Case 4:21-cv-00686 Document 1 Filed on 03/02/21 in TXSD Page 12 of 82
in firing and/or removing all but a few top-level Black employees from their positions. Many of the fired and removed Black employees have held their positions for decades while compiling exemplary work histories at the College before Maldonado’s arrival. A. Maldonado s Documented Hispanic Preference” Agenda 103.
The massive displacement of senior level Blacks at HCC is not accidental. Nor is
the displacement of Blacks merely de facto discrimination (although it certainly is that)—it is much more premeditated and intentional as documented in an email string Plaintiffs have obtained.3 104.
Maldonado became chancellor in May 2014. He is Hispanic. He immediately set
the College on a dramatic new racist course. Within a month of being confirmed as the new chancellor, Dr. Ricardo Solis, a Hispanic Director at HCC, explained in writing that Maldonado would adopt policies and take actions to provide preferential treatment for Hispanics. In an April 21-24, 2014 email string, Solis wrote to Maldonado congratulating him on his appointment. Solis offered to provide the new chancellor with “the pulse of [the College] system” and invited him to have dinner soon. Within days of that email, Solis wrote another Hispanic colleague at HCC the following prescient email reflecting Maldonado’s racist agenda: “Now WE [Hispanics] will finally get preferential treatment.”4 Another recipient on the email string will testify in this case that he personally saw and participated in HCC interviews where more qualified Black employees were repeatedly not even considered while less qualified Hispanic candidates were put into positions
3
An authorized recipient of the email string supplied the emails to Plaintiffs. See Exhibit 2. One of the recipients of these emails will testify that he personally observed intentional discriminatory decisions being made to hire multiple less-qualified White and Hispanic applicants over more qualified Black candidates. There is also evidence that new HCC positions were promised to Hispanic or White hires before Black employees were ever notified that the positions were being posted or available for the Black employees to apply. Another scheme was to “eliminate” a position held by a Black employee, only to recast the same or similar job duties under a different title, then give the “new position” to a Hispanic or White candidate. 4
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