Plaintiff Beverly Perry was a resident of Houston, Harris County, Texas

because he was never interested in training. This was all a part of Joe’s plan to push Andrew in a

lead role and prevent Ms. Jones from advancing in the department. Andrew was then given the job

of web content specialist. Despite being the more qualified and experienced for the position, and

even training the individual that was awarded the position, Ms. Jones was denied a promotion in

favor of a less experienced, less qualified non-black employee. Later, Ms. Jones was given job

responsibilities outside of the scope of employment. When she complained to her manager, he

told her to figure it out or face the consequences. She was not provided with any additional

compensation or benefits for the extra duties even though other white and Hispanic employees

who were working outside of their scope were regularly given stipends or additional benefits. Joe

Conway called Ms. Jones in to meet with him and Linda. Shortly into the meeting Linda began to

echo things from Joe regarding constant mistakes that he had harassed Ms. Jones about on an on-

going basis relating to her perceived deficiencies in the tasks outside of her scope of employment.

It became apparent to Ms. Jones that he was plotting with Linda to move against her with some

performance issues. Linda Toyota began to tell Ms. Jones that the Chancellor was on to her about

errors that Ms. Jones had made in her work. When Ms. Jones responded that she had been given

these tasks of writing by Joe, but writing did not have anything to do with her Job Description, she

was ignored. To add insult to injury, Linda Toyota denied additional training for Ms. Jones in her

new capacity, while non-Black employees were regularly allowed to receive training to succeed

and advance in new positions. Rather, Ms. Jones was being selectively targeted in order to pad

her employee file as an insubordinate and ineffective employee even though HCC was the culprit

in failing to provide her with the resources to effectively complete her duties. Ms. Jones was being

setup to fail.

107. Elamees Kelly-Molo - Race discrimination: Denied promotion/advancement -