On April 16, 2021 a
Party Notice
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.
Preview
FILED
11/17/2021 3:55 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
individually and on behalf of their minor son, )
T.E., deceased, and MONIQUE PICKENS, )
individually and on behalf of her minor son, )
D.W. )
)
Plaintiffs, ) 162nd JUDICIAL DISTRICT
)
V. )
)
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. )
To: Custodian of Records
Dallas Police Department
1400 Botham Jean Blvd
Dallas, Texas 75215
PLEASE TAKE NOTICE that you are required to produce the following items by 3:00 p.m., on
December 15, 2021, at The Witherspoon Law Group, 5565 Deer Creek, Unit A, Dallas, Texas
75228 to TaWana Stegall or any other representative at that location or via email to Emily Taylor
at tavlor@twlglawvers.com.
This Notice is being served in connection with the above-styled lawsuit, involving the shooting
death of Tony Evans Jr. on April 11, 2021, at Tasacom Real Estate d/b/a Hawthorn Suites Dallas
Love Field located at 7900 Brookriver Drive, Dallas, Texas 75347.
Documents to Produce
1. The Police Report associated with the above-described shooting of Tony Evans Jr.
on April 11, 2021, at Tasacom Real Estate d/b/a Hawthorn Suites Dallas Love Field located at
7900 Brookriver Drive, Dallas, Texas 75347.
2. The complete police investigation file of the shooting described above, including
but not limited to, all witness statements, recorded Video, including body camera and dash camera
footage, photos, and all police narrative reports for the incident that is in the possession, custody,
or control of the Dallas Police Department.
NOTICE - Page 1 of 3
3. A11 reports of violent crime, including murder, manslaughter, rape, robbery, assault,
sexual assault, and aggravated assault, occurring within a one-mile radius of Tasacom Real Estate
d/b/a Hawthorn Suites Dallas Love Field located at 7900 Brookriver Drive, Dallas, Texas 75347
for the three years prior to April 11, 2021; and
4. All reports of crime occurring on the premises of Tasacom Real Estate d/b/a
Hawthorn Suites Dallas Love Field located at 7900 Brookriver Drive, Dallas, Texas 75 347 for the
five years prior to April 11, 2021.
This Notice is being provided pursuant to Texas Rules of Civil Procedure 205.2 and 205.3.
Respectfully submitted,
WITHERSPOON LAW GROUP
/s/ Emily Taylor
Nuru Witherspoon
State Bar No. 24039244
Emily Taylor
Texas Bar No. 24046951
5565 Deer Creek, Unit A
Dallas, Texas 75228
214-773-1133 — Telephone
972-696-9982 — Fax
taylor@twlglawyers.com
witherspoon@twlglawyers.com
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
The undersigned certifies that on the 17th day of November 2021, a true and correct copy
of the foregoing document was served via Rule 21a to all attorneys of record in this lawsuit.
Emily Taylor
/s/
Emily Taylor
NOTICE - Page 2 of 3
MEMORANDUM OF ACCEPTANCE
I accepted service of a copy of this notice on [date].
Signature on behalf of Arlington Police Dept.
Printed Name
RETURN
I certify that I served the annexed notice by delivering a copy, in person, at 620 W. Division
St, Arlington, Texas 76011 on [date].
Signature
Printed Name
Company/Title
NOTICE - Page 3 of 3
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.
Emily Taylor on behalf of Emily Taylor
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 59264111
Status as of 11/18/2021 7:59 AM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 11/17/2021 3:55:03 PM SENT
Nuru Witherspoon witherspoon@twlglawyers.com 11/17/2021 3:55:03 PM SENT
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 11/17/2021 3:55:03 PM SENT
Nuru Witherspoon witherspoon@twlglawyers.com 11/17/2021 3:55:03 PM SENT
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Nuru Witherspoon witherspoon@twlglawyers.com 11/17/2021 3:55:03 PM SENT
Emily Taylor taylor@twlglawyers.com 11/17/2021 3:55:03 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.
