Plaintiff Ava Cosey is a resident of Houston, Harris County, Texas

were the final decision-makers in many instances with respect to the employment policies and

practices challenged in this suit.

70. The common practices utilized by these executives yield one of three common

outcomes: (1) Black employees relent to the false charges to keep their jobs, which action is then

used to include a demerit in the employee’s file justifying a demotion or is used as ammunition for

additional adverse employment actions against the employee in the future; (2) the investigations,

administrativeleave, and harassment continues until theBlack employeehas no choicebut to leave

or resign their position; and/or (3) if the Black employees resist the incredible pressure placed of

them, they are terminated, disciplined, put on forced leave, or demoted.

71. As part of this common discriminatory practice, Anderson and May have generally

signed off on the alleged “investigations” of Black employees and, finally, “approved” the

investigations even when they are knowingly false and/or objectively exaggerated. Indeed,

Anderson and May have routinely and customarily signed off on and implemented harsher

punishments for Black employees than White and Hispanic employees accused of the same or

more egregious policy transgressions, and Maldonado ratifies their decisions.

72. Placing an employee on forced “leave of absence” is HCC’s way of placing the

employee under a cloud of suspicion suggesting they have engaged in a major act of wrongdoing.

Since Maldonado’s arrival, nearly 95% of the time when a Black person is given a forced “leave

of absence” they have been ultimately terminated or demoted.

73. Even more distressing is the fact that unsued executives Thomas Anderson and

terminating, disciplining, and/or demoting employees. See Maldonado’s sworn deposition testimony in Cause No. 2015-77438, Dr. Sabrina Lewis v. Houston Community College, taken in the 269th District Court, Harris County, TX. While this testimony is not entirely true—because Maldonado himself instigated the directive by action and policy that Black executives are expendable—it is true that his directive is implemented with dispatch by May and Anderson to rid the College of experienced Black employees.