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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

MELODY JOY CANTU and

DR. RODRIGO CANTU, 

Plaintiffs

V.

DR. SANDRA GUERRA and

DIGITAL FORENSICS 

CORPORATION, LLC

Defendants

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CASE NO.: 5:20-CV-00746-JKP (HJB)

DR. GUERRA’S SUR-REPLY TO PLAINTIFFS’ REPLY TO DR. GUERRA’S 

RESPONSE TO PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT 

TO THE HONORABLE UNITED STATES DISTRICT COURT:

NOW COMES Defendant, DR. SANDRA GUERRA (“Dr. Guerra” and “Defendant”), and 

files this Dr. Guerra’s Sur-Reply to Plaintiffs’ Reply to Dr. Guerra’s Response to Plaintiffs’ 

Motion for Summary Judgment [Doc. 118], and, in support thereof, would respectfully show unto 

the Court as follows:

I.

SUMMARY JUDGMENT EVIDENCE

1. In support of this Sur-Reply, Dr. Guerra relies upon the following:

• Exhibit K: Dr. Rodrigo Cantu’s Supplemental Responses to Dr. Guerra’s First 

Request for Production – Joint Advisory

• Exhibit L: Melody Joy Cantu’s Supplemental Responses to Dr. Guerra’s 

Second Request for Production– Joint Advisory

• Exhibit M:Melody Joy Cantu’s Supplemental Responses to Dr. Guerra’s 

Interrogatories – Joint Advisory

• Exhibit N: Dr. Rodrigo Cantu’s Supplemental Responses to Dr. Guerra’s 

Interrogatories – Joint Advisory

• Exhibit O: Bexar County Criminal Docket Sheet – Order of the Court

• Exhibit P: Emails between Dr. Sandra Guerra and Dr. Rodrigo Cantu

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• Exhibit Q: Final Decree of Divorce of Melody Joyce Ross and Charles Robert 

Ross 

• Exhibit R:Mother’s Day Card from Dr. Rodrigo Cantu to Dr. Guerra

• Exhibit S: Texas Medical Board Notice to Dr. Cantu of Denial of Registration 

dated November 26, 2018

• Exhibit T: Emails between Dr. Rodrigo Cantu and Dr. Guerra Regarding Child 

Support Payments

• Exhibit U: Letter from Texas Attorney General Child Support Division to Dr. 

Guerra dated December 31, 2018 and Dr. Guerra’s Custodial Parent’s Affidavit 

of Direct Payments

• Exhibit V: Excerpts from the Deposition Transcript of Melody Joy Cantu dated 

July 16, 2022

• Exhibit W: Dr. Rodrigo Cantu’s Original Petition for Divorce from Melody Joy 

Cantu

• Exhibit X: Melody Joy Cantu’s Original Answer and Original Counter-Petition 

for Divorce from Dr. Rodrigo Cantu

• Exhibit Y: San Antonio Police Report filed Against Melody Joy Cantu by Dr. 

Rodrigo Cantu.

2. In addition, Dr. Guerra relies upon, and incorporates herein by reference as if fully 

set forth verbatim, Dr. Guerra’s Motion for Summary Judgment on Plaintiffs’ Claims [Doc. 109] 

and Exhibits 1 – 12 attached thereto1 and Dr. Guerra’s Response to Plaintiffs’ Motion for Summary 

Judgment [Doc. 114] and Exhibits A – J thereto.2 Dr. Guerra also requests the Court to take judicial 

notice of the pleadings and motions of the parties referenced herein and all other orders and pleadings 

on file.

II.

RESERVATION OF RIGHT TO AMEND AND/OR SUPPLEMENT 

3. Pursuant to the parties’ Joint Advisory to the Court Regarding the In-Person 

Hearing Set on November 4, 2022 [Doc. 116], Plaintiffs were required to supplement their 

discovery responses no later than November 11, 2022. However, as of the date hereof, Plaintiffs 

1 Docs. 109, 109-1 to 109-13.

2 Doc. 114-1 to 114-11.

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have failed to comply with the terms of the parties’ agreement under the Joint Advisory. Plaintiffs, 

among other things, were required to confirm in writing that no documents responsive to Dr. 

