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: [Pending]

Date: June 11, 2025
To: Mrs. Elizabeth Rader, District Director, Charlotte District Office
Cc: Ms. Veronica Chaney, District Director’s Secretary
U.S. Equal Employment Opportunity Commission
129 W. Trade Street, Ste. 400
Charlotte, NC 28202
veronica.chaney@eeoc.gov

  There are moments when the record itself becomes the argument—when facts, once gathered and aligned, reveal a pattern so persistent and disregard so systematic that the only possible response is to acknowledge the harm and demand remedy. This is such a moment. What follows is not simply a collection of exhibits or grievances, but the beginning of a reckoning—a record that, once assembled, will not permit indifference or ambiguity. The evidence here is not only cumulative; it is catalytic. It exposes a reality that has persisted for years, a reality that could have been mitigated at countless junctures had those entrusted with authority chosen to act. The time for equivocation has passed. The time for accountability has arrived.

I submit this cover letter with humility and respect for the process, fully aware that no single document can capture the weight of lived experience or the impact of institutional neglect. Yet, it is my hope that what follows will serve as both a record and a call to conscience—a demonstration that, even when procedures falter, the truth can and will be brought to bear. This letter precedes a comprehensive legal submission with multiple attachments and exhibits. The accompanying main document presents a full evidentiary record and detailed legal argument, organized for immediate review by the EEOC, cross-agency partners, and potential legal and advocacy representatives.

VEC Appeal Win Proves Cox’s Assertions Are False:
The Virginia Employment Commission, after reviewing the evidence, reversed the denial of my benefits on appeal—finding medical separation, not voluntary resignation. For the VEC to rule in my favor, Cox’s core assertions must be false.

HEADLINED FACTS DEMONSTRATING URGENCY AND JURISDICTION

Immediate Retaliation After Protected Activity:
Within hours of submitting a written request for reasonable accommodations for a serious heart condition, Cox HR sent me home on leave and, the same day, cut my pay for an entire month. This is irrefutably documented in contemporaneous emails and payroll records.
False and Unsigned Position Statement:
Cox’s position statement to the EEOC is unsigned, unsubstantiated, and unsupported by any affidavits or interviews. This is consistent with Cox’s pattern of refusing to provide real evidence or subject its supervisors to scrutiny—yet the EEOC has, to date, accepted this as sufficient.
Pattern of Retaliation and Pretext:
Multiple emails show that Cox supervisors and HR did not even acknowledge my accommodation request for days, then terminated me within hours of my notice to contact the U.S. Department of Justice.

The evidence and documentation provided are not simply procedural—they are deeply personal. They reflect years of perseverance, repeated attempts to seek redress through every available channel, and the lived consequences of institutional inaction. This submission is designed to make the scope and seriousness of these violations unmistakable, and to ensure that every reviewer—whether legal, regulatory, or public—can see not only the harm but the imperative for remedy.

Comprehensive Personnel File and Performance Reviews: Demonstrates a consistent record of satisfactory or commendable performance, with no legitimate basis for adverse action.
Medical Documentation and Disability Certification: Includes all physician letters, FMLA/ADA forms, and MetLife approvals, confirming both the existence of a qualifying disability and full compliance with all procedural requirements.
Chronological Email and Written Communication Log: A curated set of emails and written correspondence with HR, supervisors, MetLife, and agency representatives, documenting every request, escalation, and denial.
Complete Company Policies and Employee Handbook: Official policies on ADA, FMLA, anti-retaliation, payroll, and leave, juxtaposed with evidence of their violation or disregard.
Sworn Witness Statements: Signed declarations from coworkers and other witnesses attesting to observed discrimination, retaliation, or procedural failures.
Payroll and Benefits Records: Pay stubs, commission records, and benefits statements showing delays, discrepancies, or interruptions directly tied to protected activity.
Master Timeline of Events: A single, annotated chronology mapping every key action, request, response, and adverse event, cross-referenced to supporting exhibits.
Internal HR Complaints and Ethics Reports: All internal complaints and ethics filings, with evidence of non-response or perfunctory dismissal.
Agency Correspondence and Parallel Investigation Notices: Letters and emails to and from the EEOC, VEC, DOL, MetLife, and other agencies, documenting both your efforts and their responses or lack thereof.
Evidence of Pattern or Pretext: Documentation of similar cases, prior complaints, or shifting explanations by Cox, establishing a broader pattern of conduct.
Advocacy and Social Impact Materials: A “Why This Case Matters” summary, any media coverage, and materials prepared for advocacy or public awareness campaigns.

Each exhibit is referenced in the main body and indexed for immediate review. The cumulative effect is not only to prove the violations but to make denial impossible. This is a record designed to command attention, demand justice, and withstand scrutiny from any forum—legal, regulatory, or public.

With respect and hope,
/s/ Thomas D. Coates
Thomas D. Coates
tdcoates@gmail.com | (757) 374-3539
Dated: June 11, 2025

Attachments:
(See main document for full exhibit list and supporting materials)

Cross-Agency Notification:
This matter has been formally noticed to the following agencies and organizations:

U.S. Department of Justice (DOJ) – Civil Rights Division
U.S. Department of Labor (DOL) – Wage and Hour Division
Virginia Employment Commission (VEC)
Office of the Inspector General (EEOC and DOL)
Social Security Administration (SSA)
MetLife (Disability Insurer)
Governor’s Office, Commonwealth of Virginia
Selected national advocacy groups (e.g., ACLU, NDRN, Public Justice)