EXHIBIT 9

Case 5:20-cv-00746-JKP Document 109-9 Filed 10/14/22 Page 1 of 11
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IN THE § IN THE DISTRICT COURT 

INTEREST OF § 

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§ 1501h JUDICIAL DISTRICT 

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SOFIA ELENA CANTU AND MAYA § 

ISABELLA CANTU, CHILDREN 

BEXAR COUNTY, TEXAS 

MEDIATED SETTLEMENT AGREEMENT 

The undersigned parties to this settlement agreement agree to compromise and settle the 

stated claims and controversies between them as described on the attachments. The parties wish 

to avoid potentially protracted and costly litigation. 

1. Terms of the settlement are as attached as Exhibit "A". 

2. Each party is responsible for their own attorney fees and court costs, unless 

otherwise provided. 

3. If any dispute arises with regard to the interpretation or performance of this 

agreement or any of its provisions including the necessity and form of closing documents, the 

parties agree to try to resolve the dispute by phone conference with the mediator who facilitated 

this settlement. Disputes regarding drafting provisions will be resolved using language contained 

in the Texas Family Law Practice Manual. Any disputes regarding drafting shall be resolved by 

ERNEST E. KARAM as Arbitrator by binding arbitration. 

4. This agreement is made in Bexar County, Texas. 

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GUERRA 000724

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5. Each signatory to this settlement has entered into the settlement freely and without 

duress after having consulted with professionals of his or her choice. Each party has been advised 

by the mediator that the mediator is not the attorney for any party and that each party should have 

this agreement approved by that party's attorney before executing it. 

6. This stipulation is signed voluntarily on the dates set out below and subject to the 

court's approval, and its provisions are intended to be incorporated into a final order. 

The parties agree that either party may appear in court to present evidence and 

secure rendition of judgment in accordance with this Mediated Settlement Agreement. 

8. Parties will do everything necessary to effectuate this agreement. 

9. This agreement can be modified upon mutual agreement of the parties in writing. 

THIS AGREEMENT IS NOT SUBJECT TO REVOCATION. 

Petitioner /' ( 

Signed on: 

C7 (z4,c1 

Attorney for Petitioner ,te4nc& 1Zo541b4 ond 

Signedon: O(1)25)OJCI 

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GUERRA 000725

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4VAc )c#nL-' 

Respondent 

Signed on: 7c/g 

Attorney for Respondent 

Signed on: ' 25 / 

E EST E, KARAM, Mediator 

Signed on: 9 

APPROVED AND RENDERED this jKdayof September, 2019. 

C SEP 2 52019 

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Norma Gonzales - 

Presiding Judge 

2 131st Judicaj District 

Bexar County, Texas 

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GUERRA 000726

Case 5:20-cv-00746-JKP Document 109-9 Filed 10/14/22 Page 4 of 11
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September 25, 2019 

RODRICO "DAVID" CANTU "Dad" (Atty. Tania Rosamond) and SANDRA GUERRA "Mom" (Atty. Tina Torres) 

Modification/Enforcement Mediation (42008-Cl-I 8856), In the 150" District Court Bexar 

ITIO Maya (16), Child 

Exh. "A" 

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MODIFY ONLY THE FOLLOWING CHILD PRO VISIONS • 

FROM PREVIOUS FINAL ORDERS: 

1) Child Support Modification: Dad's obligation is fully 

prepaid, satisfied and ceases effective today. 

2) Health Insurance p/FDD. Finding of no arrears effective 

today. 

3) Loving and Caring Order which parents will enforce 

against third parties who are in parent's presence. - 

4) Dad will be respectful of child's desires regarding 

possession/access which will be subject to child's approval. 

5) Mutual personal injunctions p/Bexar County Standing 

Orders, paragraph III, which shall apply to spouses and 

"significant others" and include prohibition against illegal 

actions against the other— r(c) oj 14-4 h6u~~4id, 

6) Standing/Temporary Orders end upon signing of this 

agreement. 

7) If Maya agrees to counseling, she may participate with OD-1 

counselor of her choice and parent's will cooperate. 

8) Parties agree neither patty owes the other for obligations 

under prior Orders. 

ENFORCEMENT/SUSPENSION OF COMMITMENT ORDER: 

To be Dismissed with Prejudice. 

GUERRA 000727

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SPECIAL ORDER NO. 

