EXHIBIT D

Case 5:20-cv-00746-JKP Document 111-4 Filed 10/27/22 Page 1 of 9
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

Plaintiff Dr. Cantu’s 

Responses to Defendant Dr. 

Guerra’s First Set Of 

Interrogatories 

______________________________________

Plaintiff Dr. Rodrigo Cantu’s Response to Defendant Dr. Guerra’s First Set of

Interrogatories

Plaintiff Dr. Rodrigo Cantu hereby responds to the interrogatories served by Defendant 

Dr. Sandra Guerra. Defendant reserves the right to change, revise, and supplement these

responses and objections based on new information. 

GENERAL OBJECTIONS

1. Plaintiff objects to the Interrogatories to the extent that they seek information and/or

documents that are protected from disclosure by the attorney-client privilege, the joint

defense privilege, the work product doctrine, or any other privilege or legal protection

from disclosure.

2. Plaintiff objects to the Interrogatories to the extent that they seek information and/or

documents that are confidential, competitively sensitive, and/or trade secrets.

Case 5:20-cv-00746-JKP Document 111-4 Filed 10/27/22 Page 2 of 9
3. In responding to and/or objecting to the Interrogatories, Plaintiff does not concede that 

any of the documents and/or information sought are relevant to, material to, or admissible 

in this action, or reasonably likely to lead to the discovery of evidence that would be 

relevant to, material to, or admissible in any proceeding, including, but not limited to, this 

action. No objection or limitation in this response, or lack thereof, shall be deemed an 

admission by Plaintiff as to the responsiveness, relevance, existence, or nonexistence of 

documents or information.

4. In responding to the Interrogatories, Plaintiff does not in any way waive or intend to 

waive, but rather intends to preserve and is preserving, all objections as to competency, 

relevancy, materiality, and admissibility of the Interrogatories or the subject matter 

thereof, all objections as to vagueness, ambiguity, and undue burden, all rights to object 

on any ground to the use of any of said documents or responses, or the subject matter 

thereof, in any subsequent proceeding, in this action or any other proceeding, and all 

rights to object on any ground to any request for further responses to these or any other 

requests for documents, interrogatory requests, or any other discovery requests involving 

or related to the subject matter of the Interrogatories.

5. Plaintiff objects to the Interrogatories to the extent that they call for the production of 

documents and/or information already in the possession or control of Defendant or 

documents produced or made available for inspection by other sources, on the grounds 

that such production would be unnecessary and unduly burdensome. Plaintiff objects to 

the Interrogatories to the extent that they purport to require Plaintiff to seek out and 

produce documents that are not within its actual possession or control or that could just as 

easily be obtained by Defendant as Plaintiff.

Case 5:20-cv-00746-JKP Document 111-4 Filed 10/27/22 Page 3 of 9
6. Plaintiff objects to the Definitions and Instructions of the Interrogatories to the extent that 

they seek to impose obligations different from or in excess of the obligations imposed by 

Federal Rules of Civil Procedure.

RESPONSES

1. Identify with specificity all the compensatory damages (including, without 

limitation, all medical bills and costs) you seek to recover from Dr. Guerra in 

connection with the CFAA Claims you have asserted against Dr. Guerra. Please 

include with your answer the amount of each item of compensatory damages and 

the date such damage/cost was incurred. 

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

2. Identify with specificity all the compensatory damages (including, without 

limitation, all medical bills and costs) you seek to recover from Digital Forensics 

Corporation, LLC (“DFC”) in connection with the CFAA Claims you have asserted 

against DFC. Please include with your answer the amount of each item of 

compensatory damages and the date such damage/cost was incurred. 

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

3. Identify with specificity all the compensatory damages (including, without 

limitation, all medical bills and costs) you seek to recover from Dr. Guerra in 

connection with the Texas Statutory Claims you have asserted against Dr. Guerra. 

Please include with your answer the amount of each item of compensatory damages 

and the date such damage/cost was incurred. 

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

4. Identify with specificity all the compensatory damages (including, without 

limitation, all medical bills and costs) you seek to recover from DFC in connection 

with the Texas Statutory Claims you have asserted against DFC. Please include with 

your answer the amount of each item of compensatory damages and the date such 

damage/cost was incurred. 

Case 5:20-cv-00746-JKP Document 111-4 Filed 10/27/22 Page 4 of 9
Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

5. Identify with specificity all the compensatory damages (including, without 

limitation, all medical bills and costs) you seek to recover from Dr. Guerra in 

connection with the malicious prosecution claim you have asserted against Dr. 

