EXHIBIT K

Case 5:20-cv-00746-JKP Document 119-3 Filed 11/14/22 Page 1 of 4
Supplemental Responses – Joint Advisory

Defendant Dr. Guerra’s Second Request for Production for Plaintiff Dr. Rodrigo Cantu

See below Plaintiff Dr. Rodrigo Cantu’s supplemental responses to Dr. Guerra’s Second

Request for Production of Documents #35-72:

35-57. Defendant Dr. Guerra’s Third Request for Production Nos. 31-57 request receipts 

and documentation to support compensatory, consequential, and punitive damage claims 

brought by Plaintiffs. Plaintiffs refer defense counsel to the Supplemental Responses to 

Plaintiffs’ First Set of Interrogatories submitted together with this response. Plaintiffs’ 

counsel has outlined responsive discovery to each of the requests made in Nos. 35-57

with Bates numbers identifying each expense incurred by Plaintiffs as a direct result of 

Defendants’ unlawful conduct.

58. All receipts, invoices, and documents evidencing the costs and damages identified in 

Section 3 of Plaintiffs’ Initial Required Disclosures served on December 1, 2020.

Supplemental Response: All documents have been submitted.

59. All medical records pertaining to the treatment you received from Dr. John Seals which is 

referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Supplemental Response: Although Rodrigo Cantu received treatment from Dr. 

John Seals, there are no medical records available, and they are not attainable. 

60. All billing records pertaining to the treatment you received from Dr. John Seals which is 

referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Supplemental Response: Although Rodrigo Cantu received treatment from Dr. 

John Seals, there are no billing records available, and they are not attainable.

61. All medical records pertaining to the treatment you received from Steve Cervantes which 

is referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Supplemental Response: HIPPA forms for request for records have been signed 

and submitted to Defendant Dr. Guerra. 

62. All billing records pertaining to the treatment you received from Steve Cervantes which is 

referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Case 5:20-cv-00746-JKP Document 119-3 Filed 11/14/22 Page 2 of 4
Supplemental Response: HIPPA forms for request for records have been signed 

and submitted to Defendant Dr. Guerra; PlaintiffsSuppDisc#00184-85. 

63. All medical records pertaining to the treatment you received from Randolph A. Pollock, 

MA, LPC which is referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures 

served on December 1, 2020. 

Supplemental Response: Plaintiff Dr. Rodrigo Cantu did not receive treatment 

from Randolph Pollock

64. All billing records pertaining to the treatment you received from Randolph A. Pollock, MA, 

LPC which is referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures 

served on December 1, 2020. 

Supplemental Response: Plaintiff Dr. Rodrigo Cantu did not receive treatment 

from Randolph Pollock.

65. All medical records pertaining to the treatment you received from Dr. Joann Murphy which 

is referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Supplemental Response: Plaintiff Dr. Rodrigo Cantu did not receive treatment 

from Joann Murphy.

66. All medical records pertaining to the treatment you received from Deena Trevino which is 

referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Supplemental Response: HIPPA forms for request for records have been signed 

and submitted to Defendant Dr. Guerra.

67. All medical records pertaining to the treatment you received from Christine Hefel which is 

referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Supplemental Response: Plaintiff Dr. Rodrigo Cantu did not receive treatment 

from Christine Hefel.

68. All billing records pertaining to the treatment you received from Christine Hefel which is 

referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Case 5:20-cv-00746-JKP Document 119-3 Filed 11/14/22 Page 3 of 4
Supplemental Response: Plaintiff Dr. Rodrigo Cantu did not receive treatment 

from Christine Hefel.

69. All billing records pertaining to the treatment you received from Deena Trevino which is 

referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Supplemental Response: HIPPA forms for request for records have been signed 

and submitted to Defendant Dr. Guerra. 

70. All billing records pertaining to the treatment you received from Dr. Joann Murphy which 

is referenced in Section 1 and 3 of Plaintiffs’ Initial Required Disclosures served on 

December 1, 2020. 

Supplemental Response: Plaintiff Dr. Rodrigo Cantu did not receive treatment 

from Joann Murphy.

71. All receipts, invoices, and documents evidencing your claim in Section 3 of Plaintiffs’ 

Initial Required Disclosures that you incurred approximately $50,000 in fees, taxes, and 

penalties for withdrawing the money from your and/or Melody Joy Cantu’s retirement 

funds in order to pay Plaintiffs’ attorneys’ fees as a result of Defendants’ conduct. 

Supplemental Response: MCantuFinalProd# 001245-001246; 001081-001082.

72. Copies of all the photographs and emails referenced in Melody Joy Cantu’s deposition 

testimony below that she testified you and/or Melody Joy Cantu saved: 

Supplemental Response: MCantuFinalProd# 001112.

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