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Plaintiff Trina Campbell is a resident of Houston, Harris County, , Texas

in firing and/or removing all but a few top-level Black employees from their positions. Many of

the fired and removed Black employees have held their positions for decades while compiling

exemplary work histories at the College before Maldonado’s arrival.

A. Maldonado s Documented Hispanic Preference” Agenda

103. The massive displacement of senior level Blacks at HCC is not accidental. Nor is

the displacement of Blacks merely de facto discrimination (although it certainly is that)—it is

much more premeditated and intentional as documented in an email string Plaintiffs have

obtained.3

104. Maldonado became chancellor in May 2014. He is Hispanic. He immediately set

the College on a dramatic new racist course. Within a month of being confirmed as the new

chancellor, Dr. Ricardo Solis, a Hispanic Director at HCC, explained in writing that Maldonado

would adopt policies and take actions to provide preferential treatment for Hispanics. In an April

21-24, 2014 email string, Solis wrote to Maldonado congratulating him on his appointment. Solis

offered to provide the new chancellor with “the pulse of [the College] system” and invited him to

have dinner soon. Within days of that email, Solis wrote another Hispanic colleague at HCC the

following prescientemail reflecting Maldonado’sracist agenda: “NowWE[Hispanics]will finally

get preferential treatment.”4 Another recipient on the email string will testify in this case that he

personally saw and participated in HCC interviews where more qualified Black employees were

repeatedly not even considered while less qualified Hispanic candidates were put into positions

3 An authorized recipient of the email string supplied the emails to Plaintiffs. 4 See Exhibit 2. Oneofthe recipients of these emails will testify thathe personally observedintentional discriminatory decisions being made to hire multiple less-qualified White and Hispanic applicants over more qualified Black candidates. There is also evidence that new HCC positions were promised to Hispanic or White hires before Black employees were ever notified that the positions were being posted or available for the Black employees to apply. Another scheme was to “eliminate” a position held by a Black employee, only to recast the same or similar job duties under a different title, then give the “new position” to a Hispanic or White candidate.

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