White v. Norfolk Shipbuilding & Drydock Corporation Proposed Consent Decree

    UNITED STATES DISTRICT COURT FOR THE 
EASTERN DISTRICT OF VIRGINIA 

NORFOLK DIVISION

EDWARD D. WHITE et al.,
individually and on behalf of 
all others similarly situated,

Plaintiffs,
v.

NORFOLK SHIPBUILDING & DRYDOCK 
CORPORATION et al.,

Defendants.

)
)
)
)

Civil Action No. 279-72-N

PROPOSED CONSENT DECREE



TO PRESENT AND FORMER BLACK EMPLOYEES OR APPLICANTS 
FOR EMPLOYMENT (OR THEIR FAMILY MEMBERS OR ESTATES) 
OF NORFOLK SHIPBUILDING AND DRY DOCK CORPORATION

In May, 1972, Edward D. White and five other persons filed suit 

in the United States District Court in Norfolk against the Norfolk 

Shipbuilding and Dry Dock Corporation [N.S.D.D.], the International 

Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths,

Forgers and Helpers of America, and Local 68^ of this International 

Union. The lawsuit alleged that the company and the unions had dis­

criminated against black persons in employment. The suit was brought 

as a class action whereby the plaintiffs represent all present and 

former black employees and applicants of N.S.D.D.

The plaintiffs and the defendants have agreed to settle the 

case, and have submitted the proposed terms of settlement, called a 
Consent Decree, to the Court for approval.

The Decree will bar all claims of racial discrimination for any­

thing occurring up to the Court's approval of the settlement. If 

you object to any of the terms of the proposed Consent Decree or to 

the manner in which the monetary settlement is proposed to be dis­

tributed, you must file objections within the next thirty days. If 

you wish to file objections, they must be put in writing, and must be 

received within the next thirty days by the Clerk of Court. His name 

and address are:

W. FARLEY POWERS, JR., CLERK 
United States District Court 
United States Court House 
Norfolk, Virginia 23501

Any document you file should state the name of the case and its 

number: White v. Norfolk Shipbuilding and Dry Dock Corporation,
Civil Action No. 279-72-N.

A brief description of the terms of settlement follows:
1. The defendants do not admit that they have ever dis­

criminated and promise that there will be no discrimination in 
the future.

2. The Decree will bar all claims of discrimination 
occurring up to the date of the Court's approval of the 
settlement.

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3. Employees in the Labor and Dock Departments will have 

a continuing opportunity to transfer to Helper positions in 

other departments. Their seniority will be carried forward, 

and they will have a right to bump back into their old depart­

ments in the event of a layoff. See paragraph 4(a ) of the 

proposed Consent Decree, on p. 3.

4. Laborers, labor helpers and dock helpers with 

seniority before 1969 will qualify for training programs, with 

specified maximum time periods for promotion to higher grades 

for those performing satisfactorily, if they apply for the 

program within 60 days after receiving notice of it. For 

employees who have worked substantial amounts of overtime in 
the past, there are provisions under which they retain certain 

rights to work overtime in their old departments. See para­

graphs 4(C) and 4(d ) of the proposed Consent Decree, on pp. 4-5.

5. Laborers will be given an extra 10 cents an hour when 

they are loaned out to other departments to work under the other 

departments' supervisors, except where the loan-out is made to 

avoid a layoff. See paragraph 5 of the proposed Consent Decree, 

on p. 5.

6. There are provisions intended to ensure that a fair 

number of blacks will be placed in N.S.D.D.'s better-paying 

jobs, including apprenticeships. See paragraphs 6 through 8 

of the proposed Consent Decree, on p. 6.

7. N.S.D.D. will appoint a person to try to resolve 

complaints of discrimination. See paragraph 10 of the 

proposed Consent Decree, on p. 8.

8. Local 684 will establish an Evaluation Committee to 

review and evaluate all grievances of minority employees. One 

member will be selected by the minority employees. Every 6 
months, Local 684 will submit reports on the disposition of 

these grievances to the Court. See paragraph 11 of the 

proposed Consent Decree, on p. 8.

9. Every 6 months, N.S.D.D. will submit progress reports 

on the implementation of the Decree to the Court. See para­

graph 16 of the proposed Consent Decree,on p. 10.



10. N.S.D.D. will pay $ 140,000 and the unions will pay

$ 40,000 for the monetary settlement of this case. Plaintiffs' 

costs in litigating this case, providing notice and distributing 

the proceeds will be paid out of this amount. Costs are tenta­

tively estimated at $ 18,891.39. Attorneys' fees are 25% of 

the remainder, tentatively estimated at $ 40,277.15. The sum 

to be distributed to the class is tentatively estimated at 

$ 120,831.46. See paragraph 1 of Appendix B to the proposed 

Consent Decree, on p. 43.
11. Each of the six plaintiffs will receive $ 2,500, but 

will not be included under paragraphs 12 to 14 below. See 

paragraph 2 of Appendix B to the proposed Consent Decree, on 

p. 43.
12. The sum of $ 20,000 shall be used to redress the 

claims of all class members who filed proof-of-claim forms.

This does not include any claim described in paragraphs 13 or

14 below. See paragraph 3 of Appendix B to the proposed Consent 

Decree, on p. 43.

13. $ 5,000 is the initial allocation to compensate all 
class members who lost 6 or more months' seniority upon trans­

ferring departments from 1965 to 1971. No one who does not fit 

this description will be paid for loss of seniority. See 
paragraph 5 of Appendix B to the proposed Consent Decree, on p. 44.

14. $ 75,831.46 is the initial allocation to compensate 

eligible class members who have worked at least 12 months after 

July 1, 1965 in any combination of the job categories of Laborer, 
Paint Laborer, Track Laborer, Laborer Helper, Dock Helper, Truck 

Driver, Janitor or Janitress. To be eligible, a class member who 
did not file a proof-of-claim form must have worked for N.S.D.D. 

on or after June 25, 1967. This requirement does not apply to 

persons who filed proof-of-claim forms. No one who has not 

worked a total of 12 months after July 1965 will be included.

For Dock Helpers, the 12 months has to have been between July 
1965 and December 1970. For Laborers, Labor Helpers and Dock 

Helpers, only class members hired in 1968 or earlier will be 

included. For the others, date of hire makes no difference.

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See paragraphs 6 through 9 of Appendix B to the proposed 

Consent Decree, on pp. 44-48.

15. $ 5,000 will be set aside as an escrow fund to cover 

mistakes in calculations, other valid claims, and unexpected 

costs. Any amount left one year after the Court's approval 

of the Consent Decree will be distributed equally to the 

plaintiffs. See paragraph 12 of Appendix B to the proposed 

Consent Decree, on p. 50.

16. Former employees who did not fi 1 e proof-of-cla:im

forms must Inform the attorneys for plaintiffs, in wri ting,

that they desire to share in the monetary settlement. If the

attorneys for p 1 a.in ti f fs do not recel ve a. required statement

wi thin 30 days from today, the former employee will lose his
or her right to share in this money. The required statements

must be mailed to:

RICHARD T. SEYMOUR 
Attorney at Law 
1763 R Street, N. W.
Washington, D. C. 20009

See paragraphs 9 and 10 of Appendix B to the proposed Consent 

Decree, on pp. 48-50.

17. Appendix A to the proposed Consent Decree lists some 
information about each person to whom it is proposed to dis­

tribute money, and some information about each person who filed 

a proof-of-claim form. If there are any errors, a written cor­
rection must be received by Mr. Seymour within 30 days from 

today or it will not be considered.

18. If a class member has died, his immediate family or 
estate are entitled to his share. Notification requirements 

still apply, but can be satisfied by executors, administrators, 

adult members of the person's immediate family, or designated 

beneficiaries of wages owing at the time of death. See para­
graph 11 of Appendix B to the proposed Consent Decree, on p. 50.

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UNITED STATES DISTRICT COURT FOR THE 
EASTERN DISTRICT OF VIRGINIA 

NORFOLK DIVISION

EDWARD D. WHITE, ct al., )
individually and on behalf )
of all others similarly )
situated, )

)
Plaintiffs, )

)
v. ) Civil Action No, 279-72-N

)
NORFOLK SHIPBUILDING & DRYDOCK )

CORPORATION, et al., )
)

Defendants. )

CONSENT DECREE

Plaintiffs brought this action against Norfolk Shipbuilding N 

Drydock Corporation (hereinafter the Company) and the International 

Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths,

Forgers & Helpers, AFL-CIO, and Local No. 684 of said International 
Brotherhood (hereinafter the Unions) pursuant to Title VII of the 

Civil Rights Act of 1964, as amended by Public Law 92-261 (March 24, 

1972), 42 U.S.C. § 2000e et seq., the Civil Rights Act of 1866,

42 U.S.C. § 1981, the National Labor Relations Act, 29 U.S.C. $ 151 
et seq., and § 301(a) of the Labor-Management Relations Act, 29 U.S.C. 

§ 185(a). Jurisdiction is vested in the Court by virtue of 42 U.S.C.

§ 2000e-5(f), 28 U.S.C. § 1343(4), 29 U.S.C. § 1337, and 29 U.S.C.

§§ 185(a) and (c).
The Company and the Unions expressly deny any violation of 

Title VII of the Civil Rights Act of 1964, as amended by Public Law 

92-261 (March 24, 1972), 42 U.S.C. § 2000e et seq., the Civil Rights 

Act of i860, 42 U.S.C. § 1981, or any other equal employment law, 
regulation or order; or the breach of any provision of an applicable 

collective bargaining agreement. This Decree and consent hereto does 

not constitute a finding or an admission of any unlawful or 

discriminatory conduct by the Company or the Unions.

WHEREAS, the plaintiffs, the Company and the Unions are desirous 

of resolving this matter without the time and expense of further liti­

gation, and the parties have consented to the entry of this Decree, 
and it appearing to the Court that the entry of this Decree will 

further the objectives of the aforementioned enactments, and that the



2

Decree fully protects the rights and interests of all employees and 
applicants for employment, it is

ADJUDGED, ORDERED and DECREED, as follows:

1. General

A. Pursuant to this Decree, the instant action is entirely 

resolved as to the Company and the Unions with prejudice to all 

claims of racially discriminatory employment practices of ail 

parties plaintiff and with prejudice to such claims of all members 

of the class represented by plaintiffs (without regard to whether 

such members are members of the subclasses entitled to share in the 

award of back pay, as set forth in Appendices A and B to this Decree) 
against the Company, the Unions and their respective officers, 
employees, successors and assigns.

B. The class represented by the plaintiffs includes all past 
and present minority employees of the Company; and all past and 

present minority applicants for employment by the Company.

C. This Decree shall not foreclose the rights of any named 

plaintiff or class member as to discriminatory practices by the 

Company or the Unions occurring after the entry of this Decree.

2. Monetary Consideration

A. In settlement of all claims and costs (including court 

costs and administrative costs not heretofore paid in proceedings 
before this Court) the Company agrees to pay a sum of $140,000 and

the Unions agree to pay the sum of $40,000 for a total sum of $180,000 

for back pay, counsel fees, costs, in full and final settlement of 

any and all claims, by said plaintiffs or the class they represent, 

of racial discrimination in employment, occurring up to the effec­

tive date of this Decree, against the Company, the Unions, their 

respective officers, employees, successors and assigns. The Company 
and the Unions by this Decree release each other of any claim of 

contribution or indemnification.
B. The apportionment of the total $180,000 shall be in 

accordance with the formula and in the manner set forth in the 
attached Appendices A and B. Distribution of such funds according 

to such apportionment shall be the responsibility of counsel for the



plaintiffs. Counsel for plaintiffs may rely on the accuracy of 

information compiled by their agents from Company records or 

furnished by the Company in response to requests for information. 

Assuming no showing of a lack of good faith, all parties, including 

their counsel, will not be liable for miscalculations, omissions or 

errors in apportionment and distribution. Opportunity will be 

afforded for class members to object to the proposed apportionment 

and distribution.

3. Specific Assignments
A. Albert Parker will be promoted to the position of Pusher 1 

at the first vacancy or within 60 days after the entry of this 

Decree, whichever occurs sooner.

B. Kenneth Cox will be promoted to the position of helper l/C 
in whichever of the craft departments has the first vacancy (except 

Plate & Welding). The position is one that will afford the training 

opportunity contemplated under Paragraph ;*C of this Decree. If no 
helper l/C vacancy occurs within 60 days after the effective date

of this Decree, then the Company will promptly assign Cox to one of 

those departments as an additional helper l/C.

C. Charles D. White, J. A. Moore and Calvin R. Williams will 

be placed in the first available vacancies within the handyman 3/C 

category of the Outside Machine Shop.
D. The former employees listed in Appendix C will be sent the 

letter contained in Appendix D and if determined to have been 

qualified at the time of initial hire at the Company for placement as 
handyman 3/C or better will bo given a priority over applicants for 

such placement.

h . Transfer Program

A. Notice of Transfer Opportunities. The Company will post a 

notice at a facility readily available to employees of the Labor and 
Dock Departments of the continuing opportunity to apply for transfer 

to Helper positions in other departments. Such notice will indicate 

that employees so transferring will carry their seniority (calculated 
from their last date of hire) forward into their new department and 

will have a bump back right to their old department in case of layoff



pursuant to Article IX, Sections 4 and 5 of the Labor Agreement, 

effective March 7, 1973. These notices will further inform 

employees who believe they have qualifications for placement into 

a handyman or higher position that they should advise the Personnel 
Office of their skills and interests.

B. Restoration of Seniority. Seniority of all employees who 

had their seniority altered as a result of transferring at their 

own request shall be calculated from their last date of hire.

