Case 4:22-cv-01547 Document 1 Filed on 05/13/22 in TXSD Page 43 of 76
because he was never interested in training. This was all a part of Joe’s plan to push Andrew in a lead role and prevent Ms. Jones from advancing in the department. Andrew was then given the job of web content specialist. Despite being the more qualified and experienced for the position, and even training the individual that was awarded the position, Ms. Jones was denied a promotion in favor of a less experienced, less qualified non-black employee. Later, Ms. Jones was given job responsibilities outside of the scope of employment. When she complained to her manager, he told her to figure it out or face the consequences. She was not provided with any additional compensation or benefits for the extra duties even though other white and Hispanic employees who were working outside of their scope were regularly given stipends or additional benefits. Joe Conway called Ms. Jones in to meet with him and Linda. Shortly into the meeting Linda began to echo things from Joe regarding constant mistakes that he had harassed Ms. Jones about on an ongoing basis relating to her perceived deficiencies in the tasks outside of her scope of employment. It became apparent to Ms. Jones that he was plotting with Linda to move against her with some performance issues. Linda Toyota began to tell Ms. Jones that the Chancellor was on to her about errors that Ms. Jones had made in her work. When Ms. Jones responded that she had been given these tasks of writing by Joe, but writing did not have anything to do with her Job Description, she was ignored. To add insult to injury, Linda Toyota denied additional training for Ms. Jones in her new capacity, while non-Black employees were regularly allowed to receive training to succeed and advance in new positions. Rather, Ms. Jones was being selectively targeted in order to pad her employee file as an insubordinate and ineffective employee even though HCC was the culprit in failing to provide her with the resources to effectively complete her duties. Ms. Jones was being setup to fail. 107.
Elamees Kelly-Molo - Race discrimination: Denied promotion/advancement -
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