UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

SAN ANTONIO

______________________________________

MELODY JOY CANTU AND DR. RODRIGO 

CANTU,

Plaintiffs,

v.

DR. SANDRA GUERRA and DIGITAL 

FORENSICS CORPORATION, LLC,

Defendants.

5:20-CV-0746 JKP – HJB

______________________________________

PLAINTIFFS’ATTACHMENTS TO DKT. NO. 78 MOTION TO COMPEL 

DISCOVERY

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 1 of 20
DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUESTS FOR PRODUCTION PAGE 1 OF 9

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

MELODY JOY CANTU and

DR. RODRIGO CANTU, 

Plaintiffs

V.

DR. SANDRA GUERRA and

DIGITAL FORENSICS 

CORPORATION, LLC

Defendants

§

§

§

§

§

§

§

§

§

§

CASE NO 5:20-CV-00746-JKP (HJB)

DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO

PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

TO: Plaintiffs, MELODY JOY CANTU and DR. RODRIGO CANTU, by and through their 

attorneys of record, Tor Ekeland, TOR EKELAND LAW, PLLC, 30 Wall Street, 8th Floor, 

New York, NY 10005, Email: tor@torekeland.com, and Rain Minns, MINNS LAW 

FIRM, P.C. d/b/a RAIN MINNS LAW FIRM, 4412 Spicewood Springs Rd., Suite 500, 

Austin, TX 78759-8583, Email: rain@rainminnslaw.com.

Now comes Defendant, DR. SANDRA GUERRA, and serves these her Objections 

Responses to Plaintiffs’ First Request for Production of Documents, attached hereto and 

incorporated herein as if fully copied and set forth at length.

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 2 of 20
DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUESTS FOR PRODUCTION PAGE 2 OF 9

Respectfully submitted,

McCombs Plaza, Suite 250

755 E. Mulberry Avenue

San Antonio, Texas 78212

Telephone No.: (210) 822-6666

Telecopier No.: (210) 660-3795

 

By:

RICARDO G. CEDILLO

State Bar No. 04043600

rcedillo@lawdcm.com

BRANDY C. PEERY

State Bar No. 24057666

bpeery@lawdcm.com

ATTORNEYS FOR DEFENDANT,

DR. SANDRA GUERRA

CERTIFICATE OF SERVICE

I certify that on this 28th day of February 2022, a true and correct copy of the foregoing 

was served to all counsel of record for the parties in accordance with the Federal Rules of Civil 

Procedure. 

Ricardo G. Cedillo

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 3 of 20
DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUESTS FOR PRODUCTION PAGE 3 OF 9

DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

REQUEST FOR PRODUCTION NO. 1:

All communications, including recordings, ESI, emails, phone calls, etc., between Dr. Guerra and 

any investigative services she has used to look into Dr. Cantu and/or Mrs. Cantu.

OBJECTIONS: Defendant objects to this request on the grounds that: (i) it is 

argumentative; (ii) assumes facts not established with respect to 

whether Defendant engaged the services of any third party for the 

specific purpose of “look[ing] into” Plaintiffs as opposed to another 

purpose; and (iii) is vague as to the phrase “look into.”

RESPONSE: Defendant interprets “look into” as meaning to try to discover the 

facts about something or someone. Subject to and without waiving 

the foregoing objections, please see GUERRA 000037 – 000087

previously produced. Defendant will produce other responsive, 

non-privileged documents (if any) within her custody, possession,

or control after a diligent search of Defendant’s records.

REQUEST FOR PRODUCTION NO. 2:

Recordings, transcripts, and/or records of communications between Dr. Guerra and Dr. Cantu 

and/or Mrs. Cantu.

OBJECTIONS: Defendant objects to this request on the grounds that it is not 

properly limited in scope. 

RESPONSE: Subject to and without waiving the foregoing objection, Defendant 

will produce responsive, non-privileged documents (if any) within 

her custody, possession, or control after a diligent search of

Defendant’s records.

REQUEST FOR PRODUCTION NO. 3:

Contracts Dr. Guerra signed with any investigative service including Detective.com, and Digital 

Forensics Corporation LLC.

