Whether a Court may properly grant summary
judgment where a party failed to establish, by a
preponderance of evidence, as shown in the records,
that the party defendant's excuse for failure to
promote was not a pretext for racial and or age
discrimination.

Whether a Court may properly deny summary
judgment on racial discrimination claim where a pro
se party presented credible and relevant evidence of
historical racial prejudice against African American
employees of the Respondent.

Whether the employment practices and policies of
Respondent SCCOE has a disparate impact on
minority employees of the SCCOE, especially African
Americans.

Whether a Court may properly grant summary judgment where a party failed to establish, by a preponderance of evidence, as shown in the records, that the party defendant's excuse for failure to promote was not a pretext for racial and or age discrimination