Overview
Exhibit I-73
Total Work Days
427
422 office • 5 WFH
Total Hours Worked
3,656.1h
vs 3,416h contracted
Overtime Hours
354.9h
All unpaid, never claimed
OT Value (1.0× straight)
$15,525
Conservative floor
OT Value (1.5× ESA min.)
$23,287
Legal minimum entitlement
Banked OT Owed (ESA s.22.1)
$1,050
14h banked • owed on termination
Annual Gross Earnings (Dayforce Payroll)
Exhibit I-74
2022–2025 Earnings Trajectory — verified from Dayforce payroll PDFs
+$52,720 salary growth from 2023 ($76,787) to 2025 ($100,410) demonstrates progressive value recognition — cut short by disability-related termination January 24, 2026. Bi-weekly pay: $3,477.69.
Base Salary Rate Evolution — 101 Pay Stubs
Exhibit I-77
Annual base rate per bi-weekly pay period — May 2022 to Mar 2026 (Dayforce verified)
$75,000
Hired — May 2022
R&D Transition Lead
R&D Transition Lead
$77,625
May 2023 (+3.5%)
Year-1 raise
Year-1 raise
$88,000
Mar 2024 (+13.4%)
CI Lead — same AI projects
CI Lead — same AI projects
$90,420
Mar 2025 (+2.8%)
Year-3 raise
Year-3 raise
+20.6% total salary growth ($75,000 → $90,420) over 3.75 years — 3 consecutive raises, all merit-based.
The $88,000 CI Lead promotion (Feb 2024) recognized the same projects Rod was already leading —
Ignition SCADA, camera systems, PLC integration, Docker orchestration — the identical AI infrastructure
that Dare disconnected (Sep 30) and permanently shut down (Oct 19), 7 days after ADHD disclosure.
The promotion proves Dare valued these exact projects enough to award a 13.4% raise,
then eliminated them post-disclosure.
Salary was still rising at termination, projected $93,000+ for 2026.
Daily Hours Timeline (GPS + Chrome verified)
Exhibit I-75
Work hours per day — blue = OFFICE attendance, orange = WFH. Dashed line = 8h contract threshold.
Jul 7, 2025 — First Medical Leave
Sep 22, 2025 — Return to Work / ADHD Disclosure
Oct 24, 2025 — Second Leave (Panic Attack)
Jan 24, 2026 — Termination
Cumulative Overtime Accumulation
I-76
Running total of unpaid overtime hours — never claimed in 3.75 years
Pre vs Post Disclosure Hours
I-77
Average daily hours — GPS verified (Jun 2024 – Oct 2025)
Normal Period (Pre-Disclosure)
DatesApr 2024 – Jul 6, 2025
Days worked203
Avg hrs/day9.04h
OT/day (avg)+1.04h
Post-Disclosure Retaliation
DatesSep 22 – Oct 23, 2025
Days worked20
Avg hrs/day7.96h
Change−11.9% (−1.08h/day)
Overtime Entitlement Calculation
Exhibit I-78
Employment Standards Act Overtime Calculation — $43.75/hr base rate
| Rate | Hours | Value | Basis |
|---|---|---|---|
| 1.0× (Straight) | 354.9h | $15,524.69 | Conservative floor — no premium |
| 1.5× (ESA Minimum) | 354.9h | $23,287.03 | ESA s.22 legal minimum entitlement |
| 2.0× (Dare's Own Bank Rate) | 354.9h | $31,049.38 | Dare's internal OT bank multiplier |
| 1.5× Banked OT (8h) — ESA s.22.1 | 8.0h | $525.00 | Bank 1 • owed on termination (8 × $43.75 × 1.5) |
| 2.0× Banked OT (6h) — ESA s.22.1 | 6.0h | $525.00 | Bank 2 • owed on termination (6 × $43.75 × 2.0) |
| TOTAL (1.5× + Banked OT) | 368.9h | $24,337.03 | Legal minimum + ESA s.22.1 banked entitlement |
ChatGPT Technical Work Evidence (Dare-Related Sessions)
Exhibit I-79
1,615+ Dare-related conversations (Jun 2023 – Oct 2025) — Chrome history verified
1,615+ documented work sessions in ChatGPT (Dare-related): SCADA/Ignition systems, Python automation, KPI dashboards, and camera systems. Demonstrates technical depth and AI system value beyond normal Analyst duties.