This filing is submitted to memorialize and document a critical mass of evidence, activism, and self-advocacy in the face of ongoing retaliation and discrimination by Cox Communications, Inc. It directly and specifically refutes the assertions and omissions in Cox’s position statement, demonstrates procedural and substantive violations, and demands corrective action and cross-agency review.

The record includes over a dozen requests for accommodation, detailed reporting of violations, and extensive evidence that Cox’s narrative is false, misleading, and unsupported by admissible evidence.

1. False Claim of First Disclosure:
   “For the first time, he disclosed that his recent absences were allegedly due to caring for his ailing son...”
   - Cox Position Statement, April 11, 2025
   Refutation: Documentary evidence (emails, portal records, and supervisor communications) proves that I notified my supervisor and HR of my son’s illness and my need for leave as early as June 19, 2024, not for the first time on June 27, 2024.
   Citation: 42 U.S.C. § 12112(b)(4); 29 U.S.C. § 2615; see attached timeline and exhibits.
2. Unsigned, Unsworn Submission:
   [Cox position statement is unsigned and not certified by any responsible officer or attorney.]
   Refutation: This violates 29 C.F.R. § 1601.18(c) and EEOC evidentiary requirements; no weight should be given to such statements.
3. Absence of Affidavits or Sworn Testimony:
   [No affidavits or sworn declarations are attached from any manager, HR official, or witness.]
   Refutation: Factual assertions require sworn support; see Fed. R. Evid. 801(d)(2), 29 C.F.R. § 1601.15(c).
4. Failure to Attach Referenced Documents:
   [References to internal policies, records, and communications are made, but no documents are attached.]
   Refutation: This is a direct violation of 29 C.F.R. § 1601.15(c).
5. Improper Use of Footnotes to Disclaim Investigation:
   [Footnotes disclaiming any formal investigation or disclosure.]
   Refutation: Undermines the integrity of the submission and suggests lack of good faith cooperation with the EEOC; see EEOC Best Practices.
6. Vague and Non-Specific Assertions:
   [Statement relies on generalizations and policy summaries rather than specific dates, names, or events.]
   Refutation: Prevents meaningful review or rebuttal and violates EEOC evidentiary standards.
7. Failure to Provide Statutorily Required Details:
   [Omission of required details such as dates of alleged performance issues, names of decision-makers, and specific basis for adverse action.]
   Refutation: Violates 29 C.F.R. § 1601.15(c); see also EEOC Compliance Manual, Section 6.
8. Improper Reliance on Verbal Claims:
   [References to verbal conversations and supervisor impressions without documentation.]
   Refutation: Inadmissible under EEOC and federal evidentiary rules; see Fed. R. Evid. 802, 803(6).
9. No Statement of Internal Investigation:
   [No evidence of internal investigation, no interview notes, no summary of findings.]
   Refutation: Contravenes EEOC best practices and undermines credibility.
10. Improper Blanket Confidentiality Claims:
    [Broad assertions of confidentiality without justification or separate redacted exhibits.]
    Refutation: Contrary to EEOC guidance and due process; see EEOC Guidance 915.002 (2006).
11. Failure to Certify Completeness and Accuracy:
    [Submission is not certified as complete and accurate under penalty of perjury or professional responsibility.]
    Refutation: Violates 29 C.F.R. § 1601.18(c) and undermines evidentiary value.
12. Retaliatory Motive and Pretext:
    [Negative evaluation and disciplinary action initiated immediately after protected activity.]
    Refutation: The timing and sequence of events establish a prima facie case of retaliation and pretext. See Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000); 42 U.S.C. § 2000e-3(a).
13. Shifting Explanations and Inconsistencies:
    [Cox’s narrative has shifted and is inconsistent with the documentary record.]
    Refutation: Classic indicator of pretext under federal law; see EEOC Compliance Manual, Section 8.
14. Systemic and Pattern-or-Practice Issues:
    [Evidence suggests broader systemic issues and pattern-or-practice violations.]
    Refutation: Warrants cross-agency investigation; see 42 U.S.C. § 2000e-6.
15. Good Faith Participation and Exhaustion of Remedies:
    [Complainant has demonstrated consistent good faith participation and exhausted all reasonable internal remedies.]
    Refutation: Satisfies 29 C.F.R. § 1601.28 and supports right to further relief.

The attached record constitutes overwhelming evidence of my repeated, timely, and good faith efforts to obtain accommodation, report violations, and ensure compliance with federal law. Cox Communications’ narrative is contradicted by documented facts, and their position statement is procedurally and substantively deficient under EEOC and federal standards. The critical mass of evidence and self-advocacy reflected here demands not only a finding in my favor, but also heightened scrutiny of Cox’s practices and the EEOC’s handling of this matter.

• 42 U.S.C. § 12112(a), (b)(4) – ADA associational discrimination and retaliation
• 29 U.S.C. § 2615 – FMLA interference and retaliation
• 42 U.S.C. § 2000e-3(a) – Title VII retaliation
• 29 C.F.R. § 1601.15(c), § 1601.18 – EEOC evidentiary and procedural standards
• EEOC–DOJ–DOL MOU (2018, rev. 2022) – Collaborative enforcement
• Federal Rule of Evidence 801(d)(2), 802, 803(6) – Party admissions and evidentiary rules
• EEOC Enforcement Guidance 915.002 (2006) – Confidentiality and retaliation
• EEOC Compliance Manual, Section 6 & 8 – Evidence and retaliation
• Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000) – Pretext and shifting explanations
• 42 U.S.C. § 2000e-6 – Pattern or practice enforcement
• 29 C.F.R. § 1601.28 – Exhaustion and right to sue
• EEOC Quality Control & Best Practices Guidelines – Recordkeeping and due process
• 42 U.S.C. § 1981 – Right to enforce contracts and seek redress for discrimination

• Immediate rejection of Cox’s current position statement as procedurally and substantively deficient;
• Formal notice to Cox requiring a compliant, certified, and fully documented response within 10 business days;
• Full memorialization of all complainant filings, evidence, and objections in the official record;
• Referral of systemic and pattern-or-practice issues to DOJ Civil Rights Division and DOL WHD;
• Written confirmation from the EEOC of corrective action and next steps.