C. Training. To ensure that adequate training opportunities 

are provided to minority employees who are laborers, paint laborers, 

track laborers, labor helpers, dock helpers, janitors or janitresses 

with seniority prior to 1969, the Company agrees as follows:

All such minority employees who apply for transfer to 
trade helper or trade handyman positions within sixty (60) 

days after being informed by letter of the terms of this 

provision, will, when assigned to such positions, be 

afforded training opportunities which will, assuming 

satisfactory job and training performance, enable them to 

qualify for promotions on the following time schedule:

Handyman 3/C - 12-18 months of active employ­
ment as a helper after the date 
of this Decree

Mechanic 3/C - 36-48 months of active employ­
ment as a handyman after the 
date of this Decree

The above letter will be issued within thirty (30) days after 
the final entry of this Decree.

The above time schedule shall not be used to extend the time of 

an individual's progress if his performance and skills merit faster 

progression, and the Company shall make appropriate good faith efforts 

to qualify individuals for promotion within the lesser times stated 

above. The progress of each trainee under this subsection will be 

evaluated at six-month intervals, and a copy of this evaluation will 

be forwarded to counsel for plaintiffs.

Individuals who are serving as helper l/C and who are transferred 

pursuant to this subsection to a helper 2/C position will not have 

their wage rate reduced unless they thereafter decline promotion to 

a helper l/C position or fail to qualify for such promotion within 
one year of the time of their transfer.



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D. Overtime Opportunities. Each eligible minority laborer or 

helper in the Labor or Dock Departments with seniority prior to 1969, 

who applies for transfer to a helper position in a trade department 

within sixty (60) days after being informed by letter of the terms 

of this provision will, for two years after the date of this Decree 
or until he becomes a handyman 3/C, whichever occurs sooner, have 

the option in any overtime preference period as defined hereinafter 

to share equitably in overtime opportunities in his former depart­

ment which are not accepted by the employee who performed the same 

work during the preceding shift. To be eligible for this provision, 

an employee must have had at least 500 overtime hours in the period 

1970-72. Those eligible are listed in Appendix E.
In allocating an equitable share of such overtime opportunities 

in the employee's former department, account will be taken of the 

overtime opportunities the transferee has had in his new department 
as well as the overtime opportunities which have been made available 

to him in his former department. It is further understood that to 

the extent that an employee exercises his option to share in over­
time in his former department, he may be required to work overtime 

in that department on the same basis that he could be required to 

work overtime in his new department.
An overtime preference period shall be the three months period 

immediately following a calendar quarter after the employee's transfer 

in which quarter (l) the employee was offered at least 15 percent less 

overtime than his quarterly average listed in Appendix E and (2) the 
overtime hours worked in his former department equaled or exceeded 

85 percent of the quarterly average of overtime worked in that depart­

ment in the years 1970, 1971, and 1972.

5. Loan Outs
Labor Department employees loaned outside the Labor Department 

shall receive a premium rate of pay of #.10 per hour where the loan- 
out is for more than three consecutive working days and the loan-out 

has not been made in part to prevent the employee's being laid off.
In such circumstances, the premium rate shall be payable beginning 

on the fourth consecutive working day. For purposes of this pro­
vision, an employee is loaned out only when he is directly subject



6

to supervisors of a department other than the Labor Department. A 

loan-out does not include the assignment of laborers under a Labor 

Department supervisor to work in another department.

6. Supervisors

A. In filling positions of supervisors in the Labor Depart­

ment, first consideration shall be given to then current employees 
in the Department.

B. The Company will make a good faith effort to increase the 
utilization of minority employees as supervisors in all departments.,

7. Helper —  Laborer Assignments

In each year during the life of this Decree, approximately the 

same ratio of minority to white employees shall be attained in the 

assignments of new hires made to each of the following positions: 

trade helper, dock helper, laborer, paint laborer, track laborer, and 

janitor or janitress, provided that at all times the Company shall be 

free to make necessary assignments if employees of only one race are 

presently available for such an assignment and provided further that 
in determining compliance with this requirement ratios will be based 

on actual offers of assignments without regard to whether or not the 

offers were accepted. The company shall not offer trade helper 

positions to an applicant who has rejected a laborer position within 
the previous thirty (30) days except where necessary to fill a 

vacancy and where necessary to meet the assignment ratios provided 
for in this paragraph.

8. Minority Placement Rates

A. Except as provided in paragraph B below, in each year 

during the life of this Decree, at least 25 percent of the place­

ments (new hires and promotions) as mechanics in each trade and

25 percent of such placements as handymen in each trade and 25 percent 

of such placements as apprentices will be minority group members.

B. (l) In each year during the life of this Decree the follow­

ing rates shall apply for the placement (new hires and promotions) of 

minorities in the positions listed unless the percentage of minorities 

employed in such positions reaches 20 percent, in which case only the 
terms of provision 8.A. above will apply:



7

Sheet Metal handyman - 50%
Crane Operator - 50%
Guard - 33-1/3%
Rigger handyman - 33-1/3%

(2) With respect to the following positions, the placement 

rate of minorities (new hires or promotions) will be 50 percent until 

there is at least one minority employee in the position, in which case 

only the terms of paragraph 8.A. will apply:
Power Plant Operator - Power Plant Maintenance
Storeroom Maintenance Machinist
Tug and Launch Captain
C. The specified minority placement rates in paragraphs 8.A. 

and 8.B. above are subject to availability of qualified minority 

persons willing to accept such positions. It shall be a defense 

and an appropriate excuse that the Company has in good faith sought 
to recruit a qualified minority person to fill a vacancy, from the 

sources listed in Appendix F, but does not have a current application 

of such a person.
D. Nothing in this Decree shall be construed to prevent the 

Company from exceeding the goals of minority placement and 

utilization set forth above.
E. The high school diploma requirement shall not be used to 

the extent that it precludes reaching the minority placement rate 

for apprentices. The Company will make its best efforts to assure 
that minority apprentices are not concentrated in particular depart­

ments but are widely represented among the different departments 

covered by the apprenticeship program.

9. Vocational Training

The Company agrees to determine the feasibility of further 

participation in or cooperation with training programs sponsored by 
public vocational education organizations in the metropolitan Norfolk 

area. In this connection the Company will offer to nominate Company 
representatives to vocational craft committees relevant to shipyard 

work and will notify current employees of offsite training courses 

that will provide relevant training opportunities outside working 
hours to the extent such notification will not obligate the Company 

to compensate the employees for time spent in such training. Tin? 

Company further agrees to recommend improvements in existing offsite



training opportunities for potential applicants and present 

employees and the establishment of additional training courses or 

programs relevant to shipyard work to the extent such actions will 

not obligate the Company to compensate employees for time spent in 
such training.

By September 30, 1973, the Company shall prepare a report on the 

feasibility of further participation and cooperation in public voca­
tional training programs. Such a report will give due consideration 

to all types of training possibilities. The Company further agrees 

to discuss this subject with counsel for plaintiffs should the 

latter believe, after receiving the feasibility report, that the 

Company is not adequately participating in or cooperating with such 
vocational training programs.

10. EEO Compliance Officer

The Company will designate an EEO officer to assure compliance 

with the terms of this Decree and will post a notice to all employees 
of this designation. The EEO officer will be authorized to receive 

employee complaints of discrimination and to investigate and seek 
resolution of such complaints.

11. Union Monitoring Procedure

A. The Local Union agrees to establish and maintain during the 

life of this Decree, an Evaluation Committee to review and evaluate 

all grievances of the minority employees of the Compahy. This Com­

mittee shall consist of the president and vice-president of the Union, 
a member selected by the minority employees and two other members 
selected by the Local Union.

B. The said Committee shall meet at least quarterly and shall 
have the responsibility to review and evaluate all grievances of 

minority employees and to assist the Shop Stewards in resolving 
these grievances.

C. Any minority employee of the Company having a grievance 

hampered by the action or inaction of his Shop Steward shall have the 
option of filing his grievance with the president of the Union; pro­

vided, however, that any such grievance shall be pursued in accordance 
with the terms of Article XI "Grievance Procedure" of the Labor
Agreement.



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D. The Local Union will prepare and submit to the counsel for 

all parties reports indicating the disposition of grievances of 

minority employees, commencing on July 1, 1973 and thereafter semi­

annually. A final progress report will be submitted at least twenty 

(20) days prior to the expiration of the terms of this Decree.

E. The Company and the Local Union shall cooperate with each 

other in fulfilling their respective obligations under this Decree.

12. Term of the Decree

This Court retains jurisdiction of this action for a period of 

four (^) years for the purposes of assuring compliance with this 
Decree. After that time, the Decree shall be dissolved. At any 

time that this Decree works an unexpected or undue hardship upon 

the Company, it may move for appropriate modification, upon thirty 

(30) days notice to plaintiffs. If there has not been substantial 

progress in minority utilization in categories aggregating a sub­

stantial number of positions, this Court, upon motion of plaintiffs, 
may extend the terms of this Decree to cover those positions for a 
period not to exceed two (2) years.

13. Complaint Procedure

If, at any time during the term of this Decree, any complaints 
or instances of possible non-compliance come to the attention of 

plaintiffs, the Company and/or the Union as appropriate shall be 
notified in writing and permitted to investigate and rectify any 

complaints. Internal procedures, such as the grievance procedures, 
may be used to resolve the problem. If the matter is not resolved 

to the satisfaction of plaintiffs within thirty (30) days of the 

Company's and/or the Union's receipt of this notice, plaintiffs may 
move for an appropriate resolution by the Court. This section shall 

not be construed as a limitation in seeking judicial review after 
said thirty (30) days.

14. Exclusive Remedy
It is agreed that this Consent Decree embodies the exclusive 

remedy as to the Company and the Unions for any claims of employment 

discrimination against plaintiffs and the class they represent aris­

ing prior to the entry of this Decree, and that no other actions will



10

be brought against the Company and the Unions with respect to such 

claims in any forum, administrative or judicial.

15. Notice
A. The Company will provide counsel for plaintiffs with a 

mailing list for present minority employees and as accurate and 

complete a list as possible of former minority employees for direct 

mailing of a copy of this Decree and of Appendices A through E.
B. A summary of this Decree, including the proposed method of 

monetary distribution, will be published once in the Norfolk Journal 
and Guide and the Virginia Pilot. The text of the notice shall be 

as set forth in Appendix G hereto. The notice will expressly afford 

to members of the class, and persons excluded from the class by the 

definition herein, opportunity to file objections to this Decree, or 

proposed corrections to the factual information contained in 

Appendix B, with this Court no later than thirty (30) days following 

the date of publication of the notices. Promptly following such 

publication, plaintiffs shall submit' to the Court and to each defen­

dant herein a certificate attesting to said publication and the dates 

thereof, and shall submit therewith actual or xeroxed copies of the 

notices as published. In the absence of any such objections within 

the aforesaid thirty (30) days, this Decree shall become final 
without further action by this Court.

16. Monitoring and Reporting

A. In connection with implementation of this Decree, the 

Company will monitor job placements and maintain records. The 
Company will prepare and submit a copy to counsel for all parties 
of progress reports commencing January 1, 1972*, and thereafter 

semi-annually. A final progress report will be submitted to counsel 

for all parties, at least twenty (20) days before expiration of

the terms of this Decree.

B. At annual intervals during the life of the Decree, the 

Company will submit to counsel for all parties a report covering 

the positions under the Program showing name, race, job classifi­

cation, employee number and date of employment of all employees of 
the Company. The Company shall promptly advise counsel for all



parties of any changes in the coding systems used to record such 

informati on.

J u d g e  K e l l  ant
U n i t e d  S t a t e s  D i s t r i c t  C o u r t



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APPENDIX A

LISTS OF PERSONS ENTITLED TO SHARE IN THE MONETARY SETTLEMENT

In accordance with the provisions of Appendix B, each of the 

plaintiffs will receive the amount of $2,500 and shall not share 
under any of the other provisions for distributing the monetary 

settlement. The remainder of the monetary settlement available for 

distribution to the class will be distributed according to the 

following lists. Persons may appear —  and share —  on more than 
one list.

Page
List 1 Persons who filed proof-of-claim forms 13

List 2 Persons who lost six or more months'
seniority in transferring departments 27

List 3 Eligible present and former laborers 28

List 4 Eligible present and former paint laborers
and track laborers 34

List 5 Eligible present and former labor helpers 35

List 6 Eligible present and former dock helpers 37

List 7 Eligible present and former truck drivers 41
List 8 Eligible present and former janitors

and janitresses 42
Note: To be "eligible" in lists 3 through 8, a person must have

worked a total of at least twelve months, since July 1965, in any 
combination of these job categories. In addition, persons who did 

not file proof-of-claim forms must have worked for N.S.D.D. on or 

after June 25, 1967. See Appendix B for details. CAUTION: The

"estimated amounts of back pay" are only estimations. They may be 

a little larger or a little smaller. Some taxes may also have to 

be withheld on part of the amounts involved. Persons marked with an 

asterisk (*) before their name must send a postcard to the attorneys 

for the plaintiffs by the deadline or they will lose their rights 

to receive money, and everyone else's share will increase according­

ly. If you see any mistakes in this table, notify the attorneys 
for plaintiffs _as soon as posslble since nothing can be done about 

the mistake after the final calculations have been made. Check for
your name on all lists.



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1. LIST OF PERSONS WHO FILED 
PROOF-OF-CLAIM FORMS

The following list shows the best judgment of the attorneys 

for plaintiffs on the merits of each proof-of-claim form filed 

in this case. Each person's claim has been given a rating of up 

to ten points, reflecting the following factors: likelihood

that the claim is true, based upon the extensive depositions and 

voluminous discovery taken herein, degree of economic loss, 

length of time the alleged discriminations continued, recency of 

the events involved, factors mitigating the defendants' alleged 

conduct, problems of proof if the claim had had to have been 

litigated at trial, and likelihood of success in the event of 

such litigation.

