QBE in the Record
Procedural and Operational Record Map
Case 1:25-cv-03175-JMF-OTW
QBE is not a new topic. QBE is not an afterthought. QBE has been part of the factual and procedural narrative for a long time.
This page organizes selected docket filings and record materials into anchor pages, topics, and related records so readers may follow the recurring QBE-related issues across the procedural and operational history of this matter.
Anchor Page Record Map
| ECF | Anchor Page | Topics | Related Record |
|---|---|---|---|
| ECF 94 | Motion to Join QBE | Third-party complaint, QBE laptop, device ownership, return delay, endpoint responsibility. | ECF 96, ECF 149, ECF 193, ECF 221 |
| ECF 96 | Supplemental QBE Joinder Filing | QBE governance, device recovery, cross-domain workflow, third-party accountability. | ECF 94, ECF 149, ECF 193 |
| ECF 149 | QBE as Necessary Party | Client-issued laptop, access control, auditability, endpoint governance, Rule 19 issues. | ECF 94, ECF 193, ECF 14-38 |
| ECF 193 | Supplemental Joinder Record | QBE infrastructure, device ownership, audit logs, provisioning data, governance questions. | ECF 149, ECF 94, ECF 14-38 |
| ECF 558 | Requested Injunctive Relief | Future conduct, Mphasis, QBE, settlement posture, litigation next steps. | ECF 560, ECF 560-1, ECF 561 |
| ECF 560 | QBE.global Motion | QBE.global, endpoint accountability, security escalation, operational reliance, QBE-issued laptop. | ECF 558, ECF 560-1, ECF 561 |
| ECF 560-1 | Dual Endpoints & Forgotten QBE Laptop | Operational sequence, governance questions, endpoint management, access control, QBE laptop. | ECF 560, ECF 558, ECF 221 |
| ECF 561 | Clarification of the Record | QBE-related procedural history, clarification, disputed factual record, requested relief. | ECF 558, ECF 560, ECF 560-1 |
| ECF 14-4 | QBE.pptx Routing Record | QBE.pptx, Ruturaj Waghmode, PowerPoint routing, personal email transmission, workflow constraints. | ECF 14-15, ECF 14-5, ECF 14-38 |
| ECF 14-15 | QBE.pptx & Weekend Work Record | Weekend work, QBE draft deck, SharePoint limitations, personal-device usage, QBE deliverables. | ECF 14-4, ECF 14-5, ECF 14-38 |
| ECF 14-5 | DLP Escalation & Dual-Endpoint Notice | DLP Incident DR110325111903, security escalation, no Mphasis laptop, personal Mac, endpoint governance. | ECF 14-4, ECF 14-15, ECF 14-36, ECF 14-38 |
| ECF 14-17 | QBE Laptop Collecting Dust | Dilip Nayak, QBE laptop, New York custody, return discussions, endpoint accountability. | ECF 14-18, ECF 14-20, ECF 221 |
| ECF 14-18 | QBE Return Coordination | End of contract, QBE laptop return, QBE location, prepaid shipping-label option, Mphasis coordination. | ECF 14-17, ECF 14-20, ECF 14-32 |
| ECF 14-20 | QBE Return Instructions | Return logistics, QBE contact, Mphasis leadership, client concern, device recovery. | ECF 14-17, ECF 14-18, ECF 221 |
| ECF 14-21 | Whistleblower and Laptop Timeline | Whistleblower disclosures, QBE work, denial of resources, retaliation timeline, QBE-issued device. | ECF 14-5, ECF 14-15, ECF 14-38, ECF 221 |
| ECF 14-25 | Private Investigator Laptop Recovery | Brad D. Kelly declaration, attempted recovery, service efforts, laptop custody, QBE/Mphasis device dispute. | ECF 14-17, ECF 14-20, ECF 221 |
| ECF 14-32 | QBE London / New York Return Conflict | FedEx label request, QBE London office, conflicting return instructions, QBE Dell laptop. | ECF 14-17, ECF 14-18, ECF 14-20, ECF 14-36 |
| ECF 14-36 | Shipping Label and Box Request | Return materials, FedEx label, QBE laptop, asset tracking, chain-of-custody, counsel communications. | ECF 14-20, ECF 14-25, ECF 14-32, ECF 221 |
| ECF 14-38 | No Mphasis Laptop Issued | Infrastructure denial, web-only access, QBE laptop assignment, endpoint governance, whistleblower defenses. | ECF 14-4, ECF 14-5, ECF 14-15, ECF 14-41 |
| ECF 14-41 | Integrated Response and QBE Motion | Integrated response, motion to compel non-party QBE, QBE-issued laptop, return shipping materials, data security, evidentiary material, and whistleblower-protection issues. | ECF 14-38, ECF 14-36, ECF 94, ECF 96 |
| ECF 221 | Forgotten QBE Laptop | No Due Clearance, Service Letter, clean exit record, missing laptop reference, later recovery dispute. | ECF 14-17, ECF 14-20, ECF 14-25, ECF 560-1 |
Chronological Record Index
| ECF | Filed | Description |
|---|---|---|
| ECF 14-4 | 04/30/25 | QBE.pptx routing record showing Mphasis management transmitted a QBE draft deck to Defendant and Defendant subsequently forwarded the file to his personal email during a period when no Mphasis-issued laptop had been provided. |
| ECF 14-15 | 04/30/25 | QBE draft deck and weekend-work correspondence concerning QBE.pptx, SharePoint access limitations, personal-device usage, and operational communications later referenced during the DLP escalation process. |
