Plaintiff Cassandra Brown is a resident of Houston, Harris County, Texas

manufacturefalseclaimsagainsttheBlackemployeeswhichthenarepurportedly“investigated”—

which investigations manufacture objectively false claims against the Black employees—-

resulting in their ultimate dismissal, termination or being victims of other adverse employment

action. College subordinates like Thomas Anderson, Janet May, and Maya Durnovo, have

participatedin and/orhave authorized false reports orcharges against many ofthePlaintiffs named

in this suit, andapproved thesefalsereports evenwhen thealleged wrongdoing was probably false.

Janet May and others under her then carry out the displacement of the Black employees by either

placing them on “leave of absence,” “transforming” the employee out of their job, or the

employee’s position is “transformed” to a different title or eliminated all together, then the

“vacancies” or “new positions” are filled by less qualified Hispanic or White candidates. Also, the

slightest perceived rule infraction by a Black employee is exaggerated and elevated to a serious

offense worthy of severe disciplinary action, “final write-ups,” or termination; while similar and

even more grievous infractions by Hispanic and White employees are ignored, treated as trivial,

and/or are overlooked entirely. HCC has essentially put in place an effective “Displacement Plan”

for Black employees which is pretextual to get around the appearance of racial discrimination

when in fact it is utilized to discriminate against Black employees. Following are some of the

more common components of the various discriminatory schemes used at HCC to rid itself of

talented Black employees:

a. a Black employee is targeted for firing, disciplinary action, demotion, or removal;

b. allegations are manufactured with false, exaggerated, excessive, or completely untrue narratives about the Black employee which purports to claim the Black employee violated some HCC rule or policy;

c. an “investigation” is launched into the inflated or false charge;

d. the charade of an “investigation” is merely a pretext to place the Black employee under suspicion, placed on administrative leave, reassigned, or have their position