Guerra’s certain requests for production to Plaintiffs are being withheld by Plaintiffs on the basis 

of privilege or any objection.

3

 Plaintiffs failed to provide such required written confirmation.4

4. Plaintiffs were also required to serve, no later than November 11, 2022 their signed

and sworn responses to each and every interrogatory set forth in Dr. Guerra’s First Set of 

Interrogatories to Melody Joy Cantu served on August 15, 2022 and Dr. Guerra’s First Set of 

Interrogatories to Dr. Rodrigo Cantu served on August 15, 2022.5

 However, the responses 

provided by Plaintiffs were neither signed nor sworn to by Plaintiffs.

6

5. In addition, Plaintiffs’ counsel was required to provide a signed and sworn affidavit 

stating the total amount Plaintiffs have actually paid Tor Ekeland Firm, PLLC and the Rain Minns 

Law Firm for fees and expenses as of November 3, 2022.7 Plaintiffs’ counsel stated the amount 

they purportedly “billed” Plaintiffs but failed to comply with their obligation under the Joint 

Advisory to state the total amount Plaintiffs have actually paid to their attorneys.

6. Accordingly, Dr. Guerra reserves the right to amend and/or supplement her 

Summary Judgment on Plaintiffs’ Claims [Doc. 109], Response to Plaintiffs’ Motion for Summary 

Judgment [Doc. 114], and this Sur-Reply pending Plaintiffs full compliance with the Joint 

Advisory. 

3 Doc. 116, ¶2(a).

4 Ex. L and Ex. K.

5 Doc. 116, ¶4(a).

6 Ex. M and Ex. N.

7 Doc. 116, ¶2(c).

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III.

ARGUMENT AND AUTHORITIES

A. MELODY HAS FAILED TO CONCLUSIVELY ESTABLISH AS A MATTER OF LAW THAT SHE WAS 

INNOCENT.

7. Melody continues to ignore in her Reply that she must conclusively establish as a 

matter of law that she was innocent of the criminal charge of harassment against Dr. Guerra in 

order to be entitled to summary judgment on her malicious criminal prosecution claims against 

Defendants.

8

 Because a suit for malicious prosecution is a civil action, there is no presumption 

that the plaintiff was innocent of the crime.9

 Yet, Melody has failed to produce any competent 

summary judgment evidence conclusively establishing that she was innocent of any of allegations 

reported by Dr. Guerra to the San Antonio Police Department.

8. Melody completely fails to address the fact that she admitted under oath to 

committing several of the acts described in the State of Texas’ Probable Cause Affidavit,

10

including, without, limitation, (i) calling Dr. Guerra’s then-employer, Humana, to accuse Dr. 

Guerra of posting Human’s proprietary information om Facebook, (ii) accosting Dr. Guerra and 

her daughters in a restaurant parking lot and sending Dr. Guerra numerous unsolicited messages 

over social media, (iii) sending numerous messages to the ex-wife of Dr. Guerra’s then-boyfriend 

(now husband) accusing Dr. Guerra of being “manipulative and deceptive” and implying (if not 

explicitly stating) that Dr. Guerra had a sexually transmitted disease.”11

9. The record reflects that there are genuine issues of material fact regarding Melody’s 

innocence. Plaintiffs point to no evidence in Plaintiffs’ Motion for Summary Judgment or in 

8 Kroger Tex. L.P. v. Suberu, 216 S.W.3d 788, 792 n.3 (Tex. 2006); Richey, 952 S.W.2d at 517

(emphasis added). 9 See Missouri, Kan. & Tex. Ry. V. Groseclose, 110 S.W. 477, 480 (Tex.App.—Texarkana 1908, 

no writ).

10 See Doc. 114-2. 11 See Doc. 114, ¶¶17-26 (including Exhibits cited in fn. 14-36 therein).

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Plaintiffs’ Reply that conclusively establishes as a matter of law that Melody was innocent of the 

criminal harassment charge against her. Consequently, Plaintiffs have failed to satisfy their 

summary judgment burden with respect to this essential element of Melody’s malicious 

prosecution claims against Defendants. 

