On April 16, 2021 a
Stipulation,Agreement
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
2/18/2022 4:08 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 on behalf of their minor son, §
T.E., deceased, and MONIQUE PICKENS, §
individually and on behalf of her minor son, §
D.W. §
§
Plaintz'flfs, § DALLAS COUNTY, TEXAS
§
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, § 162ml JUDICIAL DISTRICT
§
Defendant. §
§
AGREED MOTION FOR ENTRY OF PROTECTIVE ORDER
All parties in this case hereby file their Agreed Motion for Entry of Protective Order, and in support
states as follows:
1. Discovery in this case is likely to involve the disclosure of, at least in part, information that is
considered by the producing party to be confidential and/or proprietary.
2. For purposes of facilitating discovery, all parties have agreed to be bound by the terms of a
Confidentiality and Protective Order governing the use and disclosure of such information.
3. A proposed Protective Order is attached to this Motion. It has been approved by counsel for all
parties, and it tracks the Court’s standard order.1
Accordingly, the parties respectfully request that this Court enter the Confidentiality and Protective
Order filed contemporaneously with this Motion.
1
https://www.dallascounty.org/Assets/uploads/docs/courts/civil-district/162/Protective-Order-2019-Version.pdf
AGREED MOTION FOR ENTRY OF PROTECTIVE ORDER - Page l of 2
Dated: February 18, 2022 Respectfully submitted,
/s/ Nuru Witherspoon (with permission) /s/ Jason Hopkins
Nuru Witherspoon Jason Hopkins
State Bar No. 24039244 State Bar No. 24059969
witherspoon@tw1g1awyers.com jason.hopkins@dlapiper.com
Emily Taylor 1900 N. Pearl St. Suite 2200
State Bar N0. 24046951 Dallas, Texas 75201
taylor@twlglawyers.com Telephone: (214) 743-4500
The Witherspoon Law Group, PLLC Facsimile: (214) 743-4545
5565 Deer Creek, Unit A Christopher B. Donovan
Dallas, Texas 75228 State Bar No. 24097614
Telephone: (214) 773—1133 Christopher.b.donovan@dlapiper.com
Facsimile: (972) 696-9982 1000 Louisiana Street, Suite 2800
Houston, Texas 77002
Counsel for Plaintiffs Telephone: (713) 425-8400
Facsimile: (713) 425-8401
Counsel for Defendants
Wyndham Hotels & Resorts, Inc. and
Hawthorn Suites Franchising, Inc.
/s/ Tasha L. Barnes (with permission)
Tasha L. Barnes
State Bar No. 00796163
tbames@thompsoncoe.com
Morgan J. Wells
State Bar No. 24106562
mwells@thompsoncoe.com
Samantha C. Jeffers
State Bar No. 24120924
sj effers@thompsoncoe.com
701 Brazos, Suite 1500
Austin, Texas 78701
Telephone: (512) 708-8200
Facsimile: (512) 708—8777
Counsel for Defendants
Tasacom Real Estate, LLC and
Mohammad Sadiq Noshahi
CERTIFICATE 0F SERVICE
I hereby certify that on February 18, 2022 a true and correct copy of the foregoing document was
served on counsel of record in accordance with the Texas Rules of Civil Procedure Via the court’s
electronic filing system:
/s/ Christopher B. Donovan
Christopher B. Donovan
AGREED MOTION FOR ENTRY OF PROTECTIVE ORDER - Page 2 of 2
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.
