Petition for Writ of Certiorari — Antonio Goodwin, Petitioner v. AT&T Corporation

Supreme Court briefJun 26, 2026

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Case: 26-927, 06/02/2026, DktEntry: 20.1, Page 1 of 1

FILED

UNITED STATES COURT OF APPEALS

JUN 2 2026

FOR THE NINTH CIRCUIT

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

ANTONIO GOODWIN,

Plaintiff - Appellant,

v.

AT&T CORPORATION,

No. 26-927

DC. No.

2:23-cv-01950-GMN-DJA

District of Nevada,

Las Vegas

ORDER

Defendant - Appellee.

Before: FRIEDLAND, R. NELSON, and BADE, Circuit Judges.

After considering the responses to the court’s March 31, 2026 order, we

deny the motion to proceed in forma pauperis (Docket Entry No. 3) and dismiss

this appeal as frivolous. See 28 U.S.C. § 1915(a), (e)(2).

All other pending motions are denied as moot.

This court will not entertain any further filings in this closed case.

DISMISSED.

Case 2:23-cv-01950-GMN-DJA

Document 240

Filed 06/24/26

Page 1 of 1

FILED

UNITED STATES COURT OF APPEALS

JUN 24 2026

FOR THE NINTH CIRCUIT

MOLLY C. DWYER, CLERK

U.S. COURT OF APPEALS

ANTONIO GOODWIN,

Plaintiff - Appellant,

v.

AT&T CORPORATION,

No. 26-927

D.C. No.

2:23-cv-01950-GMN-DJA

District of Nevada,

Las Vegas

MANDATE

Defendant - Appellee.

The judgment of this Court, entered June 02, 2026, takes effect this date.

This constitutes the formal mandate of this Court issued pursuant to

Rule 41(a) of the Federal Rules of Appellate Procedure.

FOR THE COURT:

MOLLY C. DWYER

CLERK OF COURT

This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT

RESPOND to this e-mail because the mail box is unattended.

***NOTE TO PUBLIC ACCESS USERS*** There is no charge for viewing opinions.

United States District Court

District of Nevada

Notice of Electronic Filing

The following transaction was entered on 2/6/2026 at 3:45 PM PST and filed on 2/5/2026

Case Name:

Goodwin v. AT&T

Case Number:

2:23-cv-01950-GMN-DJA

«*

Filer:

WARNING: CASE CLOSED on 02/05/2026

Document Number:212

Docket Text:

ORDER ADOPTING REPORT AND RECOMMENDATION.

IT IS ORDERED that Plaintiff's [200] Objection is STRICKEN.

IT IS FURTHER ORDERED that the [189] Report and Recommendation is ACCEPTED and

ADOPTED in full.

IT IS FURTHER ORDERED that Plaintiff's Motions (ECF Nos. [185]-[187]) are certified as

frivolous.

IT IS FURTHER ORDERED that this case is DISMISSED without prejudice.

IT IS FURTHER ORDERED that all other pending motions are DENIED as moot.

The Clerk of Court is kindly directed to close the case.

Signed by Judge Gloria M. Navarro on 2/5/2026. (Copies have been distributed

pursuant to the NEF - AMMi)

2:23-cv-01950-GMN-DJA Notice has been electronically mailed to:

Zachary P. Takos

zach@takoslaw.com. amber@takoslaw.com. steven@takoslaw.com

Stacey A. Campbell

stacev@camDbell-litigation.com, bayan@campbell-

litigation.com. brett@campbell-litigation.com. carl@campbelllitigation.com. carynann@campbell-litigation.com . mario@campbell-litigation.com

Antonio Goodwin

tonygoodwinl 19@gmail.com

2:23-cv-01950-GMN-DJA Notice has been delivered by other means to:

The following document's) are associated with this transaction:

Document description:Main Document

Original filename:n/a

Electronic document Stamp:

[STAMP dcecfStamp_ID=1101333072 [Date=2/6/2026] [FileNumber=12246335-0

] [9a1e7dd465533dc12384e49ed843a058b0ccbaabeb2b629e76c28b00ae40e4e4357

ea836ab1 f983a792a419677ad0911689eda25af4880ff1 b0e47fe42cedbc3]]

8:19

.il 5G?

February 18,2022

LogOut

AT&T INC.

ATAT FU TiFU ME NT SAVINGS Pi AN t ASY

E.NflOl.l

You're Enrolled!

Please print and save this confirmation.

We will send a notification to

TONYGOODWIN119^GMAIL.COM with a link

to details of your last transaction.

Your selections will generally take effect in 1-2

pay periods

AT&T RETIREMENT SAVINGS PLAN

401K

Contribution

6% of paycheck. Pre-Tax

Investment

AT&T ASSET ALOC 2035

Annual Increase

1% (Beginning 03/18/202

Confirmation

220500024 W819

2/

Your Money M... 2/14/22

To: Tony Goodwin >

Reply To: Fidelity Dnv... >

Take action before

your automatic

enrollment on

03/18/2022

& Fidelity

AT&T Retirement Savings Plan

ANTONIO GOODWIN

Transaction Date: 02/11/2022

Congratulations, you can now get started in your AT&T

Retirement Savings Plan.

You have until 03/18/2022 to enroll in your plan or make

changes before you will be directed into the plan default

options. Take action now.

View details of your Automatic Enrollment Information.

Please contact us at 800-416-2363 if you need

assistance.

Fidelity is committed to

your security. To keep

your information

private, we have

provided further details

on our passwordprotected Web site,

NetBenefits.com.

/yj^\ Your Money...

2/23/22

To: Tony Goodwin >

Reply To: Fidelity Inv... >

Summary of your

recent account

changes

^Fidelity

AT&T Retirement Savings Plan

ANTONIO GOODWIN

Transaction Date:02/22/2022

Confirmation of Changes to Your

Account

The following activities have occurred on your account:

• There was an update to your election.

• Your investment elections have been changed as

requested.

> View all activity details

Remember, you can visit NetBenefits.com any time to

manage your workplace benefits, or call us at 800-416-2363

for help.

Quick Links

Fidelity is committed to

your security. To keep

your information private,

we have provided further

details on our passwordprotected Web site,

NetBenefits.com.

YM) Your Money...

7/29/22

To: Tony Goodwin >

Reply To: Fidelity Inv... >

Disclosure About Your

Retirement Plan - Your

latest quarterly

statement is available

^Fidelity

ANTONIO GOODWIN

AT&T Retirement Savings Plan

Quarterly Statement

Important information about your retirement plan is now available. Please review this

information.

Your latest quarterly statement is available to view online.

You can visit NetBenefits® any time* to view statements dating back 10 years.

If you wish to opt-out of electronic delivery, please update your mail preferences.

i?(9)UuiA)(a uiru «5tnnj8)uu m imjsjuu ma...

/y^. Your Money M... 1/25/23

To: Tony Goodwin >

Reply To: Fidelity inv.,. >

IMPORTANT TAX

RETURN DOCUMENTS

AVAILABLE

^Fidelity

ANTONIO GOODWIN

AT&T RETIREMENT SAVINGS PLAN

Your 2022 Tax Form(s) are Ready to View and

Print

Your tax form(s) are now available online for the 2022 tax year

» View My Tax Forms

Tax forms are plan specific. If you have multiple plans, you may receive more than one

email with a link to the associated tax forms for that plan.

Your Money M... 11/7/22

To: Tony Goodwin >

Reply To: Fidelity inv... >

A notification about

your distribution is

available online

AT&T Retirement Savings Plan

ANTONIO GOODWIN

Transaction Date: 11/04/2022

IMPORTANT NOTICE: ACTION MAY BE REQUIRED BY

4PM EASTERN TIME 12/23/2022

> View account balance on NetBenefits.com

> View tax notice

We are writing in respect to your retirement account in the

Plan listed above. As part of a periodic review, your

account has been identified as having a vested market

value equal to or less than your Plan's minimum required

Fidelity is <

your secui

your inforr

private, w(

provided fi

on our pas

protected'

NetBenefii

4*. iBb Your Money M... 8/9/22

To: Tony Goodwin >

Reply To: Fidelity Inv... >

^Fidelity

ANTONIO GOODWIN

AT&T Retirement Savings Plan

Your Funds are on their Way

Quick Links

Your funds will be sent via UPS. You should receive your

check within 2 to 3 business days.

Your tracking number will be active within one business day.

Select the number below to track your package, or copy and

paste it on the UPS website.

Your tracking number is 1Z543V7Y1347943228.

Please note:You may see a message reading "A label for this

shipment has been created, but UPS does not yet have

possession of this shipment," for one business day, while the

check is being processed.

Secure Login £

www.ups.com

Withdrawals

Learn how to protect your

account by going to

NetBenefits.

Your Money...

7/29/22

To: Tony Goodwin >

Reply To: Fidelity Inv... >

Your recent Benefits

Center experience

&Fidelity.

AT&T

Dear ANTONIO GOODWIN

X? Two minutes of your time

to improve your

experience

Quick Links

Share your feedback

now

Please tell us about your recent call with the Fidelity

Benefits Center. Your feedback is important to us as we

strive to provide exceptional customer service.

Start the survey

Thank you for your assistance!

Fidelity Investments Benefits Center

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Fidelity has hired Medallia Inc. to develop, collect and analyze the responses generated by the

attached survey. Fidelity Investments and Medallia Inc, are Independent entities and arc not

legally affiliated.

Neither Fidelity nor Medallia Inc. will individually respond to any feedback you provide In

this survey unless required to do so by applicable law, nor will they use your feedback

for Individual marketing efforts. Please do not include any personally identifiable information

related to an account in your responses. If you have specific issues that you would like Fidelity

to follow up on with you. please contact Fidelity directly through your normal contact channel.

Please do not respond to this email. This mailbox is not monitored, and you will not receive a

response.

Your workplace benefits account is currently set to send emails of the following type:

Confirmations of One-Time Transactions. To change this email setting dick: Stop receiving

emails of this type. Note: You will be required to log in to NetBenefits.

Fidelity Brokerage Services LLC. Member NYSE. SIPC. 900 Salern_Street,.Smithfield, Rl 02917

1025761.1.0

(YM J Frem: WMF

7 To: Toouy @©@diwooD

Reply To: FM@DK:f [ow....

October 27, 2022 aft 12:...

Disclosure About Your

Retirement Plan - Your

latest quarterly

statement is available

ANTONIO GOODWIN

AT&T Retirement Savings Plan

Quarterly Statement

Important information about your retirement plan is now available. Please review this

information.

Your latest quarterly statement is available to view online.

You can visit NetBenefits® any time* to view statements dating back 10 years.

If you wish to opt-out of electronic delivery, please update your mail preferences.

On Tuet Aug 9f 2022 at 9:35 AM Your Money Matters

<Fidelity.lnvestments@mail.fidelitv.com> wrote:

View In your browser

^Fidelity

ANTONIO GOODWIN

AT&T Retirement Savings Plan

Secure Login fl

You r Funds are on their Way

Your funds will be sent via UPS. You should receive your

check within 2 to 3 business days.

Quick Links

www.uDs.com

Your tracking number will be active within one business day.

Select the number below to track your package, or copy and

paste it on the UPS website.

Your tracking number is 1ZM3V7Y1M7943228.

Please note: You may see a message reading "A label for this

shipment has been created, but UPS does not yet have

possession of this shipment," for one business day, while the

check is being processed.

Privacy Policy

|

Terms of Use

UPS and Fidelity Investments are independent entities and are not legaly affiliated.

Your workplace benefits account Is currently set to send emails of the following type: Confirmations of One-Time

Transactions. To change this email setting dick: Stop receiving emaite of Otis type. Note: You will be required to

log In to NetBenefits,

The information in this e-mail is intended solely for the attention and use of the named addressee. This message

or any part thereof must not be disclosed, copied, distributed, or retained by any person without authorization of

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Fidelity Investments Institutional Operations Company LLC 245 Summer Street. Boston, MA 02210

© 2019 FMR LLC. AM rights reserved.

1018574.1.0

ctzAii occrr-tnoiruicnn^ ooexinv

.

.

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Sent from my iPhone

i

__

____

On Tue, Aug 9# 2022 at 9:35 AM Your Money Matters

<Fidelitv.lnvestments@rnaiLfidelitvxorn> wrote:

View in your browser

^Fidelity.

ANTONIO GOODWIN

AT&T Retirement Savings Plan

§££.u.r-9_Lflgia fi

Your Funds are on their Way

Your funds will be sent via UPS. You should receive your

check within 2 to 3 business days.

Quick Links

www.ups.corn

Your tracking number will be active within one business day.

Select the number below to track your package, or copy and

paste it on the UPS website.

Withdrawals

Your tracking number is 1Z543V7Y1347943228.

Leam how to protect vour

account bv going to

b>et.BgjTgJt§.

Please note:You may see a message reading "A label for this

shipment has been created, but UPS does not yet have

possession of this shipment," for one business day, while the

check is being processed.

Privacy Policy

|

Terms of Use

UPS and Fidelity Investments are independent entities and are not legally affiliated.

Your workplace benefits account is currently set to send emails of the following type: Confirmations of One-Time

Transactions. To change this email setting click: Stop receiving emails of this type. Note: You will be required to

log in to NetBenefits.

The information in this e-mail is intended solely for the attention and use of the named addressee. This message

or any part thereof must not be disclosed, copied, distributed, or retained by any person without authorization of

the addressee.

Fidelity Investments Institutional Operations Company LLC 245 Summer Street. Boston, MA 02210

© 2019 FMR LLC. All rights reserved.

1018574.1.0

®

Your Money M... 1/25/22

To: Tony Goodwin >

Reply To: Fidelity Inv... >

Start thinking of the

future today! You're

now eligible to enroll

in your AT&T 401 (k)

savings plan.

4® AT&T

Enroll in your AT&T savings

plan.

Congratulations! You are eligible to enroll in your

AT&T 401 (k) savings plan. Start thinking about

your future today. Consider participating early

and maximize your company match. For every

dollar you contribute (up to 6% of your eligible

compensation), AT&T provides a matching

contribution. That’s free money!

your

monegj

matters

QUICK LINKS

'

> www.NelBenefrts.com/

art

Three easy steps to enroll:

Go to www.NetBenefits.com/att and select enroll. If you don’t

already have a Fidelity account, set up a user ID/password; and select

Register Now. Or, call the Fidelity Service Center at (800) 416-2363 to

enroll.

$

Decide how much to contribute. You can save up to 50% of your

eligible compensation in your AT&T savings plan subject to annua!

limits. Contribute at least 6% on every paycheck to take full advantage

ATCTa

-----------------

------------

Case 2:

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Dylan >

Aug 3, 2022 at 5:23 PM

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32 of 42

Case 2:

34 of 42

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Aug 4, 2022 at 7:37PM

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submitted just waiting for all

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Fidelity.

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36 of 42

Case 2

12:43

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Aug 5, 2022 at 11:02 AM

Aug 5, 2022 at 1:50 PM

From what I see this

morning as of 7.30am is

complete

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Document 78-1

Filed 04/29/25

Page 3 of 42

Case 2:23-cv-01950-GM|)|2pj(ftilpocument 26

Empl ID:

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Check Date:

Check Number

Batch Number

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00644278

Page 001 of 001

OM7fiO22 • 03/12/2022

03/18/2022

2047241780

000000000711

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915 ALPER CENTER DR

UNTT 1307

HENDERSON, NV 89062

722-1787

Tbfa Furled

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Rate

Fay Pnr1ed(022722-011222)

REGULAR

PREMIUM 0.5

NIGHT DIF REG IM

SIMMY DIF REG IM

NIGHT DIF OT IM

SUNDAY DIF OT IM

16.6250

8.3125

1.6625

1.6625

1.6625

1.6625

Taxable Waves Suvary

Fed

Social security

Medicare

2022 SOC SECURITY LIMITS: WAGES:

2022 SOC SECURITY LIMITS: TAXES:

97.45

17.45

1.22

16.08

0.83

1.68

1,620.11

145.05

2.03

26.73

1.38

2.79

This Furled Ye*r-to-*ete

1.719.41

6.782.60

1.800.94

6,864.13

1.800.94

6,864.13

147,000.00

9,114.00

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NM BASIC 4012

Purled Teer-te-Oate

81.S381.53-

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FED

TH* Perled Year-te-Sate

181.33775.60-

Soc<a1 Security

111.66-

425.50-

Case 2:23-cv-01950-GMN-DJA

Document 78-1

Filed 04/29/25

Page 4 of 42

Case 2:23-cv-01950-GMN-DJA Document 26 -Filed 04/25/24 Page 8 of 87

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Check Number

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00644278

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03/13/2022 ■ 03/26/2022

04/0142022

2047248281

000000000735

ANTOMO GOODWIN

815 ALPER CENTER DR

UNTT 3307

HEM3ERSON, NV 88082

Eaminfs

Pay Period(031322-832621)

REGULAR

PREMIUM 0.5

NIGHT DIF REG 104

SUNDAY DIF REG 104

NIGHT DIF OT 104

ADO'L ADJUSTED OT PREM

Poy Per1od(*2ei4t-e2t822)

C0NUSS10N*

Rate

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16.6250

8.3125

1.6625

1.6625

1.6625

80.07

0.88

1.55

15.42

0.60

Other

This

Period

Year-te-Nate

ARSP BASIC 401K

150.25-

231.78-

This Period

1,331.16

7.32

2.58

25.64

1.00

0.16

Tas bodectiee*

FED

Social Security

This Period Year-te-Oate

377.851.153.45158.00583.56-

1,159.40

•SEE CONUSSTON/INCENTIVE/AXARD

STATEMENT(S) FOR MORE DETAIL

Taxable Nafoe Staamry

Fed

Social security

Medicare

2022 SOC SECURITY LIMITS: WAGES:

2022 SOC SECURITY LIMITS: TAXES:

Thia Period Yoar-te-Nete

2,395.16

9,180.76

2,548.41

9,412.54

2,548.41

9,412.54

147,000.00

9,114.00

Case 2:23-cv-01950-GMN-DJA

Document 78-1

Filed 04/29/25

Page 5 of 42

Case 2:23-cv-01950-GJ^^J^ 7(pocument 26

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04/2912022

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NIGHT DIF REG IM

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NIGHT DIF OT IM

AOO'1 AWIISTFt) OT PStX

Pay Period(4M122-433122)

COMMISSION*

Pay Period(43*122-*33122)

■ears

Rate

This Period

Other

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Oodactleee__________ Peeled

Year-te-Oate

165.28-

478.55-

ARSP BASIC 401K

16.6250

8.3125

1.6625

1.6625

1.6625

80.55

0.55

4.02

7.98

0.55

1,339.14

4.57

6.68

13.27

0.91

0.07

Ta* Mortices

FEO

Social Security

Tide Parted Year-te-Oate

439.321,736.46175.74850.37-

1.404.73

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C18M, 2006. AOP, Wc. Al RitftS

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STATEMENT(S) FOR MORE DETAIL

Tbit Period Year-te-Oate

2,669.27

13.237.05

2.834.55

13,715.60

2.834.55

13.715.60

2022 SOC SECURITY LIMITS: WAGES:

2022 SOC SECURITY LIMITS: TAXES:

TEAR HERE

147,000.00

9,114.00

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Case 2:23-cv-01950-GMN-DJA

Document 78-1

Filed 04/29/25

Page 6 of 42

Case 2:23-cv-01950-GW^apocument 26

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Check Me:

Check Number

Balch Number.

