Motion for Leave in TONY EVANS, Sr., et al vs. TASACOM REAL ESTATE, LLC, et al| Trellis.Law

On April 16, 2021 a Motion,Ex Parte 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
7/27/2022 8:48 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
individually and on behalf of their minor son, )
T.E., deceased, FAITH TAN KSLEY on behalf of )
minor T.E., III, individually and on behalf of )
his father, T.E., deceased, and DEON WILLIAMS, )
)
Plaintiffs, )
)
V.
3
TASACOM REAL ESTATE, LLC d/b/a ) l62nd JUDICIAL DISTRICT
HAWTHORN SUITES DALLAS LOVE FIELD, )
HAWTHORN SUITES FRANCHISING, INC., )
WYNDHAM HOTELS & RESORTS, INC., )
MOHAMMAD SADIQ NOSHAHI, )
DIAMOND STAFFING SERVICES, LLC, )
WYNDHAM HOTEL GROUP, LLC, )
TASACOM TECHNOLOGIES, INC., SANJEEV )
JAIN and MMAROOFUL CHOUDHURY, )
)
Defendants. ) DALLAS COUNTY, TEXAS
PLAINTIFFS’ RESPONSE TO DEFENDANTS TASACOM REAL ESTATE, LLC
D/B/A HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ
NOSHAHI, AND DIAMOND STAFFING SERVICES, LLC’S
MOTION FOR LEAVE T0 FILE THIRD-PARTY PETITION

Plaintiffs Tony Evans, Sr. and Aretha Evans, individually and on behalf of their minor son,

T.E., deceased, Faith Tanksley on behalf of minor T.E., III, individually and on behalf of his father,

T.E., deceased, and Deon Williams (collectively “Plaintiffs”) ﬁle their Response to Defendants

Tasacom Real Estate, LLC d/b/a Hawthorn Suites Dallas Love Field, Mohammad Sadiq Noshahi

and Diamond Stafﬁng Services, LLC’s (collectively “Defendants”) Motion for Leave to File

Third-Party Petition, as follows:

I. INTRODUCTION

Defendants’ current Motion is Wholly unnecessary and is a blatant attempt to muddy the

waters at trial and prejudice the jury by confusing the salient and complex legal issues they face in

PLAINTIFFS' RESPONSE TO DEFENDANTS TASACOM REAL ESTATE, LLC D/B/A Page 1 of 8
HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ NOSHAHI, AND DIAMOND
STAFFING SERVICES,LLC'S MOTION FOR LEAVE TO FILE THIRD-PARTY PETITION
this litigation. Defendants attempt to claim that the alleged shooter, Keyshawn Hanis (“Harris”),

is a necessary party to this negligence, premises liability matter simply because he could ultimately

be liable to them for contribution. The shooter has no interest in this case and is not indispensable

to these proceedings. Defendants are liable herein based on their own conduct independent of the

shooter’s identity — in the absence of Defendants’ conduct, the shooting would not have occurred.

Any purported contribution claim would also follow and is dependent ﬁrst on a ﬁnding of liability

against Defendants. Defendants requested relief to join the unconVicted, ostensible shooter that

caused the death and personal injuries alleged in this case would essentially permit Defendants to

maintain a separate, sidetracked litigation within the current litigation that will certainly prejudice

Plaintiffs. Any purported contribution claim can be brought separately once liability against

Defendants is decided. 1

II. ARGUMENTS AND AUTHORITIES

A. TEX. R. CIV. P. 38 DOES NOT MANDATE J OINDER FOR CONTRIBUTION CLAIMS

At the outset, neither TEX. R. CIV. P. 38, nor Chapter 33 of the Texas Civil Practice and

Remedies Code, mandate joinder of contribution claims, especially given the circumstances herein

that are fully explained below. See, also, infra, § II.B-C. The plan language of Rule 38(a) provides

permissive language, only:

a defending party, as a third-party plaintiff, may cause a citation and petition to be
served upon a person not a party to the action who is or may be liable to him . . .
for all or part of the plaintiff s claim against him.

