IN THE UNITED STATES DISTRICT COURT
                    FOR THE SOUTHERN DISTRICT OF GEORGIA
                             WAYCROSS DIVISION

   UNITED STATES OF AMERICA,
   Plaintiff,

   PAMELA F. STARLING, GAIL R. BERRY, JACKIE EMBRY, and JANICE WATERS,

   Plaintiff-Intervenors, Civil Action No.
   CV599-68

   CITY OF ALMA, GEORGIA; and
   BACON COUNTY, GEORGIA, Defendants.

                               CONSENT DECREE

   This action was brought on behalf of the United States of America
   ("United States") against the City of Alma, Georgia and Bacon County,
   Georgia ("Defendants") to enforce the provisions of Title VII of the
   Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq., as amended
   ("Title VII"), following receipt by the Department of Justice from the
   Equal Employment Opportunity Commission ("EEOC") of a charge of
   discrimination filed by Pamela F. Starling (Charge Number
   115-96-0501). This Court has jurisdiction over this action under 42
   U.S.C. § 2000e-5(f) and 28 U.S.C. § 1345.

   In its complaint, the United States alleges that Defendants, through
   the Alma-Bacon County Fire and Emergency Medical Service ("Alma-Bacon
   County Fire and EMS"), an entity operated for the citizens of the City
   of Alma and Bacon County, have discriminated against Pamela F.
   Starling and similarly-situated women on the basis of their sex in
   violation of Section 703(a) of Title VII, 42 U.S.C. § 2000e-2(a), by,
   inter alia:

   a. Failing or refusing to hire these women or to consider them for
   hire into full-time Firefighter/Emergency Medical Technician and/or
   Firefighter/Paramedic positions; and

   b. Failing or refusing to take appropriate action to correct the
   effects of these discriminatory policies and practices.

   Their motion for intervention having been granted by the Court, in
   their Complaints in Intervention, plaintiff-intervenors allege similar
   claims of discrimination to those alleged by the United States.

   The Defendants specifically deny the United States' allegations and
   the allegations of plaintiff-intervenors, and further deny that they

                        UNITED STATES DISTRICT COURT
                    FOR THE SOUTHERN DISTRICT OF GEORGIA
                             WAYCROSS DIVISION

                         UNITED STATES OF AMERICA,
                                 Plaintiff,

                                    vs.

                      CITY OF ALMA, GEORGIA; and BACON
                              COUNTY, GEORGIA,
                                Defendants.

                                 COMPLAINT

   Plaintiff, United States of America, alleges:

   1. This action is brought on behalf of the United States to enforce
   the provisions of Title VII of the Civil Rights Act of 1964, 42 U.S.C.
   § 2000e, et seq., as amended.

   2. The Court has jurisdiction of this action under 42 U.S.C.
   2000e-5(f) and 28 U.S.C. § 1345.

   3. Defendant City of Alma, Georgia ("Alma"), is a body politic and a
   political subdivision of the State of Georgia, established pursuant to
   the laws of the State of Georgia.

   4. Defendant Alma is a person within the meaning of 42 U.S.C.
   2000e(a) and an employer within the meaning of 42 U.S.C. § 2000e(b).

   5. Defendant Bacon County, Georgia ("Bacon"), is a body politic and a
   political subdivision of the State of Georgia, established pursuant to
   the laws of the State of Georgia.

   6. Defendant Bacon is a person within the meaning of 42 U.S.C.
   2000e(a) and an employer within the meaning of 42 U.S.C. § 2000e(b).

   7. Defendants Alma and Bacon jointly operate an entity known as the
   Alma-Bacon County Fire and Emergency Medical Service ("Alma-Bacon
   County Fire and EMS").

   8. The entity known as the Alma-Bacon County Fire and EMS provides
   firefighting and emergency medical services throughout the City of
   Alma and Bacon County, Georgia.

   9. Persons employed in the entity known as the Alma-Bacon County Fire
   and EMS, including persons employed as full-time Firefighter/Emergency