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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 1 of 18
·1· · · · · · IN THE UNITED STATES DISTRICT COURT

· · · · · · · ·FOR THE WESTERN DISTRICT OF TEXAS

·2· · · · · · · · · ·SAN ANTONIO DIVISION

·3 MELODY JOY CANTU and DR.· · ·)

· ·RODRIGO CANTU ,· · · · · · · )

·4· · · · · · · · · · · · · · · )

· · · · · · · · ·Plaintiffs,· · )

·5· · · · · · · · · · · · · · · ) CIVIL ACTION

· ·VS.· · · · · · · · · · · · · )

·6· · · · · · · · · · · · · · · ) NO.: 5:20-CV-00746-JKP

· ·DR. SANDRA GUERRA and· · · · ) (HJB)

·7 DIGITAL FORENSICS· · · · · · )

· ·CORPORATION, LLC,· · · · · · )

·8· · · · · · · · · · · · · · · )

· · · · · · · · ·Defendants.· · )

·9

10· · · · · · -----------------------------------

11· · · · · · ·ORAL AND VIDEOTAPED DEPOSITION OF

12· · · · · · · · · · DR. RODRIGO CANTU

13· · · · · · · · · · · · (VIA ZOOM)

14· · · · · · · · · · · ·JULY 16, 2022

15· · · · · · -----------------------------------

16· · · ORAL AND VIDEOTAPED DEPOSITION OF DR. RODRIGO CANTU,

17 produced as a witness at the instance of the DEFENDANT,

18 and duly sworn, was taken in the above-styled and

19 numbered cause on July 16, 2022 from 2:24 o'clock p.m.

20 to 5:40 o'clock p.m., Via Zoom, before

21 DEBBIE S. LONGORIA, CSR in and for the State of Texas,

22 reported by machine shorthand, pursuant to the Federal

23 Rules of Civil Procedure.

24

25

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·1· · · · · · · · · ·A P P E A R A N C E S

·2

·3 FOR THE PLAINTIFFS:

·4· · · TOR EKELAND (Via Zoom)

· · · · TOR EKELAND LAW, PLLC

·5· · · 30 WALL STREET, 8TH FLOOR

· · · · NEW YORK, NEW YORK 10005

·6· · · (718) 737-7264

· · · · tor@torekeland.com

·7

· ·FOR THE DEFENDANTS DR. SANDRA GUERRA and DIGITAL

·8 FORENSICS CORPORATION, LLC:

·9· · · BRANDY C. PEERY (Via Zoom)

· · · · RICARDO G. CEDILLO (Via Zoom)

10· · · DAVIS, CEDILLO & MENDOZA, INC.

· · · · 755 E. MULBERRY, SUITE 500

11· · · SAN ANTONIO, TEXAS 78212

· · · · (210) 822-6666

12· · · bpeery@lawdcm.com

· · · · rcedillo@lawdcm.com

13

14 ALSO PRESENT:

15· · · KYLE LABYER, Videographer (Via Zoom)

· · · · MELODY JOY CANTU (Via Zoom)

16· · · NICOLE GUITELMAN (Via Zoom)

· · · · KATHLEEN N. FOLKS (Via Zoom)

17· · · DR. SANDRA GUERRA (Via Zoom)

18

19

20

21

22

23

24

25

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·1 that?

·2· · · A.· ·The brand name is Valtrex.

·3· · · Q.· ·Okay.· Dr. Cantu, do you recall the deposition

·4 testimony Melody gave regarding the incident at the Pei

·5 Wei on April 1st, 2018?

·6· · · A.· ·Yes.

·7· · · Q.· ·And do you agree with all of her testimony

·8 regarding the events of that day?

·9· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

10· · · · · · · · ·THE WITNESS:· Yes.

11· · · Q.· ·(By Ms. Peery) Okay.· Why don't you -- if

12 you -- if you would, please, tell the jury what happened

13 on April 1st, 2018 at the Pei Wei.

14· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

15· · · · · · · · ·THE WITNESS:· I was having dinner with my

16 daughters.· We were outside on the patio.· After we had

17 ordered, we sat down and we were waiting for our food

18 and Sandra came to the restaurant.· She saw us and came

19 over and she said she was ordering food to go, and

20 that's why she was there.· My daughters invited her to

21 stay and eat with us, which I agreed to.· She went and

22 ordered and came and sat with us and we had our meal.

