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EXHIBIT 2-E

UNITED STATES DISTRICT COURT


NORTHERN

DISTRICT OF FLORIDA

PENSACOLA DIVISION

Plaintiffs,

v.

CASE NO. 3:05cv286/MCR

CITY OF PENSACOLA and


PENSACOLA PROFESSIONAL
FIREFIGHTERS LOCAL
CHAPTER 707,
Defendants.

Affidavit of

Before me, the undersigned authority, personally appeared ~ by me first duly sworn deposes and states on oath as follows:
-

/;:' who, being

I am a firefighter in the Pensacola Fire Department. I began working there


February 27,1989, almost twenty years ago. I am a white person but I have made it
clear that I do not agree with racism or discrimination against anyone. During my
employment as a firefighter, I have heard many racist comments made about African
American firefighters by white firefighters. Many white firefighters who do not consider
themselves to be "racist" still commonly use the term "nigger."
I have heard derogatory jokes about African Americans using "nigger" told in the
presence of upper management at the fire station and no corrective remarks or action
has been taken. These kind of comments are common and accepted. The
atmosphere toward African Americans and women is generally hostile. I hear
comments like "Why aren't 'they' happy? They have a job, or 'they' got promoted."
I recall sometime in 2000, one white firefighter, ~

J. telling

"What is a substitution in the NBA? Answer: Renigging." _"

0"

__

the joke

.lalso said this

to several people - "look at those little nig91ets playing." He thought that he was really
being funny.

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___ .~I recall thaL,.

" ~_

~offended an Afrir~r] AmericanC

.J

When

~~- _ .".performed well on a practice test, Chief\."


_4 made a comment to him - "I
k""w that you all have trouble in school. so let me know if you need remedial classes."
. ~was
o~ended because Chief!;
->E ~assumed that ~::-i-. '; -Jand
all other
Arncan Americans needed remedial classes.
We all live and work at the fire department with the common knowledge about
the blatant racist acts of white firemen that have never been disciplined. Some of the
racist acts include:
1} Whites calling Blacks niggers in front of their superiors.

C . -

2} Whites dressing up as KKK r.1~nsmenin sheets, like


Nho
admitted doing it, and
""ho dressed in a white pillow case and kicked
. a door open and showed(
__
Jd hangman's noose and invited him to
join them outside with the otner white firefighters to see if he could be "fitted for a
necktie"after they all watched the racially-based movie, "Mississippi Burning."

C-=-

3) Two different nooses at the fire station were found by_

.land

4) Racist jokes by the white firefighters in the presence of their superiors.


The bottom line is the message is loud and clear -- Racist attitudes and actions
are condoned, and if you complain you will be retaliated against.

.---

I ......
"Q
ohserved

what happens to peonle that complain about racism. I know


that
!rote up a statement that /
,Joke about
and
said "that Wt:: uv not need nigger~ in fhq departmen1 married to white women. I he
battalion chief retaliated against
or speaking up and placed him directly under
f
~s~pervision,
where he
ostr~cized And ignorArI I I"\ver~ear< _

_speaking about how he was mlstreattngl.,


said: "thafno good
bastard, he is going to get his pay took for talking auout me. I wOricer how he likes his
job now."

wa~

It appeared to me that African Americans were essentially kept out of the loop
about opportunities for training, advancement, and mentoring. At the same time, white
firefighters were given advance information about tests which enabled them to get
higher scores for promotions. In one instance, about three years ago, a group of white
firefighters were told in advance that certain questions would be on the test even
though the posted syllabus did not cover these questions, so others not given that
advance information were not prepared to answer those questions.
I have complained to Suzanne Humphrey at the civil service board several times
personally about the promotion tests being compromised in this manner and she would
tell me that there was nothing that she could do about it. She would become scared
and agitated. She appeared to have no authority or power over the tests.

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I have also complained to ActiI19 Chiefr-.

Chief(
and Chief
and the~ toOl<. ~utelY
no_
when Chief "
.Istood outside
my office and pretended to cry like a baby. He said "Oh they cheated, ... wahhh too
>

,about the tests being compromJsed in th~er


corrective action. In fact. I was ridiculed for cornplalnlnq
bad."

f have observed that Blacks have often been assigned to menial tasks in a
repetitive fashion while Whites have been allowed to sit back in their chairs.

r am also concerned about the fairness of the grading Of the practical hands on
part of the promotion tests as this was done by the Chiefs and was very subjective.
The atmosphere of racism still exists at the Pensacola firefighters. The African
are made to feel unwelcome and unprotecf;ed. The white firefighters keep
helpfUl information to themselves and exclude African Americans and others who do not
agree with their attitudes, such as:
Americans

1) Information about test questions;


2) Knowledge

that six captains slots were available instead of one; and

3) Information apout pracUoaJ portions of the test that counted toward the test
grade even though the sUbject matter was not previously CJisclosedfor all to
prepare for the test.

This has lead to favoring whites in promotions and disfavoring African Americans
and other white firefighters wtlo are sympathetic to African Americans. Once a alaCk
firefighter or a white person who openly objects to the racism, is heJd back unfairly In
promotions. then the person held back loses seniority, money. and the opportunity to
apply for other positions.
- The present attitude about Afiican Americans can be summed up by an older
retired firefighter recently coming to the fire station and stating to the white firefighter understand that you have to eat off the same table with the nfggers now'? We did not
have to do that" - and the whIte firefighter simply saying "yeah, we have to do-that."

*.

To this day. I see that white firefighters are also given pref9r'entlal treatment
when they are promoted without an opening. Yet. African Americans haVe been
prevented from being promoted even though openings exist African American
firefighters are still kept out of the loop of information. They are still denied training and
white firefighters are still given unfair advatlG6 information abOUt tQst 9xam qo~on:s
and teshmswers. ThIs haS been brought to the city's attention by going to the Fire
Chiefs and to the Civil Service Board and no one has takGn any eorreetive action's.

.."-

.~

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-"*'

--:!:- -=-~

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---------------

an

uiI!i3!::a1o

My Commission

Expires; __

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NOTARY

PUBLIC

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