OBJECTIONS: Defendant objects to this request on the grounds that it is not 

properly limited in scope. 

RESPONSE: Subject to and without waiving the foregoing objection, Defendant 

will produce responsive, non-privileged documents (if any) within 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 4 of 20
DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUESTS FOR PRODUCTION PAGE 4 OF 9

her custody, possession, or control after a diligent search of

Defendant’s records.

REQUEST FOR PRODUCTION NO. 4:

All statements, such as bank statements, receipts of cash/check withdrawals containing evidence 

that Dr. Guerra paid for her counsel Andrew Del Cueto.

OBJECTIONS: Defendant objects to this request on the grounds that it: (i) seeks 

information protected by the attorney-client privilege and/or workproduct privilege; (ii) seeks information and materials constituting 

Defendant’s private and/or confidential information; and (iii) is 

irrelevant and not reasonably calculated to lead to the discovery of 

admissible evidence.

REQUEST FOR PRODUCTION NO. 5:

Provide receipts and all records related to the purchase of the iPads for your daughters (referenced 

in your counterclaims) and any evidence that show you were searching for the lost or missing iPad.

RESPONSE: Defendant will produce responsive, non-privileged documents (if 

any) within her custody, possession, or control after a diligent search 

of Defendant’s records.

REQUEST FOR PRODUCTION NO. 6:

All documents and communications between Dr. Guerra and Digital Forensics Corporation, LLC.

RESPONSE: Please see GUERRA 000062 – 000087 previously produced. 

Defendant will produce other responsive, non-privileged documents 

(if any) within her custody, possession, or control after a diligent 

search of Defendant’s records.

REQUEST FOR PRODUCTION NO. 7:

All documents and communications concerning this matter which Dr. Guerra will raise, introduce, 

or rely upon at trial.

OBJECTION: Defendant objects to this request on the grounds that it is premature 

as discovery has only recently begun in this case.

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 5 of 20
DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUESTS FOR PRODUCTION PAGE 5 OF 9

RESPONSE: Subject to and without waiving the foregoing objection, please see 

GUERRA 000001 – 000097 previously produced. Defendant will 

produce other responsive, non-privileged documents (if any) within 

her custody, possession, or control after a diligent search of

Defendant’s records. Defendant further reserves the right to use at 

trial any document produced by any party to this cause of action.

REQUEST FOR PRODUCTION NO. 8:

Any ESI or physical evidence or documentation asserting that there has been unauthorized access 

to Dr. Cantu’s and Dr. Guerra’s daughters’ iPad.

RESPONSE: Please see GUERRA 000062 – 000096 previously produced. 

Defendant will produce other responsive, non-privileged documents 

(if any) within her custody, possession, or control after a diligent 

search of Defendant’s records. Defendant further reserves the right 

to use at trial any document produced by any party to this cause of 

action.

REQUEST FOR PRODUCTION NO. 9:

Any ESI or physical evidence or documentation asserting that Dr. Guerra’s Verizon account has 

been accessed without authorization.

RESPONSE: Please see GUERRA 000062 – 000096 previously produced. 

Defendant will produce other responsive, non-privileged documents 

(if any) within her custody, possession, or control after a diligent 

search of Defendant’s records. 

REQUEST FOR PRODUCTION NO. 10:

Any ESI or physical evidence or documentation asserting that Dr. Guerra sustained a loss due to 

the unauthorized access of her daughters’ iPad and/or Verizon account.

RESPONSE: Please see GUERRA 000062 – 000096 previously produced. 

Defendant will produce other responsive, non-privileged documents 

(if any) within her custody, possession, or control after a diligent 

search of Defendant’s records. 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 6 of 20
DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUESTS FOR PRODUCTION PAGE 6 OF 9

REQUEST FOR PRODUCTION NO. 11:

Any ESI or physical evidence or documentation asserting that Dr. Guerra’s computer network has 

been accessed without authorization.

RESPONSE: Please see GUERRA 000062 – 000096 previously produced. 

Defendant will produce other responsive, non-privileged documents 

(if any) within her custody, possession, or control after a diligent 

search of Defendant’s records. 

