Exhibit ‘B’

Case 5:20-cv-00746-JKP Document 110-2 Filed 10/14/22 Page 1 of 27
■3DIGITAL

FORENSICS CORP

Phase I

Evaluation Report

Case Number 157307

Examiner Name 223

Received

Completed 8/22/2018

GUERRA 000062

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Page |2

TABLE OF CONTENTS

, ---------------------- . ------------- -------- .... .................

CLIENT DIRECTIVES....................................................................................................................................................3

BACKGROUND............................................................................................................................................................ 3

FORENSIC SCOPE OF WORK.......................................................................................................................... 4

PHASE I SCOPE OF WORK.............................................................................................................................4

PHASE II SCOPE OF WORK..................................................................................................................................4

CYBER HARASSMENT DOCUMENTATION......................................................................................................... 7

ATTEMPTED PHONE HACKING....................................................................................................................7

IDENTITY THEFT AND MISAPPROPRIATION............................................................................................. 8

SUSPICIOUS LINKEDIN ACCOUNT "GARY MORIN"..............................................................................11

ONLINE HARASSMENT..................................................................................................................................12

WEB INVESTIGATION.............................................................................................................................................13

INFO ABOUT MELODY JOY BROWN CANTU..........................................................................................13

TRACKING URLs....................................................................................................................................................... 16

TRACKING URL RESULTS..............................................................................................................................20

ENGINEER'S SUMMARY AND RECOMMENDATIONS.................................................................................. 23

CONCLUSION............................................................................................................................................................24

APPENDIX A - SAMPLE POLICE REPORT............................................................................................25

GUERRA 00006

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CLIENT DIRECTIVES

DR. SANDRA GUERRA (the "Client") has requested the following:

1. Conduct a digital investigation on a known suspect; and

2. Discover the identity of an unknown cyber-harasser.

BACKGROUND

By the work of an unknown person, the Client has been the victim of:

1. Attempted Phone Hacking: attempted intrusion into Client's mobile phone account via

Client's mobile phone service provider;

2. Identity Theft and Misappropriation:the creation of accounts on dating websites

using Client's email address; and

3. Defamation: Untrue statements concerning the Client which harms the Client.

In addition to the above, the Client has also been the victim of harassment caused by

MELODY JOY BROWN CANTU when the Client's social network received unwanted messages

disparagingthe Client's characterfrom Ms. Cantu.

Cyber harassment - also known as cyber bullying or internet harassment --refers

to the malicious use of technology to willfully and deliberately HARASS, HARM,

or DEFAME another individual or entity.

GUERRA 000064

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FORENSIC SCOPE OF WORK

PHASE I SCOPE OF WORK

1. The scope ofwork for a Phase I Evaluation of a cyber harassment digital forensics case

is to record and document the online harassment, harm, or defamation.

2. Phase I includes the collection, extraction, recovery, and preservation of all data from

available client devices and online accounts and performing an extensive search ofthe

online presence of the suspects based on the information provided.

3. Phase I also includes the creation of tracking URLs to target at the suspect(s). The

clientwill send the tracking URLs to the suspect(s) and Digital Forensics Corporation

(DFC) will monitorthe tracking URLs for any activity by the suspect(s).

PHASE II SCOPE OF WORK

1. A Phase II Examination for cyber harassment is primarily an external action phase for a

digital forensics investigation which may include initiating a legal proceeding for the

purposes of issuing a subpoena against any third-party entities (such as internet

service providers (ISPs), phone service providers (PSPs), or online service providers

(OSPs)) to discoverthe suspects' true identities.

2. Phase II includes the creation of a searchable archive of all data successfully collected,

extracted, recovered, and preserved, from all devices and/or accounts, as part of

Phase I.

GUERRA 000065

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Page I 5

3. A Phase II Examination will also include the all information discovered by DFC's

exhaustive web investigation of the suspect(s) based on the results of the Phase I

Evaluation.

4. If the client is interested in proceeding to Phase II, the client needs to file a police

report at the local police station to document the cyber harassment or cyberfraud.

