EXHIBIT N 

Case 5:20-cv-00746-JKP Document 119-6 Filed 11/14/22 Page 1 of 4
Supplemental Responses – Joint Advisory

Defendant Dr. Guerra’s First Set of Interrogatories for Plaintiff Dr. Rodrigo Cantu

1. $18,415.61. Jointly and severally between Defendants Dr. Guerra and DFC for 

compensatory damages related to Defendants’ unlawful conduct. See 

Dr.CantuProd#000001-28 (Computer Forensic Investigations, LLC retainer and billing 

records, expenses are ongoing and subject to increase); Dr.CantuProd#000005 (retainer 

agreement signed with Computer Forensic Investigations, LLC); MCantuProd00193-206 

(service appointment scheduling and billing from Spectrum Cable to identify the issue 

with Plaintiff’s internet network, and photos of cable splicing); PlaintiffSuppDisc#00186-

87 (Purchase of replacement MacBook).

2. $18,415.61. Jointly and severally between Defendants Dr. Guerra and DFC for 

compensatory damages related to Defendants’ unlawful conduct. See 

Dr.CantuProd#000001-28 (Computer Forensic Investigations, LLC retainer and billing 

records, expenses are ongoing and subject to increase); Dr.CantuProd#000005 (retainer 

agreement signed with Computer Forensic Investigations, LLC); MCantuProd00193-206 

(service appointment scheduling and billing from Spectrum Cable to identify the issue 

with Plaintiff’s internet network, and photos of cable splicing); PlaintiffSuppDisc#00186-

87 (Purchase of replacement MacBook).

3. $18,415.61. Jointly and severally between Defendants Dr. Guerra and DFC for 

compensatory damages related to Defendants’ unlawful conduct. See 

Dr.CantuProd#000001-28 (Computer Forensic Investigations, LLC retainer and billing 

records, expenses are ongoing and subject to increase); Dr.CantuProd#000005 (retainer 

agreement signed with Computer Forensic Investigations, LLC); MCantuProd00193-206 

(service appointment scheduling and billing from Spectrum Cable to identify the issue 

with Plaintiff’s internet network, and photos of cable splicing); PlaintiffSuppDisc#00186-

87 (Purchase of replacement MacBook).

4. $18,415.61. Jointly and severally between Defendants Dr. Guerra and DFC for 

compensatory damages related to Defendants’ unlawful conduct. See 

Dr.CantuProd#000001-28 (Computer Forensic Investigations, LLC retainer and billing 

records, expenses are ongoing and subject to increase); Dr.CantuProd#000005 (retainer 

agreement signed with Computer Forensic Investigations, LLC); MCantuProd00193-206 

(service appointment scheduling and billing from Spectrum Cable to identify the issue 

with Plaintiff’s internet network, and photos of cable splicing); PlaintiffSuppDisc#00186-

87 (Purchase of replacement MacBook).

5. $4,000.00. PlaintiffSuppDisc#00142, 00150-51, 00167-68, 00176 (Time off for Plaintiff 

Melody Joy Cantu’s court dates).

Case 5:20-cv-00746-JKP Document 119-6 Filed 11/14/22 Page 2 of 4
6. $4,000.00. PlaintiffSuppDisc#00142, 00150-51, 00167-68, 00176 (Time off for Plaintiff 

Melody Joy Cantu’s court dates.

7. $5,460.00. Jointly and severally between Defendants Dr. Guerra and DFC for 

compensatory damages related to Defendants’ intentional infliction of emotional distress, 

these costs are ongoing and subject to increase. See HIPPA forms for request for records 

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

(Medical Services provided to Dr. Cantu). 

8. $5,460.00. Jointly and severally between Defendants Dr. Guerra and DFC for 

compensatory damages related to Defendants’ intentional infliction of emotional distress, 

these costs are ongoing and subject to increase. See HIPPA forms for request for records 

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

(Medical Services provided to Dr. Cantu).

9. $316,615.76. Jointly and severally between Defendants Dr. Guerra and DFC for 

consequential damages related to Defendants’ unlawful conduct. These bills continue to 

accumulate for Plaintiff Dr. Rodrigo Cantu and are subject to increase. See Attorney 

Affidavit of Tor Ekeland (Attorney’s fees for this case, subject to ongoing increase); 

MCantuFinalProd#001081-82, 001245-46 (Loss of 401k profit by having to withdraw to 

deal with this case); MCantuFinalProdBates#001680-1682 (Hawk Security Service bills); 

PlaintiffsSuppDisc#111 (Kelmar Security bills); PlaintiffsSuppDisc#00201-03 

(replacement of unusable iPads affected by Defendants’ computer intrusion).

