LEGAL NOTICE OF INDIVIDUAL RESPONSIBILITY AND ACCOUNTABILITY
The following individuals are hereby formally memorialized as principals, agents, or respondents for all purposes of this record. Each has, at various times and in various forms:
- Entered data, made changes, or taken action in Cox’s HR, payroll, benefits, or compliance systems;
- Sent, received, or been copied on emails, internal communications, or system notes relevant to leave, accommodation, payroll, discipline, or compliance;
- Made, repeated, or allowed false statements, unsupported assertions, or omissions in the April 2025 Position Statement, related filings, or other documented communications;
- Failed to intervene, report, or correct known or suspected violations of EEOC statutes, ADA, FMLA, or other applicable laws, thereby enabling such violations to persist or propagate.
Each individual named below is subject to:
- Formal demand for sworn affidavit, deposition, or interview regarding their knowledge, actions, and participation in any and all matters related to this case, including but not limited to the position statement, system entries, and all communications or decisions impacting the Complainant;
- Requests for clarification and correction of any disputed or unsupported facts or statements for which they were responsible or had knowledge;
- Personal and professional exposure for perjury, bad faith, breach of fiduciary duty, or failure to correct or report known violations, as determined by the EEOC, DOL, DOJ, or any court or oversight agency;
- An ongoing duty to preserve all records, communications, and system data relevant to this matter, regardless of format or medium, including any future or supplemental actions taken in relation to the Complainant or this case.
Any attempt by these individuals to disclaim, “fix,” or distance themselves from the position statement, related communications, or system actions will not defeat the integrity of the memorialized record, as their knowledge, participation, and actions are independently corroborated by system logs, emails, and documentary evidence. This memorialization is not limited to the position statement, but extends to all relevant conduct, past, present, and future, that may impact the rights of the Complainant or the integrity of the proceedings.
| # |
Name |
Title |
Role/Context |
| 1 |
Lakita Gaines |
HR Business Partner (CCI-Atlanta) |
Included in several email threads regarding Complainant’s accommodations and return-to-work status; copied on EEOC-related correspondence; linked to Workday coordination and employee relations. |
| 2 |
Jennifer Melton |
Senior Manager, Employee Relations & Compliance (CCI-Atlanta) |
Central in communications regarding ADA accommodations, return-to-work status, documentation demands, and Open Enrollment issues. Her Nov. 20, 2024 email initiated a last-minute RTW letter demand, leading to significant procedural conflict. |
| 3 |
Keith Wilson |
(Unconfirmed, but involved in Employee Relations or HR Operations) |
Regular recipient of ADA and return-to-work correspondence. Referenced in MetLife coordination and ESC (Employee Service Center) exchanges. |
| 4 |
Kia Painter |
Chief People Officer / Executive Leadership – HR Oversight (Cox Enterprises, Inc.) |
Subject of high-level disclosures regarding ADA compliance failures, fiduciary responsibility issues, and ethical reporting obligations. Previously identified for SEC, CEI (Cox Enterprises Inc.), and legal oversight relevance. |
| 5 |
Ursula Rogers |
HR Manager or Advisor (Title inferred from correspondence context) |
Referenced in oversight, coordination with MetLife, and ADA process execution. May have been involved in benefits and system-level HR data handling. |
| 6 |
Azariah Workman |
Supervisor or Frontline Manager |
Played a role in sending Complainant home due to chest pain on June 28, 2024. Key witness in workers’ compensation timeline and early ADA health interactions. |
| 7 |
Donte Holmes |
Supervisor (CCI-Atlanta) |
Immediate supervisor during key leave and accommodation events. Acknowledged out-of-office notices, and confirmed certain occurrences were logged as excused. |
| 8 |
Sarah DellaVecchio |
Manager or HR Liaison (CCI-Virginia) |
Included in attendance tracking and Workday communications. Mentioned in context of reports and accommodation coordination. |
| 9 |
Chauntriss Herring |
Unspecified, likely involved in Benefits or HR Compliance |
Referenced in previous correspondence threads related to benefits eligibility and Workday permissions. |
| 10 |
Rachel Smith |
Possibly Benefits or Legal/HR Liaison |
Occasionally CC’d in formal letters involving leave policy and disability-related case progression. |
All individuals above are required to:
- Preserve and produce all emails, internal chat logs (Teams, Slack), Workday/HRIS records, and any documentation relating to leave, accommodation, payroll, discipline, compliance, or any matter relevant to this proceeding;
- Provide sworn affidavits or be available for deposition/interview regarding their knowledge, decisions, and participation in the creation, approval, or dissemination of the Cox April 2025 Position Statement and any related communications, system entries, or actions impacting the Complainant or this case;
- Correct the record for any false, misleading, or unsupported statements for which they were responsible or had knowledge, whether in the position statement or any other form or forum;
- Comply with all legal, regulatory, and ethical obligations to ensure the accuracy, integrity, and preservation of the record for EEOC, DOL, DOJ, and judicial review.
Failure to comply will be memorialized as non-response, subject to adverse inference, sanctions, and referral for further agency or judicial action. This memorialization is ongoing and encompasses all conduct, statements, and evidence relevant to these proceedings, not limited to the position statement alone.