B. PLAINTIFFS LACK COMPETENT SUMMARY JUDGMENT EVIDENCE TO OVERCOME THE 

PRESUMPTION OF PROBABLE CAUSE.

10. In order to overcome the presumption of probable cause, the plaintiff must produce 

evidence that the motives, grounds, beliefs, and other evidence upon which the defendant acted 

did not constitute probable cause.

12 

11. Again, completely ignoring the fact that Melody has admitted under oath to 

committing several of the acts described in the State of Texas’ Probable Cause Affidavit, Plaintiffs 

make the conclusory allegation in their Reply that “Defendants lied to the police and the State had 

no way prove its case because it was based on a lie.”13 However, Plaintiffs have failed to submit 

any competent summary judgment evidence to support such allegation. Instead, Plaintiffs cite to 

Melody’s own Motion to Set Aside Information for Failure to Afford Constitutional Right to 

Speedy Trial (the “Motion to Set Aside”) and falsely advises this Court that the “prosecution

state[d], ‘the State could not prove its case, now, or ever.’ ”14 Plaintiffs also falsely claim that the 

“Motion to Set Aside states the court could not make any findings of probable cause and that it 

could not prove its case.”15 These are blatant and egregious misrepresentations of the facts and 

evidence. The Motion to Set Aside, which was filed by Melody, is a request to the Court to “set 

12 Richey, 952 S.W.2d at 517-18. 13 Doc. 118, p. 4.

14 Id. citing Doc. 118-113 (emphasis added). 15 Id. citing Doc. 118-113.

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aside the information for failure to afford the defendant [Melody] a speedy trial” and states as 

follows:

The prosecutor orally announced that his office was still issuing subpoenas in effort 

to prove this case, or some other unspecified case or cases. [Melody’s] Counsel

objected to a reset orally, pointing out that the State could not prove this case, now 

or ever, and this Court suggested that a motion to dismiss for want of a speedy trial 

should be filed.16

12. Contrary to Plaintiffs’ representations in their Reply, neither the prosecutor nor the 

Court stated that the “court could not make any findings of probable cause.” The Motion to Set 

Aside is just that: a motion containing a request for relief. It is not an order of the Court. The 

Motion to Set Aside does not contain any findings of fact or conclusions of law by the Court.17 

The Court simply dismissed the case on “speedy trial grounds.”18

C. MELODY HAS FAILED TO CONCLUSIVELY ESTABLISH AS A MATTER OF LAW THAT DR.

GUERRA ACTED WITH MALICE.

13. For purposes of malicious prosecution, malice means “ill will or evil motive, or 

such gross indifference or reckless disregard for the rights of others as to amount to a knowing, 

unreasonable, wanton, and willful act.”19

14. The events giving rise to Melody’s purported malicious criminal prosecution claim 

against Defendants occurred on or about September 4, 2018 when Dr. Guerra filed a police report 

against Melody for harassment.20 Plaintiffs allege in their Reply that Dr. Guerra has engaged in 

an “obsessive stalking campaign against Plaintiffs” which “stems from her [alleged] jealousy” 

because “she simply cannot move on.”21 In support of this conclusory allegation, Plaintiffs rely 

16 Doc. 118-13, p. 2-3.

17 Doc. 118.

18 Ex. O.

19 Luce v. Interstate Adjusters, Inc., 26 S.W.3d 561, 566 (Tex. App.—Dallas 2000, no pet.). 20 Doc. 6, ¶40.

21 Doc. 118, p. 4. 

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upon an email sent by Dr. Guerra to Dr. Rodrigo on September 11, 2011 (the “2011 Email”) as 

purported evidence that “Dr. Guerra has never fully accepted that Dr. Cantu moved on and has 

repeatedly targeted Mrs. [Melody] Cantu.”22

15. The 2011 Email was sent by Dr. Guerra to Dr. Cantu on the 10th anniversary of 9/11 

and reflects on the events of that day and its impact on Dr. Guerra, her family, and the two 

daughters she and Dr. Cantu share.23 Dr. Guerra sent the 2011 Email to Dr. Cantu nearly 7 years 

before the date Dr. Guerra filed a police report against Melody for harassment on September 4, 

