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
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
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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
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Please do not respond to this email. This mailbox is not monitored, and you will not receive a
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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
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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.
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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
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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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12:35
Dylan >
Aug 3, 2022 at 5:23 PM
A
I submitted everything
Okay
32 of 42
Case 2:
34 of 42
12:41
Dylan
Aug 4, 2022 at 7:37PM
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Hello,
The paperwork was
submitted just waiting for all
approval to go through for it
to show on both Att and
Fidelity.
Case 2
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35 Of 42
36 of 42
Case 2
12:43
Dylan >
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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Case 2:23-cv-01950-GMN-DJA
Document 78-1
Filed 04/29/25
Page 3 of 42
Case 2:23-cv-01950-GM|)|2pj(ftilpocument 26
Empl ID:
AAbeta
^AT&T Payrot
1010 Pina Stnot, 7E-K-00
Period BegCnd:
Check Date:
Check Number
Batch Number
St Lou» MO 63101-2015
00644278
Page 001 of 001
OM7fiO22 • 03/12/2022
03/18/2022
2047241780
000000000711
ANTOMO GOODWIN
915 ALPER CENTER DR
UNTT 1307
HENDERSON, NV 89062
722-1787
Tbfa Furled
Ea relate
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
Other
Radwrtlm
ni»
NM BASIC 4012
Purled Teer-te-Oate
81.S381.53-
Ta» Oeductlees
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
oo28i8-a)27i7
Earnings Statement
Empl 10:
AT&TI
Period Beg/End:
Check Date:
Check Number
Beth Number
1010 Pint Strut, 7E-K-08
St Lout MO 88101-2015
00644278
Pape 001 of 001
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
Neers
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
Empi IO:
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Check Date:
Check Number
Batch Number
Ml (XI
St Louit MO 63101-2015
00844278
Page 001 Of 001
04/10^2022 - 04,23^2022
04/2912022
2047261118
000000000782
ANTOMO aOOOWIN
016 ALPER CENTER DR
UNTT 3307
HENDERSON, NV 80082
Eamiaas
Pay Period(*41422-442322)
REGULAR
PREMIUM 0.5
NIGHT DIF REG IM
SUNDAY DIF REG IM
NIGHT DIF OT IM
AOO'1 AWIISTFt) OT PStX
Pay Period(4M122-433122)
COMMISSION*
Pay Period(43*122-*33122)
■ears
Rate
This Period
Other
Tbit
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
fiT TDHF-ltP JUOD*L CfiMP
Taxable Wage* Saaaary
Fed
Social eecurity
Medicare
C18M, 2006. AOP, Wc. Al RitftS
*SEE COMIISSKM/INCEMTIVE/ANARO
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
Alrrua.r-irr,1*. rnl naan
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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
Empi ID:
AT&T
niwi
Mdntt
ioioP^t8tmtt.7E-K-O9
StLou»MO83101-&15
00844278
Punt ooi at 001
Period Befl^nd:
03070022 - 04/590022
Check Me:
Check Number
Balch Number.
04/150022
2047254727
000000000750
ANTONIO GOODWIN
918 ALPER CENTER DR
untt »07
HENDERSON, NV 88062
722-1787
Kantian
Par Per1ed(WI722-044922)
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
Other
Dedectieea
Thia
Peried
Yeer-te-8ete
ARSP BASIC 401K
81.49-
313.27-
Taa Mectlaae
FEO
Secial Security
Tbie Purled Year-te-tate
143.691,297.1491.05674.63-
50.00
Taaable Magee Timii jt
Fed
Social eecurity
Medicare
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
•Mir ADR. UC rOBUCH
LVFmry.npFPEru;
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
NIGHT DIF REG IM
1.6625
SUNDAY OIF REG IM
1.6625
toy Perted(040122-043022)
TAXABLE NON-CASH AMANO*
Other
Thia
BaBertieaa__________ Parted
!*—™
ARSA BASIC 401K
74.65
2.93
15.27
Tax Dedactleaa
FED
Social Security
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:
Check Date:
Check Number
Belch Number
Payroll AMntt
HHOPinoStvt.TE-K-M
St. LjOitia MO 83101-2015
00844278
pIQf 001 of 001
06^2022 - 06/18^2022
06040022
2047286776
000000000676
ANTONIO GOODWIN
616 ALTER CENTER DR
UNIT 3307
HENDERSON, NV 66062
Thia
Earnlee*
Pay Per1od(060522-MU22)
REGULAR
PREMIUM 0.5
NIGHT DIF REG IM
SUNDAY DIF REG IM
NIGHT DIF OT IM
ADO'L ADJUSTED OT PREM
Pay Period(050122-eS3122)
COMMISSION*
Pay Per1od(M01U-«63122)
Rate
Naera
1h1a Period
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
Social Security.
