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To summarize our 30 minute meeting, I was basically offered "an opportunity=20
to make some money on the side." Mr. Cohn suggested that if I knew of "2 or=
=20
3 other, hard working, conscientious, intelligent black people who could=20
"penetrate the black community" in effort to persuade black business owners=20
to buy advertising on COOL 105, then we all could share "in the pot of=20
money." He would get "the most" of course, because it's his "radio station,=
"=20
and the 2 or 3 black individuals that I coerced into and trained in working=20
with me and him, would get some and I would=20
get some of the money. =20

Mr. Cohn admitted to me that they had come to realize that some of the issue=
s=20
I had brought to the management's attention in the past when I was a=20
part-time employee, regarding the "black community" was correct. He also=20
stated that "out of all the people who had worked at the radio station," I=20
was the "only one who always talked about the black community," and that thi=
s=20
was an area where they "a bunch of white folk" were not able to penetrate,=20
thereby, not generating 30 to as much as 60% of the potential revenue in the=
=20
black community."=20

Mr. Cohn further stated that since I had always expressed a passion for the=20
station that perhaps I could offer some additional insight, ideas and such t=
o=20
help them know how to accomplish their goal. =20

Mr. Cohn further suggested that if I knew 2 or 3 other "black people" that=20
would be interested in this kind of situation, it would be a lot easier than=
=20
placing an ad in the paper. And, before he started talking with people whom=
=20
he knew nothing about, he would offer this opportunity to me, if I knew of=20
these kind of people, because=20
he knew that he did not know of any.=20

Mr. Cohn, also indicated that there was not need to rush into a decision at=20
this time. He suggested I take my time and think about what he was offering=
=20
and if it was something I'd be interested in doing, he'd like to have his=20
"game" in place by September. Mr. Cohn made it clear that he didn't want t=
o=20
deal with interviewing "black people" or going through the hassle of=20
advertising for them. =20

15

Technically Mr. Cohn has no legal way to advertise for minorities to be used=
=20
the way he intends to use them without violating EEO policies. And, by him=20
not legally and legitimately advertising under established EEO guidelines he=
=20
is in violation =E2=80=A6 Certainly an ad in the paper such as:

"ATTENTION =E2=80=A6 COOL 105 RADIO STATION & WHITE GENERAL MANAGER SEEKS 2=20=
OR 3 HARD=20
WORKING, CONSCENTIOUS, INTELLIGENT, BLACK PEOPLE TO PENETRATE THE BLACK=20
COMMUNITY AND BLACK=20
BUSINESS OWNERS IN CHARLESTON, SC AND SURROUNDING AREAS IN EFFORT TO GENERAT=
E=20
REVENUE FOR MY RADIO STATION AND MAXIMIZE=20
MY PROFIT THAT I AM NOT ABLE TO ACHIEVE ON MY OWN BECAUSE I=20
DON'T KNOW ANY, AT ALL =E2=80=A6"

On July 31st, 2002, I received an email referring me to a site where I was=20
able to access and download a 112 page document in which 36 of the pages,=20
that I have provided as enclosures, were communications about me directly or=
=20
referring to me, my employment, circumstances regarding my employment and=20
issues concerning my re-employment within the LM Communications management=20
system. =20

These enclosures, that I submit along with my formal complaint, further=20
validate and substantiate my initial concerns and provide credibility to my=20
allegations and warrant an investigation into allegations that are in direct=
=20
violation of Title VII of the Civil Rights Act (Title VII), Equal Pay Act=20
(EPA), and the Civil Rights Act of 1991, as they pertain to the illegal and=20
unethical business practices of L. M. Communications Inc.; L. M.=20
Communications of South Carolina, Inc.; L. M. Communications II of South=20
Carolina, Inc., et al., 1300 Greendale Road, Lexington, KY 40511 and 59 S.=20
Windermere Blvd, Charleston, SC 29407. =20

These enclosures were provided to me and abstracted from the PD, Lee Kent's=20
LM Communication's management documents while an employee of LM=20
Communications who had been hired in January 2002 and then let go in July=20
2002. =20


16