REQUEST FOR PRODUCTION NO. 12:

Any ESI or physical evidence or documentation asserting that Dr. Guerra’s personal email has 

been accessed without authorization.

RESPONSE: Please see GUERRA 000062 – 000096 previously produced. 

Defendant will produce other responsive, non-privileged documents 

(if any) within her custody, possession, or control after a diligent 

search of Defendant’s records. 

REQUEST FOR PRODUCTION NO. 13:

Any ESI or physical evidence or documentation obtained from accessing Mrs. Cantu’s email, 

social media, personal devices, and router.

RESPONSE: Defendant will produce responsive, non-privileged documents (if 

any) within her custody, possession, or control after a diligent search 

of Defendant’s records. 

REQUEST FOR PRODUCTION NO. 14:

Any ESI or physical evidence or documents containing information regarding defamation of your 

character by the Cantus.

RESPONSE: Please see GUERRA 000021 – 000036 and GUERRA 000088 –

000096 previously produced. Defendant will produce other 

responsive, non-privileged documents (if any) within her custody,

possession, or control after a diligent search of Defendant’s records. 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 7 of 20
DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUESTS FOR PRODUCTION PAGE 7 OF 9

REQUEST FOR PRODUCTION NO. 15:

Any ESI or physical evidence or documents containing direct threats to you or your children by 

the Cantus.

RESPONSE: Defendant will produce responsive, non-privileged documents (if 

any) within her custody, possession, or control after a diligent search 

of Defendant’s records. 

REQUEST FOR PRODUCTION NO. 16:

Any bank statements or credit card statements showing that you hired security for your wedding.

OBJECTION: Defendant objects to this request on the grounds that it: (i) seeks 

information and materials constituting Defendant’s private and/or 

confidential information.

RESPONSE: Subject to and without waiving the foregoing objection, Defendant 

will produce responsive, non-privileged documents (if any) within 

her custody, possession, or control after a diligent search of

Defendant’s records. 

REQUEST FOR PRODUCTION NO. 17:

A copy of your restraining order against Mrs. Cantu.

OBJECTION: Defendant objects to this request on the grounds that it is 

argumentative and assumes facts not established.

RESPONSE: Subject to and without waiving the foregoing objection, none. 

Defendant did not obtain a temporary restraining order against 

Plaintiff, Melody Joy Cantu. On April 2, 2018, Dr. Guerra and 

Plaintiff, Dr. David Cantu, met at the Bexar County Courthouse 

Annex to file a restraining order against Plaintiff, Melody Joy Cantu. 

Defendant was informed that she was unable to obtain a restraining 

order against Plaintiff, Melody Joy Cantu, because she had not had 

a sexual relationship with Plaintiff, Melody Joy Cantu. Plaintiff, Dr. 

David Cantu, proceeded to request a restraining order against 

Melody which was timely issued. 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 8 of 20
DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUESTS FOR PRODUCTION PAGE 8 OF 9

REQUEST FOR PRODUCTION NO. 18:

Any ESI or physical evidence or documentation containing your last contact and/or 

communication with Mrs. Cantu.

RESPONSE: Defendant will produce responsive, non-privileged documents (if 

any) within her custody, possession, or control after a diligent search 

of Defendant’s records. 

REQUEST FOR PRODUCTION NO. 19:

Any phone bills and/or ESI containing calls to the police regarding alleged stalking by Mrs. Cantu.

RESPONSE: Defendant will produce responsive, non-privileged documents (if 

any) within her custody, possession, or control after a diligent search 

of Defendant’s records. 

REQUEST FOR PRODUCTION NO. 20:

Any ESI or physical evidence or documents showing you had to miss work due to alleged 

hacking(s).

RESPONSE: Defendant will produce responsive, non-privileged documents (if 

any) within her custody, possession, or control after a diligent search 

of Defendant’s records. 

REQUEST FOR PRODUCTION NO. 21:

Any ESI or physical evidence or documents that show your email and name were used to set up 

online profiles/accounts on your behalf.

RESPONSE: Please see GUERRA 000062 – 000096. Defendant will produce 

other responsive, non-privileged documents (if any) within her

custody, possession, or control after a diligent search of Defendant’s 

records. 

