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

______________________________________

Fourth Continuance Request On Consent Of All Parties

Case 5:20-cv-00746-JKP Document 49 Filed 06/15/21 Page 1 of 4
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Plaintiffs Dr. Rodrigo Cantu and Melody Joy Cantu in their fourth 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 June 16, 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 

these 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. Plaintiffs and Dr. Guerra are communicating with the intent to partake in mediation. 

Parties plan to use the continuance to choose a date for mediation and begin the 

processes of mediation.

5. 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 60-day continuance. After which, they will reconvene to review 

whether another continuance is necessary.

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

deadlines. With the new deadlines as follows:

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

• August 30, 2021: Responses to Settlement Offers from Opposing Parties

Case 5:20-cv-00746-JKP Document 49 Filed 06/15/21 Page 2 of 4
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• September 14, 2021: Last day to Amend/Supplement Pleadings, and Joinder

• October 1, 2021: Designation of Experts by Parties Resisting Claims

• November 15, 2021: Discovery Deadline

• November 29, 2021: Joint Report on Settlement Negotiations

• December 13, 2021: Last Day to File Dispositive Motions

Dated: June 15, 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

Case 5:20-cv-00746-JKP Document 49 Filed 06/15/21 Page 3 of 4
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Certificate of Service

I certify that on this 15th of June 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

Case 5:20-cv-00746-JKP Document 49 Filed 06/15/21 Page 4 of 4