IN THE UNITED STATES DISTRICT COURT
                 FOR THE WESTERN DISTRICT OF NORTH CAROLINA
                            STATESVILLE DIVISION
                        Civil Action No. 5:99CV189-V

   UNITED STATES OF AMERICA,
   Plaintiff,
   &
   DONALD R. STOKLEY,
   Plaintiff-Intervenor,
   v.
   CITY OF NEWTON, NORTH CAROLINA,
   Defendant.

                  CONSENT DECREE BETWEEN THE UNITED STATES
                   AND THE CITY OF NEWTON, NORTH CAROLINA

   This action was brought by the United States of America ("United
   States") against the City of Newton, North Carolina, ("the City"
   or "Defendant") 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"), following receipt by the United States Department
   of Justice from the Equal Employment Opportunity Commission
   ("EEOC") of EEOC Charge Number 140-97-1556 filed by Donald R.
   Stokley.

   In its Complaint, the United States alleges that the City has
   discriminated against Mr. Stokley, a male formerly employed as a
   sanitation worker in the City's Department of Public Works and
   Utilities, 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 Mr. Stokley to racial harassment while he was employed
   in the City's Department of Public Works and Utilities on the basis of
   his race and his association with a black person;

   b. discharging Mr. Stokley from his employment as a sanitation worker
   on the basis of his race and his association with a black person; and

   c. failing or refusing to take appropriate action to remedy the
   effects of the discrimination against Mr. Stokley.

   The City denies that it has discriminated in any manner against Mr.
   Stokley in violation of Title VII. Nonetheless, the parties, desiring
   that this action be settled by an appropriate Consent Decree and
   without the burden of protracted litigation, agree to the jurisdiction
   of this Court over the parties, and the subject matter of this action,

                    IN THE UNITED STATES DISTRICT COURT

                 FOR THE WESTERN DISTRICT OF NORTH CAROLINA

                            STATESVILLE DIVISION

   UNITED STATES OF AMERICA,
   Plaintiff,
   v.
   CITY OF NEWTON, NORTH CAROLINA,
   Defendant.

                    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 Newton, North Carolina (hereinafter referred to as
   "Newton" or "the City") is a political subdivision of the State of
   North Carolina created pursuant to North Carolina law.

   4. Defendant Newton 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 Newton has discriminated against Donald Stokley, a white
   male formerly employed as a sanitation worker in the City's Department
   of Public Works and Utilities, because of his race, white, and his
   association with a black person, 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 Mr. Stokley to racial harassment while he was employed
   in the City's Department of Public Works and Utilities on the basis of
   his race and his association with a black person;

   b. discharging Mr. Stokley from his employment as a sanitation worker
   on the basis of his race and his association with a black person; and

   c. failing or refusing to take appropriate action to remedy the
   effects of the discrimination against Mr. Stokley.