| ECF 14-5 | 04/30/25 | DLP escalation and cybersecurity notice concerning workflow, infrastructure, endpoint governance, and security concerns. |
| ECF 14-17 | 04/30/25 | QBE laptop “collecting dust” email to Dilip Nayak, documenting that the QBE-issued laptop remained in New York after prior return discussions. |
| ECF 14-18 | 04/30/25 | QBE and Mphasis communications concerning contract end, QBE laptop return instructions, QBE location coordination, and the prepaid shipping-label option. |
| ECF 14-20 | 04/30/25 | QBE instructions and internal Mphasis communications regarding return of the QBE-issued laptop, coordination with Mphasis leadership, and the prepaid shipping-label option. |
| ECF 14-21 | 04/30/25 | Record material concerning protected whistleblower activity, QBE work, denial of standard IT resources, DLP-related events, and post-termination communications. |
| ECF 14-25 | 04/30/25 | Declaration of Brad D. Kelly, L.P.I., concerning service efforts and attempted recovery of the laptop at issue in the litigation. |
| ECF 14-32 | 04/30/25 | Communications concerning QBE laptop return conflict, QBE London, New York return location, FedEx label request, and continued return-process uncertainty. |
| ECF 14-36 | 04/30/25 | Shipping label and box request concerning return of the QBE-issued Dell laptop, chain-of-custody concerns, and communications with counsel and QBE-related stakeholders. |
| ECF 14-38 | 04/30/25 | Integrated response addressing infrastructure denial, lack of a Mphasis-issued laptop, endpoint governance, whistleblower defenses, and request to compel QBE return materials. |
| ECF 14-41 | 04/30/25 | Service of Defendant’s integrated motion response and motion to compel non-party QBE to provide return shipping materials or show cause, addressing data-security issues, evidentiary material, return logistics, and the QBE-issued device. |
| ECF 94 | 05/08/25 | Defendant’s motion for leave to file third-party complaint against QBE Insurance Group Limited. |
| ECF 96 | 05/09/25 | Additional filing concerning QBE and Defendant’s motion for leave to file third-party complaint against QBE Insurance Group Limited. |
| ECF 149 | 05/28/25 | Supplemental statement in support of mandatory joinder of QBE North America. |
| ECF 193 | 05/31/25 | Supplemental statement in support of mandatory joinder of QBE North America. |
| ECF 221 | 06/12/25 | Supplemental declaration concerning No Due Clearance, Service Letter, post-termination events, and the QBE laptop later becoming central to the dispute. |
| ECF 558 | 06/05/26 | Plaintiff sought next-step relief and referenced litigation posture, contempt issues, sanctions, settlement, and future proceedings. |
| ECF 560 | 06/09/26 | Plaintiff sought relief concerning QBE.global and described the website as discussing infrastructure constraints, endpoint accountability, security escalation, operational reliance, the QBE-issued laptop, DLP concerns, cybersecurity risks, and endpoint governance issues. |
| ECF 560-1 | 06/09/26 | Plaintiff attached Defendant’s June 8, 2026 email describing the operational sequence reflected in the record and governance questions involving the dual-endpoint environment and QBE-issued laptop. |
| ECF 561 | 06/08/26 | Defendant sought leave to file a clarification of the procedural record, noting that QBE-related issues had been repeatedly raised throughout the litigation and remained relevant to Plaintiff’s requested relief. |
Preserved Underlying Correspondence and Related Materials:
- February 28, 2025 – QBE Weekend Engagement Correspondence
- March 5, 2025 – Charles Schwab Engagement Correspondence
- March 7, 2025 – Clarification Needed on Project Changes
- March 12–13, 2025 – Potential DLP Incident / Dual-Endpoint Workflow Correspondence
- March 14, 2025 – Termination Notification
- March 15, 2025 – Violation of Contractual Agreements Letter
- March 29, 2025 – Formal Demand for Reinstatement
- Complete Preserved Correspondence Archive
These materials consist of preserved communications, operational notices, management directives, cybersecurity correspondence, HR communications, termination records, and related materials concerning the events discussed in ECF 14-4, ECF 14-5, ECF 14-15, ECF 14-17, ECF 14-20, ECF 14-38, ECF 560, and related filings.
The correspondence is provided for historical, archival, and public-record reference and may provide additional context regarding the dual-endpoint workflow, QBE-issued laptop, DLP escalation, project assignments, cybersecurity concerns, endpoint-governance issues, and subsequent events.
Defendant respectfully submits that the procedural and operational record reflects a continuing and repeated focus on QBE-related issues throughout these proceedings. This page does not attempt to resolve any disputed issue.
Readers are encouraged to review the underlying filings directly and draw their own conclusions.