Plaintiff Antionette Dickson is a resident of Houston, Harris County, , Texas

resignation - Rosemary Edwards was a mathematics professor at HCC for 15 years. In 2018, due

to “transformation,” the department did not assign any classes to her but instead gave them to

newly hired faculty members who were not Black. HCC constructively discharged Ms. Edwards

when she was forced to resign from her position in late 2019.

140. Catina Eiland - Race discrimination: Wrongful termination/ Denied FMLA

/Retaliation/Forced to sign fabricated violation/complaint - Ms. Eiland worked as an enrollment

associate at HCC from 2009-2018. She was displaced from her home as a result of Hurricane

Harvey and was diagnosed with PTSD. Despite this condition, HCC refused to allow her to use

FMLA and informed her that she would lose her job if she did not return to work. HCC gave Ms.

Eiland's original job duties and direct reports to Laura Velasquez, a Hispanic female, who was in

school at the time and had no degree. HCC terminated Ms. Eiland's employment only to rehire

her in a reduced capacity.

141. Lorlie Ellis - Race discrimination: Denied promotion/advancement - Ms. Ellis

worked in several positions at HCC from 2008 – 2016. She faced constant harassment and

retaliation from her supervisors, especially after Maldonado arrived. In her dedication to HCC,

Ms. Ellis applied for several positions at HCC but was never even offered an interview. To

improve her prospects, she obtained a doctorate and applied for additional jobs within HCC also

to no avail. Without any path available at HCC to advance, she was forced to resign.

142. Readri Epps-Lincoln – Race discrimination: Retaliation/ Harassment/ Intimidation/

Reduced Pay - Readri Epps-Lincoln was hired by Houston Community College in May 2000 as

the Senior Human Resources Representative, and worked in the Human Resources department for

sixteen (16) years under Katherine Engle (current Executive Director) and Janet May (Chief

Officer of Talent Engagement), both of whom are white females. Ms. Epps-Lincoln accepted a