The following list does not include any claims of a type 

covered in any other lists, but is in addition to any such 

allocations. Of the total $180,000 settlement, $20,000 has 
been set aside for the payment of the claims in this list. In 

the judgment of counsel for plaintiffs, this is an adequate and 

fair amount of the total settlement to be allocated for these 
claims.

Many of the persons filing proof-of-claim forms did so 
more to bring facts they considered important to the attention 

of the Court and of the parties than to seek money for themselves. 
Without this information, it might not have been possible to 

reach this settlement, and they are commended for their 

co-operation.
None of the persons who filed a proof-of-claim form is 

required to send a postcard to counsel for plaintiffs; each is 

eligible to receive his or her share without any further action 

on his or her part. The "estimated amounts of back pay" are 

tentative and may be a little larger or a little smaller. If 
you see any mistakes in this table, notify the attorneys for 

plaintiffs as soon as possible since nothing can be done about 

the mistakes after the final calculations have been made.



-14-

C AC TT ON: SOME TAXES Ml'ST HE WITHHELD.

Estimated
Amounts for Claims

Points On this List______

1. Adamson, James E. (230 66 5020)
Claims on initial assignment and den­
ial of apprenticeship application 1 $ 79.68

la. Allen,Eugene C. Did not state any claim — __
Alston, Herbert

Apprenticeship claim 1 79.68

3. Alston, Robert L.
Facts are not enough to show 
discrimination

4. Amos, Albert S.
All valid claims covered in other 
lists

5. Andrews, Joan P.
No claim stated — —

6. Armstrong, Annie E.
Covered on Janitors’ list __ --

7. Artis, Laurence H.
Facts are not enough to show 
discrimination

8. Askew, Bennie
Covered on Laborers' list — —

9. Askew, Bernard
Covered on other lists __ —

10. Askew, Crist
Facts are not enough to show 
discrimination

11. Baker, Linwood Sr.
Did not state a claim — —

12. Baker, Samuel
Facts do not show discrimination — —

13. Barbour, George
Did not state a claim __ —

14. Barbour, Jeff III (225 68 5066)
Loan-outs and apprenticeship claims 1 79.68

15. Barnard, Pearlie
Covered on Dock-Helper list — —

1 6. Barrett, Calvin L. (227 50 5745) 
Initial assignment claim 2 159.36

17. Batts, Rufus (223 56 0370)
Initial assignment claim 1 79 .68

18. Bell, Roland L. Sr.
Facts do not show discrimination — —

19. Benson, Albert L. (229 54 2480) 
Apprenticeship claim 5 398.41

20. Bernard, Paul L.
No claim stated



Points

Estimated
Amounts for Claims
On this List______

-15-
CAUTION: SOME TAXES MUST BE WITHHELD.

21. Billups, Lewis B.
Facts do not show discrimination __ —

22. Blowe, Paul D. (224 66 1982)
Transfer and apprenticeship claim 1 $ 79.68

23. Bolar, Eddie
Facts not enough to show discrimination __ —

24. Boone, Bobby L.
Covered in List of Plaintiffs _ _

25. Bowden, Allen (46l 26 6918)
Initial assignment claim 2 159.36

26. Bowers, Junius L.
Claim outside a recent enough period — —

27. Boyce, Charles
Facts do not show discrimination — _

28. Boyd, Bruce E. (228 36 2150) 
Apprenticeship claim 1 79.68

29. Branch, Lorenzo E. (228 80 4705) 
Initial assignment claim 3 239.06

30. Bright, George L.
Facts do not show discrimination — —

31. Brown, Arthur T.
Facts do not show discrimination — —

32. Brown, Matthew III (225 56 1736) 
Racial antagonism claim 3 239.06

33. Brown, Milton L. (228 20 6930)
Initial assignment claim; also 
covered on Truck Drivers' list 1 79.68

34. Brown, Warden E. (512 30 8176) 
Initial assignment claim 1 79.68

35. Brown, William T.
Facts do not show discrimination — _

36. Bryant, Jahugh (226 22 0265) 
Initial assignment claim 3 239.06

37. Bryant, James A. (243 20 4940)
Claim of failure to promote 10 796.81

38. Bryant, William E., Jr. (246 40 6871) 
Claim of failure to promote 10 796.81

39. Burke, Elmo Jr.
Did not work long enough to share — —

40. Bynum, Jesse J.
Facts do now show discrimination — —

41 . Caldwell, Elmer (262 66 5306) 
Initial assignment claim 1 79.68

42. Calhoun, Huey D.
Failure to re-assign after injury 1 79.68

43. Cameron, Lonzia
Covered on Laborers' list — —

44. Carroll, William H.
Did not state any claim; covered on 
Laborers' list



Points

Es tima ted
Amounts for Claims
On this List __

-16-
CAUTION: SOME TAXES MUST BE WITHHELD„

45. Chamberlain, Ronald G.
Did not work long enough to share — —

46. Chatman, Leroy
Facts not enough to show discrimination — __

47. Cherry, Conston A. (230 14 1416) 
Failure to promote claim 3 $239 .06

48. Chesson, William T. Jr. (228 32 0327) 
Initial assignment claim 1 79 .68

49. Clinkscales, Henry E.
Did not state any claim — —

50. Collin.s, James (254 5^ 6917)
Failure to promote claim; also 
covered on Laborers’ list 2 159.36

51. Collins, Raymond Jr.
Initial assignment claim 1 79.68

to Cooper, Louiss R.
Facts do not show discrimination

53. Copeland, Coley Jr. (228 52 2562)
Claim of occupational disease and 
failure to re-assign; also covered
on Dock Helpers’ list 5 398.41

54. Corprew, Joseph L.
Did not work long enough to share

55. Covington, Harold C.
Initial assignment and unequal pay
claims 1 79.68

56. Cox, Kenneth L.
Covered on List of Plaintiffs —  —

57. Cradle, William H.
Did not work long enough to share —  —

58. Crocker, Lloyd W.
Did not state a claim —  —

59. Cromuel, March Jr. (262 52 7728)
Hiring and recall claims 1 79.68

60. Cuffee, Joseph A.
Did not state a claim.

61. Cuffee, Ronald B.
Did not state a claim. —  —

62. Cuffee, Reginald T.
Did not state a claim —  —

63. Gurney, Milton E.
Did not state a claim —  —

64. Daniels, Edward B.
Covered in Dock Helpers' List —  —

65. Daugherty, Marvin (227 72 5730)
Initial assignment claim and failure
to give lighter work after injury 2 159.36

66. Davis, Valelicch L. (224 66 1962)
Failure to re-assign claim 1 79.68



CAUTION
-17-

: SOME TAXES MUST BE WITHHELD. Points
Estimated
Amounts for Claims
On this List

6 7. Dawkins, Alice
Did not state a claim; covered on 
Janitors’ list —

68. Dawkins, Elford
Covered on Dock Helpers’ list — _ _

69.

70.

DeBerry, John H., Jr.Initial assignment and failure to 
promote claims 1

DeLoateh, Franklin R.
Covered on Paint Laborers’ List —

$ 79.68

71. Dildy, Larry K. (223 72 1279)
Initial Assignment and Failure to 
reassign to avoid layoff 3 239.06

72. Dodson, Daryl (224 70 5743)
Discharge claim 2 159.36

73. Dorsey, Norman H.
Facts not enough to show discrimination — _ _

74. Dowdy, John H. (228 36 5603)
Discharge for garnishment claim 2 159.36

75. Driver, Rudell
Facts not enough to show discrimination — —

76. Dukes, Horace T.
Facts not enough to show discrimination — —

77. Dukes, James L. Ill
Did not state a claim — —

78. Durham, Carl M. (230 68 5680)
Initial assignment claim 1 79.68

79. Eason, Wagus E.
Covered on Dock Helpers' list —

80. Edwards, Milton L.
Did not state a claim —

81. Elliott, Lloyd C.
Apprenticeship claim 1 79.68

82. Elliott, Junius D.
Covered on Dock Helpers’ list — —

83. Epps, Doris E.
Covered on Janitors’ list — —

84. Evans, Leroy
Covered on Laborers' List —

85. Farmer, Ronnelle W. (294 50 3153)
Initial assignment claim 1 79.68

86. Faulk, David T.
Did not state a claim; covered 
on Dock Helpers' list —

87. Faulkins, Tom L.
Facts not enough to show discrimination — _ _

88. Felton, Leroy
Facts not enough to show discrimination — —

89. Finch, Charles E. (230 44 9536)
Discharge claim 1 79.68

90. Flowers, Orren T.
Apprenticeship claim 1 79.68



Po ints

Estimated
Amounts for Claims
On this List______

-18-
CAUTION: SOME TAXES MUST HP WITHHELD.

9 1 . Fly the, David L.
Facts not enough to show discrimination —

92. Ford, Robert (228 34 6058)
Unequal pay claim; covered on Dock 
Helpers' list

93. Ford, Willie L.
Facts not enough to show discrimination —

94. Forrest, James A.
Did not work long enough to share —

95. Foster, Archie L.
Did not work long enough to share —

96. Freeman, Linwood W.
Covered on Laborers' list _ _

97. Fulgham, James L.
Failure to promote claim 1

98. Fuller, George E.
Did not work long enough to share —

99. Gardner, Freddie
Facts do not show discrimination _ _

100. Garrett, Clarence M. (231 50 0086) 
Failure to promote claim; also 
covered on Dock Helpers' list 2

101. Gibbs, Samuel E.
Covered on Dock Helpers' list _ _

102. Gibson, Paul (228 42 7833)
Initial assignment claim 2.

103. Giddens, Donald M.
Did not work long enough to share —

104. Gilliam, Arthur J.
Facts do not show discrimination

105. Gilliam, Milton V.
Hiring and failure to promote claims 2

106. Gormandy, Eric It. (227 26 1383)
Claim of failure to re-assign to take 
account of disability 1

107. Gray, George E.
Did not work long enough to share _ _

108. Greene, Alphonso
Did not work long enough to share —

109. Griffin, Joseph (231 03 2270) 
Initial assignment claim 1

110. Griffin, Quince D.
Apprenticeship claim 1

111. Guy, Leonard L. (225-46-8707)
Failure to promote to supervisory 
position; also covered on Laborers' 
list and on Labor Helpers' list 2

112. Hammond, Earl
Did not state a claim —

113. Hampton, Earl J. (227 66 5829)
Loan-out, apprenticeship and discharge 
claims; also covered on Laborers' list 7

$159.36

79.68

159.36

159.36

159.36

79.68

79.68

79.68

159.36

557.77



114.

115.

116.

117.

118.

119.

120.

121 .

122.

123.

124.

125.

126.

127.

128.

129.

130. 

131 .

132.

133.

134.

135.

136.

CAUTION
-19-

: SOME TAXES MUST BE WITHHELD. Estimated
Amounts for Claims

Points On this List______

Harris, James E. (246 64 0624)
Supervisory promotion and demotion claim 
also covered on Laborers' list 2 $159.36

Harris, Emery Jr.
Facts not enough to show discrimination — —

Harris, Samuel
Did not work long enough to share — —

Harvey, William (231 34 2511) 
Failure to promote claim 4 318.73

Haskett, William J. (226 56 8362)
Failure to promote claim; also 
covered on Laborers' list 2 159.36

Hill, Joe Lee
Facts do not show discrimination — —

Hines, Bruce C.
Racial antagonism olaim 1 79.68

Hinton, Garland (227 72 5124) 
Apprenticeship claim 2 159.36

Holliday, David L. (237 70 4028)
Apprenticeship and loan-out claims 3 239.06

Holloway, Oliver W.
Deceased, no claim shown from records — —

Hopkins, Shirley B. (227 50 6206)
Initial assignment, unequal pay and 
antagonism claims 239.06

Howell, Arthur C.
Failure to promote claim 2 159.36

Jackson, Cleraith A.
Facts do not show discrimination — —

-Jackson, Harvey Jr. (228 80 1721) 
Initial assignment claim 1 79.68

James, Rudolph
Did not work long enough to share — —

Jamison, Michael
Did not work long enough to share — __

Jenkins, J. J.
Covered on Laborers' list — —

Johnson, Alonza I.. (232 60 6644) 
Loan-out claim 1 79.68

Johnson, Ira
Facts not enough to show discrimination — —

-Johnson, Michael (227 66 510b) 
Discharge claim 1 79.68

-Johnson, Robert A. (230 66 4389)
Initial assignment and apprenticeship 
claims 1 79.68

-Johnson, Ward T. (223 3b 6741 ) 
Initial assignment claim 1 79.68

-Jones, Don L. ,(230 66 4764) 
Apprenticeship claim 1 ccr-

l
Jones, George L. W.

Racial antagonism claim 79.68



-20-
CAUTION: SOME TAXES MUST BE WITHHELD.

Points
138. King, Garland C.

