Preview
FILED
4/5/2022 11:07 AM
FELICIA PITRE
1 ClT/ESERVE DISTRICT CLERK
DALLAS 00., TEXAS
Alicia Mata DEPUTY
CAUSE NO. DC-21-18263
ROBYN LANGLEY, IN THE DISTRICT COURT
§§§§§§§§§§§
Plaintiff,
v. 193m JUDICIAL DISTRICT
NEWCRESTIMAGE HOLDINGS, LLC,
and NEWCRESTMAGE MANAGEMENT,
LLC d/b/a AC HOTEL DOWNTOWN
DALLAS, and THOMAS PROTECTION
GROUP, LLC
Defendants. DALLAS COUNTY, TEXAS
PLAINTIFF’S SECOND AMENDED PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Robyn Langley, (hereinafter referred to as “P1aintiff’), who files this
Plaintiffs Original Petition against Newcrestimage Holdings, LLC and Newcrestimage
Management, LLC D/B/A AC Hotel Downtown Dallas and Thomas Protection Group, LLC
(hereinafter referred to as “Defendants”), and respectfully shows this Court as follows:
I. DISCOVERYCONTROL PLAN AND RELIEF SOUGHT
Plaintiff intends to conduct discovery under Level 2 of the Texas Rules of Civil Procedure
190.4. Plaintiff seeks monetary relief over $1,000,000.00 pursuant to Tex. R. Civ. P. 47(c)(4).
II. PARTIES AND SERVICE
Plaintiff is a resident of Palm Beach County, Florida.
Defendant Newcrestimage Holdings, LLC, D/B/A AC Hotel Downtown Dallas,
(hereinafter referred to as “AC Hotel”) is a company doing business in Texas. Defendant may be
served by serving its registered agent, Mehul Patel, located at 700 State Highway 121 Bypass,
Suite 175, Lewisville, TX 75067. Defendant has appeared herein.
PLAINTIFF’S SECOND AMENDED PETITION
Page 1 of 8
Defendant Newcrestimage Management, LLC D/B/A AC Hotel Downtown Dallas,
(hereinafter referred to as “AC Hotel”) is a company doing business in Texas. Defendant may be
served by serving its counsel of record Defendant has appeared herein.
Defendant Thomas Protection Group, LLC (hereinafter referred to as “TPG”) is a
company doing business in Texas. Defendant may be served by serving its registered agent,
United States Corporation Agents, Inc. located at 9900 Spectrum Dr., Austin, Texas 78717.
ISSUANCE OF CITATION IS REQUESTED.
III. MISNOMER/ALTER EGO
In the event any parties are misnamed or not included herein, it is Plaintiff’s contention
that such was a "misidentification", "misnomer" and/or such parties are/were "alter egos" of
the parties named herein. Alternatively, Plaintiff contends that such “corporate veils” should be
pierced to hold such parties properly included in the interest of justice.
IV. JURISDICTION
This Court has jurisdiction as Plaintiff‘s damages exceed the minimum jurisdictional
limits of this Court. Plaintiff is seeking damages in excess of $1,000.000.00.
V. VENUE
Venue is proper in Dallas County, Texas, pursuant to 15.002(a)(1) of the Texas Civil
Practice and Remedies Code, because the facts that give rise to the causes of action occurred in
Dallas County, Texas.
VI. FACTS
1. On or about February 17, 2021, Defendants owned, leased, possessed, operated, maintained
or managed a property located at located at 1712 Commerce Street Dallas, Texas 75201
(the "Property") under the trade or assumed name AC Hotel Dallas Downtown.
PLAINTIFF’S SECOND AMENDED PETITION
Page 2 of 8
2. At all times hereinafter mentioned, Defendants possessed, operated, maintained, managed
and controlled or had a duty to possess, operate, manage or control, both directly or
indirectly through its agents, servants, contractors and/or employees, the Property. In the
course of its said operation of the Property, Defendants invited Plaintiff as a guest to enter
the Property.
3. On February 17, 2021, Defendant TPG was providing security services to the Premises.
4. On February 17, 2021, Plaintiff was a hotel guest at AC Hotel Dallas Downtown in room
1006. During the pendency of the evening, Plaintiff saw and heard a party occurring in
hotel room 1001 and out in the hallway. Plaintiff made a complaint to hotel employees
about the loud music and yelling, yet nothing was done. At 3:00 a.m., Plaintiff opened the
door to her hotel room and saw people coming in and out of room 1001 and roaming in the
hallways. Plaintiff politely asked if the hotel guests could turn their music down. In
response to the request, an unknown hotel guest walked towards Plaintiff, entered her
room, and punched Plaintiff in the face two times.