IN RE: 

STANDING ORDER REGARDING 

CHILDREN, PROPERTY, AND 

CONDUCT OF PARTIES IN DIVORCE 

AND SUITS AFFECTING THE 

PARENT CHILD RELATIONSHIP 

IN THE CIVIL DISTRICT COURTS 

BEXAR COUNTY, TEXAS 

STANDING ORDER REGARDING CHILD(REN), PROPERTY 

AND CONDUCT OF PARTIES IN DIVORCE AND 

SUITS AFFECTING THE PARENT-CHILD RELATIONSHIP 

I. INTRODUCTION 

No pasty to this lawsuit has requested this order. Rather, this order is a standing order of the 

Bexar County Civil District Courts that applies in every divorce suit and every suit affecting the 

parent-child relationship filed in Bexar County. This Order is not intended to affect or 

circumvent prior orØers entered regarding conservatorship of children, including the right 

to determine the primary residence of a child and all prior orders remain in effect until 

further order of the Court. The Civil DistrictCourts of Bexar county have adopted this order 

because the parties and their child(ren) should be protected and their property preserved while 

the lawsuit is pending before the Court. -. 

II. NO DISRUPTION OF CHILD(REN) 

Both parties are ORDERED to refrain from doing the following acts concerning any 

child(ren) who are subjects of this case: 

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2 2.1 Removing the child(ren) from the State of Texas, acting directly or in concert with others, 

9 without the written agreement of both parties or an order of this Court. 

2.2 Disrupting or withdrawing the child(ren) from the school or day-care facility where the 

1 child(ren) are presently enrolled, without the written agreement of both parents or an order of 

8 this Court. 

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o 2.3 Hiding or secreting the ehild(ren) from the other parent or changing the child(ren)'s current 

1.. residence, without the written agreement of both parents or an order of this Court. 

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2.4 Disturbing the peace of the child(ren). 

6 2.5 Making disparaging remarks about each other or the other person's family members, to 

P include but not be limited to the child(ren)'s grandparents, aunts, uncles, or stepparents. 

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GUERRA 000728

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2.6 Discussing with the child(ren), or with any other person in the presence of the child(ren), any 

litigation related to the child(ren) or the other party. 

2.7 Consuming any illegal Controlled Substance (as that term is defined in the Texas Controlled 

Substance Act), 12 hours prior to and during possession of the child(ren). 

2.8 If this is an original divorce action, allowing anyone with whom the party is romantically 

involved, to remain over night in the home while in possession of the child(ren). Overnight is 

defined from 10:00p.m. that evening until 7:00 a.m. the next morning. 

III. CONDUCT OF THE PARTIES DURING THE CASE 

Both parties, their agents; servants, and/or employees, are ORDERED to refrain from doing 

the following acts: 

3.1 Using vulgar, profane, obscene, or indecent language, or a coarse or offensive manner, to 

communicate with the other party, whether in person, by telephone, or in writing. 

3.2 Threatening the other party in person, by telephone, or in writing to take unlawful action 

against any person. 

3.3 Placing one or more telephone calls, at an unreasonable hour, in an offensive or repetitious 

manner, without a legitimate purpose of communication, or anonymously. 

3.4 Opening or diverting mail addressed to the other party. 

IV. PRESERVATION OF PROPERTY AND USE OF FUNDS DURING DIVORCE 

CASE 

If this is a divorce case, both parties to the marriage, their agents, servants, and/or employees, 

are ORDERED to refrain from doing the following: 

4.1 Destroying, removing, encumbering, transferring, or otherwise harming or reducing the value 

of the property of one or both of the parties. 

4.2 Misrepresenting or refusing to disclose to the other party or the Court, on proper request, the 

existence, amount, or location of any property of one or both of the parties. 

4.3 Damaging or destroying the tangible property of one or both of the parties, including any 

document that represents or embodies anything of value. 

4.4 Tampering with the tangible property of one or both of the parties, including any document 

that represents or embodies anything of value, and causing pecuniary loss to the other party. 

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GUERRA 000729

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4.5 Selling, transferring, assigning, mortgaging, encumbering, or in any other manner alienating 

any of the property of either party, whether personal property or real estate property, and whether 

separate or community, except as specifically authorized by this order. 

4.6 Incurring any indebtedness, other than legal expenses in connection with this suit, except as 

specifically authorized by this order. 

4.7 Making withdrawals from any checking or savings account in any financial institution for 

any purpose, except as specifically authorized by this order. 

4.8 Spending any sum of cash in either party's possession or subject to either party's control for 

any purpose, except as specifically authorized by this order. 

4.9 Withdrawing or borrowing in any manner for any purpose from any retirement, profitsharing, pension, death, or other employee benefit plan or employee savings plan or from any 

individual retirement account or Keogh account, except as specifically authorized by this order. 

4.10 Signing or endorsing the other party's name on any negotiable instrument, check, or draft, 

such as tax refunds, insurance payments, and dividends or attempting to negotiate any negotiable 

instrument payable to the other party without the personal signature of the other party. 

4.1 iTaking any action to terminate or limit credit or charge cards in the name of the other party. 

4.12 Entering, operating, or exercising. control over the motor vehicle in the possession of the 

other party 

4.13 Discontinuing or reducing the withholding for federal income taxes on wages or salary 

while this suit is pending. 

