Plaintiff Ameenah Muhammad is a resident of Stafford, Fort Bend County, Texas

Technology. He was told in a letter that the position he held would no longer exist as a result of

“transformation.” At the time this letter was presented to him in the presence of an HR

representative (Satrice Morris), the new Campus Technology Services lead (Regional Manager)

positions had already been filled while being advised to apply. Fortunately, he did apply for the

Regional Manager Campus Technology Services position, which is equivalent to the Manager

Technical Support position in functions that he held at the time the positions were still open. He

was told that he would not be considered for an interview nor offered a position. Instead, one of

thethreeRegional Manager Campus Technology Services positions was offered to a Hispanicwho

had no experience in the functions or duties of the position. The announcement of his new position

identified his background in IT Project Management which is not directly related to the functions

of the position he has been offered. In essence, he was demoted and now holds a Senior Technician

position—a position that used to report to him.

200. LaQuinta Vargas - Race Discrimination: Pay Disparity—Ms. Vargas is a current

HCC employee and works as an Academic Advisor and Adjunct Professor. Ms. Vargas has been

a loyal and dedicated employee. However, her Hispanic supervisors have made it difficult for Ms.

Vargas to fulfill her duties without feeling threatened, bullied, and worried about her job security.

Ms. Vargas and other coworkers have faced constant scrutiny from their Hispanic supervisors,

with reprimands for minor infractions. Other Hispanic and White employees are not treated

as harshly, if at all.

201. Alyssa Wallace - Race Discrimination: Denied Promotion and Advancement/

Demotion/Income Loss/Retirement Loss—Ms. Wallace is a police officer within the Houston

Community College Police Department. She has been an officer at HCC since July of 2019. Ms.

Wallace has been an exemplary employee and has obtained all necessary and additional