Preview
FILED
7/11/2022 9:24 AM
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 DEON WILLIAMS, §
§
Plaintiffs, §
§
vs. § DALLAS COUNTY, TEXAS
§
TASACOM REAL ESTATE, LLC d/b/a §
HAWTHORN SUITES DALLAS LOVE §
FIELD, HAWTHORN SUITES §
FRANCHISING, INC., WYNDHAM §
HOTELS & RESORTS, INC., §
MOHAMMAD SADIQ NOSHAHI, §
DLAMOND STAFFING SERVICES, LLC, §
WYNDHAM HOTEL GROUP, LLC, § 162““ JUDICIAL DISTRICT
TASACOM TECHNOLOGIES, INC., §
SANJEEV JAIN, and MMAROOFUL §
CHOUDHURY, §
§
§
Defendants. §
WYNDHAM HOTEL GROUP, LLC’S ORIGINAL ANSWER
Defendant Wyndham Hotel Group, LLC (“WHG”) files its Original Answer to Plaintiffs’
operative petition (including any amendments or supplements thereto) (the “Petition”), filed by
Tony Evans, Sr., and Aretha Evans, individually and on behalf of their minor son, T.E., deceased,
and Deon Williams.
GENERAL DENIAL
Pursuant to Rule 92 of the Texas Rules of Civil Procedure, WHG generally denies each
and every allegation contained in Plaintiffs’ Petition and any amendments or supplements thereto,
and WHG demands strict proof thereof. WHG further reserves the right to amend or supplement
this answer at a filture date in accordance with the Texas Rules of Civil Procedure.
II.
AFFIRMATIVE AND OTHER DEFENSES
Subject to the foregoing general denial, without admitting liability as to any of Plaintiffs’
claims, and without assuming the burden of proof on any claims, defenses, or factual issues that
would otherwise rest with Plaintiffs, WHG asserts the following defenses:
1. Plaintiffs’ claims and/or alleged damages are barred in whole or in part because the
Petition fails to state a claim upon which relief can be granted and because Plaintiff has not alleged
facts supporting the damages requested.
2. Plaintiffs’ claims and/or alleged damages are barred in whole or in part because the
proximate cause(s) of the injuries or damages alleged in the Petition, if any, was the negligence
and/or tortious conduct of persons or entities other than WHG, and therefore Plaintiffs are barred
from obtaining a recovery herein against WHG, or, alternatively, any such recovery must be
reduced in proportion to the negligence and tortious conduct of others, including all limitations set
forth in the Comparative Responsibility Act, Tex. Civ. Prac. & Rem. Code §§ 33.001, et seq., or
otherwise under applicable law. Moreover, as alleged, one or more unknown persons allegedly
committed criminal acts that caused the alleged loss or injury that is the subject of this lawsuit.
Based on Plaintiffs’ allegations, WHG would show that persons involved in the shooting alleged
in the Petition (“John Does 1-5”) are unknown criminal actors and are properly designated as
responsible third parties pursuant to Section 33.0040) of the Texas Civil Practice & Remedies
Code. John Doe 1 allegedly engaged in criminal acts giving rise to Plaintiffs’ claims. John Does
2-5 are the persons, if any, who allegedly acted in conjunction with John Doe 1 in committing
criminal acts. Plaintiffs have not identified or meaningfully described John Does 1-5, and WHG
is unaware of their identities.
3. Plaintiffs’ claims and/or alleged damages are barred in whole or in part under the
doctrines of contributory negligence, comparative responsibility, and proportionate responsibility.
4. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part because the
incident that is the subject of Plaintiffs’ Petition was not caused in fact or proximately caused by
any fault, negligence, act, omission, conduct, or breach of duty attributable to WHG.
5. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part because
WHG did not own, operate, employ persons at, or control the day-to-day operations of the
Hawthorn Suites®-branded hotel where the alleged acts giving rise to Plaintiffs’ claims took place.
6. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part because any
injuries or damages alleged by Plaintiffs were the results of intervening and superseding causes
for which WHG cannot be held liable.
7. Plaintiffs’ claims and/or alleged damages are barred in whole or in part by operation
of the assumption of risk doctrine.
8. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part due to
offset/setoff, credit, contribution, and submission of comparative responsibility as to all potentially
responsible parties pursuant to Chapters 32 and 33 of the Texas Civil Practice & Remedies Code.
9. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part to the extent
Plaintiffs received, or are entitled to receive, payments from non-parties outside the scope of the
collateral source rule.
10. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part under
Chapter 41 of the Texas Civil Practice & Remedies Code, including but not limited to Section
41.005 and Section 41.008.
11. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part in
accordance with the provisions of the applicable wrongfiil death statutes and common law.
12. Plaintiffs’ request for punitive/exemplary damages, to the extent such damages are
available, is capped by applicable rule and/or statute and is subject to reduction.
13. Plaintiffs’ request for joint and several liability is limited under Section 33.013 of
the Texas Civil Practice & Remedies Code.
14. Plaintiffs’ request for damages for medical expenses is limited under Section
41.0105 of the Texas Civil Practice & Remedies Code.
15. Plaintiffs’ claims and request for relief (including request for exemplary/punitive
damages) are barred in Whole or in part insofar as they are inconsistent with the Constitution of
the United States of America, the Constitution of the State of Texas, or other applicable law.
16. Plaintiffs’ claims are barred insofar as they lack standing to assert them.
17. Plaintiffs are not entitled to exemplary/punitive damages insofar as such relief is
inconsistent with Chapter 71 of the Texas Civil Practice & Remedies Code.
WHG reserves the right to amend and supplement its answer to add affirmative defenses
as necessary based on information obtained during investigation or discovery. In addition,
pursuant to Rule 5 8 of the Texas Rules of Civil Procedure, WHG incorporates by reference all
affirmative defenses pled or otherwise asserted in pleadings filed by other Defendants.
III.
PRAYER
WHEREFORE, WHG respectfully requests that upon trial or other final hearing of this
matter, Plaintiffs take nothing against the WHG and that the Court grant the WHG such other and
further relief to which it may be justly entitled, at law or in equity, including costs and reasonable
attorneys’ fees.
Date: July 11, 2022 Respectfully submitted,
DLA PIPER LLP (US)
/S/ Jason Hopkins
Jason Hopkins
State Bar No. 24059969
jason.hopkins@dlapiper.com
1900 N. Pearl St. Suite 2200
Dallas, Texas 75201
T: 214.743.4500
F: 214.743.4545
Christopher B. Donovan
State Bar No. 24097614
christopherb.donovan@dlapiper.com
845 Texas Avenue, Suite 3800
Houston, Texas 77002
T: 713.425.8400
F: 713.425.8401
Counsel for Defendants
Wyndham Hotels & Resorts, Ina,
Hawthorn Suites Franchising, Ina, and
Wyndham Hotel Group, LLC
CERTIFICATE OF SERVICE
I hereby certify that, on July 11, 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
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.
Sally Jones on behalf of Jason Hopkins
Bar No. 24059969
sally.jones@dlapiper.com
Envelope ID: 66175758
Status as of 7/11/2022 9:36 AM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Nuru Witherspoon witherspoon@twlglawyers.com 7/11/2022 9:24:29 AM SENT
Emily Taylor taylor@tw|glawyers.com 7/11/2022 9:24:29 AM SENT
Witherspoon Litigation litigation@twlglawyers.com 7/11/2022 9:24:29 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 7/11/2022 9:24:29 AM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 7/11/2022 9:24:29 AM SENT
Morgan Wells mwells@thompsoncoe.com 7/11/2022 9:24:29 AM SENT
Keith M. Aurzada Kaurzada@reedsmith.com 7/11/2022 9:24:29 AM SENT
Samantha Jeffers sjeffers@thompsoncoe.com 7/11/2022 9:24:29 AM SENT
Case Contacts
Name
Josimayra Diaz
Luz Aguilar
RoseMarie Chambers
NURU WITHERSPOON
Ronald DHinds
Bradley J. Purcell
Alicia Nixon
Charletta Dawson
Shikendra Rhea
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.
