this 23 comes to roughly $39,000 in additional fees sought by plain tiffs. Plaintiffs sought additional paralegal costs of $440.00 and additional litigation costs and expenses of $975.89. (JA-116-17) In all, plaintiffs sought attorneys fees of $199,000; paralegal costs of $11,780; and litigation costs and expenses 10/ of $7,646.76. The district court awarded $94,200 in attorneys' fees; $8,800 in paralegal costs; and litigation costs and expenses of $7,646.76. 11/ Under both Title VII and the Civil Rights Attorney's Fees 12/ Awards Act of 1976, plaintiffs clearly are prevailing parties and entitled to an award of attorneys' fees, costs and expenses. On November 11, 1975 the district court entered judgment grant ing plaintiffs the needed relief sought including substantial injunctive relief and back pay. Moreover, that court's judg ment was affirmed by this Court in a per curiam opinion rendered IP/ Defendant took no discovery in the district court as to the basis or necessity for the hours claimed and filed no brief in opposition to the fees and costs requested. I V 42 U.S.C. §2000e-5k. See Christiansburg Garment Co. v . EEOC, 54 L. Ed. 2d 648, 654 (January 23, 1978); Albemarle Paper Co. v. Moody, 422 U.S. 405, 415. 1W 4-2 U.S.C. §1988. See, Beazer v. New York City Transit Authority, 558 F.2d 97, 100 (2d. Cir. 1977) 24 r \ on January 24, 1977, and rehearing en banc by the Fourth Circuit was denied on March 7, 1977 The standards for determining the amount of the attorneys' 13/ fee are the same both under Title VII and under the 1976 Act, and are set forth in Johnson v. Georgia Highway Express, supra, 488 F .2d 714. In determining an appropriate fee in a civil rights case where Congress has clearly authorized an award to prevailing litigants, the Court must try "to insure fair and reasonable compensation to plaintiff's attorneys as well as to encourage similar services from public interest advocates s' /\0 in the future." Parker v. Matthews, 11 EPD 5^0,821 (D.D.C.1976). V'- V ” "Civil rights laws depend heavily upon private enforcement, and fee awards will prove an essential remedy if private citizens are to have a meaningful opportunity to vindicate the 14/ important Congressional policies which these laws contain. Both plaintiffs' motion for attorneys’ fees and the district court's determination are based on a meticulous appli cation of the factors in Johnson to the facts of this case. 1. Results Obtained The district court found that plaintiffs had obtained B / S. Rept. at 6 Legislative History of the Civil Rights Attorneys' Fees Awards Act of 1976 (Public Law 94-559 S .22 78 14/ Legislative History, S.Rept. at 2. 25 substantial relief for black employees at defendant's Stanley facilities. Apart from having to reinstate plaintiff and other class members, defendant was ordered to make changes in procedures and policies to insure that black employees are free to transfer to ocher departments and to receive promotions on the same basis as whites and without suffering the effects of past discrimination. The district court further noted that all black back pay claims had been settled. Plaintiffs prevailed on all major issues in the litigation, and defendant has been brought into compliance with federal equal employment opportunity laws. 2. The difficulty and novelty of the case. The district court found that the case did not present novel questions of law, but that it did involve the organization 15/ and presentation of a great quantity of information. The district court also noted that defendant is noted for "its indefatigable defense of cases involving labor, and its vigorous defense of this case was in keeping with its reputation."(JA-127) 3. Fees paid to opposing counsel. The district court noted that while there was no evidence in the record, it was informed that defendant's counsel was on 15/ For example, the record in this case consists of seven volumes of appendices, over 3000 pages. 26 a once a year billing basis, and was not paid on an hourly or case by case basis. 4. Time and labor involved. The district court found that the time spent by plaintiffs' attorneys (1344.7 hours), and by paralegals (529) was not un reasonable, considering the nature of the case. The court noted that the work done by lawyers was not work suitable for clericals or paralegals. Moreover, the work done by paralegals was not superfluous, the largest portion of their time was spent analyzing personal records. The actual hours spent by plain tiffs' attorneys and paralegals were described in detail in an affidavit summarizing their time records (JA-59-72). This court should note that nearly 150 hours had to be spent defending the district court's decision on the merits on appeal. 5. Loss of other business. The district court found that a case of this magnitude requiring the expenditure of over 1300 hours of lawyer time over four and one half years of necessity restricts the work a law firm can do for other clients. 6. Fees customarily charged for similar cases. The district court found that it is usual for competent attorneys in that part of the country to charge $50 an hour or more for their services. Plaintiffs sought and obtained an award of $75 an hour for Mr. Chambers and Mr. Belton; $60 27 an hour for Mr. Wallas; and $55 an hour for Mr. Lesesne. Hourly rates of this kind find support in the legislative history of the 1976 Act, where in it was noted that the fee award in civil rights cases is to be governed by the prevail ing rate for other types of complex federal litigation, such 17/ as antitrust and security cases. We list below a number of fee award cases from all walks of federal jurisprudence. The cases range in complexity and magnitude from single plaintiff Title VII cases, requiring a few hundred hours of lawyer work, to the Gypsum antitrust cases involving thousands of lawyer hours. We believe these cases provide useful comparisons, both positive and negative (from our standpoint) to the instant case. We caution that civil rights cases only recently have begun to receive the dignity and respect they are due in the matter of attorney's fees and in all other respects. 16/ 16/ Defendant did not contest these hourly rates in the district court. 17/ See, S. Rept. at 6: "It is intended that the amount of fees awarded under [the 1976 Act] be governed by the same standards which prevail in other types of equally complex federal litigation, such as antitrust cases and not be reduced because the rights involved may be nonpecuniary in nature." 