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000000000750

ANTONIO GOODWIN

918 ALPER CENTER DR

untt »07

HENDERSON, NV 88062

722-1787

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REGULAR

PREMIUM 0.5

NIGHT DIF REG IM

SUNDAY DIF REG IM

NIGHT DIF OT IM

SUNDAY OIF OT IM

AOD'L ADJUSTED OT PREM

Par Perled(W0122-8B3122)

TAXABLE NON-CASH AWARD*

■aura

Rate

16.6250

8.3125

1.6625

1.6625

1.6625

1.6625

82.12

2.23

2.22

15.80

0.22

0.97

IMe Purled

1,365.25

18.54

3.69

26.27

0.37

1.61

0.46

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Dedectieea

Thia

Peried

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ARSP BASIC 401K

81.49-

313.27-

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143.691,297.1491.05674.63-

50.00

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2022 SOC SECURITY UNITS: MSES:

2022 SOC SECURITY UNITS: TAXES:

>18*2008. ADP, ine. M W a

•$££ COMISSION/INCENTIVE/MMRO

STATEMENT ($) FDR MORE DETAIL

Tbit Perled Ye«r-te-Dete

1.387.02

10,567.78

1,468.51

10,881.05

1,468.51

10,881.05

147.000.00

9,114.00

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Case 2:23-cv-01950-GMN-DJA

Document 78-1

Filed 04/29/25

Page 7 of 42

Case 2;23-cv-01950-G^^document 26

Empl ID:

AT&T

Period Bog£nd;

Check Dads:

Check Number.

Belch Number.

1010 Pint Stntt, 7E-K-C8

St. Lou* MO 63101-3015

00644278

Page 001 of 001

04/24/2022 - 06/37/2022

05/13/2022

2047267209

000000000806

ANTONIO QOOOWWN __

915 ALPER CENTER DR

UNIT 3307

HENDERSON, NV 09062

722-1717

Um1w»_________________ Uf

Pay Perted(04S42>-0W722)

REGULAR

16.6250

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1.6625

SUNDAY OIF REG IM

1.6625

toy Perted(040122-043022)

TAXABLE NON-CASH AMANO*

Other

Thia

BaBertieaa__________ Parted

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74.65

2.93

15.27

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P«y Perted(040122-043022)

2022 SOC SECURITY UNITS: WAGES:

2022 SOC SECURITY UNITS: TAXES:

Thia Perled Year-te-Data

1.270.64

14,507.69

1,346.92

15,062.52

1,346.92

15,062.52

147,000.00

9,114.00

76.28-

554.83-

This Parted Year-te-Oate

132.061,868.51-

83.51-

933.88-

•SEE CONIISSIOR/INCENTIVE/AWARD

STATEMENT (S) FOR MME DETAIL

offiS av

Taxable Wafea Tawaary

Fed

Social security

Medicare

Year-te-Data

toot W io

s

I

Case 2:23-cv-01950-GMN-DJA

Document 78-1

Filed 04/29/25

Page 8 of 42

Case 2:23-cv-01950-(^ (p0|j^3pocument 26

Empi IO:

AT&T

TMOU

Period Befl/End:

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REGULAR

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NIGHT DIF REG IM

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ADO'L ADJUSTED OT PREM

Pay Period(050122-eS3122)

COMMISSION*

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Rate

Naera

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16.6250

8.3125

1.6625

1.6625

1.6625

73.53

2.92

2.48

15.58

0.72

1,222.44

24.27

4.12

25.90

1.20

0.60

ARSP BASIC 401K

Tax DodectlOM

FED

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Period

Year-ta Pate

123.02-

876.83-

Thia Period Yoer-te-tete

315.592,579.51137.021,276.68-

846.41

2022 SOC SECURITY UNITS: WAGES:

2022 SOC SECURITY UNITS: TAXES:

Thle period Year-te-Mta

2,066.92

19.717.93

2.209.94

20,594.76

2,209.94

20,594.76

147,000.00

9,114.00

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Case 2:23-cv-01950-GMN-DJA

Document 78-1

Filed 04/29/25

Page 9 of 42

Case 2:23-cv-01950-GM^fPocument 26

AMTOMIO GODWIN

8^ TOW IT 3307

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2022 SOC SECURITY LIMITS: MAGES:

2022 SOC SECURITY LIMITS: TAXES:

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—

Case 2:23-cv-01950-GMN-DJA

Document 78-1

Filed 04/29/25

Page 10 of 42

Case 2:23-cv-01950Empi ID;

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147,000.00

9,114.00

1,561.00-

Case 2:23-cv-01950-GMN-DJA

Document 32

Filed 05/10/24

1

UNITED STATES DISTRICT COURT

2

DISTRICT OF NEVADA

Page 1 of 6

3

ANTONIO GOODWIN,

4

5

Plaintiff,

vs.

6

AT&T,

)

)

Case No.: 2:23-cv-01950-GMN-DJA

)

ORDER DENYING MOTION FOR

JUDGMENT ON THE PLEADINGS

)

)

7

8

)

)

Defendant.

)

)

9

10

Pending before the Court is the Motion for Judgment on the Pleadings, (ECF No. 13),

11

filed by Defendant AT&T Corp. Pro se Plaintiff Antonio Goodwin filed a Motion to

12

Supplement the Records for the Time Period in Dispute, (ECF No. 26), which the Court

13

liberally construes1 as a response, and a second Response, (ECF No. 28), to which AT&T filed

14

a Reply, (ECF No. 30).

15

Also pending before the Court are Plaintiffs Motion Seeking Motion from Defendant,

16

(ECF No. 23), and Motion to Strike, (ECF No. 29), in addition to AT&T’s First and Second

17

Motions to Strike, (ECF Nos. 18, 27).

18

For the reasons discussed below, the Court DENIES AT&T’s Motion for Judgment on

19

the Pleadings and Second Motion to Strike.2 The Court further DENIES Plaintiffs Motion

20

21

1 A document filed pro se is to be liberally construed. See Erickson v. Pardus, 551 U.S. 89, 94 (2007).

22

23

24

25

2 AT&T’s Second Motion to Strike contends that Plaintiff’s Motion Seeking Motion, (ECF No. 23), and Motion

to Supplement the Records, (ECF No. 26), should be stricken because they are amended complaints filed in

violation of Fed. R. Civ. P. 15. The Court disagrees. Liberally construing the Motion Seeking Motion, it

appears Plaintiff is requesting discovery from AT&T to demonstrate it was his employer. Thus, while the Court

DENIES Plaintiffs Motion to the extent it seeks discovery, (Magistrate Judge Order, ECF No. 24), it declines to

strike this Motion from the docket. Next, the Court construes Motion to Supplement the Records for the Time

Period in Dispute as a response to AT&T’s Motion for Judgment on the Pleadings, not an attempt by Plaintiff to

file an amended complaint. Accordingly, AT&T’s Second Motion to Strike is DENIED.

Page 1 of 6

Case 2:23-cv-01950-GMN-DJA

Document 32

Filed 05/10/24

Page 2 of 6

1

Seeking Motion from Defendant3 and Motion to Strike.4 Finally, the Court GRANTS AT&T’s

2

First Motion to Strike5 and Plaintiff’s Motion to Supplement the Record for the Time Period in

3

Dispute.6

4

I.

BACKGROUND

5

This action arises from AT&T’s alleged discrimination and retaliation against its

6

employee, Plaintiff Antonio Goodwin. (See generally Am. Compl., ECF No. 10). AT&T filed

7

an Answer denying it ever employed. (Answer 2:19-26, ECF No. 12). AT&T’s denial is

8

predicated on an assertion by Paula M. Phillips, a Director-Legal Administrator for AT&T

9

Services, Inc., stating that she “conducted an exhaustive search of AT&T’s employment

10

records” and determined there were “no records of [Plaintiff] ever being employed by AT&T

11

12

13

3 As stated, the Court DENIES Plaintiffs Motion to the extent it seeks. (Magistrate Judge Order, ECF No. 24).

14

4 Plaintiff seeks to strike AT&T’s Response, (ECF No. 27), and requests the Court impose sanctions on AT&T

because it allegedly withheld discovery. (Pl.’s Mot. Strike at 3, ECF No. 29). Because the Court denies any

discovery request made by Plaintiff, it DENIES his Motion and declines to issue sanctions.

15

16

17

18

19

20

21

22

23

24

25

5 AT&T’s First Motion to Strike contends that Plaintiffs Affidavit, (ECF No. 15), should also be stricken

because it is an amended complaint filed in violation of Fed. R. Civ. P. 15. The Court agrees with AT&T that

liberally construing Plaintiffs Affidavit, it constitutes an amended complaint filed in violation of Rule 15. “A

party may amend its pleading once as a matter of course within: (A) 21 days after serving it, or (B) if the

pleading is one to which a responsive pleading is required, 21 days after service of a responsive pleading or 21

days after service of a motion under Rule 12(b), (e), or (I), whichever is earlier.” Fed. R. Civ. P. 15(a)(1).

Otherwise, “a party may amend its pleading only with the opposing party’s written consent or the court’s leave.”

Fed. R. Civ. P. 15(a)(2). Plaintiff has already filed an amended complaint as a matter of course, (Am. Compl.,

ECF No. 10), and this case is otherwise past the point where Plaintiff can amend without AT&T’s consent or the

Court’s leave. “When a party files an amended complaint without the right to do so, it is properly stricken by the

Court.” Wilkins v. Macober, No. 2:16-cv-0475, 2022 WL 18027822, at *2 (E.D. Cal. Dec. 30, 2022). Because

Plaintiff filed his Affidavit without proper authorization, the Court grants AT&T’s First Motion to Strike, (ECF

No. 18), and STRIKES the Affidavit from the docket.

6 As explained above, the Court construes this filing as a response to AT&T’s Motion for Judgment on the

Pleadings. Nevertheless, the Court does not consider any argument or evidence in this filing in resolving

AT&T’s Motion for Judgment on the Pleadings to the extent it introduces argument and evidence beyond that

contained in Plaintiffs pleadings. See Hal Roach Studios, Inc. v. Richard Feiner & Co. Inc., 896 F.2d 1542,

1550 (9th Cir. 1990) (holding that “judgment on the pleadings is improper when the district court goes beyond

the pleadings to resolve an issue”).

Page 2 of 6

Case 2:23-cv-01950-GMN-DJA

Document 32

Filed 05/10/24

Page 3 of 6

1

from January 2020 onward . . . either at AT&T’s headquarters or any other AT&T corporate

2

location.” (Paula Phillips Decl. Tf 6, Ex. A to Answer, ECF No. 12-1). AT&T then filed its

3

Motion for Judgment on the Pleadings, (ECF No. 13).

4

IL

LEGAL STANDARD

5

“After the pleadings are closed—but early enough not to delay trial—a party may move

6

for judgment on the pleadings.” Fed. R. Civ. P. 12(c). “[J]udgment on the pleadings is proper

7

‘when, taking all the allegations in the non-moving party’s pleadings as true, the moving party

8

is entitled to judgment as a matter of law.’” Ventress v. Japan Airlines, 486 F.3d 1111, 1114

9

(9th Cir. 2007) (citation omitted).

Motions for judgment on the pleadings pursuant to Fed. R. Civ. P. 12(c) are

10

11

“functionally identical” to motions to dismiss for failure to state a claim under Federal Rule of

12

Civil Procedure 12(b)(6). Dworkin v. Hustler Magazine Inc., 867 F.2d 1188, 1192 (9th Cir.

13

1989). Moreover, when reviewing a motion for judgment on the pleadings pursuant to Rule

14

12(c), a court “must accept all factual allegations in the complaint as true and construe them in

15

the light most favorable to the non-moving party.” Fleming v. Pickard, 581 F.3d 922, 925 (9th

16

Cir. 2009). The allegations of the nonmoving party must be accepted as true while any

17

allegations made by the moving party that have been denied or contradicted are assumed to be

18

false. MacDonald v. Grace Church Seattle, 457 F.3d 1079, 1081 (9th Cir. 2006).

19

III.

20

DISCUSSION

AT&T moves for judgment on Plaintiffs Title VII claims, arguing they fail as a matter of

21

law because “[AT&T] was never Plaintiffs employer” and “Title VII has no applicability

22

outside of the employer/employee relationship.”7 (Mot. J. Pleadings 4:14-17). AT&T’s

23

24

25

7 AT&T also contends the Court should grant its Motion for Judgment on the Pleadings under Local Rule 7-2(d)

because Plaintiff failed to file a timely response to its Motion. (Reply 3:24-4:9, ECF No. 30). However,

considering the fact that Plaintiff did file a response, albeit untimely, and because the Court disagrees with

AT&T’s underlying argument, it refrains from granting AT&T’s Motion on this basis.

Page 3 of 6

Case 2:23-cv-01950-GMN-DJA

Document 32

Filed 05/10/24

Page 4 of 6

1

argument is well taken, as Title VII only protects employees, not non-employees. Adcock v.

2

Chrysler Corp., 166 F.3d 1290, 1292 (9th Cir. 1999). Thus, Plaintiff is “entitled to the

3

protections of Title VII only if [ ]he is an employee” of AT&T. Murray v. Principal Fin.

4

Group, Inc., 613 F.3d 943, 944 (9th Cir. 2010). However, whether Plaintiff was employed by

5

AT&T is a factual dispute not suitable for resolution at this stage.

6

The existence of affirmative defenses usually precludes judgment on the pleadings. See

7

Gen. Conference Corp, of Seventh-Day Adventists v. Seventh-Day Adventist Cong. Church, 887

8

F.2d 228, 230 (9th Cir. 1989). However, where affirmative defenses raise only questions of

9

law, such affirmative defenses do not preclude judgment on the pleadings. See Unite Here

10

Local 19 v. Picayune Rancheria of Chukchansi Indians, 101 F. Supp. 3d 929, 934 (E.D. Cal.

11

2015) (citing 5C Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure §

12

1367 (3d ed. 2004)). “The motion for a judgment on the pleadings only has utility when all

13

material allegations of fact are admitted or not controverted in the pleadings and only questions

14

of law remain to be decided by the district court.” Id. If a defendant’s affirmative defenses

15

create material issues of fact, judgment on the pleadings is precluded. See Westport Ins. Corp,

16

v. N. California Relief, 76 F. Supp. 3d 869, 882-83 (N.D. Cal. 2014) (finding that the

17

defendant’s affirmative defenses failed to create a material issue of fact and therefore did not

18

preclude judgment on the pleadings).

19

The Court cannot find there are no material facts in dispute. AT&T’s affirmative

20

defense—denying that it ever employed Plaintiff or exercised control over the terms and

21

conditions of his employment—is not a legal assertion. See Bautista v. PR Gramercy Square

22

Condo., 642 F. Supp. 3d 411, 421 (S.D.N.Y. 2022) (“Determining whether an employment

23

relationship exists is a ‘fact-specific’ endeavor.”). Rather, it raises a contested factual issue, as

24

Plaintiffs Amended Complaint alleges he was employed by AT&T. (See generally Am.

25

Compl.). In this posture, it is not proper for the Court to “resolve potential conflicts between

Page 4 of 6

Case 2:23-cv-01950-GMN-DJA

Document 32

Filed 05/10/24

Page 5 of 6

1

the allegations in Plaintiffs [Amended] Complaint and an attachment to [AT&T]’s Answer

2

provided in conjunction with an [a]ffirmative [d]efense, and [AT&T] cites no case in which a

3

Court properly undertook such a task at this early stage of the litigation (without converting the

4

motion to one for summary judgment, which no party requests the Court to do here).” Affiliated

5

FMIns. Co. v. Hill Phoenix Inc., No. 22-cv-00450, 2023 WL 244494, at *2 (D. Ariz. Jan. 18,

6

2023). Accordingly, AT&T’s Motion is DENIED.

7

Considering Plaintiffs claims and filings, the Court finds that exceptional circumstances

8

exist justifying the appointment of counsel. To determine whether exceptional circumstances

9

exist warranting the appointment of counsel, a court must consider: (1) the likelihood of

10

success on the merits; and (2) the ability of the plaintiff to articulate their claims pro se in light

11

of the complexity of the legal issues involved. See Palmer v. Valdez, 560 F.3d 965, 970 (9th

12

Cir. 2009).

13

The Court has denied AT&T’s Motion for Judgment on the Pleadings. At this point,

14

Plaintiff has a likelihood of success on his claims. This case will now proceed to discovery and

15

then dispositive motions. To date, Plaintiffs filings have been disjointed and unclear. The

16

Court anticipates that Plaintiff will encounter challenges conducting discovery and articulating

17

his arguments at the summary judgment stage. Whether Plaintiff was employed by AT&T, and

18

if he was discriminated against in the course of his employment, are two issues of sufficient

19

complexity that the Court finds appointment of counsel is warranted.

20

IV.

21

22

CONCLUSION

IT IS HEREBY ORDERED that AT&T’s Motion for Judgment on the Pleadings,

(ECF No. 13), is DENIED.

23

IT IS FURTHER ORDERED that AT&T’s First Motion to Strike, (ECF No. 18), is

24

GRANTED. Plaintiffs Affidavit, (ECF No. 15), is HEREBY STRICKEN from the docket.

25

Page 5 of 6

Case 2:23-cv-01950-GMN-DJA

1

2

3

4

5

6

7

8

9

Document 32

Filed 05/10/24

Page 6 of 6

IT IS FURTHER ORDERED that AT&T’s Second Motion to Strike, (ECF No. 27), is

DENIED.

IT IS FURTHER ORDERED that Plaintiffs Motion Seeking Motion, (ECF No. 23),

is DENIED.

IT IS FURTHER ORDERED that Plaintiffs Motion to Supplement the Records for

the Time Period in Dispute, (ECF No. 26), is GRANTED.

IT IS FURTHER ORDERED that Plaintiffs Motion to Strike, (ECF No. 29), is

DENIED.

IT IS THEREFORE ORDERED that this case be referred to the Pro Bono Program for

10

appointment of counsel for the purposes identified herein, unless Plaintiff notifies the Court

11

that he does not desire appointment of counsel.

12

13

14

15

16

IT IS FURTHER ORDERED that Plaintiff shall have until June 8, 2024, to notify the

Court if he does not desire appointment of counsel.

IT IS FURTHER ORDERED that the Clerk of Court shall forward this Order to the

Pro Bono Liaison.

DATED this 9

day of May, 2024.

17

18

19

Gloria

United

20

21

22

23

24

25

Page 6 of 6

ict Judge

urt

1

Zachary P. Takes, Esq., (Nevada Bar #11293)

TAKOS LAW GROUP, LTD.

2

10785 West Twain Avenue, Suite 226

3 Las Vegas, Nevada 89135

Tel: (702) 658-1900

4

Email: zach@takoslaw.com

5

6

10

Stacey A. Campbell, (Colorado Bar #38378)

(Pro Hac Vice Application Pending)

Stacey@Campbell-Litigation.com

Campbell Litigation, P.C.

1410 N. High St.

Denver, Colorado 80218

Tel: (303) 536-1833 '

11

Attorneys for Defendant

7

8

9

12

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEVADA

13

14

15

16

17

18

19

ANTONIO GOODWIN,

Plaintiff,

Case No.: 2:23-cv-01950-GMN-DJA

DECLARATION OF PAULA M.