Rose Chambers on behalf of Jason Hopkins
Bar No. 24059969
rose.chambers@dlapiper.com
Envelope ID: 61906813
Status as of 2/18/2022 4:12 PM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlg|awyers.com 2/18/2022 4:08:07 PM SENT
Nuru Witherspoon witherspoon@twlglawyers.com 2/18/2022 4:08:07 PM SENT
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@tw|g|awyers.com 2/18/2022 4:08:07 PM SENT
Nuru Witherspoon witherspoon@twlg|awyers.com 2/18/2022 4:08:07 PM SENT
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Nuru Witherspoon witherspoon@twlglawyers.com 2/18/2022 4:08:07 PM SENT
Emily Taylor taylor@twlglawyers.com 2/18/2022 4:08:07 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 2/18/2022 4:08:07 PM SENT
Morgan Wells mwells@thompsoncoe.com 2/18/2022 4:08:07 PM SENT
Keith M. Aurzada Kaurzada@reedsmith.com 2/18/2022 4:08:07 PM SENT
Samantha Jeffers sjeffers@thompsoncoe.com 2/18/2022 4:08:07 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
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.
Rose Chambers on behalf of Jason Hopkins
Bar No. 24059969
rose.chambers@dlapiper.com
Envelope ID: 61906813
Status as of 2/18/2022 4:12 PM CST
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 2/18/2022 4:08:07 PM SENT
Ronald DHinds rdhinds@verizon.net 2/18/2022 4:08:07 PM SENT
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 2/18/2022 4:08:07 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 2/18/2022 4:08:07 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 2/18/2022 4:08:07 PM SENT
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 2/18/2022 4:08:07 PM SENT
Case Contacts
Name
Josimayra Diaz
Luz Aguilar
RoseMarie Chambers
NURU WITHERSPOON
Bradley J. Purcell
Ronald DHinds
Janae Johnson
Alicia Nixon
Charletta Dawson
Shikendra Rhea
Devan J. DalCol
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.
Rose Chambers on behalf of Jason Hopkins
Bar No. 24059969
rose.chambers@dlapiper.com
Envelope ID: 61906813
Status as of 2/18/2022 4:12 PM CST
Case Contacts
DAWN MAY MAY@TWLGLAWYERS.COM 2/18/2022 4:08:07 PM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 2/18/2022 4:08:07 PM SENT
Document Filed Date
February 18, 2022
Case Filing Date
April 16, 2021
Category
OTHER PERSONAL INJURY
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED 2/18/2022 4:08 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 on behalf of their minor son, § T.E., deceased, and MONIQUE PICKENS, § individually and on behalf of her minor son, § D.W. § § Plaintz'flfs, § DALLAS COUNTY, TEXAS § 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, § 162ml JUDICIAL DISTRICT § Defendant. § § AGREED MOTION FOR ENTRY OF PROTECTIVE ORDER All parties in this case hereby file their Agreed Motion for Entry of Protective Order, and in support states as follows: 1. Discovery in this case is likely to involve the disclosure of, at least in part, information that is considered by the producing party to be confidential and/or proprietary. 2. For purposes of facilitating discovery, all parties have agreed to be bound by the terms of a Confidentiality and Protective Order governing the use and disclosure of such information. 3. A proposed Protective Order is attached to this Motion. It has been approved by counsel for all parties, and it tracks the Court’s standard order.1 Accordingly, the parties respectfully request that this Court enter the Confidentiality and Protective Order filed contemporaneously with this Motion. 1 https://www.dallascounty.org/Assets/uploads/docs/courts/civil-district/162/Protective-Order-2019-Version.pdf AGREED MOTION FOR ENTRY OF PROTECTIVE ORDER - Page l of 2 Dated: February 18, 2022 Respectfully submitted, /s/ Nuru Witherspoon (with permission) /s/ Jason Hopkins Nuru Witherspoon Jason Hopkins State Bar No. 24039244 State Bar No. 24059969 witherspoon@tw1g1awyers.com jason.hopkins@dlapiper.com Emily Taylor 1900 N. Pearl St. Suite 2200 State Bar N0. 