Plaintiff Drusilla Bailey is a resident of Houston, Harris County, Texas

60. The conduct complained of in this suit concerns a generalized policy, custom and

practice of conscious and deliberate racial discrimination, retaliation, harassment, and disparate

treatment of non-Hispanic Blacks at HCC in violation of 42 U.S.C. §§ 1981 and 1983, which

provides a cause of action and waiver of HCC’s alleged immunity. The complained-of conduct

was deliberate, willful, intentional, and clearly unlawful at the time of its occurrence. The

referenced federal law provides for a private cause of action and waives the College's immunity

and permits Plaintiffs to press their private claims in this suit against HCC. Because the College

accepts federal grant funding,2 the College thereby expressly agreed to waive its sovereign

immunity to the type of racial discrimination and retaliation claims Plaintiffs assert in this case.

See Gruver v. La. Bd. of Supervisors for the La. State Univ. Agric. & Mech. Coll., 959 F.3d 178

(5th Cir. 2020) (governmental entity which accepts federal funds held to have expressly waived

sovereign immunity as to discrimination claims).

61. Venue is proper in the Southern District of Texas because the events complained

about in this casesubstantially occurred in Harris County,Texas, andwithin theHouston Division.

Additionally, the Defendant has its principal place of business in this District. At least one ormore

of the Plaintiffs have satisfied all conditions precedent to bring the claims asserted in this suit,

including exhaustion of pre-trial administrative opportunities to resolve this dispute, if any such

acts were required.

IV.

BACKGROUND

62. Plaintiffs are victims of a well-developed, systematic, entrenched, and wildly

successful campaign of deliberate race and sex discrimination against non-Hispanic Black

2 See Exhibit 1: Relevant pages from the HCC’s 2019 Fund Report documenting its receipt and acceptance of federal funding at the College. Such receipt of federal funds continued throughout the entirety of the period covered by this suit.