LORETTA BURRELL, LINDA L. BROWN, CATHERINE MCAFEE, JOHN
GRANT, JOHN MCDOWELL, PHYLLIS MILLER, SUSAN ROBERTSON,
and KAREN SLOAN
          Plaintiffs,
     v.
CROWN CENTRAL PETROLEUM CORPORATION
          Defendant.

2) Thirty-three years have elapsed since the passage of the 1964 Civil Rights Act but, unfortunately, time has stood still at Crown, particularly at its Texas refineries, where the Company has cultivated an environment that is openly hostile to African-American and female employees. Defendant Crown has maintained a system of discrimination. At Crown refineries, supervisors routinely call African-Americans "niggers" or "boys" and often make statements to women such as "a woman's place is at home in the kitchen, but not on the job." Supervisors have frequently created, distributed and posted in the workplace misogynist and racist cartoons and handbills which degrade and demean African-American and/or female employees. Crown's discriminatory human resource practices are part of the Company's "good ole boy" environment which has suppressed the career development of female and African-American employees.

3) As evidence of the pattern and practice of race and gender discrimination, plaintiffs allege the following specific examples of disparate treatment:

  a. A comparison of salaries of Caucasian and
  African-American supervisors at the Crown Pasadena
  facility with the same title and similar responsibilities
  illustrates compensation disparities which adversely
  affect African-Americans. On average, Caucasian
  supervisors at the Pasadena facility are paid more on an
  annual basis than their African-American counterparts

  b. Crown supervisors routinely create, distribute, and
  post handbills in the workplace that are hostile to
  African-Americans. Samples of these handbills are
  attached as Exhibit A. Crown supervisors have handed out
  documents that demean African-Americans such as the
  "NIGGER APPLICATION FOR EMPLOYMENT." The "Application"
  contains an affirmation in the text that the applicant
  was to answer "to the best of Nigger's ability, and that
  I swear that I will always look like a nigger, act like
  a nigger, and smell like a nigger." In late 1995, a Crown
  supervisor, posted on his bulletin board outside his
  office a document entitled "APPLICATION FOR EMPLOYMENT
  FOR JESSE JACKSON'S STAFF." Said document contained
  entries such as "Length of Last Jail Time" and "Why You
  Be Out of Jail: Escape __ Probation __ Other __."

  c. Crown supervisors routinely create, distribute and
  post handbills in the workplace that are hostile to women
  (see Exhibit B). Crown supervisors have handed out
  documents with statements such as:
  
       * "SEXUAL HARASSMENT IN THE AREA WILL NOT BE REPORTED,
  HOWEVER, IT WILL BE GRADED."
       * "APPLICATION FOR A PIECE OF ASS." ... "Screwing
  Preferences: How Often? Pussy? Ass? Both? Other __"
       * "Plain Facts: Scientists have determined that the
  average time of intercourse is four minutes.... The
  average girl does it about three times a week, fifty
  weeks out of the year...."
       * In a cartoon where a man inadvertently pushes the back
  of a pool stick in the rear end of a woman, the woman
  says, "I'm in love! I'm in love."
       * Alongside a drawing of a dog with an American Indian
  headdress is a quote "my wife is a cross between an
  Indian and a Bulldog. When she's not on the War Path,
  She's Sittin' on Her Ass Growlin.'"

  d. Male supervisors have allowed women to be subjected to
  countless demeaning measures which stigmatize them in the
  workplace. When Crown first hired women, some Crown
  employees insisted that new female employees "put bells
  on their shoes" by insisting that they lace small metal
  bells on their work boots so the men "would know where
  the girls are." At least one woman agreed to "put bells
  on her shoes."

  e. Notwithstanding at least one Department of Labor,
  Occupational, Safety and Health Administration ("OSHA")
  citation, finding non-compliance with 29 C.F.R.
  1910.14l(c)(i)(i) (Exhibit C), Crown refused to provide
  separate restrooms for most female employees in the
  Pasadena and Tyler refineries. In the Pasadena facility,
  women had one of two choices -- walk across the refinery
  for a female only restroom or use a "unisex" restroom
  containing mean spirited misogynist magazines such as
  Hustler.

5) The discriminatory systems challenged herein are designed, implemented and administered by a nearly all- Caucasian staff of supervisors and managers. Crown's "glass ceiling" problems are reflected in the paucity of female or African-American persons who hold supervisory or managerial positions.

6) The discrimination experienced by the named plaintiffs and the Class illustrates a statistically significant pattern of discrimination rather than a chance occurrence. Moreover, the discrimination experienced by plaintiffs marks a system that has been and is of a continuing nature. Absent injunctive relief, Defendant's discriminatory system will persist unaltered....