Plaintiff Quincy Henderson is a resident of Manvel, Brazoria County, Texas

as a Tech I but with higher pay. Mr. Crosby worked during the pandemic, but neither HR nor his

managers will approve essential pay as they have approved for other white and Hispanic

employees. Since his hire, he has applied for promotions to Tech 2, Tech 3 and Quality Assurance

Coordinator. One such time was at the request of his supervisor and he still did not get the

promotion. When Mr. Crosby asked why he was not being hired for the position and was told that

he does not have credentials– the other person (a non-Black) got the position because he had a

boiler certificate. But, having a boiler certificate was not a requirement of any of the positions for

which he applied. When applying for other positions, he was told that he had not been with the

company long enough – then a non-black individual was hired "off the street" from Amazon. He

was ultimately told he was better suited for Tech II but was not hired when he applied twice in

favor of less qualified and less experienced non-black employees. When his supervisors call

campus managers to check on his performance, they all say that he does good work. Mr. Crosby

is often asked to help the non-black Tech II and Tech III because of his knowledge and experience

and who he is also responsible for training, but he himself cannot be promoted to one of those

positions despite his tenure and qualifications. Essentially, Mr. Crosby is capable enough to train

the Hispanic and White employees on how to be a Tech II or Tech III, and he is also tasked with

physically completing that work, however he is no qualified enough to actually be placed in that

position along with the added salary and benefits that would come along with it.

87. Linda Denkins - Race discrimination: Denied promotion/ advancement/

Demotion/Income Loss/Retirement Loss - Linda Denkins was a 40-year+ employee of HCC. HCC

moved counselors from the faculty pay scale to a lower pay scale which caused Ms. Denkins to

lose thousands of dollars of income. Greater than 50% of the counselors at HCC were black

counselors so this reduction disproportionately affected black employees as compared to white