UNITED STATES DISTRICT COURT
                     FOR THE NORTHERN DISTRICT OF TEXAS
                              DALLAS DIVISION

                    UNITED STATES OF AMERICA, Plaintiff

                                     v.

                      CITY OF DALLAS, TEXAS, Defendant

                    COMPLAINT AND DEMAND FOR JURY TRIAL

   Plaintiff, the 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. § 2000e, et seq.

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

   3. Defendant City of Dallas, Texas, is a political subdivision of the
   State of Texas, created pursuant to the laws of the State of Texas.

   4. Defendant City of Dallas, Texas, 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 City of Dallas, Texas, has retaliated against Lee A.
   Bush, in violation of § 704(a) of Title VII of the Civil Rights Act of
   1964, as amended, 42 U.S.C. § 2000e-3(a), among other ways, by:

   (a) failing or refusing to grant Mr. Bush a promotion to
   the rank of sergeant with the City of Dallas Police Department because
   he opposed practices he reasonably believed to be unlawful under Title
   VII; and

   (b) failing or refusing to take appropriate action to remedy the
   effects of the retaliation against Mr. Bush.

   6. Lee A. Bush timely filed two charges with the Equal Employment
   Opportunity Commission (EEOC), EEOC Charge Nos. 310-98-3049 and
   310-98-0226, alleging that because of his race, Black, and in
   retaliation against him for previously filing charges of
   discrimination with the EEOC and raising an internal grievance
   alleging race discrimination in the City of Dallas Police Department,
   he was subjected to adverse personnel actions, suspended for two days,
   and denied a promotion to the rank of sergeant in the City of Dallas