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

______________________________________

Fifth Continuance Request 

Case 5:20-cv-00746-JKP Document 57 Filed 08/16/21 Page 1 of 4
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Plaintiffs Dr. Rodrigo Cantu and Melody Joy Cantu, in their fifth continuance request, 

and Co-Defendant Dr. Sandra Guerra, 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. Plaintiffs and Defendant Dr. 

Sandra Guerra are starting mediation on August 20, 2021. 

3. The ADR Report was filed on March 15, 2021 (Docket. No. 44). On August 16, 

2021, expert designations are due.

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

thrown off a horse. Mrs. Cantu is still dealing with pain management and recovery 

these past few months. She continues to be in immense pain and had an additional 

surgery two weeks ago.

5. Plaintiffs’ counsel reached out to opposing counsel for both Co-Defendants and had a 

good faith conference regarding their request for a continuance with Dr. Sandra 

Guerra’s counsel. Parties are in agreement to a 30-day continuance. After which, they 

will reconvene to review whether another continuance is necessary.

6. Counsel for Co- Defendant Digital Forensics Corporation, LLC, has not responded.

7. Plaintiffs and Co-Defendant Dr. Sandra Guerra are in agreement and stipulate to a 

thirty-day continuance of our discovery deadlines. With the new deadlines as follows:

• September 15, 2021: Designation of Experts by Parties Asserting Claims

• September 29, 2021: Responses to Settlement Offers from Opposing Parties

• October 14, 2021: Last day to Amend/Supplement Pleadings, and Joinder

Case 5:20-cv-00746-JKP Document 57 Filed 08/16/21 Page 2 of 4
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• November 1, 2021: Designation of Experts by Parties Resisting Claims

• December 15, 2021: Discovery Deadline

• December 29, 2021: Joint Report on Settlement Negotiations

• January 12, 2022: Last Day to File Dispositive Motions

Dated: August 16, 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 57 Filed 08/16/21 Page 3 of 4
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Certificate of Service

I certify that on this 16th of August 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 57 Filed 08/16/21 Page 4 of 4