I. The Pivotal Role of Azariah Workman – A Timeline and Analysis

• June 19–20, 2024: Workman directly assists in issuing a negative evaluation and written warning immediately after Complainant’s leave request-textbook retaliation and a “paradigm shift” event. This triggers a cascade of subsequent violations and false statements.
• June 27, 2024: Workman provides the “Physician Accommodation Request” form, yet later claims the process was not followed or that documentation was missing-despite her own system logs showing the request and her involvement.
• July 1–18, 2024: Complainant repeatedly requests resolution of payroll, leave, and accommodation issues. Workman’s responses are delayed, vague, and ultimately non-responsive, despite her acknowledgment of receipt.
• July 9, 2024: Workman acknowledges receipt of accommodation request but offers only to “discuss the details further when you return from your leave in September”-a stalling tactic that contradicts the ADA’s requirement for prompt interactive process.
• July 11, 2024: Workman asserts Complainant closed his own leave case and is “not on an approved leave,” ignoring the underlying retaliation and her own role in blocking or delaying the process.
• July 18, 2024: Complainant documents a litany of unresolved issues: payroll, system access, ADA/FMLA compliance, and more. Workman’s lack of substantive response is itself further evidence of ongoing bad faith.
• Late July–September 2024: Despite repeated outreach, Workman and HR fail to correct records, restore pay, or address ADA/FMLA violations. The written warning (already rescinded) remains in the record, and pay is cut off-directly traceable to Workman’s actions.

II. Ten Critical Points for Workman’s Affidavit and Cross-Examination

1. Direct Retaliation: Why did you, as HR Director, assist in issuing a negative evaluation the day after a medical leave request?
2. Perjury Check: Can you explain why Cox’s position statement claims the warning predated the leave request, when system records show otherwise?
3. Payroll Manipulation: What was your role in cutting off Complainant’s pay the day after you told him to take leave?
4. Accommodation Process Delay: Why did you acknowledge the accommodation request but refuse to process it until “September,” in violation of ADA promptness standards?
5. False Narrative of Voluntary Leave Closure: Why did you claim Complainant closed his own leave case, when your own actions (cutting pay, denying PTO) forced his hand?
6. Failure to Provide Documentation: Why did you insist on more forms after already providing the “Physician Accommodation Request” and after being notified of the need?
7. System Access and STAR Discrepancies: Why did you not restore access to essential systems or correct STAR/payroll errors despite repeated requests?
8. Ongoing Reference to Rescinded Warning: Why did you and Cox continue to reference the rescinded warning in filings and communications after HR confirmed its removal?
9. Failure to Engage in Interactive Process: Why did you not initiate or document a good-faith ADA interactive process, as required by law, after multiple requests?
10. Pattern of Non-Response: Why did you fail to answer or resolve critical issues from June through September, despite repeated written documentation and escalation?

III. Paradigm Shift – How This Changes the Legal Landscape

• All subsequent Cox statements, policies, and denials must be viewed in light of this initial, documented act of retaliation and bad faith. Every assertion of “policy compliance” or “good faith” is tainted by Workman’s central role in the original violation.
• Perjury and False Statements: Workman’s and Cox’s continued misrepresentations to the EEOC and in litigation are not mere errors-they are deliberate, knowing falsehoods, subject to sanction and adverse inference.
• Systemic Failure: The correspondence and record show not just individual mistakes, but a systemic pattern of retaliation, delay, and cover-up, with Workman as a central actor.
• Notice to EEOC and All Agencies: The EEOC’s failure to address these issues after being provided with this evidence months ago is itself a procedural failure, and justifies Complainant’s demand for affidavits, cross-examination, and cross-agency enforcement.

IV. Relief and Next Steps

• Require Azariah Workman to provide a sworn affidavit addressing each of the above ten points, under penalty of perjury.
• Order Cox to produce all system logs, payroll records, and correspondence related to leave, pay, and accommodation from June–September 2024.
• Memorialize this addendum as a paradigm-shifting event that taints all subsequent Cox statements and defenses.
• Refer the matter for adverse inference, sanctions, and possible referral to DOJ/EEOC OIG for perjury and obstruction.

This addendum is submitted to highlight the central role of Azariah Workman in initiating and perpetuating retaliation, false statements, and procedural abuse. All subsequent Cox statements must be scrutinized in this context, and Workman’s actions must be subject to full evidentiary inquiry and cross-examination.