Plaintiff Reynaldo Pradia is a resident of Houston, Harris County, Texas

addressing other employees, and abused her power and authority over Ms. King. Ms. King was

the only individual in her department that received such behavior from her manager. The other

white and Hispanic individuals were not subjected to such treatment. Ms. King experienced

retaliation for turning in her coworker to HR and for bringing up some improprieties that she

discovered in HCC’s financials to her supervisor. The project consisted of cleaning up the assets

that HCC owned. When she started researching, she found out it was a mess, so she ended up just

working on the building’s category, cleaning up over $32 million dollars that have been misstated

in their financials. HCC was very passive and in their communication to the auditors (Grant

Thornton) they mentioned that some cleanup work was done, and they waited for the Auditors to

ask more questions about it. HCC had been written up the previous year and in a write-up like that

it causes the audit firm to be reprimanded so HCC didn't want to trigger another incident with

them. So, the way it was handled it was kind of downplayed so that the Auditors would not be

written up for not catching these items. HCC decided that it would adjust the books and not have

the effect of it roll up through the fund balance. The Accounting Department had the IT Group

zeroed out the dollar amounts. If it ran up through fund balance that would be a bad thing for HCC

because they would have to explain that. The building's category was the only category Ms. King

made adjustments in. As she reviewed the other categories she came up with a lot of different

problems and HCC decided not to correct any other problems. One of the problems that she ran

into was really big in the Furniture and Equipment category. There were no checks and balances

and it was an easy area where merchandise could be stolen. When Ms. King addressed these

concerns with her supervisor, she was told not to worry about it and to do her job. Shortly

thereafter she terminated from her employment. This is another all too familiar tactic at HCC, if

Black individuals happen to stumble upon any impropriety that may be occurring at HCC, they are