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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

Plaintiff’s Initial Disclosures 

Pursuant to Rule 26(a)(1) of 

the Federal Rules of Civil 

Procedure

______________________________________

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Under Fed. R. Civ. P. Rule 26(a)(l), Plaintiffs Melody Joy Cantu and Dr. Rodrigo David 

Cantu (“Cantus”) hereby make their initial disclosures. The initial disclosures are made without 

the benefit of any discovery. Plaintiffs reserve the right to amend their disclosures to add 

additional witnesses, documents, or computation of damages calculations as a result of discovery 

or other factors. The Cantus reserve the right to amend, revise, or supplement these disclosures in 

supplemental disclosures served under Fed. R. Civ. P. Rules 26(a)(1) or 26(e)(1), in written 

discovery responses, in deposition testimony, or by any other means as the case progresses. 

1. List of Witnesses 

Name of Person Person’s Address and 

Telephone Number

Description of what the 

person knows

Melody Joy Cantu (210) 414-0409; 128 Spring 

Hill Dr, Boerne, TX 78006

Co-Plaintiff in the case.

Rodrigo David Cantu (210) 425-5765; 128 Spring 

Hill Dr, Boerne, TX 78006

Co-Plaintiff in the case.

Dottie Laster (210) 882-2259 Private Investigator hired by 

Cantus for the criminal 

matter against Melody Cantu.

Kristina Prewit (877) 445-5362; 100 NE 

Loop 410 STE 540, San 

Antonio, TX 78216

Forensic expert for ExhibitA, 

which the Cantus hired.

Sheri Makowski (239) 645-8465; Lehigh 

Acres, Florida 33936 

Forensic expert for KIP & 

Associates which the Cantus 

hired.

Dr. Sandra Guerra 410 E Rosewood Ave, San 

Antonio, TX 78212

Co-Defendant was deposed in 

a previous civil matter with 

Plaintiffs, and provided a 

Phase I report from Digital 

Forensics Corporation, LLC.

Digital Forensics 

Corporation, LLC

(833) 230-9341, (844) 390-

2818; 1100 NW Loop 410 

#700, San Antonio, TX 

78213

Co-Defendant 

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Jackie Johnston (210) 367-4641; 1130 

Summit Crst, San Antonio, 

TX, 78258

Friend of Plaintiff and knew 

background on the case.

Mindy Holeman (503) 754-5884; 732 June Dr, 

Molalla, OR, 97038

Melody Joy Cantu’s halfsister helped Melody dealing 

with all issues stemming 

from the criminal and civil 

matters. 

Dale Hammerschmidt (254) 781-1679; 720 

Morningside Dr, Nolanville, 

TX, 76559

Friend of Melody Joy Cantu, 

witness to Cantus’ trauma 

caused by Defendants.

Danielle Wollervweron (830) 992-1438; 2020 

Briarwood Cir, 

Fredericksburg, TX 78624

Friend of Cantus, witness to 

Cantus’ trauma caused by 

Defendants.

Rene Charles (281) 384-0407; 18519 W 

Laura Shore Dr, Cypress, TX 

77433

Friend of Cantus, witness to 

Cantus’ trauma caused by 

Defendants.

Dr. John Seals (210) 615-2222; 4410 

Medical Dr #240; San 

Antonio, TX 78229

Melody Joy Cantu’s 

neuropsychologist with 

information on trauma and 

stress caused by Defendants, 

as well as helped Melody’s 

children with trauma. 

Steve Cervantes (210) 341-3525; 325 E 

Sonterra, San Antonio, TX 

78258

Dr. Rodrigo David Cantu’s 

therapist from 2017. 

Randolph A. Pollock, MA, 

LPC

(210) 558-8200; 11118 

Wurzbach, Suite 207, San 

Antonio, TX 78230

Melody Joy Cantu’s therapist 

for panic and anxiety.

Sameer Kinra (713) 824-1342; 5624 Signal 

Point, Austin, TX 78724

Melody Joy Cantu’s friend 

who was with her when 

contacting Spectrum 

regarding the cable router.

Janet Betts 011441565653711; 88 

London Road, Crewe, 

England, CW4 7BD, UK

Melody Joy Cantu’s friend 

Cantus’ trauma caused by 

Defendants.

Lorena M. Hernandez Information not available. Has information regarding 

the timeline of events of 

when the Cantus reconciled 

and who knew. 

Keira Schwartz Dux (832) 795-2542; 6705 

Cambian Pine, Las Vegas, 

NV 89140

Lived with Melody Joy Cantu 

after her arrest and witnessed

trauma to Cantus, as well as 

the issues involved with the 

criminal case.

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Edwardo Gallardo Detective at Prue Road Sub 

Station.

Detective that charged 

Melody Joy Cantu in the 

criminal case.

Sergeant Sergio Flores Detective at the Downtown 

San Antonio Police 

Department Special Victims 

Unit. 