Sally Jones on behalf of Jason Hopkins
Bar No. 24059969
sally.jones@dlapiper.com
Envelope ID: 66175758
Status as of 7/11/2022 9:36 AM CST
Case Contacts
Devan J. DalCol ddalcol@reedsmith.com 7/11/2022 9:24:29 AM SENT
Witherspoon Litigation litigation@twlgla\wers.com 7/11/2022 9:24:29 AM SENT
Sally Jones sally.jones@dlapiper.com 7/11/2022 9:24:29 AM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/11/2022 9:24:29 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/11/2022 9:24:29 AM SENT
Ronald DHinds rdhinds@verizon.net 7/11/2022 9:24:29 AM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/11/2022 9:24:29 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/11/2022 9:24:29 AM SENT
Ronald DHinds rdhinds@verizon.net 7/11/2022 9:24:29 AM SENT
Associated Case Party: T. E.
Name BarN um ber Email TimestampSubmitted Status
Nuru Witherspoon Witherspoon@twlglawyers.com 7/11/2022 9:24:29 AM SENT
Emily Taylor taylor@twlglawyers.com 7/1 1/2022 9:24:29 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 7/11/2022 9:24:29 AM SENT
Associated Case Party: ARETHA EVANS
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.
Sally Jones on behalf of Jason Hopkins
Bar No. 24059969
sally.jones@dlapiper.com
Envelope ID: 66175758
Status as of 7/11/2022 9:36 AM CST
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Nuru Witherspoon Witherspoon@twlglawyerscom 7/11/2022 9:24:29 AM SENT
Emily Taylor taylor@twlglawyers.com 7/1 1/2022 9:24:29 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 7/11/2022 9:24:29 AM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 7/11/2022 9:24:29 AM SENT
Eva DeLeon edeleon@thompsoncoe.com 7/11/2022 9:24:29 AM SENT
Preview
FILED 7/11/2022 9:24 AM 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 DEON WILLIAMS, § § Plaintiffs, § § vs. § DALLAS COUNTY, TEXAS § TASACOM REAL ESTATE, LLC d/b/a § HAWTHORN SUITES DALLAS LOVE § FIELD, HAWTHORN SUITES § FRANCHISING, INC., WYNDHAM § HOTELS & RESORTS, INC., § MOHAMMAD SADIQ NOSHAHI, § DLAMOND STAFFING SERVICES, LLC, § WYNDHAM HOTEL GROUP, LLC, § 162““ JUDICIAL DISTRICT TASACOM TECHNOLOGIES, INC., § SANJEEV JAIN, and MMAROOFUL § CHOUDHURY, § § § Defendants. § WYNDHAM HOTEL GROUP, LLC’S ORIGINAL ANSWER Defendant Wyndham Hotel Group, LLC (“WHG”) files its Original Answer to Plaintiffs’ operative petition (including any amendments or supplements thereto) (the “Petition”), filed by Tony Evans, Sr., and Aretha Evans, individually and on behalf of their minor son, T.E., deceased, and Deon Williams. GENERAL DENIAL Pursuant to Rule 92 of the Texas Rules of Civil Procedure, WHG generally denies each and every allegation contained in Plaintiffs’ Petition and any amendments or supplements thereto, and WHG demands strict proof thereof. WHG further reserves the right to amend or supplement this answer at a filture date in accordance with the Texas Rules of Civil Procedure. II. AFFIRMATIVE AND OTHER DEFENSES Subject to the foregoing general denial, without admitting liability as to any of Plaintiffs’ claims, and without assuming the burden of proof on any claims, defenses, or factual issues that would otherwise rest with Plaintiffs, WHG asserts the following defenses: 1. Plaintiffs’ claims and/or alleged damages are barred in whole or in part because the Petition fails to state a claim upon which relief can be granted and because Plaintiff has not alleged facts supporting the damages requested. 