Plaintiff Hyginus Chukwu is a resident of Houston, Harris County, Texas

get preferential treatment.”5 Another recipient on the email string will testify in this case that he

personally saw and participated in HCC interviews where more qualified Black employees were

repeatedly not even considered while less qualified Hispanic candidates were put into positions

they were not qualified to occupy. The Solis email string would soon prove true “preferential

treatment” of Hispanics was going to be Maldonado’s racist agenda. Such a race-based policy is

per se racist.

68. Solis’s emails could be dismissed as the wishful thinking of Maldonado’s personal

friend except that, as Solis was an HCC director at the time, his emails indicate the extent and

forethought dedicated to the general policy that led to HCC’s Displacement Plan, as well as his

confidence in Maldonado’s preferential program for Hispanics. Moreover, Solis’s prediction has

proven to be factually true. While Black employees in leadership and other roles have been

uniformly reduced, less-trained and less-experienced Hispanics and Whites have flooded in to

replace them. The events since Maldonado’s arrival only make sense when understood in the

context of HCC’s scheme of racial discrimination and retaliation against Black employees.

B. HCC’ s Racial “Displacement Plan” to Discriminate Against Black Employees

69. HCC’s board of trustees, in practice, has delegated their power and authority to

Maldonado, who in turn has admittedly assigned, delegated to, and acted in concert with his

subordinates the right and authority to hire, investigate, discipline, and terminate the Black

employees.6 Accordingly, Maldonado and the unsued defendants, Anderson and May, are and

5 See Exhibit 2. One ofthe recipients of these emails will testify that hepersonallyobserved intentional discriminatory decisions being made to hire multiple less-qualified White and Hispanic applicants over more qualified Black candidates. There is also evidence that new HCC positions were promised to Hispanic or White hires before Black employees were ever notified that the positions were being posted or available for the Black employees to apply. Another scheme was to “eliminate” a position held by a Black employee, only to recast the same or similar job duties under a different title, then give the “new position” to a Hispanic or White candidate. 6 In another racial discrimination lawsuit filed by a former Black HCC executive, Maldonado confirmed under oath that he simply relies on and accepts the recommendations of his underlings like Janet May and Thomas Anderson in