FORMAL REJECTION OF FINAL FINDING IN CASE NO. 2510183 (MEDEIROS V. DCP); DEMAND FOR IMMEDIATE VACATUR FOR ADMINISTRATIVE FRAUD; AND NOTICE OF MANDATORY FEDERAL SELF-REPORTING OBLIGATIONS

Formal Rejection and Demand Letter: Exposing Administrative Fraud in CHRO Case No. 2510183 As a transparency advocate and whistleblower in Connecticut, I'm publishing this formal letter as an Article to amplify accountability in civil rights enforcement. This document rejects a flawed CHRO finding, demands vacatur for fraud, and notifies federal oversight. Share to hold agencies responsible. TO: Commission on Human Rights and Opportunities (CHRO) Attn: Investigator Jo Keogh and Legal Division 450 Columbus Boulevard, Suite 2 Hartford, CT 06103 Email: CHRO.Intake@ct.gov TO: State of Connecticut, Department of Consumer Protection (DCP) Attn: Commissioner and Legal Director Paulette Annon 450 Columbus Boulevard, Suite 901 Hartford, CT 06103 Email: paulette.g.annon@ct.gov AND TO: Office of the Attorney General Attn: AAG Rebecca Quinn 165 Capitol Avenue Hartford, CT 06106 Email: Rebecca.Quinn@ct.gov CC: U.S. Department of Justice, Civil Rights Division (Disability Rights Section) U.S. Department of Health and Human Services, Office for Civil Rights (OCR) U.S. Office of Special Counsel (OSC) RE: FORMAL REJECTION OF FINAL FINDING IN CASE NO. 2510183 (MEDEIROS V. DCP); DEMAND FOR IMMEDIATE VACATUR FOR ADMINISTRATIVE FRAUD; AND NOTICE OF MANDATORY FEDERAL SELF-REPORTING OBLIGATIONS Date: January 28, 2026 I. PRELIMINARY STATEMENT: THE PROCEEDING IS VOID AB INITIO DUE TO MATERIAL FALSITY The Final Finding of No Reasonable Cause issued on January 22, 2026, is legally void ab initio because it is predicated on a demonstrable falsehood regarding the administrative record. Specifically, the Investigator certified: "No comments were received, thus no changes were made to the draft finding." The Record Proves Administrative Fraud: Submission: On December 29, 2025, at 3:34 PM EST, I served a "Formal Rebuttal to Draft Findings" via email to Investigator Keogh, AAG Quinn, and Assistant Legal Director Annon. The delivery receipt confirms this message was "Relayed" and delivery was "complete". Acknowledgment: On January 5, 2026, at 10:18 AM EST, Investigator Keogh explicitly acknowledged receipt of this rebuttal via email, stating: "Received, thank you.". The issuance of a Final Finding claiming "no comments were received" seventeen days after acknowledging receipt of those comments constitutes a deliberate suppression of evidence and a material breach of due process under the Fourteenth Amendment and the Connecticut Uniform Administrative Procedure Act (UAPA). I hereby demand that the adverse finding be immediately VACATED and the investigation reopened to incorporate the unrefuted evidence of discrimination and retaliation detailed below. II. DECONSTRUCTING THE PRETEXTUAL DEFENSES The Final Finding relies on four specific legal fabrications to evade jurisdiction. These defenses are refuted by the Respondent's own admissions and binding federal authority. DEFENSE 1: The "Guest Presenter" Immunity Fallacy CHRO Claim: DCP was merely a "guest presenter" at a third-party (BIAC) event and thus bore no responsibility for accommodations. The Facts: DCP officials (Director Brown, Investigator Barton) appeared in their official capacity to disseminate public policy regarding Homemaker Companion Agency (HCA) regulations and audits. Governing Law: Under Title II of the ADA (28 C.F.R. § 35.102), a public entity is liable for discrimination in any "service, program, or activity" it conducts, regardless of the venue. A state agency cannot "contract away" its civil rights obligations by hosting official business at a private venue. By presenting official state policy, DCP transformed the meeting into a covered activity. Violation: Failure to ensure program accessibility (28 C.F.R. § 35.149). DEFENSE 2: The "Undercover Investigator" Security Fabrication CHRO Claim: Recording was denied because Investigator Barton is "undercover" and recording him poses a "security risk". The Facts: This defense is factually incoherent. Investigator Barton presented publicly at a scheduled, advertised conference. A public official cannot claim "undercover status" while standing at a podium giving a public lecture. Legal Reality: This is a post hoc rationalization used to deny a reasonable accommodation (recording as a memory aid for TBI). Violation: Pretextual denial of reasonable modification (28 C.F.R. § 35.130(b)(7)). DEFENSE 3: The "Unwritten Policy" Admission (Constructive Denial) CHRO Claim: DCP has a "longstanding unwritten policy" against video recording. The Smoking Gun: On October 9, 2025, Assistant Attorney General Rebecca Quinn admitted in writing: "DCP states that there is no written policy on recording investigator presentations per se". Governing Law: The enforcement of an ad hoc, unwritten preference to override a federally protected civil right (ADA accommodation) violates the Supremacy Clause and the Administrative Procedure Act (APA). An agency cannot enforce a "policy" that has never been promulgated, especially to deny disability rights. Violation: Arbitrary and Capricious agency action; Denial of Effective Communication. DEFENSE 4: Procedural Irregularity & Ex Parte Communication The Fact: On October 21, 2025, Investigator Keogh removed AAG Quinn (Counsel for Respondent) from the email thread. Legal Reality: This manipulation of the service list creates an improper ex parte channel and suggests an attempt to conduct proceedings off the record or conceal evidence from the Respondent's own legal counsel. Violation: Breach of administrative due process and ethical standards. III. NOTICE OF MANDATORY FEDERAL COMPLIANCE REPORTING OBLIGATIONS As a "Public Entity" receiving federal funds (Medicaid/CMS), DCP is strictly bound by Title II of the ADA and Section 504 of the Rehabilitation Act. My complaint and this rebuttal constitute formal "Notice of Non-Compliance." You are legally obligated to self-report the following to your Federal Oversight Officers: To the U.S. Department of Justice (Civil Rights Division): Reportable Event: The enforcement of an "unwritten policy" to deny ADA accommodations (recording) at a public agency presentation. Regulation: 28 C.F.R. § 35.105 (Self-Evaluation). You must disclose policies that do not comply with Title II requirements. To the U.S. Department of Health & Human Services (HHS-OCR): Reportable Event: Denial of "Effective Communication" for a TBI survivor (refusal of email-only communication; refusal of recording aid). Regulation: 45 C.F.R. § 84.4. You must report unresolved grievances regarding access to federally funded programs. IV. DEMANDS FOR PRESERVATION, REMEDY, AND COMPLIANCE IMMEDIATE VACATUR: The Final Finding must be VACATED immediately as it relies on the false certification that "no comments were received." The record must be corrected to include my December 29, 2025 rebuttal. LITIGATION HOLD: Preserve all server logs and metadata associated with the email address Jo.Keogh@ct.gov and the shared mailboxes for CHRO.Capitol and Paulette.G.Annon for the dates December 29, 2025 and January 5, 2026. The "Relayed" status on my delivery receipt proves the email entered your system; any claim to the contrary implies spoliation. PROOF OF POLICY: Produce the "basis" for the unwritten recording policy referenced by AAG Quinn on Oct 9, 2025, or admit that no such legal authority exists. GOVERN YOURSELVES ACCORDINGLY. Sincerely, David Medeiros Founder, ABI Resources Attachments: Exhibit A: Proof of Service (Relayed Delivery Receipt) dated Dec 29, 2025 Exhibit B: Investigator Keogh's Email Acknowledgment dated Jan 5, 2026 Exhibit C: AAG Quinn Email Admitting "No Written Policy" dated Oct 9, 2025 Exhibit D: Email Thread Showing Ex Parte Removal of Counsel (Oct 21, 2025) Exhibit E: Draft Finding of No Reasonable Cause dated Dec 12, 2025