UNITED STATES DISTRICT COURT FOR
                         SOUTHERN DISTRICT OF TEXAS
                              HOUSTON DIVISION

   UNITED STATES OF AMERICA,
   Plaintiff,

   V.

   H.N. McELROY, Harris County
   Justice of The Peace, Precinct 4,
   Position 1 (in his official capacity);
   and HARRIS COUNTY,
   Defendants.

                                                         Civil Action No.

                                 COMPLAINT

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

   3. Defendant H.N. McElroy ("H.N. McElroy"), the Harris County Justice
   of the Peace, Precinct 4, Position 1, is an elected official in the
   State of Texas. H.N. McElroy is sued in his official capacity only.

   4. H.N. McElroy has responsibility for the employment of persons in
   the office of the Harris County Justice of the Peace, Precinct 4,
   Position 1, including the hire, promotion and termination of all
   employees in that office.

   5. H.N. McElroy is a person within the meaning of 42 U.S.C. § 2000e(a)
   and an employer or agent of an employer within the meaning of 42
   U.S.C. 2000e(b).

   6. Defendant Harris County, a political subdivision of the State of
   Texas, is named as a party pursuant to Rule 19(a) of the Federal Rules
   of Civil Procedure. Through its Commissioners Court, the County
   appropriates monies for the operation of the Justice of the Peace,