Formal Motion No. 4 - Request for Certified HR Records, Workday/PeopleSoft Audit, and SoD Review

I. INTRODUCTION AND REQUEST FOR DOCKET ENTRY

Complainant Thomas D. Coates respectfully submits this Motion No. 4 requesting the immediate production and certification of specific HR records, Workday and PeopleSoft audit logs, Segregation of Duties (SoD) conflict matrix, and all associated communications and access logs, as detailed below. This motion is submitted for entry into the EEOC record and for cross-agency evidentiary review. The requests herein are made in direct reference to, and as a follow-up to, the formal letter sent to Cox HR and ServiceNow on August 2, 2024, memorialized and incorporated by reference.

II. DOCUMENT REQUESTS AND PRODUCTION SPECIFICATIONS

Inclusive User List and Procedural Clarification:
The following requests apply to any and all activity, access, or changes to the Workday, PeopleSoft, Microsoft Teams, or HR/payroll records of Thomas D. Coates (including but not limited to all spellings, user IDs, and account variants), whether performed during employment or post-employment, and regardless of the spelling, inclusion or omission of middle initials, or user identification on record.

This request specifically includes, but is not limited to, all actions performed by the following users or accounts:

Azariah Workman
Ursula Rogers
Lakita Gaines
Donte Holmes
[Additional names to be provided in a supplemental filing]

This request covers any and all activity on the account(s) of Thomas D. Coates, whether by these users or any other HR, IT, management, or administrative personnel, for the entire period of employment and post-employment (including post-January 2, 2025).

No procedural or technical objection shall be raised on the basis of:

Variations in spelling of names or user IDs
Presence or absence of middle initials or alternate identifiers
Changes in user roles, titles, or employment status
Account aliases, legacy system migrations, or system upgrades

This request is intended to be all-inclusive and to capture the full scope of relevant activity, regardless of how the user or account is referenced in any system or record.

Document Category	Date Range	Production Format & Certification
Certified HR Personnel File (Complete)	Full Employment Duration	Redacted PDF with Notarized Certification by Custodian of Records
All HR Case Files/Investigations involving Thomas D. Coates (including but not limited to accommodation, discipline, and performance)	January 1, 2023 – Present	PDF copies, each with certification of completeness and authenticity
Workday System User Logs & Audit Trails (for all users above, on the account of Thomas D. Coates)	Employment start date – Present (including post-employment/post-January 2, 2025)	Native XLSX/CSV with metadata and digital signature of IT custodian
All internal/external email communications regarding Thomas D. Coates (to/from/cc: any user listed above, including HR, business partners, executives)	June 20, 2024 – January 2, 2025 (or later if relevant)	PST/EML export with metadata; include all attachments
Microsoft Teams chats and account communications regarding Thomas D. Coates (among any users above and HR/IT/executive personnel)	June 20, 2024 – January 2, 2025 (or later if relevant)	Exported chat logs, with timestamps and user IDs
PeopleSoft Payroll Records and Audit Logs (any activity by users above on Thomas D. Coates' account)	May 30, 2024 – May 12, 2025	PDF, CSV, or native export; include all payroll generation, file, account login, user input, and changes
Workday Segregation of Duties (SoD) Matrix, Role-Based Access Control (RBAC), and Approval Workflow Logs (for all users above, on Thomas D. Coates' account)	June 15, 2024 – Present	Full SoD matrix, RBAC logs, approval chains, conflict reports, and policy documentation
Workday/PeopleSoft SoD Policy in force and all compliance/audit reports	June 15, 2024 – Present	Policy document PDF and all compliance reports

Legal Basis: 29 C.F.R. § 1601.18 (EEOC document retention and production); 42 U.S.C. § 12117(a); Federal Rules of Evidence 803(6), 902(11); OPM and DOL recordkeeping standards; Workday/PeopleSoft audit best practices; and as specifically requested in the August 2, 2024 letter to Cox HR and ServiceNow (memorialized and incorporated by reference).

III. JUSTIFICATION AND MATERIALITY

The requested HR case files, certified personnel records, and all audit logs are directly material to refuting Respondent’s position statement and to establishing the actual timeline and content of all HR actions, communications, and accommodations regarding Complainant.
The Workday and PeopleSoft user logs, SoD matrix, RBAC, and approval workflow logs are necessary to verify all system activity, requests, workflow actions, and segregation of duties controls attributed to Complainant and HR personnel, and to identify any discrepancies, conflicts of interest, or omissions in Respondent’s narrative.
Certified copies and native format exports are required to ensure evidentiary integrity and to enable cross-agency review by the EEOC, DOJ, and DOL.
Failure to produce these records in the requested format may result in adverse inference, sanctions, or referral for further investigation.

Reference: The August 2, 2024 letter sent to Cox HR and ServiceNow, which formally requested a full investigation into pay change alterations, SoD conflicts, approval workflows, audit trails, user access reviews, and policy enforcement, is hereby memorialized and incorporated by reference as the basis for the scope and specificity of these requests.

IV. RELIEF REQUESTED

The Complainant respectfully requests that the EEOC and cross-agency recipients:

Order Cox Communications to produce all requested records and audit logs, in certified and native format, within 10 business days of this motion;
Require Respondent to provide a notarized certification of completeness and authenticity for all HR, Workday, and PeopleSoft records produced;
Permit Complainant to inspect and copy all responsive documents, and to request additional production if deficiencies or gaps are found;
Refer any noncompliance or evidence of spoliation to the DOJ Civil Rights Division and DOL WHD for enforcement action;
Distribute a certified copy of this motion and all subsequent productions to all relevant oversight agencies for synchronized review.

V. SERVICE CERTIFICATION

I certify that this motion and all supporting exhibits have been served via EEOC Portal and electronic mail to:

Alexander Perez, Investigator, U.S. EEOC – Norfolk Area Office
Attorney Justin Miles, Littler Mendelson, P.C. (for Cox Communications)
Other designated agency officials as required by protocol

Dated:

VI. CONCLUSION

The requested records, audit logs, and SoD documentation are essential to the integrity of this administrative proceeding and to the fair adjudication of all claims. The EEOC and any reviewing court must require full and certified production of these materials, and must give dispositive weight to any evidence of noncompliance, omission, or alteration.