1
Should the Court permit joinder of alleged shooter Keyshawn Harris, Plaintiffs will promptly ﬁle a Motion for
Severance and/or for Separate Trials based on the prejudice of j oining him to the current lawsuit. A claim is severable
if 1) the controversy involves more than one cause of action; 2) the severed claim would be property subject of a
lawsuit if asserted independently; and 3) the claim is not so interwoven with remaining claims that two trial will
involves the same facts and legal issues. In re State, 355 S.W.3d 611 (Tex. 2011); Guaranty Federal v. Horseshoe
Operating, 793 S.W.Zd 652, 658 (Tex. 1990). See, also, infra, at Il.B.
PLAINTIFFS’ RESPONSE TO DEFENDANTS TASACOM REAL ESTATE, LLC D/B/A Page 2 of 8
HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ NOSHAHI, AND DIAMOND
STAFFING SERVICES,LLC'S MOTION FOR LEAVE TO FILE THIRD-PARTY PETITION
(emphasis added). Likewise, TEX. CIV. PRAC. & REM. CODE § 33.016(b) provides:

Each liable defendant is entitled to contribution form each person who is not a
settling person and who is liable to the claimant for a percentage of responsibility
but from whom the claimant seeks no relief at the time of submission. A party may
assert this contribution right against any such person as a contribution defendant in
the claimant’s action.

(emphasis added).

Nothing in the controlling rules of statutes states that a contribution claim must or shall be

brought in the pending action, and use of “may” indicates that contribution claims are permitted

post-judgment against a joint tortfeasor. In re Martin, 147 S.W.3d 453, 459 (Tex. App.--Beaumont

2004, pet. struck) (“We see nothing in the applicable provisions of Chapter 33 requiring that a

contribution claim be asserted in the primary lawsuit, or precluding a post-judgment contribution

claim against a joint tort-feasor who was not a party to the primary lawsuit”); Pacesetter Pools,

Inc. v. Pierce Homes, Inc., 86 S.W.3d 827 (Tex. App.--Austin, 2002, no pet.) (holding that a

defendant could seek contribution after being held liable in an arbitration proceeding). In light of

Plaintiffs’ arguments below, joinder of the contribution claim sought herein, should not be

permitted. See, infra, § II.B-C.

B. PRACTICAL CONSIDERATIONS RESOLVE AGAINST PERMISSIVE JOINDER —
DELAY,
PREJUDICE, CONFUSION 0F THE ISSUES

Joinder rests on the concept of judicial efﬁciency and the policy of providing full and

adequate relief to the parties. In re Martin, 147 S.W.3d at 457. A trial court’s decision on joinder
should be based on practical considerations regarding What is fair and orderly. Id. Defendants

herein are seeking a trial within a trial that would be wholly prejudicial and risk confusion of the

issues by the jury in the current litigation that does not turn on any resolution of contribution by

Harris. See, e.g., Security State Bank v. Commercial Standard Title Ins. C0,, 605 S.W.2d 673, 675

PLAINTIFFS' RESPONSE TO DEFENDANTS TASACOM REAL ESTATE, LLC D/B/A Page 3 of 8
HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ NOSHAHI, AND DIAMOND
STAFFING SERVICES,LLC'S MOTION FOR LEAVE TO FILE THIRD-PARTY PETITION
(Tex.App.—Dallas 1980, no pet.) (explaining one limitation on joinder is that parties cannot be

added to prejudice the rights of those who have already commenced the litigation).

Plaintiffs’ claims in this lawsuit sound in negligence and gross negligence, including

premises liability, deceptive trade practice Violations, conspiracy, and misrepresentation, against

multiple hotel owners and/or operators, in addition to their individual and entity alter egos. See,

generally, Pls.’ 5th Am. Pet. Plaintiffs have additional claims against a security company who

provided inept security on the hotel premises. Id., 111151-53, 104. Given the nature of the business

relationships of the parties, including a franchisee hotel and its four potential alter egos, as well as

a franchisor, with two afﬁliated companies, all with interrelated control over the safety and security

of the hotel premises, this is already a complex lawsuit consisting of four plaintiffs and nine

defendants. See, generally, Pls.’ 5th Am. Pet. The existing claims will require the jury to parse

through multiple corporate entanglements and overlapping issues regarding control, management,

ﬁnances, and corporate and/or company governance. See, e. g., id., 111121-36, 121-146.

Given this complexity, the addition of a non-essential claim of contribution risks

unnecessary delay and substantial prejudice to Plaintiffs, as well as potential for confusing the

jury. For their contribution claim, Defendants will be required to prove the outcome of the pending

criminal lawsuit, i.e., that Harris pulled the trigger, intentionally causing Decedent’s death and the

personal injuries alleged herein. This will certainly cause unnecessary delay, as Defendants have

offered no evidence to suggest the criminal trial is soon approaching. Any evidence from Harris

will certainly be objected to on Fifth Amendment grounds, further delaying the current suit.

Defendants have known since June 16, 2021, that Harris was indicted for the shooting, yet they

waited a year to seek adding him to the case. Defs.’ Motion, Ex. A. Their current Motion is a

blatant delay tactic.