10. $316,615.76. Jointly and severally between Defendants Dr. Guerra and DFC for 

consequential damages related to Defendants’ unlawful conduct. These bills continue to 

accumulate for Plaintiff Dr. Rodrigo Cantu and are subject to increase. See Attorney 

Affidavit of Tor Ekeland (Attorney’s fees for this case, subject to ongoing increase); 

MCantuFinalProd#001081-82, 001245-46 (Loss of 401k profit by having to withdraw to 

deal with this case); MCantuFinalProdBates#001680-1682 (Hawk Security Service bills); 

PlaintiffsSuppDisc#111 (Kelmar Security bills); PlaintiffsSuppDisc#00201-03 

(replacement of unusable iPads affected by Defendants’ computer intrusion).

11. $316,615.76. Jointly and severally between Defendants Dr. Guerra and DFC for 

consequential damages related to Defendants’ unlawful conduct. These bills continue to 

accumulate for Plaintiff Dr. Rodrigo Cantu and are subject to increase. See Attorney 

Affidavit of Tor Ekeland (Attorney’s fees for this case, subject to ongoing increase); 

MCantuFinalProd#001081-82, 001245-46 (Loss of 401k profit by having to withdraw to 

deal with this case); MCantuFinalProdBates#001680-1682 (Hawk Security Service bills); 

PlaintiffsSuppDisc#111 (Kelmar Security bills); PlaintiffsSuppDisc#00201-03 

(replacement of unusable iPads affected by Defendants’ computer intrusion).

Case 5:20-cv-00746-JKP Document 119-6 Filed 11/14/22 Page 3 of 4
12. $316,615.76. Jointly and severally between Defendants Dr. Guerra and DFC for 

consequential damages related to Defendants’ unlawful conduct. These bills continue to 

accumulate for Plaintiff Dr. Rodrigo Cantu and are subject to increase. See Attorney 

Affidavit of Tor Ekeland (Attorney’s fees for this case, subject to ongoing increase); 

MCantuFinalProd#001081-82, 001245-46 (Loss of 401k profit by having to withdraw to 

deal with this case); MCantuFinalProdBates#001680-1682 (Hawk Security Service bills); 

PlaintiffsSuppDisc#111 (Kelmar Security bills); PlaintiffsSuppDisc#00201-03 

(replacement of unusable iPads affected by Defendants’ computer intrusion).

13. $217,066.79. Jointly and severally between Defendants Dr. Guerra and DFC for 

consequential damages related to Defendants’ malicious prosecution of Plaintiff Melody 

Joy Cantu. See Attorney Affidavit of Tor Ekeland (Attorney’s fees for this case, subject 

to ongoing increase).

14. $217,066.79. Jointly and severally between Defendants Dr. Guerra and DFC for 

consequential damages related to Defendants’ malicious prosecution of Plaintiff Melody 

Joy Cantu. See Attorney Affidavit of Tor Ekeland (Attorney’s fees for this case, subject 

to ongoing increase). 

15. $5,460.00. Jointly and severally between Defendants Dr. Guerra and DFC for 

compensatory damages related to Defendants’ intentional infliction of emotional distress, 

these costs are ongoing and subject to increase. See HIPPA forms for request for records 

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

(Medical Services provided to Dr. Cantu).

16. $5,460.00. Jointly and severally between Defendants Dr. Guerra and DFC for 

compensatory damages related to Defendants’ intentional infliction of emotional distress, 

these costs are ongoing and subject to increase. See HIPPA forms for request for records 

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

(Medical Services provided to Dr. Cantu).

17. $10,000,000.00. Jointly and Severally between Defendants Dr. Guerra and DFC for 

punitive damages related to Defendants’ unlawful conduct. 

18. $10,000,000.00. Jointly and Severally between Defendants Dr. Guerra and DFC for 

punitive damages related to Defendants’ unlawful conduct. 

Plaintiffs also seek full attorney’s fees for Tor Ekeland Law, PLLC, jointly and severally 

between Defendants Dr. Guerra and DFC, related to this case. Currently, $209,979.89 has 

been billed for time and expenses. This amount is subject to increase. 

Case 5:20-cv-00746-JKP Document 119-6 Filed 11/14/22 Page 4 of 4