5. Hotel employee and night auditor Monique Barker was sleeping in the room next door to
Plaintiff in room 1002 due to the winter storm that took over Dallas in February of 2021.
It is further believed that the same guests were partying at the hotel at least two nights
before Plaintiff’s incident. Plaintiff was told that the hotel security/hotel employees along
with TPG had come up asking the hotel guests to be quiet, but the guests did not cease the
loud music and partying, and hotel security/hotel employees along with TPG failed to do
anything further to stop the conduct.
6. Following this incident, Plaintiff was rushed to the hospital where she was told that she
needed a laceration repair of her upper lip. In addition to her lip laceration, Plaintiff was
PLAINTIFF’S SECOND AMENDED PETITION
Page 3 of 8
diagnosed with a contusion of the face and unspecific injury of the head. Plaintiff currently
suffers from the physical and mental injuries she sustained.
VII. NEGLIGENCE, GROSS NEGLIGENCE, NEGLIGENT
UNDERTAKING, NEGLIGENT ACTIVITY, AND
PREMISE LIABILITY
l. Despite the knowledge of the unruly hotel guests and complete foreseeability of impending
violent crime, Defendants and TPG failed to keep Plaintiff reasonably safe from harm.
Defendants and TPG did nothing to prevent nor deter criminal activity on the premises.
2. Defendants and TPG had a duty to exercise ordinary care While operating the Hotel and
providing security services to patrons of the Hotel. Furthermore, Defendants and TPG had
a duty to the Plaintiff, as an invitee, to keep its premises reasonably safe and to warn against
or remedy any unreasonably dangerous condition it knew or should have known about, or
that was foreseeable.
3. The conduct of Defendants and TPG was the proximate cause and/or one of the proximate
causes of Plaintiff’ s injuries and damages in that Defendants and TPG’s acts and/or
omissions constituted negligence, gross negligence, negligence per se and/or malice in the
following acts of negligence, to wit:
a. Failed to employ adequate and/or competent security, patrols, procedures,
equipment, personnel or other reasonable measures;
b. Failed to properly instruct AC Hotel by Marriot’s personnel in any of the foregoing
safety and protective measures and/or how to properly and adequately warn invitees
of the risks associated with being on the premises;
c. Failed to properly train AC Hotel by Marriot’s personnel in any of the foregoing
safety and protective measures and/or how to properly and adequately warn invitees
of the risks associated with being on the premises;
PLAINTIFF’S SECOND AMENDED PETITION
Page 4 of 8
Failed to stop loud music, excessive drinking, and partying when employees knew
or should have known that the patrons were intoxicated, and danger would arise;
Failed to warn of the danger which had been created due to the environment on the
premises;
Failed to install security cameras designed to act as a deterrent of criminal activity
or to prevent criminal assaults;
Failure of its employees to monitor the criminal activity on the property and in the
surrounding vicinity of the property, which posed a danger to persons lawfully on
the premises;
TPG failed to train and/or supervise its security officers to prevent incidents such
as what happened to Plaintiff;
TPG negligently hired, trained, and supervised its security personnel;
TPG failed to have security officers that were licensed to handle situations like the
one that involved Plaintiff; and
. Defendants and TPG failed to take action as a whole to prevent the incident
involving Plaintiff.
4. Defendants and TPG are liable for the criminal acts of third parties, when the acts were
foreseeable. Based on the reported behavior of the unruly drunk hotel guests, it was
foreseeable that something like this would occur, and that other hotel guests would get
injured as a result of their behavior. Defendants and TPG were fully aware of the
complaints made about the behavior of these hotel guests yet continued its negligent
operations.
5. Defendants and TPG are liable under the doctrine of respondeat superior for the acts and
PLAINTIFF’S SECOND AMENDED PETITION
Page 5 of 8
omissions of their respective agents, servants, employees, and statutory employees and
agents. Defendants and TPG’s employees and agents committed various acts and/or
omissions during the course and scope of employment, which proximately caused the
Plaintiff s injuries.
