IN THE UNITED STATES DISTRICT COURT
                   FOR THE WESTERN DISTRICT OF LOUISIANA
                              MONROE DIVISION

   UNITED STATES OF AMERICA,

   Plaintiff,

   v.

   CITY OF BASTROP, LOUISIANA,

   Defendant.

   Civil Action No.

                    COMPLAINT AND DEMAND FOR JURY TRIAL

   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, as
   amended, 42 U.S.C. Section 2000e, et seq. ("Title VII").

   2. This Court has jurisdiction over the action under 42 U.S.C. Section
   2000e-5(f) and 28 U.S.C. Section 1345.

   3. Defendant City of Bastrop, Louisiana (hereinafter referred to as
   "Bastrop" or "the City") is a political subdivision of the State of
   Louisiana created pursuant to Louisiana law.

   4. Defendant City of Bastrop is a person within the meaning of 42
   U.S.C. Section 2000e(a), and an employer within the meaning of 42
   U.S.C. Section 2000e(b).

   5. Defendant City of Bastrop has discriminated against Kimberly
   Mullins, a white female formerly employed as an operator in the City's
   Streets Department, because of her race, white, and her sex, female,
   in violation of Section 703(a) of Title VII of the Civil Rights Act of
   1964, as amended, 42 U.S.C. Section 2000e-2(a), among other ways, by:

   a. subjecting Ms. Mullins to (1) racial harassment and (2) sexual
   harassment while she was employed in the City's Streets Department,
   which created an intimidating, hostile or offensive work environment
   and which adversely affected the terms, conditions and privileges of
   Ms. Mullins' employment;

   b. failing or refusing to take appropriate action to remedy the