28 Name, Citation and Type of Case Adams v. Weinberger, C.A. No. 3095-70 (D.D.C.1976)(school desegration suit against HEW under Title VI) Rosenfeld v. Southern Pacific Co., 519 F .2d 527 (9th Cir. 1975)(Title VII) Palmer v. Rogers, 10 EPD ^[10,499 (D.D.C.1975)(Title VII— not a class, but an individual action) National Association for Mental Health v. Weinberger, 68 F.R.D. 387 (D.D.C.1975)(unlawful im poundment of Federal funds) National Association of Regional Medical Programs v. Weinberger, 396 F.Supp. 842 (D.D.C.1975) (unlawful impoundment of Federal funds) Oppenlander v. Standard Oil Co., 64 F.R.D. 597 (D.Col.1974) (Securities Act) Arenso v. Board of Trade of City of Chicago, 372 F.Supp.1349 (N.D. 111.1974)(antitrust) S.E.C. v. W.L.Moody & Co., 363 F.Supp. 481 (S .D.Tex.1973) (Securities Act) City of Philadelphia v. Chas. Pfizer Co., 345 F.Supp.454 (S.D.N.Y.1972)(antitrust) Fee Awarded (Exclusive of Expenses) $100/hour for all counsel; no bonus since issues "were neither novel nor complex"; fees awarded under §718 Upheld average of $73.71/hour for all counsel (1971 award) $75/hour for lead counsel; $40/hour for junior counsel; $15/hour for paralegals $70/h o u r for substantive work plus 75% "bonus" for an effective hourly rate of $122.50, plus $50/hour for work on fee application $70/hour plus 100% "incentive bonus", for effective hourly rate of $140 $190/hour Up to $125/hour, multiplied by a factor of 4 to take account of contingent nature of fee and of the results achieved, bringing some effec tive rates up to $500/hour $90/h o u r for lead counsel and $60/hour for others (ho con tingency) "Mix rate" of $200/hour for all counsel. 29 Colson v. Hilton Hotels Corp., 59 F.R.D. 324 (N.D.111.1972) (antitrust) Illinois v. Harper & Row Publishers, 55 F.R.D. 221 (N.D.111.1972)(antitrust) Newman v ■ Avco-Corp., C.A. Nos. 5158 & 4335 (M.D. Tenn. June 3, 1975)(Title VII) Kelsey v. Weinberger, C.A. No. 1660-73 (D.D.C.1975)(Faculty desegregation suit against HEW) Blank v. Talley Industries, 390 F.Supp. 1 (S.D.N.Y.,1975) (Securities Act) Lindy Bros, of Phila. v. Ameri can R & S San. Co., 382 F.Supp 999 (E.D.Pa.1974)(antitrust) In re Gypsum Cases, 386 F.Supp. 959 (N.D. Calif.1974)(anti trust) Oliver v. Kalamazoo Board of Education, 73 F.R.D. 30 (W.D. Mich., S.C., 1976)(school desegregation) Average of $152.29/hour for all counsel. Average of $119.50/hour for all counsel. Rate of $100/hour (apparently for senior counsel (the maxi mum rate requested by counsel was $60/hour; the award thus reflects an incentive increase) $100/hour for all counsel, plus a bonus of 50% for an effective rate of $150/hour; award under §718 $100/hour for partners; $50/ hour for associates, plus a bonus of 50% to make effec tive rates $150 and $75/hour. Hourly amounts ranged from $35/hour to $125/hour and were multiplied by a factor of 2 for certain work for effective hourly rates ranging from $70 to $250/hour. $100/hour for partners, $50/ hour for associates, $30/hour for purely administrative work, $15/hour for paralegals. Rates for different law firms multi plied by factors ranging from 1.75 to 3 as bonus, bringing some rates up to $300/hour Rate of $100/hour for senior counsel and $35 to $75/hour for junior counsel. ($75/hour for junior counsel with major responsibility) - 30 - 7. Fixed or contingent fee The district court found that while plaintiffs had accepted this case on a contingent basis, this does not eliminate the attorney's entitlement to a fee award. See Swann v. Charlotte- Mecklenburq Board of Education, supra, 66 F.R.D. at 486. 8. The undesirability of the case. By having chosen to be civil rights attorneys plaintiff's attorneys are thereby precluded from other profitable employ ment. Some potential clients would not choose to eriploy them because of their opposition to the results sought (and obtained) in cases of this sort or because of a fear that others, includ ing judges and jurors, would have animosity towards them. Thus, from the point of view of income to be realized by plain tiffs' counsel, this action was an undesirable one. In addition the district court also found as follows: This case was accepted on a contingent fee basis; it promised to span several years before counsel could be compensated at all? and it required counsel to sue adversaries known for their persistent and vigorous defense of cases involving labor. See, e,g. J.P. Stevens & Co. v. NLRB, No. 30,391 (2nd Cir., August 31, 1977)(approving idea of compliance fines to secure obedience by Stevens to several outstand ing court orders)? NLRB v. J.P. Stevens & Co., Inc., 538 F.2d 1152 (5th Cir. 1976)(holding Stevens in civil contempt for violating a court order that it bargain in good faith with its employees as required by the National Labor Relations Act); NLRB v. J.P. Stevens & Co., 464 F.2d 1326 (2nd Cir. 1972)(holding 31 Stevens in civil contempt for failure to comply with Court of Appeals order affirming NLRB en forcement of the National Labor Relations Act); and J.P. Stevens v. NLRB, 417 F.2d 533 (5th Cir. 1969)(finding repeated violations of National Labor Relations Act). These factors made this case very undesirable. Few competent and experienced lawyers would have been willing to make the sacrifices required to pursue it. (JA-128) 9. Reputation, experience & ability of plaintiff's counsel. The district court found that "Plaintiffs' counsel are all exceptional in this regard." (JA-128). The court noted that they have successfully litigated numerous employment discrimination and other civil rights cases including many landmark cases. See affidavits of Jonathan Wallas, JA-59-63; 112-113 10. Expenses and advancements. The district court found that the expenses claimed by plaintiffs of $7,696.76 (see itemization at JA-70-72; 117) were directly related to the litigation. The court found further that some of those costs had been advanced and had to be repaid. (JA-12 8-2 9) . 32 11. Cost of operating a law business. In support of its determination of the hourly rate for plaintiffs' counsel, the district court took into account the cost of operating a law office, and noted that their costs have to be paid out of fees "before the lawyers can start paying themselves and the income tax collections; and that the fees herein awarded are not 'net profits' to the recipients." (JA-12 9) 12. Incentive Bonus. While the district court noted that the purpose of awarding attorneys' fees is to attract competent counsel in order to in sure full enforcement of federal civil rights laws, and that an extra incentive award may be appropriate in employment discrimin ation, the court declined to make such an incentive award. Rather the court limited itself to awarding plaintiffs attorneys' fees at the hourly rates requested, less roughly $1000. (JA-129) It thus appears that the district court carefully analized plaintiffs' request for attorneys' fees according to the stan dards articulated in Johnson v. Georgia Highway Express, supra, 488 F .2d 714. Indeed the court denied by more than half the fees requested by plaintiffs. We submit that defendant has shown no abuse of discretion in that award, and the award should be affirmed. 