6. Defendants and TPG’s conduct as described above constituted gross negligence in that
(l) Defendants and TPG’s acts or omissions, when viewed objectively from the standpoint
of Defendants and TPG at the time of its occurrence, involved an extreme degree of risk,
considering the probability and magnitude of the potential harm to others; and (2)
Defendants and TPG had actual, subjective awareness of the risk involved, but
nevertheless proceeded with conscious indifference to the rights, safety, and welfare of
others, including Plaintiff. Therefore, Plaintiff is entitled to, and seeks, exemplary damages
in this action under Sections 41.001 et seq. of the Texas Civil Practice & Remedies Code.
VIII. DAMAGES
1. As a result of the above-referenced wrongful conduct of Defendants and TPG, Plaintiff
suffered serious injuries to various parts of her body.
2. As a result of the injuries Plaintiff sustained, Plaintiff incurred reasonable and necessary
doctors' and medical expenses for her necessary medical care and attention in excess of the
jurisdictional limits of this court. There is also a reasonable probability Plaintiff will incur
additional expenses for necessary medical and related health care in the future in an amount
unknown at this time.
3. In addition, Plaintiff suffered severe physical and mental pain, suffering and anguish,
disfigurement, and in all reasonable probability, will continue to suffer in this manner well
into the future, if not for the balance of her life
PLAINTIFF’S SECOND AMENDED PETITION
Page 6 of 8
4. As a proximate result of the negligence of Defendants and TPG, Plaintiff suffered injuries
to her body in general. Defendants and TPG’s negligence diminished Plaintiff’ s past
earning capacity and ability to administer to her own needs. In all probability, Plaintiff s
ability to attend to customary household duties and earning capacity will continue to be so
impaired well into the fiiture, if not for the balance of her natural life.
5. Plaintiff therefore brings suit for the following damages:
a. Past and future medical expenses;
b. Past and future physical pain;
c. Past and future mental anguish;
d. Past and future physical impairment;
e. Past and future lost earning capacity;
f. Past and future physical disfigurement; and
g. Exemplary damages
1X. RULE 193.7 SELF-AUTHENTICATION
1. Plaintiff hereby provides notice to all Defendants that any documents produced in
response to written discovery will be authenticated for use in any pre-trial proceeding
or at trial.
X. PRAYER
WHEREFORE, Plaintiff will respectfully request that all Defendants be cited to appear
and answer, and that on final trial, Plaintiff be awarded judgment against all Defendants for the
following:
a. Actual medical bills for Plaintiff, which are necessary and reasonable for these
types of services in Dallas County, Texas; and for future medical attention in
PLAINTIFF’S SECOND AMENDED PETITION
Page 7 of 8
amounts unknown at this time;
b. Monetary damages Plaintiff for past physical pain and suffering and mental
anguish found to be reasonable and just by the trier of fact;
c. Monetary damages for Plaintiff for future physical pain and suffering and
mental anguish as found to be reasonable and just by the trier of fact;
d. Physical and wage impairment as determined by the trier of fact;
e. Pre and post judgment interest at the maximum legal rate;
f. Cost of Court; and
g. For such other and further relief, at law or in equity, to which Plaintiff will be
justly entitled.