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
^ TEAfiHCTS
Taxable Vafoa linry
Fed
Social aacurity
Medicare
oneXMOS. ADP.Inc. AiR W a
*SEE CONaSSION/INCENTlVE/AMARO
STATEMENT(S) FDR MORE DETAIL
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
Erol 10:
St Louie MO 03101-2015
Period BepAEnd:
Check Me:
Check Number
Batoh Number
Ackfreaa
AT&T Payrot
1010 Pine Street. 7E-K-00
00844278
Pape 001 of 001
07/31/2022 - 08/1372022
0806,2022
2047307172
000000000951
ANTOMO QOOOWW __
915 ALPER CENTER DR
UNTT 3307
____
HENDERSON, NV 89052
land we
tote
Scare
Thia Parled
Pay Parted(873UI-«SUtt)
REGULAR
SUMDAY OIF REG IM
PD TIME III LIEU MOM-CAL
Pay Perted(87M22-«73122)
17.5875
1.7588
17.5875
7.53
7.53
43.00
132.43
13.24
756.26
Other
Bedectleea
ARSP BASIC 401K
Tbit
Parted Teer-te Sata
8.741,147.77-
Taa Dedoctlaaa
Thia Parted Yeer-te-Sata
177.3859.02-
FED
Social Security
*SEE CONaSSION/INCEHTIVE/AHARD
STATEJOT(S) FOR MORE DETAIL
147,000.00
9,114.00
rv -wt 'dov aooi aeeio
2022 SOC SECURITY LIMITS: MAGES:
2022 SOC SECURITY LIMITS: TAXES:
MtfdCP.ucratA*
—
Case 2:23-cv-01950-GMN-DJA
Document 78-1
Filed 04/29/25
Page 10 of 42
Case 2:23-cv-01950Empi ID;
ATA.T
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Pa^otMdmta
i010PlnaStrt*t,7E-K-O6
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Parted Bo^End:
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07/17/2022 - 07/30/2022
Check Data:
Check Number.
Balch Number
08060022
2047304759
000000000042
ANTOMO QOOOW1N
018 ALPER CENTER DR
UNTT 3307
.
HENDERSON, NV 88082
EarsIngs
Pay Poriad(l71722-473022)
REGULAR
PREMIUM 0.5
NIGHT OIF REG IM
SUNDAY DIF REG IM
NIGHT DIF OT IM
SUNDAY DIF OT IM
AOO'L ADJUSTED OT PREM
Pay Per1ed(M«m-M30tt)
CONUSSION*
Ute
Bears
This Perled
17.5875
8.7938
1.7588
1.7588
1.7588
1.7588
81.03
3.20
2.18
15.42
1.20
1.00
1.425.12
28.14
3.83
27.12
2.11
1.76
0.70
Deductlees_______ Period Year-te Bate
ARSP IAS1C 4011
124.101,139.03Tax ladartisai
FEO
Social Security
This Period Year-te-Sate
285.453,087.13134.49-
668.54
key Per1od(M0122-863n2)
/IT
AM1! CflMP
Taxable Mates 1—ury
Fed
Social security
Medicare
2022 SCC SECURITY LIMITS: WAGES:
2022 SOC SECURITY LIMITS: TAXES:
*SEE COMM1SSION/1NCEWTIYE/AHARD
STATEMENT(S) FOR MORE OCTAIL
This Perled Vear-to-8eto
2,045.01
24,038.34
2,169.11
25,177.37
2,169.11
25,177.37
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
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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
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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
2
3
4
5
6
7
8
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10
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11/20/2025
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Text us now
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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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AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.
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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AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.
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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AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.
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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AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.
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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AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.
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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AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.
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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AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.
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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