2018. More interestingly, Dr. Guerra sent the 2011 Email to Dr. Cantu, nearly 3 years before 

Plaintiffs, Melody Joy Cantu and Dr. Cantu, were ever married.24 In fact, Melody was still married 

to her second husband, Charles Robert Ross, when Dr. Guerra sent the 2011 Email to Dr. Cantu.25

16. It is also important to note that Plaintiffs only included Dr. Guerra’s email to Dr. 

Cantu sent on September 11, 2011.26 Plaintiffs purposefully excluded Dr. Cantu’s email response

to Dr. Guerra, which was inexplicably sent to Dr. Guerra seven years later on September 12, 

2018.27 

17. Plaintiffs allege that “[t]hroughout her campaign of harassment...Dr. Guerra has 

repeatedly exhibited malicious conduct,” but Plaintiffs omit that Dr. Cantu sent Dr. Guerra a 

Mother’s Day card in 2018 stating:

...Thank you for being such a great mom to our kids. “Great” doesn’t do you 

justice. I’m so blessed to be in this parenting thing with you!28

22 Doc. 118, p. 4 (citing Doc. 118-22 in fn. 5). 23 Doc. 118-22; see also Ex. P.

24 Doc. 118, p. 4 (“Plaintiff married in 2014”).

25 Ex. Q.

26 Doc. 118, p.4 (citing Doc. 118-22 in fn. 5). 27 Doc. 118, p.4 (citing Doc. 118-22 in fn. 5); compare to Ex. P. 28 Ex. R.

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18. Furthermore, although it is entirely irrelevant to Melody’s malicious criminal 

prosecution claims against Defendants, Plaintiffs misrepresent to the Court that “[e]vidence from 

the Texas Medical Board shows that Dr. Guerra lied to authorities, wrongfully accusing Dr. Cantu 

of failing to meet his child support obligations” and “as a direct result...,Dr. Cantu’s medical 

license was suspended.29 However, the letter from the Texas Medical Board to Dr. Cantu actually 

states:

Dear Dr. Cantu,

You are being contacted as a result of a computerized match, based on identifiers 

such as social security number, name, and date of birth. This matching process is 

performed by the Texas Office of the Attorney General – Child Support Division 

in order to notify licensing boards that you may have defaulted on your child 

support payments for six months or more prior to the date of this notice.30

19. The summary judgment evidence establishes that Dr. Cantu’s June 2018 child 

support payment to Dr. Guerra was returned by the bank due to insufficient funds and his 

September 2018 child support payment was late.31 Nevertheless, after Dr. Guerra received a 

notice from the Texas Attorney General Child Support Division dated December 31, 2018 

requesting she complete and return an Affidavit of Direct Payments, she promptly completed 

the Custodial Parent’s Affidavit of Direct Payments on January 9, 2019 and returned it to the 

Texas Attorney General as requested.32 Thus, Plaintiffs’ allegations that Dr. Guerra “lied” and 

caused Dr. Cantu’s medical license to be suspended are further gross fabrications by Plaintiffs 

of the truth.

29 Doc. 118, p.5 (citing Doc. 118-21 in fn. 7 therein); see also Ex. S, which is a legible copy of 

Doc. 118-21.

30 Doc. 118-21; see also Ex. S, which is a legible copy of Doc. 118-21 (emphasis added). 31 Ex. T.

32 Ex. U.

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D. MELODY’S ALLEGED EMOTIONAL HARDSHIPS ARE THE RESULT OF HER PRE-EXISTING 

MENTAL HEALTH CONDITIONS AND DYSFUNCTIONAL RELATIONSHIP WITH PLAINTIFF, DR.

CANTU.