23· · · · · · · · ·During the meal, I guess toward the end

24 of the meal, Melody called me and she was -- she had

25 come to the restaurant, as well, and wanted to be able

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 4 of 18
·1 to talk to my daughters and tell them that we had been

·2 in a relationship for the last two years after our

·3 divorce.· So, I agreed to clear the air and, you know,

·4 for it to not be a secret anymore.· I think we were all

·5 tired of living in that way.

·6· · · · · · · · ·So, I said she could come and speak to

·7 them.· And as we were leaving, Melody was walking up to

·8 the restaurant, and so we were on the sidewalk just

·9 outside the restaurant and she came up and said "Hi,"

10 and she said, "Happy Easter."· And my girls and Sandra

11 responded back "Happy Easter."

12· · · · · · · · ·And then Joy started to tell them that we

13 had been in a secret relationship since the end of our

14 divorce.· And she started to tell them it was in secret

15 because I was afraid that my girls would not want to

16 spend time with me and that Sandra would withhold the

17 girls from me.

18· · · · · · · · ·And that's when Sandra started to walk

19 off toward her car and she said, "I don't like being

20 ambushed" and kept walking.· And that's when it was

21 obvious that she was very upset and I think my daughters

22 were getting upset, as well, because Sandra ran off.

23 And so, I told them to go with their mother so I could

24 talk to Joy.· So, they -- they went off with their

25 mother.· I think I put Maya -- or opened the door for

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 5 of 18
·1 Maya to get into the car with her mother.

·2· · · · · · · · ·Then I went over to my car and Joy and I

·3 started -- started talking when Sandra was starting to

·4 leave and she lunged her car forward, then backed up and

·5 then went forward again and then finally -- finally

·6 left.· By this point, I -- you know, I saw how everybody

·7 reacted and so I was upset, as well, and so I told Joy I

·8 didn't want to talk to her.· So, I got in my car and

·9 left and left her there in the parking lot.

10· · · Q.· ·(By Ms. Peery) Okay.· But, you -- you did not

11 tell Dr. Guerra or your daughters that Melody -- that

12 you told Melody to come meet you at the restaurant, did

13 you?

14· · · · · · · · ·MR. EKELAND:· Objection.

15· · · · · · · · ·THE WITNESS:· I did not -- oh, sorry. I

16 did not tell them --

17· · · Q.· ·(By Ms. Peery) Why?

18· · · A.· ·-- that she was coming.

19· · · · · · · · ·I was afraid of how they were going to

20 react to me telling them that Joy wanted to talk to

21 them.

22· · · Q.· ·Why were you afraid?

23· · · · · · · · ·MR. EKELAND:· Objection.

24· · · · · · · · ·THE WITNESS:· I'd been afraid for two

25 years of how they were going to react.· I've been afraid

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 6 of 18
·1 of Sandra withholding my children.· I've been afraid of

·2 my daughters not wanting to spend time with me.· I've

·3 been afraid of my parents not wanting to visit me or

·4 have a relationship with me.· This was my fear for the

·5 two years.· That's why I got divorced and that's why I

·6 went two years without telling them about it.

·7· · · Q.· ·(By Ms. Peery) You knew the girls would be

·8 upset if you were with Melody again; is that your

·9 testimony?

10· · · · · · · · ·MR. EKELAND:· Objection.

11· · · · · · · · ·THE WITNESS:· I feared that they would be

12 upset.

13· · · Q.· ·(By Ms. Peery) What caused you to fear that

14 they would be upset, was it something they had told you

15 before?

16· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

17· · · · · · · · ·THE WITNESS:· It's -- it's what Sandra

18 told me in text messages, it's what my mother told me,

19 and at this time, my father did speak and say he wasn't

20 going to come visit me either.· So, that's what drove my

21 fear.· My daughters, honestly, I don't think I ever had

22 a really deep conversation with them about it.· And I --

23 I think just was afraid of how they would react or

24 didn't know exactly how to approach them with the

25 subject.

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 7 of 18
·1· · · Q.· ·(By Ms. Peery) Okay.

·2· · · A.· ·And that's -- that's what happened for two

·3 years, I didn't know how to bring it up with them or to

·4 tell anybody.

·5· · · Q.· ·And you were afraid of your -- what your

·6 daughters' reactions might be, so you thought the better

·7 course was to have Melody show up unexpected and for

·8 Melody to tell them?

·9· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

10· · · · · · · · ·THE WITNESS:· I thought it would be best

11 if we would both tell them.· I thought if I told them

12 ahead of time that they may just leave and not give the

13 opportunity.

14· · · Q.· ·(By Ms. Peery) So, you didn't tell them ahead

15 of time because you wanted to make sure they didn't

16 leave?

17· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

18· · · · · · · · ·THE WITNESS:· Yes, I wanted -- I wanted

19 to be able to have the discussion.

20· · · Q.· ·(By Ms. Peery) But you didn't have the

21 discussion, Melody did --

22· · · · · · · · ·MR. EKELAND:· Objection.

23· · · Q.· ·-- isn't that right?

24· · · · · · · · ·MR. EKELAND:· Objection.

25· · · · · · · · ·THE WITNESS:· I didn't -- we didn't get

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 8 of 18
·1 that far.· Melody started to talk and Sandra ran off.

·2· · · Q.· ·(By Ms. Peery) Were you upset with Melody?

·3· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

·4· · · · · · · · ·THE WITNESS:· I think I was after I saw

·5 the reaction from Sandra and my kids.

·6· · · Q.· ·(By Ms. Peery) Why were you upset with Melody?

·7· · · A.· ·Because what I was afraid of happening was

·8 starting to happen and I was taking it out on her.

·9· · · Q.· ·How were you taking it out on her?

10· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

11· · · · · · · · ·THE WITNESS:· By being angry with her.

12· · · Q.· ·(By Ms. Peery) Did you yell at her?

13· · · · · · · · ·MR. EKELAND:· Objection.

14· · · · · · · · ·THE WITNESS:· No, I just said I didn't

15 want to talk and got in my car and left.

16· · · Q.· ·(By Ms. Peery) When Melody showed up in the

17 parking lot at the Pei Wei, what was her demeanor like?

18· · · A.· ·She was calm, she was, I think, trying to be

19 cordial.· I think she was smiling.· She was in a -- her

20 demeanor was good.

21· · · Q.· ·She was in a good mood?

22· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

23· · · · · · · · ·THE WITNESS:· I would say yes.

24· · · Q.· ·(By Ms. Peery) Had she been in a good mood all

25 day?

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 9 of 18
·1· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

·2· · · · · · · · ·THE WITNESS:· I don't know if she'd been

·3 in a good mood all day.

·4· · · Q.· ·(By Ms. Peery) Had you spoken to her prior to

·5 the call you received at Pei Wei before she arrived?

·6· · · A.· ·We spoke about her daughter.· Her daughter was

·7 developing a rash and she was concerned about it, and so

·8 we spoke about it, and she was worried about that.· So,

·9 I guess earlier in the day she was frightened or scared

10 or anxious.

11· · · Q.· ·And I'm -- I apologize, I didn't hear.· She

12 was -- she was frightened about a rash?

13· · · A.· ·Her daughter was ill.· She was worried about

14 her daughter's illness.

15· · · Q.· ·Okay.· What was -- what was her daughter's

16 illness?

17· · · A.· ·Hepatic failure.

18· · · Q.· ·Was she in the hospital?

19· · · A.· ·Not at the time that we spoke.

20· · · Q.· ·Okay.· Where was her daughter?

21· · · A.· ·With her at home.

22· · · Q.· ·Was she taking her to get treatment?

23· · · A.· ·She was going to.

24· · · Q.· ·What happened after you left Melody in the

25 parking lot at the Pei Wei?

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 10 of 18
·1· · · A.· ·I drove away and called Sandra.· I believe she

·2 answered and told me not to call and hung up.

·3· · · Q.· ·Why did you call Sandra?

·4· · · · · · · · ·MR. EKELAND:· Objection.

·5· · · · · · · · ·THE WITNESS:· To -- I called to try to

·6 talk to the girls and talk to them about what had just

·7 transpired.

·8· · · Q.· ·(By Ms. Peery) Did the girls have cell phones

·9 at that time?

10· · · A.· ·Yes.

11· · · Q.· ·Did you try to call their cell phones?

12· · · A.· ·Yes.

13· · · Q.· ·And they weren't answering?

14· · · A.· ·Correct.

15· · · Q.· ·After the girls didn't answer, then you called

16 Dr. Guerra?

17· · · · · · · · ·MR. EKELAND:· Objection.

18· · · · · · · · ·THE WITNESS:· I don't remember the

19 sequence.

20· · · Q.· ·(By Ms. Peery) How many times did Melody call

21 you between when you left during the parking lot at the

22 Pei Wei and the end of the next day, April 2nd, 2018?

23· · · A.· ·I don't know the exact number.

24· · · Q.· ·How about an estimation of the number of times

25 she called you between the time period when you left her

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 11 of 18
·1 in the parking lot at the Pei Wei and the end of the

·2 next day, April 2nd, 2018?

