Free Affidavit - District Court of Delaware - Delaware

_ Case 1 :04-cv-01450-JJF Document 32 Filed 1 1/30/2005 Page 1 of 3
. IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE I
CASSANDRA JOHNSON * g J
:
Plaintiff, * CIVIL ACTION
* NO. 04-1450 (JJF)
V. _ *

WAL-MART STORES, INC., *

Defendant. * ‘
AFFIDAVIT OF CASSANDRA JOHNSON
STATE OF DELAWARE * A ·

COUNTY OF * SS
F BE IT REMEMBERED, that on this & day of O'?/{/"" AMC , A.D.,
2005, personally appeared before me, the Subscriber, a Notary Public in and for the State and _
County aforesaid, Cassandra Johnson who, being by me duly sworn according to law, did depose
and say:
I. I certify that I am over the age of eighteen years and am compeient to make such
an affidavit. ·
2. I certify that 1ny direct supervisor, Johnny Revis, singled me out as the subject of
_numerous derogatory and demeaning comments on multiple occasions. Mr. Revis did not make
such pointed and demeaning comments to the male employees in the tire center at Wal-Mart
l where I worked. W

Case 1 :04-cv-01450-JJF Document 32 Filed 1 1/30/2005 Page 2 of 3 ‘
J — 3. The comments Mr. Revis made were primarily belittling comments concerning my i
weight. As an example of one of these comments, Mr. Revis on one occasion referred to me as a J
"big bear" in front of my co-worker, Lakeria Bryant, and a customer. I did not hear Mr. Revis I
make any comments about the weight of the male employees in the tire department.
I 4. Mr. Revis also sarcastically referred to me as "The Genius” when he had to refer
other employees to me to answer questions about store policy or procedure to which he did not
know the answer. Specifically, Mr. Revis would tell these employees, "I don’t know. Why
don’t you go ask ‘The Genius"?"
U _ 5. In addition, at one point, Mr. Revis brought in a picture of a large, scantily-clad
woman and showed it to me. _
6. Mr. Revis also became excessively angry with me for not telling him exactly when
I was taking my lunch break. In particular, on January 24, 2004 when I took my lunch break,
Mr. Revis became extremely angry and accused me of leaving half an hour earlier than I had
actually left. Mr. Revis was also angry that I had not informed him exactly where I was going for ‘
my break.
. 7. I certify that I, on multiple occasions, reported Mr. Revis’s behavior to
management personnel at Wal—Ma1t. I informed my supervisors numerous times beginning at the
end of 2003 about Mr. Revis’s continued and repeated comments but no one took any action to V
stop Mr. Revis.
` 8. In particular, I met with my manager, Jeremy Stone, on January 29, 2004 to
complain about Mr. ‘Revis’s treatment of me. Instead of taking any action to remedy the
situation, however, l\/Ir. Stone advised me just to make fun of Mr. Revis in return.

p Case 1 :04-cv-01450-JJF Document 32 Filed 1 1/30/2005 Page 3 of 3
9. On January 30, 2004, I called the home office about the conversation I had had the _
previous day with Mr. Stone. I reported Mr. Revis’s behavior towards me and also reported my
frustration with my supervisors’ inaction in this matter. The woman with whom I spoke at the i
home office then sent an e—mail to Comell Randolph, the manager of the Dover Sam’s Club.
10. That same day, January 30th, I met with Mr. Randolph about Mr. Revis’s ·
actions. Mr. Randolph, however, only justified and excused Mr. Revis’s behavior. Mr.
Randolph told me that I should be accountable to Mr. Revis and should tell Mr. Revis when I
was taking my break and where I was going any time I left the department. No other employee
had to report this closely to Mr. Revis. No action was taken to correct Mr. Revis°s behavior. i
ll. I further certity that I perform a substantial amount of physical work in my job in
g ~ J `the tire center, both at the cashier desk and in the tire shop as a certified tire technician. My
work involves stocking and pulling down tires as well as carrying the tires to the shop for
installation. In addition, I am required, on a regular basis, to go outside to inspect customers’ cars V
to determine which type of tire the customer needs. Further, I am required to help install tires on
con as-needed basis.
/ .
{ gan
Cassan ra Johnson
SWORN TO AND SUBSCRIBED before me the day and year aforesaid.
. ? ·x\·»”“·"·if·#¤m_ i
Q/4.1. 1 4%
_ I\lotaryPublic w Q :DEg%Fg%U§! ‘

V