Nuvem Legal Notice: Protected Whistleblower Disclosure

OFAC.ai
OFAC.ai
  • Home
  • Selected Exhibits

Protected Whistleblower Disclosure

18 U.S.C. § 1833(b) (DTSA) · 15 U.S.C. § 78u-6(h) (Dodd-Frank) · 18 U.S.C. § 1514A (Sarbanes-Oxley) · N.Y. Lab. Law § 740

Legal Notice:

This archive reproduces evidence filed in Rojas v. Nuvem Health LLC, No. 1:25-cv-04684 (SDNY), under 28 U.S.C. § 1746.
Originally published on Nuvem.health, now hosted for continuity of public-interest record under federal whistleblower protection statutes.

All materials are non-commercial, redacted, and statutorily immune from liability under 18 U.S.C. § 1833(b).

Juror-Facing One-Pager (plain-language copy)

What this page is:

My sworn account (with documents) of what happened in October 2023. I raised a security concern, filed a federal report, my bosses knew, and I was let go days later. Everything below is supported by the PDFs labeled Exhibits A–G.

What I was hired to do:
I was hired as a Cloud/Data Administrator to help protect patient data and maintain database systems.

What I saw:
An offshore SaaS  Madeira setup required a sysadmin “master-key” account—an all-access login to databases with patient information. That level of access is risky and not necessary for monitoring.

What I did (step-by-step):

  • Oct 17 – I warned leadership in writing that the tool required a master-key account (Ex. A).
  • Oct 19 (morning) – I was told to proceed with the sysadmin setup. I filed a HIPAA breach notice with HHS OCR to protect the company and patients (Ex. B) and told my VP I had filed (Ex. C).
  • Oct 19 (afternoon) – My VP emailed asking me to send the HHS confirmation “for our files,” showing management knew about the federal filing the same day (Ex. D).
  • Oct 19 (evening) → Oct 20 (morning) – I asked HR to archive my compliance objection in my personnel file; HR replied, “I will save this to your files.” (Ex. D).
  • Oct 20 – The company’s IT admin agreed with my concern in texts (Ex. E).
  • Oct 24 (morning of termination) – I was actively corresponding with leadership on the company’s security campaign—on time, professional, and working (Ex. F). I was then terminated, later described as “attendance.”

Why this matters:
This shows:

  1. I did the job I was hired to do—protect patient data.
  2. My bosses knew about my federal report.
  3. I was let go days later.
  4. The “attendance” reason doesn’t fit the timestamps and emails from that morning.

What I did not do:
I did not grant a master-key login to a third party. I proposed safer alternatives.

Legal protections (plain English):
U.S. law protects employees who report data-privacy risks in good faith. It’s illegal to punish someone for making such a report. (Sarbanes-Oxley §1514A; DTSA §1833(b) whistleblower immunity; NY Labor Law §740.)

Documents (Exhibits) – read them yourself:

  • Exhibit A – Oct 17 email warning: “This is a ‘master key’.”
  • Exhibit B – HHS OCR breach filing (official federal form).
  • Exhibit C – Oct 19 email chain (I report, VP rebukes “not your place”).
  • Exhibit D – VP asks for HHS confirmation “for our files”; HR: “I will save this to your files.”
  • Exhibit E – Oct 20 texts with IT admin agreeing with my concern.
  • Exhibit F – Oct 24 morning emails showing I was active and professional.
  • Exhibit G – Console evidence confirming credential custody chain.

Redactions & purpose:
Sensitive tokens/IDs are redacted. Originals are preserved for regulators and the Court. This page is non-commercial and exists solely to keep an accurate, document-backed record.

Declaration 28 USC § 1746

Timeline Graphic

All of this happened in my first week. When I refused to enable a master admin key, they made me the problem.

Oct 17 → Internal Warning  

Oct 19 AM → HHS OCR Filing  

Oct 19 PM → VP & HR Acknowledgment  

Oct 20 → IT Corroboration  

Oct 24 AM → Active Work / Termination

Exhibit Timeline

Exhibit A 💬 Internal Emails

October 17 2023 Solar Winds Email

Early written warning to Nuvem management that Solar Winds required “master-key” access—equivalent to Server Admin or Active Directory Admin—to query system tables containing PII. Establishes that Rojas raised the sysadmin-risk issue before any dispute or regulatory filing.

Exhibit A Solar Winds Email

Exhibit B ⚙️ Technical Evidence

HHS OCR Breach Filing Acknowledgment (Oct 19 2023 9:43 a.m.)

Official record of the HIPAA breach report naming Nuvem Health LLC as Business Associate and identifying the “master key to our healthcare customers” risk. Demonstrates contemporaneous protected disclosure under federal law.

Exhibit B HHS Filing

Exhibit C ⚙️ Technical Evidence

October 19 2023 Email to VP R&D Luigi Squillante (“Madeira Access / Sysadmin Key Directive”)

Email chain showing Rojas’s refusal to provision a sysadmin account and Squillante’s written rebuke: “It is not your place to submit breach information.” Proves both protected activity and management knowledge / disfavor.

Exhibit C Madeira Access

Exhibit D 💬 Internal Emails

HR Acknowledgment (Oct 19–20 2023)

Includes VP Luigi Squillante’s written request for the HHS.gov confirmation and HR’s

reply, “I will save this to your files.”

Confirms executive-level knowledge and recordation of the protected disclosure.

Exhibit D HR Acknowledgement

Exhibit E 📱 Text Messages,

Text Messages with Joel Ignatovich (IT Administrator)

October 20 2023 texts confirm the sysadmin credential’s custody inside IT.

Rojas: “I’m the one that killed the Solar Winds provisioning yesterday.”

Ignatovich: “Lol that was my concern as well … We were on the same page for that.”

Corroborates that Rojas’s objection was compliance-aligned, not insubordinate.

Exhibit E Joel Ignatovich

Exhibit F 📧 Morning-of-Termination.

October 24 2023 Email (“October is Security Awareness Month”)

 Morning-of-termination correspondence with Nuvem’s VP of IT Security Michael Larke

and VP R&D Luigi Squillante, evidencing active, professional engagement moments

before discharge. Rebuts any “attendance” pretext.

Exhibit F Termination

Exhibit G SUPPLEMENTAL DECLARATION

Nuvem Console Screenshot / Supplemental Declaration

Console image identifying Joel Ignatovich as the custodian of the sysadmin credential,

submitted under 28 U.S.C. § 1746. Provides technical confirmation of the custody chain

described in Exhibit E and directly rebuts later misstatements in the WIPO UDRP filing.

Exhibit G Supplemental Declaration

Formal Whistleblower Disclosure filed under 18 U.S.C. § 1833(b). No classified, sealed, or proprietary materials are included.

  • EXHIBIT_Timeline
  • Declaration 28 USC & 1746
  • Exhibit_A_Solar_Winds
  • Exhibit_B_HHS_Breach
  • EXHIBIT_C_Madeira_Access
  • EXHIBIT_D_HR_Acknowledge
  • EXHIBIT_E_Joel Ignatovich
  • EXHIBIT_F_Termination
  • EXHIBIT_G_Declaration
  • Selected Exhibits