·3· · · · · · · · ·MR. EKELAND:· Objection.

·4· · · · · · · · ·THE WITNESS:· It was probably more than

·5 five.

·6· · · Q.· ·(By Ms. Peery) More than five.· More than ten?

·7· · · · · · · · ·MR. EKELAND:· Objection.

·8· · · · · · · · ·THE WITNESS:· It might have been more

·9 than ten.

10· · · Q.· ·(By Ms. Peery) More than 20?

11· · · · · · · · ·MR. EKELAND:· Objection.

12· · · · · · · · ·THE WITNESS:· I don't know the exact

13 number.

14· · · Q.· ·(By Ms. Peery) I'm not asking you for an exact

15 number, I'm asking you if it was more than 20.

16· · · · · · · · ·MR. EKELAND:· Objection.

17· · · · · · · · ·THE WITNESS:· I don't know.

18· · · Q.· ·(By Ms. Peery) Did you speak to her each time

19 she called you?

20· · · A.· ·No.

21· · · Q.· ·Why not?

22· · · A.· ·I didn't want to talk to her.

23· · · Q.· ·Was she sending you text messages?

24· · · A.· ·Yes.

25· · · Q.· ·Did she call your mother?

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 12 of 18
·1· · · A.· ·I don't know.

·2· · · Q.· ·Did she call your father?

·3· · · A.· ·I don't know.

·4· · · · · · · · ·MR. EKELAND:· Objection.

·5· · · Q.· ·(By Ms. Peery) Did you call your mother after

·6 you left the Pei Wei?

·7· · · A.· ·Yes.

·8· · · Q.· ·Okay.· Why?

·9· · · A.· ·I wanted to tell them what had happened and I

10 believe they had already heard from Sandra.· And so, I

11 told them that I was trying to get ahold of my daughters

12 to talk to them, they weren't answering, and Sandra had

13 told me not to -- not to call anymore.

14· · · Q.· ·Did your parents come to stay with you?

15· · · A.· ·They did.

16· · · Q.· ·Why?

17· · · A.· ·They wanted to.

18· · · Q.· ·Were they living in Edinburg at the time?

19· · · A.· ·Yes.

20· · · Q.· ·So, you -- you called them after you left the

21 Pei Wei and then they decided to come up from Edinburg

22 to stay with you?

23· · · · · · · · ·MR. EKELAND:· Objection.· You can answer.

24· · · · · · · · ·THE WITNESS:· That's right.

25· · · Q.· ·(By Ms. Peery) Did they make it there that

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 13 of 18
·1 night?

·2· · · A.· ·Yes.

·3· · · Q.· ·This is both your mother and your father?

·4· · · A.· ·Correct.

·5· · · Q.· ·And did you ask them to come?

·6· · · A.· ·No.

·7· · · Q.· ·Did you tell them -- did you tell them that

·8 you were in fear for your safety?

·9· · · A.· ·No.

10· · · Q.· ·How long did they stay with you?

11· · · A.· ·Maybe a couple of days.· And then my mom went

12 back and my dad come back by himself.

13· · · Q.· ·Did you ask your parents to bring a gun with

14 them?

15· · · A.· ·No.

16· · · Q.· ·Did they bring a gun with them?

17· · · A.· ·I believe so.· My dad owns a gun and takes it

18 everywhere.

19· · · Q.· ·What did you tell your parents happened at the

20 Pei Wei?

21· · · A.· ·I told them what I told you.

22· · · Q.· ·Told them exactly what you just testified

23 under oath, that's exactly what you told them?

24· · · A.· ·Not verbatim, but I told them the same things

25 I told you.· There's nothing different what I said.

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·1· · · Q.· ·Okay.· What happened at -- you left Melody in

·2 the parking lot.· Did you go home?

·3· · · A.· ·Yes.

·4· · · Q.· ·Okay.· Was that Heather Stone?

·5· · · A.· ·Heather Ridge, yeah.

·6· · · Q.· ·Heather Ridge, pardon me.· What did you do

·7 when you got home?

·8· · · A.· ·I went inside and I think I took off my church

·9 clothes.· I think my parents were calling me wanting to

10 come up here.· I kept trying to tell them not to come,

11 they were insistent.· A few minutes later, Sandra came

12 to my house with her father and she came to get Sofia's

13 and Maya's backpacks and things that were at my house

14 and to collect Sofia's car, which was also at my house.