33 ARGUMENT III PLAINTIFFS SHOULD BE AWARDED FEES AND COSTS ON THIS APPEAL. Under Rule 38 of the Federal Rules of Appellate Procedure,this Court may awary "just damages and single or double costs to the appellee" when an appeal is "frivolous." Defendant's appeal is clearly without merit. Moreover, the award of attorneys' fees, costs and expenses made by the district court was not formally apposed by defendant in the district court, and the issues raised herein were raised for the first time in this Court. Plaintiffs therefore respectfully request this Court to award double fees and costs to plaintiffs on this appeal. 34 Conclusion For all the reasons stated, plaintiffs request summary affirmance of the district court's counsel fees award, and an award of costs and expenses on this appeal. 951 South Independence Boulevard Charlotte, North Carolina 28202 JACK GREENBERG JAMES M. NABRIT, III LOWELL JOHNSTON 10 Columbus Circle Suite 2030 New York, New York 10019 Attorneys for Plaintiffs. 35 CERTIFICATE OF SERVICE The undersigned certifies that copies of the foregoing Brief for Appellees was served on counsel for the defendant by United States mail, postage prepaid, this 10th day of May, 1978, as follows: Whiteford S. Blakeney, Esq. Brown Hill Boswell, Esq. Blakeney, Alexander & Machen 3450 NCNB Plaza Charlotte, North Carolina 28280 Attorney for Plaintiffs 36 APPENDIX ’A* o J. P. STEVENS & CO., INC. STANLEY PLANT A. C. SHERRILL, et. al., J. P. STEVENS & CO., INC. CIVIL ACTION NO. C-C-73-12 PURSUANT TO PROVISIONS OF PARAGRAPH #15 THE FOLLOWING REPORT IS SUBMITTED FOR PERIOD (SIX) 1DNTHS ENDING JUNE 30, 1977. APPENDIX 'A > o U; j STANLEY PLANT J. P. STEVENS & CO., INC. I. List of Black Employees transferred to Production or Maintenance jobs during six months ending June 30, 19770 Name Transfer Date Seniority Date Job Title A. C. Sherrill 3-28-77 2-14-68 Section Man II. List of Supervisory, Clerical, Office and Maintenance Vacancies occuring during six months ending June 30, 1977. Job Title Department 10-B Twister Fixer Turbo Spinning & Twisting Section Turbo 10-3 Twister Fixer Turbo Temporary Overhauler Plant if2 Temporary 10-B Twister Fixer Turbo Temporary Overhauler Plant #2 Temporary Machinist Shop Temporary 10-B Twister Fixer Turbo Production Clerk Office Production Trainee General Plant Overseer Plant H2 III. List of Employees selected to fill Supervisory, Clerical, Office and Maintenance Vacancies during six months ending June 30, 1977. Name Sex Race Original Hire Date Jerry N. Woody M W 12-27-66 Robert Ingle M W 5-31-48 Max Smith M w 5-30-51 Hunter A. 31ack M w 4-14-77 William Howie M w 1-17-77 Dennis H. Eldridge M w 5-9-77 Blair Bynum M w • 6-3-77 William Howie M w 5-2-77 Patricia S. Abernathy F w 3-14-77 William J. Seay M w 5-20-76 Stephen J. Auten M w 8-2-76 Job Title 10-3 Twister Fixer Spinning & Twisting Section 10-3 Twister Fixer Temporary Overhauler Temporary 10—3 Twister Fixer Temporary Overhauler Temporary Overhauler Temporary 10-B Twister Fixer Production Clerk Production Trainee Overseer o (2) IV. Current Roater of Supervisory, Clerical and Maintenance Personnel at.the Stanley Facility. Name Sex Race Job Title Original Hire Department Charles Rhyne M W Plant Manager 2-25-52 General Ronald V. Furr M W Superintendent 1-29-62 General William Abernathy M w Foreman 9-1-47 Plant rf2 Stephen J. Auten M w Overseer 8-2-76 Plant jf2 Ronald Baker M w Personnel Manager 10-7-63 Office Fred Bradshaw M w Overseer 7-13-49 Plant rfl Eli Brown M w Shop Supervisor 5-10-47 Shop Russell Christopher M w General Overseer •3-3-56 Turbo J. D. Clemmer M w Overseer 1-2-46 Turbo John Moore M w General Overseer 11-6-62 Plant if2 James Gantt M w Foreman 1-19-52 Plant -fl Raymond Hoffman M w Foreman 10-10-56 Plant !f2 E. W, Human M w Overseer 11-1-54 Plant rf2 Joe W. Jenkins M w Planning Manager 11-26-63 Office J* • «T • Ladd M' w Office Manager 7-11-60 Office Paul Mauney M w Overseer 9-15-35 Plant #1 James Mitchell M w Industrial Eng. Manager 1-3-66 Office John C. Powell M w Foreman 6-24-74 Turbo Hazel McGinnis M w Foreman 1-1-42 Turbo William Oates M w Foreman 10-5-55 Plant ff2 Donald Sapp M w Quality Control Manager 10-4-50 Office Neal Watts M w General Overseer 12-1-41 Plant #1 Richard Perkins M w Training Supervisor 3-26-73 Office Dan Link M w Asst. Ind. Engr. 10-9-72 Office Earl Withers M w Handling & Storage 9-28-47 Office Manager-Supervisor James Sadler M w Clerk 3-25-63 Office James Cannon M w Supply Supervisor 10-1-47 Office John Jeffries M B Warehouse Foreman 5-10-54 Office Leonard Lowe M w Planning Clerk 2-16-42 Office Arthur McGinnis M w Asst, H. & S. 1-3-55 Office Supervisor David Morris M w Planning Clerk 11-1-49 Office Max Presswood M w Engineering Clerk 8-6-59 Office Deanne Caudle F w Secretary 1-5-65 Office Vickie Cloninger F w Clerk 10-18-71 Office Martha Coley F w Personnel Clerk 3-2-59 Office Gail Huss F w Payroll Clerk 2-9-70 Office Carolyn Mcore F w Clerk 9-1-52 Office Patricia Ritchie F w Clerk 6-12-72 Office Margaret Sigmon F w Clerk 9-25-72 Office Elsie Stalvey F w Clerk 3-17-69 Office Mary Watts F w Supply Clerk 3-27-42 Office Phyllis D. Luckey F B Payroll Clerk 8-10-76 Office Hope Withers F w Clerk 11-16-64 Office Eennie R. Webb F w Clerk 6-3-74 Office Ann Moore F w Switchboard Operator 7-25-74 Office ) (3) rI, (Cont’d.) Marne Ruth Cloninger Betty Abernathy Geraldine Cloninger Ollie McConnell Bobbie Fletcher Andrea Hicks Frank Dellinger Patrick Johnson Ruth Lackey Claude Phillips Lathan Hovia Coy R. Woody Steve Morris R. A. Robinson Hubert Stroupe Donald Whitley John Warlick Jack Ward Artie C. Hawn A. C. Kennedy Terry Sumraey ^ William N. Luckey John Mills Albert R. Perkins John Siak Janes Steel9 Ernest Shuford 0. Co Soles Forrest Rogers Charles Satterfield h i Jack Schronce Danny Armstrong Charles Satterfield Frank Lewis Harold Helms Richard Payne Jack Hull Nathan Martin Robert Homesley Hall I-Sorris Curtia A. Hubbard J, Bo Long George Moore A. P. Glenn Charles Hammack Claude 3rackett Race Job Title W Clerk V Cost Checker W Cost Checker W Cost Checker W Lab Technician W ■ Lab Technician w Supply Clerk w Supply Clerk w Clerk w Section Man w ?! it w tt It w tt it w it It w 1! it w It it w II it w It it w It It w I! It w If (f B it I! w t! II w it it w ?! n w it it w tt it w It It w it II w it it w 1! tt w If It w it ii w it It w 1! It w it It w tl It w II It w I! It w It tt w tt it w ii it w It tt w tt tt w it tt w It 11 Sex F F F F F F M M F M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M Original Hire 9-3-74 9-9-64 3- 27-63 8- 29-554— 26—61 3-5-73 9- 11-59 10- 19-64 10-3-75 6-16-75 8-16-42 6- 11-71 5-14-73 10- 12-53 8-24-64 1- 25-67 11- 12-59 5-26-53 