UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS 

SAN ANTONIO DIVISION

MELODY JOY CANTU AND DR. 

RODRIGO CANTU

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5:20-cv-00746-jkp

 PLAINTIFFS §

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v. §

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DR. SANDRA GUERRA AND 

DIGITAL FORENSICS 

CORPORATION LLC

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 DEFENDANTS §

DEFENDANT DIGITAL FORENSICS CORPORATION LLC’S

INITIAL DISCLOSURES

In accordance with Rule 26(a)(1) of the Federal Rules of Civil Procedure, 

Plaintiff, Digital Forensics Corporation, LLC, respectfully makes their mandatory 

disclosures as follows:

A. Witnesses

The name and, if known, the address and telephone number of each

individual likely to have discoverable information that the disclosing party 

may use to support its claims or defenses, unless solely for impeachment, 

identifying the subjects of the information.

RESPONSE:

Melody Joy Cantu & Dr. Rodrigo Cantu

c/o their counsel Tor Ekeland & Rain Levy Minns

195 Montague Street, 14th Floor

Brooklyn, New York 11201

(718) 737-7264

Case 5:20-cv-00746-JKP Document 33 Filed 12/01/20 Page 1 of 4
Defendant’s Initial Disclosure Page 2 of 4

Dr. Sandra Guerra

c/o her counsel Richard G. Cedillo & Courtney R. Gaines

755 E. Mulberry Avenue

San Antonio, Texas 78212

(210) 822-6666

B. Documents

A copy of, or a description by category and location of, all documents, 

electronically stored information, and tangible things that are in the 

possession, custody, or control of the party and that the disclosing party may 

use to support its claims or defenses, unless solely for impeachment.

RESPONSE:

• Client Services Agreement between 1ST All File Recovery LLC and Sandra 

Guerra

• Phase 1 Report provided to Sandra Guerra from Digital Forensics Corp

C. Computation of Damages

A computation of any category of damages claimed by the disclosing party, 

making available for inspection and copying as under Rule 34 the documents 

or other evidentiary material, not privileged or protected from disclosure, 

on which such computation is based, including materials bearing on the 

nature and extent of injuries suffered.

RESPONSE:

Defendant has not calculated all of its potential damages and claims but will do so 

and supplement accordingly.

Case 5:20-cv-00746-JKP Document 33 Filed 12/01/20 Page 2 of 4
Defendant’s Initial Disclosure Page 3 of 4

D. Insurance Agreements

For inspection and copying as under Rule 34 any insurance agreement under 

which any person carrying on an insurance business may be liable to satisfy 

part or all of a judgment which may be entered in the action or to indemnify 

or reimburse for payments made to satisfy the judgment.

RESPONSE:

There are none.

Respectfully submitted,

THE HARLEY LAW GROUP

4801 Woodway Drive

Suite 300E

Houston, Texas 77056

(713) 968-6540 

lewis.harley@harleylawgroup.com

By: ___________________________

 Lewis K. Harley

 Texas Bar No. 09015500

 

ATTORNEY FOR DEFENDANT

DIGITAL FORENSICS

CORPORATION LLC

Case 5:20-cv-00746-JKP Document 33 Filed 12/01/20 Page 3 of 4
Defendant’s Initial Disclosure Page 4 of 4

CERTIFICATE OF SERVICE

I certify that on December 1, 2020, a true and correct copy of the foregoing 

document was served via CM/ECF in accordance with the Federal Rules of Civil 

Procedure, on the attorneys of record listed below.

 _________________________

 Lewis K. Harley

Via Electronic Mail: 

Tor Ekeland

Tor Ekeland Law, PLLC

195 Montague Street, 14th Floor

Brooklyn, New York 11201

Phone: (718) 737-7264

Email: tor@torekeland.com

Attorney for Plaintiffs

Rain Levy Minns

Rain Minns Law Firm

4412 Spicewood Springs Road

Suite 500

Austin, Texas 78759

Phone: (512) 372-3222

Email: rain@rainminnslaw.com

Attorney for Plaintiffs

Richard G. Cedillo

Courtney R. Gaines

Davis Cedillo & Mendoza, Inc.

McCombs Plaza, Suite 500

755 E. Mulberry Avenue

San Antonio, Texas 78212

Phone: (210) 822-6666

Email: rcedillo@lawdcm.com

Email: cgaines@lawdcm.com

Attorneys for Defendant

Dr. Sandra Guerra

Case 5:20-cv-00746-JKP Document 33 Filed 12/01/20 Page 4 of 4