I. PARTIES AND JURISDICTION

Complainant	Thomas D. Coates
Respondent(s)	Cox Communications, Inc., MetLife, Payroll Department
Jurisdiction	EEOC Charge No.: 12K-2025-00001 DOJ ADA Complaint No.: 536785-LFD DOL WHD Matter: Potential FLSA/FMLA violations OSHA Whistleblower Protection Program Most recent adverse action: September 2024

II. TIMELINE OF EVENTS

Date	Event/Action	Evidence Ref.
06/19/2024	Complainant requests medical leave from supervisor	Ex. 1A (email/text and Workday log)
06/20/2024	Supervisor issues negative evaluation and written warning	Ex. 1B (Workday system logs showing HR Director involvement)
06/25/2024	Complainant formally requests correction/removal of warning	Ex. 1C (email/ticket to HR)
07/15/2024	Complainant files internal complaint about payroll discrepancies	Ex. 4A (internal complaint, payroll records)
07/20/2024	Payroll adjustments made without authorization, PTO improperly deducted	Ex. 4B (payroll records, before/after)
08/05/2024	Complainant notifies Chief Compliance Officer of violations	Ex. 4C (email to Ms. Painter with receipt confirmation)
08/15/2024	Complainant files DOL complaint regarding wage/hour violations	Ex. 4D (DOL complaint receipt)
08/20/2024	Further adverse payroll actions, access restrictions implemented	Ex. 4E (system access logs, payroll records)

III. STATUTES AND POLICIES VIOLATED

Statute/Regulation	Description	Policy Guidance
FLSA, 29 U.S.C. Â§ 215(a)(3)	Anti-retaliation provision for wage complaints	DOL Fact Sheet #77A
FMLA, 29 U.S.C. Â§ 2615	Prohibition against interference and retaliation	29 C.F.R. Â§ 825.220
Sarbanes-Oxley Act, 18 U.S.C. Â§ 1514A	Whistleblower protection for reporting violations	OSHA Whistleblower Manual
ADA, 42 U.S.C. Â§ 12203	Prohibition of retaliation and coercion	EEOC Enforcement Guidance on Retaliation
Cox HR-405 / Payroll Policy	Accurate payroll processing and documentation	Cox Employee Handbook
Cox Whistleblower Policy	Protection for internal reporting of violations	Cox Compliance Manual

IV. MATERIAL INCONSISTENCIES & FALSE ASSERTIONS

Assertion/Statement	Source	Contradictory Evidence	Implication
"All payroll adjustments were properly authorized"	Cox Position Statement (04/2025)	Payroll records show unauthorized deductions after complaint (Ex. 4B)	Retaliatory payroll manipulation
"No retaliation occurred for any protected activity"	Cox Position Statement (04/2025)	System access restrictions implemented after DOL complaint (Ex. 4E)	Direct retaliation for federal filing
"Cox has a robust whistleblower protection program"	Cox Position Statement (04/2025)	No action taken on report to Chief Compliance Officer (Ex. 4C)	Whistleblower policy is a sham
"Warning was not related to leave request"	Cox Position Statement (04/2025)	Workday logs show warning created one day after leave request (Ex. 1A, 1B)	Pretextual discipline, FMLA retaliation

V. POLICY ANALYSIS

Policy Requirement	What Should Have Happened	Actual Action	Deviation
FLSA: No retaliation for wage complaints	Investigate complaint, correct errors, no adverse action	Further payroll manipulation after complaint	Direct FLSA anti-retaliation violation
FMLA: No interference with leave rights	Process leave request without adverse action	Negative evaluation issued immediately after request	FMLA interference and retaliation
Whistleblower Policy: Investigate reports	Chief Compliance Officer should investigate and remediate	No action taken on formal report	Policy breach, SOX violation
Payroll Policy: Accurate processing	Maintain accurate records, proper authorization	Unauthorized adjustments, improper PTO deductions	Policy violation, potential fraud

VI. RESPONSIBLE PARTIES & RELATED INDIVIDUALS

Name	Title/Role	Involvement
Azariah Workman	HR Director, Cox	Facilitated retaliatory warning, failed to correct
Ms. Painter	Chief Compliance Officer	Failed to investigate whistleblower complaint
Keith Wilson	Supervisor, Cox	Initiated retaliatory warning after leave request
[Payroll Manager]	Payroll Department	Processed unauthorized payroll adjustments

VII. PRIOR FILINGS & EVIDENCE OF PATTERN

Date	Filing/Agency	Case/Reference	Status/Outcome
08/15/2024	DOL WHD	FLSA Complaint #[Insert]	Under investigation
09/10/2024	OSHA	Whistleblower Complaint #[Insert]	Pending
05/15/2025	EEOC	12K-2025-00001	Pending, multiple motions

VIII. EXHIBITS & EVIDENCE

Ex. 1A: June 19, 2024 leave request email/text and Workday log
Ex. 1B: June 20, 2024 Workday system logs showing HR Director involvement in warning
Ex. 1C: June 25, 2024 request for correction/removal of warning
Ex. 4A: July 15, 2024 internal complaint about payroll discrepancies
Ex. 4B: July 20, 2024 payroll records showing unauthorized adjustments
Ex. 4C: August 5, 2024 email to Chief Compliance Officer with receipt confirmation
Ex. 4D: August 15, 2024 DOL complaint receipt
Ex. 4E: August 20, 2024 system access logs and payroll records showing further adverse actions

IX. RELIEF AND REMEDIES SOUGHT

Immediate investigation of payroll manipulation and whistleblower suppression
Restoration of all improperly deducted wages, PTO, and benefits
Sanctions for retaliation against protected activities
Referral to DOJ, DOL WHD, OSHA, and SEC for coordinated enforcement
Executive accountability for Chief Compliance Officer's failure to act
Any other relief deemed just and proper

X. SERVICE AND NOTICE TO THIRD PARTIES

EEOC Norfolk Area Office
Cox Communications, Inc. HR and Legal
U.S. Department of Justice, Civil Rights Division
U.S. Department of Labor, Wage and Hour Division
Occupational Safety and Health Administration, Whistleblower Protection Program
Securities and Exchange Commission, Office of the Whistleblower
Virginia Office of the State Inspector General
Other relevant agencies

Notice: This addendum is intended to satisfy the recordkeeping, disclosure, and transmission requirements of all referenced agencies and courts. All parties are requested to preserve, review, and incorporate this record in accordance with applicable law.