2. Plaintiffs’ claims and/or alleged damages are barred in whole or in part because the proximate cause(s) of the injuries or damages alleged in the Petition, if any, was the negligence and/or tortious conduct of persons or entities other than WHG, and therefore Plaintiffs are barred from obtaining a recovery herein against WHG, or, alternatively, any such recovery must be reduced in proportion to the negligence and tortious conduct of others, including all limitations set forth in the Comparative Responsibility Act, Tex. Civ. Prac. & Rem. Code §§ 33.001, et seq., or otherwise under applicable law. Moreover, as alleged, one or more unknown persons allegedly committed criminal acts that caused the alleged loss or injury that is the subject of this lawsuit. Based on Plaintiffs’ allegations, WHG would show that persons involved in the shooting alleged in the Petition (“John Does 1-5”) are unknown criminal actors and are properly designated as responsible third parties pursuant to Section 33.0040) of the Texas Civil Practice & Remedies Code. John Doe 1 allegedly engaged in criminal acts giving rise to Plaintiffs’ claims. John Does 2-5 are the persons, if any, who allegedly acted in conjunction with John Doe 1 in committing criminal acts. Plaintiffs have not identified or meaningfully described John Does 1-5, and WHG is unaware of their identities. 3. Plaintiffs’ claims and/or alleged damages are barred in whole or in part under the doctrines of contributory negligence, comparative responsibility, and proportionate responsibility. 4. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part because the incident that is the subject of Plaintiffs’ Petition was not caused in fact or proximately caused by any fault, negligence, act, omission, conduct, or breach of duty attributable to WHG. 5. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part because WHG did not own, operate, employ persons at, or control the day-to-day operations of the Hawthorn Suites®-branded hotel where the alleged acts giving rise to Plaintiffs’ claims took place. 6. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part because any injuries or damages alleged by Plaintiffs were the results of intervening and superseding causes for which WHG cannot be held liable. 7. Plaintiffs’ claims and/or alleged damages are barred in whole or in part by operation of the assumption of risk doctrine. 8. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part due to offset/setoff, credit, contribution, and submission of comparative responsibility as to all potentially responsible parties pursuant to Chapters 32 and 33 of the Texas Civil Practice & Remedies Code. 9. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part to the extent Plaintiffs received, or are entitled to receive, payments from non-parties outside the scope of the collateral source rule. 10. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part under Chapter 41 of the Texas Civil Practice & Remedies Code, including but not limited to Section 41.005 and Section 41.008. 11. Plaintiffs’ claims and/or alleged damages are barred in Whole or in part in accordance with the provisions of the applicable wrongfiil death statutes and common law. 12. Plaintiffs’ request for punitive/exemplary damages, to the extent such damages are available, is capped by applicable rule and/or statute and is subject to reduction. 13. Plaintiffs’ request for joint and several liability is limited under Section 33.013 of the Texas Civil Practice & Remedies Code. 14. Plaintiffs’ request for damages for medical expenses is limited under Section 41.0105 of the Texas Civil Practice & Remedies Code. 15. Plaintiffs’ claims and request for relief (including request for exemplary/punitive damages) are barred in Whole or in part insofar as they are inconsistent with the Constitution of the United States of America, the Constitution of the State of Texas, or other applicable law. 16. Plaintiffs’ claims are barred insofar as they lack standing to assert them. 17. Plaintiffs are not entitled to exemplary/punitive damages insofar as such relief is inconsistent with Chapter 71 of the Texas Civil Practice & Remedies Code. WHG reserves the right to amend and supplement its answer to add affirmative defenses as necessary based on