To:
Alexander Perez, Investigator
U.S. EEOC, Norfolk Area Office
Charlotte A. Burrows, Chair
U.S. Equal Employment Opportunity Commission, Washington, D.C.
Deputy Assistant Attorney General for Civil Rights
U.S. Department of Justice, Civil Rights Division

• Charlotte A. Burrows, Chair, U.S. EEOC: charlotte.burrows@eeoc.gov
• Norfolk Area Office, EEOC: norfolk@eeoc.gov
• EEOC Subpoena Unit: subpoena@eeoc.gov
• Investigator Alexander Perez, EEOC: alexander.perez@eeoc.gov
• DOJ Civil Rights Intake: crt.intake@usdoj.gov
• DOJ Disability Rights Section: ada.complaint@usdoj.gov
• DOL Wage and Hour Division: whd@dol.gov
• Virginia Office of the State Inspector General: osig@osig.virginia.gov
• Office of the Governor of Virginia: constituent.services@governor.virginia.gov

On May 15, 2025, I submitted a formal notice and motion to toll the rebuttal deadline and to demand cure of procedural and evidentiary deficiencies in Cox Communications’ position statement. On May 16, 2025, Investigator Alexander Perez summarily denied this request via email, without citation to any statutory or regulatory authority, and without written findings or supervisory review.

Pursuant to 42 U.S.C. § 2000e-5(b), 29 C.F.R. § 1601.15(c), § 1601.18, and the EEOC’s Quality Control and Best Practices Guidelines, I hereby challenge this denial as contrary to law, due process, and EEOC policy, and request immediate supervisory and cross-agency review.

1. On what statutory or regulatory authority do you base your ability to unilaterally deny a charging party’s motion to toll the rebuttal deadline, especially when procedural deficiencies in the employer’s position statement have been identified?
   (See 42 U.S.C. § 2000e-5(b); 29 C.F.R. § 1601.15(c); 29 C.F.R. § 1601.18)
EXHIBIT A – EMAIL FROM INVESTIGATOR PEREZ DENYING TOLLING REQUEST

From: Alexander Perez <alexander.perez@eeoc.gov>
To: Thomas D. Coates <tdcoates@gmail.com>
Date: [Insert Date]
Subject: ADDENDUM: NOTICE OF TOLLING OF REBUTTAL DEADLINE & DEMAND FOR CURE OF DEFICIENCIES ADDENDUM TO PRIOR FILING EEOC Charge No.: 12K-2025-00001

Mr. Coates,
This request is hereby denied. Please submit your rebuttal as originally agreed to. Failure to submit a rebuttal will result in a finding based on the information in the file as of the date the rebuttal is due.

Enjoy your weekend.

Alexander Perez, Investigator
U.S. Equal Employment Opportunity Commission
Norfolk Local Office
200 Granby Street, Suite 739
Norfolk, VA 23510
757-600-4725 (main)
757-441-3475 (alt)
757-441-6720 (fax)
Alexander.Perez@EEOC.Gov

Referenced in this motion as Exhibit A.

2. What is the EEOC’s formal process for reviewing and ruling on motions or requests for procedural relief (such as tolling), and where is this process documented in the Commission’s regulations or guidance?
3. Are you authorized to deny such motions without supervisory review or formal written findings? If so, under what EEOC policy or regulation?
4. What steps, if any, did you take to review the procedural and evidentiary deficiencies I identified in Cox’s position statement before denying my request?
5. Did you consult with your supervisor, legal counsel, or the District Director prior to denying my motion? If not, why not?
6. How does the EEOC ensure compliance with 29 C.F.R. § 1601.15(c) and § 1601.18, which require that all employer submissions be procedurally sound, fully documented, and supported by sworn or certified evidence before being accepted into the record?
7. What is the EEOC’s protocol when a charging party identifies clear procedural violations or deficiencies in an employer’s position statement? Is the agency not required to demand a cure before proceeding?
8. How does the denial of my tolling request comply with the EEOC’s Quality Control and Best Practices Guidelines regarding due process, record integrity, and charging party rights?
9. Will the denial of my request be formally memorialized in the charge file, and will I receive a written explanation, including the legal and factual basis for the denial, as required by federal recordkeeping standards?
10. If I disagree with your denial, what is the process for immediate supervisory review or appeal within the EEOC, and how do I ensure that my objections are preserved for cross-agency and judicial review?

I respectfully demand that each of these questions be answered in writing and entered into the official record for EEOC Charge No. 12K-2025-00001, with copies furnished to all oversight agencies listed below.

I formally preserve all rights to supervisory, cross-agency, and judicial review of this denial, and request that this motion be immediately escalated to the District Director and the EEOC’s Office of Federal Operations for independent review.

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
• Charlotte A. Burrows, Chair, U.S. EEOC, Washington, D.C.
• Deputy Assistant Attorney General for Civil Rights, U.S. DOJ
• Virginia Equal Opportunity Commission (VEOC)
• DOJ Civil Rights Division
• DOL Wage and Hour Division
• Virginia Office of the State Inspector General
• Office of the Governor of Virginia
• Other designated agency officials as required by protocol

Dated: May 16, 2025

The integrity of this administrative proceeding depends on strict adherence to statutory and regulatory requirements, due process, and the preservation of the charging party’s rights. I respectfully demand immediate written justification for the denial of my tolling request and formal supervisory review.