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

______________________________________

Second Continuance Request On Consent Of All Parties

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Plaintiffs Dr. Rodrigo Cantu and Melody Joy Cantu, in their second 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. On March 15, 2021 counsel for 

Co-Defendant Dr. Sandra Guerra filed the ADR Report (Docket. No. 44). On March

17, 2021 expert designations are due.

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

thrown off a horse. On February 1, 2021, Mrs. Cantu was in the ICU for a week 

having corrective surgery due to all but her four ribs being broken, a shattered 

clavicle, and a head injury.

4. Mrs. Cantu was dealing with pain management and recovery for the past month and a 

half. We requested the original continuance to allow her proper recovery time.

5. Last week, Mrs. Cantu was taken back to the ICU. One of her ribs was fragile and 

broke while she was recovering at home. This injury necessitated additional time in 

the ICU and further pain management. 

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 60-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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• May 17, 2021: Designation of Experts by Parties Asserting Claims

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

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

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

• August 16, 2021: Discovery Deadline

• August 30, 2021: Joint Report on Settlement Negotiations

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

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Dated: March 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

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Certificate of Service

I certify that on this 15th of March 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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