Case 4:22-cv-01547 Document 1 Filed on 05/13/22 in TXSD Page 14 of 76
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Proof of the success of the College's Displacement Plan in ridding itself of
experienced Black employees is readily discoverable. Following are but a few actual instances of how the discrimination plot has disparately impacted experienced Black employees at the College since Maldonado’s arrival: a. 45+ year employed top-level Black female, with decades of exemplary work at the College, passed over for a promotion for which she was the most qualified candidate and the position given to a less qualified 30-year-old Hispanic female. b. 20+ year employed Black female, with prior exemplary work history, targeted for removal by the Administration and forced out of her position when her duties were “transformed” and given to a non-Black employee. c. 25+ year employed Black female demoted, and ultimately forced out of her position without cause, when her job functions were “transformed” to non-Black employees. d. 20+ year employed Black female working in a supervisory position, with exemplary prior work history, assaulted by a white female employee in the workplace, then targeted for removal by the Administration. The white female who was the wrongdoer was allowed to remain employed—the innocent Black female supervisor who did not assault the white employee was fired. e. 20+ year employed Black female targeted for removal by the Administration and forced out based on a manufactured false claim. f. 22+ year employed Black female, with prior exemplary work history, targeted for removal by the Administration and forced out of her position under the College “transformation” plan. g. 41+ year employed Black female passed over for promotion to an Executive Director position for which she was the best and most qualified. A white male was given the position. h. Black female with 7 years’ experience working at the College targeted for removal by the Administration and forced out after observing unethical purchasing practices by her Hispanic Purchasing Department Director without any corrective action being taken by the Administration against the Hispanic employee. Only the Black female who complained was displaced. i. 42+ year employed Black female at the College, and creator of the most successful online enrollment program at the College, targeted for removal by the Administration and was removed from her presidency at the NW College’s North West campus and replaced by a non-Black hire.
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