The client should attach the entire "Phase I Evaluation Report" to the police report as

documentation of the cyber harassment or cyberfraud.

a. If, prior to the conclusion of the Phase I investigation, the client has already

filed a police report with the client's local jurisdiction, the client should

"supplement"the existing police report by including a copy of this "Phase I

Evaluation Report".

5. In Phase II, the client will need to provide the following to Digital Forensics Corporation

(DFC):

• Copy of filed and time-stamped police report (which has been supplemented

with DFC's Phase I Evaluation Report).

6. In Phase II, Digital Forensics Corporation (DFC) will provide any IP addresses obtained

as a result of DFC's tracking URLs engineered specifically forthe client. If a suspect clicks

on a DFC tracking URL, the IP address of the individual will be relayed to DFC. With

additional legal work, the IP address can be used to determine the physical location

and/or identity of the suspect.

7. In Phase II, Digital Forensics Corporation will coordinate with and support an outside

attorney who will file the official legal pleadings and discovery requests in order to

obtain any information associated with the suspects which may be retained by thirdparties (such as ISPs, PSPs, or OSPs). The filed police report (containing the Phase I

GUERRA 000066

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Page |6

Evaluation Report), results of DFC's tracking URL campaign, and any additional

information provided by the client such as an affidavit will be used for the official legal

Many internet service, phone service, and online service providers have very specific

requirements regardingthe release of their clients' personal information; therefore,

it is very important to structure and submit a formal request in the correct and

properform according to all the requirements.

inquiry.

a. Please note that in an official legal inquiry such as a complaint to discover the

identity of a cyber harasser, a party (such as an ISP or social media website) may

decline or object to a legal requestfor information aboutthe identityof account

owners and/or subscribers. In that case, DFC will continue supporting and

coordinatingwith the outside attorney to provide a response to the objection or

file another subpoena to obtain relevant information regarding the identity of

the individual of interest. The client understands that this process may involve

additional costs to account for additional subpoenas being served. DFC services

will only cover supporting an outside attorney for serving the additional

subpoena; however, DFC cannot represent the client in court. DFC is not a

iawfirm and will not represent you in any legal capacity. If authorized, we will

attemptto locate a licensed attorneyto representyou and that engagementwill

be between you and the attorney and governed by the terms of an engagement

agreement. The engagement letter will state that you agree that DFC may be

engaged in a consultingcapacity with the attorney(s) and any compensation will

be governed by DFC's agreement with the attorney assigned to your case.

8. Although DFC cannot guarantee any particular outcome, the intent of a Phase II

investigation is to assist the client in preparation for legal action against the actual

person(s) responsible forthe cyber harassment or cyber fraud.

GUERRA 000067

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Page 17

CYBER HARASSMENT DOCUMENTATION

Digital Forensics Corporation performed investigation and documentation of attempted

phone hacking, identity theft and misappropriation, and defamation. DFC engineers acquired

all evidence related to the acts described above. This evidence is documented below.

ATTEMPTED PHONE HACKING

An unknown malicious hacker attempted to gain access to Client's Verizon mobile phone

account (account number 521731356-00001) (the "Verizon Account'). The Clients account

came under attack at the followingtimes:

Date Time

May 16, 2018 1:15 PM

May 18, 2018 12:32 AM

May 18, 2018 11:46 AM

May 20, 2018 9:32 AM

May 24, 2018 2:42 PM

May 31, 2018 4:22 PM

June 2, 2018 10:20 PM

June 6,2018 11:07 AM

On June 8,2018, at 1:15 AM, Verizon notifed Client that the Verizon Account would have its

online account access removed due to an excessive and suspicious number of failed log-in

attempts on the Verizon Accounts voicemail. As a result, the Client could only restore

voicemail access by agreeingto remove online account access.

GUERRA 000068

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Page 18

IDENTITY THEFT AND MISAPPROPRIATION

The Client's email address (drsandraguerra@yahoo.com) was used by an unknown individual

to create profiles on two social media websites dedicated to people with sexually transmitted

diseases. These accounts were both created with the nickname "MonkeyBarl970".