11-4-58 11-30-52 7- 10-69 5-21-51 2- 28-72 7- 23-57 8- 11-49 8- 29-68 10- 4-63 9- 11-72 5- 29-73 2-13-63 4-5-45 6- 29-62 2- 9-59 11- 1-58 6- 15-63 8-21-62 8-10-63 10-28-69 7- 7-75 6-28-48 8- 26-58 10- 30-61 9- 1^50 12- 10-45 3- 5-47 8-20-58 Department Office Office Office Office Office Office Office Office Office Plant #1 Plant #1 Plant tf1 Plant f f l Plant #1 Plant rfl Plant ;7l Plant If1 Plant //I Plant #1 Nub Unit Plant #1 Plant ff2 Plant #2 Plant //2 Plant #2 Plant #2 Plant £2 Plant #2 Plant #2 Plant if2 Plant if2 Plant if2 Plant #2 Plant if2 Plant //2 Plant if2 Plant {f2 Plant #2 Plant #2 Turbo Turbo Turbo Turbo Turbo Turbo Turbo IV. (Cont'd) Name Sex Race David Kincaid M W Raymond Oaborne M w Robert Linebergar M w (A. C. Sherrill M B Robert Ingle M w Glenn Smith M w Kenneth Garrison M . w James Caldwell M w Harlen Clemmer M w John Hoffman M w Edward Faulkner M w James Reagan M w Clifton Sherrill M w Jacob Faulkner M w James A. Bradshaw M w Theodors Powell M w Larry D. Haney M w Blair 3. Bynum M w James Hamilton M w Charles Handsel M w Billy J. Rawing M w James D. Devine M w Ervin S. Brafford M w Robert Miller M w Marshall Wilkinson M w Bobby K. Abernathy M w Tony R. Stilwell M w Paul R. Conner M w Lloyd Brown M w Joseph Rudisill M w Randy D. King M w Miles Abernathy M w Carl Brown M w Claude Kirkland M w Casper Spargo M w Murray E„ McGinnis M w Ralph Hoffman M w Vincson Howard M w John D. Gilbert M w Charles Friday M w Neil A. Rhyne M u Fredrick >bore M w Robert Wilkinson M w J. D. Garrison M w Thad 3a Hard M V William J. Seay M w Daniel W. Rankin M w Job Title Original Hire Section Man 1-1-4.3 it ti 7-12-55 If . If 3-26-48 it ii 2-14-63 ii ii 5-31-48 it ii 2-6-61 it it 11-24-49 !t It 10-7-48 It It 2-19-59 it it 7-9-35 It It 4-5-55 it ii 11-9-63 n ii 1-5-48 It If 11-17-60 Hum. & Refrigeration 3-19-47 n it 2-25-48 ii it 10-27-69 Temporary Machinist 4-12-76 Hum. & Refrigeration 5-12-75 Electrician 3-28-56 it 6-6-63 Machinist 3-3-59 ii 7-17-64 it 10-23-68 It 8-3-59 It 1-21-55 Hum. & Refrigeration 9-11-72 Carpenter 6-16-47 Auto Coner Fixer 7-1-40 it ii ii 12-29-51 it it it 4-3-75 0verhaul9r 11-3-47 It 8-12-43 It 1-3-48 Card Grinder 3-5-37 Auto Coner Fixer 6-2-52 Overhauler 8-9-48 ii 5-23-63 It 8-11-53 Card Grinder 12-5-54 Overhauler 5-2-47 ft 1-5-48 It 5-22-50 It 10-4-46 Auto Coner Fixer 8-28-56 Production Trainee 5-20-76 Production Trainee 6-1-76 Department Turbo Turbo Turbo Plant #1 Turbo Turbo Turbo Turbo Turbo Turbo Turbo Turbo Turbo Turbo Shop Shop Shop Shop Shop Shop Shop Shop Shop Shop Shop Shop Shop Shop Plant if2 Plant if2 Plant if2 Plant #2 Plant if2 Plant #2 Plant #2 Plant if2 Plant #1 Plant if 1 Plant //1 Plant Hi Turbo Turbo Turbo Turbo Turbo Turbo Plant #1 o (5) 9 v . Name List of Supervisory, Clerical, Office and Maintenance employees terminated, demoted or transferred from the Stanley Plants during the six months end_ng June 30, 1977 Frank Auten Gla Hoyle Jerry Loftin William Howie William Howie 0 Sex Race Job Title M W Foreman F W Payroll Supervisor M W Section Man M W 10-3 Twister Fixer M w 10-B Twister Fixer Original Hire Date 8- 15-49 1-1-44 9- 24-62 1-17-77 5-2-77 Department Plant #2 Office Turbo Turbo Turbo VI, List of New Hires during six months ending Juno 30, 1977a Name Sex Race Prig. Hire Date Plant Shift Fannie Mae Drum F W Patricia 3, Harris F W Pink R, Wooten M w Eugene D. Pressley M w Gerry Donald Mils M w •Sharron L. McCorkle F 3 Deborah Tate Craig F w Jeffrey M. HuffsticklerM w William P, Howie M w James A, Stiltner M w Virginia L, Johnson F w Patricia Q. Dills F w Jerry W, Loftin M w Jack Weaver M w Charles H, Haynes M w Brenda Gail Roberts p w Robert Edward Phillips M w Michael Russel Abernathy M w Karen L. Lovingood F w David M. Fletcher M w David Eugene Payne M w William Ray Hudson M w Alfred C, Crawford M w Brenda Darlene Middleton F w Carolyn R0 Khweis F w Calvin D, Jone3 M w William Jerry Pennell M w Walter 3, Weaver M w Rickey Dean Payne M w 1-3-77 Turbo 2nd 1-3-77 Turbo 3rd 1-12-77 Plant ^1 3rd 1-10-77 Plant #2 2nd 1-10-77 Turbo 3rd 1-10-77 Turbo 3rd 1-10-77 Turbo 3rd 1-17-77 Plant #1 2nd 1-17-77 Turbo 1st 1-19-77 Turbo 3rd 1-17-77 Turbo 3rd 1-17-77 Turbo 3rd 1-26-77 Plant ?f2 3rd 1-27-77 Turbo 2nd 1-31-77 Turbo 3rd 1-31-77 Turbo 3rd 2-1-77 H & S 1st 2-7-77 Plant #2 3rd 2-8-77 Turbo 2nd 2-9-77 Turbo 2nd 2-22-77 Plant ;fl 3rd 2-14-77 Plant #2 3rd 2-14-77 Plant #2 3rd 2-21-77 Plant #2 3rd 2-24-77 Turbo 3rd 2-28-77 Turbo 2nd 2-23-77 Turbo 2nd 3-2-77 Turbo 2nd 2-2S-77 H & S 2nd Job Title Roto Coner Operator Skein Winder Operator Yarn Service U. S, Oil & Tape/ Service Man Roving Tender Skein Winder Operator Skein Winder Operator Spinning Doffer Fixer Roving Tender Skein Winder Operator Skein Winder Operator Spinning Doffer Pin Drafter Operator Yarn Service/Steamer Skein Winder Operator Laborer Yarn Service Stock Changer Roving Tender Spinning Doffer Spinning Doffer Utility Man Spinner Spinner R/C Yarn Service Spinning Doffer Roving Hauler Laborer (6) 0u VI. (Cont'd.) Name Sex Race Leon M. Terry, II M W Tony Raymond Caudle M W Bobby Ray Tate M w Patricia S. Abernathy F w Carloa Nickey Jenkins M w Rodney C0 Self M w A. C. Sherrill M 3 Eddie Wayne Brown M W Lester Lee Crawford M W Teresa R. Samuels F W William R. Rikard, II M W Opal A. Woody F w Ryan E. Bowman M w Sara Linda Chastain F w David J. Speas M w Frances Christopher F w J. Scott Weaver M w John W. Barden M w Melvin G. Walker, Jr0 M w Ben Jr. Steele M w Verna Lea Stines V w Hunter A. Black M w Freddie Kirkland M w William G. Hill M w Peter Christoph Smith M w Rene Crawford F w Charner Greer M w Nancy W. Bradshaw F w Mark D. McMahan M w Dennis J. Stines M w Brenda D0 Faulkner F w Doris Catherine Fleming F w Nettie Curtis Tedder F w Jerry Thomas Quilliams M w Hattie 0o Powell F w Reginal W. Green M w David C. Howard M w Willard Johnson M w Orig. Hire Date Plant 3-14-77 Plant #2 3-15-77 Plant #2 3-14-77 Turbo 3-14-77 Office 3-21-77 Plant r/2 3-22-77 Turbo 3-28-77 Plant rrl 3-31-77 Plant -rl 4-30-77 Plant #2 4-1-77 Turbo 3-28-77 Turbo 3-30-77 Turbo 3-31-77 Turbo 3-31-77 Turbo 3-28-77 Turbo 4-4-77 Plant #1 4-6-77 Plant #2 4-6-77 Plant ?f2 4-5-77 Plant 2 4-4-77 Plant #2 4-6-77 Turbo 4-14-77 Plant #2 4-12-77 Plant #2 4-12-77 Plant #2 4-14-77 Plant r/2 4-13-77 Plant #2 4-14-77 Plant //I 4-12-77 Plant //I 4-12-77 Turbo 4-15-77 Turbo 4-12-77 Turbo 4-12-77 Turbo 4-13-77 Turbo■ 4-13-77 H A S 4-13-77 Plant #1 4-19-77 Plant #1 4-13-77 Plant r/2 4-19-77 Plant fr'2 Shift Job Title 2nd Card Room Utility Man Downstairs 3rd A/C Yarn Service 2nd R/C Yarn Service 1st Payroll Production Clerk 3rd Card Room Utility Man Upstairs 2nd Roving Tender 3rd Section Man Trainee 2nd Draw Tender 3rd Utility Man - Downstairs 2nd Skein Winder Operator 2nd Rovinvg Hauler 2nd Skein Winder Operator 2nd Roving Hauler 3rd Skein Winder Operator 3rd Can Pusher/Sweeper 2nd Roto Coner Operator 2nd Card Tender - 4 Hr. 2nd Card Tender - 4 Hr. 3rd Utility Man 3rd Card Tender - Downstairs 3rd Reel Tender 1st Overhauler 3rd Lap Hauler Picker Tender3rd 3rd Yarn Service 3rd Spinner 2nd Card Tender 3rd Roto Coner Operator 2nd Yarn Man 3rd Can Pusher/Sweeper 3rd Skein Winder Operator 3rd Skein Winder Operator 3rd Skein Winder Operator 1st Laborer 1st P./C Operator 2nd Spinning Coffer 2nd Lap Hauler 3rd Picker Tender (7) VI. (Cont'd.) Name Sex Race Origo Hire Date Plant Shift Job Title Hazel Joyce Parnell F W 4.