Detective interviewed Dr. 

Guerra regarding the criminal 

case filed by Melody Joy 

Cantu. 

Dr. Joann Murphy (210) 495- 0221; 1202 W 

Bitters Rd #3, San Antonio, 

TX, 78216

Forensic Phycologist 

consulted Cantus after 

Melody’s arrest.

Deena Trevino (210) 647- 7712; 7272 

Wurzbach Rd #1504, San 

Antonio, TX 78240

Court appointed therapist in 

their civil case.

Christine Hefel (210) 698-8818; 23535 I-10 

#2204 San Antonio, TX 

78257

Provided therapy to Dr. 

Rodrigo Cantu’s daughters.

2. Category 

Category of Document, Electronically 

Stored Information, Item, or Tangible 

Thing

Location of Document, Electronically 

Stored Information, Item, or Tangible 

Thing

Exhibit A Forensic Report for Cantus Box and/or Logikcull

KIP & Associates Forensic Report for Cantus Box and/or Logikcull

Digital Forensics Phase I Report for Dr. 

Guerra by DFC LLC.

Box and/or Logikcull

Photos and phone calls relating to the cable 

box splitter 

Box and/or Logikcull

Receipts for costs listed below Box and/or Logikcull

Phone call with Spectrum regarding the cable 

splitter

Box and/or Logikcull

Screenshots of suspicious computer and 

phone activity 

Box and/or Logikcull

3. Plaintiffs/Claimants: Damages Calculation 

Nature of Cost Amount Owed Injuries Suffered

Monthly Management 

and Security of the 

$1,407.12 As a result of Defendants’ 

conduct, accessing the Cantus’ 

protected computers without 

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Router to CDR Business

IT Solutions, LLC.

authorization, thereby obtaining 

private information. The damage 

includes impairment to the 

integrity and availability of the 

Cantus’ data, programs, systems, 

and information on the Cantus’ 

computers and networks resulting 

from computer crashes, 

diminished bandwidth, 

diminished processing time, and 

the deletion and alteration of data,

the Cantus suffered loss in 

expending time, money, and 

resources to investigate the 

intrusion, assess the damage, and 

restore their systems to their prior 

state.

Router Replacement to 

CDR Business IT 

Solutions, LLC.

$660.00 As a result of Defendants’ 

conduct, accessing the Cantus’ 

protected computers without 

authorization, thereby obtaining 

private information. The damage 

includes impairment to the 

integrity and availability of the 

Cantus’ data, programs, systems, 

and information on the Cantus’ 

computers and networks resulting 

from computer crashes, 

diminished bandwidth, 

diminished processing time, and 

the deletion and alteration of data. 

The Cantus suffered loss in 

expending time, money, and 

resources to investigate the 

intrusion, assess the damage, and 

restore their systems to their prior 

state.

Retainer Funds for 

Digital Investigation

$5,000 As a result of Defendants’ 

conduct, accessing the Cantus’ 

protected computers without 

authorization, thereby obtaining 

private information. The damage 

includes impairment to the 

integrity and availability of the 

Cantus’ data, programs, systems, 

and information on the Cantus’ 

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computers and networks resulting 

from computer crashes, 

diminished bandwidth, 

diminished processing time, and 

the deletion and alteration of data. 

The Cantus suffered loss in 

expending time, money, and 

resources to investigate the 

intrusion, assess the damage, and 

restore their systems to their prior 

state.

Consultation Meeting 

with Exhibit A Computer 

Forensics

$237.38 As a result of Defendants’ 

conduct, accessing the Cantus’ 

protected computers without 

authorization, thereby obtaining 

private information. The damage 

includes impairment to the 

integrity and availability of the 

Cantus’ data, programs, systems, 

and information on the Cantus’ 

computers and networks resulting 

from computer crashes, 

diminished bandwidth, 

diminished processing time, and 

the deletion and alteration of data. 

The Cantus suffered loss in 

expending time, money, and 

resources to investigate the 

intrusion, assess the damage, and 

restore their systems to their prior 

state.

Monthly Data Storage by 

Exhibit A Computer 

Forensics

$865.92 As a result of Defendants’ 

conduct, accessing the Cantus’ 

protected computers without 

authorization, thereby obtaining 

private information. The damage 

includes impairment to the 

integrity and availability of the 

Cantus’ data, programs, systems, 

and information on the Cantus’ 

computers and networks resulting 

from computer crashes, 

diminished bandwidth, 

diminished processing time, and 

the deletion and alteration of data. 

The Cantus suffered loss in 

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expending time, money, and 

resources to investigate the 

intrusion, assess the damage, and 

restore their systems to their prior 

state.

Internal Hardrive for 

Exhibit A Computer 

Forensics 

$216.50 As a result of Defendants’ 

conduct, accessing the Cantus’ 

protected computers without 

authorization, thereby obtaining 

private information. The damage 

includes impairment to the 

integrity and availability of the 

Cantus’ data, programs, systems, 

and information on the Cantus’ 

computers and networks resulting 

from computer crashes, 

diminished bandwidth, 

diminished processing time, and 

the deletion and alteration of data. 