REQUEST FOR PRODUCTION NO. 22:

Any ESI or physical evidence or documents that your personal email(s) account(s) were accessible 

through your daughter’s iPad.

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 9 of 20
DEFENDANT, DR. SANDRA GUERRA’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUESTS FOR PRODUCTION PAGE 9 OF 9

RESPONSE: Please see GUERRA 000062 – 000096. Defendant will produce 

other responsive, non-privileged documents (if any) within her

custody, possession, or control after a diligent search of Defendant’s 

records. 

REQUEST FOR PRODUCTION NO. 23:

Any ESI or physical evidence or documents containing phone records from April 1, 2018 – April 

2, 2018.

OBJECTION: Defendant objects to this request as not being properly limited in 

scope. This request does not state with reasonable particularity the 

phone records of calls to or from whom or between whom it seeks. 

RESPONSE: Subject to and without waiving the foregoing objection, Defendant 

will produce responsive, non-privileged documents (if any) within 

her custody, possession, or control after a diligent search of

Defendant’s records. 

REQUEST FOR PRODUCTION NO. 24:

Any ESI or physical evidence or documentation, including any hardware electronic devices or 

software given to DFC for forensic analysis or any other analysis.

RESPONSE: Defendant will produce responsive, non-privileged documents (if 

any) within her custody, possession, or control after a diligent search 

of Defendant’s records. 

REQUEST FOR PRODUCTION NO. 25:

All documents related to your recent settlement with Humana Inc.

OBJECTION: Defendant objects to this request on the grounds that: (i) it seeks 

Defendant’s private and confidential information; (ii) seeks 

documents that are protected by the work-product privilege and/or 

attorney-client privilege; (iii) seeks documents that are subject to a 

confidentiality agreement between Defendant and a third party; (iv) 

not properly limited in scope and amounts to nothing more than an 

impermissible “fishing expedition;” and (v) is irrelevant and not 

reasonably calculated to lead to the discovery of admissible 

evidence. 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 10 of 20
DEFENDANT DIGITAL FORENSICS CORPORATION’S OBJECTIONS AND 

RESPONSES TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION PAGE 1

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

MELODY JOY CANTU AND §

DR. RODRIGO CANTU, §

§

Plaintiffs, §

§

V. § CIVIL ACTION NO. 5:20-CV-0746-JKP

§

DR. SANDRA GUERRA and DIGITAL §

FORENSICS CORPORATION, LLC, §

§

Defendants. §

DEFENDANT DIGITAL FORENSICS CORPORATION’S OBJECTIONS AND RESPONSES TO 

PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION

TO: Plaintiffs Melody Joy Cantu and Dr. Rodrigo Canto, by and through their attorneys of 

record, Tor Ekeland, Tor Ekeland Law, PLLC, 195 Montague Street, 14th Floor, 

Brooklyn, NY 11201, and Rain Levy Minns, Minns Law Firm, P.C., d/b/a Rain Minns

Law Firm, 4412 Spicewood Springs Road, Suite 500, Austin, Texas 78759

Defendant Digital Forensics Corporation, LLC (“Defendant or DFC”) submits its 

Objections and Responses to Plaintiffs’ First Request for Production.

DEFENDANT’S OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS

The following objections to Instructions and Definitions are incorporated by reference 

into each specific objection to each request: 

1. Defendant objects to Plaintiffs’ Instructions and Definitions to the extent they are 

inconsistent with the plain meaning of a defined term or are inconsistent with the Federal Rules 

of Civil Procedure or the Local Rules.

2. Defendant objects to the definition of “DFC” as overly broad, unduly 

burdensome, vague, and ambiguous. Defendant further objects to this definition to the extent it 

requires Defendant to provide information not in its possession, care, custody, or control.

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 11 of 20
DEFENDANT DIGITAL FORENSICS CORPORATION’S OBJECTIONS AND 

RESPONSES TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION PAGE 2

3. Defendant objects to the definition of “You,” and “Your” as overly broad, unduly 

burdensome, vague, and ambiguous. Defendant further objects to this definition to the extent it 

requires Defendant to provide information not in its possession, care, custody, or control. 