15 She asked me if I was going to stay at the house and I

16 said yes.· She said, "I don't think you -- I don't think

17 you should."· She said she wasn't going to stay at her

18 home and she asked me if I still had a gun, and she said

19 yes, and she said, "I think you should take it with you

20 wherever you stay."

21· · · Q.· ·Did you stay at the house?

22· · · A.· ·No.

23· · · Q.· ·You left the house after that?

24· · · A.· ·I did.

25· · · Q.· ·Where did you stay?

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 15 of 18
·1· · · A.· ·I --

·2· · · Q.· ·Or where did you go after that?

·3· · · A.· ·Well, I -- you know, you alluded my parents

·4 were taking a long drive from Edinburg to San Antonio,

·5 so I got a hotel on the south-end of town so they

·6 wouldn't have to drive all the way through town to my

·7 house, so their drive would be about an hour shorter. I

·8 was working on that end of town already so it would be

·9 very close to my work the next morning.· And since I was

10 going to wait for my parents to arrive, I thought it was

11 the most convenient way to be able to get some rest and

12 accommodate my parents.

13· · · Q.· ·Did you take your gun with you?

14· · · A.· ·I did.

15· · · Q.· ·Why?

16· · · A.· ·Because Sandra told me to.

17· · · Q.· ·Your testimony is that the only reason you

18 took the gun with you was because your ex-wife told you

19 to?

20· · · A.· ·That's what I said.

21· · · Q.· ·You filed a police report against Melody

22 Cantu, didn't you?

23· · · A.· ·Yes, ma'am.

24· · · Q.· ·Okay.

25· · · · · · · · ·MS. PEERY:· Kyle, can you please bring up

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Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 16 of 18
·1· · · · · · IN THE UNITED STATES DISTRICT COURT

· · · · · · · ·FOR THE WESTERN DISTRICT OF TEXAS

·2· · · · · · · · · ·SAN ANTONIO DIVISION

·3 MELODY JOY CANTU and DR.· · ·)

· ·RODRIGO CANTU,· · · · · · · ·)

·4· · · · · · · · · · · · · · · )

· · · · · · · · ·Plaintiffs,· · )

·5· · · · · · · · · · · · · · · ) CIVIL ACTION

· ·VS.· · · · · · · · · · · · · )

·6· · · · · · · · · · · · · · · ) NO.: 5:20-CV-00746-JKP

· · · · · · · · · · · · · · · · ) (HJB)

·7 DR. SANDRA GUERRA and· · · · )

· ·DIGITAL FORENSICS· · · · · · )

·8 CORPORATION, LLC,· · · · · · )

· · · · · · · · · · · · · · · · )

·9· · · · · · · ·Defendants.· · )

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11· · · · · · · · ·REPORTER'S CERTIFICATION

12· · · · · · · DEPOSITION OF DR. RODRIGO CANTU

13· · · · · · · · · · · ·JULY 16, 2022

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15· · · I, Debbie S. Longoria, Certified Shorthand Reporter

16 in and for the State of Texas, hereby certify to the

17 following:

18· · · That the witness, DR. RODRIGO CANTU, was duly sworn

19 by the officer and that the transcript of the oral

20 deposition is a true record of the testimony given by

21 the witness;

22· · · I further certify that pursuant to FRCP Rule 30(f)

23 (1) that the signature of the deponent:

24· · · ____was requested by the deponent or a party before

25 the completion of the deposition and returned within 30

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Rodrigo Cantu Pages 100 Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 17 of 18
·1 days from date of receipt of the transcript.· If

·2 returned, the attached Changes and Signature Page

·3 contains any changes and the reasons therefor;

·4· · ·__X__was not requested by the deponent or a party

·5 before the completion of the deposition.

·6· · · I further certify that I am neither attorney nor

·7 counsel for, related to, nor employed by any of the

·8 parties to the action in which this testimony was taken.

·9· · · Further, I am not a relative or employee of any

10 attorney of record in this cause, nor do I have a

11 financial interest in the action.

12· · · Subscribed and sworn to on this the 28th day

13 of July, 2022.

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15

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· · · · · · ·___________________________________

17· · · · · ·Debbie S. Longoria, Texas CSR #5232

· · · · · · ·Expiration Date:· 10/31/23

18· · · · · ·Lexitas - Firm Registration No. 539

· · · · · · ·100 N.E. Loop 410, Suite 955

19· · · · · ·San Antonio, Texas 78216

· · · · · · ·(210) 481-7575

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Rodrigo Cantu Pages 101 Case 5:20-cv-00746-JKP Document 114-6 Filed 10/28/22 Page 18 of 18