information obtained during investigation or discovery. In addition, pursuant to Rule 5 8 of the Texas Rules of Civil Procedure, WHG incorporates by reference all affirmative defenses pled or otherwise asserted in pleadings filed by other Defendants. III. PRAYER WHEREFORE, WHG respectfully requests that upon trial or other final hearing of this matter, Plaintiffs take nothing against the WHG and that the Court grant the WHG such other and further relief to which it may be justly entitled, at law or in equity, including costs and reasonable attorneys’ fees. Date: July 11, 2022 Respectfully submitted, DLA PIPER LLP (US) /S/ Jason Hopkins Jason Hopkins State Bar No. 24059969 jason.hopkins@dlapiper.com 1900 N. Pearl St. Suite 2200 Dallas, Texas 75201 T: 214.743.4500 F: 214.743.4545 Christopher B. Donovan State Bar No. 24097614 christopherb.donovan@dlapiper.com 845 Texas Avenue, Suite 3800 Houston, Texas 77002 T: 713.425.8400 F: 713.425.8401 Counsel for Defendants Wyndham Hotels & Resorts, Ina, Hawthorn Suites Franchising, Ina, and Wyndham Hotel Group, LLC CERTIFICATE OF SERVICE I hereby certify that, on July 11, 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 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. Sally Jones on behalf of Jason Hopkins Bar No. 24059969 sally.jones@dlapiper.com Envelope ID: 66175758 Status as of 7/11/2022 9:36 AM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Nuru Witherspoon witherspoon@twlglawyers.com 7/11/2022 9:24:29 AM SENT Emily Taylor taylor@tw|glawyers.com 7/11/2022 9:24:29 AM SENT Witherspoon Litigation litigation@twlglawyers.com 7/11/2022 9:24:29 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 7/11/2022 9:24:29 AM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 7/11/2022 9:24:29 AM SENT Morgan Wells mwells@thompsoncoe.com 7/11/2022 9:24:29 AM SENT Keith M. Aurzada Kaurzada@reedsmith.com 7/11/2022 9:24:29 AM SENT Samantha Jeffers sjeffers@thompsoncoe.com 7/11/2022 9:24:29 AM SENT Case Contacts Name Josimayra Diaz Luz Aguilar RoseMarie Chambers NURU WITHERSPOON Ronald DHinds Bradley J. Purcell Alicia Nixon Charletta Dawson Shikendra Rhea 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. Sally Jones on behalf of Jason Hopkins Bar No. 24059969 sally.jones@dlapiper.com Envelope ID: 66175758 Status as of 7/11/2022 9:36 AM CST Case Contacts Devan J. DalCol ddalcol@reedsmith.com 7/11/2022 9:24:29 AM SENT Witherspoon Litigation litigation@twlgla\wers.com 7/11/2022 9:24:29 AM SENT Sally Jones sally.jones@dlapiper.com 7/11/2022 9:24:29 AM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/11/2022 9:24:29 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/11/2022 9:24:29 AM SENT Ronald DHinds rdhinds@verizon.net 7/11/2022 9:24:29 AM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/11/2022 9:24:29 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/11/2022 9:24:29 AM SENT Ronald DHinds rdhinds@verizon.net 7/11/2022 9:24:29 AM SENT Associated Case Party: T. E. Name BarN um ber Email TimestampSubmitted Status Nuru Witherspoon Witherspoon@twlglawyers.com 7/11/2022 9:24:29 AM SENT Emily Taylor taylor@twlglawyers.com 7/1 1/2022 9:24:29 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 7/11/2022 9:24:29 AM SENT Associated Case Party: ARETHA EVANS 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. Sally Jones on behalf of Jason Hopkins Bar No. 24059969 sally.jones@dlapiper.com Envelope ID: 66175758 Status as of 7/11/2022 9:36 AM CST Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Nuru Witherspoon Witherspoon@twlglawyerscom 7/11/2022 9:24:29 AM SENT Emily Taylor taylor@twlglawyers.com 7/1 1/2022 9:24:29 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 7/11/2022 9:24:29 AM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 7/11/2022 9:24:29 AM SENT Eva DeLeon edeleon@thompsoncoe.com 7/11/2022 9:24:29 AM SENT