-19-77 Plant #2 3rd Roto Coner Operator Paul Leon Pressley M w 4.-20-77 Plant ;?2 3rd Spinning Doffer Bill Andrew Biggerstaff M w 4-18-77 Turbo 2nd Roving Tender Roger Dale Harr M w 4-28-77 Plant j£L 3rd Spinning Doffer Christine Elizabeth Simmons F W 4-25-77 Plant #1 3rd Roto Coner Operator -l^enjamin Davis M B 4-26-77 Plant #2 3rd Spinning Doffer Bruce Parker M w 4-25-77 Turbo 2nd Roving Tender Velma B. Rose F w 4-29-77 Turbo 3rd Skein Winder Operator Roger Lee Brooks M w 4-27-77 Turbo 3rd Spinning Doffer Eva Rebecca Mason F w 4-26-77 Turbo 3rd Skein Winder Operator Bobby Go Cook M w 4-25-77 H & S 1st Laborer Randy D0 Cook M w 5-4-77 Plant fifl 3rd Roving Hauler Mark L, Barden M w 5-3-77 Plant #1 3rd Yarn Service Ida Nadine Osborne F w 5-2-77 Plant #2 2nd Spinner Timothy N. Terry M w 4-26-77 Plant #2 2nd Roving Hauler Lucille Co Hester F w 5-4-77 . Plant #2 3rd Roto Coner Operator William Po Howie M w 5-2-77 Turbo 1st 10-B Twister Overhauls ^Shirley Matie Hill F B 5-6-77 Turbo 3rd Auto Coner Operator Mary Cheryl Cox F w 5-4-77 Turbo 3rd Spinner Patricia S. Jones F w 5-4-77 Turbo 3rd Spinner Mary Elizabeth Carter ? w 5-4-77 Turbo 3rd Reel Tender Wanda Yvonne Crawford F w 5-2-77 Turbo 3rd Skein Winder Operator Judy Ann Mills F w 5-2-77 Turbo 3rd Reel Tender Dennis Howard Eldridge M w 5-9-77 Plant #‘2 1st Overhauler Guynelle Susie Phillips F w ■ 5-9-77 Plant //2 3rd Roto Coner Operator Edith F. Baker F w 5-9-77 Turbo 2nd Skein Winder Operator •T̂ Sloise Thompson F B 5-9-77 Turbo 3rd Skein Winder Operator ' Willie Cox * M W 5-9-77 Turbo 3rd Spinning Doffer Floyd Jo Anderson M w 5-17-77 Plant //l 2nd Draw Tender Larry Da Isaacs M w 5-16-77 Plant #1 2nd Yarn Service James L„ Thompson M B 5-16-77 Plant #1 2nd Draw Tender David Van Randy Hawkins M W 5-17-77 Plant #2 3rd Utility M m Dennis E« Davis M B 5-16-77 Plant #2 3rd Lap Hauler Consuelo Vs Griffin F Sp. 5-20-77 Turbo 2nd Skein ’Winder Operator Debra P. Cameron F w 5-19-77 Turbo 2nd Skein Winder Operator David Wo Fields M w 5-16-77 Turbo 2nd Roving Tender Patricia Ann Roberts F w 5-19-77 Turbo 3rd Rel-Set Tender Marvin Edward Roberts M w 5-19-77 Turbo 3rd Can Pusher/Sweeper Iva L« Cuthbert F w 5-16-77 Turbo 3rd Skein Winder Operator Alice Teresa Hord F w 5-16-77 T\irbo 3rd Skein 'Winder Operator Judy So Cochran F w 5-18-77 Turbo 3rd Skein Winder Operator David Thomas Caughron M w 5-25-77 Plant #1 3rd Spinning Doffer Jeanette Nolen Carver F w 5-25-77 Plant #1 3rd Spinner Barbara Ann McLemore F w 5-24-77 Plant #1 3rd Roto Coner Operator (8) i.4 • \ ■ J VI. (Cont'd.) Name Sex Race Origo Hire Date Plant Shift Job Title Timothy W. Wooten M W 5-2A-77 Plant #2 2nd Spinning Doffer Teresa Louise Watson F W 5-26-77 Plant #2 3rd Roto Coner Operator Madeline C, Brewster F W 5-27-77 Turbo 2nd Reel Tender Earhara Dianne Navey F W 5-2A-77 Turbo 2nd Roto Coner Operator Veronica Lee Btters F W 5-23-77 Turbo 3rd Skein Winder Operator Lester 0. West M w 5-30-77 Plant #1 3rd Yarn Man 9̂ Sharon Kay Floyd F B 5-31-77 Plant #1 3rd Roto Coner Operator Eddie Wayne Broun M W 6-1-77 Plant it2 2nd Spinning Doffer Steven Clayton Dellinger * M w 6-3-77 Plant #2 3rd Utility Man - Cards Marjorie G. Rogers F w 6-3-77 Plant #1 3rd Spinner - Spare •^.Carmen Ea Lynch F B 5-31-77 Plant #2 3rd Roto Coner Operator Mary Lou Osborne F w 5-31-77 Turbo 2nd Skein Winder Operator Ernest H. Featherstone, Jr0- M w 6-1-77 Turbo 2nd Roving Hauler Wayne Hanroton Roberts M w 6-2-77 Turbo 3rd Steamer/Yarn Service Kathie L. Boothe F w 5-31-77 Turbo 3rd Skein Winder Operator Mildred S. Schied DavisF w 5-30-77 Turbo 3rd Skein Winder Operator Clifford Surratt M B 6-2-77 Plant #2 3rd Card Tender Blair 3a Bynum M w 6-3-77 Shop 1st Machinist Cynthia Iris Ibore F w 6-9-77 Plant #1 2nd Spinner Michael David Pickel M w 6-10-77 Plant #1 3rd Card Tender Barbara Freeman McAlister F ■ w 6-6-77 Plant #1 3rd Roto Coner Operator William Randy McCoig M w 6-10-77 Plant #1 3rd Spinning Doffer Gerald E« Sellers M w 6-7-77 Plant #1 3rd Spinning Doffer Sheila Da Gardner F w 6-6-77 Plant ;f2 3rd Roto Coner Operator Boyce Edward Whitworth M w 6-7-77 Plant #2 3rd Lap Hauler Johnny Leonard Faulkner - M w 6-9-77 Turbo 2nd Yarn Man ^ Cathern L. Adams F B 6-6-77 Turbo 3rd Spinner Christine D„ Hawkins F W 6-13-77 Plant #1 3rd Abbott Winder Tender Sandra H. Walker F w 6-13-77 Plant #2 2nd Roto Coner Operator Patrick E. Johnson. Jr0 M w 6-13-77 Plant #2 3rd Lap Hauler Donald R. Crisp M w 6-13-77 Plant #2 • 3rd Utility Man Erenda J« Brown F w 6-15-77 Turbo 2nd Roto Coner Operator Douglas Fa Davis M w 6-17-77 Turbo 3rd Auto Coner Yarn Man Margaret Ca Lutz F w 6-13-77 Turbo 3rd Skein Winder Operator John David Carver M w 6-20-77 Plant #1 3rd Draw Tender William N» Luckey, JroM B 6-20-77 Plant if2 2nd Lap Hauler - U Hr. Joe Marion McClure M W 6-20-77 Plant fr2 3rd Yarn Service John W0 Godsey, Jr„ M w 6-20-77 Turbo 2nd Auto Coner Service Mar Ronald Dale CoDe M w 6-20-77 Turbo 3rd Draw Tender Clarence S» Howell M w 6-20-77 Turbo 3rd Yarn Service/Steamer Terri A, Nantz F w 6-20-77 Turbo 3rd Auto Coner Operator Barbara J0 Dawkins F w 6-23-77 Turbo 3rd Skein Winder Operator Leona Marie Lay F w 6-22-77 Turbo 3rd Skein Winder Operator Jo Ann McClure F w 6-22-77 Turbo 3rd Roto Coner Operator o (9) VII. Racial Composition of Production and Warehouse Employees by Plant. PLANT £1 - CARDING DEPARTMENT Name Race Seniority Date Hall K. Dellinger White 12-1-42 Sylvanus L. Hawkins White 9-12-49 Harrison >1. Johnson ■ White 11-3-52 Avery C. Kennedy White 11-30-52 Clarence Lee Putnam White 4-1-54 Charles L. Friday White 12-5-54 Dennis W. Fincannon White 5-30-56 Jack R. Ward White 5-26-53 Artie Craig Hawn White 11-4-53 Jack Thomas Hamrick White 5-12-59 John W. Warlick White 11-12-59 Terry Lee Summey White 7-10-69 Thurman T„ Hoke White 1-20-50 William Clyde McClain Black 10-16-72 George S„ Lawrence Black 1-1-44 RalDh Robin Rogers White 5-14-74 Billy D. Oates White 9-16-74 V/a Iter L. Smith White 8-28-74 Lewis G. Hawkins White 6-23-75 Neal Wilson McCarver White 9-18-75 Phillip D„ Lutz White 11-7-75 Donald Lee Williams White 4-20-76 Claude T« Phillips White 6-16-75 Kenneth W. Hawn White 6-14-76 Ralph Lawrence Rogers White 7-12-76 Edwin Ja Crisp White 5-19-76 Stephen