VERIFIED EVIDENCE SUBMISSION
FOR COURT, EEOC RECORD, CROSS-AGENCY, AND ADVOCACY OVERSIGHT
FORMAL MULTI-AGENCY FILING AND CROSS-AGENCY RECORD PRESERVATION
EEOC Charge No.: 12K-2025-00001 | DOJ ADA Complaint No.: 536785-LFD
Submission of Motion No. 1 and Addendum, served to: EEOC, DOJ, DOL, Virginia OIG, Governor’s Office, and other oversight bodies.
Legal Basis: 42 U.S.C. § 2000e-5(b), 29 C.F.R. § 1601.15(c), § 1601.18, EEOC-DOL-DOJ MOU (2018, rev. 2022).
Purpose: To preserve the record, prevent summary closure, and comply with all multi-agency recordkeeping and due process requirements.
Filed: May 27, 2025
Submitted by: Thomas D. Coates, Pro Se
MEMORANDUM OF UNRESOLVED FACTUAL AND PROCEDURAL ISSUES
Motion to Preserve the Record and Pending Motions
Documents all pending motions, factual disputes, and procedural matters requiring resolution before any determination. Necessitated by risk of summary determination without full review.
Cites: 42 U.S.C. § 2000e-5(b), 29 C.F.R. § 1601.15(c), Federal Rule of Evidence 801(d)(2).
Key Point: No determination may issue until all pending motions are formally ruled upon.
ORDER OF APPEALS EXAMINER – VIRGINIA EMPLOYMENT COMMISSION
Order No.: UI-25009642 | Dated: June 23, 2025
The VEC Appeals Examiner vacated the Deputy’s overpayment determination as void ab initio for lack of promptness and due process.
Legal Impact: Establishes that the employer’s narrative was false and the agency’s delay was unlawful.
Submitted as: Direct evidence of procedural violations and exoneration of claimant.
EXHIBIT: EEOC INVESTIGATOR EMAIL EVIDENCE
May 27, 2025 – Alexander Perez, EEOC Norfolk
Email demonstrates prejudgment, arbitrary deadlines, and refusal to rule on pending motions.
Legal Citations: 42 U.S.C. § 2000e-5(b), 29 C.F.R. § 1601.15(c), § 1601.18, FRE 801(d)(2), 401.
Material Fact: Shows investigator’s failure to maintain neutrality and due process.
FORMAL MOTION: MEMORIALIZATION OF PROCEDURAL DEFICIENCIES & PAYROLL CONTRADICTIONS
Filed: May 16, 2025
Details deficiencies in Cox’s position statement: unsigned, uncertified, lacking affidavits, missing referenced documents, and payroll anomalies (“Stay Pay”, zeroed pay, inconsistent benefits).
Statutes: 29 C.F.R. § 1601.15(c), § 1601.18(c), 29 U.S.C. § 211(c), 20 C.F.R. § 641.565, 18 U.S.C. § 1001, 18 U.S.C. § 1519.
Relief Requested: Reject deficient employer submission, require sworn/certified evidence, refer for cross-agency enforcement.
EEOC INQUIRY COMPARISON: NOT A DUPLICATE
Formal Request for Evidentiary Basis of Agency Action
Point-by-point, statute-backed comparison showing why EEOC Inquiry No. 437-2025-01523 is NOT A DUPLICATE of No. 437-2025-01209.
Mandates: MD-110 § 2-302, 29 C.F.R. § 1601.15(b)-(c), § 1601.18(b).
Legal Impact: Requires vacatur of improper closure and independent review of each claim.