No pay loss claimed __

139. Lamp, James W. (231 34 0345)
Promotional claim 1

140. Lancaster, James E.
Covered on Dock Helpers' list __

141. Lassiter, Billy L.
Facts not enough to show discrimination

142. Lassiter, Roland C.
Did not work long enough to share

143. Lee, Alfred H. (227 56 2666)
Failure to promote claim 10

144. Lewis, Charles
Most of claim not within a recent 
enough period; for rest, did not work 
long enough to share

145. Lewis, Ernest R.
Did not state a claim

146. Lindsey, Ellis L. (230 78 6221)
Discharge claim 1

147. Lockhart, James T.
Claim not within a recent enough period

148. Long, Charlie L.
Covered in Dock Helpers' list

149. Lowe, Edward M.
Did not work long enough to share

150. Madison, John D.
Failure to promote claim 3

151. Madison, Larry D.
Covered on Laborers' list; facts on pay 
claim not enough to show discrimination —

152. Majette, Graham
Covered on Laborers' list and on Dock 
Helpers' list

153. Martin, George W.
Covered on Dock Helpers' list

154. Mason, Zollie Jr.
Did not work long enough to share —

155. Mathis, Marvin F.
Covered on Laborers' list —

156. Mayfield, Augustus (255 60 9231)
Layoff and loan out claims; also
covered on Laborers' list 1

157. McCoy, Linwood F.
Covered on Dock Helpers' list

158. McCoy, Woney
Covered on Dock Helpers' list

159. McKinnon, Cezar J.
Covered on Dock Helpers' list

160. Miller, Reuben L. (228 20 4067)
Failure to promote claim

Estimated
Amounts for C!
On this List

a 79.68

796.81

79.68

239.04

79.68

7 557.77



-21-
CAUTION: SOME TAXES MUST BE WITHHELD. Estimated

Amounts for Claims
Points On this List

161. Mitchell, Melvin L.
Failure to promote claim; also
covered on Dock Helpers* list 2 $ 159.36

162. Mitchell, Morris E.
Claims not within a recent enough 
peri od

163. Mitchell, Roy
Initial assignment claim 1 79.68

164. Moore, James A. (219 38 0565) 
Initial assignment claim 2 159.36

1 6 5. Moore, Quindell G. (241 74 8141) 
Discharge claim 1 79.68

166. Morgan, Donnie L.
Did not work long enough to share

1 6 7. Morgan, Joe
Did not work long enough to share

168. Moseley, Glenn K. (225 60 6940)
Layoff and discharge claims; also 
covered under Laborers* list 1 79.68

169. Moss, Alfred D. (227 50 7133) 
Discharge claim 1 79.68

170. Newby, Eddie L.
Facts not enough to show discrimination

171. Newby, William F.
Covered on Laborers' list

171a. Newsome, Isaiah Failure to promote claim 5 398.41172. Nixon, Frederick D. (227 56 4129)
Initial assignment and failure to 
promote claims 2 159.36

173. Nixon, Herman R.
Did not state a claim

174. O'Neal, Moses (231 44 7482)
Loan-out claim; also covered on 
Laborers' list 1 79.68

175. Owens, Thomas A.
No records show discrimination

1 7 6. Parker, Albert L.
Covered on Plaintiffs' list . .

177. Parker, Eldridge L.
Covered on Laborers' List and on 
Truck Drivers' list

178. Parker, Jackie R. (229 70 4199)
Initial assignment and discouragement 
of transfer claims 1 79.68

179. Patterson, Robert L.
Did not work long enough to share __

180. Peede, Carlton E. (227 56 4485)
Apprenticeship, loan-out and dis­
couragement of transfer claims; also 
covered on Laborers' list 3 239.06

181. Peoples, Ethel
Covered on Janitors* list — __

182. Perry, Charles E.
Did not state a claim



-22-
CAUTION: SOME TAXES MUST BE WITHHELD. Estimated

Amounts for
Points On this List

183. Person, Amos
Did not state a claim _ _ —

184. Phillips, Willie E.
Covered on Dock Helpers' list — __

185. Pierce, Clifton E. (228 62 3563) 
Antagonism claim 2 $159.36

186. Pope, Edmond L.
Facts do not show discrimination — —

187. Pitt, Herbert
Initial assignment claim 1 79.68

188. Porter, .James H. (241 64 4783)
Deprivation of training claim; 
also covered on Laborers' list 2 159.36

189. Powell, Garfield
Covered on Dock Helpers' list — —

190. Powell, Joe L. Jr.
Did not file a claim — __

191. Prayer, Bobby J. (230-68-4242)
Loan-out claim; also covered on 
Laborers' List 1 79.68

192. Pugh, Carlton E. (227-72-4939)
Antagonism and discharge claims 7 557.77

193. Ramseur, Anthony (238-34-6315) 
Initial assignment claim 2 159.36

194. Reid, George Lee
Covered on Laborers' List __ __

195. Reid, Harvey E.
Did not work long enough to share __ __

196. Richardson, Alphonso
Covered on Laborers' List

197. Riddick, Cleophus L.
Facts not enough to show discrimi­
nation

198. Riddick, Ernest
Failure to re-assign to lighter work 
when ill; also covered on Laborers'
List 3 239.09

Riddick, Obie (223-20-7699)
Pay claim; also covered on Dock 
Helpers' List 1 79.68

Roberts, Columbus (230-18-8802) 
Loan-out claim 1 79.68

Robinson, Benny A. (227-48-3970) 
Initial assignment claims 1 79.68

202. Rodgers, Robert L.
Did not work long enough to share

203. Roscoe, Horace G.
Covered on Loss-of-Seniority List

Claims

1 7 9 . 6 8



CAUTION: SOME TAXES MUST BE WITHHELD.-23-

Points

2 0 k . Roscoe, Isaiah L.
Did not work long enough to share

205. Sanderlin, Henry L.
Did not work long enough to share

206. Savage, Gerald Lee
Covered on Dock Helpers’ List

207. Sawyer, William (230-66-2986)
Failure to reassign when
health so required 3

208. Scott, William E., Jr.
Did not state a claim

209. Short, Willie C.
Covered on Laborers' List; 
facts as to other claims do not 
show discrimination within a recent 
enough period —

210. Simmons, Duke (231-03-7038)
Failure to promote claim for
period recent enough to allow
recovery 2

2 1 1. Simms, Willie R.
Covered on Paint Laborers' List

212. Simon, John, Jr.
Facts do not show discrimination

213. Simon, Sinclair
Facts do not show discrimination

2\k. Slight, Charles E.
Covered on Dock Helpers' List

215. Smith, Helen N. (228-52-3369)
Antagonism claim 2

216. Southall, Mack, D., Jr.
Facts not enough to show discrimination

217. Smith, John E. (238-20-9383)
Initial assignment claim 8

218. Sparrow, George R.
Facts not enough to show discrimination 

218a. Sparrow, Marvin L. Discharge ulaim 3
219. Speight, Joseph C.

Covered on List of Plaintiffs
220. Spencer, Clarence

Facts not enough to show discrimination

221. Spires, Eugene R. (423-52-5447)
Initial assignment claims and recall 
claim k

222. Spraggins, James E.
Covered under Laborers' List

223. Spraggins, Willie L. (230-52-7619)
Layoff claim

Estimated
Amounts for Claims
On this List

#239.06

159.36

159.36

637.45

239.04

318.73

1 79.68



-24-
CAUTION: SOME TAXES MUST BE WITHHELD.

Points

224. Spruill, Larry E.
Covered on List of Plaintiffs —

225. Steeley, Clarence C.
Covered on List of Laborers —

226. Stevens, William H.
Covered on List of Dock Helpers —

227. Stevenson, Wylie, Jr. (231-34-1330)
Failure to promote claim; also
covered on Dock Helpers' List 2

228. Stevenson, Richard 0.
Did not work long enough to share —

229. Stevenson, Sylvester (227-12-5995)
Initial assignment claim 1

230. Stokley, Joe N.
Did not work long enough to share —

231. Stokes, William A.
Facts not enough to show discrimination —

232. Stokley, Roy L.
Covered on Dock Helpers’ List —

233. Stokley, Willie L.
Covered on Dock Helpers' List —

234. Sturdivant, Pursell (251-56-2468)
Loan-out claim; also covered on 
Laborers' List 1

235. Surratt, Charles H.
Facts not enough to show discrimination —

236. Sykes, Timothy D. (228-60-8386
Loan-out and apprenticeship claims;
also covered on Laborers' List 2

237. Taylor, Leroy I.
Facts not enough to show discrimination —

238. Taylor, Randolph (223-72-9104)
Claim of recall discrimination
and deprivation of training opportunities 1

239. Thompson, Henry L.
Facts not enough to show discrimination —

240. Thornhill, Ima J. (045-34-5765)
Promotion and layoff claims 1

241. Thornton, Carlton E.
Covered on Laborers' List

242. Tilghman, Wesley
Covered on Dock Helpers' List —

243- Tillmon, Theodore (432-32-4658)
Initial assignment claim 2

244. Tyler, Samuel V.
Failure to transfer; also covered 
on Dock Helpers' List

Estimated
Amounts for Claims
On This List

#159.36

79.68

79.68

159.36

79.68

79.68

159.36

1 7 9 . 6 8



-25-
c au t i o n : SOME TAXES MUST BE VITIfHELi).

Points
2'*5. Vaughn, Alvester, Jr. (223-56-0857)

Initial assignment and failure to
promote claims 2

2^6. Ward, David
Covered on Laborers’ List and on
Labor Helpers' List —

247. Ward, Dewey It.
Did not work long enough to share —

248. Waters, Lloyd T.
Did not work long enough to share —

249. Whidbee, Roger L.
Facts not enough to show discrimi­
nation —

250. White, Edward B.
Racial antagonism claim 1

251. White, Edward D.
Covered on List of Plaintiffs

252. White, J. Alexander
Covered on Dock Helpers' List —

253. Whitehurst, Luther A., Jr. (243-42-2490)
Initial assignment claim 1

254. Whitehurst, Melvin R.
Covered on Dock Helpers' List

255. Wiggins, Cecil
Initial assignment claim not within 
a recent enough period; is covered on 
Laborers' List and on Truck Drivers'
List .—

256. Wilkins, Patrick E. (230-68-6397)
Apprenticeship claim 1

257. Williams, Calvin R.
Did not state any claim —

258. Williams. Charlie A.
Covered on Laborers' List

259. Williams, Donnell R. (238-72-9237)
Initial assignment claim 1

260. Williams, Elwood N. (243-42-7409)
Racial antagonism claim 1

261. Williams, James L.
Did not work long enough to share —

262. Williams, Leroy (231-09-7351)
Allocation of work claim 1

263. Williams, Luther B.
Did not work long enough to share

264. Williams, Mamie W. (228-20-3081)
Layoff claim; also covered on 
Janitors' List

8159.36

Es(i ma ted
Amounts for Claims
On 'Hiis hist______

79.68

79.68

79.68

79.68

79.68

79.68

1 79.68



CAUTION; SOME TAXES MUST BE WITHHELD.
Estimated
Amounts for Claims

Points On This List______

265. Williams, Martha D. (231-09-2914)
Layoff,recall and discharge claims 6 i 478.09

266. Williams, Roland (241-48-5202)
Failure to promote claim; also on 
Dock Helpers’ List 2 159.36

267. Williams, Wesley T.
Covered on Laborers’ List — —

268. Williams, William H. (225-28-3159)
Discouragement of transfer; also 
covered on Dock Helpers' List 1 79.68

269. Wilson, Edward Leon
Did not work long enough to share — —

270. Wilson, Frank L.
Did not work long enough to share — —

271. Winborne, Delmus D. (225-74-8938) 
Apprenticeship; layoff and 
antagonism claims 2 159.36

272. Winfield, Henry L.
Facts not enough to show discrimi­
nation during the short period of 
time employed

273. Winnegan, Wardell (229-30-5i*49) 
Failure to promote claim 2 159.36

274. Winslow, James, Jr.
Did not work long enough to share — —

275. Wood, Lawrence (229-5^-1051)
Loan-out and failure to promote 
claims; also covered on Laborers' List 5 398.41

276. Young, Arthur
Did not work long enough to share

TOTAL: 251 8 20,000.00



-27-

LIST 2
Black Persons Who Lost Six or More Months 
Transferring Departments (Excluding Other 
With Less Than Six Months Lost)

' Seniority in 
Transfers

Name
Months’ Seniority 
Lost on Transfer

Estimated Minimum 
Amounts of Back Pa

Albert Amos 65 $217.39
*C. Baker 16 53.51
*Dallas Battle 16 53.51
*P. K. Boykins 24 80.27
C . R . Brown 7 23.42
R. L. Cherry 13 43.48

*Howard S. Claggion 14 46.82
James Collins 89 297.66

*C. Copeland 21 70.23
Eddie Cox k2 140.47
H. A. Farrell kO 133.78
*George Foy 23 76.92
M. L. Futrell 83 277.59
*Walton B. Heckstall 13 43.48
*W. J. Hill 125 418.06
A. C. Howell 56 187.29
*Roosevelt Johnson 15 50.17
*John L. Kelly 33 110.37
*Mitchell 0. Mack 30 100.33
L. D. Madison 27 90.30

*Daniel Mann 17 56.86
Augustus Mayfield 13 43.48
R. L. Owens 35 117.06
*W. H. Reich 10 33.44
J. R. Robertson kk 147.16
S. N. Robinson 39 130.43
H. G. Roscoe 31 103.68
*R. R. Roscoe 23 76.92
J. McC. Ruffin 115 384.62
R. L. Ruffin 115 384.62
*J. E. Smith 61 204.01
R. L. Stancil 17 56.86
R. D. Stokley 60 200.67
V. L. Tolliver 12 40.13
Wesley T. Williams 29 96.99
A. McC. Wilson 11 36.79
J. M. Winfield 41 13 7.12
*J. Wright, Jr. 70 234.11

TOTAL MONTHS 1,495 $5,ooo!oo

CAUTION: SOME TAXES MUST BE WITHHELD



-28-

3. LIST OF PRESENT AND FORMER LABORERS ELIGIBLE 
TO SHARE IN THE BACK PAY SETTLEMENT FOR TIME 
WORKED AS LABORERS

See Appendix B for an explanation of the means used to 

determine which present and former laborers are eligible 
to share in the back pay settlement for the time they worked 

as laborers, and the means used to calculate their share.
CAUTION: The "estimated amounts of back pay" are only

estimations. It may be a little larger or a little smaller. 

Persons marked with an asterisk (*) before their name must 

send a postcard to the attorneys for plaintiffs by the 

deadline or they will lose their rights to receive money, 

and everyone else’s share will be increased accordingly.

If you see any mistakes in this table, notify the attorneys 
for plaintiffs as soon as possible since nothing can be done 

about the mistake after the final calculations have been 

made. Check for your name on other lists as well.

