| 2 |
Email Thread — “Misconduct and Statutory Contradiction – Claim #3858978 / Certified BYE Conflict” |
Email from Wendy Pease (VEC Chief of Benefits) dated Aug 1 2025 replying to claimant Thomas D. Coates, stating claim BYE was 07/28/2024–07/26/2025; asserts expiration despite prior certification. Includes official contact details, attached BYE Reminder Notice, and links to VEC claim guidance. |
Aug 1–2 2025 (email timestamps 1:27 PM and 2:40 PM) |
Verified email headers from vec.virginia.gov domain; reply chain; file-level metadata showing timestamp consistency; attached PDF and linked record URLs. |
Original sender: Wendy Pease (VEC); recipient: Thomas D. Coates. Stored copies in claimant’s email archive and downloaded attachments on secure drive. |
Establishes the agency’s written position on claim expiration and demonstrates systemic failure to acknowledge the certified BYE conflict. Forms basis for allegations of procedural defects, due-process violations, and misapplication of Va. Code §§ 60.2-612, 619, 620. |
High |
Exhibit_2_VEC_WendyPease_BYEConflict_2025-08-01.pdf |
| 3 |
Formal Charge & Demand for Show Cause – Wendy Pease (VEC) | DOL & DOJ Notifications |
Letter from Thomas D. Coates to U.S. Dept of Labor and Dept of Justice alleging misconduct, statutory violations, and obstruction by VEC official Wendy Pease in handling Claim #3858978. Details six statutory violations, references federal and state code sections, and demands investigation and show-cause response. |
Aug 2 2025 (2:40 PM email timestamp) |
Email headers; metadata; copies of letter submitted to multiple agencies; proof of delivery via BCC/CC list including DOJ and DOL addresses. |
Claimant Thomas D. Coates; custodian of original email and signed letter; recipients include federal agencies responsible for oversight and enforcement. |
Documents formal external escalation and notice to federal authorities of VEC’s procedural misconduct; preserves record of statutory notice and triggers potential federal oversight review. |
Very High |
Exhibit_3_ShowCause_WPease_VEC_2025-08-02.pdf |
| 4 |
Demand: Payment Correction & Non-Appealable Directive (VEC Procedural Failures) |
Formal demand letter from Thomas D. Coates to VEC (and cross-agencies) asserting that VEC improperly “fell back” on vacated deputy decisions, delaying payment after Commission decision UI-145419-C. Seeks activation of payment priority queue, non-appealable directive, and immediate benefits disbursement. |
June 30, 2025 (document date); references to Order UI-25009642 (June 23, 2025) and UI-145419-C (May 8, 2025) |
Original PDF with metadata (creation, modification timestamps); email or delivery headers if submitted via email or official channel; certified copy of the demand; cross-agency CC list verifying dissemination. |
Claimant Thomas D. Coates; document maintained in claimant’s file and sent to VEC / DOL / OSIG / DOJ; preserved in original PDF form and copies in multiple jurisdictions. |
Shows formal escalation demanding compliance with Va. Code §§ 60.2-612, 60.2-622 and VEC Procedure Manual § 3.3.7; demonstrates that VEC’s delay in payment after favorable decision constitutes procedural noncompliance. |
High |
Exhibit_4_VEC_PaymentDemand_2025-06-30.pdf |
| 5 |
Correspondence “vec06112025” – VEC Internal / External Communication |
Document titled “vec06112025” (PDF/HTML) representing VEC communication or internal memo — possibly a payment notice, delayed adjudication or internal email chain — regarding claimant’s case, cited to show a procedural or timing error. |
June 11, 2025 (document date in filename) |
File metadata (creation and modification timestamps), internal headers or footers, embedded system logs, if any; verification by original file origin (VEC/ claim file) or FOIA custodian attest. |
Produced by VEC or forwarded from internal custodian; preserved by claimant via download or archival copy; original in claimant’s file repository. |
Serves as evidence of VEC’s internal communication or action at a key date (June 11, 2025) — can demonstrate a timing discrepancy, failure to act, or conflicting internal position with later determinations. |
Medium to High |
Exhibit_5_VEC_vec06112025_0001.pdf |
| 6 |
“Demetrios” Correspondence / Document |
PDF document titled “demetrios.pdf” — possibly correspondence, internal memo, or related record referencing claimant’s case or VEC handling, used to show inconsistent or adverse internal treatment or notice. |
Date embedded in metadata (file creation / transmitted date) and any visible header/footer dates |
File metadata (creation, modification timestamps), original PDF file with embedded properties, any signatures or digital stamps, forwarded email header if applicable. |
Custody by claimant (downloaded copy) and preservation of original digital file; if submitted via email or FOIA, also held in VEC or third-party archives. |
Shows additional internal or external communication regarding the claim, which can be compared with VEC’s public and adjudicative responses to show inconsistency, delay, or internal acknowledgment of error. |
