UNITED STATES EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

NOTICE OF FILING: This memorandum is submitted to formally memorialize and require the full integration of updated and newly discovered evidence into the EEOC and cross-agency record. In light of a now-docketed federal case and significant new findings, this filing supersedes and supplements all prior submissions, and must be reflected as the most current, controlling statement of record.

Grounds for Refiling and Updated Submission

• This filing incorporates time-stamped evidence, third-party agency findings, and statutory authorities that have emerged or clarified since any previous record entry.
• By integrating all new records as of today, this motion eliminates the risk of administrative closure, mootness, or procedural default.
• The existence of a valid federal docket compels full cross-jurisdictional review and projects all claims forward for judicial, systemic, and administrative action.
• This submission corrects, rebuts, and overrides any conflicting claims, omissions, or procedural errors by prior parties or agencies that might prejudice the record.
• It commands immediate attention from all agencies, memorializes oversight notification, and preserves the full evidentiary chain for appeal, enforcement, and further proceedings.
• The updated record maximizes the probability of sanctions, remedies, and corrective agency action—including referral to DOJ, DOL, and court-based oversight.

Sections That Must Be Reviewed and Updated

1. Update ALL DATES and TIMESTAMPS: Ensure every reference aligns with today’s date and current legal status.
2. Header/Title: Reflects “as of October 31, 2025” and the federal docket number if available.
3. Agency Addresses: Confirm proper addressees and contacts for any new agencies or parties since previous filings.
4. New Evidence Statements: Add references and summaries for any evidence acquired since the last submission; attach exhibit or index if possible.
5. Relief Sought: Include new remedy requests enabled by current federal or cross-agency posture (e.g., emergency relief, sanctions, open record for supplemental submissions).
6. Closing Certification and Footer: Affirm this filing is the most current and complete, superseding outdated or partial filings, with your digital/email signature and correct contact details.

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