This Addendum is submitted in direct reference to my previously filed letter/motion entitled “DEMAND FOR PROCEDURALLY PROPER POSITION STATEMENT (Request for Cure of Deficiencies and Memorialization of Procedural Objections)” dated May 15, 2025. This Addendum is to be incorporated into the administrative record for EEOC Charge No. 12K-2025-00001.

NOTICE: The time period for submitting my rebuttal to the Respondent’s position statement is hereby STOPPED, TOLLED, and SUSPENDED until all identified procedural deficiencies are fully cured. This tolling is asserted pursuant to my rights under 42 U.S.C. § 2000e-5(b) and 29 C.F.R. § 1601.15(c). No rebuttal will be submitted, and the rebuttal deadline is not to run, until the following deficiencies are addressed and corrected. This Addendum is to be transmitted to outside counsel for Cox Communications at the earliest possible convenience.

1. Lack of Author Certification: The position statement is unsigned, lacks an identified author, and is not certified by any responsible officer or attorney as required by 29 C.F.R. § 1601.18(c).
2. Absence of Affidavit or Sworn Testimony: No sworn affidavits or declarations are attached from any manager, HR official, or witness to support factual assertions, as required for credibility and admissibility.
3. Failure to Attach Referenced Documents: The statement references internal policies, records, and communications but fails to produce or attach them, in violation of 29 C.F.R. § 1601.15(c).
4. Improper Use of Footnotes to Disclaim Investigation: Footnotes appear to disclaim any formal investigation or disclosure, undermining the integrity of the submission and suggesting a lack of good faith cooperation with the EEOC.
5. Vague and Non-Specific Assertions: The statement relies on generalizations and policy summaries rather than specific dates, names, or events, preventing meaningful review or rebuttal.
6. Failure to Provide Statutorily Required Details: The statement omits required details such as dates of alleged performance issues, names of decision-makers, and the specific basis for each adverse action, in violation of EEOC evidentiary standards.
7. Improper Reliance on Verbal Claims: The statement references verbal conversations and supervisor impressions without documentation, which is inadmissible under EEOC and federal evidentiary rules.
8. No Statement of Internal Investigation: There is no evidence of an internal investigation, no interview notes, and no summary of findings, contrary to EEOC best practices.
9. Improper Blanket Confidentiality Claims: The statement makes broad assertions of confidentiality without justification or separate redacted exhibits, contrary to EEOC guidance.
10. Failure to Certify Completeness and Accuracy: The submission is not certified as complete and accurate under penalty of perjury or professional responsibility.

I respectfully demand that this Addendum and the list of deficiencies be immediately transmitted to outside counsel for Cox Communications and that the EEOC confirm in writing when this has been accomplished.

For the avoidance of doubt, all relief, objections, and procedural demands set forth in my prior filing dated May 15, 2025, are hereby reaffirmed and incorporated by reference as if fully set forth herein.