Respectfully Submitted,
Wolf Law, PLLC
r
By:
Julie f [uguk
Texas Bar No. 24051542
julie@wolflawpllc.com
12222 Merit Dr., Suite 1200
Dallas Texas 75251
Tel. (972) 338-4477
Fax. (972) 338-5044
Attorneys for Plaintiff
PLAINTIFF’S SECOND AMENDED PETITION
Page 8 of 8
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Julie Wolf on behalf of Julie Wolf
Bar No. 24051542
julie@wolflawpllc.com
Envelope ID: 63267293
Status as of 4/1 1/2022 11:02 AM CST
Associated Case Party: ROBYN LANGLEY
Name BarNumber Email TimestampSubmitted Status
Wolf Law PLLC service@wo|flawpllc.com 4/5/2022 11:07:48 AM SENT
JULIE FWOLF julie@wolflawpllc.com 4/5/2022 11:07:48 AM ERROR
Associated Case Party: NEWCRESTIMAGE MANAGEMENT, LLC D/B/A AC HOTEL
DOWNTOWN DALLAS
Name BarNumber Email TimestampSubmitted Status
Christine YDuperroir cduperroir@bbarr.com 4/5/2022 11:07:48 AM SENT
Melanie Baker mbaker@bbarr.com 4/5/2022 11:07:48 AM SENT
Autumn Herron aherron@bbarr.com 4/5/2022 11:07:48 AM SENT
Preview
FILED 4/5/2022 11:07 AM FELICIA PITRE 1 ClT/ESERVE DISTRICT CLERK DALLAS 00., TEXAS Alicia Mata DEPUTY CAUSE NO. DC-21-18263 ROBYN LANGLEY, IN THE DISTRICT COURT §§§§§§§§§§§ Plaintiff, v. 193m JUDICIAL DISTRICT NEWCRESTIMAGE HOLDINGS, LLC, and NEWCRESTMAGE MANAGEMENT, LLC d/b/a AC HOTEL DOWNTOWN DALLAS, and THOMAS PROTECTION GROUP, LLC Defendants. DALLAS COUNTY, TEXAS PLAINTIFF’S SECOND AMENDED PETITION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Robyn Langley, (hereinafter referred to as “P1aintiff’), who files this Plaintiffs Original Petition against Newcrestimage Holdings, LLC and Newcrestimage Management, LLC D/B/A AC Hotel Downtown Dallas and Thomas Protection Group, LLC (hereinafter referred to as “Defendants”), and respectfully shows this Court as follows: I. DISCOVERYCONTROL PLAN AND RELIEF SOUGHT Plaintiff intends to conduct discovery under Level 2 of the Texas Rules of Civil Procedure 190.4. Plaintiff seeks monetary relief over $1,000,000.00 pursuant to Tex. R. Civ. P. 47(c)(4). II. PARTIES AND SERVICE Plaintiff is a resident of Palm Beach County, Florida. Defendant Newcrestimage Holdings, LLC, D/B/A AC Hotel Downtown Dallas, (hereinafter referred to as “AC Hotel”) is a company doing business in Texas. Defendant may be served by serving its registered agent, Mehul Patel, located at 700 State Highway 121 Bypass, Suite 175, Lewisville, TX 75067. Defendant has appeared herein. PLAINTIFF’S SECOND AMENDED PETITION Page 1 of 8 Defendant Newcrestimage Management, LLC D/B/A AC Hotel Downtown Dallas, (hereinafter referred to as “AC Hotel”) is a company doing business in Texas. Defendant may be served by serving its counsel of record Defendant has appeared herein. Defendant Thomas Protection Group, LLC (hereinafter referred to as “TPG”) is a company doing business in Texas. Defendant may be served by serving its registered agent, United States Corporation Agents, Inc. located at 9900 Spectrum Dr., Austin, Texas 78717. ISSUANCE OF CITATION IS REQUESTED. III. MISNOMER/ALTER EGO In the event any parties are misnamed or not included herein, it is Plaintiff’s contention that such was a "misidentification", "misnomer" and/or such parties are/were "alter egos" of the parties named herein. Alternatively, Plaintiff contends that such “corporate veils” should be pierced to hold such parties properly included in the interest of justice. IV. JURISDICTION This Court has jurisdiction as Plaintiff‘s damages exceed the minimum jurisdictional limits of this Court. Plaintiff is seeking damages in excess of $1,000.000.00. V. VENUE Venue is proper in Dallas County, Texas, pursuant to 15.002(a)(1) of the Texas Civil Practice and Remedies Code, because the facts that give rise to the causes of action occurred in Dallas County, Texas. VI. FACTS 1. On or about February 17, 2021, Defendants owned, leased, possessed, operated, maintained or managed a property located at located at 1712 Commerce Street Dallas, Texas 75201 (the "Property") under the trade or assumed name AC Hotel Dallas Downtown. PLAINTIFF’S SECOND AMENDED PETITION Page 2 of 8 2. At all times hereinafter mentioned, Defendants possessed, operated, maintained, managed and controlled or had a duty to possess, operate, manage or control, both directly or indirectly through its agents, servants, contractors and/or employees, the Property. In the course of its said operation of the Property, Defendants invited Plaintiff as a guest to enter the Property. 3. On February 17, 2021, Defendant TPG was providing security services to the Premises. 