R. Norris White 7-11-74 David M. Fletcher White 2-9-77 James Gibley White 10-1-73 Gene D. Leagon White 9-7-76 Jeffrey D« Etchison White 11-11-75 Ronald D„ Cone White 6-20-77 A. C. Sherrill Black 2-14-68 Michael Pickel White 6-10-77 Jeffrey Rickman White ‘ 7-19-76 Lloyd D. Slifer White 5-29-75 William Hagar White 6-14-76 James Nichols White 8-22-75 Floyd Anderson White 5-17-77 Alonzo D0 Hicks White 9-13-76 Billy Dellinger White 6-29-77 Charner Greer White 4-14-77 VII. (Cont'd.) Mozelle W0 Watts Elonnie W. Terry Ottie Idelle Spargo Iva Lee H. Ballard James M. Pressley Audrey Lee Abernathy Pansy Wood Warlick Pauline H. Oates Norma R. Johnson James Welch Helen F« Smith R. A„ Robinson, Jr0 Jonas Reed Perkins Virginia Gabriel Porter Virginia P® Adams Alice E. Saunders Eva E. Banda Bonnie G. Garner Willa M. McKinnish Maggie Mason Brown Agnes Reel Ballard Rachel Marie Soles Donald R. Whitley Patricia Ann Ramey Hubert Stroupe Ella Mae Sigmon Imogene R. Cornell Leato Jean Heffner Willie Mae Propst Estelle Long Billy Bryson Marylene D0 'Wooten Cynthia Renee King Elizabeth D. Osborne Virgie C0 Woody Willie Joe McLenore Brenda D0 Middleton Jeanette Nolen Carver Emma Lee Jones Max D. Smith Mary D„ Wilkinson Lucille M. Dellinger Cynthia I. Jfoore Gerald E0 Sellers John D. Carver Ted L. Smith Stella M. Kinley . Randy D. Cook Edward S. Bryson PLANT £L - SPINNING DEPARTMENT Name Race Seniority Date ’White 6-1-17 White 11-1-4-2 White 3-1-43 White 5-12-43 White 5-12-43 White 7-22-44 White 3-21-48 White 4-9-51 White 4-14-51 White 12-29-43 White 2-1-43 White 10-12-53 White 2-5-62 White 6-21-62 White 7-16-59 White 5-13-63 White 8-23-63 White 9-16-64 White 11-16-64 Black 12-13-65 White 7-26-67 White 8-7-67 White 1-25-67 White 3-22-73 White 8—24—64 White 4-30-74 White 5-22-74 White 5-27-74 White 7-8-75 White 8-26-59 White 4-30-75 White 4-7-76 White 8-30-76 White 11-7-73 White 6-l6—69 White 11-30-76 White 2-21-77 White 5-25-77 White 9-10-63 White 5-30-51 White 2-14-72 White 5-31-62 White 6-9-77 White 6-7-77 White 6-20-77 White 7-8-75 White 11-21-55 White 5-4-77 White 11-8-76 VII. (Cont'd.) PLANT £l - WINDING DEPARTMENT Name Lucille W, Poteat Janie Nc Johnson Lois Hovis Caldwell Nora M. Homesley Lathan E. Hovis Odessa Graham Virginia C« Heavner Emma Lou Helms Ralph Jo McConnell Murray E. McGinnis Josephine P„ Armstrong Sarah Perkins Coy R0 Woody Danny L» Helderman Martha Jane Rhyne Steve W0 Marria Wilma Davis Eury Joyce E0 Waters James D0 Rhyne Helen Hicks Francenia E. Lynch Angela Go Bryson Doris N. Handsel Dorothy H. Vorris Daisy Floyd Vicky Poovey Christine D. Hawkins Bobby Lo Me Knight Sheila Lynch Larry Dn Isaacs Jeff Halffstickler Lester 0o West Barbara F« McAlister Mary 0o Williams Mark L, Barden Wanda Crawford Race Seniority Date White 2-1-41 White 5-20-41 White 6-14-4-3 White 2-1-46 White 8-16-42 White 6-18-53 White 5-21-58 White 9-2-58 White 5-12-58 White 6-2-52 White 8-2-71 White 3-17-72 White 6-11-71 White 5-1-73 White 11-19-73 White 5-14-73 White 9-4-73 White 5-23-74 White 11-21-73 White 7-28-75 Black 9-10-75 White 4-5-76 White 7-30-70 White 3-13-53 Black 12-13-65 White 7-26-76 Whits 3-11-76 Black 4-15-75 Black 3-16-76 White 5-16-77 White 1-7-77 White 5-30-77 ’White 6-6-77 White 9-21-72 White 5-3-77 White 5-2-77 (12) VII. (Cont'd.) PLANT #1 - GENERAL Name Race Seniority Date Ralph Wo Hoffman White 8-9-A8 Vinscon E. Howard White 5-23-63 John David Gilbert White 8-11-58 Eloiae R» Pruett White 9-15-75 (13) PLANT it2 - CARDING DEPARTMENT Name Casper Spargo Frank Lee Lewis John Do Sisk Leroy C0 West Ivie Lee Nantz Albert Reid Perkins Marcella G. Banda Lat Lawing Harold R« Helms Ernest F0 Shuford Miles Calvin Luckey Johnny F0 Queen Samuel M0 Hawkins William No Luckey Johnnie Lewis Williams Elie Roosevelt Anderson Seth Wesley Hamrick John David Mills Sherman Lee Shelton Gary M0 King Lawrence B, Lewis Kenneth L0 Luckey James E, Poplin Tony Ray Hilton James W, Mauney Adrian Sylvester Friday Jeffrey Surratt Kenneth Rogers Gary Lee Rushing Donald Lee Phillips William M. Rickard Mike Kirkland Helen Rudisill Joseph Ho Rogers William Lee McKinnish Royce Dean Hart Micah Jo Hull Robert Homesley Ronnie J. Hall Timothy Lewis Rushing Leon Mo Terry, II Ben Jr» Steele John ’Jo Barden Hunter A. Black David Co Howard Willard Johnson Steve A. Brown VII. (Cont'd.) Race Seniority Date White 3-5-37 White 11-1-4.8 White 8-11-4.9 White 1-10-4.8 White 8-4-53 White • 7-23-57 White 9-3-62 White 6-14-62 White 6-15-63 White 10-4-63 Black White S-25-65 White 6-3-67 Black 5-21-51 White 3-27-68 Black ■ 9-28-71 White 1-31-72 White 2-28-72 White 4-3-72 White 6-15-72 White 1-25-73 Black 12-19-55 White 7-12-67 White 9-26-73 White 12-11-73 Black 5-20-74 Black 6-25-74 White 5-29-73 White 9-17-74 White 10-17-74 White 5-5-75 White 3-17-75 White 10-9-75 White 10-8-74 White 12-31-75 White 2-2-76 White 2-24-75 White 7-7-75 White 9-17-75 White 12-27-76 White 3-14-77 White 4-4-77 White 4-6-77 White 4-14-77 White 4-18-77 White 4-19-77 White 4-26-76 ( U ) PLANT £2 - CARDING DEPARTMENT. (Cont'd Name Donald S0 Reagan Alta C„ Brackett Ivey A0 McCorkle Donald R.' Crisp Patrick Johnson, Jr0 Carl E. Goodman William N. Luckey, Jr0 Clifford Surratt James H. Steele Eduard Lynn Carpenter VII. (Cont'd.) Race Seniority Date White 8-30-76 White 10-7-74- Black 12-9-74. White 6-13-77 White 6-13-77 White 6-27-77 Black 6-20-77 Black 6-3-77 White 8-29-68 White 1-5-76 (15) 3 VII. (Cont'do) Mildred E. Helton Isabelle C„ Hovis Pauline H. Williamson Eunice P. Phillips Helen C„ Ingle Ruth Gunter Case Pauline H. Brown Louise Mo Kirkland Ernest C. Kinley Lois A0 Summey Grace W0 Kennedy Handy H0 Homesley Jack Hull Selwyn B» Perkins Mildred A. Carpenter Helen F, Kirkland Grover West Bertha W, Hefner Ruth So Caldwell Margaret Kate Tallent Margie Nantz Ballard Walter Pinkney Keever Ronald C0 Smith Betty Jean Richard Lester Kendall Auten Herman J. Keever Richard T. Payne Audrey Pressley Wanda L. Johnson Naomi Cynthia Rayfield Charles M, Satterfield, III Lewis Jerry Bowen Nelda F. Rushing Wilma 0, Rick Delia Faye Fortenberry Junie Bates Geraldine M, Bumgarner Nancy Scott Ruby Mo Brown Barbara McLean Frances Ln Smith Orren Coy Soles Forrest E» Rogers Tommy Dean Wooten Jo Ann Harrison PLANT £2 - SPINNING DEPARTMENT Name Race Seniority Date White 9-1-42 White 9-1-42 White 7-1-43 White 6-30-49 White 3-24.