Plaintiff Linda Denkins is a resident of Houston, Harris County, Texas

76. 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+yearemployed Black femaledemoted, andultimately forcedout ofherposition withoutcause,whenherjobfunctionswere“transformed”tonon-Blackemployees.

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 forremoval by the Administration. The white femalewho 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.