4. On February 17, 2021, Plaintiff was a hotel guest at AC Hotel Dallas Downtown in room 1006. During the pendency of the evening, Plaintiff saw and heard a party occurring in hotel room 1001 and out in the hallway. Plaintiff made a complaint to hotel employees about the loud music and yelling, yet nothing was done. At 3:00 a.m., Plaintiff opened the door to her hotel room and saw people coming in and out of room 1001 and roaming in the hallways. Plaintiff politely asked if the hotel guests could turn their music down. In response to the request, an unknown hotel guest walked towards Plaintiff, entered her room, and punched Plaintiff in the face two times. 5. Hotel employee and night auditor Monique Barker was sleeping in the room next door to Plaintiff in room 1002 due to the winter storm that took over Dallas in February of 2021. It is further believed that the same guests were partying at the hotel at least two nights before Plaintiff’s incident. Plaintiff was told that the hotel security/hotel employees along with TPG had come up asking the hotel guests to be quiet, but the guests did not cease the loud music and partying, and hotel security/hotel employees along with TPG failed to do anything further to stop the conduct. 6. Following this incident, Plaintiff was rushed to the hospital where she was told that she needed a laceration repair of her upper lip. In addition to her lip laceration, Plaintiff was PLAINTIFF’S SECOND AMENDED PETITION Page 3 of 8 diagnosed with a contusion of the face and unspecific injury of the head. Plaintiff currently suffers from the physical and mental injuries she sustained. VII. NEGLIGENCE, GROSS NEGLIGENCE, NEGLIGENT UNDERTAKING, NEGLIGENT ACTIVITY, AND PREMISE LIABILITY l. Despite the knowledge of the unruly hotel guests and complete foreseeability of impending violent crime, Defendants and TPG failed to keep Plaintiff reasonably safe from harm. Defendants and TPG did nothing to prevent nor deter criminal activity on the premises. 2. Defendants and TPG had a duty to exercise ordinary care While operating the Hotel and providing security services to patrons of the Hotel. Furthermore, Defendants and TPG had a duty to the Plaintiff, as an invitee, to keep its premises reasonably safe and to warn against or remedy any unreasonably dangerous condition it knew or should have known about, or that was foreseeable. 3. The conduct of Defendants and TPG was the proximate cause and/or one of the proximate causes of Plaintiff’ s injuries and damages in that Defendants and TPG’s acts and/or omissions constituted negligence, gross negligence, negligence per se and/or malice in the following acts of negligence, to wit: a. Failed to employ adequate and/or competent security, patrols, procedures, equipment, personnel or other reasonable measures; b. Failed to properly instruct AC Hotel by Marriot’s personnel in any of the foregoing safety and protective measures and/or how to properly and adequately warn invitees of the risks associated with being on the premises; c. Failed to properly train AC Hotel by Marriot’s personnel in any of the foregoing safety and protective measures and/or how to properly and adequately warn invitees of the risks associated with being on the premises; PLAINTIFF’S SECOND AMENDED PETITION Page 4 of 8 Failed to stop loud music, excessive drinking, and partying when employees knew or should have known that the patrons were intoxicated, and danger would arise; Failed to warn of the danger which had been created due to the environment on the premises; Failed to install security cameras designed to act as a deterrent of criminal activity or to prevent criminal assaults; Failure of its employees to monitor the criminal activity on the property and in the surrounding vicinity of the property, which posed a danger to persons lawfully on the premises; TPG failed to train and/or supervise its security officers to prevent incidents such as what happened to Plaintiff; TPG negligently hired, trained, and supervised its security personnel; TPG failed to have security officers that were licensed to handle situations like the one that involved Plaintiff; and . Defendants and TPG failed to take action as a whole to prevent the incident involving Plaintiff. 4. Defendants and TPG are liable for the criminal acts of third parties, when the acts were foreseeable. Based on the reported behavior of the unruly drunk hotel guests, it was foreseeable that something like this would occur, and that other hotel guests would get injured as a result of their behavior. Defendants and TPG were fully aware of the complaints made about the behavior of these hotel guests yet continued its negligent operations. 