Medium to High |
Exhibit_6_Demetrios_0001.pdf |
| 7.1 |
Reasonable Accommodation Request (PDF) — Appendix A-6 |
Complainant’s formal request (PDF) to Cox / VEC (or employer) for ADA reasonable accommodation initiated on 7/8/2024, asserting disability and asking for adjustments. |
7/08/2024 |
PDF file metadata, signed request or cover email, internal timestamp of submission, email headers or delivery receipt. |
In claimant’s possession and part of EEOC/agency record submissions; also cross-referenced in the automated tool’s index. |
Shows claimant engaged protected ADA activity before adverse actions; triggers interactive process obligations. |
High |
Appendix_A-6_Accommodation_Request_2024.pdf |
| 7.2 |
EEOC Charge Filing Acknowledgment — Appendix D-2 |
Acknowledgment from EEOC (date 10/24/2024) confirming receipt of the charge of employment discrimination by the claimant. |
10/24/2024 |
EEOC acknowledgment letter/email, EEOC file stamp, metadata, headers. |
Held by claimant and EEOC file; included in the automated evidence index. |
Establishes the formal commencement of EEOC processing and creates federal investigatory timeline. |
High |
Appendix_D-2_EEOC_Charge_Acknowledgment_2024.pdf |
| 7.3 |
Commission Final Decision UI-145419-C — Appendix F-1 / Appendix A-1 |
The VEC Commission’s decision dated 5/8/2025 awarding benefits (reversing prior determinations), which the agency failed to promptly execute. |
05/08/2025 |
Official Commission decision document, stamped, signed, with metadata, docket number. |
At VEC’s records; claimant copy; referenced in the evidence tool index. |
Demonstrates adjudicated eligibility; anchors the claim that VEC must pay and cannot reverse arbitrarily. |
High |
Appendix_F-1_UI-145419-C_Decision.pdf |
| 7.4 |
B-FWC-001 Expiration Notice — Appendix G-3 |
VEC’s automatic Benefit Year End expiration notice issued 7/22/2025, despite ongoing appeal and protective filings. |
07/22/2025 |
The notice document, with VEC header, date stamp, possibly mail tracking, or email header. |
In VEC files, claimant’s record, and referenced as an inconsistent automation event in the tool. |
Shows VEC prematurely triggered benefit-year expiration whereas claim was still active or under protective status. |
High |
Appendix_G-3_BFWC001_ExpirationNotice_2025.pdf |
| 7.5 |
Vacatur Order UI-25009642 — Appendix A-3 |
VEC Appeals / Judicial order dated 6/23/2025 vacating prior deputy-level determinations, removing legal force from earlier denials. |
06/23/2025 |
Certified order document, docket stamp, signature, metadata. |
VEC appeal board / legal unit file; claimant retains copy; cited in the tool. |
Establishes that prior deputy decisions are void and cannot be reactivated; central to your argument. |
Very High |
Appendix_A-3_Vacatur_Order_UI-25009642.pdf |
| 7.6 |
FOIA Request to VEC for Internal Logs — Appendix C-1 |
FOIA request submitted 7/10/2025 asking for internal audit logs, metadata, routing flags, and VUIS system access records related to your file. |
07/10/2025 |
Copy of FOIA request, email header, return receipt if any, and metadata. |
Claimant’s copy and VEC FOIA office file; referenced in the tool index. |
Supports your demand that VEC must release internal logs and audit trails to prove or disprove record manipulations. |
High |
Appendix_C-1_FOIARequest_InternalLogs_2025.pdf |
| 7.7 |
Request to DOJ ADA Division for Review — Appendix B-8 |
Request submitted 7/12/2025 to DOJ ADA Division seeking investigation into VEC and Cox’s ADA retaliation & discrimination as applied to your claim. |
07/12/2025 |
Email or letter, headers, certified delivery evidence, metadata. |
In claimant’s records and DOJ/agency submission files, as referenced in the tool. |
Demonstrates escalation to federal ADA oversight and documentation of protected activity retaliation claim. |
High |
Appendix_B-8_Request_DOJ_ADA_Review_2025.pdf |
| 7.8 |
EEOC Inquiry 437-2025-01209 Filed — Appendix B-4 |
Formal EEOC inquiry filed on 4/2/2025 under charge number 437-2025-01209, closed prematurely without documented ADA or investigative follow-up. |
04/02/2025 |
EEOC intake record, internal file metadata, closure memo or notice, portal/email headers. |
EEOC case file and your records; also referenced in the evidence tool index. |
Shows procedural failure of EEOC to properly investigate your complaint, supporting arguments of suppression or abandonment of process. |
High |
Appendix_B-4_EEOC_Inquiry_437-2025-01209.pdf |
| 8 |
Weekly Certification Submission & Confirmation — Appendix A-8 |
Claimant’s weekly certification submission for benefit week(s) and system confirmation receipt showing claimant timely attempted to certify (portal entry and confirmation screen capture / email confirmation). |
07/18/2025 |
Native portal confirmation screenshot / email, server response headers, timestamped log export (if available) or claimant screenshot with device metadata. |
