11.   The lawsuits allege quotas do exist and that older, white men who previously had received positive evaluations were suddenly given C grades.

12.   Those who receive Cs are ineligible for a raise or bonus and a C grade for two consecutive years is grounds for demotion or termination.

13.   Two consecutive C grades are grounds for termination or demotion.

14.   Two consecutive C grades could result in dismissal.