Name

Social
Security
Number

*Adams, George Westley, Jr. 122-40-6923
Alston, Stanley, Jr. 240-60-2816
Amos, Albert 224-40-1608
Askew, Bennie-^/ 224-54-5087
Askew, Bernard 227-48-4697
Anderson, James Roosevelt 224-54-5408

♦Baker, C. 230-07-1363
♦Battle, D. 237-50-2474
*Batts, T.E. 224-50-2660

♦Beale, R.S. 226-22-6729
Beamon, Jerry 239-48-8290

♦Berger, L.C. 224-34-8959
♦Biggs, W.H. 239-28-3200

Total 
Months 
Worked As 
Laborer 
From July 
1965 To 
April 1973

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Laborers

45 $ 1 6,901.66 *233.67
76 33,553.33 463.88
14 6,723.30 92.95
88 41,722.00 576.81
80 34,703.46 479.78
49 1 9,165.71 264.97
16 9,019.41 124.69
15 5,841.59 80.76
63 24,900.66 344.25
14 3,903.15 53.96
76 35,428.70 489.80
14 4,332.43 59.90
12 4,045.68 55.93

j JIncludes time spent as janitor.

CAUTION: SOME TAXES MUST BE WITHHELD.



CAUTION; SOME TAXES MUST BE WITHHELD.
-29-

Name

Social
Security
Number

*Blue, Lionel 231-44-5882
Blunt, Charles Fulton 228-09-2045
*Boone, A.L. 238-48-7856
Booth, Alpheus Thower 227-26-5555
Bostic, Charles Edward 411-26-4158

*Boston, W.R. 237-62-7531
*Bowers, Lonnie L. 228-62-1778
*Bowman, B.F. 228-64-0886
*Bowser, E. 240-68-0505
*Boykins, P.K. 225-56-0832
*Brock, A. 227-48-4005
Brock, Richard Oliver 228-36-5783
Brown, Curtis 226-34-0460
Brown, Harvey 245-07-4891
Brown, James Samuel 225-12-5152

*Brown, L.K. 248-26-4144
Brown, Oscar 263-60-6107
Brown, Serge 227-12-6115

*Burgess, F.M. 243-40-6280
Burrell, Ernest 229-10-7134
Butler, Tommie Lee 224-40-1786

*Bynum, A.E. 231-72-0461
Cameron, Lonzia 237-22-5662
Carroll, William Henry 241-40-4911
Cherry, Joseph Edward 238-20-8328
Cherry, Roosevelt L. 243-50-0115

*Chisolm, J.F. 249-36-5713
*Claggion, H.S. 228-60-7984
Collins, James 254-54-6917
*Copeland, A. 226-40-7813
Cox, Ernest Linwood 229-44-1068
*Dale, C.M. 246-40-8224
*Davis, J. 227-50-6746
*Davis, R.C. 223-52-5314
*Duke, H. 231-01-1487
Dunston, Raymond 231-09-7613
Eason, Willis Augustus, Jr. 238-48-8865
*Etheridge, B. 246-54-5712
Evans, Leroy 231-10-3189
Farrell, Henry Alexander 225-60-6193

*Fenderson, L. 224-30-5614
*Fisher, J.R. 231-34-0376
*Foy, G. 230-52-6400
*Franklin, C.D. 226-56-8366

Total 
Months 
Worked As 
Laborer 
From July 
1965 To 
April 1973

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Laborers

28 # 10,697.73 #147.90
94 48,059.13 664.42
48 1 5,037.33 207.89
94 36,719.11 507.64
44 14,892.87 205.89

3 1,084.89 15.50

65 26,574.78 367.40
36 12,147.25 167.94
46 1 3,155.49 181.87
25 10,429.95 144.19
66 24,514.65 338.92
76 41,810.48 578.03
86 39,700.39 548.86
94 50,719.70 701.20
94 43,558.03 602.19
53 1 7 ,969.43 248.43
1 399.75 6.05

80 44,273.42 612.08
34 21,033.00 290.78
94 47,285.90 653.73
80 35,061.25 484.72
20 6,221.89 86.02
61 28,094.51 388.41
94 43,824.78 605.88

77 33,248.51 459.66
22 8,129.52 112.39
32 1 2,060.44 166.74

23 7 ,451.91 103.02
42 20,719.59 286.45
48 18,884.89 261.08
82 29,096.71 402.26
52 18,249.67 252.30
46 18,779.08 259.62
42 15,949.85 220.51
47 24,576.04 339.76
64 37,075.00 512.56
39 1 7 ,663.10 244.19
2 505.71 7.49

54 26,103.14 360.88

33 1 3,773.53 190.42
11 4,176.40 57.74

34 13,303.88 183.93
14 5,586.30 77.23
21 8,100.12 111.98



CAUTION': SOME TAXES MUST BE WITHHELD.
-30-

Name
Social
Security
Number

Total 
Months 
Worked As 
Laborer 
From July 
1965 To 
April 1973

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Laborers

Freeman, John Henry 239-07-8723 54 8 28,480.41 #393.74
Freeman, Linwood Willie 231-26-6665 54 30,911.04 427.35
Freeman, William E. 231-07-9312 54 22,710.22 313.97
Futre.l 1 , Moncure Lazurs 231-40-3912 33 12,940.50 178.90
Gabriel, Hezekiah 237-20-4936 78 39,679.20 548.57
*Gallop, L . M . 238-78-9013 31 12,516.73 173.04
'Goldman, W., Jr. 227-32-1359 32 12,851.52 177.67
*Goodman, W . T . 223-44-3796 67 28,980.19 400.65
Gordon, Edward J. 228-52-4854 51 22,166.29 306.45
Gray, Butler G. 248-14-3086 25 10,670.7s 147.52
*Gri f fin, D.E., Jr. 238-72-9649 42 13,211.54 182.65
*Griffin, D.H. 241-48-5211 47 18,201.42 251.64
Griffin, Mi ttet 239-42-6876 78 40,554.88 560.67
Guy, Leonard Louis 225-46-8707 75 44,827.97 619.75
Hampton, E. J. 227-66-5829 36 10,986.68 151.89
Harris, J.E. 246-64-0624 45 17,628.78 243.72
Harris, Joseph Lonsfels 239-44-5648 94 40,900.31 565.45
Harris, Luke, Jr. 224-26-0992 25 12,474.84 172.47
Haskett, William J. 226-56-8362 12 3,579.21 49.48
Hawkins, Lee Wesley 227-50-5494 40 15,223.24 210.46
*Hayes, J .F. 225-68-6448 19 6,370.93 88.08
♦Heekstall, W.B. 226-34-2009 14 4,827.61 66.74
*Henderson, E. 242-60-1082 32 12,661.35 175.04
*Hil1, W. J. 231-10-0386 14 6,295.00 87.03
Holliday , Jay Connie 231-18-8771 26 9,639.37 133.26
*Hunter, R.R. 227-42-7245 22 17,112.28 236.58
Hunter, Walter Benjamin 228-20-8032 49 20,502.64 283.45
*Huskey, W.A., Jr. 229-22-8692 30 10,618.32 146.80
Jacobs, Junius 249-34-5096 93 55,404.58 765.97
James, Jessie 227-52-2756 80 41,739.89 577.05
Jenkins, James Thomas 223-56-4925 63 28,498.75 394.00
Jenkins, Jessie Joshua 

Sylvester 223-63-5964 60 33,193.15 458.90
*Jennings , R.W. 230-66-4402 22 4,693.57 64.89
Johnson, John Richard, Jr. 245-20-6280 14 4,853.91 6 7.11
Jones, Alvin 227-50-7213 36 18,287.89 252.83

*Jones, C .P. 231-09-0328 74 22,998.45 317.95
Jones, George Columbus 229-30-4201 46 23,595.10 326.20

*Jones, T 227-14-6134 72 28,858.82 398.97
Jordan, Arteal 227-50-5271 64 26,216.56 362.44

*King, L. 225-58-3069 19 6 ,262.79 86.58
*Lancaster, R. 238-28-0491 28 8,959.49 123.87
Lee, Robert Edward 230-56-2225 92 40,982.64 566.59
Lewis, C 231-01-3825 16 1,829.69 25.30



CAUTION; SOME TAXES MUST BE WITHHELD.

Name
Lynch, Willie P.
MeClaud, James Edward 
"McClease, John Henry 
McOleese, Frederick Hazeitt 
Madison, Alien Harold 
Madison, L.D.
Majette, G.
''■Mann, D.W.
Marrow, James E.
"Mason, G.
Mathis, M.F.
Mayfield, A.
*Mayo, C .V .
"Mitchell, II.L.
Moseley, Glenn Kirby 
Newby, William Franklin 
Newton, Amos 
*01(18, P.J.
O'Neal, Moses 
Parker, Eldridge 
Parker, Louis 
Peede, Carlton Eugene 

*Peede, T.D.
"Peele, E.
Perkins, Allen Wendell 

*Perry, H.
"Pittman, C.L., Jr. 
"Pittman, M.A.
"Pitts, J.H.
Porter, J.H.
Prayer, Bobby J.

"Prayer, E., Jr.
Pritchard, William Oliver 
Proctor, Will 
Reid, Charlie Edward 
Reid, George Lee 
Richardson, Alphonso 
Riddick, Augustus 
Riddick, E.
"Riddick, W.E.
Roberts, Columbus 
Robertson, J.R.
Robinson, Robert Lee 
Robinson, Samuel Nathaniel

Total 
Months 
Worked As 
Laborer

-31-

Social From 
Security 1965 
Number Apri

July
To

1 1973

223-56-269'* 37
229-22-5652 28
231-26-1577 87
225-52-7336 95

227-68-5730 55
223-64-5889 29
238-70-2^50 2
228-20-2596 15
228-32-5690 46
228-60-9853 52

221-20-9777 13
225-60-9231 14
223-52-3^89 35
228-36-7020 23
225-60-6950 22
253-16-0355 74
239-56-3618 57
223-72-4582 32
231-44-7482 84
231-35-5165 4
223-34-2791 39
227-56-5585 26

225-58-3356 29
251-16-3919 50
230-56-1627 82
23I-IO-O9IO 67
225-60-8876 37
230-58-7526 9
254-18-5519 25
251-65-5783 16

230-68-5252 61

230-56-2212 12
225-58-4155 74
705-16-5359 14
212-28-5836 25
228-36-6575 64
227-68-6555 60
231-50-0673 79
231-07-0391 15
706-07-5151 67
230-18-8802 69
225-58-3329 55
225-52-8769 13
223-60-2750 18

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Laborers

9 1 5,635.92 8202.35

9,171.89 126.80
35,556.36 576.36
43,928.64 607.31
1 5,653.25 216.41
11,017.70 152.32

1,079.27 14.92
5,307.47 73.38

18,457.53 255.18
17,148.38 237.08
4,626.85 63.97
6,068.97 83.90

12,858.99 177.78
7 ,659.97 105.90
8,272.89 114.37
37,398.53 517.03
23,454.38 325.26

1 2,688.79 175.42
44,132.30 610.30
1,293.38 17.88

1 5,372.20 212.52
8,625.95 119.24

11,763.70 162.63
18,121.01 250.52
25,974.82 359.10
27,843.95 384.94
13,725.97 189.76

3,571.65 48.00
10,949.52 151.38
7,773.85 107.47

26,823.00 370.83
3,537.29 48.90

35,377.82 475.27
5,111.50 70.67

13,555.77 187.41
29,283.55 404.85
25,337.57 350.29
38,706.85 535.12

3,975.59 55.95
29,315.81 405.29
32,600.18 450.70
26,101.27 360.85
5,269.70 72.85
5,002.56 69.16



CAUTION: SOME TAXES MUST BE WITHHELD.

-32-

Name

Social
Security
Number

Total 
Months 
Worked As 
Laborer 
From July 
1965 To 
April 1973

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Laborers

*Rogers, <J. 249-16-6927 40 $ 1 4,253.51 $ 197.06

Ro.seoe, Horace Gene 223-58-9206 17 6,123.37 89.66
*Roscoe, R.R., Jr. 2311-56-0780 16 6,038.96 83.99
Ruffin, J. McC. 227-48-4619 55 27,412.58 378.98
Ruffin, R.L. 223-44-3956 55 27,923.80 386.05
*Scott, J.W. 227-38-39^5 36 15,272.37 211.14
Sharp, Ernest 229-42-4891 57 37,320.38 515.95

*Shaw, M. 230-18-7692 33 8,858.66 122.47
Short, Willie C. 229-54-4966 13 4,148.23 57.35
Sills, Jesse James 227-14-5817 48 30,513.40 421.85

*Simon, 0. , Jr. 225-60-8391 12 6,723.93 92.96

Skinner, Melvin Leon 224-50-5918 73 35,307.34 488.12
Smith, Calvin T. 229-42-6937 60 30,790.96 925.69

*Smith, J.E. 227-46-3038 63 39,163.97 472.32
*Speight, C. 238-56-5758 82 23,204.44 320.80
Spellman, James 230-14-1290 48 28,462.74 393.50
Spraggins, Elisha Tune 228-50-3059 23 12,161.75 168.14
Spraggins, James E. 229-52-4843 56 23,167.12 320.29

*Spruill, C.E. 223-44-7141 10 4,180.86 57.80
Stancil, Robert Lee 241-40-5442 19 7,212.86 99.72
Steeley, Clarence Cecil 228-20-2360 28 8,875.76 122.71
Stokley, Renzie Darling 246-54-7459 43 17,273.12 238.80
Sturdivant, Pursell 251-56-2468 70 29,671.27 410.21

*Surratte, F.J. ClClLfN1COC)in-3*Cl 36 10,794.50 199.23
*Swinton, A. 251-03-8304 12 5,807.32 80.29
Sykes, Timothy Dale 228-60-8386 36 13,652.32 188.74
Thorne, Boyce 245-16-3885 93 42,732.45 590.78
Thornton, C.E. 238-78-9001 10 7,148.87 98.83
*Tillar, J.E. 227-26-5264 52 1 6,229.76 224.38
*Toeny, J. 422-46-8068 29 10,467.59 144.71
*Towe, R.E., Jr. 225-56-0802 12 3,726.07 51.51
Trotman, John 231-07-0819 94 37,679.98 520.93
Turner, Henry 229-09-8353 86 A6,819.38 647.28
Walker, Ernest E. 225-36-0430 89 96,091.91 636.53
Walton, Dempsey, Jr. 228-36-1504 94 38,969.90 538.76

*Walton, M. 230-22-1309 33 9,424.18 130.29
Wa rd, D . 225—2b—7666 11 3,251.49 44.95
*Webb, L.W. 237-30-2368 23 7,963.09 103.18
‘White, F. 244-52-0577 16 6,198.82 85.70
*White, W. 242-22-0443 36 20,927.39 289.32
''Whitehead, T.M. 230-46-4234 12 6 ,372.57 88.10
Whitten, Calvin Vinson 227-46-7414 86 39,023.65 539.50
Wiggins, Cecil 227-14-7931 3 1,393.52 21 .34



CAUTION; SOME TAXES MUST BE WITHHELD.