4. Defendant objects to the Instructions to the extent they seek the production of 

information or documents containing proprietary or confidential business information before the 

parties have agreed to, and the Court has entered, a protective order establishing a procedure for 

disclosing such information under Rule 26(c). 

5. Defendant objects to the Instructions to the extent they are overly broad, unduly 

burdensome, seeking the production of irrelevant evidence, and not proportional to the needs of 

the case. 

6. Defendant objects to the Instructions to the extent they are contrary to, and 

attempt to impose obligations beyond, Federal Rules of Civil Procedure 26 and 34.

7. Defendant objects to the Instructions to the extent they subject Defendant to 

significant expense and undue burden in responding through, inter alia, the identification, 

collection, restoration, and/or processing of information or otherwise, that is likely to be 

disproportionate relative to the likely probative value, if any, of the information sought. 

Defendant further objects to producing electronically stored information or other records in 

response to Plaintiff’s First Requests for Production other than in a form to which Defendant 

agrees and which is reasonable. Defendant reserves the right to have the cost of searching for, 

collecting, and producing any electronically stored information or other records or items shifted 

to Plaintiff.

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 12 of 20
DEFENDANT DIGITAL FORENSICS CORPORATION’S OBJECTIONS AND 

RESPONSES TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION PAGE 3

8. Defendant objects to the Instructions to the extent they seek the disclosure of 

documents or information protected by the attorney-client privilege, work-product doctrine, or 

any other applicable privilege or immunity.

OBJECTIONS AND RESPONSES

REQUEST FOR PRODUCTION NO. 1: All documents and communications, including recordings, 

ESI, emails, phone calls, etc., between DFC and any agents or investigative services they used to 

look into Dr. Cantu and/or Mrs. Cantu.

RESPONSE: Defendant objects to this request for the reason that it asks for information that is 

not proportional to the needs of the case. Specifically, the requested discovery is of low 

importance to resolving the issues and the requested discovery places a burden or expense on 

Defendant that outweighs its likely benefit. Defendant further objects to this request for the 

reason that it covers documents that are protected from discovery by the work product privilege, 

which Defendant is withholding. 

REQUEST FOR PRODUCTION NO. 2: Recordings, transcripts, and/or records of communications

between DFC and Dr. Guerra.

RESPONSE: Defendant objects to this request for the reason that it asks for information that is 

not proportional to the needs of the case. Specifically, the requested discovery is of low 

importance to resolving the issues and the requested discovery places a burden or expense on 

Defendant that outweighs its likely benefit. Defendant further object to this request for the 

reason that it covers privileged communications between Defendant and its counsel as well as 

documents that are protected from discovery by the work product privilege, all of which 

Defendant is withholding. 

REQUEST FOR PRODUCTION NO. 3: Contract(s) Dr. Guerra signed with DFC (and as defined 

above).

RESPONSE: Defendant objects to this request for the reason that it asks for information that is 

not proportional to the needs of the case. Defendant further objects to this request for the reason 

that it covers documents that are protected from discovery by the work product privilege, which 

Defendant is withholding. 

REQUEST FOR PRODUCTION NO. 4: All statements, such as bank statements, receipts of 

cash/check withdrawals containing evidence that Dr. Guerra paid DFC.

RESPONSE: Defendant objects to this request for the reason that it asks for information that is 

not proportional to the needs of the case. Specifically, the requested discovery is of low 

importance to resolving the issues and the requested discovery places a burden or expense on 

Defendant that outweighs its likely benefit. Defendant further objects to this request for the 

reason that it covers documents that are protected from discovery by the work product privilege, 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 13 of 20
DEFENDANT DIGITAL FORENSICS CORPORATION’S OBJECTIONS AND 

RESPONSES TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION PAGE 4

which Defendant is withholding. 

REQUEST FOR PRODUCTION NO. 5: All statements, such as bank statements, receipts of 

cash/check withdrawals containing evidence that Dr. Guerra received any form or refund from 

DFC.

