On April 16, 2021 a
Answer
was filed
involving a dispute between
Evans, Aretha,
Evans, Tony, Sr.,
Perkins, Monique,
Tanksley, Faith,
Williams, Deon,
and
Choudhury , Mmarooful,
Diamond Staffing Services, Llc,
Hawthorn Suites Franchising, Inc.,
Jain , Sanjeev,
Noshahi, Mohammad Sadiq,
Tasacom Real Estate, Llc,
Tasacom Technologies Inc,
Wyndham Hotel Group, Llc,
Wyndham Hotels & Resorts, Inc.,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
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FILED
11/9/2021 12:13 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Margaret Thomas DEPUTY
CAUSE NO. DC-21-04901
TONY EVANS, SR., and ARETHA EVANS, IN THE DISTRICT COURT OF
individually and 0n behalf of their minor
son, T.E., deceased, and MONIQUE
PICKENS, individually and on behalf of
her minor son, D.W.
Plaintiffs
162““ JUDICIAL DISTRICT
VS.
TASACOM REAL ESTATE, LLC d/b/a
HAWTHORN SUITES DALLAS LOVE
FIELD, HAWTHORN SUITES
FRANCHISING, INC., WYNDHAM
HOTELS & RESORTS, INC., and
MOHAMMAD SADIQ NOSHAHI,
DALLAS COUNTY, TEXAS
Defendants
DEFENDANT HAWTHORN SUITES FRANCHISING, INC.’S ORIGINAL ANSWER
AND REQUEST FOR DISCLOSURE
Comes now HAWTHORN SUITES FRANCHISING, INC., a Defendant in the above styled
and numbered cause and makes this its Original Answer to the lawsuit above styled and numbered
and in support of which would show unto the Court the following:
I.
General Denial
Defendant denies each and every, all and singular the allegations of Plaintiffs contained in
Plaintiff’s Original Petition and any amendments and supplements thereto, demands strict proof
thereof and a Jury to determine same and the opportunity to plead further.
II.
Request for Disclosure
Pursuant to Rule 194 of the Texas Rules of Civil Procedure, Plaintiffs are requested to
disclose, within 30 days of service of this request, the information or material described in Rule
194.2, and produce such information to the undersigned counsel at the offices of Ronald D. Hinds,
14580 E. Beltwood Pkwy, Suite 110, Farmers Branch, Texas or by mail at USPO Box 113404,
Carrollton, Texas 75011.
WHEREFORE, premises considered, Defendant prays that upon final hearing and trial
hereof, Plaintiffs take nothing by their lawsuit and that Defendant be awarded all relief to which he
may be justly entitled.
Respectfully Submitted,
/s/ Ronald D. Hinds
Ronald D. Hinds
State Bar No. 09689500
USPO Box 113404
Carrollton, Texas 7501 1
(214) 549-5350
(972) 360-7550 (fax)
rdhinds@verizon.net
ATTORNEY FOR DEFENDANT
HAWTHORN SUITES FMNCHISING,
INC.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served on attorneys of
record on this the 9th day of November, 2021 via eFile.
/s/ Ronald D. Hinds
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.
Ronald Hinds
Bar No. 9689500
rdhinds@verizon.net
Envelope ID: 58991895
Status as of 11/9/2021 2:39 PM CST
Associated Case Party: TONY EVANS
Name BarN umber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 11/9/2021 12:13:29 PM SENT
Nuru Witherspoon witherspoon@twlglawyers.com 11/9/2021 12:13:29 PM SENT
Associated Case Party: T. E.
Name BarN umber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 11/9/2021 12:13:29 PM SENT
Nuru Witherspoon witherspoon@twlglawyers.com 11/9/2021 12:13:29 PM SENT
Associated Case Party: ARETHA EVANS
Name BarN umber Email TimestampSubmitted Status
Nuru Witherspoon witherspoon@twlglawyers.com 11/9/2021 12:13:29 PM SENT
Emily Taylor taylor@twlglawyers.com 11/9/2021 12:13:29 PM SENT
Case Contacts
Name
Josimayra Diaz
Luz Aguilar
Ronald DHinds
Janae Johnson
Bradley J. Purcell
Alicia Nixon
Charletta Dawson
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.
