Plaintiff Shirley Collins is a resident of Houston, Harris County, , Texas

111. ByApril13,2015,Maldonadohadimplemented whathetermeda“transformation”

plan, which in effect was his way of displacing Blacks and hiring more less qualified Hispanic and

White employees. HCC’s publications pretend that its displacement of Blacks is merely

undertaken as part of “transforming” the College to a better educational center. And, in a literal

sense, they are in fact “transforming” the College—its upper tier supervisors and personnel are

becoming whiter and more Hispanic at the unfair and discriminatory expense of Black employees.

When Black executives are removed, their vacancies are disproportionately filled with less

qualified Hispanic and White employees.

112. Plaintiffs have evidence that the term “transformation” was a clever afterthought to

mask the true intent of the plan—i.e., to get rid of more Black employees. Plaintiffs’ counsel has

located a witness who will testify that Maldonado and HCC eschewed the phrase “reduction in

force” (“RIF”) because such an approach to displace employees would be expected to proceed on

a “last in-first out” basis or “point-score-calculation” method which would easily compare

employees based on tenure and merit. Such neutral systems would not easily accommodate the

goal of racial replacement of seasoned Black executives at the College. Instead, Maldonado

decided on a “transformation” scheme which more easily accommodated his goal of displacing

Black employees in favor of hiring more Whites and Hispanics.

113. Proof of the success of the College's Displacement Plan in ridding itself of

experienced Black employees is readily discoverable. Following are but a few actual instances of

how the discrimination plot has disparately impacted experienced Black employees at the College

since Maldonado’s arrival:

a. 45+ year employed top-level Black female, with decades of exemplary work at the

College, passed over for a promotion for which she was the most qualified candidate and the position given to a less qualified 30-year-old Hispanic female.