Plaintiff Doris Lacey is a resident of Houston, Harris County, Texas

that they were in fact good friends. This is just a glimpse of how HCC’s policies are selectively

enforced or rather, not enforced for Black individuals at the campus. Although Ms. Hubbard had

a valid complaint she wished to file against a member of the HCCPD, since Captain Boxie was an

individual with some amount of clout at the college, HCC effectively stonewalled Ms. Hubbard

from moving forward with a complaint by giving her the run around and not actively following

HCC written procedure. Such treatment is not seen amongst the other white and Hispanic

employees of the college. Rather, Black individuals’ complaints are regularly treated with less

haste, more skepticism, or no action at all. Since attempting to lodge her complaint, Ms. Hubbard

has faced retaliation. Captain Boxie in turn filed a complaint of his own against Ms. Hubbard

which mischaracterized her as an unprofessional, stereotypical angry, black female who interferes

with the police activity. All of these allegations are untrue. Her initial complaint involved a

perceived lack of police presence around the campus and in the library. Since making her

complaint, she has noticed even less of a police presence in the area of the school that she works.

100. Rodney Jackson - Race discrimination: Wrongful termination - Mr. Jackson began

his employment at HCC as Manager of Financial Aid Services. Mr. Jackson had years of success

atHCCuntilthearrivalofChancellorMaldonado. AfterMaldonado’s arrival,Mr.Jacksonnoticed

that many of his other black co-workers were being replaced in favor of white and Hispanic

employees. Shockingly, Mr. Jackson was made aware that his Hispanic supervisor, Teri Zamora,

said that he too needed to go. Following this, one of his employees went to HR to file a grievance

complaint against him because shedid not get a position shethought shewas getting (SocialMedia

Coordinator). HR referred the employee to the OIE’s office to file her grievance with that office.

Employee filed a false Title IX “Sexual Harassment” compliant against Mr. Jackson alleging he

made unwanted sexual favors/advancements to her. He was called in by EEO/OIE’s office to