5. Defendants and TPG are liable under the doctrine of respondeat superior for the acts and PLAINTIFF’S SECOND AMENDED PETITION Page 5 of 8 omissions of their respective agents, servants, employees, and statutory employees and agents. Defendants and TPG’s employees and agents committed various acts and/or omissions during the course and scope of employment, which proximately caused the Plaintiff s injuries. 6. Defendants and TPG’s conduct as described above constituted gross negligence in that (l) Defendants and TPG’s acts or omissions, when viewed objectively from the standpoint of Defendants and TPG at the time of its occurrence, involved an extreme degree of risk, considering the probability and magnitude of the potential harm to others; and (2) Defendants and TPG had actual, subjective awareness of the risk involved, but nevertheless proceeded with conscious indifference to the rights, safety, and welfare of others, including Plaintiff. Therefore, Plaintiff is entitled to, and seeks, exemplary damages in this action under Sections 41.001 et seq. of the Texas Civil Practice & Remedies Code. VIII. DAMAGES 1. As a result of the above-referenced wrongful conduct of Defendants and TPG, Plaintiff suffered serious injuries to various parts of her body. 2. As a result of the injuries Plaintiff sustained, Plaintiff incurred reasonable and necessary doctors' and medical expenses for her necessary medical care and attention in excess of the jurisdictional limits of this court. There is also a reasonable probability Plaintiff will incur additional expenses for necessary medical and related health care in the future in an amount unknown at this time. 3. In addition, Plaintiff suffered severe physical and mental pain, suffering and anguish, disfigurement, and in all reasonable probability, will continue to suffer in this manner well into the future, if not for the balance of her life PLAINTIFF’S SECOND AMENDED PETITION Page 6 of 8 4. As a proximate result of the negligence of Defendants and TPG, Plaintiff suffered injuries to her body in general. Defendants and TPG’s negligence diminished Plaintiff’ s past earning capacity and ability to administer to her own needs. In all probability, Plaintiff s ability to attend to customary household duties and earning capacity will continue to be so impaired well into the fiiture, if not for the balance of her natural life. 5. Plaintiff therefore brings suit for the following damages: a. Past and future medical expenses; b. Past and future physical pain; c. Past and future mental anguish; d. Past and future physical impairment; e. Past and future lost earning capacity; f. Past and future physical disfigurement; and g. Exemplary damages 1X. RULE 193.7 SELF-AUTHENTICATION 1. Plaintiff hereby provides notice to all Defendants that any documents produced in response to written discovery will be authenticated for use in any pre-trial proceeding or at trial. X. PRAYER WHEREFORE, Plaintiff will respectfully request that all Defendants be cited to appear and answer, and that on final trial, Plaintiff be awarded judgment against all Defendants for the following: a. Actual medical bills for Plaintiff, which are necessary and reasonable for these types of services in Dallas County, Texas; and for future medical attention in PLAINTIFF’S SECOND AMENDED PETITION Page 7 of 8 amounts unknown at this time; b. Monetary damages Plaintiff for past physical pain and suffering and mental anguish found to be reasonable and just by the trier of fact; c. Monetary damages for Plaintiff for future physical pain and suffering and mental anguish as found to be reasonable and just by the trier of fact; d. Physical and wage impairment as determined by the trier of fact; e. Pre and post judgment interest at the maximum legal rate; f. Cost of Court; and g. For such other and further relief, at law or in equity, to which Plaintiff will be justly entitled. Respectfully Submitted, Wolf Law, PLLC r By: Julie f [uguk Texas Bar No. 24051542 julie@wolflawpllc.com 12222 Merit Dr., Suite 1200 Dallas Texas 75251 Tel. (972) 338-4477 Fax. (972) 338-5044 Attorneys for Plaintiff PLAINTIFF’S SECOND AMENDED PETITION Page 8 of 8 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Julie Wolf on behalf of Julie Wolf Bar No. 24051542 julie@wolflawpllc.com Envelope ID: 63267293 Status as of 4/1 1/2022 11:02 AM CST Associated Case Party: ROBYN LANGLEY Name BarNumber Email TimestampSubmitted Status Wolf Law PLLC service@wo|flawpllc.com 4/5/2022 11:07:48 AM SENT JULIE FWOLF julie@wolflawpllc.com 4/5/2022 11:07:48 AM ERROR Associated Case Party: NEWCRESTIMAGE MANAGEMENT, LLC D/B/A AC HOTEL DOWNTOWN DALLAS Name BarNumber Email TimestampSubmitted Status Christine YDuperroir cduperroir@bbarr.com 4/5/2022 11:07:48 AM SENT Melanie Baker mbaker@bbarr.com 4/5/2022 11:07:48 AM SENT Autumn Herron aherron@bbarr.com 4/5/2022 11:07:48 AM SENT