Exhibit C | Master-Key Sysadmin Access & Management Rebuke

Exhibit C

Madeira Access / Master-Key Sysadmin Access Directive

Exhibit C documents the October 19, 2023 email chain concerning proposed “master-key sysadmin access” for a third-party offshore engagement and the written management response to the protected disclosure.

Protected Disclosure

Plaintiff warned management that provisioning a third party with elevated administrator-level access created material risk to regulated healthcare and PII-related systems.

The contemporaneous email record references: “master-key sysadmin access”, administrator-level access, SolarWinds access, and unrestricted access to system-level data.

Management Rebuke

“It is not your place to submit breach information especially since they are working for us it is not a breach.”

The written response came after Plaintiff disclosed concerns regarding the proposed provisioning of elevated administrative access and after Plaintiff stated that a federal HHS.gov breach notice had been submitted.

Contemporaneous Timing

The October 19, 2023 exchange occurred before termination, before any retaliation dispute existed, and before litigation.

The record therefore documents a contemporaneous technical and regulatory concern rather than a later-developed litigation narrative.

Evidentiary Significance

Exhibit C is significant because it captures:

  • the protected disclosure itself,
  • management knowledge of the disclosure,
  • management disagreement with the disclosure,
  • the “master-key sysadmin access” concern, and
  • the chronology preceding termination.

View Complete Exhibit C PDF