Plaintiff Mary Page is a resident of Houston, Harris County, , Texas

certifications to perform her duties well and above reproach. Nevertheless, similar to other Black

police officers employed at HCC, she is severely underpaid for the same position and duties that

other White and Hispanic officers are paid. Specifically, a Hispanic officer with similar

qualifications to Ms. Wallace was hired around the same time. The Hispanic officer, Jennifer

Montieo, was onboarded with a starting salary of nearly $10,000 more than Ms. Wallace. More

alarming, Ms. Wallace was forced to patrol HCC without all of the necessary equipment required

by an officer to do their job safely and effectively. She was not provided with a taser until

December 2019, only after a more senior Black officer forced the department to issue her one. No

reason was ever provided to Ms. Wallace as to why she would be endangered this way. Ms.

Wallace and other similarly situated Black officers at HCC have continuously brought the pay

disparity issue to their supervisors’ and HR's attention. To date, no action has been taken by HCC

to ensure that these dedicated officers are paid equal or comparable to their White and Hispanic

counterparts. Ms. Wallace has continued to be intimidated and abused by her superiors and faced

unwarranted disciplinary actions. Regarding the present lawsuit, Ms. Wallace and other Black

police officers have been threatened with termination if they participated in this lawsuit by their

supervisors.

202. Germaine Washington - Ms. Washington has worked at HCC as a Manager of

Conference Services for the last five (5) years. She has been refused the title and compensation

paid to directors even though she handles and performs the duties of a director. Even when a recent

directorship opened up, she was told by her supervisor that she would not be allowed to assume

the position even though she was the best qualified and already doing the work of the director. In

addition, instead of bestowing on her the title for the job functions she was performing, she was

told that HCC would be willing to pay her a stipend for the work, but not bestow on her the title.