IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION

EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION,




Plaintiff, 
Civil Action No. 3:13-1060
V. Judge Campbell
Magistrate Judge Brown
THE INDUSTRIAL LABOR MANAGEMENT 
GROUP, INC, 

Defendant. 
DECLARATION OF MARKEISHA K. SAVAGE

I, Markeisha K. Savage declare the following based on my direct ?rsthand knowledge

and to the best of my recollection:

l. I am a Trial Attorney for the Equal Employment Opportunity Commission
(Commission). I am the attorney for the Commission in this action.

2. Using the Commission?s automated Pay Cale program, the Commission has I
calculated the back pay damages for four claimants totaling $37,807.43. The
documents are Bates numbered EEOC 2347, EEOC 2348 EEOC 2349, and EEOC
2350. This amount considers any interim earnings that the claimant received. The
Commission requests that the court award back pay to Sherry Brewer 
Mary Barrett (3315531 5), Rose Crigger and Rosheta Jackson


3. The Commission requests that the court award compensatory damages Sherry Brewer
and Rosheta Jackson 

4. The Commission requests that the court award punitive damages in the amount of

$50,000.

Case 3:13-cv-01060 Document 53-1 Filed 04/14/15 Page 1 of 6 PageID 194

5. On or about June 6, 2014, produced invoices from 2011 between Manuli Stretch
and The invoices Show that ILM placed at least 55 male applicants with Manuli
Stretch in 201 l.

6. On or about June 16, 2014, ILM provided responses to the Commission?s Request for
Admissions. (See Exh.7 to Memorandum). ILM admits as follows:

a. ILM kept files separated by gender.

b. Female ?les had yellow applications attached.

0. Male ?les had bluish/teal applications attached

d. The ?le cabinet containing Manuli Stretch personnel ?les contained only

bluish/teal colored ?les.

I declare under penalty of perjury that the foregoing is true and correct. Executed on

 

iff; 
Wig/E if??   . 
MARKEISHA K. 

2
Case 3:13-cv-01060 Document 53-1 Filed 04/14/15 Page 2 of 6 PageID 195

 PAYCALC 

 

a program to calculate backpay with interest

Industrial Labor Managment
Enterest Due at End of Apr 2015, compeunded 

Case 3:13-cv-01060 Document 53-1 Filed 04/14/15 Page 3 of 6 Pa]?

Date .22 Backng .Eez?aimsw Net. .mi?fg?wA
Brewer, Sherry

01/2011 $1,360.00 $0.00 $1,360.00 $192.41
02/2011 $1 .36000 $0.00 $1 ,360.00 $188.54
03/2011 $1,360.00 $0.00 $1 ,36000 $184.68
04/2011 $1,360.00 $0.00 $1,360.00 $179.55
05/2011 $1 .36000 $208.33 $1,151.67 $147.71
06/2011 $1,360.00 $269.33 $1,090.67 $135.80
07/2011 $1,360.00 $269.33 $1,090.67 $131.73
08/2011 $1,360.00 $0.00 $1,360.00 $159.19
09/2011 $1,360.00 $0.00 $1,360.00 $154.14
10/2011 $1,360.00 $282.00 $1,078.00 $119.19
11/2011 $1,360.00 $1,745.50 $0.00 $0.00
12/2011 $1 .36000 $1 .74550 $090 $0.00

$12,571.01 $1,592.95

Total $14,163.96

$12,571.01

 

$1,592.95

 

Grand Total $14,163.96 

 PAYCALC 

 

a program to calculate backpay with interest

Industrial Labor Management
Enterest Due at End of Apr 2015, compounded monthiy

 

ere Backpay Earnings Net 
Barrett, Mary

08/2011 $1,360.00 $0.00 $1,360.00 $159.19

09/2011 $1,360.00 $0.00 $1,360.00 $154.14

10/2011 $1 ,36000 $0.00 $1,360.00 $150.37

11/2011 $1,360.00 $000 $1 .36000 $146.60

12/2011 $1,360.00 $0.00 $1,360.39 $142.84
$6,800.00 $753.15

Total 3 $7,553.15

$6,800.00 $753.15

 

Grand Total $7,553.15

 

 

 

Case 3:13-cv-0106O Document 53-1 Filed 04/14/15 Page 4 of 6 PageID 197


 

 

 PAYCALC 
a program to calculate backpay with interest
Industrial Labor Managment
Interest Due at End of Apr 2015, compounded 
Backpay Earnings [161111 iolegeet 
Rose Crigger
04/2011 $340.00 $0.00 $340.00 $44.89
05/2011 $1,360.00 $0.00 $1,360.00 $174.43
06/2011 $1,360.00 $0.00 $1,360.00 $169.34
07/2011 $1 ,36000 $0.00 $1 ,360.00 $164.26
08/2011 $1 ,360.00 $1,116.60 $243.40 $28.49
09/2011 $1,360.00 $1,116.60 $243.40 $27.59
10/2011 $1,360.00 $1,116.60 $243.40 $26.91
11/2011 $1,360.00 $1,116.60 $243.40 $26.24
12/2011 $1,360.00 $1,116.60 $243.40 $25.57
$5,637.00 $687.71
Total 4 $6,324.71
$5,637.00 $687.71

 

Grand Total $6,324.71

 

 

Case 3:13-cv-01060 Document 53-1 Filed 04/14/15 Page 5 of 6 PageID 1 8

BBQ _02349

 PAYCALC 

 

a program to calculate backpay with interest

Industrial Labor Management
Enteres? Due at End of Apr 2015, compounded 

 

129.19.. -. Backpay Earnings  l0t9?9?L,
Rosheta Jackson

00/2011 $012.00 $0.00 $012.00 $70.20
07/2011 $1,300.00 $0.00 $1,300.00 $104.20
00/2011 $1,300.00 $0.00 $1,300.00 $159.19
09/2011 $1,300.00 $0.00 $1,300.00 $154.14
10/2011 $1,300.00 $0.00 $1,300.00 $150.37
11/2011 $1,300.00 $0.00 $1,300.00 $140.00
12/2011 $1,300.00 $0.00 $1,300.00 $142.05}

$8,772.00 $993.01

Total $9,765.61

 

$8,772.00 $993.61

 

 

Grand Total $9,705.01 

 

Case 3:13-cv-01060 Document 53-1 Filed 04/14/15 Page 6 of 6 Pageg?so