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Plaintif Adrian Brown is a resident of Houston, Harris County, Texas

and permits Plaintiffs to press their private claims in this suit against HCC. Because the College

accepts federal grant funding, 1 the the College thereby expressly agreed to waive its sovereign

immunity to the type of racial discrimination and retaliation claims Plaintiffs assert in this case.

See Gruver v. La. Bd. of Supervisors for the La. State Univ. Agric. & Mech. Coll., 959 F.3d 178

(5th Cir. 2020) (governmental entity which accepts federal funds held to have expressly waived

sovereign immunity as to discrimination claims).

98. Venue is proper in the Southern District of Texas because the events complained

about in this casesubstantially occurred in Harris County, Texas, andwithin theHouston Division.

Additionally, the Defendant has its principal place of business in this District. At least one ormore

of the Plaintiffs have satisfied all conditions precedent, either individually and/or representatively

on behalf of the Putative Plaintiff Class, to bring the claims asserted in this suit, including

exhaustion of pre-trial administrative opportunities to resolve this dispute, if any such acts were

required.

IV.

BACKGROUND

99. Plaintiffs are victims of a well-developed, systematic, entrenched, and wildly

successful campaign of deliberate race and sex discrimination against non-Hispanic Black

employees in various employee and leadership positions at HCC. This “campaign,” led by

Maldonado and implemented and enforced by a number of unsued supervisors at the College, is

andwas carriedout with great efficiency andhas resultedinthedismissal,demotion,displacement,

and/or termination of Black employees at alarming and disproportionate rates. Maldonado and his

henchmen target Black executives and employees to be removed or demoted, then subordinates

1 See Exhibit 1: Relevant pages from the HCC’s 2019 Fund Report documenting its receipt and acceptance of federal funding at the College. Such receipt of federal funds continued throughout the entirety of the period covered by this suit.

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