UNITED STATES DISTRICT COURT FOR THE
                        WESTERN DISTRICT OF NEW YORK

   UNITED STATES OF AMERICA,

   Plaintiff

   v

   ERIE COUNTY, NEW YORK,

   Defendant.

                               CONSENT DECREE

   This action was brought by the United States against Erie County, New
   York, ("Erie") 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 of charges filed by four
   correctional officers employed at the Erie County Correctional
   Facility ("ECCF").

   The correctional officers -- one man and three women --alleged that
   the ECCF improperly used gender as a basis for choosing correctional
   officers to escort inmates on trips away from the ECCF. For example,
   if a female prisoner was sent to the eye doctor, ECCF policy required
   her to be escorted by at least one female correctional officer.
   Similarly, all male inmates had to be escorted by at least one male
   correctional officer, regardless of whether or not the inmate was
   likely to need to undress during the trip.

   In its complaint, the United States alleges that Erie, in the ECCF,
   violated Title VII by assigning only men to guard male inmates and
   only women to guard female inmates during trips outside the ECCF, when
   such gender-based assignments were not reasonably necessary as bona
   fide occupational qualifications.

   The parties, desiring that this action be settled by 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. Subject to the Court's approval of this Consent
   Decree, the parties waive a hearing and findings of fact and
   conclusions of law on all issues, and further agree to the entry of
   this Decree as final and binding between themselves as to the issues
   raised in the United States' complaint filed in this case and the
   matters resolved in this Decree.

                        UNITED STATES DISTRICT COURT
                    FOR THE WESTERN DISTRICT OF NEW YORK

   UNITED STATES OF AMERICA,

   Plaintiff,

   v.

   ERIE COUNTY, NEW YORK

   Defendant.

                                 COMPLAINT

   Plaintiff United States of America alleges that:

   1. This action is brought by 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., (hereinafter "Title VII").

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

   3. The defendant Erie County, New York, is a municipal corporation
   established by laws of the State of New York.

   4. The defendant, through its Erie County Correctional Facility
   ("ECCF"), employs guards to supervise inmates at the ECCF and assigns
   duties to those guards.

   5. The defendant 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).

   6. The defendant has discriminated against Niala Diebold, Roberta
   Grachowski, Claudia Pustulka and Craig Duff ("complainants"), guards
   at the ECCF, on the basis of their sex in violation of Title VII, by
   pursuing policies and practices that discriminate against men and
   women, deprive or tend to deprive men and women of employment
   opportunities, and adversely affect the status of men and women as
   employees because of their sex. The defendant has implemented these
   policies and practices by assigning only men to guard male inmates and
   only women to guard female inmates during trips outside the ECCF,
   regardless of whether such gender-based assignments are reasonably
   necessary as bona fide occupational qualifications.

   6. The Equal Employment Opportunity Commission ("EEOC") received
   timely charges filed by the complainants, in which they alleged that