The Cantus suffered loss in 

expending time, money, and 

resources to investigate the 

intrusion, assess the damage, and 

restore their systems to their prior 

state.

Forensic Analysis for 2 

Reports by Exhibit A 

Computer Forensics

$1,034.25 As a result of Defendants’ 

conduct, accessing the Cantus’ 

protected computers without 

authorization, thereby obtaining 

private information. The damage 

includes impairment to the 

integrity and availability of the 

Cantus’ data, programs, systems, 

and information on the Cantus’ 

computers and networks resulting 

from computer crashes, 

diminished bandwidth, 

diminished processing time, and 

the deletion and alteration of data. 

The Cantus suffered loss in 

expending time, money, and 

resources to investigate the 

intrusion, assess the damage, and 

restore their systems to their prior 

state.

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Dark Web Live Email 

Scan by Exhibit A 

Computer Forensics

$274.89 As a result of Defendants’ 

conduct, accessing the Cantus’ 

protected computers without 

authorization, thereby obtaining 

private information. The damage 

includes impairment to the 

integrity and availability of the 

Cantus’ data, programs, systems, 

and information on the Cantus’ 

computers and networks resulting 

from computer crashes, 

diminished bandwidth, 

diminished processing time, and 

the deletion and alteration of data. 

The Cantus suffered loss in 

expending time, money, and 

resources to investigate the 

intrusion, assess the damage, and 

restore their systems to their prior 

state.

Router Monitoring 

Subscription by CDR 

Business Solutions

$216.48 As a result of Defendants’ 

conduct, accessing the Cantus’ 

protected computers without 

authorization, thereby obtaining 

private information. The damage 

includes impairment to the 

integrity and availability of the 

Cantus’ data, programs, systems, 

and information on the Cantus’ 

computers and networks resulting 

from computer crashes, 

diminished bandwidth, 

diminished processing time, and 

the deletion and alteration of data. 

The Cantus suffered loss in 

expending time, money, and 

resources to investigate the 

intrusion, assess the damage, and 

restore their systems to their prior 

state.

Attorney’s Fees for the 

Criminal Matter 

$25,000 As a result of the malicious 

prosecution, Plaintiff Melody 

Cantu suffered loss in paying 

attorney’s fees for representation 

in the criminal matter.

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Bond Fee for the 

Criminal Matter

$80.00 As a result of the malicious 

prosecution, Plaintiff Melody 

Cantu suffered loss in paying for 

bond in the criminal matter.

Attorney’s Fees for the 

CPS Investigation 

$3,500 As a result of the false CPS 

Investigation filed by Dr. Sandra 

Guerra, Cantus suffered loss in 

paying for attorney’s fees to 

resolve the situation. 

Dr. Seals Melody Joy Cantu - $2762.12

Dr. Rodrigo David Cantu- $600

William Stuart Ross $2334.77

Madeleine Joy Ross- $2495.29

As a result of the trauma to 

Cantus and their family caused by 

Defendants’ actions, Cantus and 

Melody’s children much 

emotional stress- necessitating 

therapy.

Randolf Pollock Madeleine Joy Ross - $1479.16

William Stuart Ross $ 791.66

Lilian Grace Ross - $416.66

As a result of the trauma to 

Cantus and their family caused by 

Defendants’ actions, Cantus and 

Melody’s children much 

emotional stress- necessitating 

therapy.

Steve Cervantes $2600 As a result of the trauma to 

Cantus and their family caused by 

Defendants’ actions, Dr. Cantu 

required therapy.

Hawk Security $1,800 As a result of Defendants’ 

conduct, the Cantus feared for 

their safety, and suffered loss in 

paying for security cameras.

Fees, Taxes, and 

Penalties

Approximately $50,000 As a result of Defendants’ 

conduct, Plaintiffs suffered loss in 

fees, taxes, and penalties for 

withdrawing money from their 

retirement funds in order to pay

their attorney’s fees.

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CERTIFICATE OF SERVICE

Case name: Melody Joy Cantu et al v. Dr. Sandra Guerra et al.

Case number: 5:20-CV-0746 JKP – HJB

On December 1, 2020, I Nicole Guitelman personally emailed opposing counsel, in the 

aforementioned matter, Plaintiffs’ Initial Disclosures.

To: jerry.rios@harleylawgroup.com; lewis.harley@harleylawgroup.com; bpeery@lawdcm.com; 

lstrieber@lawdcm.com; rcedillo@lawdcm.com. 

Document sent on: 12/1/2020

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Dated: December 1, 2020

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

bill@rainminnslaw.com

Counsel for Plaintiffs Melody Joy Cantu and 

Dr. Rodrigo Cantu

t

a

t

e 

B

a

r 

N

o

. 

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