RESPONSE: Defendant objects to this request for the reason that it asks for information that is 

not proportional to the needs of the case. Specifically, the requested discovery is of low 

importance to resolving the issues and the requested discovery places a burden or expense on 

Defendant that outweighs its likely benefit. Defendant further objects to this request for the 

reason that it covers documents that are protected from discovery by the work product privilege, 

which Defendant is withholding. 

REQUEST FOR PRODUCTION NO. 6: All documents and communications concerning this 

matter which DFC will raise, introduce, or rely upon at trial.

RESPONSE: Defendant has not determined what documents it will raise, introduce or rely 

upon at trial and, thus, will supplement this response.

REQUEST FOR PRODUCTION NO. 7: Any ESI or physical evidence or documentation pointing 

to any form of unauthorized access of the Cantus internet service, cable providers, etc., by DFC.

RESPONSE: Defendant objects to this request for the reason that it is vague and assumes facts 

not in evidence. Subject to and without waiving the forgoing objections, Defendant has no

documents responsive to this request.

REQUEST FOR PRODUCTION NO. 8: Any ESI or physical evidence or documentation containing 

the Cantus’ personal information.

RESPONSE: Defendant objects to this request for the reason that it is vague and overly broad. 

Defendant objects to this request for the reason that it asks for information that is not 

proportional to the needs of the case. Specifically, the requested discovery is of low importance 

to resolving the issues and the requested discovery places a burden or expense on Defendant that

outweighs its likely benefit. Defendant further objects to this request for the reason that it covers 

documents that are protected from discovery by the work product privilege, which Defendant is 

withholding. 

REQUEST FOR PRODUCTION NO. 9: Any ESI or physical evidence or documentation showing 

the Cantus had any form of participation or knowledge of alleged unauthorized access of Dr. 

Guerra’s devices and/or internet service/accounts.

RESPONSE: Defendant objects to this request for the reason that and to the extent it seeks 

Defendant’s private and confidential information, seeks documents that are protected by the 

work-product privilege and/or attorney-client privilege, seeks documents that are subject to a 

confidentiality agreement, assumes facts not in evidence, and is not properly limited in scope and 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 14 of 20
DEFENDANT DIGITAL FORENSICS CORPORATION’S OBJECTIONS AND 

RESPONSES TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION PAGE 5

amounts to nothing more than an impermissible “fishing expedition,” Defendant objects to this 

request for the reason that it asks for information that is not proportional to the needs of the case. 

Specifically, the requested discovery is of low importance to resolving the issues and the 

requested discovery places a burden or expense on Defendant that outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 10: Any ESI or physical evidence or documentation asserting 

that Dr. Guerra’s computer network has been accessed without authorization.

RESPONSE: Defendant objects to this request for the reason that and to the extent it seeks 

Defendant’s private and confidential information, seeks documents that are protected by the 

work-product privilege and/or attorney-client privilege, seeks documents that are subject to a 

confidentiality agreement, assumes facts not in evidence, and is not properly limited in scope and 

amounts to nothing more than an impermissible “fishing expedition,” Defendant objects to this 

request for the reason that it asks for information that is not proportional to the needs of the case. 

Specifically, the requested discovery is of low importance to resolving the issues and the 

requested discovery places a burden or expense on Defendant that outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 11: Any ESI or physical evidence or documentation asserting 

that Dr. Guerra’s personal email has been accessed without authorization.

RESPONSE: Defendant objects to this request for the reason that and to the extent it seeks 

Defendant’s private and confidential information, seeks documents that are protected by the 

work-product privilege and/or attorney-client privilege, seeks documents that are subject to a 

confidentiality agreement, assumes facts not in evidence, and is not properly limited in scope and 

amounts to nothing more than an impermissible “fishing expedition,” Defendant objects to this 

request for the reason that it asks for information that is not proportional to the needs of the case. 

Specifically, the requested discovery is of low importance to resolving the issues and the 

requested discovery places a burden or expense on Defendant that outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 12: Any ESI or physical evidence or documentation obtained 

from accessing the Cantus’ email, social media, personal devices, and router.