Client contacted the websites and asked them to suspect and/orremove the accounts. One of

the websites, positivesingles.com at 416-682-1072 via Lisa John, informed Client that the

account MonkeyBarl970was set up with Client's email from IP 72.179.171.30 at 4:26 PM on

Tuesday, May 22,2018, from an iPhone. This IP address is located somewhere in the greater

San Antonio area. No other information aboutwho created MonkeyBarl970 was available.

Evidence showing "MonkeyBarl970" existed but has since been removed.

i7/'wwwJisvsingles.com/error

MOST 'Popt/or OATING G SUPPORT SITE FOR SINGLES WITH HSV

GUERRA 00006

g
Page |9

IP Address from which the MonkeyBarl970 account was created is located in San Antonio.

GUERRA 000070

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Page I 10

Positivesingles.com is a Florida-based website and subject tothe laws of Florida.

Showing results for: positivesingles.com

Original Query: positivesingles.com

Contact Information

Registrant Contact Admin Contact Tech Contact

Name Moniker Privacy Services Name Moniker Privacy Services Name Moniker Pnvacy Services

Organization Moniker Privacy Organization: Moniker Privacy Organization Moniker Pnvacy

Services Services Services

Mailing Address 2320 NE 9th St. Mailing Address 2320 NE 9th St, Mailing Address 2320 NE 9th St,

Second Floor. Fort Lauderdale FL Second Floor Fort Lauderdale FL Second Floor, Fort Lauderdale FL

33304 US 33304 US 33304 US

Phone +1 8006886311 Phone +1 8006886311 Phone:+1.8006886311

Ext Ext Ext

Fax +1 9545859186 Fax +1 9545859186 Fax +1.9545859186

Fax Ext Fax Ext Fax Ext:

Email Email Email

e810aa3c058043b11429de6b1564 e810aa3c058043b11429de6b1564 e810aa3c058043b11429de6b1564

87930525dcad480cb1fa6c42408f2 87930525dcad480cb1fa6c42408t2 87930525dcad480cb1fa6c42408f2

9tbf1e8@positivesinglescom whoi 9tbf1e8@posrtivesingles com whoi 9fbf1e8@positivesingles com whoi

sproxy.org sproxy org sproxy org

On August 21,2018, DFC contacted the second website, hsvsingles.com, was contacted at

888-494-2850 via customer service agent "Rose". HSVSingles said they could not reveal the IP

address from which the account MonkeyBarl970 was created, but would do so upon receipt

of a copy of a police reportfiled in this matter. They requested the time-stamped police

report be faxed to them at 866-599-9719 (ATTN: Donna).

GUERRA 00007

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HSVsingles.com is a Florida-based website and subject to the laws of Florida.

Showing results for: hsvsingles.com

Original Query: hsvsingles.com

Contact Information

Registrant Contact Admin Contact Tech Contact

Name Dating Media Group Name Dating Media Group Name: Dating Media Group

Organization Dating Media Group Organization Dating Media Group Organization: Dating Media Group

Mailing Address 6919 W Mailing Address 6919 W Mailing Address. 6919 W

BROWARD BLVD, STE 270 BROWARD BLVD STE 270 BROWARD BLVD, STE 270

Plantation FL 33317 US Plantation FL 33317 US Plantation FL 33317 US

Phone +18007702715 Phone +18007702715 Phone +18007702715

Ext Ext: Ext

Fax Fax Fax

Fax Ext Fax Ext Fax Ext

Email helpdesk@dmgbill com Email helpdesk@dmgbill com Email helpdesk@dmgbill com

SUSPICIOUS LINKEDIN ACCOUNT "GARY MORIN"

DFC Engineers acquired and archived the Client's Linkedln and Facebook accounts. The

Linkedln user "Gary Morin" contacted Client. Gary Morin is believed to be a fake account.

Gary Morin has sent a request for adding to Sandra Guerra's friends of Linkedln.

• "Gary Morin to Sandra Guerra,"5/22/18,1:46AM" INCOMING"

GUERRA 00007

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ONLINE HARASSMENT

The Client's social media contacts were harassed and the Client defamed by the online

Facebook username "Joy Brown" and Linkedln username "Melody Joy Cantu". On May 20,

2018, Melody Joy Cantu contacted Nate Bellinger, the Client's friend, on Linkedln. Mr.