20. Plaintiffs publicly filed Melody’s unredacted medical records as part of their 

summary judgment evidence33 in support of Melody’s claim that she “suffered significant damages 

as a direct result of Dr. Guerra’s obsessive campaign against her and Dr. Cantu.”34 Plaintiffs claim 

that “[b]ecause of Dr. Guerra and DFC’s malicious prosecution of Mrs. Cantu, Mrs. Cantu has had 

to undergo therapy.”35 However, the competent summary judgment evidence (including Melody’s 

medical records filed with her Reply) establish that Melody’s therapy and emotional hardships not 

only predate the date Dr. Guerra filed a police report against Melody for harassment, but are the 

direct result of Melody’s pre-existing mental health conditions and dysfunctional relationship with 

her husband Dr. Cantu.36

21. Melody suffers from Major Depressive Disorder and Panic Disorder with 

Agoraphobia.37 Melody testified she was diagnosed with Major Depressive Disorder “in 2014 or 

2015 when [Plaintiff, Dr. Cantu] and [Melody] started getting divorced.”38 She testified she was 

diagnosed with Panic Disorder with Agoraphobia in 2016 but claimed the “[agoraphobia] started 

33 Dr. Guerra notes that Plaintiffs submitted Plaintiffs’ medical records as part of the public record 

in spite of their spurious objections to Dr. Guerra’s third-party subpoenas and requests for

production of Plaintiffs’ medical and billing records and repeated refusals to provide HIPAA 

authorizations for the production of such medical and billing records. See Docs. 90, 93, 101, 104, 

106, and 116. Plaintiffs continue to withhold Plaintiffs’ HIPAA authorization as of the date of this 

filing. 

34 Doc. 118, p. 5 (citing Doc. 118-19 and 118-20 in fn. 9-10 therein)

35 Doc. 118, p. 5.

36 See Doc. 118-19 and 118-20.

37 Ex. V, 9:12-16:25. 38 Id 9:12-15.

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in 2015.”39 Melody’s medical records also indicate that she suffers from Obsessive Compulsive 

Disorder (“OCD”).

40

22. Plaintiffs, Melody and Dr. Cantu, married on April 18, 201441 and “ceased to leave 

together as husband and wife” as of the date Dr. Cantu filed his petition for divorce from Melody 

on November 5, 2015.42 Melody filed her Counter-Petition for Divorce on December 10, 201543

and Plaintiffs finalized their divorce on June 17, 2016.44 Plaintiffs later re-married on June 1, 

2018.45 

23. Melody testified that “[Dr. Cantu] was very difficult to live with” and was “cruel 

[to her] at times.”46 Dr. Cantu, for his part, filed a police report against Melody for harassment on 

April 2, 2018 wherein the police investigator stated that Dr. Cantu reported that “[Melody] had 

called him more than 50 times...and stated in text messages to [Dr. Cantu] that [she] was going to 

send intimate pictures of him and [her] to [Dr. Cantu’s] parents if [Dr. Cantu] does not take her 

back.”47

24. The events giving rise to this lawsuit occurred in 2018. Specifically, Dr. Guerra 

filed a police report against Melody for harassment on September 4, 2018. However, the medical 

records indicate Melody was in therapy long before 2018, and she continued therapy after 2018 

for reasons wholly unrelated to Defendants.

48 By way of example, Melody’s therapist included 

the following notes in Melody’s medical records:

39 Id. 11:8-12; 15:12-16:4.

40 Doc. 118-19, MCantuFinalProd#Bates1657, 1659, 1662.

41 Ex. V, 57:11-13. 42 Ex. W.

43 Ex. X.

44 Ex. V, 62:20-25.

45 Id. at 115:2-11.

46 Id. at 90:22 – 92:7.

47 Ex. Y.

48 See Doc. 118-19 and 118-20. 

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• Sep. 9, 2016: “...[Melody] states she is confused about the relationship with David. 