-33-

Social

Total 
Months 
Worked As 
Laborer 
From July

Amount
Earned

Estimated 
Back Pay 
For Time

Security 1965 To During Worked As
Name Number April 1973 This Period Laborers

Williams, Charlie Alphonso 118-30-332/1 89 37,505.27 518.51
Williams, George M. 242-50-4407 94 40,392.79 558.43
*Wil liams, J.C. 238-46-1863 46 20,590.56 284.66
Williams, James Elliott 225-60-6559 49 25,904.91 358.14
*Williams, P. 238-40-5517 42 20,046.28 277.14
Williams, Percy 238-36-5516 94 37,016.11 511.75
Williams, Raleigh, Jr. 243-28-3395 37 14,721.97 203.53
Williams, Wesley Theodious 224-44-7448 16 5,694.84 78.73
Wilson, Ralph 719-14-4828 13 4,655.95 64.37
*Wilson, R.E. 230-56-0067 42 13,465.78 186.16
Wilson, Samuel 230-07-1060 32 11,836.57 163.64
Wilson, William Augustus 227-50-5705 71 42,720.48 590.61
Winfield, J.M. 225-58-3940 41 16,428.92 227.13
*Wood, J.A. 228-32-3419 52 18,172.60 251.24
Wood, Lawrence 229-54-1051 . 66 3 7,727.26 521.58

Totals; 9173 43,992,985.5'! $55,204.64



-34-

4. LIST OF PRESENT AND FORMER PAINT AND TRACK 
LABORERS ELIGIBLE TO SHARE IN THE BACK PAY 
SETTLEMENT FOR TIME WORKED AS LABORERS

See Appendix B for an explanation of the means used to 

determine which present and former laborers outside of the 

labor department are eligible to share in the back pay 

settlement for the time they worked as laborers, and the 

means used to calculate their share.
CAUTION: The "estimated amounts of back pay" are only

estimations. It may be a little larger or a little smaller. 

Persons marked with an asterisk (*) before their name must 

send a postcard to the attorneys for plaintiffs by the 
deadline or they will lost their rights to receive money, 

and everyone else's share will be increased accordingly. If 

you see any mistakes in this table, notify the attorneys for 

plaintiffs as soon as possible since nothing can be done 

about the mistake after the final calculations have been made. 

Check for your name on other lists as well.

Social
Security
Number

Total 
Months 
Worked As 
Laborers 
From July 
1965 To 
April 1973

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Laborers 
Outside of the 
Labor Dept.

♦Cohen, Willie A. 248-92-5233 14 $ 5,609.69 $. 54.29
Deloatch, Franklin 

Roosevelt 227-44-5575 27 10,746.14 104.00
♦Fisher, J.E. 230-40-2754 14 9,962.19 96.22

*Hill, W.J. 231-10-0386 48 19,738.91 191.03
Johnson, John 

Richard, Jr. 245-20-6280 20 10,376.52 100.42
O'Neal, M. 231-44-7482 5 2,055.86 19.94

♦Morning, L.J. 238-09-6138 55 17,826.00 172.53
*Person, E.L. 231-16-0119 17 9,211.77 89.15
Proctor, Will 704-16-4359 48 19,413.18 187.88
Sawyer, Claude 237-74-1616 34 13,824.01 133.79
Simms, W.R. 225-56-2613 21 12,322.81 119.20

♦Spruill, Cleveland 227-38-3605 27 8,895.61 86.09

Totals: 336
months

#139,963.29 #1 ,559.60

CAUTION: SOME TAXES MUST BE WITHHELD.



-35-

CAUTION: SOME TAXES MUST BE WITHHELD.

5. LIST OF PRESENT AND FORMER LABOR HELPERS ELIGIBLE 
TO SHARE IN THE BACK PAY SETTLEMENT FOR TIME 
WORKED AS LABOR HELPERS

See Appendix B for an explanation of the means used to 
determine which present and former labor helpers are eligible 

to share in the back pay settlement for the time they worked 

as labor helpers, and the means used to calculate their share.
CAUTION: The "estimated amounts of back pay" are only

estimations. It may be a little larger or a little smaller. 
Persons marked with an asterisk (*) before their name must 

send a postcard to the attorneys for plaintiffs by the dead­

line or they will lose their rights to receive money, and 

everyone elsefs share will be increased accordingly. If you 

see any mistakes in this table, notify the attorneys for 

plaintiffs a£ soon as possible since nothing can be done about 

the mistake after the final calculations have been made.
Check for your name on other lists as well.

Name

Alston, Stanley, Jr. 
Askew, Bernard 
Baker, McConnell 
Beamon, Jerry 
Brock, Richard Oliver 
Brown, Curtis 
Butler, Tommie Lee 
Dunston, Raymond
Eason, Willis 

Augustus, Jr.
Freeman, John Henry 
Guy, Leonard Louis 
James, Jessie 
*Lee, William Me. 
McCloud, James E. 
Roberts, Columbus 

*Roscoe, R.R., Jr.

Social
Security
Number

Total 
Months 
Worked As 
Labor 
Helpers 
From July 
1965 To 
April 1973

240-60-2816 18
227-48-4697 8
243-50-7408 15
239-48-8290 18
228-36-5783 18
226-34-0460 8
224-40-1786 7
231-09-7613 18

238-48-8865 20
239-07-8723 40
225-46-8707 7
227-52-2756 14
226-36-3663 24
229-22-5652 42
230-18-8802 25
230-56-0780 4

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Labor Helpers

$ 8,061.73 $ 44.59
3,779.10 20.90
9,679.18 53.54

12,035.54 66,57
12,012.53 66.44
4,416.22 24.43
3,457.46 1 9 .12
9 ,693.50 53.61

22,463.24 124.20
27,326.48 151.14
6,056.08 33.50
8,518.36 4.7.12
8,807.01 48.71

1 6,700.92 92.34
1 4,491.95 80.16

618.97 3.42



-36-

CAUTION: SOME TAXES MUST BE WITHHELD.

Name

*Simon, A.
Smith, Calvin T.
Smith, William Penn 
Turner, Henry 
Whitten, Calvin Vinson 
Williams, James Elliott 
Wilson, William Augustus 
Wood, Lawrence

Social
Security
Number

Total 
Months 
Worked As 
Labor 
Helpers 
From July 
1965 To 
April 1973

227-58-1693 14
229-42-6837 18
245-05-6325 9

8
227-48-7414 8
225-60-6559 8
227-50-5705 8
229-5^-1051 8

Totals: 367

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Labor Helpers

$ 5,802.18 $ 32.09
10,802.64 59.75
6,244.61 34.54
4,969.75 27.49
4,417.78 24.43
4,644.66 25.69

10,377.88 57.40
3,539.30 19.58

1218,917.07 $1,210.76



-37-

6. LIST of p re se n t a n d f o r m e r doc k h e l p e r s e l i g i b l e 
TO s ha re in t h e bac k pay s e t t l e m e n t for t i m e 
w o r k e d a s d o c k h e l p e r s

See Appendix B for an explanation of the means used to 

determine which present and former dock helpers are eligible 

to share in the hack pay settlement for the time they worked 
as dock helpers, and the means used to calculate their 
share.

CAUTION: The "estimated amounts of hack pay" are only-
estimations. Tt may he a little larger or a little smaller. 
Persons marked with an asterisk (*) before their name must 

send a postcard to the attorneys for plaintiffs by the 
deadline or they will lose their rights to receive money, 

and everyone eise's share will be increased accordingly.

If you see any mistakes in this table, notify the attorneys 

for plaintiffs a_s soon as possible since nothing can be done 

about the mistake after the final calculations have been 
made. Check for your name on other lists as well.

Name

*Alford, E.B.
Armstrong, Embria Hamilton 
*Barber, H.L.
*Barber, J.
*Barber, T.
Barnard, Pearlie Lee 
Blow, Wesley Eugene 
Boone, Wrillie 
Booth, Joseph 

*Boston, W.R.
*Branch, U.
Branch, Willie 
Brinkley, Curtis Mayo 
Brite, Lenial Mertis

Total 
Months 
Worked As

Social 
Securi ty 
Number

Dock Helpc rs 
From July 
1965 To 
Dec. 1970

228-38-2592 31
239-20-8034 47
227-56-4567 25
224-50-0389 13
228-36-0869 43
229-54-1383 13
225-42-1067 41
223-52-2633 29
227-56-2674 26

237-62-7531 9
224-66-2192 29
223-60-3517 36
244-62-5493 31
243-42-2455 31

Amount 
Earned 
During 
This Period

Est i ma ted 
Back Pay 
For Time 
Worked As 
Dock Helpers

8 13,212.57 73.07
20,180.20 111.60
10,733.36 59.36
2,435.09 13.47

17,712.49 97.95
6,282.04 34.74

18,342.40 101.43
12,515.95 69.21
10,167.75 56.23
2,382.97 13.18

10,898.98 60.27
15,903.30 87.95
16,284.35 90.05
19,788.57 109.43

CAPTION: SOME TAXES MUST BE WITHHELD.



CAUTION: SOME TAXES MUST BE WITHHELD.
-38-

Name
Social
Security
Number

Total 
Months 
Worked As 
Dock Helpers 
From July 
1965 To 
Dec. 1970

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Dock Helpers

Brown, Charles Roland 719-07-1182 18 0 5 ,253.45 9 29.05
*Brown, James 228-64-0771 22 4,644.55 25.68
Brown, Lorenzo Preston, Sr. 409-14-7794 41 18,287.88 101.13
Brown, Oscar 263-60-6107 19 12,231.29 6 7.64

*Cleveland, W.G. 260-68-9497 23 9,233.87 51.06
*Copeland, A.J., Jr. 224-54-2019 19 4,827.18 26.69
Copeland, Coley, Jr. 228-52-2562 36 1 3,622.78 75.33
*Copeland, P.S. 223-60-4971 21 9,349.82 51.71
Daniels, Edward B. 225-28-7925 16 9,420.79 52.10
Dawkins, Elford, Jr. 223-44-7260 15 4,532.11 25.06
Eason, Wayne Randolph 240-62-6670 21 10,828.61 59.88
Elliott, J.D. 227-50-5760 36 17,585.68 97.25

*Etheridge, B. 246-54-5712 20 7,118.91 39.37
*Evans, M.V. 244-48-3131 58 21,449.80 119.62
*Evans, W. 223-44-5488 12 4,810.00 26.60
*Evans, W.F. 238-46-6297 26 14,075.13 77.84
Faulk, David Thomas 224-50-1734 48 24,644.65 136.29
*Faulk, J.R. 225-46-9041 20 9,067.89 50.15
Ford, Robert, Jr. 228-34-6058 21 12,907.05 71.38
Garrett, Clarence Monroe 231-50-0086 19 8,250.15 45.62
Gee, Leo 241-28-3543 29 14,414.19 79.71
Gibbs, Samuel E. 245-20-0331 31 15,230.84 84,23
*Griffin, B., Jr. 237-60-8315 15 7,914.60 43.77
Griffin, Ervin Roland 240-56-5076 21 12,470.78 68.96
Griffin, McRay 241-40-2516 37 23,322.79 128.98
Griffin, William R. 243-38-8870 37 22,840.12 126.31

*Hargrove, R.H. 223-60-4916 28 10,573.03 58.47
*Henderson, E. 242-60-1082 22 9 ,827,62 54.35
*Hike, S.J. 226-22-3110 31 15,095.74 83.48
*Hinton, George H. 242-50-4316 20 9,813.52 54.27
*Hogans, M.I. 243-40-2633 12 3,899.50 21.56
Hopson, Robert Earl 224-50-5496 13 7 ,029.65 38.87
Hopson, William Ruffin 225-46-8949 14 7,490.03 41.42
^Howard, J.M. 224-50-3883 44 17,874.97 98.85
*Jackson, J.E. 231-44-5956 35 1 4,645.07 80.99
*Jenkins, H. 230-22-4619 13 3,848.52 21.28
Johnson, William Amos 225-20-4626 59 3 7,174.36 205.57
Johnson, Willie Lee 226-40-9822 29 1 6,567.38 91.62
*Jones, V.A. 230-58-9554 34 1 2,257.88 67.79
Kirby, Ditarine 226-22-5878 29 1 1 ,999.60 66.36
Lancaster, James E. 239-28-2976 40 24,177.08 133.70



CAUTION: SO.ME TAXES MUST DE WITHHELD

-39-

Name

Social
Security
Number

Total 
Months 
Worked As 
Dock Helpers 
From July 
1965 To 
Dec. 1970

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Dock Helpers

*Laurey, W.J. 228-52-3907 19 $ 7 ,523.99 * 41.61
Long, Charlie Lee 229-22-7779 31 16,276.14 90.01
Long, William Andrew 241-34-7092 53 24,386.18 134.86

