Plaintiff Ayoade Farinde, is a resident of Houston, Harris County, Texas

Talent Engagement told Dr. Adams that his file is still with David Cross. Dr. Adams finds himself

in the midst of the employment displacement plan, i.e.:

a. Black employee is targeted for firing, disciplinary action, demotion, or removal;

b. allegations are manufactured with false, exaggerated, excessive, or completely untrue narratives about the Black employee which purports to claim the Black employee violated some HCC rule or policy;

c. an “investigation” is launched into the inflated or false charge;

d. the charade of an “investigation” is merely a pretext to place the Black employee under suspicion, placed on administrative leave, reassigned, or have their position eliminated all together;

e. the Black employee is then confronted with the trumped-up charges and resultorientedinvestigation and thefindings inthe “investigation” are thenused to “pad”the employee’s personnel file for justification of further adverse employment actions against the Black employee; and

f. if the Black employee refuses to confess to the false and/or exaggerated charge(s), or otherwise tries to expose the injustice of the charge (for example, by filing an EEOC complaint, filing or participating in litigation against the College, or whistleblowing), they suffer multiple indignities such as being placed on forced administrative leave, deprived of promotions, placed under the supervision of unqualified employees whom the Black employees actually first trained, and/or being left out of meetings and ultimately terminated from their employment.

More so, when Dr. Adams tried to complain pursuant to HCC’s internal grievance

procedures, he was stonewalled from doing so, something that does not occur when other White

or Hispanic individuals have similar complaints. Rather, Dr. Adams has not been afforded the

opportunity to address his complaints through HCC’s written policy, as they are selectively

enforced, or not followed, when it comes to Black HCC employees.

79. Moses Agboola Race discrimination: Pay Disparity/Promotion/Harassment/

Advancement Denied. Mr. Agboola works in HCC’s IT department. Mr. Agboola, and the three

other black co-workers in his department are faced with constant harassment and discrimination

from their supervisors, Saul Marroquin, and the Lead Tech (Assistant Manager) Antonio Quintero,