4.14 Terminating or in any manner affecting the service of water, electricity, gas, telephone, 

/ cable television, or other contractual services, such as security, pest control, landscaping, or yard 

2 maintenance at the other party's residence or in any manner attempting to withdraw any deposits 

for service in connection with such service. 

0 4.15 Intercepting or recording the other party's electronic communications. 

8 4.16 Excluding the other party from the use and enjoyment of the other party's residence. 

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0 V. PERSONAL AND BUSINESS RECORDS IN DIVORCE CASE 

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4 If this is a divorce case, both parties to the marriage, their agents, servants, and/or employees, 

g are ORDERED to refrain from doing the following acts: 

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6 5.1 Concealing or destroying any family records, property records, financial records, 

p business records or any records of income, debts, or other obligations. 

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GUERRA 000730

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5.2 Falsifying any writing or record relating to the property of either party. 

"Records" include e-mail or other digital or electronic data, whether stored on a computer 

hard drive, diskette or other electronic storage device. 

VI. INSURANCE IN DIVORCE CASE 

If this is a divorce case, both parties to the marriage, their agents, servants, and/or employees, 

are ORDERED to refrain from doing the following acts: 

6.1 Withdrawing or borrowing in any manner all or any part of the cash surrender value of life 

insurance policies on the life of either party, except as specifically authorized by this order. 

6.2 Changing or in any manner altering the beneficiary designation on any life insurance on the 

life of either party or the parties' child(ren). 

6.3 Canceling, altering, or in any manner affecting any casualty, automobile, or health insurance 

policies insuring the parties' property of persons including the parties' minor child(ren). 

SPECIFIC AUTHORIZATION IN DIVORCE CASE 

If this is a divorce case, both parties to the marriage are specifically authorized to do the 

following: 

7.1 To engage in acts reasonable and necessary to the conduct of that party's usual business and 

occupation. 

7.2 To make expenditures and incur indebtedness for reasonable attorney's fees and expenses in 

connection with this suit. 

7.3 To make expenditures and incur indebtedness for reasonable and necessary living expenses 

for food, clothing, shelter, transportation and medical care. 

7.4 To make withdrawals from accounts in financial institutions only for the purposes authorized 

by this order. 

SERVICE AND APPLICATION OF THIS ORDER 

8.1 The Petitioner shall attach a copy of this order to the original petition and to each copy of the 

petition. 

8.2 This order is effective upon the filing of the original petition and shall remain in full force 

and effect as a temporary restraining order for fourteen days after the date of the filing of the 

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GUERRA 000731

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original petition and is renewed for subsequent periods of every fourteen days thereafter until a 

temporary injunction is ordered. If no party contests this order by presenting evidence at a 

hearing on or before fourteen days after the date of the filing of the original petition, this order 

shall continue in full force and effect as a temporary injunction until further order of the court. 

This entire order will terminate and will no longer be effective once the court signs a final order. 

IX. EFFECT OF OTHER ORDERS 

If any part of this order is different from any part of a protective order that has already been 

entered or is later entered, the protective order provisions prevail. Any part of this order not 

changed by some later order remains in full force and effect until the court signs a final decree. 

X. PARTIES ARE ENCOURAGED TO MEDIATE 

The parties are encouraged to settle their disputes amicably without court intervention. The 

parties are encouraged to use alternative dispute resolution methods, such as mediation or 

collaborative law, to resolve the conflicts that may arise in this lawsuit. 

XI. BOND WAIVED 

It is ORDERED that the requirement of a bond is waived. 

XII. FAMILY STABILIZATION 

Parents of minor child(ren) are required to attend a family stabilization program (Helping 

Children Cope with Divorce) within 60 days of the filing of the Petition for Divorce or the Suit 

Affecting the Parent Child Relationship. Waivers'mày be granted only by order of the court. 

Proof of completion of the program must be provided to the court upon meeting this requirement. 

o SIGNED X7, zpi? AQ.Q2 720 , 

8 MICHAEL MERY CATHLEEN'STRY E 

/ 37TH DISTRICT COURT 224TH DISTRIC COURT 

V /STEPHANIWALSH PETER SAKAI o 45TH DISTRICT COURT 225TH DISTRICT COURT 

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57TH DISTRICT COURT 285TH DISTRICT COURT 

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GUERRA 000732

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DAVID CANALES 

73R0 DISTRICT CURT 288TH DISTRICT COURT 

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kYal 

ST DIStRICT COURT 

asuca A ThtLtk& 

RENEE YANTA 

150THDISTR1 WOURT 

COURT 

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ANGk1CA JIME$EZ) 

4081H DISTRICT O1JRT 

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ROSIE ALVARADO 

4381H DISTRICT COURT 

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GUERRA 000733

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