PHILLIPS IN SUPPORT OF

DEFENDANT’S ANSWER AND

AFFIRMATIVE DEFENSES

v.

AT&T,

Defendant.

20

21

22

DECLARATION

23

24 I, PAULA M. PHILLIPS, declare as follows:

25

1.

lam over the age of 18 and have personal knowledge of the matters set forth

26 in this Declaration, and am submitting this Declaration in support of Defendant AT&T

27

28

1

nciorAU/TNi nnnnm

1

Corp.’s1 (“AT&T’s”) Answer to Plaintiff Antonio Goodwin’s January 23, 2024 amended

2 Complaint for Employment Discrimination in the above-referenced case.

3

2.

If called as a witness to testify, I could and would do so truthfully and

4 competently regarding the subject matter of this Declaration.

5

3.

lam employed by AT&T Services, Inc. as Director-Legal Administrator and

6 I have worked for AT&T Services, Inc. since 2007.

7

4.

AT&T is a global telecommunications company headquartered at One AT&T

8 Way, Bedminster, New Jersey, 07921-0752, with multiple subsidiaries within its global

9 family of companies. Its parent company, AT&T Inc., is a publicly traded holding

10

11

company and located at Whitacre Tower, 208 S. Akard Street, Dallas, Texas, 75202.

5.

Per the Complaint, Mr. Goodwin alleges that AT&T was his employer and

12 has asserted that AT&T violated Title VII of the Civil Rights Act of 1964 (“Title VII”) by

13 discriminating against him based on race, color, and sex, and also retaliated against him in

14 violation of Title VII.

15

6.

In my role as a Director-Legal Administrator for AT&T Services, Inc., I have

16 access to and have conducted an exhaustive search of AT&T’s employment records, and

17 there are no records of Antonio Goodwin ever being employed by AT&T from January

18

2022 onward (the date range in which Mr. Goodwin alleges he was employed by AT&T

19 and was discriminated against by AT&T), either at AT&T’s headquarters or any other

20 AT&T corporate locations.

21

22

[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

23

24

25

26

27

1 Plaintiff served his Complaint on AT&T Corp., which is not his employer, and this Declaration is

28 given

on behalf of AT&T Corp., as part of its Answer to the Complaint.

2

nrvriruvrKT nnnnno

1

I declare under penalty of perjury under the laws of the United States of

2 America that the foregoing is true and correct.

3

4

Executed on

Zlfi, 2024.

5

PAPULA M. PHILLIPS----Director-Legal Administrator

AT&T Services, Inc.

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

3

/^orYTY\vr\T nnnnm

ADDITIONAL RACIAL DISCRIMINATION AND HOSTILE WORK ENVIRONMENT EVIDENCE

(TRIGGER WARNING: DYLAN ADAMS AT&T MANAGER RACIAL LANGUAGE AND

CONTENT)

Appellant respectfully provides the following evidence, which contains explicit language

and descriptions relevant to allegations of racial discrimination, hostile work

environment, and workplace misconduct. This content is included verbatim for

evidentiary purposes only and reflects statements, conduct, and context experienced

and reported by Appellant.

Appellant contends that the lower court failed to properly address this overwhelming

evidence.

DYLAN ADAMS AT&T MANAGER - Racial Discrimination Evidence

PLEASE PROVIDE YES DYLAN ADAMS AT&T MANAGER SINGING NIGGER LYNCHING

SONGS WALKING BEHIND MR ANTONIO GOODWIN IN THE AT&T INVENTORY ROOM

• The term “woke” has come to include a sense of being aware of social and racial

discrimination and injustice?

PLEASE PROVIDE YES • THE TERM (“WOKE”)/ STAY WOKE IS REFERRING TO NIGGERS

CREEPING IN THE STAY WOKE VIDEO

PLEASE PROVIDE YES

• The term “STAY WOKE” DYLAN ADAMS SINGING NIGGER LYNCHING SONGS WHILE

WALKNING BEHIND ANTONIO GOODWIN IN THE AT&T INVENTORY ROOM. THE SONG IS

TALKING ABOUT AND MEANS NIGGERS CREEPING IN THE GET OUT MOVIE AND

VIDEO: THE MEANING OF THE STAY WOKE LYRICS IS BELOW THE GET OUT MOVIE

AND VIDEO SHOW AND MEAN NIGGERS BEING CHASE, HUNTED, LYNCHED AND

KILLED IN THE GET OUT MOVIE. THE STAY WOKE LYRICS IS BELOW? YES IT HAPPEN

TO ANTONIO GOODWIN MANY OCCASIONS UNDER PENALTY AND PERJURY

But stay woke (stay woke, stay woke), niggas creepin’ (they be creepin’)

They gon’ find you (they gon’ find you)

Gon’ catch you sleepin’, ooh (gon’ catch you sleepin’, put your hands up now, baby)

Now stay woke, niggas creepin’

Now, don’t you close your eyes, but stay woke (ooh-ah)

Niggas creepin’ (they gon

This version adds your new evidence at the bottom while preserving the rest.

Trigger Warning

E. PLEASE PROVIDE MARCUS CARTER DID DEREK ZAMAGNI THE

AT&T CORPORATE MANAGER WRITE YOU UP FOR SEXUAL HARASSMENT AND

SEXUALLY HARASSING MR. ANTONIO GOODWIN AT THE 6436 N DECATUR

BLVD LAS VEGAS NV , 89131 LOCATION? YES

PLEASE PROVIDE YES MARCUS CARTER DID YOU SAY YOU CAN TURN

ANY MARRIED MAN INTO A GAY MAN? YES IT HAPPEN TO ANTONIO GOODWIN UNDER

PENALTY AND PERJURY

PLEASE PROVIDE YES MARCUS CARTER DID YOU SAY YOU CAN TURN

ANY MARRIED MAN INTO A GAY MAN WHILE STANDING BESIDE MR ANTONIO

GOODWIN? YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE YES MARCUS CARTER IS MR. ANTONIO GOODWIN

MARRIED?

YES

PLEASE PROVIDE YES MARCUS CARTER DID YOU MASSAGE SERGIO

HENRIQUEZ WHILE SAYING HEY BIG DADDY , GIVE IT TO ME BIG DADDY , AT

THE AT&T 6436 N DECATUR BLVD LAS VEGAS NV , 89131 LOCATION

PLEASE PROVIDE YES MARCUS CARTER DID YOU MASSAGE MARCOS

DIAZ WHILE SAYING HOW DOES THAT FEEL BABY GIRL, WHICH MARCOS DIAZ

IS A MAN AT AT&T?

YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY AND

PERJURY

(WHICH THIS INCIDENT HAPPEN AT THE AT&T 6436 N

DECATUR BLVD LAS VEGAS NV , 89131 LOCATION?

YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID DA VION LYNCH AT&T

MANAGER WALK IN ON YOU MESSAGING MARCOS DIAZ AND DAVION LYNCH

SAID WHAT IS GOING ON HERE? YES IT HAPPEN TO ANTONIO GOODWIN UNDER

PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID YOU EVER SAY YOU HAVE

DICK ON YOUR BREATHE AT THE AT&T 6436 N DECATUR LOCATION? YES IT HAPPEN

TO ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID YOU REPEATEDLY ASK MR.

ANTONIO GOODWIN TO DRIVE YOU HOME?

YES IT HAPPEN TO ANTONIO GOODWIN

UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER WAS YOU SHAKING THE

BATHROOM DOOR AND KNOB TRYING TO GET IN THE BATHROOM WHILE MR

ANTONIO GOODWIN WAS INSIDE USING THE BATHROOM AT THE 6436 N

DECATUR BLVD LAS VEGAS NV , 89131 LOCATION? YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER WAS YOU STANDING OUTSIDE

THE BATHROOM DOOR CLOSE BETWEEN THE BATHROOM DOOR AND BREAK

ROOM WHEN MR.ANTONIO GOODWIN CAME OUT THE BATHROOM? YES IT HAPPEN

TO ANTONIO GOODWIN UNDER PENALTY AND PERJURY

AT THE 6436 N DECATUR BLVD LAS VEGAS NV , 89131 LOCATION? PLEASE PROVIDE

MARCUS CARTER DID YOU LUST OVER AT&T

MALE CUSTOMERS BUTTS?

YES IT HAPPEN TO ANTONIO GOODWIN UNDER

PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID YOU LUST OVER AT&T

MALE CUSTOMERS BUTTS IN FRONT OF MR ANTONIO GOODWIN?

WHILE THE MALE AT&T CUSTOMERS WAS SHOPPING FOR AT&T

PHONES AND WHILE MR ANTONIO GOODWIN WAS STANDING BESIDE YOU? AT

THE AT&T 6436 N DECATUR BLVD LAS VEGAS NV , 89131 LOCATION? YES IT HAPPEN

TO ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID YOU TELL JAZMIN CHA VEZ

SHE WOULD BE A PERFECT 9 IF SHE HAD HER TITIES OUT DURING AT&T

BUSINESS HOURS?

YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY AND

PERJURY

PLEASE PROVIDE MARCUS CARTER DID YOU TELL MR ANTONIO

GOODWIN TO COME TO THE BACK OF THE INVENTORY ROOM TO COUNT

MONEY WHILE YOU STOOD CLOSE BEHIND MR ANTONIO GOODWIN WHILE

YOU REACH ACROSS MR. ANTONIO GOODWIN BODY TO GRAB AND COUNT

MONEY OUT OF THE CASH REGISTER? YES IT HAPPEN TO ANTONIO GOODWIN

UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER .THE AT&T POLICY IS TO COUNT

THE AT&T CASH REGISTER MONEY IN THE BREAK ROOM AND NOT COUNT THE

CASH REGISTER IN THE BACK OF THE INVENTORY ROOM? YES

PLEASE PROVIDE MARCUS CARTER DID YOU EVER STARE AT MR

ANTONIO GOODWIN? YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY AND

PERJURY

PLEASE PROVIDE MARCUS CARTER WHEN MARCIS DIAZ WILL NOT

SHOW UP FOR WORK ON HIS SCHEDULE AT&T SHIFT DID DYLAN ADAMS ASK

YOU TO CALL MARCOS DIAZ BECAUSE HE DID NOT ANSWER HIS PHONE WHEN

DYLAN ADAMS THE AT&T MANAGER CALLED MARCOS DAIZ? YES

PLEASE PROVIDE MARCUS CARTER DID MARCOS DIAZ EVER NOT

CALL AND NOT SHOW UP FOR WORK AT AT&T? YES IT HAPPEN ANTONIO GOODWIN

UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID YOU EVER HAVE TO CALL

AND TEXT MARCOS DIAZ TO REMIND HIM TO COME INTO WORK AT AT&T? YES

PLEASE PROVIDE YES MARCUS CARTER IS AT&T POLICY IF YOU DO NOT CALL OR

SHOW UP FOR WORK IT’S IMMEDIATE TERMINATION? YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DURING THE AT&T

PROBATIONARY PERIOD IF YOU DO NOT CALL OR SHOW UP FOR WORK IT’S

IMMEDIATE TERMINATION ACCORDING TO AT&T POLICY? YES IT HAPPEN ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID YOU TELL ELIZABETH

JIMENEZ, JAZMIN CHA VEZ AND MORE WHO YOU WOULD HA VE SEX WITH AT

THE 6436 LOCATION. THIS WAS REGARDING THE SELECTION OF YOUR MALE

CO-WORKERS AT AT&T THAT YOU WOULD HAVE SEX WITH? YES IT HAPPEN TO

ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER WAS YOU SINGING PUSSY TALK

BY CITY GIRLS DURING AT&T BUSINESS HOURS? YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID YOU PLAY THE CITY GIRLS

PUSSY IS TALK SONG OVER THE AT&T LOUD SPEAKER? YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID DYLAN ADAMS OR DA VION

LYNCH STOP YOU FROM PLAYING THE CITY GIRLS PUSSY TALK SONG OVER

THE AT&T LOUD SPEAKER DURING AT&T BUSINESS HOURS? YES IT HAPPEN TO

ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE YES MARCUS CARTER DID DYLAN ADAMS, DAVION

LYNCH AND ALL OF YOUR AT&T CO WORKERS WATCH YOU PLAY , DANCE

SENSUAL, AND SING THE CITY GIRLS PUSSY TALK SONG AT THE AT&T 6436 N

DECATUR BLVD LAS VEGAS NV , 89131 LOCATION? DURING BUSINESS HOURS

YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE MARCUS CARTER DID YOU PLAY , DANCE SENUAL

AND SING THE CITY GIRLS PUSSY TALK LYRICS BELOW? AT THE 6436 N

DECATUR BLVD LAS VEGAS NV , 89131 LOCATION

Including results for CITY GIRLS PUSSY TALK LYRICS.

Do you want results only for CITY GIRLS PUSSY TAAK LYRICS? YES IT HAPPEN TO

ANTONIO GOODWIN UNDER PENALTY AND PERJURY

Pussy Talk (feat Doja Cat)

Song by

City Girls

Southside on the Track, yeah

Mm, mm, mm, mm (ayy, ayy, ayy, ayy)

Look, boyBoy, this pussy talk English, Spanish and French (hello)

Boy, this pussy talk Euros, Dollars and Yens (oww)

Boy, this pussy talk Bentleys, Rovers and Benz

Boy, this pussy fly private to islands, to M's

Boy, this pussy talk Birkin, Gucci, Chanel (oww)

Boy, this pussy talk Louis, Pucci, YSL (YSL)

Boy, this pussy make movies, wetter than a whale (hahaha)

Boy, this pussy be choosing, draft, NFL (ching-ching)

Don't nothin' but this cash make this pussy talk (ayy-ayy)

Don't nothin' but a bag make this pussy talk (ayy)

Don't nothin' but this cash make this pussy talk (oww)

Don't nothin' but a bag make this pussy talk

Ayy, look, this pussy extort these niggas

Pussy be like, "Can you afford me, nigga?"

Broke niggas in my face, pussy ignore these niggas

For the bag, pussy speak poetry, nigga

Boy, this pussy from the hood (ayy, ayy, ayy)

This pussy from the projects

This pussy so ghetto

This pussy speak ebonies (oww)

This pussy snatched back, playin' tug of war

Turn a nigga gang-gang, he gon' go to war (gang-gang)

You want this pussy real bad?

Say "pretty please" (please)

Cop me baguetties, make my wrist freeze

Got niggas overseas goin' crazy 'bout me (loco)

Jamaican, Cuban, French, Japanese

Boy, this pussy talk English, Spanish and French (hello)

Boy, this pussy talk Euros, Dollars and Yens (oww)

Boy, this pussy talk Bentleys, Rovers and Benz

Boy, this pussy fly private to islands, to M's

Boy, this pussy talk Birkin, Gucci, Chanel (oww)

Boy, this pussy talk Louis, Pucci, YSL (YSL)

Boy, this pussy make movies, wetter than a whale (hahaha)

Boy, this pussy be choosing, draft, NFL (ching-ching)

Don't nothin' but this cash make this pussy talk (talk)

Don't nothin' but a bag make this pussy talk (pussy talk)

Don't nothin' but this cash make this pussy talk (pussy talk)

Don't nothin' but a bag make this pussy talk (pussy talk)

Pussy talented, it do cartwheels

And he pay 'cause he like how that part feel (yuh)

Pussy give speeches, heartfelt

Said the pussy really talk like it Garfield (it do)

Said I got a way with my lipsPokerface, daddy, you know I don't play with my chips (mmm)

Play with my food, play with my tits

No game so the money make me play with my clit (ah!)

Talk out your act, you gon' get that cat

If that shit lookin' fat, throw another stack

She break her back, you know, put it on the map

Wanna make that shit talk? You should prolly bring a bag (hahaha)

Boy, this pussy talk English, Spanish and French (hello)

Boy, this pussy talk Euros, Dollars and Yens (oww)

Boy, this pussy talk Bentleys, Rovers and Benz

Boy, this pussy fly private to islands, to M's

Boy, this pussy talk Birkin, Gucci, Chanel (oww)

Boy, this pussy talk Louis, Pucci, YSL (YSL)

Boy, this pussy make movies, wetter than a whale (hahaha)

Boy, this pussy be choosing, draft, NFL (ching-ching)

Don't nothin' but this cash make this pussy talk (talk)

Don't nothin' but a bag make this pussy talk (pussy talk)

Don't nothin' but this cash make this pussy talk (pussy talk)

Don't nothin' but a bag make this pussy talk (pussy talk)

Uh, boy, this pussy bilingual (hola)

Anti-social, this pussy don't mingle (period)

Don't go broke or this pussy going single (haha)

"Ho, ho, ho", pussy turn him Kris Kringle

I bet your nigga disappear if this pussy speak (yup)

Hoe, we can't be friends if your pussy cheap (nah)

Spend a million with this pussy, you could get a week (ah)

I ain't talkin' 'bout dinner when I tell him "eat"

Uh, boy, this pussy worth a felony (yup)

This pussy goin' places pussy niggas never be

My nigga told me, "This pussy made a better me"

I feed a dog ass nigga, pussy Pedigree

Boy, this pussy talk English, Spanish and French (hello)

Boy, this pussy talk Euros, Dollars and Yens (oww)

Boy, this pussy talk Bentleys, Rovers and Benz

Boy, this pussy fly private to islands, to M's

Boy, this pussy talk Birkin, Gucci, Chanel (oww)

Boy, this pussy talk Louis, Pucci, YSL (YSL)

Boy, this pussy make movies, wetter than a whale (hahaha)

Boy, this pussy be choosing, draft, NFL (ching-ching)

Don't nothin' but this cash make this pussy talk (talk)

Don't nothin' but a bag make this pussy talk (pussy talk)

Don't nothin' but this cash make this pussy talk (pussy talk)Don't nothin' but a bag make this

pussy talk (pussy talk)

ADDITIONAL RACIAL DISCRIMINATION AND HOSTILE WORK ENVIRONMENT EVIDENCE

PLEASE PROVIDE IF THE FOLLOWING AT&T EMPLOYEE ANTONIO

GOODWIN CAUGHT DYLAN ADAMS AND DAVION LYNCH BREAKING LABOR

LAWS IN THE AT&T UNION MEETING ON MAY 5, 2022 CONDUCTED BY CARLA

CAMPOS ORTIZ AT&T REP AND ALBERTO GONZALEZ AT&T VICE PRESIDENT.? YES

PLEASE PROVIDE YES OR NO WHEN I SPOKE UP REGARDING DYLAN ADAMS

BREAKING LABOR LAWS. HE IMMEDIATELY WROTE UP MR. ANTONIO GOODWIN

FOR POOR JOB PERFORMANCE RIGHT AFTER THE AT&T UNION MEETING WAS

OVER WITH CARLA CAMPOS ORTIZ THE AT&T UNION REP AND ALBERTO

GONZALEZ THE AT&T UNION VICE PRESIDENT ON MAY 5, 2022? YES

PLEASE PROVIDE IF CARLA CAMPOS AT&T UNION REP STATED TO

MR. ANTONIO GOODWIN ON MAY 5, 2022 THAT DYLAN ADAMS RETALIATED

AGAINST HIM AND CARLA CAMPOS ORTIZ TOLD MR.ANTONIO GOODWIN TO

IMMEDIATELY FILE THE RETALIATION HARASSMENT CASE AGAINST DYLAN

ADAMS ON MAY 5, 2022? YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY

AND PERJURY

PLEASE PROVIDE IF AT&T EMPLOYEE CAELA CAMPOS ORTIZ TOLD

ANTONIO GOODWIN THIS WAS RETALIATION DONE BY DYLAN ADANS AND

DAVION LYNCH BECAUSE I CAUGHT THOSE GUYS BREAKING LABOR LAWS

AND REPORTED DYLAN ADAMS AND DAVION LYNCH TO THE AT&T UNION REP

CARLA CAMPOS AND THE AT&T UNION VICE PRESIDENT ALBERTO GONZALEZ

ON MAY 5, 2022? YES IT HAPPEN TO ANTONIO GOODWIN

PLEASE PROVIDE IF AT&T EMPLOYEE ANTONIO GOODWIN DID NOT

RECEIVED A PROPER VERBAL WARNING FROM DYLAN ADAMS THE AT&T

MANAGER ON JUNE 18, 2022?. YES IT HAPPEN TO ANTONIO GOODWIN UNDER

PENALTY AND PERJURY

PLEASE PROVIDE IF OTHER AT&T EMPLOYEES RECEIVE A VERBAL

WARNING BEFORE THEY RECEIVED A FINAL WRITTEN WARNING IN JUNE OF

2022 THRU AUGUST OF 2022? ANTONIO GOODWIN NEVER RECEIVED A VERBAL

WARNING UNDER PENALTY AND PERJURY

PLEASE PROVIDE DYLAN ADAMS FIRST EXCUSE FOR NOT GIVING

MR.ANTONIO GOODWIN A VERBAL WARNING ON JUNE 18, 2022 WAS HIS

COMPUTER WAS NOT WORKING PROPERLY? YES IT HAPPEN TO ANTONIO GOODWIN

UNDER PENALTY AND PERJURY

PLEASE PROVIDE IF DYLAN ADAMS 2ND EXCUSE FOR NOT GIVING

MR. ANTONIO GOODWINCA VERBAL WARNING WAS HE DID NOT SEE MR.

