209. In addition, the representative asked the Court to order the State to pay, as nonpecuniary damage, 241 the sum of US$150,000.00 (one hundred and fifty thousand United States dollars) to Mrs. Suárez Peralta, US$100,000.00 ((one hundred thousand United States dollars) to Melba Peralta Mendoza, US$50,000 (fifty thousand United States dollars) to Dennis Cerezo Cervantes and US$20,000 (twenty thousand United States dollars) to each of their children: Gandy, Katherine and Marilyn, all with the surnames Cerezo Suárez. 210. The State indicated, with regard to incidental damage, that the Court should “stipulate that there are possibly grounds for incidental damage calculated at $38,654.22 (thirty-eight thousand six hundred and fifty-four United States dollars and twenty-two cents), a sum equal to 12% of the amount requested by the representative.” Consequently, the State asked the Court to rule, in equity, with regard to the pecuniary damage. However, in its final written arguments, the State asked the Court “[t]o declare inadmissible to claims for the supposed pecuniary damage, because the amounts claimed had not been validly [substantiated …]. Therefore, if the Court should decide pecuniary reparation, this should not be more than twenty thousand dollars for loss of earnings and incidental damage.” The State also contested everything requested for loss of earnings. 242 211. Regarding non-pecuniary damage, the State indicated that the amounts stipulated by the representative were extremely high, because the Compliance Agreement between the presumed victims and the Ministry of Justice included an amount corresponding to pecuniary damage, non-pecuniary damage, costs and expenses of $300,000.00 (three hundred thousand dollars). In addition, in its final written arguments, the State asked the Court to declare that the non-pecuniary damage should be calculated, based on the equity principle, in accordance with the standards and principles contained in inter-American case law, which could never be more than a total of $10,000.00 (ten thousand dollars) for the two victims. November 2008 $180.00; (13) Emergency hospitalization twice: Alcívar Clinic $8,045.08; (14) Operation on adhesions in the Alcívar Clinic: $7,345.50; (15) Cleaning adhesions in the Alcívar Clinic: $1,500.00; (16) Loan from Luis Azanza Azanza $11,800.00; (17) Loan from Stalin Intriago Burgos $8,000.00; (18) Loan from Luis Humberto Córdova Ramos $8,500.00; (19) Sale of house of Melba Suárez Peralta $28,000.00; (20) Sale of 2005 Jeep Hyundai Tucson: $20,990.00; 21) Sale of vehicle, license plate GNX-577: $12,810.00; (22) Sale of vehicle, license plate GPB969: $12,810.00; (23) Loan from the Retirement Fund of the CTE Supervisory Units: $20,902.04; (24) Loans from the Banco Cooperativa Nacional: $18,340.00; (25) Loans from COOPCCP Cooperativa Financiera: $14,000.00; (26) Loans from the Banco Solidario: $4,005.61; (27) Loans from the CTE Credit and Loan Cooperative: $6,540.00; (28) Annual property rental 2009/2010/2011: $12,040,00; (29) MasterCard Debt: $1,413.14; (30) Diners Club of Ecuador debt: $6,086.09; (31) Debt with the Banco de Pichincha financial institutions: $923.12; (32) Debt with the Banco de Guayaquil financial institutions: $2,410.16; (33) Debt with the Alcívar Hospital Clinic financial institutions: $273.00, and (34) General expenditure for treatment of keratoconus for the child Gandy Cerezo: $20,000.00.” 241 The representative indicated that, in this case, the non-pecuniary damage should be analyzed based on the following circumstances: (a) the operation perform on Mrs. Suárez Peralta in July 2000; (b) the permanent post-operative complications due to the adhesions that continually formed in Mrs. Suárez Peralta’s intestine; (c) the physical pain and the suffering resulting from the subsequent operations and the rehabilitation; (d) the pain and anguish resulting from the termination of Mrs. Suárez Peralta’s employment, and (e) the effects suffered by her family members. 242 In this regard, the State indicated that “the company that Melba Suárez supposedly owned, dedicated to the rental of vehicles and known as "Melba Suárez,” […] is not registered as a company in the Company Registry of Duran canton, or in that of Guayaquil; moreover, it does not exist as a company registered with the Superintendence of Companies; in other words this company does not exist and has never existed.” It also indicated that “the taxpayers, Melba del Carmen Suárez Peralta and Dennis Edgar Cerezo Cervantes have never presented a tax return; in other words, the supposed income of Mrs. Suárez was never recorded by the Ecuadorian tax authorities [and], consequently, is unsubstantiated. Consequently, the State “contest[ed] everything requested for loss of earnings.” 56