Claimant’s device/archives; VEC portal record if produced via FOIA; preserve original screenshots and native files. |
Demonstrates claimant actively certified during the contested window and rebuts any claim of voluntary inactivity or failure to file. |
High |
Appendix_A-8_WeeklyCert_2025-07-18.pdf |
| 9 |
Administrative Hold Objection (Pre-BYE) — Appendix A-11 |
Formal objection filed by claimant to VEC disputing an automated administrative hold placed on the claim prior to Benefit Year End (document includes rationale and request for manual review). |
07/20/2025 |
Original submitted document/email, delivery receipt, and FOIA/acknowledgment entry if present; metadata and any VEC response. |
Claimant custody; VEC FOIA/appeals file upon production. |
Proves claimant attempted to stop automated hold processing and requested manual intervention before BYE expiration—critical to show administrative error rather than claimant inaction. |
Medium-High |
Appendix_A-11_AdminHoldObjection_2025-07-20.pdf |
| 10 |
Email to EEOC OFO — Appeal Escalation / Portal Evidence — Appendix B-9 |
Escalation email to EEOC Office of Federal Operations requesting review and immediate action (includes attachments: chronology, FOIA request, and portal screenshots). |
07/24/2025 |
Native email files with headers, attachments, EEOC inbox receipt (if any), and delivery metadata. |
Claimant’s sent mail archive and EEOC receipt; potential EEOC docket entry. |
Shows federal escalation and documents the claimant’s attempt to secure administrative relief while VEC automated processes continued. Useful to show agency had notice of ongoing dispute. |
High |
Appendix_B-9_EEOC_OFO_Escalation_2025-07-24.pdf |
| 11 |
Submission to DOJ ADA Civil Rights Division — Appendix B-7 |
Formal submission to DOJ (ADA Division) detailing ADA retaliation/discrimination claims and requesting federal review and enforcement. Includes chronology and supporting exhibits. |
07/15/2025 |
Native submission letter/email, certified mailing receipt or delivery log, attachments list, and file stamp (if DOJ acknowledges). |
Claimant’s records and DOJ intake file upon agency acknowledgment. |
Demonstrates another formal federal escalation and documents protected activity; strengthens retaliation and failure-to-accommodate theories. |
Very High |
Appendix_B-7_DOJ_ADA_Submission_2025-07-15.pdf |
| 12 |
FOIA Request FOIA-001 to VEC (Internal Logs / Audit Trails) — Appendix C-2 |
FOIA request served on VEC seeking internal VUIS audit logs, mailroom logs, adjudication metadata, and document production history associated with the claimant’s files. |
06/01/2025 |
Original FOIA submission copy, email headers or certified mail receipt, FOIA tracking ID, and any initial FOIA acknowledgment. |
Claimant’s FOIA records; VEC FOIA office file upon production (C-2). |
Establishes early effort to compel VEC to disclose underlying system logs and chain-of-custody—critical to prove missing audit trail or post-hoc edits. |
High |
Appendix_C-2_FOIA-001_InternalLogs_2025-06-01.pdf |
| 13 |
Follow-Up Letter to DOJ with Evidence Chronology — Appendix D-3 |
Supplementary follow-up to DOJ (and other agencies) supplying an organized evidence chronology and referencing appendices A–C to aid investigation. |
07/05/2025 |
Native email or letter files, attachments, delivery confirmation, and attached index (chronology). |
Claimant’s submission archive; DOJ/agency intake files if acknowledged. |
Consolidates evidence for federal reviewers and demonstrates methodical preservation and presentation of the case timeline. Useful to show consistency and preemption of agency assertions. |
High |
Appendix_D-3_FollowUp_DOJ_Chronology_2025-07-05.pdf |
| 14 |
Employer Termination Notification Received During EEOC Charge — Appendix B-6 |
Official termination notice/HR communication from Cox received by claimant during active EEOC intake—documenting adverse employment action contemporaneous with EEOC complaints. |
04/16/2025 |
Native termination letter, HR email headers, signed acknowledgements, and payroll termination entry metadata. |
Employer (Cox) records; claimant copy; EEOC intake file references. |
Direct evidence of adverse action potentially linked to protected activity; central to retaliation/retaliatory discharge claims. |
Very High |
Appendix_B-6_Termination_Notice_2025-04-16.pdf |
| 15 |
Motion to Stay Final Determination Pending Appeal — Appendix B-25 |
Motion filed to stay enforcement/collection of any adverse determination while appeal and remediation demands were pending (includes legal arguments and citations). |
05/21/2025 |
Filed motion PDF, court/agency docket stamp, service list, and proof of service. |
Claimant filing records and agency docket; office of the clerk or agency appeals docket. |
Shows claimant sought immediate judicial/administrative relief to prevent adverse enforcement and demonstrates timely procedural steps to preserve rights. |
High |
Appendix_B-25_MotionToStay_2025-05-21.pdf |