GOODWIN AT WORK FROM JUNE 18, 2022 THRU JULY 6, 2022

PLEASE PROVIDE YES OR NO IF DYLAN ADAMS 3RD EXCUSE FOR NOT GIVING

MR. ANTONIO GOODWIN A VERBAL WARNING WAS HE DID NOT WANT TO TEXT

MR.GOODWIN REGARDING THIS SERIOUS ATTENDANCE MATTER ON JUNE 18,

2022 OVER THE PHONE? YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY

AND PERJURY

PLEASE PROVIDE IF ON JULY 7„ 2022 MR. ANTONIO GOODWIN

RECEIVE A FINAL WRITTEN NOTICE REGARDING HIS ATTENDANCE?

PLEASE PROVIDE YES OR NO IF MR. ANTONIO GOODWIN SHOULD HAVE

RECEIVED A VERBAL WARNING ON JUNE 18, 2022 THRU JULY 6, 2022, WHICH IS

AT&T POLICY AND PROTOCOL? YES IT HAPPEN TO ANTONIO GOODWIN UNDER

PENALTY AND PERJURY

PLEASE PROVIDE IF MR. ANTONIO GOODWIN RECEIVED THE FINAL

WRITTEN WARNING ON JULY 15, 2022. ANTONIO GOODWIN NEVER RECEIVED A

VERBAL WARING

PLEASE PROVIDE IF AT&T GAVE MR. ANTONIO GOODWIN 2 WEEKS

OF VACATION TIME OFF 2 TO 5 DAYS AFTER AT&T ISSUED MR. GOODWIN THE

FINAL WRITTEN WARNING ON JULY 15, 2022 FOR ATTENDANCE.

PLEASE PROVIDE AT&T EMPLOYEE MARCOS DIAZ WENT DAYS

AND WEEKS WITHOUT CALLING , INTO WORK AT AT&T OR TEXTINGS AT&T

MANAGERS TO LET THEM KNOW HE WILL NOT BE COMING INTO WORK

DURING THE AT&T, PROBATION PERIOD WHICH IS IMMEDIATE TERMINATION

ACCORDING TO AT&T POLICY? MARCOS DIAZ DID NOT GET TERMINATED DYLAN

ADAMS NEVER WROTE MARCOS DIAZ UP. NOTHING HAPPEN, HOWEVER ANTONIO

GOODWIN CALL IN WORK AND SPOKE WITH DYLAN ADAMS REGARDING HIS WIFE

LIFE THREATENING CONDITION AS WELL AS PROVIDED A SIGNED DOCTOR LETTER

REGARDING MY WIFE LIFE THREATENING CONDITION HOWEVER DYLAN ADAMS

SERVE ME A FINAL WRITTEN WARNING THIS HAPPEN TO ANTONIO GOODWIN UNDER

PENALTY AND PERJURY. THIS IS WITHOUT A REASONABLE DOUBT RACIAL

DISCRIMINATIONS

PLEASE PROVIDE YES OR NO IF AT&T EMPLOYEE ANTONIO GOODWIN IN

FEBRUARY, MARCH, APRIL AND MAY WAS:

VOTED EMPLOYEE OF THE MONTH MARCH/ APRIL OF 2022?

BECAME A EXPERT, IN CRU, BUSINESS SALES FEBRUARY/MARCH/APRIL OF

2022,

BECAME A EXPERT IN FIRST NET SALES IN FEBRUARY/MARCH/APRIL OF 2022,

,#1 IN THE DISTRICT IN INSURANCE PROTECTION SALES IN

FEBRUARY/MARCH/APRIL OF 2022,

PLEASE PROVIDE IF ANGEL THE DISTRICT MANAGER IN FEBRUARY

MARCH/APRIL OF 2022 APPOINTMENT ANTONIO GOODWIN THE TEAM LEADER

FOR AT&T CRU BUSINESS SALES TEAM TO MENTOR HIS AT&T CO. WORKERS AT

THE 6436 N DECATUR BLVD, LAS VEGAS NV 89131 LOCATION; YES

PLEASE PROVIDE IF AT&T EMPLOYEE ANTONIO GOODWIN IN

FEBRUARY/MARCH/APRIL WAS:THE ONLY INSIDE SALESPERSON THAT HAD

SPECIAL PERMISSION FROM ANGEL THE DISTRICT MANAGER TO CLOSE

BUSINESS DEALS OUTSIDE OF THE 6436 N DECATUR BLVD OFFICE LOCATION

OFFICE WHICH MEANS I WAS THE ONLY SALESPERSON THAT HAD SPECIAL

AUTHORIZATIONS TO TRAVEL TO DIFFERENT COMPANIES/CORPORATIONS

LOCATIONS TO CLOSE AT&T CRU BUSINESS DEALS? YES

PLEASE PROVIDE IF THE FOLLOWING AT&T EMPLOYEE DYLAN

ADAMS INSTRUCTED ME ANTONIO GOODWIN ON MANY OCCASION THAT I

ANTONIO GOODWIN HAD TO ASK WHITE MARCOS DIAZ WITH ZERO EXPERIENCE TO

OPEN THE AT&T INVENTORY ROOM DOOR BEFORE I ANTONIO GOING WAS ALLOW TO

ENTER?. YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE IF DYLAN ADAMS WOULD GIVE WHITE MARCOS DIAZ WITH ZERO

EXPERIENCE

THE SECURITY CODE FOR THE AT&T INVENTORY ROOM DOOR ON LATE

EVENING AND NIGHT SHIFTS AND NOT MR.ANTONIO GOODWIN WITH 20 YEARS OF

B2B MANAGEMENT EXPERIENCE AND #1 IN CRU SALES AND FIRST NET SALES IN THE

AT&T COMPANY

PLEASE PROVIDE IF I WOULD EXPLAIN TO MARCOS DIAZ, DYLAN

ADAMS, DAVION LYNCH AND DEREK ZAMNGNI THAT MARCOS DIAZ WAS

HIRED AFTER ME ANTONIO GOODWIN WITH FAR LESS EXPERIENCE THAN ME

ANTONIO GOODWIN HOWEVER I HAD TO ASK MARCOS TO OPEN THE

INVENTORY DOOR FOR ME BEFORE ENTERING? YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE IF I SHARED MY QUALIFICATION WITH MARCOS

DIAZ, DYLAN ADAM, CARLA CAMPOS ORTIZ THAT I WAS A SENIOR ACCOUNT

EXECUTIVE FOR VERIZON AND NEXTEL WHICH I HANDLE CORPORATE

BUSINESS TO BUSINESS AND GOVERNMENT CONTRACTS AS WELL AS MENTOR

OVER 100 SALES REP HOWEVER I STILL HAD TO ASK MAROCS DAIZ TO OPEN

THE AT&T INVENTORY DOOR BEFORE ENTERING? YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE IF I WOULD SHARE WITH MARCOS DIAZ, CARLA

CAMPOS ORTIZ, MY QUALIFICATIONS AND ACCOLADES I CURRENT HAD WITH

AT&T BECAUSE MARCOS DIAZ HAD FAR LESS EXPERIENCE AND

QUALIFICATIONS THAN ME ANTONIO GOODWIN AND I STILL HAD TO ASK MARCOS

DIAZ TO OPEN THE EASY AT&T INVENTORY SECURITY DOOR, YES IT HAPPEN TO

ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE IF I ANTONIO GOODWIN WAS INSTRUCTED BY

DYLAN ADAMS TO ASK MARCOS DIAZ TO OPEN THE EXTREMELY SIMPLE AND

EASY SECURITY CODE AT&T INVENTORY ROOM DOOR ON MANY OCCASIONS

AND I ANTONIO GOODWIN WAS NOT ALLOWED TO HAVE THE EASY 4 DIGIT

SECURITY CODE FOR THE AT&T INVENTORY ROOM WHICH WAS INSTRUCTED

BY DYLAN ADAMS?. YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY AND

PERJURY

PLEASE PROVIDE IF DYLAN ADAMS REFUSE TO TRAIN ME ON THE

COMPUTER, IPADS, AND KIOS I ANTONIO GOODWIN WAS INSTRUCTED BY

DYLAN ADAMS TO DUMP TRASH, CLEAN THE BATHROOM, CLEAN THE BREAK

ROOM,, WINDEX AND CLEAN TABLES AND THE FRONT STORE WINDOWS AND

MORE EVERY NIGHT

PLEASE PROVIDE DYLAN ADAMS REFUSE TO TRAIN ME ANTONIO

GOODWIN ON THE KIOS, COMPUTER AND IPADS AND DYLAN KNEW I WAS A

SENIOR B2B EXECUTIVE THAT HANDLE CORPORATE AND GOVERNMENT

CONTRACTS WITH EXTREMELY HIGH QUALIFICATIONS? YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE DYLAN ADAMS REFUSE TO TRAIN ME ANTONIO GOODWIN

GOODWIN FROM MARCH OF 2022 THRU AUGUST 4, 2022 WHICH I ANTONIO

GOODWIN REPORTED THIS SERIOUS RACIAL DISCRIMINATION .INCIDENTS TO

DEREK ZAMAGNI AT&T CORPORATE HR MANAGER. ( WHICH IS WELL

DOCUMENTED OF ME REPEATEDLY BEGGING DYLAN ADAMS TO TRAIN

ME)

PLEASE PROVIDE MR.ANTONIO GOODWIN AT&T ACCOLADES IS

BELOW, FOR HIS PERFORMANCES IN FEBRUARY, MARCH, APRIL AND MAY OF

2022

VOTED EMPLOYEE OF THE MONTH BECAME A EXPERT, IN CRU, BUSINESS

SALES ACCOMPLISH IN 3 MONTHS WHICH IS A 12 MONTH GOAL,

BECAME A EXPERT IN FIRST NET SALES ACCOMPLISH IN 3 MONTHS WHICH IS

A 12 MONTH GOAL,

,#1 IN THE DISTRICT IN INSURANCE PROTECTION SALES,

CLOSING 20 TO 80 CRU BUSINESS SALES IN 1 MONTH IN FEBRUARY,, MARCH,

APRIL, MAY, JUNE AND JULY OF 2022

YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE IF AT&T UNION REP EMPLOYEE CARLA CAMPOS

ORTIZ TOLD ME ANTONIO GOODWIN TO FILE A HARASSMENT/SEXUAL HARASSMENT

REPORT ON DYLAN ADAMS FOR WALKING EXTREMELY CLOSE

BEHIND ME ANTNIO GOODWIN ON MAY 13, 2022. YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE IF AT&T UNION REP CARLA CAMPOS ORTIZ TOLD

MR. ANTONIO GOODWIN ON MAY 17, 2022. THAT DYLAN ADAMS WROTE HIM UP

FOR POOR JOB PERFORMANCES ON MARCH 4, 2022 AND APRIL 24, 2022. CARLA

CAMPOS ORTIZ CLEARLY STATED THIS WAS A MONTHLY ACTION PLAN AND IT

WAS ONLY GOAL SETTING WITH JULIO MARTINEZ MY PREVIOUS AT&T

MANAGER WHICH WAS NOT FOR POOR JOB PERFORMANCE. YES IT HAPPEN TO

ANTONIO GOODWIN UNDER PENALTY AND PERJURY

PLEASE PROVIDE IF THIS WAS A ILLEGAL WRITE UP ON MAY 17,

2022 DONE BY DYLAN ADAMS AND THE WRITE UP WAS NEVER REMOVED

FROM MY RECORDS FROM MAY 17, 2022 TO AUGUST 4, 2022 (I HAVE THE TEXT

MESSAGES TO PROVE IT?). YES IT HAPPEN TO ANTONIO GOODWIN UNDER PENALTY

AND PERJURY

PLEASE PROVIDE IF AT&T MANAGER DYLAN ADAMS ALLOWED

MARCUS CARTER TO PERFORM SEXUAL MASSAGES ON SERGIO HENRIQUEZ &

MARCOS DIAZ DAILY WHILE SAYING HEY BIG DADDY TO SERGIO HENRIQUEZ

AND CALLING MARCOS DIAZ BABY GIRL WHILE MASSAGING HIM,AS WELL AS

PROVIDE YES OR NO IF MARCUS CARTER WAS ALLOWED TO SING AND PLAY CITY

GIRLS PUSSY TALK LYRICS AND SONG DURING BUSINESS HOURS OVER THE

AT&T LOUD SPEAKER SO EVERYONE COULD HERE THE PUSY TALK SONG AND

LYRICS? (2ND WITNESS DAVION LYNCH AT&T MANAGER) YES IT HAPPEN TO ANTONIO

GOODWIN UNDER PENALTY AND PERJURY

1

2

UNITED STATES COURT OF APPEALS

3

FOR THE NINTH CIRCUIT

4

5

6

7

ANTONIO GOODWIN,

Ninth Circuit Case No. 26-927

8

Plaintiff,

9

10

v.

AT&T,

MOTION TO RECALL THE MANDATE

BASED ON NEWLY DISCOVERED 63

AUTHENTIC

AT&T

EMPLOYEE

DOCUMENTS SENT DIRECTLY FROM

AT&T TO THE EEOC,

11

Defendant..

12

13

14

15

16

17

18

19

20

21

1

1

MOTION TO RECALL THE MANDATE BASED ON NEWLY DISCOVERED 63 AUTHENTIC

AT&T EMPLOYEE DOCUMENTS SENT DIRECTLY FROM AT&T TO THE EEOC, MATERIAL

2

3

CONTRADICTION OF PAMELA M. PHILLIPS’ DECLARATION, FIFTH AMENDMENT DUE

PROCESS VIOLATIONS, SANCTIONS IMPOSED BY MAGISTRATE JUDGE DANIEL J.

ALBREGTS AND DISTRICT JUDGE GLORIA M. NAVARRO, DISCOVERY CUT-OFF

4

VIOLATIONS,

AND

REQUEST FOR SPECIFIC

WRITTEN

FINDINGS

BY JUDGES

FRIEDLAND, R. NELSON, AND BADE

5

6

7

8

9

Plaintiff-Appellant Antonio Goodwin, proceeding pro se, respectfully moves this Court to

recall the mandate in Ninth Circuit Case No. 26-927.

Plaintiff respectfully submits that extraordinary circumstances exist because Plaintiff has

now located and possesses 63 authentic AT&T employee documents sent directly from

AT&T to the Equal Employment Opportunity Commission (“EEOC”). These documents

10

include Plaintiff Antonio Goodwin’s AT&T Mobility LLC employee history, AT&T employee

number, name, passcode, AT&T write-ups, AT&T coaching records, AT&T response

11

12

materials sent directly to the EEOC, and AT&T employment-related documents connected

to AT&T Mobility LLC, AT&T, AT&T Inc., and AT&T Corp.

13

These 63 AT&T-generated employee documents directly contradict Pamela M. Phillips’

14

declaration stating that there were no records of Antonio Goodwin ever being an

employee of any AT&T company.

15

16

17

18

Plaintiff respectfully requests that Judges Michelle T. Friedland, Ryan D. Nelson, and

Bridget S. Bade recall the mandate, reopen the appeal, and issue specific written findings

addressing whether Plaintiff’s AT&T employment evidence was deemed frivolous,

insufficient, inadmissible, unsupported, or ignored without a merits determination.

19

I. INTRODUCTION

20

21

This case concerns the central issue of whether Antonio Goodwin was employed by

2

I

AT&T, AT&T Mobility LLC, AT&T Inc., AT&T Corp., or any AT&T-related entity.

2

Plaintiff contends that the answer is proven by extensive AT&T employment evidence,

3

4

including

1,053

AT&T

documents,

employment

more

than

5,000

AT&T

employment-related images and records, and now 63 authentic AT&T employee

documents sent directly from AT&T to the EEOC.

5

6

Plaintiff further contends that Pamela M. Phillips submitted a declaration stating that no

records existed showing Antonio Goodwin was ever employed by any AT&T company.

7

8

9

10

Plaintiff respectfully contends that this declaration is materially contradicted by AT&T’s

own documents sent to the EEOC.

Plaintiff respectfully submits that the Ninth Circuit’s mandate should be recalled because

sanctions and dismissal were imposed against Mr. Goodwin by Magistrate Judge Daniel

J. Albregts and District Judge Gloria M. Navarro without an express merits ruling on

11

Plaintiff’s AT&T employment evidence, and because Judges Friedland, R. Nelson, and

Bade dismissed or treated the appeal as frivolous without specific written findings

12

addressing the AT&T employment evidence.

13

14

II. EEOC CHRONOLOGICAL TIMELINE

15

Plaintiff’s AT&T employment evidence began before the federal court case.

16

17

In 2023, Plaintiff Antonio Goodwin pursued the EEOC matter against AT&T concerning

Plaintiff’s employment, racial discrimination, sexual harassment, labor law violations,

18

and related claims.

19

20

21

Plaintiff contends that the EEOC matter was captioned and treated as Antonio Goodwin

v. AT&T, and that the EEOC documents for approximately three years identified AT&T as

the respondent.

3

1

2

Plaintiff contends that during the EEOC investigation, AT&T responded to the EEOC and

did not state that Antonio Goodwin was never an employee of AT&T until after Plaintiff

3

filed the federal lawsuit in the United States District Court for the District of Nevada.

