Cox Position Statement – 100 Factual Assertions (Legal Assessment Table)

Cox Communications April 2025 Position Statement
100 Factual Assertions (Legal Assessment Table)

#	Summary (6–8 words)	Page	Shortcut Link
1	Cox prohibits discrimination or retaliation	3
2	Mr. Coates hired Nov 27
3	2023	3
4	Job required in-person call center work	3
5	Role focused on mobile sales connects	3
6	Performance tracked by monthly Scorecards	3
7	First accountable month was March 2024	3
8	Failed to meet March sales threshold	3
9	Received verbal warning after March Scorecard	3
10	Received written warning for May 2024	3
11	Performance improvement plan was initiated	3
12	No protected activity before warnings issued	10
13	Cox approved job-protected medical leave	6
14	Leave was extended through August 20	6
15	Mr. Coates refused to engage HR	6
16	Assigned Senior HR Manager for help	6
17	Cox called but Coates didn’t respond	6
18	Approved remote work and flexible absences	7
19	Arranged office equipment pickup	7
20	Coates refused to return after clearance	7
21	Medical release occurred but no return	7
22	Access restrictions followed unpaid leave policy	6
23	Denied access to sales systems only	6
24	Always retained access to HR systems	6
25	Termination based on failure to return	10
26	No evidence of pretext for firing	10
27	Cox followed ADA interactive process	6
28	Accommodations denied only when not feasible	6
29	Refusal framed as voluntary resignation	7
30	Cox provided significant accommodation efforts	6
31	EEO and anti-retaliation policies attached	3
32	Harassment policy provided multiple reporting avenues	11
33	No harassment reported by Mr. Coates	11
34	Harassment claims fail legal threshold	11
35	No harassment related to disability	11
36	Managers unaware of disability during incidents	11
37	Corrective meetings were job-performance based	11
38	Coates' metrics failed company expectations	3
39	Received performance coaching during employment	3
40	Supervisor reviews occurred monthly	3
41	No retaliation after accommodation requests	10
42	Leave policies applied consistently to Coates	6
43	Used Ethics hotline available to all	3
44	Exhibits show formal warnings issued	s 14–19
45	HR documentation included multiple Scorecards	s 14–19
46	Medical appointment flexibility was granted	7
47	Coates failed to meet threshold in May	18
48	Written warning was issued June 20
49	2024	18
50	Anti-harassment training required of supervisors	10
51	Scorecard used for performance review	3
52	Interactive process began July 25
53	2024	6
54	STD and ADA requests processed simultaneously	6
55	Dedicated HR rep initiated multiple calls	6
56	Coates didn’t respond to outreach	6
57	HR rep left voicemails without reply	6
58	Cox granted ADA work-from-home request	7
59	Cox permitted short-notice appointment time off	7
60	Cox prepared equipment for return-to-work	7
61	No access to sales data while inactive	6
62	Access restored upon expected return	6
63	Failure to return deemed separation	7
64	Retaliation claims lack causal connection	10
65	Corrective actions predated ADA activity	10
66	ADA request occurred after performance warnings	10
67	Harassment claims are speculative and vague	11
68	Job duties discussed in coaching sessions	11
69	Complaint timeline undermines retaliation claim	10
70	Managers unaware of ADA need before June	11
71	Performance warnings based on sales only	3
72	Verbal warning issued March 31
73	2024	14
74	Written warning issued June 20
75	2024	18
76	Policy allows termination after repeated failures	14
77	Scorecard listed missed targets in March	14
78	Scorecard for May listed mobile deficit	18
79	ADA letter received July 25
80	2024	6
81	Leave approved through August 20	6
82	RTW clearance noted by HR	7
83	Final decision made after no contact	7
84	Coates failed to follow return plan	7
85	Ethics complaints not cited by Cox – N/A
86	Cox HR gave consistent updates	6
87	Employment ended based on HR policy	10
88	No hostile environment established by facts	11
89	Access to MetLife always retained	6
90	Computer access suspended per company rules	6
91	No formal grievance submitted internally	11
92	Harassment claims unsupported by documentation	11
93	Cox acted in good faith under ADA	6
94	No intent to discriminate shown	10
95	Performance goals detailed in scorecards	14–18
96	Coates reviewed monthly goals with manager	3
97	Corrective steps outlined clearly in warnings	14
98	Performance linked to minimum connect targets	3
99	Interactive process includes HR outreach attempts	6
100	Written accommodation acknowledgment sent Aug 16	7
101	Return-to-work date set as August 20	7
102	All accommodations within Cox’s control granted	7
103	Cox couldn’t control home noise levels	7
104	Harassment policies reviewed in Exhibit C	10
105	Cox emphasized good-faith accommodations	6
106	Company seeks 12
1	Cox prohibits discrimination or retaliation	3	Link
2	Mr. Coates hired Nov 27, 2023	3	Link
3	Job required in-person call center work	3	Link