*Lovick, J.F. 220-09-0302 41 14,398.17 79.62

McCoy, Linwood Franklin 239-40-4758 31 1 6,395.70 90.67

McCoy, Woney 24 3-42-036'! 31 22,466.16 124.24
McKinnon, Cezar, Jr. 241-24-9454 29 15,164.37 83.86
Majette G. 238-70-2450 29 1 2,046.69 66.62
*Marshall, D.D. 230-58-5163 25 9,754.95 53.95
*Martin, G.W. 229-22-9657 16 7,172.56 39.66
*Martin, W.K. 231-01-1198 38 15,445.48 85.41
Mitchell, Melvin Lee 226-34-4603 31 15,540.49 85.94
*Mitehell, O.E. 223-52-6271 15 6,686.67 36.98
*Mitchell, S. 23S-46-9616 27 17,580.53 97.22
*Moseley, J., Jr. 238-64-3269 16 6,406.75 35.43

*0’Neal, F. 242-14-6208 19 4,981.65 27.55
*Peterson, Q. 230-46-4654 20 8,069.98 44.63
Phillips, Willie Edwards 243-64-7272 41 23,615.84 130.60

*Pittman, M.A. 230-58-7426 5 1,488.73 8.66
*Pope, William L. 223-38-6935 31 14,117.92 78.07
*Porter, W.B. 223-34-4984 14 4,237.30 23.43

Powell, Garfield 238-56-7318 25 1 3,049.63 72.16

*Rattler, Melvin Lee 227-72-5901 38 16,376.64 90.56

Riddick, Obie 223-20-7644 42 20,026.11 110.74
*Roach, B. 246-44-1489 65 41,411.80 229.01
Savage, Gerald Lee 225-62,4663 20 8,123.72 44.92

*Simmons, J.R. 245-54-0831 63 25,951.47 143.5 1
*Skeeter, Frederick 230-07-3222 16 4,040.78 22.35
Slight, Charles E. 224-40-2656 23 12,230.20 67.63

Smith, Eugene Fields 228-34-9711 4 6 23,253.94 128.59
Smith, Velma 250-30-4979 27

00vOt-'Nt-~ 95.76

*Spruill, C.E. 223-44-7141 7 3,156.41 17.46
Stevens, William Henry 224-30-8368 15 8,161.81 45.14

*Stevenson, C. 227-48-4945 31 1 5,800.56 87.38
Stevenson, Wylie, Jr. 231-34-1330 26 1 3,115.24 72,53

*Stiff, J.C. 228-62-2400 20 8,206.64 45.38
Stokley, Melvin McClese 067-32-7050 19 6,485.20 35.86
Stokley, Roy Lee 241-34-6768 56 24,506.82 135.52
Stokley, Willie Lee 237-60-7705 30 12,641.04 69.91
Sykes, Cad 231-34-1607 27 1 7 ,159.95 94.90



CAUTION: SOME TAXES MUST BE WITHHELD.

- 40-

Name
Social
Security
Number

Total 
Months 
Worked As 
Dock Helpers 
From July 
1965 To 
Dec. 1970

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Dock Helpers

♦Sykes, J.L. 228-36-5046 24 * 7 ,437.97 $ 41.13
♦Teamer, A.K. 231-01-2193 45 17,318.98 95.77
Telfair, R.L. 243-20-1097 20 6,942.04 38.39
Tilghman, Wesley 243-44-0551 31 14,563.35 80.54

*Towe, R.E., Jr. 225-56-0802 1 840.25 5.15
Walton, Sherman Lee 223-48-4470 31 18,029.26 99.70
Ward, David 225-28-7668 8 1 ,919.62 11.05
♦Washington, M.G. 247-34-0961 63 26,398.39 145.98
White, Earl Junior 240-56-5017 31 20,115.63 111.24
♦White, G.L. 228-18-7623 21 7,642.79 42.27
White, James Alexander 241-48-5364 31 1 7 ,561.37 97.11
♦White, J.D. 225-09-5313 37 19,548.29 108.10
♦White, J.L. 224-38-8801 27 10,439.20 57.73
♦White, R.L. 228-32-3613 27 10,412.69 57.58
White, Samuel, Jr. 231-50-0324 29 1 3,220.31 73.11
Whitehurst, Melvin R. 229-22-4780 51 25,019.09 138.36
♦Whitfield, J.F. 228-20-3279 22 11,427.17 63.19
♦Wiggins, E.M. 225-09-7238 17 5,023.81 27.78
♦Williams, B. 239-48-9146 23 7 ,273.61 40.22
Williams, Ernest 243-20-2330 65 37,514.79 207.46
Williams, James Aaron 243-42-0774 31 1 6,964.51 93.81
♦Williams, M. 243-52-8009 27 9,824.16 54.33
Williams, Roland 241-48-5202 31 16,584.10 91.71
Williams, William Harris 225-28-3159 70 33,787.86 186.85
♦Wilson, J. 225-07-2934 38 17,573.70 97.18
♦Wolfe, J., Jr. 227-50-5036 19 5,888.88 32.57
♦Wright, J., Jr. 229-42-7432 45 26,003.11 143.80

3531 $1 ,657,701.43 #9 ,167.3 7



41-

CAUTION; SOME TAXES MUST BE WITHHELD,

7 LIST OF PRESENT AND FORMER TRUCK DRIVERS ELIGIBLE 
TO SHARE IN THE BACK PAY SETTLEMENT FOR TIME 
WORKED AS TRUCK DRIVERS

See Appendix B for an explanation of the means used to 

determine which present and former truck drivers are eligible 

to share in the back pay settlement for the time they worked 

as truck drivers, and the means used to calculate their share.

CAUTION: The "estimated amounts of back pay" are only

estimations. It may be a little larger or a little smaller. 

Persons marked with an asterisk (*) before their name must 

send a postcard to the attorneys for plaintiffs by the dead­

line or they will lose their rights to receive money, and 

everyone else's share will be increased accordingly. If you 

see any mistakes in this table, notify the attorneys for 

plaintiffs as_ soon as possible since nothing can be done 

about the mistake after the final calculations have been made. 

Check for your name on other lists as well.

Total 
Months 
Worked As
Truck Estimated

Name

Social
Security
Number

Drivers 
From July 
1965 To 
April 1973

Amount 
Earned 
During 
This Period

Back Pay 
For Time 
Worked As 
Truck Drivers

*Baker, Cecil 230 07 1363 22 $ 6961.59 $ 67.37
Brown, Milton L. 228 20 3930 94 49329.ll 377.91
Bryant, J. C. Jr. 225 22 6573 16 6451.09 62.93

*Cherry, L. L. 228 62 0948 14 3910.76 37.85
^Christmas, R. E. 227 68 3780 13 3498.00 33.85
*Copeland, R. H. 231 34 1840 79 24010.27 232.37
Cox, Eddie 426 32 4729 33 16321.61 157.96
Davis, John L. 223 52 4155 94 51886.78 502.04

*Elford, Charlie O'Neal 259 07 7733 79 37752.48 365.37
*Futrell, Moncure Lazurs 231 40 3912 61 28430.28 275.15
Gaddy, Haywood A. 225 60 5955 20 10575.45 102.35
Gordon, Lee Roy 231 10 7602 94 51157.37 495.10

*Hamlin, B. C. 231 10 8220 71 90562.79 392.57
Holley, Ashley 231 39 3924 57 29656.58 287.02

*Hunter, A. J. 225 42 2664 32 15832.28 153.23
*Moore, Eugene 231 40 2519 74 41248.56 399.20
Norfleet, Estes 230 74 3241 29 12724.61 123.15
Parker, David Arthur 231 50 0843 74 33777.69 326.90
Parker, Eldridge 231 34 4165 41 18120.34 175.37

*Simon, Osburn Jr. 225 60 8391 7 2920.41 28.26
Stancil, Clyde Lee 227 52 4670 19 10260.65 99.30
Stancil, Robert Lee 241 40 5442 73 40890.75 395.79
Taylor, L. A. 227 58 9043 36 17678.86 171.10

*Vann, L. S. 224 38 9263 20 7739.58 74.90
*Warren, J. H. Jr. 240 5'* 1110 33 13118.06 126.96
Wiggins, Cecil 227 14 7931 82 40885.91 395.69
^Williams, J. 0. 249 52 5575 12 3085.98 29.87

Totals: 1,279 $61878 7 .7 3 $59S8 .51



-42-

8. LIST OF PRESENT AND FORMER JANITORS/JANITRESSES 
ELIGIBLE TO SHARE IN THE BACK PAY SETTLEMENT 
FOR TIME WORKED AS JANITORS/JANITRESSES

See Appendix B for an explanation of the means used to 

determine which present and former janitors/janitresses are 

eligible to share in the back pay settlement for the time 

they worked as janitors/janitresses, and the means used to 

calculate their share.

CAUTION: The "estimated amounts of back pay" are only
estimations. It may be a little larger or a little smaller. 

Persons marked with an asterisk (*) before their name must 

send a postcard to the attorneys for plaintiffs by the 

deadline or they will lose their rights to receive money, 

and everyone else's share will be increased accordingly. If 
you see any mistakes in this table, notify the attorneys for 

plaintiffs aŝ  soon as possible since nothing can be done 

about the mistake after the final calculations have been made. 

Check for your name on other lists as well.

Total
Months

Name

Social
Security
Number

Worked As 
Janitors/ 
Janitresses 
From July 
1965 To 
April 1973

Amount 
Earned 
During 
This Period

Estimated 
Back Pay 
For Time 
Worked As 
Janitors/ 
Janitresses

Armstrong, Annie E„ 238-78-7861 33 $ 14,224.85 § 196.66

Baker, McConnell 243-50-7408 8 '4,848.90 67.04

*Barnes, F. P. 230-22-0773 13 1,847.56 25.68

Dawkins, Alice Leach 248-22-7641 39 13,588.27 187.86
Epps, Doris Wyatt 227-26-3782 69 25,917.31 358.31
*Fenderson, L. 224-30-5614 13 7 ,676.55 106.13
McClaud, James Edward 229-22-5652 24 10,050.90 138.95
Peoples, Ethel 225-^6-9233 26 6,514.29 90.06

*Pittman, M. I. 231-26-5132 26 9 ,954.62 137.62
Smith, William Penn 2^5-05-6325 76 39,619.52 547.74

*Walden, J. J, 224-38-6886 29 13,111.30 181.26
Williams, Mamie Wyatt 228-20-3081 43 1 5,948.26 220.49
Wilson, Joyce Little 225-56-4997 54 18,769.51 259.49
Wilson, Samuel 230-07-1060 62 28,086.22 388.29

Totals: 515 §210,158.06 *2,905.58

CAUTION: SOME TAXES MUST BE WITHHELD.



-43-

APPENDIX B

DISTRIBUTION OF THE MONETARY SETTLEMENT

1• Of the total monetary settlement of $180,000, the amount 

of $'«0,277.15 is allowed for attorneys’ fees for counsel for plain­

tiffs, and the amount of $18,891.39 is tentatively allowed as their 
costs. This is based upon the affidavit of counsel for plaintiffs. 

Some expenses are tentative, and provisions for adjustment are set 
forth at the end of this Appendix.

2. The amount available for distribution to the class is tenta­
tively set at $120,831.46. Of this amount, $15,000 shall be distri­

buted to the named plaintiffs in equal amounts, and they shall not 
share under any other provisions for distributing the monetary 

settlement. Apart from the named plaintiffs, all other class mem­
bers may share under all provisions for distributing the monetary 
settlement for which they are eligible.

3. The sum of $20,000 shall be used to redress the claims of 
class members who filed proof-of-claim forms, apportioned in the 
manner set forth in Appendix A, List 1. This list does not include 

types of discrimination covered by the other lists in Appendix A.

4. Lists 2 through 8 in Appendix A show the initial estimated 

amounts of back pay for various persons. These amounts are not yet 

definite because some former employees who did not file proof-of- 
claim forms will lose their right to receive their shares on lists

2 through 8 unless they write to counsel for plaintiffs, and the 

card, letter or notice is received by the deadline. The writing 
requirement is explained in paragraph 10 below. Since some persons 
will have died or moved away, and nobody will send in the written 

notice for them, and since some persons will not respond for other 
reasons, a number of persons will lose their rights to receive the 

shares on lists 2 through 8. The amounts forfeited will be added 

together and distributed to the remaining persons on these lists, 

in proportion to the total share of each person on the combined 
lists 2 through 8.



- A A -

Initial Apportionments and Estimated Amounts of Back Pay

5. The initial sum of $5,000 shall be used to estimate the 

compensation of class members who lost six or more months' seniority 

upon transferring departments from 1965 to 1971 in the manner set 

forth in Appendix A, List 2, in proportion to the number of months' 
seniority lost. If class members transferred departments more

than once, all transfers in which six or more months' seniority 
was lost are included for the purpose of calculating months lost.

6. The initial sum of $75,831.^6 shall initially be ap­
portioned in the following manner among these six sub-classes. 

"Eligibility"is defined in paragraph 9 .

1) For eligible class members for time spent 

working as Laborers, the initial sum of 
$55,204.6A, to be divided among them in 

proportion to their earnings as Laborers 

from July 1965 to April 1973. Each member's 
earnings should be multiplied by a factor

of .013825 to arrive at his estimated share 

of back pay for membership in this sub­
class. Plaintiffs' best approximation of 

earnings is shown in Appendix A, List 3, 
which also shows the estimated shares of 
each eligible Laborer.