4

Plaintiff contends that on or about January 2024, the EEOC issued Plaintiff Antonio

5

Goodwin a Right to Sue letter against AT&T.

6

7

8

Plaintiff contends that on May 9, 2024, EEOC Government Specialist Kathleen Gilliam

communicated with Plaintiff concerning the EEOC investigation and AT&T employment

evidence.

9

Plaintiff contends that Kathleen Gilliam stated in substance: “If you was not an employee

10

of AT&T Mr. Goodwin, AT&T would not had ever responded to the EEOC lawsuit filed

against AT&T.”

11

12

13

Plaintiff contends that the EEOC evidence, EEOC Right to Sue letter, EEOC investigation

records, and AT&T’s own EEOC response materials were repeatedly submitted to the

District Court and the Ninth Circuit but were never meaningfully addressed in written

14

findings.

15

Plaintiff now possesses 63 authentic AT&T employee documents sent directly from AT&T

16

17

to the EEOC. These records include Plaintiff’s AT&T Mobility employment history, AT&T

employee number, name, passcode, AT&T write-ups, AT&T coaching records, AT&T

EEOC response materials, and AT&T employment-related records.

18

19

Plaintiff respectfully contends that these 63 documents prove that AT&T possessed

employment records concerning Antonio Goodwin and that Pamela M. Phillips’

20

declaration stating that no such records existed is materially contradicted.

21

4

1

2

x

FEDERAL FALSE-STATEMENT, PERJURY,

AND DECLARATION-UNDER-PENALTY-OF-PERJURY ISSUES

3

4

5

6

Plaintiff respectfully contends that the record raises serious issues under federal

false-statement, perjury, and declaration-under-penalty-of-perjury laws because AT&T,

Pamela M. Phillips, and Stacey Campbell maintained for nearly three years that Antonio

Goodwin was never an employee of any AT&T company, while AT&T’s own records sent

directly to the EEOC include 63 authentic AT&T employee documents identifying

7

8

9

Plaintiff’s AT&T Mobility LLC employee history, AT&T employee number, name,

passcode, AT&T write-ups, AT&T coaching records, AT&T EEOC response materials, and

AT&T employment-related documents connected to AT&T Mobility LLC, AT&T, AT&T Inc.,

and AT&T Corp.

10

Plaintiff respectfully contends that Pamela M. Phillips’ declaration is materially

11

contradicted by AT&T’s own documents because the declaration stated that there were

no records showing Antonio Goodwin was ever employed by any AT&T company.

12

13

Plaintiff contends that this statement was false, material, and prejudicial because it was

used to support AT&T’s position that Plaintiff’s employment evidence and claims were

frivolous or unsupported.

14

15

Plaintiff respectfully contends that these facts implicate, at minimum, the following

federal statutes and legal concerns:

16

17

18 U.S.C. § 1001 — False Statements to the Federal Government.

18

Plaintiff contends that AT&T, Pamela M. Phillips, and Stacey Campbell made materially

false employment statements within matters involving federal jurisdiction, including the

19

20

EEOC proceedings and federal court proceedings, by asserting that Plaintiff was never

employed by any AT&T company despite AT&T-generated employment records.

18 U.S.C. § 1621 — Perjury.

21

Plaintiff contends that any sworn statement or declaration made under oath denying the

5

existence of Plaintiff’s AT&T employment records may constitute perjury if the statement

was knowingly false and material.

2

18 U.S.C. § 1623 — False Declarations Before Court or Grand Jury.

3

4

Plaintiff contends that any false declaration submitted in a federal court proceeding

concerning Plaintiff’s employment status may implicate 18 U.S.C. § 1623 if the

declaration was knowingly false and material.

5

28 U.S.C. § 1746 — Unsworn Declarations Under Penalty of Perjury.

6

Plaintiff contends that Pamela M. Phillips’ declaration, if submitted under penalty of

perjury, carried the same seriousness as sworn testimony and should not have been

7

8

accepted without meaningful review once Plaintiff presented AT&T records contradicting

it.

18 U.S.C. § 1503 — Obstruction of Justice.

9

10

Plaintiff contends that if false employment statements were knowingly used to influence

the federal court’s handling of Plaintiff’s case, sanctions, dismissal, or frivolousness

determination, such conduct may raise obstruction-of-justice concerns.

11

12

18 U.S.C. § 1519 — Falsification or Concealment of Records in Federal Matters.

Plaintiff

contends

that

if

records

employment

existed

and

were

concealed,

misrepresented, omitted, or contradicted by declarations in a federal matter, such

13

conduct may raise concerns under federal record-falsification or concealment laws.

14

Fraud on the Court.

15

Plaintiff contends that the false employment statements were not minor factual disputes.

Plaintiff contends that the employment-status issue was central to the entire case, the

16

sanctions, the dismissal, and the Ninth Circuit’s treatment of the appeal. Plaintiff

therefore respectfully contends that the contradiction between the Phillips declaration

17

18

19

20

and the 63 AT&T/EEOC employee documents raises a serious fraud-on-the-court issue

requiring judicial review.

Plaintiff respectfully acknowledges that criminal determinations are for the United States

Attorney, the Department of Justice, or the appropriate federal authorities. Plaintiff raises

these statutes to show the seriousness, materiality, and extraordinary nature of the

21

false-employment-record issue and why recall of the mandate is necessary to prevent

6

1

manifest injustice.

2

Plaintiff respectfully submits that the 63 AT&T employee documents sent directly from

3

4

AT&T to the EEOC prove that AT&T had employment records concerning Antonio

Goodwin. Plaintiff therefore requests that Judges Friedland, R. Nelson, and Bade recall

the mandate and issue specific written findings addressing whether the Phillips

5

declaration, Stacey Campbell’s employment statements, and AT&T’s position that

Plaintiff was never employed by any AT&T company can be reconciled with the

6

AT&T-generated employee records.

7

8

9

III. DISTRICT COURT CHRONOLOGICAL TIMELINE

Plaintiff filed the federal case in the United States District Court for the District of Nevada.

10

11

On February 26, 2024, Pamela M. Phillips submitted a declaration on behalf of AT&T

stating that there were no records showing that Antonio Goodwin was ever employed by

12

any AT&T company.

13

Plaintiff contends that AT&T, Stacey Campbell, and Pamela M. Phillips maintained the

14

15

16

17

position that Antonio Goodwin was never an employee of AT&T in January 2022 or at any

time.

Plaintiff contends that this position directly contradicted Plaintiff’s AT&T employment

evidence, including W-2 records, AT&T payroll records, AT&T pay stubs, AT&T employee

identification information, AT&T employee credentials, passwords, AT&T 401 (k) records,

18

19

20

AT&T employment communications, AT&T text messages, AT&T training materials, AT&T

University certificates, AT&T CEO Randall Stephenson training documents, AT&T

business cards, AT&T employee envelope records, Plaintiff’s AT&T employee telephone

number

1-800-331-0500,

att.com

records,

documentation.

21

7

and

other

AT&T

employment-related

1

Plaintiff contends that from February 2024 through March 2024, employment evidence

was repeatedly placed before Magistrate Judge Daniel J. Albregts and District Judge

2

Gloria M. Navarro.

3

4

On February 20, 2025, during the Joint Initial Disclosure dispute, Plaintiff specifically

raised that AT&T was making false employment statements despite AT&T employment

5

evidence already being before the Court.

6

On April 10, 2025, Plaintiff filed sanctions against AT&T in ECF Nos. 51 and 54 for making

7

8

9

10

false employment statements under oath regarding Antonio Goodwin allegedly never

being an employee of any AT&T company.

Plaintiff contends that ECF Nos. 51 and 54 placed before Magistrate Judge Daniel J.

Albregts and District Judge Gloria M. Navarro more than 900 pages of authentic AT&T

employment evidence.

11

12

Plaintiff contends that this 900-page employment record was before the Court before any

Rule 11 sanctions were filed or granted against Plaintiff.

13

14

15

16

17

On April 11, 2025, Magistrate Judge Daniel J. Albregts denied Plaintiff’s sanctions

motions through ECF No. 66.

On April 17, 2025, Plaintiff filed a motion for reconsideration of ECF No. 66 and

resubmitted more than 900 pages of AT&T employment-related evidence supporting

Plaintiff’s position that he was employed by AT&T.

18

19

20

Plaintiff contends that no order expressly analyzed or resolved the merits of the more

than 900 pages of AT&T employment evidence submitted in connection with Plaintiff’s

sanctions motions and reconsideration request.

21

8

1

On June 5, 2025, Rule 11 sanctions proceedings were granted or allowed against Plaintiff

despite Plaintiff’s position that the Court already possessed more than 900 pages of

2

authentic AT&T employment evidence as of April 10, 2025.

3

4

Plaintiff respectfully contends that Magistrate Judge Daniel J. Albregts and District

Judge Gloria M. Navarro violated Plaintiff’s Fifth Amendment due process rights by

5

imposing or allowing sanctions without first expressly resolving Plaintiff’s evidence that

AT&T’s employment-denial position was false.

6

7

8

9

IV. DISCOVERY CUT-OFF, ECF NOS. 123 AND 133, AND SEPTEMBER 25, 2025

DEPOSITION SANCTIONS

Plaintiff contends that the discovery cut-off date was August 12, 2025.

10

11

Plaintiff contends that after the August 12, 2025 discovery cut-off date, AT&T and Stacey

Campbell sought an extension and attempted to proceed with an in-person deposition of

12

Antonio Goodwin.

13

Plaintiff contends that AT&T’s motion concerning discovery and deposition issues was

14

filed as ECF No. 123 on September 3, 2025.

15

16

Plaintiff contends that AT&T’s reply or related filing was ECF No. 133 on September 11,

2025.

17

18

Plaintiff contends that the deposition was scheduled for September 25, 2025, at 9:00 a.m.,

after the August 12, 2025 discovery cut-off date and before the Court entered its later

19

ruling on the extension issue.

20

Plaintiff contends that Magistrate Judge Daniel J. Albregts and District Judge Gloria M.

21

Navarro did not issue the order granting or addressing AT&T’s requested discovery

9

1

extension until November 25, 2025.

2

Plaintiff contends that the November 25, 2025 order was approximately three months

3

4

5

6

after the August 12, 2025 discovery cut-off date and approximately two months after the

September 25, 2025 in-person deposition date.

Plaintiff contends that he was later sanctioned for not attending the September 25, 2025

deposition even though, according to Plaintiff, the deposition was invalid because it was

scheduled after the discovery cut-off date and before the Court granted the extension.

7

8

Plaintiff respectfully contends that Magistrate Judge Daniel J. Albregts and District

Judge Gloria M. Navarro imposed sanctions against Plaintiff for an invalid deposition that

9

10

occurred outside the discovery period and before a valid court order authorized the

extended discovery deadline.

11

Plaintiff further contends that Judges Friedland, R. Nelson, and Bade ignored or failed to

12

expressly address the August 12, 2025 discovery cut-off date, ECF No. 123, ECF No. 133,

the September 25, 2025 deposition date, and the November 25, 2025 late ruling when

13

dismissing or treating Plaintiff’s appeal as frivolous.

14

15

16

17

V. SEPTEMBER 10, 2025 DISPOSITIVE MOTION AND EMPLOYMENT EVIDENCE

On September 10, 2025, Plaintiff filed ECF Nos. 131, 134, and 136 seeking dispositive

relief in Plaintiff’s favor.

18

Plaintiff contends that the September 10, 2025 dispositive motion included approximately

19

1,053

authentic

AT&T

employment

documents

and

approximately

5,000 AT&T

employment-related images.

20

21

Plaintiff contends that these filings were submitted before the September 25, 2025

10

1

deposition, before the December 30, 2025 sanctions hearing, before ECF No. 189, and

before dismissal of the case.

2

3

4

Plaintiff contends that the September 10, 2025 dispositive motion directly presented the

employment-status issue to Magistrate Judge Daniel J. Albregts and District Judge

Gloria M. Navarro and requested a ruling in Plaintiff’s favor.

5

6

Plaintiff contends that the September 10, 2025 dispositive motion was never expressly

adjudicated on the merits before sanctions were imposed against Plaintiff.

7

8

9

Plaintiff further contends that ECF Nos. 155 and 156, filed on November 19 and November

20, 2025, provided additional AT&T employment evidence before the December 30, 2025

sanctions hearing.

10

11

Plaintiff contends that ECF No. 174, ECF No. 199, Exhibit A, and related submissions

provided further employment evidence before dismissal.

12

13

Plaintiff respectfully contends that the Court possessed repeated submissions of AT&T

employment evidence from February 2024 through January 2026 and never issued an

14

15

16

express written ruling determining whether Plaintiff’s employment evidence established

that Antonio Goodwin was employed by AT&T.

VI. SANCTIONS IMPOSED AGAINST PLAINTIFF

17

18

Plaintiff contends that sanctions were imposed against him by Magistrate Judge Daniel J.

Albregts and District Judge Gloria M. Navarro despite Plaintiff’s repeated submission of

19

AT&T employment evidence.

20

Plaintiff contends that Rule 11 sanctions were granted or allowed against Plaintiff on

21

June 5, 2025, after Plaintiff had already filed sanctions against AT&T on April 10, 2025 in

11

I

ECF Nos. 51 and 54.

2

Plaintiff contends that by April 10, 2025, Magistrate Judge Daniel J. Albregts and District

3

4

5

6

Judge Gloria M. Navarro already had before them more than 900 pages of authentic AT&T

employment evidence.

Plaintiff contends that additional sanctions were imposed after the December 30, 2025

sanctions hearing based on the September 25, 2025 deposition issue.

7

Plaintiff contends that the December 30, 2025 sanctions were unjust because the

8

deposition was scheduled after the August 12, 2025 discovery cut-off date and before the

Court’s November 25, 2025 ruling addressing the discovery extension issue.

9

10

11

Plaintiff respectfully contends that sanctions were imposed without adequate procedural

protection, without a fair merits determination of Plaintiff’s dispositive motion, and

without express written findings addressing Plaintiff’s AT&T employment evidence.

12

13

Plaintiff contends this violated the Fifth Amendment Due Process Clause.

14

VII. NINTH CIRCUIT PROCEEDINGS AND REQUEST FOR SPECIFIC FINDINGS

15

16

17

Plaintiff contends that Ninth Circuit Judges Michelle T. Friedland, Ryan D. Nelson, and

Bridget S. Bade issued orders or participated in the disposition of Case No. 26-927,

including the June 2, 2026 order.

18

19

Plaintiff respectfully contends that Judges Friedland, R. Nelson, and Bade did not

expressly address whether they agreed with AT&T, Stacey Campbell, Pamela M. Phillips,

20

Magistrate Judge Daniel J. Albregts, and District Judge Gloria M. Navarro that Antonio

Goodwin was never an employee of AT&T.

21

12

1

2

Plaintiff respectfully requests that Judges Friedland, R. Nelson, and Bade state in writing

whether Plaintiff’s AT&T employment evidence was treated as frivolous under 28 U.S.C. §

3

1915(a) and § 1915(e)(2).

4

Plaintiff further requests that Judges Friedland, R. Nelson, and Bade state whether the

5

6

7

dismissal rested on a finding that Plaintiff’s employment evidence, racial discrimination

evidence, sexual harassment evidence, labor law evidence, dispositive motion, exhibits,

or

entire

AT&T

employment

record

were

frivolous,

insufficient,

inadmissible,

unsupported, or lacking probative value.

8

Plaintiff respectfully contends that without such written findings, Plaintiff cannot

9

meaningfully seek review by the Supreme Court of the United States.

10

VIII. FIFTH AMENDMENT DUE PROCESS ARGUMENT

11

12

13

The Fifth Amendment states that no person shall be deprived of life, liberty, or property

without due process of law.

14

Due process requires notice, an opportunity to be heard, a fair and impartial

15

decision-maker, consideration of material evidence, and decisions made according to

established legal procedures.

16

17

Plaintiff respectfully contends that due process was violated because:

18

19

Material AT&T employment evidence was not meaningfully considered;

Plaintiff’s dispositive motion filed September 10, 2025 was not expressly ruled on before

20

sanctions and dismissal;

21

Sanctions were imposed against Plaintiff despite unresolved employment evidence;

13

1

Plaintiff was sanctioned for the September 25, 2025 deposition despite the August 12,

2025 discovery cut-off issue;

2

ECF Nos. 123 and 133 and the November 25, 2025 delayed discovery ruling were not

3

4

5

6

7

8

9

10

properly addressed;

Pamela M. Phillips’ declaration was relied upon despite contradiction by AT&T

employment evidence;

The EEOC evidence from 2023, the January 2024 Right to Sue letter, the May 9, 2024

EEOC investigation evidence, and the 63 AT&T documents sent directly to the EEOC

were not addressed in detail;

Judges Friedland, R. Nelson, and Bade did not provide specific findings explaining why

Plaintiff’s AT&T employment evidence was frivolous or legally insufficient.

Plaintiff respectfully contends that this created a fundamentally unfair proceeding and

resulted in manifest injustice.

11

IX. NEWLY DISCOVERED 63 AT&T EMPLOYEE DOCUMENTS

12

13

Plaintiff has now located 63 authentic AT&T employee documents sent directly from

AT&T to the EEOC.

14

15

These documents include:

16

17

Antonio Goodwin’s AT&T Mobility LLC employee history;

Antonio Goodwin’s AT&T employee number;

18

Antonio Goodwin’s name and passcode;

19

AT&T write-ups;

20

AT&T coaching records;

AT&T’s complete EEOC response materials;

21

14

1

2

AT&T Mobility LLC employment-related records;

AT&T and AT&T corporate records connected to Plaintiff’s employment evidence;

Records involving AT&T Inc., AT&T Corp., and the current AT&T Inc./AT&T Corp. CEO

3

John T. Stankey as part of Plaintiff’s AT&T employee documents sent directly from AT&T.

4

5

Plaintiff respectfully contends that these documents are authentic because they came

directly from AT&T to the EEOC.

6

7

Plaintiff respectfully contends that these documents directly contradict Pamela M.

Phillips’ declaration that no records existed showing Antonio Goodwin was ever

8

employed by any AT&T company.

9

Plaintiff respectfully submits that these 63 AT&T documents create extraordinary

10

circumstances justifying recall of the mandate.

11

12

X. REQUESTED RELIEF

13

Plaintiff Antonio Goodwin respectfully requests that this Court:

14

15

16

17

Recall the mandate in Ninth Circuit Case No. 26-927;

Reopen the appeal for limited review of the 63 authentic AT&T employee documents sent

directly from AT&T to the EEOC;

Plaintiff file the 63 AT&T/EEOC documents to Mandate the matter in the Ninth Circuit

Court

18

Vacate or reconsider any frivolousness determination based on the assertion that

19

Plaintiff was never an AT&T employee;

20

Issue written findings explaining whether Judges Friedland, R. Nelson, and Bade agree

with AT&T, Stacey Campbell, Pamela M. Phillips, Magistrate Judge Daniel J. Albregts, and

21

District Judge Gloria M. Navarro that Antonio Goodwin was never employed by AT&T;

15

1

Issue written findings explaining whether Plaintiff’s AT&T employment evidence was

deemed frivolous, insufficient, inadmissible, unsupported, unrelated, or lacking probative

2

value;

3

Address Plaintiff’s April 10, 2025 sanctions motions against AT&T, ECF Nos. 51 and 54;

4

Address Plaintiff’s April 17, 2025 reconsideration filing and the more than 900 pages of

employment evidence submitted;

5

Address Plaintiff’s September 10, 2025 dispositive motion, ECF Nos. 131, 134, and 136;

6

Address ECF Nos. 155,156,174,199, Exhibit A, and related submissions;

7

Address the August 12, 2025 discovery cut-off date;

Address ECF No. 123, ECF No. 133, the September 25, 2025 deposition, and the

8

November 25, 2025 discovery ruling;

9

Address the sanctions imposed by Magistrate Judge Daniel J. Albregts and District

Judge Gloria M. Navarro;

10

11

Address the EEOC evidence from 2023, the January 2024 Right to Sue letter, the May 9,

2024 EEOC investigation evidence, EEOC Government Specialist Kathleen Gilliam’s

statement, and the 63 AT&T employee documents sent directly from AT&T to the EEOC;

12

Grant any other relief this Court deems just and proper.