RESPONSE: Defendant objects to this request for the reason that and to the extent it seeks 

Defendant’s private and confidential information, seeks documents that are protected by the 

work-product privilege and/or attorney-client privilege, seeks documents that are subject to a 

confidentiality agreement, assumes facts not in evidence, and is not properly limited in scope and 

amounts to nothing more than an impermissible “fishing expedition,” Defendant objects to this 

request for the reason that it asks for information that is not proportional to the needs of the case. 

Specifically, the requested discovery is of low importance to resolving the issues and the 

requested discovery places a burden or expense on Defendant that outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 13: Any ESI or physical evidence or documentation 

containing the Phase I and Phase II reports for Dr. Guerra.

RESPONSE: Defendant objects to this request for the reason that and to the extent it seeks 

Defendant’s private and confidential information, seeks documents that are protected by the 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 15 of 20
DEFENDANT DIGITAL FORENSICS CORPORATION’S OBJECTIONS AND 

RESPONSES TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION PAGE 6

work-product privilege and/or attorney-client privilege, seeks documents that are subject to a 

confidentiality agreement, assumes facts not in evidence, and is not properly limited in scope and 

amounts to nothing more than an impermissible “fishing expedition,” Defendant objects to this 

request for the reason that it asks for information that is not proportional to the needs of the case. 

Specifically, the requested discovery is of low importance to resolving the issues and the 

requested discovery places a burden or expense on Defendant that outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 14: Any ESI or physical evidence or documentation 

containing information of what, if any, association DFC has with Tactical Rabbit, Inc.

RESPONSE: Defendant objects to this request for the reason that it is vague and overly broad. 

Defendant objects to this request for the reason that it asks for information that is not 

proportional to the needs of the case. Specifically, the requested discovery is of low importance 

to resolving the issues and the requested discovery places a burden or expense on Defendant that

outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 15: Any ESI or physical evidence or documentation 

containing information of what, if any, association DFC has with Green Squirrel Aquatics, LLC.

RESPONSE: Defendant objects to this request for the reason that it is vague and overly broad. 

Defendant objects to this request for the reason that it asks for information that is not 

proportional to the needs of the case. Specifically, the requested discovery is of low importance 

to resolving the issues and the requested discovery places a burden or expense on Defendant that

outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 16: Any ESI or physical evidence or documentation 

containing lists of all of DFC’s parent companies, subsidiaries, affiliates, divisions, departments, 

affiliated entities, directors, officers, employees, agents, consultants, members, independent 

contractors hired by DFC, or other person acting (or purporting to act) on its behalf from 2018 to 

the present.

RESPONSE: Defendant objects to this request for the reason that it is vague and overly broad. 

Defendant objects to this request for the reason that it asks for information that is not 

proportional to the needs of the case. Specifically, the requested discovery is of low importance 

to resolving the issues and the requested discovery places a burden or expense on Defendant that

outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 17: Any ESI or physical evidence or documents that show the 

Cantus had used Dr. Guerra’s email and/or name to set up online profiles/accounts on Dr. 

Guerra’s behalf.

RESPONSE: Defendant objects to this request for the reason that and to the extent it seeks 

Defendant’s private and confidential information, seeks documents that are protected by the 

work-product privilege and/or attorney-client privilege, seeks documents that are subject to a 

confidentiality agreement, assumes facts not in evidence, and is not properly limited in scope and 

amounts to nothing more than an impermissible “fishing expedition,” Defendant objects to this 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 16 of 20
DEFENDANT DIGITAL FORENSICS CORPORATION’S OBJECTIONS AND 

RESPONSES TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION PAGE 7

request for the reason that it asks for information that is not proportional to the needs of the case. 

Specifically, the requested discovery is of low importance to resolving the issues and the 

requested discovery places a burden or expense on Defendant that outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 18: Any ESI or physical evidence or documentation of hard 

drive backups or any other hardware provided to you by Dr. Guerra.

RESPONSE: Defendant objects to this request for the reason that it is vague and overly broad. 