She wants more now and wants him to lessen his relationship with family and focus 

more on her. Suggested it might be an unrealistic expectation to ask him to disconnect 

from family...”49

• March 26, 2018: “...At this session, client starts off mildly tearful and cursing her ex 

[Dr. Cantu]. She talked [sic] what a bad person he was and how upset she is with 

him.”50

• April 2, 2018: “Melody is anxious and depressed. [She] disclosed that she confronted 

her ex’s exwife and ex at a restaurant and informed her that she and David, her ex, had 

been together for the last 3 years as a secret. [Melody] sent pictures and text copies to 

both David’s ex and David’s parents. She disclosed many intimate details about 

them and their relationship as well as pictures and letters and texts. Client 

expressed no regret for what she did but at times is fearful that she will never be 

able to see David again.”51 

• April 9, 2018: “...[Melody] continues to report sadness regarding her relationship with 

David. She reports that she continues to feel hurt and confused regarding the 

relationship and why it didn’t work out...”52

• December 10, 2018: “Mood is depressed and anxious. [Melody] reports that she only 

goes out at late night...OCD is worse with more compulsions. Angry at spouse [David] 

as well.

• February 4, 2019: “...[Melody] states that her health continues to fail with issues 

from lymph nodes...[Melody] states that her OCD has spiraled out of control and she 

is afraid nothing can be done at this point. She is spending much of her time ruminating 

and his increased avoidance. She barely leaves the house. She states she has become 

fearful of running into [David’s] ex or her children. She has become more 

irrational about that fear which concerns this therapist...”53

• February 20, 2019: “Mood is depressed and anxious...States that she is feeling 

overwhelmed at this point and does not know how much more ‘she can 

handle’...Hypervigilant to cars parked on her street. Increased agitations and feelings 

of panic occurring more frequently. Ruminated ‘constantly.’ Complains that it is 

getting more difficult for her to do her job due to the ruminations as well as her 

moods...”54

49 Doc. 118-19, MCantuFinalProd#Bates1643. 50 Id. at MCantuFinalProd#Bates1644. 51 Id. at MCantuFinalProd#Bates1646 (emphasis added).

52 Id. at MCantuFinalProd#Bates1647.

53Id. at MCantuFinalProd#Bates1659 (emphasis added).

54 Doc. 118-19, MCantuFinalProd#Bates1660.

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• March 6, 2019: “....[Melody] reports that she only gets out of her bed to work. She 

spends most of her time in bed when not working or taking care of her kids...She 

reports an increase in her OCD...(This is probably the worst I have seen her OCD in 

all the years I have known her).55

IV.

CONCLUSION

Plaintiffs’ arguments and evidence in support of their Motion for Summary Judgment and 

Reply are based solely upon Plaintiffs’ assumptions, speculation, unfounded conspiracy theories, 

imagined facts, and distortions of the truth. As detailed herein and in Dr. Guerra’s Motion for 

Summary Judgment on Plaintiffs’ Claims [Doc. 109] and Dr. Guerra’s Response to Plaintiffs’ 

Motion for Summary Judgment [Doc. 114], Plaintiffs have failed to conclusively establish as a 

matter of law each and every element of Plaintiffs’ CFAA Claims and Texas Harmful Access by 

Computer Claims and Melody’s malicious prosecution claims against Defendants.

WHEREFORE, PREMISES CONSIDERED, Defendant, DR. SANDRA GUERRA,

respectfully prays that this Court deny Plaintiffs’ Motion for Summary Judgment in all respects 

and grant Dr. Guerra all such other and further relief, both general and special, at law or in equity, 

to which she may be justly entitled. 

55Id. at MCantuFinalProd#Bates1662.

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Dated: November 14, 2022. Respectfully submitted,

DAVIS, CEDILLO & MENDOZA, INC.

McCombs Plaza, Suite 250

755 E. Mulberry Avenue

San Antonio, Texas 78212

Telephone No.: (210) 822-6666

Telecopier No.: (210) 660-3795

 

By: /s/Ricardo G. Cedillo __________ 

 RICARDO G. CEDILLO

 Texas State Bar No. 04043600

 rcedillo@lawdcm.com

 BRANDY C. PEERY

 Texas State Bar No. 24057666

 bpeery@lawdcm.com

ATTORNEYS FOR DEFENDANT, DR. 

SANDRA GUERRA

CERTIFICATE OF SERVICE

I certify that on this 14th day of November 2022, 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/Ricardo G. Cedillo 

RICARDO G. CEDILLO

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