THE WITNESS: I guess she was overimpressed with the fact that this was the case throughout industry, not just Western Electric.
THE COURT: What do you mean "overimpressed"?
THE WITNESS: Perhaps that was not the right word. It was deep in her mind and she never missed an opportunity to bring up a point on it.
THE COURT: When you say "her philosophy", then you mean the fact that she pointed out that in her view women were disadvantaged?
THE WITNESS: Yes.
THE COURT: At Western Electric?
THE WITNESS: Yes.
THE COURT: And, indeed, in American industry?
THE WITNESS: Yes.
THE COURT: Did you view that as a claim without basis?
THE WITNESS: No, because I would have to agree with her to a certain extent, that throughout industry this was the case.
THE COURT: Then when you say "a matter of philosophy, chip on the shoulder," and the like of that, are you meaning to imply that she was being irrational or unreasonable about it?
THE WITNESS: I would say she was to the point of being irrational about it.
THE COURT: You mean she was concerned about it to the point of irrationality?
THE WITNESS: Right. LN * * *
Again, the objective evidence confirms the accuracy of Kyriazi's complaints to Imandt. It is interesting to note that the Kyriazi-Imandt confrontation concerning sex discrimination at Western began in early 1968 and carried forward throughout that year. The evidence in this case establishes that as late as 1974, six years after her protests to Imandt, and some three years after Kyriazi had been fired these sex preference personnel forms remained in full use at Western:
Summary of 1974 Requisitions Containing Sex Preferences
There were 9 Section Chiefs or Department Chiefs requested. All requests were for males.
There were requests for 12 Craftsmen. 11 requests were for males; the 12th was for a female Waste & Water Treatment Operator.
There were 23 requests for Grade 37 openings. All requests were for males.
There were 41 requests for Grade 36 openings. All requests were for males.
There were 61 requests for Grade 35 openings. 60 requests were for males; 1 request was for a female.
There were 85 requests for Grade 34 openings. 76 requests were for males; 9 requests were for females.
There were 60 requests for Grade 33 openings. 52 requests were for males; 8 requests were for females.
There were 96 requests for Grade 32 openings. 9 requests were for males; 87 requests were for females.
All 500 series Clerical requests were for males.
All 200 series Clerical requests for grades 209 and above were for males.
Not all organizations shown on the requisitions were listed by Western in its answers to Interrogatories.
It is, therefore, plain that Kyriazi's complaints to Imandt about the status of women at Western in general, and her condition in particular, were not the product of an irrational mind. We also consider some of this evidence Infra in dealing with Western's contentions that Kyriazi is not a satisfactory representative of a class comprised of all female employees at Western.
As a result of her confrontations with Imandt beginning in early 1968, Kyriazi attempted to transfer out of his department to work with computers in Information Systems. There is ample evidence in the record that those in authority in Information Systems told Kyriazi that they had no openings; they in fact did not want her; that she had been "turned down" both by Department Chief Wilser (Exhibit D-74b), and by Wilser's boss, Assistant Manager Wertz. "Imandt contacted G. C. Wertz to see if he would Reconsider taking her into his organization. He asked to see her personnel records, which were given to him. After reviewing these records And discussing the situation with J. Wilser he concluded he could not find a place for her in his organization." (Exhibit D-74(b), emphasis added).
The evidence is clear that Wilser and Wertz did not take Kyriazi but not because there was no opening for her. (Tr. 2604-6, 3400; Exhibit D-74(b) page 3). In fact there were such openings. (Tr. 4534). n22
n22 The following people were in fact hired or transferred into Information Systems in 1968 or at the beginning of 1969:
P-145 S. T. Liu (hired)
P-149 E. Stewart (hired)
P-214 P. Crefeld (transferred)
P-147 R. McCauley (transferred)
It is impossible, looking back years later, to determine whether Wilser and Wertz did not want her because she was a woman or because Imandt had reported that she was a troublesome woman,
but it is plain that she was not wanted and that she was put off by them on the false ground that there was no available opening.
This situation with Imandt continued throughout 1968. Finally, in December, Kyriazi went to Imandt's boss, McCaffrey, Assistant Manager of Industrial Relations, requesting to transfer to Wertz's organization in Information Systems. Imandt then prepared a letter for McCaffrey's signature, in order to arrange a transfer to Information Systems. That letter (Exhibit P-177) begins as follows:
Miss K. Kyriazi, an Industrial Engineer with 34 months experience in our organization, has expressed a desire to be transferred to an area where she can make more effective use of her educational background in the field of computers, economics and statistics.
There then follows her curriculum vitae, including her three degrees. Of her service with Western at Kearny, the letter reports
. . . she was transferred to Kearny as an Engineer in the Industrial Engineering Organization where she is presently employed. During this period she has performed satisfactorily as an Engineer associated with Wage Incentives, Maintenance and Administration of Inspection and Merchandise Incentives.