Sherrill v. JP Stevens and Company Inc Brief for Appellees

    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