Bellinger has no knowledge of Joy Brown, online or offline. On May 20,2018, Joy Brown

contacted Mr. Bellinger's ex-wife, Stacey Bellinger, through Facebook. Ms. Bellinger also had

no prior knowledge of Joy Brown, online or offline. Client believes Joy Brown and Melody Joy

Cantu are usernames of Melody Joy Brown Cantu, Client's ex-husband's current wife.

I <- 0 I « Secure https./ www.hnkedin.corr/in/melody-joy-c-921083b3/ Q, 9 Q

GUERRA 000073

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WEB INVESTIGATION

Forensic Examiner conducted Web Investigation to identify additional information regarding

individuals responsible or suspected of harassment.

INFO ABOUT MELODY JOY BROWN CANTU

Our engineers performed a thorough web-search using advanced tools and techniques. As the

result of the reconnaissance phase, the following information about investigated person was

found:

GUERRA 00007

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GUERRA 000075

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Comprehensive Report

Comprehensive Report Report Legend

Date: 08/21/2018 QJ -Deceased Person Relatives

Reference ID: NONE S. >-1“Degreeof Separation

S. »-2" Degree of Separation

Si »>- 3^ Degree of Separation

Subject Information Indicators

Other Names Associated with Subject Bankruptcies No

(Best Information forSubject) None found Liens: No

Judgments: No

Name MELODY JOY CANTU (05/30/2014 to Other DOBs Associatedwith Subject Properties Yes

06/042018) None found Corporate Affiliations: No

Name: MELODY JOY ROSS(06/01/2003to Cnmmal/Traffic: No

0425/2018) Possible PhonesAssociated with Subject: Global Watch Lists Match: Yes

Name: MELODY JOY BROWN (12/01/1994 to (210)425-5765(CT) (Mobile) (86%)

0401/2017) (210) 290-9734 (CT) (ActiveLandLine)(78%) Email Addresses Associated with

Name: JOY BROWN(09/01/2001 to07/12/2016) (210) 277-0817 (CT) (LandLine)(66%) Subject

(210) 392-5275 (CT) (Mobile) (66%) joyandtyrus@hotmail.com

Name: JOY ROSS (07/0272004 to 11/02/2013) (210) 641-9811 (CT) (LandLine)(66%) francene16@hotmail.com

Name: MELODYJOY BEAN(07/01/1999 to (210) 688-0656 (CT) (66%) aross2@satxjT.com

02/01/2009) (512) 733-1619 (CT) (66%)

Date of Birth. 01/20/1976,Bcm 42 years (512) 864-9533 (CT) (66%)

ago (608) 278-1319 (CT) (LandLine) (66%)

FORENSIC EXAMINATION DISCLOSURE: Forensic Examiner searched for information

using a variety of third-party resources. As a result, data contained in this report might

include false positives, and might require further verification.

GUERRA 000076

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Page 116

_______________________________________TRACKING URLs_______________________________________

Our forensic examiners have created some links that will help us identify people, but we need

your cooperation.

• Tracking URLs are links which send back information to the link creator when the link is

clicked by a device on the internet.

• Each individual tracking URL captures IP address, operating system, browser, screen

resolution, and hash information for the device from which the tracking URL is clicked.

This information can be used in court proceedings to determine the identity of

anonymous or unknown online individuals.

• In this case, the Forensic Examiner created unique tracking URLs for the client to send or

target at the suspects.

• FIRST: Please click the following links, which will provide us with your IP address so we

can exclude it from the results (to prevent false-positives in case you accidentally click

on any of the others).

o NOTE: Click on ONE link per device (so if you have 2 phones and a laptop, click

on a separate link for each device). If you need additional links, let us know.

Cx_Sandra_Guerra: https://goo.gl/J5GE9Z

• NEXT: Our forensic examiner created the following tracking URLs the suspect(s). They

are designed to help us identify suspects in your case. You need to send the URL to each

suspect on whatever platform (email, social media, text message) works best for that

suspect.

