In Part 14, I explained why metadata matters.
A PDF is not just a picture of a document.
Sometimes it is a scan.
Sometimes it is a court-stamped filing.
Sometimes it is exported from Word.
Sometimes it carries the name of the Word document it came from.
And sometimes that matters more than the words on the page.
This is one of those times.
The first metadata problem I want to show involves the same issue this series keeps returning to:
The Compensation Agreement.
By May 1, 2017, Valeo had filed for summary judgment.
That means Valeo was asking the court to enter judgment without a trial.
To do that, Valeo had to designate evidence.
Among the evidence Valeo designated were two documents attached to Gregory Fulk’s affidavit:
The 2010 Employment Agreement.
The 2010 Compensation Agreement.
Those two documents mattered because Fulk’s affidavit claimed that Valeo and I had entered into the 2010 Employment Agreement and the 2010 Compensation Agreement.
He claimed those 2010 agreements were distributed to advisors, including me.
He claimed Valeo paid me according to the 2010 Compensation Agreement.
But the affidavit was not dated.
And the documents themselves created another problem.
They were not scans of signed historical agreements.
They were PDFs generated from Word.
And the metadata showed they were generated three days before Valeo filed for summary judgment.
________________________________
Here is the first one:
This is the metadata for Valeo’s summary judgment Exhibit A-1, the 2010 Employment Agreement.
Look at the highlighted fields.
The title/source document is:
C&E-ASC (00156751).DOCX
The author field says:
Pam Koehler
The creator says:
Acrobat PDFMaker 15 for Word
The PDF creation date is:
April 28, 2017
________________________________
Valeo filed its summary judgment motion on May 1, 2017.
Three days later.
________________________________
Now look at the second one:
This is the metadata for Valeo’s summary judgment Exhibit A-2, the 2010 Compensation Agreement.
Again, the title/source document is:
C&E-ASC (00156751).DOCX
Again, the author field says:
Pam Koehler
Again, the creator says:
Acrobat PDFMaker 15 for Word
Again, the PDF creation date is:
April 28, 2017
________________________________
The two documents were created twenty-six seconds apart.
The 2010 Employment Agreement PDF was created at 5:27:15 p.m.
The 2010 Compensation Agreement PDF was created at 5:27:41 p.m.
Same source Word document.
Same author field.
Same software.
Same date.
Twenty-six seconds apart.
That is the point.
The issue is not whether Pam Koehler personally clicked a button on April 28, 2017.
The issue is not who maintained the Word file.
The issue is not whether an author field can be inherited from an earlier document or template.
The issue is simpler.
Valeo was asking the court to enter summary judgment based partly on two 2010 agreement exhibits.
But the electronic files showed those two exhibits were generated from the same Word document on April 28, 2017.
Three days before the summary judgment filing.
That is not what I expected to see.
If Valeo had signed 2010 agreements, I expected the record to look like old signed contracts.
A scan.
A copy.
A signed agreement pulled from a personnel file.
Something that looked like a historical business record.
But that is not what the metadata showed.
The metadata showed two court-filed PDFs generated from one Word document shortly before Valeo asked the court to enter judgment.
That does not prove everything by itself.
It does not prove motive.
It does not prove every conversation behind the scenes.
It does not prove who personally generated the PDFs.
But it does prove the files were not simply scans of signed paper agreements from 2010.
And that matters.
Because Valeo’s own Employment Agreement said my compensation was governed by a separate Compensation Agreement.
Valeo’s own Employment Agreement said the complete agreement included the Compensation Agreement.
For months, I asked whether the complete agreement existed.
For months, I asked whether the document available for inspection included an executed Compensation Agreement.
Then, on June 28, 2017, Andrew Hull admitted there was no signed Compensation Agreement.
No signed original.
No signed copy.
But before that admission, Valeo had already filed for summary judgment.
And in that filing, Valeo used Fulk’s affidavit and these two 2010 documents to argue that I had operated under the 2010 agreements.
That is the problem.
The documents did not solve the missing Compensation Agreement issue.
They made it worse.
Because the metadata forced a new question:
If there was no signed Compensation Agreement, what exactly was Valeo asking the court to enforce?
A signed 2009 Employment Agreement?
An unsigned 2010 Employment Agreement?
An unsigned 2010 Compensation Agreement?
A generic 2009 Compensation Agreement?
A course-of-conduct theory?
An implied agreement?
Something else?
That question should have been answered before summary judgment.
Instead, it was blurred.
The court was shown documents that appeared official because they were filed in court.
But the electronic files showed something the paper did not.
They showed that the 2010 Employment Agreement and the 2010 Compensation Agreement were generated from the same Word document three days before summary judgment was filed.
The paper version of the record said:
Here are the 2010 agreements.
The metadata said:
These PDFs were generated from the same Word document on April 28, 2017.
Those are not the same message.
And this is why the missing Compensation Agreement issue mattered from the beginning.
If Valeo had simply produced a signed Compensation Agreement, this issue would have been simple.
They could have attached it to the Complaint.
They could have produced it in discovery.
They could have mailed it with an affidavit.
They could have shown it at inspection.
They could have ended the question with one document.
But they did not.
Instead, the case moved forward on shifting explanations.
The 2009 Employment Agreement was signed.
The 2009 Compensation Agreement exhibit was generic.
The 2010 Employment Agreement was unsigned.
The 2010 Compensation Agreement was unsigned.
Fulk’s affidavit claimed the 2010 agreements governed my compensation, but his affidavit was undated.
Hull later admitted Valeo did not have signed copies.
And the metadata showed the 2010 agreement PDFs were generated from the same Word document three days before summary judgment.
That is not a clean record.
That is not a simple contract case.
That is not a technical misunderstanding.
That is a foundational evidentiary problem.
It also explains why the wage fines and the Compensation Agreement cannot be separated.
The Performance Standards provision was in the 2010 Compensation Agreement.
That was the provision Valeo used to reduce compensation when performance targets were not met.
That was the mechanism behind the wage reductions I have already shown.
So when Valeo could not produce a signed Compensation Agreement, it was not just missing a side document.
It was missing the document that supposedly authorized the compensation structure that reduced my pay.
And when the metadata showed that the 2010 Compensation Agreement PDF was generated from Word days before summary judgment, the issue became even more serious.
Because now the question was not only:
Where is the signed Compensation Agreement?
The question became:
Where did this exhibit come from?
That is the question metadata forced me to ask.
And after eleven years, those metadata screenshots are now in the court record.
On June 3, 2026, I filed an exhibit list and included the metadata screenshots for the 2010 Employment Agreement and the 2010 Compensation Agreement.
For the first time, the same kind of evidence I had been trying to get considered for years is now formally in the record.
That does not undo what happened.
It does not unfreeze bank accounts.
It does not give back eleven years.
It does not erase a judgment.
But it matters.
Because this story has never depended on asking people to believe me.
It depends on documents.
It depends on dates.
It depends on signatures that are missing.
It depends on words spoken in a conference room.
And now it depends on metadata.
The next question is what the court did with this kind of record.
Because once you understand the missing agreement problem, and once you understand the metadata problem, the next issue becomes unavoidable:
How did this case keep moving anyway?
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