Exhibit C
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.