-50 White 4—2—43 White 8-1-44- White 5-23-51 White 3-25-43 White 4-16-53 White 7-6-53 White 7-7-53 White 8-10-53 White 7-13-54 White 10-7-55 White 10-21-51 White 8-5-57 White 12-15-52 White 11-23-54 White 6-15-59 White 8-10-59 White 10-10-57 White 1-1-62 White 7-17-50 White 6-6-62 White 7-14-62 White 8-21-62 White 11-19-62 White 3-28-63 White 11-6-64 White 2-13-63 White 7-10-67 White 7-19-67 White 9-25-67 White 3-3-67 White 9-19-47 White 9-4-67 White 6-9-69 White 6-15-70 Black 7-6-70 White 3-3-66 White 9-11-72 White 5-29-73 White 12-18-73 White 1-1-74 Q (16) VII. (Cont'd.) Susie Grahl Cherry Virgil Lee Griffin John E. Wooten Anita G. Morrison Mary M. Bowen Ricky Do Ervin Rebecca 0o Morrison Ruby Lee Tallent Betty Go Cannon Phyllis It, Hamrick Cynthia A. Bumgarner Lewis Bo Bowen, Jr. Evelyn L0 Wooten Jill A* Byers Terry M. Brown Geraldine B0 Helton Grover West, Jr0 Renee Crawford Benjamin Davis Stella Po Stafford Zelma S. Bingham Mary Lou Jenkins Billy R. Morrison Carolyn Wilson Linda K. Armstrong Lee Roy Steele Lester Lee Crawford Harold Williams Tony A„ Jones Jerry J. Crawford Timothy N. Terry Wanda Lo Huss Eddie W. Brown PLANT £2 - SPINNING DEPARTMENT. (Cont'd.) Name Race Seniority Date White 4-29-74. White 5-21-74 White 5-27-75 White 10-29-74 White 6-4-73 White 3-13-76 White 11-30-70 White 5-10-76 White 5-12-76 White 6-1-76 White 7-27-76 White 10-3-73 White 6-2-75 White 12-13-76 White 12-20-76 White 6-10-75 White 10-11-76 Whit e 4-13-77 Black 4-26-77 White 12-31-75 White 12-3-73 White 9-16-76 White 1-18-71 Black 9-11-74 White 9-9-75 White 4-26-76 White 3-30-77 White 11-3-76 White 8-30-76 V/hite 8-6-76 V/hite 4-26-77 White 9-30-75 ’White 6-1-77 VII. (Cont'd.) PLANT £2 - WINDING DEPARTMENT Name Florence W. Derr Willie Bates Zelma Merle Bently Lonia Inez Welch. LLoyd Brown Ruby Mo Hovis • Paul D. Hovis Jack Schronce Mary 3. Keener Grady L0 Helms Julia Abernathy Novella Haney Sisk Madeline N0 Fox Sherman Vickers Betty Go Oates Robert G. Abernathy ' Joseph So Rudisill Floyd Bo Stone Christine S0 Watts Mildred E« Keever Daniel S. Armstrong Helen L. Shields Minnie McConnell Jewell T. Ottinger Faye R. Clippard Eulene Wilkinson Lena 3, Jones Mary 3, Wall Lois Musselwhite Yvonne Keever Ellie Smith Charles M0 Satterfield Gail Warlick King Geneva Ho Owens Lester E, Lowe Donald Wayne Hill Esta 3. Hawkins Dorothy Heal Tilley Mary Lou Robinson Randy D. King Mary Ruth Dellinger Ann Gold Ballard Alma E. Homesley Linda L. Griffin Race Seniority Date White 7-1-19 White 3-1-42 White 6-1-42 White 4-1-46 White 7-1-40 White 5-25-45 ’White 7-1-42 White 4-5-45 White 6-22-53 White 5-25-54 White 2-10-55 White 6-21-56 White 6-2-57 White 3-2-59 White 6-6-59 White 4-7-60 White 12-29-51 White 3-22-54 White 12-2-61 White 6-25-62 White 6-29-62 White 7-20-62 White 7-20-62 White 5-7-62 White 3-19-63 White 9-3-62 White 8-6-62 White 8-30-65 White 10-20-65 White 5-9-62 White 5-3-63 ’//bite 2-9-59 White 9-1-72 White 8-13-73 White 2-22-73 White 7-24-72 White 8-11-71 White 11-18-74 White 6-10-74 White 4-3-75 White 6-27-75 White 8-4-75 White 9-2-75 White 3-6-73 (18) VII. (Cont'd.) PLANT £2 - WINDING DEPARTMENT. (Cont'd.) Name Bonnie M. Miller Raymond V/. Wooten Gena B„ Rikard Brenda F. 1-forriaon Elizabeth B. Helms Janice M. West Thomas D. Black Rosetta B. Leatherman Carl Edvard Smith Tony Raymond Candle Sheila D. Gardner Sandra H. Walker Joe tor ion McClure James R. Handsel, Jr0 Terryl 3. Nantz Verna L. Stines Teresa L« Watson Peter C. Smith Kenneth H. Scarboro Lucille C. Hester Bonnie L. Srout Race Seniority White 4-24-60 White 3-17-76 White 5-25-76 White 5-25-76 White 7-26-76 White 11-18-76 White 9-8-76 White 2-15-63 White 7-15-75 • White 3-15-77 White 6-6-77 White 6-13-77 White 6-20-77 White 6-14-76 White 5-14-74 White 4-6-77 White 5-26-77 White 4-14-77 White 4-29-74 White 5-4-77 White 5-5-76 Date VTI. (Cont'd.) PLANT “2 - GENERAL N3E0 Miles E» Abernathy Carl Brown Claude J. Kirkland Henry E0 Turner Dennis H« Eldridge Race Seniority White 11-3-47 White 8-12-48 White 1-8-43 White 12-5-73 White 5-9-77 Date (20) VTT. (Cont’cL) turbo - CARDING DEPARTMENT Name Clifton Sherrill Harvey B„ Dills Charlie E. Grigs Neil A. Rhyne John S. Hoffman James C0 Caldwell Eduard Jo Faulkner Jacob Arnold Faulkner Jesse B. Mills Loy H« Fortenberry Karlen Lo Clemmer James Edward Estes James Edward Reagan Troy Gardner Sarah Lindsay Lewis Dorothy Rice Lloyd A. O'Donoghue David M. Blakely Douglas F. Parker Shawn P. Graska James E, Rose Logan Wo Nantz Frank Do Howell Michael D. Hayes Eetty S. Weaver Todd Lee Smith Gerry Do Mills Kyle F0 Howell Terry Lee Hill Rosa Lee Reagan Bruce Parker David Wo Fields Marvin So Roberts Billy C. Steele William C. Hill J. D. Garrison Dari Go Hord Clarence S0 Howell John H. Hicks Kenneth B. Garrison Richard A. Justice John Ho Petty Race Seniority Date White 1-5-48 White 12-14-51 White 8-13-51 White 5-2-47 White 7-9-35 White 10-7-48 White 4-5-55 . White 11-17-60 White 11-25-63 White 11-29-63 White 2-19-59 White 8-28-61 White 11-9-68 Black 8-15-66 Black 4-10-72 White 4-12-71 White 3-29-73 White 10-10-73 White 2-12-74 White 12-26-73 White 10-7-75 White 3-2-49 White 11-17-75 White 1-1-76 White 3-11-76 White 12-1-76 White 1-10-77 White 7-16-74 White 5-18-73 White 12-11-72 White 4-25-77 White 5-16-77 White 5-19-77 White 10-4-76 White 5-8-75 White 10-4-46 White 8-9-76 White 6-20-77 White 4-17-74 White 11-24-49 White 7-30-74 White 10-22-73 (21)o VII. (Cont’d.) TURBO - SPINNING PEP ARTIST? Name Grace Wilson Pearl D. Helms Stella Mae Kirkland Robert N. Lineberger Oklamae Reel Made B. Wilkinson Gwendolyn Helms Martha B„ Conner Laura C0 Bowen Edith 0o Schronce Phillips Helen L. Mauney liable Ruth Fisher Mary H. Cannon Alva H. Walker Cora A. Sherrill Genevieve H. Moore Irene E. Rudisill Raymond Osborne Ruth Palmer Lineberger Lillie Mae Herron Mae 3ell Glenn Glenn F„ Smith Frank J. Perkins Margaret Smith Johnson Allen Frank Morrison Ronnie D. Bynum Marvin R. Ray Betty Saunders Stroupe Odell Edward Hester Robbie A. W. Lawing Azzalee R. Oliver Joyce Brewster Lucille ?. Burch Aline L. Clemmer Nancy Lo McMahan Ginger H. McPherson Patricia Ann Ward Betty W0 Keeter Betty Sue Howell Jack So Fields Steve E0 Elders Ro Co Osborne Louise H. Osborne Mary K. Hart Race Seniority Date White 8-27-45 White 1-2-43 White 1-30-48 White 3-26-4S White 4-5-43 White 4-30-43 White 5-1-43 White 5-28-43 White 5-24-43 White 7-13-49 White 11-21-49 White 1-9-50 White 1-20-50 ’White 12-27-41 White 1-13-51 White 11-19-51 White 3-6-53 White 7-12-55 White 3-31-58 White 8-1-60 White 5-19-60 White 2-6-61 White 3-21-60 White 6-10-60 White 2-12-64 White 1-27-70 White 4-16-62 White 7-10-72 White 6-4-73 White 9-4-73 White 9-23-54 White 5-13-74 Black 5-24-74 White 7-23-74 White 9-25-74 White 10-2-75 White 11-18-75 White 8-14-74 White 6-8-73 White 5-12-76 White 6-8-76 White 6-21-76 White 5-19-66 White 12-13-76 o (22) TURBO - SPINNING DEPARTMENT. (Cont'd) VII. (Cont'd.) Name William R. Rikard, II Ryan E. Bowman Mary Cheryl Cox Patricia S. Jones Mary E. Carter Euabeay H. Hovia Lillie L. Hicka Ernest H. Featheratone, Jr0 Cathern L. Adams Johnny L0 Faulkner H. Wayne Gregory Claude Dean Phillips Patricia A. Roberta Harvey E. Blakely Stanley C. Rogers Willie Cox Ida N. Osborne David Jo Speas James B0 Rogers Eva R. Mason Brenda J. Brown Race Seniority