I. PARTIES AND JURISDICTION

Complainant	Thomas D. Coates
Respondent(s)	Cox Communications, Inc., MetLife, [Payroll Vendor, if applicable]
Jurisdiction	EEOC Charge No.: 12K-2025-00001 DOJ ADA Complaint No.: 536785-LFD DOL WHD Matter: [Insert if applicable] HHS OCR HIPAA Complaint No.: [Insert if filed] Most recent adverse action: [Insert date]

II. TIMELINE OF EVENTS

Date	Event/Action	Evidence Ref.
07/15/2024	HR requests and receives confidential physicianâ€™s note regarding medical leave	Ex. 3A (email, scanned physician note)
07/16/2024	HR shares medical note with unauthorized parties; note is altered in HRIS	Ex. 3B (Workday log, altered note, access log)
07/25/2024	Payroll processes PTO/wage adjustment based on altered medical record	Ex. 3C (payroll record, PTO log)
08/01/2024	Misrepresented physicianâ€™s note submitted to Social Security and VEC	Ex. 3D (correspondence to SSA/VEC, copy of altered note)

III. STATUTES AND POLICIES VIOLATED

Statute/Regulation	Description	Policy Guidance
HIPAA, 45 C.F.R. Â§Â§ 164.502, 164.530	Unauthorized disclosure and alteration of protected health information (PHI)	HHS HIPAA Privacy Rule Guidance
FLSA, 29 U.S.C. Â§ 206 et seq.	Improper wage deductions, PTO miscalculation	DOL Wage & Hour Fact Sheets #15, #53
Social Security Act, 42 U.S.C. Â§ 408	Submission of false information to SSA	SSA Program Operations Manual
ADA, 42 U.S.C. Â§ 12112(d)	Improper handling of medical records and confidentiality breach	EEOC ADA Enforcement Guidance, Section 6
Cox HR-405 / Privacy Policy	Breach of internal confidentiality and data handling policy	Cox Employee Handbook, Privacy Section

IV. MATERIAL INCONSISTENCIES & FALSE ASSERTIONS

Assertion/Statement	Source	Contradictory Evidence	Implication
"All medical records were handled in compliance with HIPAA"	Cox Position Statement (04/2025)	Access logs show unauthorized HR staff accessed and edited physician note (Ex. 3B)	Breach of HIPAA confidentiality
"PTO and wage adjustments were based on accurate records"	Payroll/HR correspondence	PTO deduction based on altered medical note, not original (Ex. 3C)	FLSA and ERISA wage violation
"No false information was submitted to SSA or VEC"	Cox/MetLife correspondence	Copy of altered note sent to SSA/VEC (Ex. 3D)	Potential Social Security Act violation

V. POLICY ANALYSIS

Policy Requirement	What Should Have Happened	Actual Action	Deviation
HIPAA: PHI only shared with authorized personnel	Limit access to designated HR/benefits staff	Medical note accessed/edited by unauthorized users	HIPAA breach, privacy violation
FLSA: Accurate wage/PTO calculation	Use original, unaltered physician note for payroll	PTO deducted based on altered record	Improper wage deduction
ADA: Confidentiality of medical records	Maintain separate, secure medical files	Medical info stored in general HRIS, shared with payroll	ADA confidentiality violation
SSA: Truthful representations	Submit original, unaltered documentation	Altered note sent to SSA/VEC	Potential fraud, reporting violation

VI. RESPONSIBLE PARTIES & RELATED INDIVIDUALS

Name	Title/Role	Involvement
Azariah Workman	HR Director, Cox	Authorized/failed to prevent improper access to PHI
MetLife Claims Processor	Disability Claims Admin	Relayed altered note to payroll/SSA
[Payroll Staff Name]	Payroll Processing	Processed PTO/wage changes using altered record
[IT/HRIS Admin]	System Access	Failed to restrict access to medical records

VII. PRIOR FILINGS & EVIDENCE OF PATTERN

Date	Filing/Agency	Case/Reference	Status/Outcome
03/10/2024	HHS OCR	HIPAA Complaint #[Insert]	Pending
04/15/2024	DOL WHD	FLSA Complaint #[Insert]	Under investigation
05/15/2025	EEOC	12K-2025-00001	Pending

VIII. EXHIBITS & EVIDENCE

Ex. 3A: Original physicianâ€™s note (scanned copy, email)
Ex. 3B: Workday/HRIS access log and altered note
Ex. 3C: Payroll/PTO deduction record
Ex. 3D: Correspondence to SSA/VEC with altered note

IX. RELIEF AND REMEDIES SOUGHT

Immediate investigation of HIPAA, FLSA, and Social Security Act violations
Restoration of PTO and correction of wage records
Sanctions for breach of confidentiality and false reporting
Referral to DOJ, DOL, HHS OCR, and SSA OIG for coordinated enforcement
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
U.S. Department of Health and Human Services, Office for Civil Rights
Social Security Administration, Office of Inspector General
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.