Formal Motion No. 4 - Request for Certified HR Records and Workday Audit Logs

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 and Workday audit logs, as detailed below, for entry into the EEOC record and for cross-agency evidentiary review.

II. DOCUMENT REQUESTS AND PRODUCTION SPECIFICATIONS

The following documents are requested for production, in certified and native format, as applicable:

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 (User: Thomas D. Coates)	May 30, 2024 – May 12, 2025	Native XLSX or CSV with metadata and digital signature of IT custodian
All Workday entries, workflow actions, and approvals/denials for Thomas D. Coates	May 30, 2024 – May 12, 2025	Full export with audit trail, including timestamps and user IDs

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 audit best practices.

III. JUSTIFICATION AND MATERIALITY

The requested HR case files and certified personnel records 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 user logs and audit trails are necessary to verify all system activity, requests, and workflow actions attributed to Complainant, and to identify any discrepancies or omissions in Respondent’s narrative.
Certified copies 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.

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 and Workday 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 and audit logs 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.