White 3-23-77 White 3-31-77 White 5-4-77 White 5-4-77 White 5-4-77 White 2-12-53 White 6-17-76 White 6-1-77 Black 6-6-77 White 6-9-77 White 2-11-74 White 7-12-76 White 5-19-77 White 5-17-74 White 8-31-76 White 5-9-77 White 6-24-77 White 3-28-77 White 8-30-74 White 4-26-77 White 6-15-77 Date o (23) TURBO - WINDING DEPARTMENT VII. (Cont'd.) Name Race Seniority Date Lola M. Ballard Mildred K. Howard Ella M. McGinnis Theresa Joy Ancil P. Glenn Willie Mae Hovis Louise McG. Stephens Phyllis E. Cannon Beulah Webb Guerin Perry F. Shelton Doris E. Lowe Olin George Moore Ruth A. Cloninger Hall M. Morris Bertha F. McClure Gladys Lowe Beulah I. Homesley Jane C. Garrison Josephine L. Hooper Nell L. Sisk Clarence A. Smith Gladys E. Lawing Johnnie L. Ingle S'chsster S0 Faulkner Blanche 3. Dixon Martha H. Land Ruth Viola Faulkner Catherine A. Idol Billie K. Wilkinson Ethel B. Dellinger Faye C. Hendrix Ruby M. Waters James B„ Long James A. Crowder Curtis Allen Hubbard Vivian F. Abernathy Nell V. Elders Everett L0 Waters Becky Shelton Carrie H. Horne Judy Queen Cecil D. Abernathy Mamie L. Stone Jo Ann Nantz White 6-1-41 White 4-29-42 White 1-19-45 ■White 9-13-45 White 12-10-45 White 3-12-46 White 1-1-46 White 9-27-47 White 1-20-43 White 3-19-48 White 9-13-48 White 9-16-50 White 1-30-52 White 6-28-48 White 7-16-52 White 2-9-48 White 7-24-52 White 6-26-46 White 6-23-53 White 11-11-54 White 7-11-55 White 8-22-55 White 5-14-56 White 5-16-56 White 8-20-58 White 11-12-58 White 8-24-59 White 10-31-61 White 4-18-60 White 6-10-60 White 3-29-62 White 3-30-62 White 10-30-61 White 9-16-63 Whit e 8-26-58 White 11-15-65 White 3-7-66 White 3-9-64 White 8-10-67 White 11-6-67 White 11-20-67 White 3-8-67 White 3-8-62 White 7-9-68 o (24) TURBO - WINDING DEPARTMENT. (Cont’d.) VII. (Cont'd.) Name Race Seniority Date Ethel H. Hovis White 8-12-68 Lillian H. Sain White 10-3-68 Jackie W. Nantz White 12-2-68 Margie N. Smith White 2-14-69 Kenneth Long White 1-18-4.6 Bonnie B„ Hovia White 4-6-70 Eetty A. Spargo White 1-3-72 Shirley J. Adams White 3-20-72 Rose Eva Hall White 5-8-72 David W. Sisk White 3-22-55 Freda A. Cross White 7-24-72 Linda L. Aldridge White 7-24-72 Charles D. Hammack White 3-5-47 Dorothy M. McDowell Black 8-30-72 James A. Carpenter White 10-17-72 Virgil Cody, Jr. White 2-12-73 Frances R« Martin White 4-12-73 Virginia W. Quilliams White 5-17-73 Mary Jane Lewis Black 6-4-73 Lucy L. Lineherger White 8-23-73 Joyce D. Summey White 11-12-73 Dorothy W. Huffstetler White 11-17-73 Murline Hord White 1-23-74 Helen M. McDowell Black 4-22-74 Zona Lee Craig White 6-10-74 Vata A. Lawing White 7-10-74 Gary A. Smith White 8-13-74 Margaret L. Blattau White 8-26-74 Doris J. Ottinger White 11-18-74 Virginia H. Etters White 11-25-74 Brenda P. Cope White 1-20-75 Edna T. Hart White 5-13-75 Linda H. Bass White 5-15-75 Keith E. Kennedy White 6-25-75 Rhoda Stilwell Davis White 7-7-75 Joyce Faye Hicks White 7-8-75 Kim J. Hall White 7-9-75 Sandra W0 Medlin White 7-21-75 Patricia A. Smith White 8-4-75 Annie Darleen Hord White 9-9-75 Ruby A, Stines White 11-18-75 Betty G„ Haynes White 12-1-75 Sibyl B. Wingate Black 12-2-75 Paulette E. Brown Black 12-8-75 Rosemary Woodard White 12-16-75 Marcella Stone White 1-5-76 o (25) i ~ * VII. (Cont'd.) TURBO - WINDING DEPARTMENT. (Cont'd.) Name Race Seniority Date Do Hie Haney White 1-6-76 Thad H. Ballard White 8-28-56 Barbara J. McCorkle Black 6-6-66 Willard M. Grier Black 5-10-76 Mary G. Blackman White 5-26-76 Cecilia G. McCorkle Black 6-1-76 Rachel J. Ballenger White 3-15-60 Bessie Duane Harris White 7-13-76 Martha A. Cornett White 11-17-75 Pearl C0 Goins White 10-8-57 Della Mae Fields White 8-23-76 Lillie Mae Best White 10-31-61. Linda J. Honeycutt White 6-21-76 Vernell N. McLean 31ack 9-27-76 Susan R. Hudsoeth White 11-8-76 Alberta D. McLean Black 11-15-76 Patricia 3. Harris White 1-3-77 Sharron L. McCorkle Black 1-10-77 Virginia L. Johnson White 1-17-77 Charles H. Haynes White 1-31-77 Bobby Ray Tate White 3-H-77 Judy A. Jonas White 12-20-76 Opal A. Woody White 3-30-77 Brenda D. Faulkner White 4-12-77 Mark D. McMahan White 4-12-77 Nettie C. Teddar White 4-13-77 Velma B. Rose White 4-29-77 Judy Ann Mills White 5-2-77 Eloise Thompson Black 5-9-77 Edith F. Baker White 5-9-77 Ida M. Hamilton White 3-30-51 Barbara D. Navey White 5-24-77 Madeline C. Brewster White 5-27-77 Donald Stallings White 2-5-68 Melvin Walker, Jr. White 4-5-77 Douglas F. Davis White 6-17-77 John W. Godsey, Jr. White 6-20-77 Terri A. Nantz White 6-20-77 Jo Ann McClure White 6-22-77 Howard Chambers White 10-9-74 Mary C„ Bishop White 7-31-72 William G. Hill 'White 4-12-77 Glenda L. Johnson White 9-25-75 Barbara Goodman White 6-27-77 Doris C. Fleming White 4-12-77 Teresa Samuels White 4-1-77 Shirley M. Hill Black 5-6-77 VII. (Cont'd.) TURBO - WINDING DEPARTMENT. (Cont'd.) Name Dion Prion Lucy T. McKinney Iva L. Cuthbert Barbara J® Dawkins Leona M. Lay Mary Lou Osborne Ricky McCorkle Veronica Etters Kathie Boothe Jerry N0 Scarberry Debra Cameron Donna Lunsford Judy S. Cochran Mildred S0 Davis Teresa Payne Reatha A. Rogers Race Seniority Date White 10-6-75 White 2-6-73 White 5-16-77 White 6-23-77 White 6-22-77 White 5-31-77 Black 5-20-76 'White 5-23-77 White 5-31-77 White 11-10-75 White 5-19-77 White 8-24-76 White 5-18-77 White 5-30-77. White 9-27-76 White 6-17-75 VII. (Cont'd.) TURBO - TWISTING DEPARTMENT Name Race Seniority Date David C. Kincaid White 1-1-48 Claude T. Perkins White 4-11-55 Mattie S« Bumgarner White 4-24-55 Claude Lee Brackett White 8-20-58 Frank U« Snencer White 12-2-63 Rose Ann'Boggs White 7-25-66 John Lewis Johnston White 6-26-72 Herman W. Stephens White 10-19-72 Robert I. Ingle, Jr„ White 5-31-48 James C, Tallent White 2-2-70 Jerry M. Woody White 12-27-66 Barbara Woody White 8-3-73 William J„ Pennell White 2-28-77 Dale Lee Sloop White 9-21-73 o (28) VII. (Cont'd.) TURBO - GENERAL Name Race Seniority Date Fredrick C„ Moore White 1-5-48 Robert Wilkinson, Jr0 White 5-22-50 Hazel E« Whitworth White 9-21-59 Lewis Yates Stroupe White 7-12-48 VII. (Cont'd.) WAREHOUSE Mace Robert Coatner Virgiel McLean Ray Lewis McDowell Dillard P. McDowell William Andy Lawrence William K. Boggs Gregory Ernest Chappell Henry D. Byers Larry C. McMillan Samuel Keith Hovis Vaughn C0 Buchanan Ronnie D. Floyd Steve R. Whitley Melvin M. Graham Loyd Donald Calvert, Jr. Paul Gene McLean Donnie R. Anderson Robert Edward Phillips Rickey D. Payne Marshall L. McLean Billy Small Theados L. Paysour Bobby Go Cook Race Seniority Date Black 10-12-51 Black 4-21-56 Black 1-10-68 Black 1-6-69 Black 2-12-70 White 4-20-72 White 7-23-73 Black 8-23-73 White 10-9-74 White 12-31-73 Black 5-26-75 Black 8-4-75 White 8-19-75 Black 9-30-75 White 1-19-76 Black 5-25-76 White 5-12-76 White 2-1-77 White 2-28-77 Black 3-8-73 White 7-26-76 Black 10-5-59 White 4-25-77 * T t