4	Role focused on mobile sales connects	3	Link
5	Performance tracked by monthly Scorecards	3	Link
1	Cox prohibits discrimination or retaliation	3
2	Mr. Coates hired Nov 27
3	2023	3
4	Job required in-person call center work	3
5	Role focused on mobile sales connects	3
6	Performance tracked by monthly Scorecards	3
7	First accountable month was March 2024	3
8	Failed to meet March sales threshold	3
9	Received verbal warning after March Scorecard	3
10	Received written warning for May 2024	3
11	Performance improvement plan was initiated	3
12	No protected activity before warnings issued	10
13	Cox approved job-protected medical leave	6
14	Leave was extended through August 20	6
15	Mr. Coates refused to engage HR	6
16	Assigned Senior HR Manager for help	6
17	Cox called but Coates didn’t respond	6
18	Approved remote work and flexible absences	7
19	Arranged office equipment pickup	7
20	Coates refused to return after clearance	7
21	Medical release occurred but no return	7
22	Access restrictions followed unpaid leave policy	6
23	Denied access to sales systems only	6
24	Always retained access to HR systems	6
25	Termination based on failure to return	10
26	No evidence of pretext for firing	10
27	Cox followed ADA interactive process	6
28	Accommodations denied only when not feasible	6
29	Refusal framed as voluntary resignation	7
30	Cox provided significant accommodation efforts	6
31	EEO and anti-retaliation policies attached	3
32	Harassment policy provided multiple reporting avenues	11
33	No harassment reported by Mr. Coates	11
34	Harassment claims fail legal threshold	11
35	No harassment related to disability	11
36	Managers unaware of disability during incidents	11
37	Corrective meetings were job-performance based	11
38	Coates' metrics failed company expectations	3
39	Received performance coaching during employment	3
40	Supervisor reviews occurred monthly	3
41	No retaliation after accommodation requests	10
42	Leave policies applied consistently to Coates	6
43	Used Ethics hotline available to all	3
44	Exhibits show formal warnings issued	s 14–19
45	HR documentation included multiple Scorecards	s 14–19
46	Medical appointment flexibility was granted	7
47	Coates failed to meet threshold in May	18
48	Written warning was issued June 20
49	2024	18
50	Anti-harassment training required of supervisors	10
51	Scorecard used for performance review	3
52	Interactive process began July 25
53	2024	6
54	STD and ADA requests processed simultaneously	6
55	Dedicated HR rep initiated multiple calls	6
56	Coates didn’t respond to outreach	6
57	HR rep left voicemails without reply	6
58	Cox granted ADA work-from-home request	7
59	Cox permitted short-notice appointment time off	7
60	Cox prepared equipment for return-to-work	7
61	No access to sales data while inactive	6
62	Access restored upon expected return	6
63	Failure to return deemed separation	7
64	Retaliation claims lack causal connection	10
65	Corrective actions predated ADA activity	10
66	ADA request occurred after performance warnings	10
67	Harassment claims are speculative and vague	11
68	Job duties discussed in coaching sessions	11
69	Complaint timeline undermines retaliation claim	10
70	Managers unaware of ADA need before June	11
71	Performance warnings based on sales only	3
72	Verbal warning issued March 31
73	2024	14
74	Written warning issued June 20
75	2024	18
76	Policy allows termination after repeated failures	14
77	Scorecard listed missed targets in March	14
78	Scorecard for May listed mobile deficit	18
79	ADA letter received July 25
80	2024	6
81	Leave approved through August 20	6
82	RTW clearance noted by HR	7
83	Final decision made after no contact	7
84	Coates failed to follow return plan	7
85	Ethics complaints not cited by Cox – N/A
86	Cox HR gave consistent updates	6
87	Employment ended based on HR policy	10
88	No hostile environment established by facts	11
89	Access to MetLife always retained	6
90	Computer access suspended per company rules	6
91	No formal grievance submitted internally	11
92	Harassment claims unsupported by documentation	11
93	Cox acted in good faith under ADA	6
94	No intent to discriminate shown	10
95	Performance goals detailed in scorecards	14–18
96	Coates reviewed monthly goals with manager	3
97	Corrective steps outlined clearly in warnings	14
98	Performance linked to minimum connect targets	3
99	Interactive process includes HR outreach attempts	6
100	Written accommodation acknowledgment sent Aug 16	7
101	Return-to-work date set as August 20	7
102	All accommodations within Cox’s control granted	7
103	Cox couldn’t control home noise levels	7
104	Harassment policies reviewed in Exhibit C	10
105	Cox emphasized good-faith accommodations	6
106	Company seeks no probable cause finding	12.

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Cox Communications April 2025 Position Statement100 Factual Assertions (Legal Assessment Table)

Cox Communications April 2025 Position Statement
100 Factual Assertions (Legal Assessment Table)