IN THE UNITED STATES DISTRICT COURT

                 FOR THE EASTERN DISTRICT OF NORTH CAROLINA

   UNITED STATES OF AMERICA,

   Plaintiff,

   v.

   COLUMBUS COUNTY, NORTH CAROLINA,
   Defendant.

                            SETTLEMENT AGREEMENT

   Plaintiff United States of America and defendant Columbus County,
   North Carolina ("Defendant" or "County") by and through their
   respective attorneys agree and stipulate as follows:

   1. The above-captioned action was brought by the United States against
   the County to enforce the provisions of Title VII of the Civil Rights
   Act of 1964, as amended, 42 U.S.C. § 2000e, et seq. ("Title VII"),
   following receipt by the Department of Justice from the Equal
   Employment Opportunity Commission ("EEOC") of EEOC Charge No.
   141-94-0719 filed by Francina Freeman.

   2. In its Complaint, the United States alleges that, during Francina
   Freeman's employment in the Columbus County Department of Aging
   ("Department of Aging") as an In-Home Aide, Defendant County, through
   the Department of Aging, discriminated against Ms. Freeman on the
   basis of her sex (female) and retaliated against her, in violation of
   Sections 703(a) and 704(a) of Title VII, 42 U.S.C. §§ 2000e-2(a) and
   -3(a), by, among other things:

   (a) subjecting Ms. Freeman to a sexually hostile work environment by
   assigning her to a work site in which it knew or should have known
   that Ms. Freeman would be subjected to unwelcome and offensive
   touching of a sexual nature and failing to take prompt and appropriate
   remedial action to eliminate the hostile work environment;

   (b) failing or refusing to assign Ms. Freeman work because of her
   opposition to the unwelcome sexual conduct; and

   (c) failing or refusing to take appropriate action to remedy the
   effects of the discriminatory treatment of Ms. Freeman.

   3. The County denies that it has discriminated in any manner against
   Ms. Freeman in violation of Title VII.

                    IN THE UNITED STATES DISTRICT COURT
                 FOR THE EASTERN DISTRICT OF NORTH CAROLINA
                            WILMINGTON DIVISION

   UNITED STATES OF AMERICA,
   Plaintiff,

   v.

   COLUMBUS COUNTY, 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.
   2000e, et seq. ("Title VII"). 2. This Court has jurisdiction of the
   action under 42 U.S.C. § 2000e-5(f) and 28 U.S.C. § 1345. 3. Defendant
   Columbus County, North Carolina ("County") is a political subdivision
   of the State of North Carolina and possesses the power to sue and be
   sued. N.C. Stat.Ann. § 153A-11. 4. Defendant County 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. Columbus County Department of Aging
   ("Department of Aging") is an agency of defendant County. 6. Between
   May 1993 and January 1994, Francina Freeman was employed in the
   Department of Aging as an In-Home Aide. 7. Defendant County, through
   its Department of Aging, has discriminated against Francina Freeman on
   the basis of her sex in violation of Section 703(a), 42 U.S.C.
   2000e-2(a), and retaliated against her in violation of Section 704(a)
   of Title VII, 42 U.S.C. § 2000e-3(a), by, among other things: (a)
   Subjecting Ms. Freeman to a sexually hostile work environment by
   assigning her to work in an environment in which it knew or should
   have known that Ms. Freeman would be subjected to unwelcome and
   offensive touching of a sexual nature and failing to take prompt and
   appropriate remedial action to eliminate the sexually hostile work
   environment; (b) Failing or refusing to assign Ms. Freeman work
   because of her opposition to the unwelcome sexual conduct; and (c)
   Failing or refusing to take appropriate action to remedy the effects
   of the discriminatory treatment of Ms. Freeman.

   8. The Equal Employment Opportunity Commission ("EEOC") received a
   timely charge filed by Francina Freeman (Charge No. 141-94-0719) in
   which she alleged that she had been discriminated against in
   employment by the Department of Aging by being sexually harassed and
   retaliated against because she opposed such harassment. Pursuant to
   Section 706 of Title VII, 42 U.S.C. § 2000e-5, the EEOC investigated
   the charge, found reasonable cause to believe that the allegations of