Guerra. Please include with your answer the amount of each item of compensatory 

damages and the date such damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

6. Identify with specificity all the compensatory damages (including, without 

limitation, all medical bills and costs) you seek to recover from DFC in connection 

with the malicious prosecution claim you have asserted against DFC. Please include 

with your answer the amount of each item of compensatory damages and the date 

such damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

7. Identify with specificity all the compensatory damages (including, without 

limitation, all medical bills and costs) you seek to recover from Dr. Guerra in 

connection with the intentional infliction of emotional distress claim you have 

asserted against Dr. Guerra. Please include with your answer the amount of each 

item of compensatory damages and the date such damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

8. Identify with specificity all the compensatory damages (including, without 

limitation, all medical bills and costs) you seek to recover from DFC in connection 

with the intentional infliction of emotional distress claim you have asserted against 

DFC. Please include with your answer the amount of each item of compensatory 

damages and the date such damage/cost was incurred. 

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

Case 5:20-cv-00746-JKP Document 111-4 Filed 10/27/22 Page 5 of 9
9. Identify with specificity all the consequential damages (including, without 

limitation, all medical bills and costs) you seek to recover from Dr. Guerra in 

connection with the CFAA Claims you have asserted against Dr. Guerra. Please 

include with your answer the amount of each item of consequential damages and the 

date such damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

10. Identify with specificity all the consequential damages (including, without 

limitation, all medical bills and costs) you seek to recover from Digital Forensics 

Corporation, LLC (“DFC”) in connection with the CFAA Claims you have asserted 

against DFC. Please include with your answer the amount of each item of 

consequential damages and the date such damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

11. Identify with specificity all the consequential damages (including, without 

limitation, all medical bills and costs) you seek to recover from Dr. Guerra in 

connection with the Texas Statutory Claims you have asserted against Dr. Guerra. 

Please include with your answer the amount of each item of consequential damages 

and the date such damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

12. Identify with specificity all the consequential damages (including, without 

limitation, all medical bills and costs) you seek to recover from DFC in connection 

with the Texas Statutory Claims you have asserted against DFC. Please include with 

your answer the amount of each item of consequential damages and the date such 

damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

13. Identify with specificity all the consequential damages (including, without 

limitation, all medical bills and costs) you seek to recover from Dr. Guerra in 

connection with the malicious prosecution claim you have asserted against Dr. 

Case 5:20-cv-00746-JKP Document 111-4 Filed 10/27/22 Page 6 of 9
Guerra. Please include with your answer the amount of each item of consequential 

damages and the date such damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

14. Identify with specificity all the consequential damages (including, without 

limitation, all medical bills and costs) you seek to recover from DFC in connection 

with the malicious prosecution claim you have asserted against DFC. Please include 

with your answer the amount of each item of consequential damages and the date 

such damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

15. Identify with specificity all the consequential damages (including, without 

limitation, all medical bills and costs) you seek to recover from Dr. Guerra in 

connection with the intentional infliction of emotional distress claim you have 

asserted against Dr. Guerra. Please include with your answer the amount of each 

item of consequential damages and the date such damage/cost was incurred.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

16. Identify with specificity all the consequential damages (including, without 

limitation, all medical bills and costs) you seek to recover from DFC in connection 

with the intentional infliction of emotional distress claim you have asserted against 

DFC. Please include with your answer the amount of each item of consequential 

damages and the date such damage/cost was incurred. 

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture.

17. Identify with specificity the amount of punitive damages you seek to recover from 

Dr. Guerra in connection with your claims asserted against her in the lawsuit and 

the basis for the calculation of such amount.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture. Without waiving

Case 5:20-cv-00746-JKP Document 111-4 Filed 10/27/22 Page 7 of 9
the foregoing objections, and reserving the right to change this number based upon new 

information and trial, Plaintiff seeks $10,000,000.00 in punitive damages.

18. Identify with specificity the amount of punitive damages you seek to recover from 

DFC in connection with your claims asserted against them in the lawsuit and the 

basis for the calculation of such amount.

Plaintiff objects to this interrogatory on the grounds that it is overbroad, unduly 

burdensome, seeks irrelevant information, and seeks information already known to 

Defendant and is premature as damages are not an issue at this juncture. Without waiving

the foregoing objections, and reserving the right to change this number based upon new 

information and trial, Plaintiff seeks $10,000,000.00 in punitive damages.

Case 5:20-cv-00746-JKP Document 111-4 Filed 10/27/22 Page 8 of 9
Certificate of Service

I certify that on September 15th, 2022, I served the above responses to Defendant’s

attorneys according to the Federal Rules of Civil Procedure.

/s/ Michael Hassard

Michael Hassard

Case 5:20-cv-00746-JKP Document 111-4 Filed 10/27/22 Page 9 of 9