13

14

15

16

XI. CONCLUSION

Plaintiff Antonio Goodwin respectfully submits that the mandate should be recalled

because

this

case

involves

extraordinary

circumstances,

newly

discovered

AT&T-generated employee documents, a material contradiction of Pamela M. Phillips’

17

18

declaration, unresolved dispositive employment evidence, sanctions imposed without

adequate consideration of material evidence, discovery cut-off violations, and Fifth

Amendment due process concerns.

19

20

Plaintiff respectfully requests that Judges Friedland, R. Nelson, and Bade recall the

mandate and provide specific written findings so that the Supreme Court of the United

21

States may meaningfully review the treatment of Plaintiff’s AT&T employment evidence,

16

1

racial discrimination claims, sexual harassment claims, labor law claims, sanctions

issues, and due process claims.

2

3

FEDERAL FALSE-STATEMENT, PERJURY,

4

AND DECLARATION-UNDER-PENALTY-OF-PERJURY ISSUES

5

Plaintiff respectfully contends that the record raises serious issues under federal

6

7

8

false-statement, perjury, and declaration-under-penalty-of-perjury laws because AT&T,

Pamela M. Phillips, and Stacey Campbell maintained for nearly three years that Antonio

Goodwin was never an employee of any AT&T company, while AT&T’s own records sent

directly to the EEOC include 63 authentic AT&T employee documents identifying

Plaintiff’s AT&T Mobility LLC employee history, AT&T employee number, name,

9

10

passcode, AT&T write-ups, AT&T coaching records, AT&T EEOC response materials, and

AT&T employment-related documents connected to AT&T Mobility LLC, AT&T, AT&T Inc.,

and AT&T Corp.

11

12

Plaintiff respectfully contends that Pamela M. Phillips’ declaration is materially

contradicted by AT&T’s own documents because the declaration stated that there were

13

no records showing Antonio Goodwin was ever employed by any AT&T company.

Plaintiff contends that this statement was false, material, and prejudicial because it was

14

15

16

17

used to support AT&T’s position that Plaintiff’s employment evidence and claims were

frivolous or unsupported.

Plaintiff respectfully contends that these facts implicate, at minimum, the following

federal statutes and legal concerns:

18

18 U.S.C. § 1001 — False Statements to the Federal Government.

19

20

Plaintiff contends that AT&T, Pamela M. Phillips, and Stacey Campbell made materially

false employment statements within matters involving federal jurisdiction, including the

EEOC proceedings and federal court proceedings, by asserting that Plaintiff was never

21

employed by any AT&T company despite AT&T-generated employment records.

17

1

2

18 U.S.C. § 1621 — Perjury.

Plaintiff contends that any sworn statement or declaration made under oath denying the

existence of Plaintiff’s AT&T employment records may constitute perjury if the statement

3

4

was knowingly false and material.

18 U.S.C. § 1623 — False Declarations Before Court or Grand Jury.

Plaintiff contends that any false declaration submitted in a federal court proceeding

5

6

concerning Plaintiff’s employment status may implicate 18 U.S.C. § 1623 if the

declaration was knowingly false and material.

28 U.S.C. § 1746 — Unsworn Declarations Under Penalty of Perjury.

7

8

Plaintiff contends that Pamela M. Phillips’ declaration, if submitted under penalty of

perjury, carried the same seriousness as sworn testimony and should not have been

accepted without meaningful review once Plaintiff presented AT&T records contradicting

9

it.

10

18 U.S.C. § 1503 — Obstruction of Justice.

Plaintiff contends that if false employment statements were knowingly used to influence

11

12

the federal court’s handling of Plaintiff’s case, sanctions, dismissal, or frivolousness

determination, such conduct may raise obstruction-of-justice concerns.

18 U.S.C. § 1519 — Falsification or Concealment of Records in Federal Matters.

13

Plaintiff

14

contends

that

if

records

employment

existed

and

were

concealed,

misrepresented, omitted, or contradicted by declarations in a federal matter, such

conduct may raise concerns under federal record-falsification or concealment laws.

15

16

17

18

Fraud on the Court.

Plaintiff contends that the false employment statements were not minor factual disputes.

Plaintiff contends that the employment-status issue was central to the entire case, the

sanctions, the dismissal, and the Ninth Circuit’s treatment of the appeal. Plaintiff

therefore respectfully contends that the contradiction between the Phillips declaration

and the 63 AT&T/EEOC employee documents raises a serious fraud-on-the-court issue

19

requiring judicial review.

20

21

Plaintiff respectfully acknowledges that criminal determinations are for the United States

Attorney, the Department of Justice, or the appropriate federal authorities. Plaintiff raises

18

I

these statutes to show the seriousness, materiality, and extraordinary nature of the

false-employment-record issue and why recall of the mandate is necessary to prevent

2

manifest injustice.

3

4

Plaintiff respectfully submits that the 63 AT&T employee documents sent directly from

AT&T to the EEOC prove that AT&T had employment records concerning Antonio

5

Goodwin. Plaintiff therefore requests that Judges Friedland, R. Nelson, and Bade recall

the mandate and issue specific written findings addressing whether the Phillips

6

7

declaration, Stacey Campbell’s employment statements, and AT&T’s position that

Plaintiff was never employed by any AT&T company can be reconciled with the

AT&T-generated employee records.

8

9

10

11

Dated: June 9, 2026

12

13

14

Respectfully submitted,

Isl Antonio Goodwin

15

Antonio Goodwin

16

Plaintiff-Appellant, Pro Se

17

21021 Sycolin Rd, Unit 503

Ashburn, VA 20147

18

19

702-352-3293

tonygoodwin119@gmail.com

20

21

19

i

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AT&T

,Stephanie Davis

.Lead EEO Consultant

AT&T Services Inc.

221 W. Winton, Rm C213

Hayward, CA. 94544

sdl841@att.com

Phone: 510-784-3588

Fax: 510-784-3588

January 3, 2023

Ms. Cherry-Marie Destura

Federal Investigator

Equal Employment Opportunity Commission

Las Vegas Local Office

333 Las Vegas Blvd. South

Suite 5560

Las Vegas, NV 89101

Re:

Antonio Goodwin vs. AT&T Mobility Services LLC

EEOC 487-2022-02050

Dear Ms. Destura:

AT&T Mobility Services LLC, hereafter referred to as “Mobility” or “the Company”, is Antonio

Goodwin’s (“Goodwin”) former employer. Mobility is a telecommunications company that has

numerous offices throughout the country, including the state of Nevada and employs individuals

above the minimum jurisdictional requirements under state and federal laws.

This letter is Mobility’s Position Statement in response to the Charge of Discrimination signed by

Goodwin on November 16, 2022.

Goodwin’s allegations are without merit. He was treated the same as all other employees and in

accordance with Company policies and the law. Mobility denies his claims in their entirety. The

Company prohibits harassment, discrimination, and retaliation. All employees company-wide are

annually required to complete web-based EEO & Harassment Policies and Code of Business

Conduct training. Attachment 1, EEO & Harassment Policies and Attachment 2, Code of

Business Conduct (COBC).

Please issue a Dismissal and Notice of Rights.

1

This response is the Company's initial position and is based on its understanding of the facts and information reviewed thus far.

This response does not constitute an affidavit or binding statement of the Company's legal position and is not intended to be

used as evidence of any kind in any administrative or court proceeding in connection with the Complainant's allegations. The

Company reserves the right to file additional information as the investigation proceeds. If more specific allegations are made to

the agency that have not been disclosed to the Company or addressed in this response, the Company requests notice of such

allegations and an opportunity to respond. The information and documentation contained in this response, and any which may

be submitted later, is strictly confidential and may not be disclosed publicly or used for any purpose other than to aid the agency

in its review of this matter. To the extent the Charging Party receives this response and/or accompanying documentation, the

Charging Party is advised that the Company's response and documentation is strictly confidential and must not be disclosed

publicly or to any individual unless the Charging Party has a privileged relationship with that individual.

AT&T

Stephanie Davis

Lead EEO Consultant

AT&T Services Inc.

221W. Winton, Rm C213

Hayward, CA. 94544

sdl841@att.com

Phone: 510-784-3588

Fax: 510-784-3588

GOODWIN VOLUNTARILY RESIGNED HIS EMPLOYMENT EFFECTIVE AUGUST 4, 2022. HE

WAS NOT CONSTRUCTIVELY DISCHARGED.

Goodwin was hired in January 2022 in the position of Retail Sales Consultant (RSC).

Approximately seven months later, effective August 4, 2022, he voluntarily tendered his

resignation. The reason Goodwin gave was that he was leaving the city—he worked in Las Vegas

and lived in Henderson. Notably, he did not state that he was resigning due to intolerable

working conditions. Goodwin was not constructively discharged. His employment was governed

by a collective bargaining agreement between Mobility and the Communications Workers of

America (CWA). Attachment 3, Retail Sales Consultant Job Description.

ANTONIO GOODWIN

ATT MOBILITY SVC

XCW921023

Withdrawn

Withdrawn

Start

08/04/2022

Personnel action

to

XXX-XX-^B

Al

Nonmanagement Sates

CWr

Regular Fulltime

App

12/31/9999

Chng 08/05/2022

- »: 1

Action Type

79 Separation From Service

Reason for Action

0?|

v

LeaveCity

THE COMPANY CONDUCTED MULTIPLE INVESTIGATIONS THAT DID NOT SUBSTANTIATE

GOODWIN’S ALLEGATIONS OF HARASSMENT, DISCRIMINATION, OR RETALIATION.

On June 28, 2022, Goodwin filed report 2022-06-28-014457 alleging peer RSCs, Marcus Carter

(Mixed race, hired Jan 2022) and Anthony Zecchino (Caucasian, hired Feb 2016) had been

harassing him for about three weeks, which consisted of “slander" and calling him “angry”. The

report was assigned to Derek Zamagni, Lead EEC Consultant for investigation.

2

Antonio Goodwin - 487-2022-02050

AT&T

Stephanie Davis

Lead EEO Consultant

AT&T Services Inc.

221 W. Winton, Rm C213

Hayward, CA. 94544

sdl841@att.com

Phone: 510-784-3588

Fax: 510-784-3588

unprotected occurrences. Adams was trying to help Goodwin avoid future attendance-based

discipline. Attachment 4, Goodwin Attendance and Performance Documentation.

EEO interviewed Carter on July 21, 2022, who denied the allegations against him and offered his

opinion that Goodwin made up the allegations because he was not performing his job.

EEO interviewed Zecchino on July 21, 2022, who denied harassing Goodwin, and indicated he

had no knowledge of Carter behaving inappropriately toward Goodwin.

None of the witnesses that EEO interviewed reported seeing or hearing Carter or Zecchino harass

Goodwin in word or deed.

The EEO investigation concluded on July 25, 2022. It was unsubstantiated Adams retaliated

against Goodwin; unsubstantiated Carter or Zecchino harassed Goodwin; and unsubstantiated

Carter made any sexual comments to Goodwin. Carter received a documented coaching and

remedial Workplace Harassment training for referring to coworkers as “daddy” and “baby", terms

he directed to various coworkers, including Goodwin.

EEO provided feedback to Goodwin on July 25, 2022. Goodwin said that since the investigation

it had been better at the store and that no one had bothered him further.

There is nothing about this investigation, the results of the investigation, or Goodwin’s subsequent

conduct to suggest that this caused Goodwin’s working conditions to become so intolerable he

had no other option but to resign his employment.

On July 19, 2022, Goodwin filed report 2022-07-19-CRTJM8 alleging a problem with ASM Adams.

The report was assigned to Brandy Shells, HR Ethics Employee Relations Manager for

investigation.

4

Antonio Goodwin - 487-2022-02050

AT&T

Stephanie Davis

Lead EEO Consultant

AT&T Services Inc.

221 W. Winton, Rm C213

Hayward, CA. 94544

sdl841@att.com

Phone: 510-784-3588

Fax: 510-784-3588

Created By

Brandi Shells

(bs1537)?

07/19/2022

12:37 PM

Control Number

2022-07-19-CRTJM8

Status

Closed

07/19/2022

12:46 PM

Assigned To

Brandi Shells (bs1537) ? HRS

A - AT&T

Classification: 0500-HRS

SubClassrfication: Employee Relations

Sub Type: Problem with Supervisor or Co -Worker Reminder, if this is a potential COBC

violation it can NOT be coded to a 500-HRS Classification.

EVENT INFORMATION

Event ID

07/19/2022

Business Unit

MOBILITY RTL SLS & SVC WEST

REG

Company Code /

Subsidiary

Ml : AT&T Mobility Services LLC

AC ANTONIO

GOODWIN AG997GPROBLEM WITH

SUPERVISOR DYLAN

ADAMS

Pending Start Date:

Pending End Date:

Disp. Pending Start

Date:

Disp. Pending 'End

Date:

Date Closed

Last Update Date

X-Up Date

07/19/2022

Ethics interviewed Goodwin on July 19, 2022, who reported he was placed on discipline for

attendance without being told about his leave options.

Ethics researched Goodwin’s concern and determined he had in fact been provided with leave

options during his May 6, 2022, Counseling and his July 15, 2022, Final Written Warning.

Attachment 5, Final Written Warning; Attachment 7, Performance Counseling.

In addition, via his company I-Pad and cell phone, Goodwin had daily access to the HR OneStop

Intranet site which contains a vast number of resources and A-Z information on all things HR

related such as leaves of absence, FMLA, disability, payroll, attendance, career opportunities,

benefits, pension, 401K, etc. Goodwin had full and unrestricted access to the information.

Similarly, there is nothing about this investigation or Adams’ alleged conduct to suggest that this

caused Goodwin’s working conditions to become so intolerable he had no other option but to

resign his employment.

5

Antonio Goodwin - 487-2022-02050

AT&T

Stephanie Davis

Lead EEO Consultant

AT&T Services Inc.

221W. Winton, Rm C213

Hayward, CA. 94544

sdl841@att.com

Phone: 510-784-3588

Fax: 510-784-3588

GOODWIN WAS NOT DENIED TRAINING.

Goodwin’s claim that he was denied training is false. All newly hired RSCs receive comprehensive

new employee classroom training. Once on the floor, employees receive further training in the

form of tailgate and huddle sessions where management gives employees the opportunity to

discuss things like sales goals, priorities, key sales strategies, processes, procedures, products &

plans, all designed to focus on the enhancement of skills. Management also conducts coaching

with employees via the direct feedback model where they provide clarity to get to root causes of

any work obstacles.

Goodwin’s training record clearly demonstrates he was provided with numerous training classes

completed during the course of his employment. Attachment 6, Goodwin Training Record.

All employees are required to complete the following courses within six months of hire and then

every two years thereafter:

Course Names

1-Preventing Harassment

2-Sexual Harassment

3-Diversity

4-Respectinq Others

Number Abbreviation

70009717

1_WPH

70009712

2_WPH

3_WPH

70009715

4_WPH

70009716

Goodwin completed his training on:

01/18/2022

ANTONIO GOODWIN

Preventing Harassment Training

01/18/2022

ANTONIO GOODWIN

Sexual Harassment Training

01/18/2022

ANTONIO GOODWIN

Diversity Training

01/18/2022

ANTONIO GOODWIN

Respecting Others Training

6

Antonio Goodwin - 487-2022-02050

AT&T

Stephanie Davis

Lead EEO Consultant

AT&T Services Inc.

221 W. Winton, Rm C213

Hayward, CA. 94544

sdl841@att.com

Phone: 510-784-3588

Fax: 510-784-3588

Carter completed his training on:

01/11/2022

MARCUS CARTER

Preventing Harassment Training

01/11/2022

MARCUS CARTER

Sexual Harassment Training

01/11/2022

MARCUS CARTER

Diversity Training

01/11/2022

MARCUS CARTER

Respecting Others Training

08/29/2022

MARCUS CARTER

Workplace Harassment Remediation

07/27/2022

MARCUS CARTER

Preventing Harassment Training

07/27/2022

MARCUS CARTER

Diversity Training

07/27/2022

MARCUS CARTER

Respecting Others Training

07/25/2022

MARCUS CARTER

Workplace Harassment Remediation

Zecchino last completed his training on:

..

05/29/2020

ANTHONY ZECCHINO

1-Preventing Harassment Intro-Retail

05/28/2020

ANTHONY ZECCHINO

3-Diversity-Retail

05/16/2020

ANTHONY ZECCHINO

2-Sexual Harassment-Retail

05/16/2020

ANTHONY ZECCHINO

4-Respecti ng Others-Retail

...

7

Antonio Goodwin - 487-2022-02050

AT&T

Stephanie Davis

Lead EEO Consultant

AT&T Services Inc.

221 W. Winton, Rm C213

Hayward, CA. 94544

sdl841@att.com

Phone: 510-784-3588

Fax: 510-784-3588

GOODWIN WAS NOT DISCIPLINED BASED ON ANY PROTECTED CLASS OR IN

RETALIATION FOR ANY PROTECTED ACTIVITY.

As the internal EEO investigation substantiated, Goodwin was not disciplined based on any

protected class or in retaliation for any protected activity.

Goodwin was not given any false write-ups. He had two records of discipline: (1) a May 6, 2022

Performance Counseling that expired on August 4, 2022 (Attachment 7, Performance

Counseling) and (2) a Final Written Warning for attendance (See Attachment 5). In both instances

the discipline was justified and supported by the facts.

Notably, others in the store were also discipline when they had attendance issues. For example,

Carter was disciplined for attendance in the form of Counseling and Written Warnings.

Attachment 8, Carter Attendance Discipline.

CONCLUSION

Given all of this, please issue a Dismissal and Notice of Rights.

Thank you.

Stephanie Davis

(510) 784-3588

Attachments

8

Antonio Goodwin - 487-2022-02050

AT&T

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

Equal Employment Opportunity (EEO) &

Harassment Policies

AT&T is strongly committed to a workplace that values diversity and inclusion

and that is free of discrimination and harassment of any kind. AT&T’s EEO and

Harassment Policies apply to all AT&T employees.