Ronald Hinds
Bar No. 9689500
rdhinds@verizon.net
Envelope ID: 58991895
Status as of 11/9/2021 2:39 PM CST
Case Contacts
Shikendra Rhea srhea@reedsmith.com 11/9/2021 12:13:29 PM SENT
Devan J. DalCol ddalcol@reedsmith.com 11/9/2021 12:13:29 PM SENT
DAWN MAY MAY@TWLGLAWYERS.COM 11/9/2021 12:13:29 PM SENT
NURU WITHERSPOON witherspoon@twlglawyers.com 11/9/2021 12:13:29 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Keith M. Aurzada Kaurzada@reedsmith.com 11/9/2021 12:13:29 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 11/9/2021 12:13:29 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 11/9/2021 12:13:29 PM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 11/9/2021 12:13:29 PM SENT
Document Filed Date
November 09, 2021
Case Filing Date
April 16, 2021
Category
OTHER PERSONAL INJURY
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FILED 11/9/2021 12:13 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Margaret Thomas DEPUTY CAUSE NO. DC-21-04901 TONY EVANS, SR., and ARETHA EVANS, IN THE DISTRICT COURT OF individually and 0n behalf of their minor son, T.E., deceased, and MONIQUE PICKENS, individually and on behalf of her minor son, D.W. Plaintiffs 162““ JUDICIAL DISTRICT VS. TASACOM REAL ESTATE, LLC d/b/a HAWTHORN SUITES DALLAS LOVE FIELD, HAWTHORN SUITES FRANCHISING, INC., WYNDHAM HOTELS & RESORTS, INC., and MOHAMMAD SADIQ NOSHAHI, DALLAS COUNTY, TEXAS Defendants DEFENDANT HAWTHORN SUITES FRANCHISING, INC.’S ORIGINAL ANSWER AND REQUEST FOR DISCLOSURE Comes now HAWTHORN SUITES FRANCHISING, INC., a Defendant in the above styled and numbered cause and makes this its Original Answer to the lawsuit above styled and numbered and in support of which would show unto the Court the following: I. General Denial Defendant denies each and every, all and singular the allegations of Plaintiffs contained in Plaintiff’s Original Petition and any amendments and supplements thereto, demands strict proof thereof and a Jury to determine same and the opportunity to plead further. II. Request for Disclosure Pursuant to Rule 194 of the Texas Rules of Civil Procedure, Plaintiffs are requested to disclose, within 30 days of service of this request, the information or material described in Rule 194.2, and produce such information to the undersigned counsel at the offices of Ronald D. Hinds, 14580 E. Beltwood Pkwy, Suite 110, Farmers Branch, Texas or by mail at USPO Box 113404, Carrollton, Texas 75011. WHEREFORE, premises considered, Defendant prays that upon final hearing and trial hereof, Plaintiffs take nothing by their lawsuit and that Defendant be awarded all relief to which he may be justly entitled. Respectfully Submitted, /s/ Ronald D. Hinds Ronald D. Hinds State Bar No. 09689500 USPO Box 113404 Carrollton, Texas 7501 1 (214) 549-5350 (972) 360-7550 (fax) rdhinds@verizon.net ATTORNEY FOR DEFENDANT HAWTHORN SUITES FMNCHISING, INC. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served on attorneys of record on this the 9th day of November, 2021 via eFile. /s/ Ronald D. Hinds 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. Ronald Hinds Bar No. 9689500 rdhinds@verizon.net Envelope ID: 58991895 Status as of 11/9/2021 2:39 PM CST Associated Case Party: TONY EVANS Name BarN umber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 11/9/2021 12:13:29 PM SENT Nuru Witherspoon witherspoon@twlglawyers.com 11/9/2021 12:13:29 PM SENT Associated Case Party: T. E. Name BarN umber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 11/9/2021 12:13:29 PM SENT Nuru Witherspoon witherspoon@twlglawyers.com 11/9/2021 12:13:29 PM SENT Associated Case Party: ARETHA EVANS Name BarN umber Email TimestampSubmitted Status Nuru Witherspoon witherspoon@twlglawyers.com 11/9/2021 12:13:29 PM SENT Emily Taylor taylor@twlglawyers.com 11/9/2021 12:13:29 PM SENT Case Contacts Name Josimayra Diaz Luz Aguilar Ronald DHinds Janae Johnson Bradley J. Purcell Alicia Nixon Charletta Dawson 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. Ronald Hinds Bar No. 9689500 rdhinds@verizon.net Envelope ID: 58991895 Status as of 11/9/2021 2:39 PM CST Case Contacts Shikendra Rhea srhea@reedsmith.com 11/9/2021 12:13:29 PM SENT Devan J. DalCol ddalcol@reedsmith.com 11/9/2021 12:13:29 PM SENT DAWN MAY MAY@TWLGLAWYERS.COM 11/9/2021 12:13:29 PM SENT NURU WITHERSPOON witherspoon@twlglawyers.com 11/9/2021 12:13:29 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Keith M. Aurzada Kaurzada@reedsmith.com 11/9/2021 12:13:29 PM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 11/9/2021 12:13:29 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 11/9/2021 12:13:29 PM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 11/9/2021 12:13:29 PM SENT