24046951 Dallas, Texas 75201 taylor@twlglawyers.com Telephone: (214) 743-4500 The Witherspoon Law Group, PLLC Facsimile: (214) 743-4545 5565 Deer Creek, Unit A Christopher B. Donovan Dallas, Texas 75228 State Bar No. 24097614 Telephone: (214) 773—1133 Christopher.b.donovan@dlapiper.com Facsimile: (972) 696-9982 1000 Louisiana Street, Suite 2800 Houston, Texas 77002 Counsel for Plaintiffs Telephone: (713) 425-8400 Facsimile: (713) 425-8401 Counsel for Defendants Wyndham Hotels & Resorts, Inc. and Hawthorn Suites Franchising, Inc. /s/ Tasha L. Barnes (with permission) Tasha L. Barnes State Bar No. 00796163 tbames@thompsoncoe.com Morgan J. Wells State Bar No. 24106562 mwells@thompsoncoe.com Samantha C. Jeffers State Bar No. 24120924 sj effers@thompsoncoe.com 701 Brazos, Suite 1500 Austin, Texas 78701 Telephone: (512) 708-8200 Facsimile: (512) 708—8777 Counsel for Defendants Tasacom Real Estate, LLC and Mohammad Sadiq Noshahi CERTIFICATE 0F SERVICE I hereby certify that on February 18, 2022 a true and correct copy of the foregoing document was served on counsel of record in accordance with the Texas Rules of Civil Procedure Via the court’s electronic filing system: /s/ Christopher B. Donovan Christopher B. Donovan AGREED MOTION FOR ENTRY OF PROTECTIVE ORDER - Page 2 of 2 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. Rose Chambers on behalf of Jason Hopkins Bar No. 24059969 rose.chambers@dlapiper.com Envelope ID: 61906813 Status as of 2/18/2022 4:12 PM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlg|awyers.com 2/18/2022 4:08:07 PM SENT Nuru Witherspoon witherspoon@twlglawyers.com 2/18/2022 4:08:07 PM SENT Associated Case Party: T. E. Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@tw|g|awyers.com 2/18/2022 4:08:07 PM SENT Nuru Witherspoon witherspoon@twlg|awyers.com 2/18/2022 4:08:07 PM SENT Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Nuru Witherspoon witherspoon@twlglawyers.com 2/18/2022 4:08:07 PM SENT Emily Taylor taylor@twlglawyers.com 2/18/2022 4:08:07 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 2/18/2022 4:08:07 PM SENT Morgan Wells mwells@thompsoncoe.com 2/18/2022 4:08:07 PM SENT Keith M. Aurzada Kaurzada@reedsmith.com 2/18/2022 4:08:07 PM SENT Samantha Jeffers sjeffers@thompsoncoe.com 2/18/2022 4:08:07 PM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. 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. Rose Chambers on behalf of Jason Hopkins Bar No. 24059969 rose.chambers@dlapiper.com Envelope ID: 61906813 Status as of 2/18/2022 4:12 PM CST Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Jason Hopkins 24059969 jason.hopkins@dlapiper.com 2/18/2022 4:08:07 PM SENT Ronald DHinds rdhinds@verizon.net 2/18/2022 4:08:07 PM SENT Christopher BDonovan Christopher.B.Donovan@dlapiper.com 2/18/2022 4:08:07 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 2/18/2022 4:08:07 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 2/18/2022 4:08:07 PM SENT Christopher BDonovan Christopher.B.Donovan@dlapiper.com 2/18/2022 4:08:07 PM SENT Case Contacts Name Josimayra Diaz Luz Aguilar RoseMarie Chambers NURU WITHERSPOON Bradley J. Purcell Ronald DHinds Janae Johnson Alicia Nixon Charletta Dawson Shikendra Rhea Devan J. DalCol 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. Rose Chambers on behalf of Jason Hopkins Bar No. 24059969 rose.chambers@dlapiper.com Envelope ID: 61906813 Status as of 2/18/2022 4:12 PM CST Case Contacts DAWN MAY MAY@TWLGLAWYERS.COM 2/18/2022 4:08:07 PM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 2/18/2022 4:08:07 PM SENT