Defendant objects to this request for the reason that and to the extent it seeks Defendant’s private 

and confidential information. Defendant objects to this request for the reason that it asks for 

information that is not proportional to the needs of the case. Specifically, the requested 

discovery is of low importance to resolving the issues and the requested discovery places a 

burden or expense on Defendant that outweighs its likely benefit. Defendant further objects to 

this request for the reason that it covers documents that are protected from discovery by the work 

product privilege, which Defendant is withholding. 

REQUEST FOR PRODUCTION NO. 19: Any ESI or physical evidence or documentation listing 

information on those who wrote Better Business Bureau reviews on DFC.

RESPONSE: Defendant objects to this request for the reason that it is vague and overly broad. 

Defendant objects to this request for the reason that it asks for information that is not 

proportional to the needs of the case. Specifically, the requested discovery is of low importance 

to resolving the issues and the requested discovery places a burden or expense on Defendant that

outweighs its likely benefit. 

REQUEST FOR PRODUCTION NO. 20: Any ESI or physical evidence or documentation of DFC’s 

insurance providers.

RESPONSE: Defendant objects to this request for the reason that it is vague and overly broad. 

Defendant objects to this request for the reason that it asks for information that is not 

proportional to the needs of the case and amounts to nothing more than an impermissible 

“fishing expedition.” Specifically, the requested discovery is of low importance to resolving the 

issues and the requested discovery places a burden or expense on Defendant that outweighs its 

likely benefit. Defendant further objects to this request for the reason that it covers documents 

that are protected from discovery by the work product privilege, which Defendant is 

withholding. 

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 17 of 20
DEFENDANT DIGITAL FORENSICS CORPORATION’S OBJECTIONS AND 

RESPONSES TO PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION PAGE 8

Respectfully submitted,

/s/ J. David Apple_____________

J. David Apple

State Bar No. 01278850

jdapple@applefinklaw.com

APPLE & FINK, LLP

735 Plaza Blvd., Suite 200

Coppell, Texas 75019

Telephone: (972) 315-1900

Facsimile: (972) 315-1955

ATTORNEYS FOR DEFENDANT DIGITAL 

FORENSICS CORPORATION, LLC

CERTIFICATE OF SERVICE

I hereby certify that on March 4, 2022 a true and correct copy of the foregoing document 

was served on the following counsel of record pursuant to the Texas Rules of Civil Procedure:

Tor Ekeland

Tor Ekeland Law, PLLC

195 Montague Street, 14th Floor

Brooklyn, NY 11201

tor@torekeland.com

Rain Levy Minns

Minns Law Firm, P.C.

d/b/a Rain Minns Law Firm

4412 Spicewood Springs Road, Suite 500

Austin, Texas 78759

rain@rainminnslaw.com

Ricardo G. Cedillo

Brandy C. Perry

Davis, Cedillo & Mendoza, Inc.

755 E. Mulberry, Suite 250

San Antonio, Texas 78212

rcedillo@lawdcm.com

bperry@lawdcm.com

/s/ J. David Apple__________

J. David Apple

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 18 of 20
1

Dated: June 13, 2022 Stipulated and respectfully submitted,

/s/ Tor Ekeland

Tor Ekeland (NY Bar No. 4493631)

Pro Hac Vice

Tor Ekeland Law, PLLC

30 Wall Street, 8th Floor

New York, NY 

t: (718) 737 - 7264

f: (718) 504 - 5417

tor@torekeland.com

and

/s/ Rain Levy Minns

Rain Minns

State Bar No. 24034581

Minns Law Firm, P.C.

d/b/a Rain Minns Law Firm

4412 Spicewood Springs Rd., Suite 500

Austin, Texas 78759-8583

Tel.: 512-372-3222

Fax: 512-861-2403

rain@rainminnslaw.com

Counsel for Plaintiffs Melody Joy Cantu 

and Dr. Rodrigo Cantu

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 19 of 20
2

Certificate of Service

I certify that on this 13th of June 2022, a true and correct copy of the foregoing was electronically 

filed with the Clerk of the Court using the CM/ECF system which will send electronic 

notification of such filing to the parties on record.

/s/ Tor Ekeland

Case 5:20-cv-00746-JKP Document 79 Filed 06/13/22 Page 20 of 20