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

______________________________________

NOTICE OF INTENT TO TAKE ORAL AND VIDEOTAPED DEPOSITION OF 

DIGITAL FORENSICS CORPORATION, LLC.

Case 5:20-cv-00746-JKP Document 92 Filed 07/14/22 Page 1 of 6
1

NOTICE OF INTENT TO TAKE THE ORAL AND VIDEOTAPED 

DEPOSITION OF DIGITAL FORENSICS CORPORATION, LLC.

TO: Digital Forensics Corporation, LLC., by and through her counsel of record J. David 

Apple, Email: jdapple@applefinklaw.com; Apple & Fink, LLP, 735 Plaza Blvd., Suite 

200, Coppell, Texas 75019.

Please take notice that pursuant to Federal Rule of Civil Procedure 30 and the Scheduling 

Order Dkt. 89, regarding the discovery period, Plaintiffs Melody Joy Cantu and Dr. Rodrigo 

Cantu, intent to take the oral and/or videotaped deposition of Defendant, DIGITAL 

FORENSICS CORPORATION (“DFC”), before a notary public pr some other officer 

authorized by law to administer oaths, at 1:30 p.m. on Tuesday, July 19, 2022, by remote means 

via a videoconferencing platform.

Pursuant to Federal Rule of Civil Procedure 30(b)(6):

Plaintiffs request TESTIMONY from the person or persons with your company most 

knowledgeable with respect to the following categories:

1) DFC’s investigation of Plaintiffs.

2) DFC’s business interactions with Co-Defendant Dr. Guerra.

3) The forensic techniques, software, and procedures used by DFC to investigate 

Plaintiffs on behalf of Dr. Guerra.

4) All records, logs (including evidence, computer and others of any type), calendars, 

meetings, discussions, communications, correspondence, and any other information 

related to this matter, and how its stored.

5) The names or how to find the names of everyone who worked on this matter on 

behalf of DFC, whether as an employee, independent contractor, agent, or otherwise. 

Case 5:20-cv-00746-JKP Document 92 Filed 07/14/22 Page 2 of 6
2

NOTICE OF INTENT TO TAKE THE ORAL AND VIDEOTAPED 

DEPOSITION OF DIGITAL FORENSICS CORPORATION, LLC.

6) Knowledge of the phishing of the Plaintiffs via text and records and information 

related to it.

7) Knowledge of the software, systems, and procedures used to surveil Plaintiffs’ cell 

phone(s).

8) All policies, systems, and procedures related to forensic investigation used in this 

case.

9) Billing records for payments made in relation to this matter.

10) DFC’s entities, how said entities are structured, and information on who owns the 

entities.

11) Knowledge of how the Phase 1, 2 and any additional reports are compiled by DFC or 

on their behalf.

12) Types of surveillance and malware software DFC used in this matter.

13) What work was done here, what was done with: files, logs, images, including Dr. 

Guerra’s electronics, and where contracts and communications with Dr. Guerra are 

stored.

14) Names of any and all forensic software used in this investigation by DFC.

15) Records of all payments made to and from DFC relating to this matter.

16) The steps DFC took to preserve Electronically Stored Evidence in this case when they 

became aware of this matter.

17) The scope of discovery review conducted in response to Plaintiffs’ discovery 

requests, and who was involved in DFC’s response to Plaintiffs’ requests.

Case 5:20-cv-00746-JKP Document 92 Filed 07/14/22 Page 3 of 6
3

NOTICE OF INTENT TO TAKE THE ORAL AND VIDEOTAPED 

DEPOSITION OF DIGITAL FORENSICS CORPORATION, LLC.

18) DFC’s retention policies in relation to Electronically Stored Information, documents, 

and information of any type.

The deposition, when taken, may continue from day to day until completed, and will be 

taken by stenographic means and videoconferencing examination with the answers to be used in 

the final trial of the above-styled and numbered cause. You are invited to have counsel present 

for purposes of cross-examination.

Case 5:20-cv-00746-JKP Document 92 Filed 07/14/22 Page 4 of 6
4

NOTICE OF INTENT TO TAKE THE ORAL AND VIDEOTAPED 

DEPOSITION OF DIGITAL FORENSICS CORPORATION, LLC.

Dated: July 14, 2022 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 92 Filed 07/14/22 Page 5 of 6
5

NOTICE OF INTENT TO TAKE THE ORAL AND VIDEOTAPED 

DEPOSITION OF DIGITAL FORENSICS CORPORATION, LLC.

Certificate of Service

I certify that on this 14th of July 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/ Tor Ekeland

Case 5:20-cv-00746-JKP Document 92 Filed 07/14/22 Page 6 of 6