2) For eligible class members for time spent 
working as Paint Laborers or Track 

Laborers, the initial sum of $1 ,35*4.60 to

be divided among them in proportion to their 

earnings in such jobs from July 1965 to April 

1973. Each member's earnings should be mul­
tiplied by a factor of .009678 to arrive at 

his estimated share of back pay for member­

ship in this sub-class. Plaintiffs' best



approximation of earnings is shown in 

Appendix A, List >\, which also shows t.ho 

estimated shares of each eligible Paint 
Laborer and Track Laborer.

3) For eligible class members for time spent 
as Labor Helpers, the initial sum of 

$1,210.76, to be divided among them in 

proportion to their earnings in such jobs 

from July 1965 to April 1973. Each mem­
ber’s earnings should be multiplied by a 

factor of .005530 to arrive at his esti­
mated share of back pay for membership in 

this sub-class. Plaintiffs’ best approxi­

mation of earnings is shown in Appendix A,

List 5, which also shows the estimated share 
of each eligible Labor Helper.

4) For eligible class members for time spent 

working as Dock Helpers, the initial sum of 

$9,167.37, to be divided among them in 
proportion to their earnings in such jobs 

from July 1965 to December 1970. Each mem­

ber's earnings should be multiplied by a 

factor of .005530 to arrive at his estimated 
share of back pay for membership in this sub­

class. Plaintiffs' best approximation of 
earnings is shown in Appendix A, List 6, which 

also shows the estimated share of each eligible 
Dock Helper.

5) For eligible class members for time spent 
working as Truck Drivers, the initial sum 

of $5,988.51, to be divided among them in 

proportion to their earnings in such jobs from



-46-

July 1965 to April 1973. Each member’s 

earnings should be multiplied by a factor 

of .009678 to arrive at his estimated share 

of back pay for membership in this sub-class. 

Plaintiffs’ best approximation of earnings 

is shown in Appendix A, List 7, which also 

shows the estimated share of each eligible 
Truck Driver.

6) For eligible class members for time spent 

working as Janitors or Janitresses, the 

initial sum of #2,905.58, to be divided 

among them in proportion to their earnings 

in such jobs from July 1965 to April 1973.

Each member’s earnings should be multiplied 

by a factor of.013825 to arrive at his or 
her estimated share of back pay for member­

ship in this sub-class. Plaintiffs’ best 

approximation of earnings is shown in Appen­

dix A, List 8, which also shows the estimated 

share of each eligible Janitor or Janitress.

7. The following is a brief summary of the basis on which 
the formulas are derived:

1) Customarily, totally unskilled persons are 

assigned upon hiring to one of the covered 

job categories or to jobs as helpers in the 
trade departments.

2) Prior to January 1, 1969, there were strong 

racial patterns in initial assignments whereby 
whites were assigned to jobs as helpers in 

the trade departments and unskilled blacks 
were assigned to one of the covered job 
categories.



3) After January 1, 1969, these raeial patterns 
of initial assignment ended with respect to 

jobs as helpers in the trade departments 

and jobs as Laborer and Dock Helper. Even 

after January 1, 1969, however, most persons 
initially assigned to the jobs of Paint 

Laborer, Track Laborer, Truck Driver, Jani­
tor and Janitress have been black.

*0 Persons who were initially assigned as hel­
pers in the trade shops have a much greater 

chance of promotion to skilled job cate­

gories than persons initially assigned to 
the jobs of Laborer, Truck Driver, Janitor 

and Janitress. Until December, 1970, Dock 

Helpers had relatively little chance for 

promotion to skilled job categories; after 

January 1, 1971, however, their opportunities 
for promotion to skilled job categories 

became as great as those of helpers in the 

trade departments. Labor Helpers have 

relatively little chance for promotion to 

skilled job categories. Paint Laborers and 

Track Laborers have a greater chance for 
promotion to skilled job categories than 
laborers.

5) Pay rates for these various unskilled entry- 

level job categories are different. Paint 
Laborers and Track Laborers have always earned 

the same rate of pay as Laborers; Dock Helpers, 

Labor Helpers and Kfelpers in the trade depart­

ments have always earned the same rate of 

pay; Laborers have customarily earned 190 to



-48-

250 an hour less than Helpers of the same 

class; Labor Helpers are made so by promo­

tion and are thus unlike other entry-level 

Helpers; Truck Drivers have customarily 

earned 90 to 100 an hour less than Helpers 

of the same class; Janitors and Janitresses 

customarily earn 190 to 200 an hour less 
than Helpers first class.

8. The factors applied to earnings in the various covered 

job categories are different, in order to take account of the 

differing economic values of these jobs to the persons in them. 
The factors bear the approximate proportion of 10 to 7 to 4: 

Laborers, Janitors and Janitresses at 10; Truck Drivers, Paint 

Laborers and Track Laborers at 7; Dock Helpers and Labor Helpers 

at 40 The factors set forth at pp. hh to 46 above take proper 
account of these differing economic values.

Eligibility Requirements for Lists 3 Through 8 of Appendix A

9. The standards for determining the eligibility of class 
members to share under the six earnings-based formulas set forth 
above and in lists 3 through 8 of Appendix A are as follows:

1) To be eligible to share in any of lists 3 

through 8 of Appendix A, a class member must 

have worked a total of at least twelve months 

after July 1965 in any combination of the 

job categories of Laborer, Paint Laborer,

Track Laborer, Labor Helper, Dock Helper,

Truck Driver, Janitor or Janitress. For Dock 

Helpers, the twelve months must have been 
between July 1965 and December 1970.

2) To be eligible to share under any of lists 3 

through 8 of Appendix A, a class member who 
did not file a proof-of—claim form must have



-49-

worked for N.S.D.D. on or after June 25, 1967, 

If a class member who did file a proof-of- 

claim form left N.S.D.D. before this date, he 

or she will still share on lists 3 through 8.

3) With respect to the jobs of Laborer, Labor 

Helper and Dock Helper, a class member must 

have been hired before January 1, 1969 —

in 1968 or before. For class members 
hired before January 1, 1969 whose employment 

was terminated before satisfying the twelve- 

month requirement and who were subsequently 

rehired in the same job category or any 

other job category covered in lists 3 through 
8 of Appendix A, subsequent months will be 

included to help meet the twelve-month require­

ment only if both of the following conditions 

are met : that the date of rehire is before 

January 1, 1970 and that the period from the 

date of separation to the date of rehire is 

no longer than a year. For class members 

hired before January 1, 1969 who were promoted 

to job categories not covered in lists 3 

through 8 of Appendix A, and subsequently 

demoted or transferred to one of the covered 

job categories, all months spent in the covered 
job categories will be included for the purpose 

of satisfying the twelve-month requirement.

4) Date of hire is irrelevant for class members 
working in the jobs of Paint Laborer, Track 

Laborer, Truck Driver, Janitor or Janitress, 
as long as the twelve-month requirement is met.



50-

The Requirement That Some Former Employees Send a 

Written Notice to Counsel for Plaintiffs in Order 

To Preserve Their Right to Share

10. Each class member who did not file a proof-of-claim 

form and who was not still employed by N.S.D.D. as of April,

1973 —  as shown by the data processing tape furnished by N.S.D.D.

to counsel for plaintiffs —  will lose his or her right to share

in the monetary settlement unless counsel for plaintiffs receives

a postcard or other writing indicating a desire to share, no

later than thirty days after the publication of notice herein

or no later than the final calculation of the shares of class

members, whichever occurs later. The notice must be sent to:

RICHARD T. SEYMOUR 
Attorney at Law 
1763 R Street, N. W.
Washington, D. C. 20009

1 1 . When plaintiffs mail copies of the proposed Consent 

Decree to class members, they shall include a properly addressed, 

stamped return postcard in the copies going to class members 

required to give written indication of their desire to share.

No present employee, and no present or former employee who

filed a proof-of-claim form, is required to take any further action.

Provisions Regarding Deceased Class Members

12. The shares of deceased class members may be paid to 

the persons, if any, who were designated by the class member on 

N.S.D.D. records to receive any wages owing at the time of death.

If there is no such designation in any instance, the class member's 
share may be paid to his or her estate, and it may be mailed to 

any member of the class member's immediate family. Counsel for 

plaintiffs will not be required to search probate records to deter­

mine the identity of any executors or administrators but shall, 

where the share is paid to an estate rather than to the beneficiary 
of wages owing at the time of death, notify the members of the



-51-

class member’s immediate family to whom the check is sent that the 

check should be given to the executor or administrator. Any member 
of the immediate family, executor, administrator, or beneficiary 

of wages owing at the time of death may send in any required 
indication of desire to share.

Escrow Fund

13. The sum of $5,000 shall be set aside as an escrow fund 
to cover the claims of persons affected by any mistake in the 

apportionments set forth in Appendix A, by excusable failure to 
send to counsel for plaintiffs a timely required notification of 

their desire to receive their share, by other meritorious claims 

for relief, and to cover out-of-pocket costs not known at the 

time of final calculations and initial distribution to class 

members, or incurred thereafter. Counsel for plaintiffs shall 

act as trustee for the class in making determinations to dis­

burse funds from this amount, but any distribution of $A00 or 

more to a class member, and any amount whatsoever for costs, must 

be approved in advance by the Court. Any class member disagreeing 

with the determination of counsel for plaintiffs with respect to 

his or her claim will have the right to appeal to the Court within 
fifteen days for a different determination.

1A. if any estimate of costs turns out to have been too 

high, but this is not learned before the final calculation and 

initial distribution of class members' shares, the excess shall be 
added to the $5,000 set aside. If any funds set aside remain 

undistributed on the first anniversary of the approval of this 

Consent Decree, and no determination on any claim for class mem­

bers is pending, the Court shall be notified of the amount involved 

and it shall be distributed equally among the named plaintiffs.

If the amount remaining is $3,000 or more, the advance approval 

of the Court is required; if less, advance approval is not required.



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Adjustments for Costs

15. Because some of the costs tentatively allowed in the 

amount of $18,891.39 reflect estimations, it is likely that 

adjustments to the amount allowed for costs must he made. The 

following procedures shall apply to such adjustments: If the

amount allowed for costs is increased or decreased hy the Court 

prior to the final calculation of the shares of class members, 

the share of each individual class member (but not the shares 

of the named plaintiffs) will be adjusted in proportion to its 

size. If the amount allowed for costs is increased or decreased 

thereafter, adjustments shall be made only with respect to the 
above-described $5,000 escrow fund.



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a p p e n d i x c
List of Former Employees to Receive Letter 

Contained in Appendix D

Beasley, Samuel William, 
Branch, Paul Leon 
Gibbs, Lorenzo 
Grier, Cassonova Pernell 
Gordon, Waverly 
Spellman, James, Jr. 
West, Christopher E. 
Bell, Edward McKinley 
Miller, Walter Glenn 
Hagans, James I.
White, Lois Laster 
Boone, Alonza, Jr.
Artis, Robert Lee 
Carey, Floyd Edward 
Newby, Eddie Leon 
Wilborn, B. N., Jr. 
Winstead, R. L.
Norman, M. V.
Hightower, L. A.
Roberts, J. 0.
Paige, W. A.
Williams, J.
Johnson, F. E.
Long, J. L., Jr.

Jr. Twine, M.
Hargraves, M. Wr. 
Hart, M.
Perdue, R. W. 
Woodley, Edwin 
Weaver, C.
Herring, Sylvester 
Townes, D. M. 
Dowtin, F. M.
Gray, J. A.
Gray, M. S.
Ridley, E„
Ridley, M, E. 
Swinton, A. 
Stokley, H. L. 
Morris, W. H. 
Williams, Morris 
Harris, C.
Lindsey, H. L. 
Locker, R. A. 
Barrow, D.
Branch, Lorenzo E. 
Dildy, Larry K. 
Bynum, Jesse J.

APPENDIX D
Text of Letter to Send Former Employees 
________ Specified in Appendix C________

Dear Former Employee:

Norfolk Shipbuilding & Drydock Corporation has recently 
been reviewing records of some of its former employees in order to 
determine if there were some who had skills that could be used more 
advantageously for future expansions in the work of the Company.

If you would be interested in future employment with the 
Company, you are requested to complete the attached form and forward 
it to the Company within 30 days. At our mutual convenience, we will 
arrange an interview that would assist in determining whether you had 
a skill level that would enable you to be placed as a handyman at the 
Company.

If you have expressed an interest and have been found 
qualified, you will be notified on a priority basis when openings 
occur.



Badge

7482
7311
7560
7525
7501
7630
7681
7391
7423
7470
7487
7367
7535
7435
7439
7521
7672
7667
7340
7584
7464
7618
7327
7598
7499
7414
7355
7607
7475
7572
7457
7494
7361
7534
7599
7461
7448
7432

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APPENDIX E

List of Persons Eligible to Take Advantage 
of Overtime Provisions in Paragraph 4D

Average Quarterly
Name Overtime Hours

Harris, J. L. 51
Prayer, B. J. 52
Lee, R. E. 52
Duns ton, Raymond 55
Wood, Lawrence 59
Burrell, Ernest 51
Cherry, J. E. 68
Pritchard, W. 0. 75
Cox, K. L. 76
McCleese, F. H. 81
Thorne, Boyce 68
Roberts, Columbus 76
Blunt, C. F. 67
Skinner, M. L. 78
Newby, W. F. 85
Reid, G. L. 93
Griffin, Millet 105
Smith, C. T. 110
James, Jesse 128
Walker, E. E. 129
Williams, J. E. 129
Brown, Serge 136
Jenkins, J. J. S. 146
Askew, Bennie 151
Brown, Curtis 151
Turner, Henry 154
Freeman, J. H. 160
Sturdivant, D. W. 188
Sharp, Ernest 189
Freeman, L. W, 160
Brock, R. 0. 139
Beamon, Jerry 118
Whitten, C. V. 83
Jacobs, Junius 211
Askew, Bernard 87
Williams, Percy 43
Brown, J . S . 65
Carroll, W. H. 51



I