Employee Responsibilities | Manager Responsibilities | Reporting a Concern | Non-Retaliation

Policy | Internal Investigations | Diversity | Equal Employment Opportunity | The American With

Disabilities Act | Confidentiality | Pregnancy Discrimination | Religious Discrimination | Military

Status | Harassment Policy | What is Sexual Harassment? | Personal Relationships Policy | Sexual

Harassment Prevention Training | Reporting Sexual Harassment | Additional Complaint

Procedures | Frequently Asked Questions

July 25,2022

c 2021 AT&T Intellectual Property. AT&T, Globe logo, and DIRECTV are registered trademarks and service marks of

AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

Page 1

AT&T

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

Policy Statement

AT&T prohibits discrimination on the basis of race, color, religion, religious creed, national origin,

ancestry, age, sex, sexual orientation, gender, gender identity, gender expression, physical

disability, mental disability, pregnancy, medical condition, genetic information, marital status,

citizenship status, military status, veteran status, or any other characteristic to the extent

protected by federal, state, or local laws. For instance, New York City also prohibits discrimination

on the basis of creed. AT&T complies with these and other applicable EEO laws and prohibits

discrimination.

AT&T also strictly prohibits all forms of abusive conduct or workplace harassment, including

sexual and racial harassment and harassment based on any of the characteristics described

above. An employee’s actions, words, or behavior must not create an intimidating, hostile, or

offensive environment. Employees are not permitted to ridicule, intimidate, threaten, demean, or

bully other employees, customers, vendor employees, or any other individuals with whom they

interact. Remarks, comments, jokes, slurs, images, gestures, messages, or social media posts of an

offensive nature will not be tolerated.

It is a violation of this policy to discriminate against or harass anyone while working on behalf of

AT&T, including co- workers, contractors, vendors, or customers.

Employee Responsibilities

AT&T employees are responsible for understanding and complying with the Company's EEO and

Harassment Policies. Failure to comply may result in disciplinary action, which can include

dismissal even for a first offense. We all have a responsibility to ensure that AT&T is free of

discrimination and harassment. Therefore, employees are responsible for reporting any violations

of the EEO and Harassment Policies.

Manager Responsibilities

All managers are responsible for enforcement of the Company's EEO and Harassment Policies by

ensuring a work environment free of discrimination and harassment. If a manager observes or

receives any reports or allegations of conduct that could potentially violate the EEO and

Harassment Policies, the manager has a responsibility to report it immediately to Human

Resources or the AT&T Hotline. Any manager who fails to do so may be subject to discipline, up to

and including termination. Such allegations are investigated by a team of EEO investigators.

Therefore, managers must always report them immediately and receive guidance from an

investigator on the next steps. In addition, supervisors are expected to:

•

•

•

Review the EEO and Harassment Policies with each direct report.

Ensure that the EEO and Harassment Policies review with each direct report is documented in

his/her training history.

Acknowledge employees’ differences and their individual value to AT&T.

July 25, 2022

© 2021 AT&T Intellectual Property. AT&T, Globe logo, and DIRECTV are registered trademarks and service marks of

AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

Page 2

Sat&t

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

Reporting a Concern

Employees should report a violation of the EEO and Harassment Policies to a direct supervisor,

any manager, Human Resources, directly to the AT&T Hotline.

AT&T has established the AT&T Hotline for reporting EEO, or harassment concerns anonymously

and confidentially. The Hotline is staffed by an independent third-party vendor contracted by

AT&T. The reported complaint will be summarized and forwarded to AT&T for further review.

Report concerns via AT&T Hotline @ 1-888-871-2622 or the AT&T Hotline Web Reporting

site https://app.mycompliancereport.com/report?cid=ATT

To the extent possible, reports to the AT&T Hotline will be kept confidential as consistent with

legal and ethical responsibilities on behalf of the Company. Following an investigation, AT&T will

take appropriate corrective action, if warranted.

Non-Retaliation Policy

Any individual who suspects an EEO violation and makes a report is acting responsibly in

accordance with the EEO and Harassment Policies. The Company forbids retaliation against any

person who makes a report or who participates in the investigative process. Allegations of

retaliation will be investigated, and appropriate action will be taken. Any individual engaging in

retaliatory behavior will be subject to disciplinary action, which may include termination of

employment. For any suspected retaliation concerns, contact the AT&T Hotline immediately.

Additional information on AT&T’s Non-Retaliation Policy may be found at the following link:

https://hronestop.web.att.com/documents/33859/7996495/20190320_NRP_ATT++FINAL.pdf/4d24ece6-e7ee-a07a-_383d-f341e1fdd373.

Internal Investigations

AT&T investigates possible violations of federal, state, and local EEO laws, and AT&T’s EEO and

Harassment Policies. Employees are required to cooperate fully with the Company’s

investigations, may not lie to investigators, obstruct the investigation, or retaliate against those

who participate. Anyone who refuses to cooperate with an investigation, lies to investigators,

obstructs, or attempts to obstruct an investigation, or engages in retaliatory conduct will be

subject to discipline, including termination. To the extent possible, confidentiality will be

maintained consistent with legal and ethical responsibilities on behalf of the Company.

All complaints will be handled appropriately, and remedial action will be taken if any misconduct is

found.

Important additional Company guidance on internal investigations may be found at the following

link:

https://hronestop.web.att.com/documents/33859/403407050/Helpful+Resources+OnePager.pdf

/93eda1fa-4705-b645-795e-a1aadb7304b6.

July 25,2022

® 2021 AT&T Intellectual Property. AT&T, Globe logo, and DIRECTV are registered trademarks and service marks of

AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

Page 3

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

Diversity

Diversity means respecting many backgrounds, cultures, and ways of thinking. AT&T recognizes

and embraces all differences-from race, gender, sexual orientation, and mental/physical ability

to perspectives, experiences, and outlooks. It is more than the right thing to do - diversity is

essential to the success of AT&T in the global marketplace. AT&T employees are responsible for

promoting an environment of inclusion: one in which each individual is valued, and every voice is

heard. Actions that guide employee commitment to diversity include:

•

•

•

•

•

•

•

•

•

Treating others with respect

Encouraging and skillfully incorporating opinions and ideas.

Viewing differences as assets.

Accommodating various strengths.

Working together in mixed teams to design and implement creative solutions for our business

suppliers and customers.

Serving our broad markets effectively and sensitively.

Creating win-win solutions.

Being open to many viewpoints, cultures, and lifestyles.

Participating in wide-ranging activities that support self-development and positive business

relationships.

Equal Employment Opportunity

AT&T provides Equal Employment Opportunity for all employees and applicants in the

administration of personnel policies such as:

•

•

•

•

•

•

•

•

•

Appraisals

Benefits and privileges of employment

Compensation and benefits

Disciplinary actions

Recruiting, hiring, placements, upgrades, promotions, and lateral movement

Social and recreational programs

Terminations of employment, layoffs, and recalls

Training and educational assistance

Working conditions

It shall be a violation of this policy for an employee to administer these personnel policies in a

discriminatory manner.

July 25, 2022

° 2021 AT&T Intellectual Property. AT&T, Globe logo, and DIRECTV are registered trademarks and service marks of

AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

Page 4

Sat&t

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

The American With Disabilities Act

The Americans with Disabilities Act (ADA) is a federal law that prohibits discrimination against

individuals with disabilities. AT&T’s policies provide reasonable accommodations to qualified

employees with disabilities when medical restrictions preclude them from performing an essential

function of their current or desired job, unless the accommodation poses an undue business

hardship for AT&T. Under the law and these policies, AT&T, through the Integrated Disability

Service Center (IDSC), engages in an interactive process with employees who may require a

reasonable accommodation of a disability as defined under the law. The IDSC has established

processes and procedures regarding accommodating disabilities. Supervisors of employees who

have requested an accommodation of a disability should refer such employees to the IDSC at 866276-2278. In certain cases, a leave may be appropriate as an accommodation. Supervisors should

consult Human Resources for advice in these situations.

Confidentiality

Confidentiality is assured for applicants and employees regarding medical information, and it will

be kept confidential except to the following extent: Supervisors and managers may be informed

regarding necessary restrictions on the work or duties of the employee and any necessary

reasonable accommodations. First aid and safety personnel may be informed where and to the

extent appropriate if the disability might require emergency treatment or assistance during

evacuations. Government officials who conduct compliance reviews may be informed.

All persons with responsibilities that may require information about the disability, physical or

mental, are advised to treat and protect the information as strictly confidential.

More information regarding the job accommodation process may be found at the following link:

https://hronestop.web.att.com/group/hr-onestop/jobaccommodations .

Pregnancy Discrimination

It is illegal and in violation of this policy to discriminate against or harass an employee because of

pregnancy. Pregnancy discrimination involves treating a pregnant employee unfavorably because

of pregnancy, childbirth, or other medical condition related to pregnancy or childbirth, including

but not limited to lactation. Employees who are disabled by pregnancy, childbirth, or related

medical conditions are entitled to apply for applicable disability benefits.

Religious Discrimination

AT&T’s commitment to diversity extends to its commitment to respecting the religious beliefs of

its employees. It is illegal and in violation of this policy to discriminate or to harass an employee

because of that employee’s sincerely held religious beliefs. AT&T’s policies provide reasonable

accommodations where an employee sincerely held religious beliefs or practices are impacted by

job requirements, unless the accommodation imposes an undue business hardship for AT&T.

Supervisors of employees who request a religious accommodation should consult with Human

Resources for guidance.

July 25, 2022

® 2021 AT&T Intellectual Property. AT&T, Globe logo, and DIRECTV are registered trademarks and service marks of

AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

Page 5

^AT&T

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

Military Status

AT&T respects and supports its employees who serve in the uniformed services. AT&T employees

called to active duty may apply for a military service leave of absence under the Company’s

applicable leave policies.

Harassment Policy

The Company prohibits all forms of harassment while working on behalf of AT&T. This includes all

harassing behavior, whether physical, verbal, written, printed, or displayed as inappropriate

objects or images. Attire, social media posts, jokes, gestures, comments, or other conduct that

represents hateful or offensive viewpoints is inconsistent with our values and will not be

tolerated. Employees are prohibited from using any Company property, including computers,

mobile phones, or any other devices, to view, send, or receive offensive material.

In addition, employees are never permitted to display offensive material in the workplace,

whether on Company or personal devices. All offensive materials are prohibited, including but not

limited to material offensive to another person’s gender, race, or other characteristic listed in the

Introduction and Policy Statement.

AT&T does not tolerate any form of harassment, including sexual harassment. Sexual harassment

is specifically prohibited in the workplace. In order to eliminate sexual harassment in the

workplace, AT&T prohibits all unprofessional behaviors of sexual or intimate nature including

some that may go beyond the legal definition of sexual harassment.

What is Sexual Harassment?

Sexual harassment may involve unwelcome romantic or sexual advances, requests for sexual

favors, and/or visual materials, verbal comments, or physical contact of a sexual nature,

regardless of gender. Involved parties, either victim or harasser, could be a co-worker,

subordinate, manager/supervisor, contractor, or even a customer.

Such conduct is a violation of this policy, even in instances where the offending employee may

have acted jokingly. Such communications, comments, actions of a sexual nature, or unwelcome

advances are prohibited at AT&T, whether or not other employees were offended.

The most obvious examples of sexual harassment involve physical behavior or physical contact.

The following is a non-exhaustive list of physical behaviors that may be considered offensive:

•

•

•

Touching an individual by massaging their neck or shoulders, hugging, kissing, patting,

pinching, fondling, or touching/pulling an individual’s clothing or hair.

Physical gestures that imply a sexual act or sexual anatomy, touching oneself in a sexual

manner.

Brushing up against another person, standing too close, or lingering.

July 25,2022

0 2021 AT&T Intellectual Property. AT&T, Globe logo, and DIRECTV are registered trademarks and service marks of

AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

Page 6

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

However, sexually harassing behavior does not always involve physical contact. The following is a

non-exhaustive list of examples of verbal and non-verbal/visual behavior that may be considered

offensive:

•

•

•

•

•

•

•

•

Suggestive behavior such as “elevator eyes” (looking a person up and down), leering, staring,

sexual gestures, whistling, catcalls, winking, throwing kisses, making kissing sounds, howling,

groaning, or smacking/licking lips.

Sexual comments or innuendoes about clothing, anatomy, appearance, or sexual jokes or

stories.

Discussions or inquiries about sexual fantasy, preferences, history, or sex life about self or

others.

Displaying pictures, objects, reading materials, or other materials that are sexually suggestive

or demeaning. This includes any sexual materials on personal or company-owned computers

or devices, shared in the workplace.

Repeated invitations and/or pressuring for dates or sexual favors; harassing phone calls, emails, or other communication.

Giving personal gifts that imply an intimate relationship.

Sending sexually suggestive communications (e.g., instant messaging, Company message

portals and/or devices, notes, letters, texts, e-mails); displaying or transmitting suggestive

visual materials (e.g., pictures, calendars, posters).

Stalking, following, or blocking an individual’s path

In addition, it is a violation of this policy, and the law, for any employee to ever state, imply, or

suggest that dating or engaging in sexual conduct with another employee could result in a

workplace benefit such as a promotion, raise, better terms and conditions of employment - or

that a refusal to date or engage in sexual conduct will negatively affect a person’s conditions of

employment or career.

AT&T’s EEO and Harassment Policies and Code of Business Conduct (COBC) rules apply in the

workplace and in work-related settings outside the workplace, such as business trips, customer

visits, social events, or other functions. AT&T also does not tolerate such conduct from outside

vendors and other providers of goods or services to AT&T when they are working in AT&T-related

settings.

Personal Relationships Policy

In accordance with AT&T’s EEO and Harassment and Conflict of Interest Policies, a dating

relationship, romantic relationship, or any similar special personal relationship, including

friendships, that give the appearance of providing preferential treatment, should never exist

between a supervisor and an employee for whom the supervisor has some responsibility,

including employees who report directly or indirectly within that supervisor's chain of command.

In other words, a manager, and another employee above or below that manager in the same chain

of command, even if not directly above or below that manager, may not have a romantic or other

close, personal relationship. This includes any manager who has influence over the employee’s

July 25, 2022

® 2021 AT&T Intellectual Property. AT&T, Globe logo, and DIRECTV are registered trademarks and service marks of

AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

Page 7

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

work, productivity, or terms and conditions of employment, such as an employee’s trainer,

manager who regularly fills in as a relieving manager over the employee, or a manager who has

any input regarding the employee’s performance. Moreover, such a relationship should never exist

between an AT&T employee and a vendor employee where that AT&T employee has some

responsibility for recommending the services of or interacting with that vendor or providing input

on the vendor’s work. These relationships can interfere with the supervisor's independent

judgment, create employee morale problems, ethical issues, or conflict of interest, and may create

a hostile work environment.

To avoid these problems and to foster a positive team environment, all personal relationships that

may create a potential conflict or the appearance of a conflict under this policy must be reported

immediately to Human Resources. After reviewing the facts, the Company will take appropriate

action, which could include transfer of either employee through job reassignment or voluntary

resignation. Failure to disclose the relationship immediately or comply with the Company’s

decision is a violation of the EEO and Harassment Policies, the Code of Business Conduct (COBC),

and Conflict of Interest Policy, and may result in discipline up to and including dismissal.

More information may be found at the following link:

https://hronestop.web.att.com/documents/33859/388425780/Conflict+of+lnterest+Policy.pdf/6

5b60b50-f31d-370f-9df4-94eee4ec5306.

Sexual Harassment Prevention Training

All AT&T employees are required to timely and successfully complete anti-harassment education

courses, which the Company provides from time to time. More information about the training

requirements for specific states may be found at: https://hronestop.web.att.com/group/hronestop/state-requirements-harassment-training .

Reporting Sexual Harassment

As discussed above, employees should report allegations of harassment, including sexual

harassment, to a supervisor, any manager, Human Resources, directly to the AT&T Hotline @ 1888-871-2622, by selecting option 2, or the AT&T Hotline Web Reporting site at:

https://app.mycompliancereport.com/report?cid=ATT

The Company investigates any incident of harassment reported under this policy. Accordingly, it is

imperative that employees give the Company the opportunity to investigate and resolve any

reported concerns. The Company promptly undertakes or directs an effective, thorough, and

objective investigation of the harassment allegations.

If the Company determines that an employee has engaged in conduct in violation of this policy,

the Company shall take prompt, remedial action commensurate with the circumstance, up to and

including termination of employment, against those who engaged in the policy violation.

July 25, 2022

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Page 8

Gat&t

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

The Company prohibits any retaliation against any employee who complains of alleged

inappropriate harassment or who participates in an investigation. Allegations of retaliation will be

investigated, and appropriate remedial action will be taken. Any individual engaging in retaliatory

behavior will be subject to disciplinary action, which may include termination of employment. For

any suspected retaliation concerns, contact the AT&T Hotline immediately.

Report concerns via AT&T Hotline @ 1-888-871-2622 or the AT&T Hotline Web Reporting site

https://app.mycompliancereport.com/report?cid=ATT

Additional Complaint Procedures

In addition to internal Company reporting methods, employees have the right to file a charge of

discrimination with a federal, state, or local agency. The United States Equal Employment

Opportunity Commission enforces federal anti- discrimination laws. All external charges of

discrimination in which the Company is identified as a Respondent, including charges received by

a Company field location, should be immediately directed to the EEO group (which is responsible

for all Company communication with the agencies) at eeooffice@att.com.

For Illinois Employees and Their Supervisors

In addition to the reporting channels identified above, Illinois employees may also report

allegations of discrimination or sexual harassment to the Illinois Secretary of State Inspector

General’s Office {(217) 785-2012 or (630) 424-2564}, the Department of Human Rights {Chicago

office: (312) 814-6200 or Springfield office (217) 785-5100}, or the state of Illinois Sexual

Harassment & Discrimination Helpline at 1-877-236-7703. Whistleblower protections are also

available under the Illinois Whistleblower Act and the Illinois Human Rights Act.

For California Employees and Their Supervisors

California state law requires employers to distribute to employees in California certain

information about sexual harassment. This information is available on the brochure titled “Sexual

Harassment: The Facts About Sexual Harassment” (DFEH-185) and is available at the following link

https://www.eaccess.att.com/hronestop/documents/33859/10774655/CA_SexualHarassmentPa%20mphlet.pdf

/1238b39c-77a0-2049-9e4b-06d7cbaeb641. Please note that all California employees and their

supervisors are required to access this brochure and review the information.

Supervisors, managers, co-workers and third parties are prohibited from engaging in unlawful

behavior under the California Fair Employment and Housing Act.

California employees or job applicants who believe that they have been sexually harassed may file

a complaint with the California Department of Fair Employment and Housing (DFEH) within one

year of the alleged harassment. For more information, contact the DFEH toll free at (800) 8841684, Sacramento and out of state at (916) 478-7200, or TTY at (800) 700-2320. You may also

contact the DFEH via email at contact.center@dfeh.ca.gov or visit the DFEH’s Web site at the

following link: https://www.dfeh.ca.gov/.

July 25, 2022

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Page 9

AT&T

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

California law requires employers to provide employees notice of their rights and obligations

under the Fair Employment and Housing Act with respect to pregnancy, childbirth, and related

medical conditions. This information is available in Notice B, "Family Care and Medical Leave and

Pregnancy Disability Leave” and is available at the following link: https://www.eaccess.att.com/hronestop/documents/33859/10774655/CA_Rights_Obligations_Pregnant_Emplo

yee.pdf/4338c358-b600-.51c1-b9a4-c1b311eb2eb2. Please note that all California employees and

their supervisors are required to access this notice and review the information.

