After three Target employees sued the company for discrimination, including the distribution of "multi-cultural tips" noting the "differences among Hispanic employees," the company says it never meant to offend.
The three employees who filed suit, Robert Gonzalez, 58, Bulmaro Fabian, 58, and Pedro Garcia-Ayala, 36, worked at a Target Distribution Warehouse in Woodland, Calif., about 15 miles northwest of Sacramento. The three men are of Mexican descent, according to the lawsuit, and were employed as warehouse workers "in manual labor positions, while Caucasian employees held nearly all management positions."
Ilija Cvetich, the attorney for the plaintiffs, declined to comment on behalf of his clients.
The three men seek unspecified punitive damages for harassment, failure to prevent harassment, age and race discrimination and retaliation.
According to the suit, "The Caucasian Target managers regularly used racial slurs while addressing plaintiffs and other Hispanic employees on the warehouse floor, including, but not limited to:
"You got to be Mexican to work like this."
"What the hell, I'm already sweating like a Mexican."
"Only a Mexican can work this hard," and
"Only a 'wet-back' can work this hard."
They also allege the company provided its distribution warehouse managers with a four-page document that describes "demographics of the Hispanic community" and their "cultural differences," according to an exhibit in the lawsuit.
A spokeswoman for Target, provided a statement to ABC News, stating, "It is never Target's intent to offend our team members or guests and we apologize. The content of the document referenced is not representative of who Target is. We strive at all times to be a place where our team and guests feel welcome, valued and respected. This document, which was used during conversations at one distribution center, was never part of any formal or company-wide training. We take accountability for its contents and are truly sorry."
The spokeswoman said the company has not yet been served with the complaint and could not comment on it directly.
The exhibit shown in the lawsuit states: "There are many cultural, behavioral and attitudinal differences between Hispanics of different countries of origin."
"Language use and accents: Spain vs. Latin American; Caribbean vs. Argentinean.
Food: not everyone eats tacos and burritos.
Music: not everyone dances to salsa; there are more music styles than mariachi.
Lifestyle: not everyone lives in small, rural communities.
Values: different beliefs
Dress: not everyone wears a sombrero."
The document also described "intra-cultural differences" by stating, "Besides these differences, we need to be aware of clashes and rivalries among Hispanics of different origins. Not all Hispanic groups are alike and not all Hispanic groups get along well."
The document in the lawsuit also gives tips to "communicate cross-culturally" and stated: "Communicating with someone from another culture goes beyond the words and the language. Understand who you are communicating with."
"Their verbal and on-verbal (sic) mannerisms, social tendencies and cultural idiosyncrasies, rather than just trying to substitute words in your language with words in another.
"Cultural idiosyncrasies: Meaning of time, being on time, embarrassed to 'perform' in front of the group.
People do not always say what they are thinking or mean what they say; you have to read between the lines."
According to the lawsuit, Gonzalez alleges that he complained to human resources about racial comments made by his manager and disparity in approving overtime, but his complaints were "dismissed" and his supervisors retaliated for it. He was fired on May 6, 2011 ostensibly for performance reasons, the lawsuit states.
But "Gonzalez believes that Target had been attempting to force Gonzalez to quit by making his work environment more and more hostile and abusive from the date he contacted human resources and reported his manager's unlawful actions."
The three plaintiffs, who are still unemployed today, say they were fired, in part, for racial reasons, the suit alleges.
Fabian was fired on Sept. 10, 2011 for "alleged performance issues after five years of employment with Target," the suit alleges.
He was "terminated while he was on restricted duty for an industrial injury," the suit states, but he "believes his termination was based on being an older Hispanic, Mexican employee."
Garcia-Ayala said he was terminated on July 28, 2012 after 10 years of employment with Target for alleged performance reasons, but he also believes he was fired "based on being a Hispanic, Mexican employee."