Exhibit ‘B’

Case 5:20-cv-00746-JKP Document 125-2 Filed 08/08/23 Page 1 of 3
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Michael Hassard

From: Brandy Peery <bpeery@lawdcm.com>

Sent: Thursday, August 3, 2023 4:52 PM

To: Michael Hassard; David Apple; Ricardo Cedillo; Derick Rodgers; 

jrios@therioslawfirm.com; lewis.harley@harleylawgroup.com

Cc: Tor Ekeland; Tauseef Ahmed; Ricardo Cedillo

Subject: RE: Continuance - Cantu et al v. Guerra et al

MichaelAlthough we can sympathize with your scheduling conflicts, the Court, by setting this case for trial in less than 

6 weeks on September 11, 2023, has sent a clear message to the parties that there will be no further delays in the 

final disposition of this lawsuit. The message has been received and Defendants recognize they are not in any 

position to oppose the will of the Court or its inherent authority to control its docket. Therefore, Defendants and 

their respective counsel are working diligently to rearrange their schedules and conflicting trial settings to 

comply with the Court’s order. I have conferred with DFC’s counsel, David Apple, and, for the foregoing 

reasons, we cannot agree to Plaintiffs’ request for a continuance of this case, let alone a 6-month continuance 

until February 2024. 

Brandy C. Peery

Shareholder

Note: New Suite Number 

OFFICE: 210-822-6666 

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EMAIL: bpeery@lawdcm.com 

ADDRESS: 755 E. Mulberry Ave., Suite 250 

 San Antonio, Texas 78212 

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From: Michael Hassard <Michael@torekeland.com> 

Sent: Thursday, August 3, 2023 11:49 AM 

To: David Apple <jdapple@applefinklaw.com>; Ricardo Cedillo <rcedillo@lawdcm.com>; Brandy Peery 

<bpeery@lawdcm.com>; Derick Rodgers <drodgers@lawdcm.com>; les@buy-lawfirm.com; jrios@therioslawfirm.com; 

lewis.harley@harleylawgroup.com 

Cc: Tor Ekeland <tor@torekeland.com>; Tauseef Ahmed <tauseef@torekeland.com> 

Subject: [External] Continuance - Cantu et al v. Guerra et al 

Counsel, 

Case 5:20-cv-00746-JKP Document 125-2 Filed 08/08/23 Page 2 of 3
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The Court has scheduled a pre-trial conference in the above referenced ma5er for September 7, 2023, and a jury trial for 

September 11. These dates do not work for us. We have a federal criminal trial in Washington D.C. scheduled to begin 

on September 14, with a pretrial conference scheduled on September 6. The case is :tled c Mr. Sterlingov faces a 

poten:al life sentence. 

Accordingly, we will need to file for a con:nuance in this case. Would you oppose any con:nuance filed on these 

grounds. If not, we’d like to work with you to propose dates that work for both sides. We are available in February and 

would like to schedule this trial for then. Would February work for you? 

Michael Hassard 

Associate 

Tor Ekeland Law, PLLC 

30 Wall Street, 8th Floor 

New York, NY 10005 

p. 718-737-7264 

michael@torekeland.com

torekeland.com 

Case 5:20-cv-00746-JKP Document 125-2 Filed 08/08/23 Page 3 of 3