For New Jersey Employees and Their Supervisors

The state of New Jersey requires that all employers notify employees annually of the New Jersey

Gender Equity in Pay, Compensation, Benefits or Other Terms or Conditions of Employment

Notification. New Jersey and federal laws prohibit employers from discriminating against an

individual with respect to his/her pay, compensation, benefits, or terms, conditions, or privileges

of employment because of the individual’s gender. This information is available on the NJ Gender

Equity notification and is available at the following link: https://www.eaccess.att.com/hronestop/documents/33859/10774655/NJ_Gender_Equity.pdf/c538fad7-4af61671-7c4d-_179754e945b4.

For New York Employees and Their Supervisors

In addition to the reporting channels identified above, New York employees may also report

allegations of sexual harassment to the New York State Division of Human Rights (718-741-8400

or www.dhr.ny.gov), may file a complaint in the New York State Supreme Court or call 1-800-4272773 to receive free legal counseling regarding any complaint of workplace sexual harassment or

to submit a complaint regarding such harassment. Employees who work in New York City may

also file complaints of sexual harassment with the New York City Commission on Human Rights

(718-722-3131 or https://www1.nyc.gov/site/cchr/index.page ).

For Delaware Employees and Their Supervisors

Delaware state law requires employers to distribute to employees in Delaware certain information

about sexual harassment. This information is available on the brochure titled "Delaware Sexual

Harassment Notice,” available at

https://hronestop.web. att.com/documents/33859/10774655/Delaware+Sexual+Harassment+Not

ice.pdf/c6e6ebaa-c2a2-_98ad-01ac-b4377fb04bae.

For Oregon Employees and Their Supervisors

In addition to the policy above, the state of Oregon prohibits an employer from requiring or

coercing an employee or prospective employee to enter into a nondisclosure or

nondisparagement agreement or any other provision which has the purpose or effect of

preventing the employee from disclosing or discussing conduct that constitutes discrimination,

including sexual harassment or sexual assault.

Oregon employees who have made a complaint may voluntarily request to enter into a

nondisclosure or nondisparagement agreement and the employee has at least seven days to

revoke that agreement.

July 25.2022

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Page 10

AT&T

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

The state of Oregon defines sexual assault as unwanted conduct of a sexual nature that is

inflicted upon a person or compelled through the use of physical force, manipulation, threat, or

intimidation.

The statute of limitations to file a complaint for Oregon residents is within five years of the

occurrence.

For Puerto Rico Employees and Their Supervisors

In addition to the reporting channels identified above, Puerto Rico law requires employers to

provide notice to employees in Puerto Rico regarding its workplace harassment law. This law’s

provisions are available in Spanish at the following link: ley-90-2020.pdf (att.com). The law’s

provisions are also available in English at: HB 306.pdf (att.com).

Frequently Asked Questions

Your Responsibility as an Employee, Contractor and/or Supervisor

Q. Are all AT&T employees and contractors responsible for ensuring their actions are conducted

in accordance with AT&T’s Equal Employment Opportunity (EEO) and Harassment Policies?

A. Yes. Failure to comply with these policies may result in disciplinary action, which can include

dismissal even for a first offense. Supervisors are responsible for ensuring the work

environment is free of discrimination and harassment.

Q. If you believe you have been subjected to discrimination, harassment, and/or retaliation or

have knowledge of conduct prohibited under the Policy, are you responsible for reporting the

matter?

A. Yes. We are all responsible for speaking up if we believe that someone at AT&T has violated

the EEO and Harassment Policies. If a manager observes or receives any reports or allegations

of conduct which could potentially violate the EEO and Harassment Policies, the manager has

a responsibility to report it immediately to Human Resources or the AT&T Hotline. Report

concerns via AT&T Hotline @ 1-888-871-2622 or the AT&T Hotline Web Reporting site

https://app.mycompliancereport.com/report?cid=ATT

Non-Retaliation Policy

Q. Are employees who raise concerns or who participate in an internal investigation protected

from retaliation?

A. Yes. Any individual who seeks advice, raises a concern, or reports an EEO concern is following

the EEO and Harassment Policies. AT&T will not tolerate retaliation against such a person.

July 25,2022

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Page 11

AT&T

ATTACHMENT 1

Human Resources, EEO, and Ethics | EEO and Harassment Policies

Internal Investigations

Q. Are employees guaranteed complete confidentiality or anonymity?

A. Investigators will maintain confidentiality or anonymity to the extent allowable by law and

where the confidentiality and anonymity does not impede the integrity of the investigation.

Sexual and Other Harassment

Q. Is it okay for a supervisor and a subordinate (including contractors) to have a close personal

relationship or a dating relationship?

A. No. Any dating relationship or close personal relationship within the chain of command is

prohibited. This also includes a supervisor who has influence over an employee’s work,

productivity, or terms and conditions of employment. Failure by either party to report

the relationship immediately is a violation of the policy.

Q. Can sexual harassment occur between individuals of the same sex?

A. Yes. Sexual harassment can happen between individuals of the same sex as well as the

opposite sex.

Q. Are jokes about sex, race, age, religion, ethnicity, or any other jokes made at the expense

of others appropriate in the workplace?

A. No. Jokes made at the expense of any person or class of persons are prohibited.

Disability

Q. Does AT&T accommodate disabilities?

A. Yes. It is AT&T’s policy to provide reasonable accommodations to qualified employees with

disabilities when medical restrictions preclude them from performing an essential

function of their current or desired job, unless the accommodation poses an undue

business hardship for AT&T.

July 25. 2022

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Page 12

ATTACHMENT 2

AT&T

Code of Business Conduct

March 2021

A Message from AT&T CEO John Stankey

To All AT&T Employees:

Our purpose at AT&T is to create connection - with each other, with what people need to

thrive and with the stories and experiences that matter.

Doing so at the highest levels requires many different talents, backgrounds and perspectives.

But the foundational requirement is a commitment to integrity.

Ethical behavior is a part of everyone’s DNA at AT&T, without exception or compromise. That’s

where our Code of Business Conduct comes in. The Code serves as our roadmap for making

sure we do what’s right in every situation, whether it’s with our customers, our partners, our

stakeholders or each other.

Acting with honesty, integrity and transparency is what our customers expect of us. And it’s

what we should demand from each other.

Thank you for living our values.

John Stankey

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Page 1

ATTACHMENT 2

AT&T

Code of Business Conduct

Introduction

Our mission at AT&T is to inspire human progress through the power of communication and

entertainment To fulfill that mission, each of us must take personal responsibility for acting

ethically and protecting our longstanding reputation.

Our Code of Business Conduct lays out our commitment to our Values and the Code itself, and

to live true by each other, our customers, our shareholders, and to all who have a stake in

AT&T’s success.

While no Code of Business Conduct can provide rules that cover every situation or challenge,

ours serves as a guide for each of us. It reinforces our commitment to “just do the right thing”

and empowers us to take action and make the right decisions, even when they’re challenging.

We protect all we believe in and the values we stand for by keeping our commitments, acting

with integrity, and making the right decisions.

Applicability

The Code of Business Conduct applies to all employees of AT&T Corporate, AT&T

Communications, and AT&T Latin America.

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Page 2

ATTACHMENT 2

AT&T

Code of Business Conduct

Our Commitment to our Values

We live true to our Values.

Live true. Do the right thing, no compromise. Think big. Innovate and get there first.

Pursue excellence. In everything, every time. Inspire imagination. Give people what they

don’t expect. Be there. When customers & colleagues need you most. Stand for equality.

Speak with your actions. Embrace freedom. Press, speech, beliefs. Make a difference.

Impact your world.

We respect our Values and apply them to our work every day.

As AT&T employees, we are part of a long tradition of employees who have conducted

themselves in an ethical manner that reflects positively on the Company. We focus on doing

the right thing - upholding our shared commitment to complying with laws, regulations, and

internal policies. Acting ethically is every employee’s responsibility. This extends beyond our

workday. Employees may be held accountable for actions, on or off the job, that could impair

work performance or affect the company’s reputation or business interests. We are

accountable for being familiar with and following this Code and the Company’s policies and

guidelines. We understand that violations may result in discipline, up to and including

termination of employment. We know that no one has the authority to direct any employee

to violate the law, this Code, or AT&T’s policies.

The Code of Business Conduct forms a strong foundation for ethical business conduct, but it

is not a substitute for good judgment and cannot address every situation we may

encounter. If we are ever unsure about what to do in a particular situation, we must ask

ourselves a few critical questions, as outlined in AT&T’s Ethical Decision-Making Model. If the

answer to any of the questions in the model is “no,” we must not proceed.

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Page 3

ATTACHMENT 2

AT&T

Code of Business Conduct

Uwe Tiru®!

Do the right thing, no compromise.

When faced with a

decision, ask yourself...

I Is it consistent

with Our Values?

f Does it comply^

with AT&T policies

and the law?

Does it feel right?

Would I feel

ok if it made

the news?

NO ON ANY

Unsure?

Speak with your supervisor, HR or

Ask Compliance (844-533-2248 - US, 1-404-898-7199 - non-US).

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Page 4

ATTACHMENT 2

AT&T

Code of Business Conduct

Our Commitment to our Values (continued)

We know our reporting rights and responsibilities.

We report when we observe a violation, or what we believe to be a violation of the law, this

Code, Company policies or guidelines. We do not knowingly and willfully make false, fictitious

statements or representations. To facilitate reporting, the Company maintains a number of

reporting outlets, several of which allow anonymous reporting (where permitted by law):

•

•

•

•

Your supervisor or anyone else in your chain of command

Human Resources

Your Business Unit attorney or Legal Department

AT&T Reporting Hotlines or Websites

The Code is not intended to limit our right to report any concerns to a government agency

or to participate in government investigations.

Supervisors know our responsibilities.

As supervisors, we demonstrate our personal commitment to the Company’s standards and

foster an environment where employees feel comfortable asking questions and reporting

issues. We also ensure our direct reports are aware of their obligations under the Code.

We are alert to potential unlawful conduct in our department and take steps to prevent such

conduct from occurring. We advise the appropriate channels of potential violations of the

Company’s standards that come to our attention.

We cooperate with investigations.

AT&T investigates possible violations of the law, this Code, Company policies and guidelines,

as well as any other behavior that we believe is unethical and/or could harm the Company,

its employees, our property, or others. We cooperate fully with the Company’s investigations.

We do not retaliate.

AT&T does not tolerate retaliation against those who seek advice, raise a question, or report

suspected violations.

We know where to find additional guidance.

We can find more detailed information to help foster an ethical environment through our

Company policy websites

• AT&T Corporate and AT&T Communications

• Mexico

• Vrio

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Page 5

ATTACHMENT 2

AT&T

Code of Business Conduct

We can also contact Ask Compliance, our supervisors, Human Resources, or Legal with any

questions related to the Code, Company policy or guidance, and ethics in general.

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Page 6

ATTACHMENT 2

AT&T

Code of Business Conduct

Our Commitment to Love True

We do the right thing, no compromise.

Ethics and integrity are foundational to who we are at AT&T. For more than 140 years, these

principles have guided our interactions with our customers, our shareowners, and each other.

While AT&T continues to transform the world of media and entertainment, communications,

and technology, our commitment to running a business rooted in ethics and integrity will never

change. Doing the right thing without compromise is the responsibility of every employee.

That means we do the right thing by shareholders, customers, communities, suppliers, public

authorities, and our fellow employees. They can trust that we do what we say.

We treat each other with respect and do not permit intimidation,

discrimination or harassment.

AT&T employees are protected from discrimination on the basis of race, color, religion,

religious creed, national origin, ancestry, age, sex, sexual orientation, gender, gender identity,

gender expression, physical disability, mental disability, pregnancy, medical condition, genetic

information, marital status, citizenship status, military status, veteran status, or any other

characteristic protected by law.

When the actions of some cause others to feel intimidated, offended, or to lose dignity, all of us

suffer. We must treat each other courteously and professionally. We insist on a positive work

environment and speak out if that goal is compromised by anyone. This extends beyond our

workday. Employees may be held accountable for actions outside of work that could impair

work performance or affect the company’s reputation or business interests.

We support a work environment that is inclusive and diverse.

Differing viewpoints that we each bring to the workplace challenge us collectively to think

more broadly and allow us to be more creative in the products and processes we develop. We

realize that the world we serve is diverse in its social customs and cultural traditions, and we

respect and embrace those differences.

We create a safe and secure place to work.

The importance of working safely has been part of our heritage for over a century. We are

committed to providing a safe working environment. When public safety is at issue, we take

reasonable precautions to safeguard the public, as well as our employees and customers. We

stay current on laws, regulations, and practices related to the safety and health of the

workplace and our products and services.

We comply with those legal and Company requirements. In addition, we do not tolerate or

permit threats, violence, or other disruptive behavior in our work environments. Our concern

for a safe workplace extends to protecting information about us that the Company maintains.

We hold the personal information of our employees, retirees, and their beneficiaries in strict

confidence.

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Page 7

ATTACHMENT 2

AT&T

Code of Business Conduct

Our Commitment to Our Business and Our

Shareholders

We work lawfully and in accordance with regulations that apply to us.

We are diligent about following the laws and regulations that relate to our business. There are

no shortcuts. We do not expose the business to harm by failing to follow any rules that may

apply to us. The Company’s policies and procedures support and clarify these laws and

regulations and facilitate our compliance. We adjust our practices as appropriate to comply

with the laws and requirements of our global markets and our diverse operations.

We comply with global trade laws and regulations.

We comply with all applicable international trade laws and regulations. These laws and

regulations apply to the import and export of goods and services, such as hardware,

software and technology (including technology downloads); sanctioned countries and

restricted parties; and international boycotts. We consult our Legal Department before

proceeding with any international transaction, shipment or import that may be covered by

these laws.

We protect assets, confidential information and intellectual property.

All AT&T’s assets, from a physical asset such as a truck or a tower to an intellectual property

asset such as material protected by copyright, trade and service marks, a patent or trade

secret, are essential tools for our success. We are good stewards of the assets we use every

day. We are personally responsible for the proper use of assets in our care and preventing their

loss. This includes protecting ideas, research, inventions, media, and our brands. We protect

confidential and proprietary information and prevent its improper, unauthorized, or

inadvertent disclosure. We will also not misuse the assets or intellectual property of others.

We manage records and information appropriately.

We create, use, retain, and dispose of our business records and information carefully and in

accordance with the Company’s Records and Information Management policies and schedules.

We follow the Finance and Legal Department’s instruction when records should be held for

potential or pending litigation, investigations, or in response to court orders.

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Page 8

ATTACHMENT 2

AT&T

Code of Business Conduct

Our Commitment to Our Business and Our

Shareholders (continued)

We use electronic communications responsibly.

Communication, in its many forms, should be appropriate and respectful, both inside and

outside of work. The communications systems in place at AT&T are primarily for business use.

We may use these systems only occasionally for personal e-mail or Internet access, but we do

not allow this use to be disruptive to the needs of the business. We do not use these systems

to access or distribute obscene or offensive media.

We avoid and resolve conflicts of interest.

When acting on behalf of AT&T, we put the Company’s interests ahead of our own personal

gain. This means we do not allow our own interest or our family or other relationships to

influence the decisions we make on behalf of the Company. Conflicts of interest can

undermine our business judgment and expose the Company to risk. We avoid actual, potential,

and appearances of conflicts of interest and disclose and resolve them promptly.

We do not allow our business decisions to be influenced by gifts, favors, or hospitality from

others. Accepting or offering gifts, favors, or entertainment can create a conflict, result in the

appearance of a conflict, and, in some cases, violate the law. If we have any doubts, we seek

guidance before accepting or offering any material gifts, favors, or entertainment.

We do not compete with the Company. We also do not take a business opportunity discovered

through our affiliation with the Company, unless the Company has already been offered the

opportunity, turned it down, and approves the business opportunity.

We strive to do business with ethical suppliers.

We try to do business with suppliers, third parties, and business partners that enhance our level

of service and provide products and services of quality. We seek suppliers who share our

commitments to ethical and sustainable business practices, human rights (including labor

rights), and diversity.

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Page 9

ATTACHMENT 2

AT&T

Code of Business Conduct

Our Commitment to Our Customers

We follow ethical sales practices.

We earn and preserve our customers’ trust by treating them with honesty and integrity and in

a professional, courteous manner. We fairly represent our products and services to them. We

listen to our customers and challenge ourselves to find new ways to deliver a unique customer

experience. We deliver what we promise. We do not provide goods or services that customers

did not authorize.

Sometimes our customers are our competitors and suppliers as well. In those situations, we

serve them in the same professional manner we would extend to any customer.

We comply with regulations that apply to government customers.

Doing business with certain government entities requires adhering to strict and sometimes

unique regulations. We are trained about these rules, and we follow these regulations in our

interaction with governments. We are committed to this enhanced level of diligence for these

governmental customers. We follow instructions to seek advice immediately from our internal

experts whenever we are in doubt about any activity.

We guard the privacy of our customers’ communications.

We protect the privacy of our customers’ communications. Not only do our customers demand

this, but the law requires it. Consistent with this principle, although we comply with

government requests for customer communications, we do so only to the extent required by

law. Maintaining the confidentiality of communications is, and always has been, a crucial part of

our business.

We protect the information about our customers that they entrust to us.

AT&T possesses sensitive, detailed information about our customers who rely on AT&T to

safeguard that information. Laws and regulations tell us how to treat such data. Any

inappropriate use of confidential customer information violates our customers’ trust and may

also violate a law or regulation. Preserving our customers’ trust by safeguarding their private

data is critical.

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AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

Page 10

ATTACHMENT 2

AT&T

Code of Business Conduct

Our Commitment to Make a Difference

We support community activities.

We participate in activities to make our communities better places to live, work, and grow. We

strengthen our communities by providing good jobs, donating our time and talents, supporting

underserved populations, and promoting education programs that create economic

opportunity.

We support political involvement.

AT&T encourages us to participate in the political process. We vote, volunteer our time,

contribute to the candidates we individually support, and hold political office. Because of laws

governing the election process, we conduct personal political activities on our own time and

with our own resources, and we avoid conflicts of interests. We comply with pertinent

campaign laws.

We operate responsibly toward the environment.

We are committed to operate and to provide products and services in an environmentally

responsible and sustainable manner. We follow applicable laws and regulations related to the

environment. We strive to follow best practices and minimize our environmental impact in

ways that are relevant to our business and important to the communities we serve.

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AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

Page 11

ATTACHMENT 2

AT&T

Code of Business Conduct

Our Commitment to Others

We maintain integrity in our financial reporting and business records.

For the sake of our shareholders, creditors, and others, we strive to generate reliable financial

reporting and business records. We are committed to full, fair, timely, accurate, and

understandable disclosure in the reports and documents we file or submit to the U.S. Securities

and Exchange Commission and regulators around the globe. We prepare our business records

and financial reports with integrity and honesty, whether they are externally reported or used

internally to oversee the Company’s operations. We report concerns about financial,

accounting, and auditing matters, as well as issues regarding business records, through

appropriate channels.

We communicate to the public via approved channels.

Only senior leaders, or other individuals expressly authorized by AT&T, speak to the public on

AT&T’s behalf, and they do so through approved channels of communication.

We do not engage in in

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Petition for Writ of Certiorari — Antonio Goodwin, Petitioner v. AT&T Corporation | Frix