Emily Taylor on behalf of Emily Taylor
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 59264111
Status as of 11/18/2021 7:59 AM CST
Case Contacts
Shikendra Rhea srhea@reedsmith.com 11/17/2021 3:55:03 PM SENT
Devan J. DalCol ddalcol@reedsmith.com 11/17/2021 3:55:03 PM SENT
DAWN MAY MAY@TWLGLAWYERS.COM 11/17/2021 3:55:03 PM SENT
NURU WITHERSPOON witherspoon@twlglawyers.com 11/17/2021 3:55:03 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Keith M. Aurzada Kaurzada@reedsmith.com 11/17/2021 3:55:03 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 11/17/2021 3:55:03 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 11/17/2021 3:55:03 PM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 11/17/2021 3:55:03 PM SENT
Preview
FILED 11/17/2021 3:55 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 individually and on behalf of their minor son, ) T.E., deceased, and MONIQUE PICKENS, ) individually and on behalf of her minor son, ) D.W. ) ) Plaintiffs, ) 162nd JUDICIAL DISTRICT ) V. ) ) 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. ) To: Custodian of Records Dallas Police Department 1400 Botham Jean Blvd Dallas, Texas 75215 PLEASE TAKE NOTICE that you are required to produce the following items by 3:00 p.m., on December 15, 2021, at The Witherspoon Law Group, 5565 Deer Creek, Unit A, Dallas, Texas 75228 to TaWana Stegall or any other representative at that location or via email to Emily Taylor at tavlor@twlglawvers.com. This Notice is being served in connection with the above-styled lawsuit, involving the shooting death of Tony Evans Jr. on April 11, 2021, at Tasacom Real Estate d/b/a Hawthorn Suites Dallas Love Field located at 7900 Brookriver Drive, Dallas, Texas 75347. Documents to Produce 1. The Police Report associated with the above-described shooting of Tony Evans Jr. on April 11, 2021, at Tasacom Real Estate d/b/a Hawthorn Suites Dallas Love Field located at 7900 Brookriver Drive, Dallas, Texas 75347. 2. The complete police investigation file of the shooting described above, including but not limited to, all witness statements, recorded Video, including body camera and dash camera footage, photos, and all police narrative reports for the incident that is in the possession, custody, or control of the Dallas Police Department. NOTICE - Page 1 of 3 3. A11 reports of violent crime, including murder, manslaughter, rape, robbery, assault, sexual assault, and aggravated assault, occurring within a one-mile radius of Tasacom Real Estate d/b/a Hawthorn Suites Dallas Love Field located at 7900 Brookriver Drive, Dallas, Texas 75347 for the three years prior to April 11, 2021; and 4. All reports of crime occurring on the premises of Tasacom Real Estate d/b/a Hawthorn Suites Dallas Love Field located at 7900 Brookriver Drive, Dallas, Texas 75 347 for the five years prior to April 11, 2021. This Notice is being provided pursuant to Texas Rules of Civil Procedure 205.2 and 205.3. Respectfully submitted, WITHERSPOON LAW GROUP /s/ Emily Taylor Nuru Witherspoon State Bar No. 24039244 Emily Taylor Texas Bar No. 24046951 5565 Deer Creek, Unit A Dallas, Texas 75228 214-773-1133 — Telephone 972-696-9982 — Fax taylor@twlglawyers.com witherspoon@twlglawyers.com ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE The undersigned certifies that on the 17th day of November 2021, a true and correct copy of the foregoing document was served via Rule 21a to all attorneys of record in this lawsuit. Emily Taylor /s/ Emily Taylor NOTICE - Page 2 of 3 MEMORANDUM OF ACCEPTANCE I accepted service of a copy of this notice on [date]. Signature on behalf of Arlington Police Dept. Printed Name RETURN I certify that I served the annexed notice by delivering a copy, in person, at 620 W. Division St, Arlington, Texas 76011 on [date]. Signature Printed Name Company/Title NOTICE - Page 3 of 3 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. Emily Taylor on behalf of Emily Taylor Bar No. 24046951 taylor@twlglawyers.com Envelope ID: 59264111 Status as of 11/18/2021 7:59 AM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 11/17/2021 3:55:03 PM SENT Nuru Witherspoon witherspoon@twlglawyers.com 11/17/2021 3:55:03 PM SENT Associated Case Party: T. E. Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 11/17/2021 3:55:03 PM SENT Nuru Witherspoon witherspoon@twlglawyers.com 11/17/2021 3:55:03 PM SENT Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Nuru Witherspoon witherspoon@twlglawyers.com 11/17/2021 3:55:03 PM SENT Emily Taylor taylor@twlglawyers.com 11/17/2021 3:55:03 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. Emily Taylor on behalf of Emily Taylor Bar No. 24046951 taylor@twlglawyers.com Envelope ID: 59264111 Status as of 11/18/2021 7:59 AM CST Case Contacts Shikendra Rhea srhea@reedsmith.com 11/17/2021 3:55:03 PM SENT Devan J. DalCol ddalcol@reedsmith.com 11/17/2021 3:55:03 PM SENT DAWN MAY MAY@TWLGLAWYERS.COM 11/17/2021 3:55:03 PM SENT NURU WITHERSPOON witherspoon@twlglawyers.com 11/17/2021 3:55:03 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Keith M. Aurzada Kaurzada@reedsmith.com 11/17/2021 3:55:03 PM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 11/17/2021 3:55:03 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 11/17/2021 3:55:03 PM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 11/17/2021 3:55:03 PM SENT