EXHIBIT G - Supplemental Declaration Joel Ignatovich

 UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

Albert Rojas,

Plaintiff,

v.

340B Technologies Inc. d/b/a Nuvem Health LLC,

Defendant.

Case No. 1:25-cv-04684 (JGK)(JW)

SUPPLEMENTAL DECLARATION OF ALBERT ROJAS UNDER 28

U.S.C. §1746

I, Albert Rojas, declare as follows:

1. I am the Plaintiff in this action. I submit this supplemental declaration to provide

additional evidence regarding sysadmin credential custody on Nuvem’s

production environment.

2. On [insert date of console capture], I accessed the Nuvem console interface used

to manage administrative permissions. The console entry identified Joel

Ignatovich as the administrator with custody of the sysadmin password credential

(see Exhibit E).

 3. This evidence confirms the statements in my prior declaration (Exhibits A–E) that

Mr. Ignatovich held the sysadmin key and was positioned to pass it downstream

for offshore use. It corroborates the October 20, 2023 text message exchange

(Exhibit E), where he acknowledged our shared concern about improper sysadmin

provisioning.

4. Exhibit F demonstrates that the sysadmin key was not an abstract or hypothetical

concern. Nuvem maintained a live console structure that documented credential

custody, confirming my October 17 warning (Exhibit A) and October 19

regulatory filing (Exhibit B).

5. This evidence is offered in light of Nuvem and Davis Wright Tremaine LLP’s

WIPO UDRP filing of October 21, 2025, which contained factual misstatements

later addressed in my Rule 11(c)(2) Safe-Harbor Notice dated October 24, 2025.

By that date, Nuvem was indisputably on notice of the sysadmin-key issue and the

federal OCR breach filing. Exhibit F further establishes that their certifications

were false or made in reckless disregard of the evidence.

I declare under penalty of perjury under the laws of the United States of America that the

foregoing is true and correct.

Executed on October 25, 2025, at New York, NY.

Respectfully submitted,

/s/ Albert Rojas

Albert Rojas (Pro Se)

319 W. 18th Street, Apt 3F

New York, NY 10011

rojas.albert@gmail.com | (646) 866-1669