EXHIBIT 6

Case 5:20-cv-00746-JKP Document 102-6 Filed 08/29/22 Page 1 of 3
From: Brandy Peery 

Sent: Monday, August 29, 2022 10:40 AM

To: Tor Ekeland <tor@torekeland.com>; Michael Hassard <Michael@torekeland.com>; Rain Minns

<rain@rainminnslaw.com>

Cc: Nicole Guitelman <nicoleg@torekeland.com>; David Apple <jdapple@applefinklaw.com>;

Ricardo Cedillo <rcedillo@lawdcm.com>

Subject: Guerra v. Cantu - Dr. Guerra's RFPs to Dr. Cantu and Melody Joy Cantu

TorPer my prior emails, your clients’ unilateral decision not to call the individuals identified in

Section 2 of Plaintiffs’ Initial Disclosures as witnesses does not dispense of your clients’

obligation to respond to written discovery regarding their communications with these

individuals. Dr. Guerra has not and does not waive her right to call these individuals to

provide deposition or trial testimony.

Melody Joy Cantu’s and Dr. Cantu’s objection to Dr. Guerra’s RFPs Nos. 21, 23, 24, 26, 28,

29, 30 and 13, 15, 16, 18, 19, 20, 21, 22, respectively, on the grounds that such non-party “is

no longer a potential witness in this matter” is not a valid objection. Please withdraw this

objection to each of these RFPs and immediately advise when these documents will be

produced.

Additionally, Dr. Guerra’s RFP 20, 22, and 25 requests all communications between Melody

Joy Cantu and non-party witnesses Danielle Wollervweron[sic], Dottie Laster, and Jackie

Johnston “regarding any matter that is the subject of this lawsuit.” Plaintiff objected to these

requests on that such requests “seeks information and materials constituting Plaintiff’s private

and/or confidential information and is irrelevant and not reasonably calculated to lead to the

discovery of admissible evidence.” These requests are limited to communications between

Plaintiff and the non-parties that concern the subject matter of this lawsuit. As such,

Plaintiff’s boilerplate objections are unsubstantiated. Please withdraw these objections and

immediately advise when these documents will be produced.

Furthermore, Plaintiffs testified during their depositions that they have recorded telephone

calls. Please confirm that all these recordings have been produced.

Brandy C. Peery

Shareholder

Note: New Suite Number

OFFICE: 210-822-6666

FAX: 210-660-3795

Case 5:20-cv-00746-JKP Document 102-6 Filed 08/29/22 Page 2 of 3
EMAIL: bpeery@lawdcm.com

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 San Antonio, Texas 78212

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Case 5:20-cv-00746-JKP Document 102-6 Filed 08/29/22 Page 3 of 3