Plaintiff Rodney Jackson is a resident of Houston, Harris County, Texas

Mr. Ford’s qualifications, managerial positions in the IT department are awarded to less qualified

and less experienced Hispanic individuals as opposed to qualified black employees. Mr. Ford is

also paid less than his Hispanic co-workers despite his qualifications and experience. Whenever

Mr. Ford attempts to address these issues with his Hispanic supervisors, he is either ignored or

given the runaround where ultimately nothing ever comes to fruition. In (May 2018) the senior

tech at the (Pinemount Campus) retired. Jose Gonzales (a Hispanic) who Mr. Ford taught and

trained was put in charge of that campus instead of him who had more years and experience. Mr.

Ford was told by Mr. Marroquin that he needed the “senior tech” to be at the “Pinemount campus”

And that Jose had already been doing the job there. This was his way of saying there was no point

in Mr. Ford applying because he was going to give the job to Jose. Jose even told Saul that Mr.

Ford was more qualified for the job. But Saul didn’t care because he wanted a Hispanic. This

position would have been a significant raise in pay and responsibility for Mr. Ford. Saul also made

a statement in a meeting at the “Fraga Campus” in which Saul stated that the “Hispanics’ were

going to be running things. In (august 2018) Saul Marroquin decided he was going to move Mr.

Ford from his current location by having his coworkers all “vote” on what location he would be

going to. He did this in order to embarrass and belittle Mr. Ford. His coworkers responded by

telling him this was not their job and it was not right for them to vote on that and they wanted no

part of it. However, he insisted that they do so anyway. Saul again choose to shame and harass Mr.

Ford while he was on FMLA. HCC policy is to notify your manager when you will be out. It is the

manager’ssoul responsibility tonotifyanyoneelse. But whileMr. Fordwas on intermittent FMLA

whenever he would call off Saul insisted that he call each of his coworkers and inform each of

them that he would not be at work. This harassment resulted in him only taking minimal time off,

instead of the time he needed to take because of the constant pressure and harassment from Saul