UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

NORFOLK AREA OFFICE – MID-ATLANTIC REGION

IN THE MATTER OF:
Thomas D. Coates, Complainant
v.
Cox Communications, Inc., Respondent
EEOC Charge No.: 12K-2025-00001
DOJ ADA Complaint No.: 536785-LFD
DOL WHD Matter: [Insert if applicable]
Date: June 10, 2025
Filed by: Thomas D. Coates
Contact: tdcoates@gmail.com | (757) 374-3539

DECLARATION AND FORMAL REQUEST FOR EXPANDED INVESTIGATION, RELIEF, AND SANCTIONS

I, Thomas D. Coates, hereby declare under penalty of perjury that the following statements are true and correct to the best of my knowledge and belief. This submission serves as a formal request for the EEOC to expand its investigation into the matters raised in EEOC Charge No. 12K-2025-00001, to consider all supplemental evidence provided, and to impose appropriate relief and sanctions against Cox Communications, Inc. for violations of federal employment laws.

The evidence presented herein, including but not limited to the Virginia Employment Commission's ruling, MetLife correspondence, payroll records, and internal communications, demonstrates a pattern of retaliation, discrimination, and procedural misconduct that demands thorough review and corrective action.

I respectfully request the following:

  1. Immediate reopening and full investigation of EEOC Charge No. 12K-2025-00001, incorporating all new and supplemental evidence.
  2. Formal acknowledgment of procedural and substantive violations by Cox Communications and the EEOC, including the improper reliance on an unsigned and unverified position statement.
  3. Assignment of a new investigator and supervisory team unaffiliated with prior determinations to ensure impartiality and fairness.
  4. Coordination with the Virginia Employment Commission, MetLife, Department of Labor, Department of Justice, and other relevant agencies to ensure consistent and lawful outcomes.
  5. Preservation of my right to supplement the record and pursue all available legal remedies, including private litigation.
  6. Written confirmation of receipt, procedural status, and all actions taken in response to this submission.
  7. Imposition of sanctions against Cox Communications for violations of the Americans with Disabilities Act, Family and Medical Leave Act, Title VII, Fair Labor Standards Act, HIPAA, and related statutes.

I trust that the EEOC will give this matter the full and fair consideration it deserves, and I stand ready to provide any further information or testimony as required.