* * * DO NOT CLICK ON THESE LINKS YOURSELF * * *

GUERRA 000077

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P a g c 117

• You need to include the link in a message containing something the suspect might be

interested enough to click on: DO NOT MENTION THE REAL PURPOSE BEHIND THE

LINK. The message could be something like "I'd like to send you money," or "You will

not believe this," alongwith that URL created forthat suspect. Be creative, but do not

reveal what the link really is.

• Ideally, a separate tracking URL should be sent to each and every device and/or account

from/to which the harassment has occurred or is occurring.

• The tracking URLs can be sent either as embedded hyperlinked text (see (i) below) or as

a stand-alone link separate from the text (see (ii) below). We suggest sending the

tracking URL using method (i), an embedded hyperlink, if possible.

GUERRA 000078

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(I): An example of sending a tracking URL as a link embedded in the text.

(ii): An example of sending a tracking URL as a stand-alone link.

Pleiie let me help you

httpS7/goo.gi/Mk¥gfcX

Victim

address and location from which tracking URL access is detected, which then will be

used to identify the Internet Service Provider (ISP) and the approximate location of the

• Once a tracking URL link is accessed, DFC will receive a report with the detected IP

-J

I knowyou have been In ha imes recently. Please let me help you out I want tooffer you this as a gift of our friendship.

Dear Scott

Subjea

1

1 Send

Ccsuspect.

GUERRA 000079

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Page 119

Below are the unique tracking URLs created for this case:

Client-directed tracking URLs

Melody_Cantu:

Rodrigo_Cantu:

DFC-directed tracking URLs

Melody_Joy_From_Teresa:

Dr.Cantu_From_Melissa:

Melody_Joy_via_Phone:

https://goo.gl/QTLpCG

https://goo.gl/yME EVj

https://goo.gl/9gqCAl

https://goo.gl/7fifqF

https://goo.gl/sCbwZZ

If additional tracking URLs are needed, more can be created.

IMPORTANT NOTE:

• Client is advised to notify DFC immediately after sending tracking URLs to

the missing individual. DFC examiners will immediately start IP address

tracking.

• If the client accidentally clicks on a tracking URL, the client should

immediately notify DFC to avoid false positives.

• If additional tracking URLs be needed, the client should let DFC know and

more tracking URLs will be provided.

• Any information obtained, including IP addresses, will be extracted,

analyzed, and provided to the client in a Phase II report.

GUERRA 000080

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TRACKING URL RESULTS

• In the Phase I Process, the DFC Forensic Examiner created specific Tracking URLs to

send to the individuals performingthe alleged harassing.

• Tracking URLs were sent to the appropriate communication platform forthe suspects

to click on. When activated tracking URLs capture recipient's geographic location

(city) and IP address. IP address can provide approximate location.

• Once a tracking URL link is accessed, the DFC will receive a report with the detected IP

address and location from which tracking URL access is detected, which then will be

used to identify the Internet Service Provider (ISP).

Sample DFC-created tracking URLs targeted at suspect.

GUERRA 000081

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Page I 21

• Below are the preliminary results and IP Information of the tracking URLs activated to

date:

Tracking Link: "Melody_Joy_via_Phone" https://goo.gl/sCbwZZ

First Click 2018-08-2112:42:08

IP Address 72.179.164.76

User OS Mac OS X

User Agent Mozilla/5.0 (Macintosh; Intel Mac OS X 10_ll_l)

AppleWebKit/601.2.4 (KHTML, like Gecko) Version/9.0.1

Safari/601.2.4facebookexternalhit/l.l Facebot Twitterbot/1.0

Device Safari

Second Click 2018-08-21 12:42:14

IP Address 72.179.164.76

User OS iPhone

User Agent Mozilla/5.0 (Macintosh; Intel Mac OS X 10_ll_l)

AppleWebKit/601.2.4 (KHTML, like Gecko) Version/9.0.1

Safari/601.2.4facebookexternalhit/l.l Facebot Twitterbot/1.0 Mozilla/5.0

(Macintosh; Intel Mac OS X 10_ll_l) AppleWebKit/601.2.4

(KHTML, like Gecko) Version/9.0.1 Safari/601.2.4

facebookexternalhit/l.l Facebot Twitterbot/1.0

Device Safari

Device and OS Information - Device and OS information can be important

circumstantial and/or corroboratingevidence when attempting to discover the

true identity of an unknown or anonymous harasser.

