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

______________________________________

Third Continuance Request On Consent Of All Parties

Case 5:20-cv-00746-JKP Document 47 Filed 05/14/21 Page 1 of 5
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Plaintiffs Dr. Rodrigo Cantu and Melody Joy Cantu in their third continuance request, 

and Co-Defendants Dr. Sandra Guerra and Digital Forensics Corporation, LLC, through their 

undersigned attorneys, hereby stipulate:

1. The last filed motion in this matter is Plaintiffs’ Reply in Support of Their Motion to 

Dismiss Dr. Sandra Guerra’s Amended Counterclaims.

2. The parties are currently going through discovery. The ADR Report has been filed on 

March 15, 2021 (Docket. No. 44). On May 17, 2021 expert designations are due.

3. On January 30, 2021 Plaintiff Melody Joy Cantu had a medical emergency, she was 

thrown of a horse. Mrs. Cantu is still dealing with pain management and recovery the 

past few months. She continues to be in immense pain and repeatedly visits doctors 

and the hospital to deal with issues stemming from the event.

4. The previous two continuances were requested to allow her proper recovery time. As 

of May 5, 2021, Mrs. Cantu’s doctors advised her to remain at home for at least 

another month. 

5. However, Parties are exploring the possibility of mediation and plan to use the 

continuance to communicate with each other regarding mediation. 

6. Plaintiffs’ counsel reached out to opposing counsel for both Co-Defendants and had a 

good faith conference regarding their request for a continuance. All parties are in 

agreement to a 30-day continuance. After which, they will reconvene to review 

whether another continuance is necessary.

7. All parties are in agreement and stipulate to a sixty-day continuance of our discovery 

deadlines. With the new deadlines as follows:

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• June 16, 2021: Designation of Experts by Parties Asserting Claims

• July 1, 2021: Responses to Settlement Offers from Opposing Parties

• July 16, 2021: Last day to Amend/Supplement Pleadings, and Joinder

• Aug 2, 2021: Designation of Experts by Parties Resisting Claims

• September 15, 2021: Discovery Deadline

• September 29, 2021: Joint Report on Settlement Negotiations

• October 14, 2021: Last Day to File Dispositive Motions

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Dated: May 14, 2021 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

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Certificate of Service

I certify that on this 14th of May 2021, 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

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