GUERRA 000082

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The IP discovered as a result of this tracking link is located in San Antonio.

72.179.164.76 Lookup IP Address

Details for 72.179.164.76

IP 72 179 164 76

Decimal 1219732556

Hostname 072-179-164-076 res spectrum com

ASN 11427

ISP Spectrum

Organization Spectrum

Services None detected

Type Broadband

Assignment Dynamic IP

Blacklist:

Continent. North Amenca

Country United States S

State/Region Texas

City San Antonio

Latitude 29 5698 (29’ 34' 11 28’ N)

Longitude -98 6161 (98’ 36' 57 96" W)

Postal Code 78249

Geolocation Map

Click Io Check Blacklist Status

GUERRA 000083

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Page I 23

ENGINEER'S SUMMARY AND RECOMMENDATIONS

• Based on the evidence provided to Digital Forensics Corporation by Client and Digital

Forensics Corporation's independent investigation, we conclude that a Phase II

Forensics Examination is recommended.

• Phase I Evaluation Report is intended for internal communication between

client and Digital Forensics Corporation; and informs the client about relevance

of findings. Phase I is not intended for use in courtrooms, presentation to

opposing counsel, arbitration, and any other legal proceedings.

• Phase II Full Examination Report is admissible in court, and includes a notarized

Affidavit of the authenticity of digital evidence.

GUERRA 000084

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Page I 24

__________________________ CONCLUSION

- - ~ - . ... — — —---------, ................................................................................ .. ............ - .........

PHASE II FORENSIC EXAMINATION - Phase II is intended to discover the identity of the

perpetrator(s)and/or suspect(s), as well as eliminate potential persons of interest. The results

of the tracking URLs, which report back to Digital Forensics Corporation the IP address of the

device when and ifthe URL is clicked, will be used in the process of discoveringthe true identity

ofthe suspect(s). Ifthese efforts are unsuccessful in discoveringthetrue identityofthe suspect,

DFC will assist the client in resorting to legal action to compel the relevelant parties (internet

service provider, phone service provider, and online service provider) to produce evidence

related to the suspect.

The client is advised to:

• File a police report with the appropriate police department and attach a copy of this

Phase I Evaluation Report to it (or add it as a "supplement" if a police report already

exists);

• Provide a time-stamped copy of the police report, containing this Phase I Evaluation

Report, to DFC;

• Send out DFC's tracking URLs to the suspect(s) and click on the tracking URL for the

client him/herself; and

• Alert DFC of any ongoing cyber harassment.

Although Digital Forensics Corporation uses the best available forensic practices and

technologies, DFC cannot guarantee any particular outcome or that any specific

information will be discovered during a forensic examination.

GUERRA 000085

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Page I 25

APPENDIX A - SAMPLE POLICE REPORT

Case Number:

Date:

Reporting Officer:

Prepared By:

Address:

Incident Type: Cyber Harassment.

Attempted Phone Hacking;

Identity Theft and Misappropriation;

Defamation;

Victim(s): Dr. Sandra Guerra

Evidence: Digital Forensics Corporation's Phase 1 Evaluation Report

(attached hereto as Exhibit A)

I, Dr. Sandra Guerra, am a victim of cyber harassment, attempted phone hacking, identity theft

and misappropriation, and defamation.

First beginning on or about May 16, 2018, , I began to be cyber harassed. The harassment

included attempted phone hacking, identity theft and misappropriation, and defamation, among

other things. This harassment was conducted by an UNKNOWN person(s). This harassment is

documented in the Phase I Evaluation Report attached hereto as Exhibit A. As a result of this

harassment, I have been HARMED personally and professionally.

I have hired a digital forensics company, Digital Forensics Corporation, to conduct an

independent investigation. They are currently working on identifying the individual(s)

responsible for this cyber harassment and assisted me with documentation of cyber harassment

as indicated in the report attached hereto as Exhibit A.

GUERRA 000086

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Page I 26

I am interested in identifying and pursuing legal action against the individual or individuals

responsible for this harassment against myself, my friends, and my family.

Name:______________________________

Date:

GUERRA 000087

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