PLAINTIFFS' RESPONSE TO DEFENDANTS TASACOM REAL ESTATE, LLC D/B/A Page 4 of 8
HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ NOSHAHI, AND DIAMOND
STAFFING SERVICES,LLC'S MOTION FOR LEAVE TO FILE THIRD-PARTY PETITION
No party to this lawsuit disputes that a shooting occurred that caused the death of Decedent

and personal injuries to Plaintiff Williams, the only evidence related to Harris that is needed for

Plaintiffs’ lawsuit —
proving his identity is unnecessary. The addition of essentially a separate

lawsuit to prove that Harris was the shooter will prejudice Plaintiffs and confuse the jury. The

identity of the shooter is immaterial to the existing negligence-based claims. The separate

contribution claim against Harris risks signiﬁcant confusion of the issues, as the jury could

reasonably believe that the identity of the shooter is germane to Plaintiffs’ claims, that Defendants

are absolved of liability if Harris is indeed found to the be shooter, or, vice versa, that if Harris is

not found to be the shooter that Defendants are absolved of liability.

Moreover, instructions to the jury assigning liability for any potential negligence on the

part of the intentional tortfeaser the shooter is prejudicial, confusing to the jury, and misleading
— —

because the shooter, unlike Defendants, did not owe Plaintiffs a similar duty. Compare Greater

Houston Transp. C0. v. Phillips, 801 S.W.2d 523, 525 (Tex. 1990) (elements of negligence) with

Schrader v. Tex. Dep't 0f Pub. Safety, No. ll-20-00145-CV, 2022 Tex. App. LEXIS 3861

(Tex.App.—Eastland 2022, no pet.) (elements of battery). The elements of negligence and those

of any intentional tort, on the other hand, are inconsistent and mutually exclusive a intent to

conduct a wrongful act is not material to negligence. See, e. g., Fulmer v. Rider, 635 S.W.2d 875,

883 (Tex.App.—Tyler 1982, writ ref’d n.r.e.). This lawsuit derives from the hotel premises owners

and operators’ negligent failure to maintain the safety and security of the premises and their public

misrepresentations that the premises was safe for their invitees, like Decedent and Plaintiff

Williams. Defendants’ contingent contribution claims should not be joined to this lawsuit.

PLAINTIFFS' RESPONSE TO DEFENDANTS TASACOM REAL ESTATE, LLC D/B/A Page 5 of 8
HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ NOSHAHI, AND DIAMOND
STAFFING SERVICES,LLC'S MOTION FOR LEAVE TO FILE THIRD-PARTY PETITION
C. TEX. R. CIV. P. 39 DOES NOT SUPPORT COMPULSORY JOINDER

Defendants assert that alleged shooter is a necessary or indispensable party to this

litigation. As the moving party, Defendants have the burden to show that Harris is, in fact, a

necessary party under TEX. R. CIV. P. 39 — he is not, and Defendants make no evidentiary showing

that he is. In re Occidental W. Tex. Overthrust, Inc., 626 S.W.3d 395, 400 (Tex.App.—El Paso

2021, no pet). Rule 39 only requires joinder of a person who “claims an interest relating to the

subject of the action” and in their absence, a party would be subjected to a “substantial risk of

incurring double, multiple, or otherwise inconsistent obligations by reason of [the absent person’s]

claimed interest.” Crawford v. XTO Energy, Ina, 509 S.W.3d 906, 913 (Tex. 2017) (internal

quotations omitted). See, also, Fisher v. Fisher, 05-19-01422-CV, 2021 Tex. App. LEXIS 4705,

*5 (TeX.App.—Dallas June 14, 2021, no pet). “Rule 39 does not require joinder of persons who

potentially could claim an interest in the subject of the action; it requires joinder, in certain

circumstances, of persons who actually claim such an interest.” Crawford, 509 S.W.3d at 913.

Harris neither claims an interest in the current action, nor is there risk of incurring

duplicative or inconsistent obligations if he is not added as a party. The claims alleged against

Defendants are wholly independent of their purported contribution claim against Harris.

Defendants have not carried their burden, through objective “record evidence” to show that Harris

has an “actual, claimed interest” in the subject matter of this litigation because they cannot do so.

In re Occidental, 626 S.W.3d at 401 (citing Crawford, 509 S.W.3d at 913). Any liability against

Harris for contribution cannot be established until after liability against the current defendants is

determined, thus no contribution claim may even be necessary. See, e. g., Ingersoll—Rand Co. v.

Valera Energy Corp., 997 S.W.2d 203, 208, 42 Tex. Sup. Ct. J. 818 (Tex. 1999). See, also, In re

Martin, 147 S.W.3d at 459; Pacesetter Pools, Inc. 86 S.W.3d at 827. Joinder pursuant to Rule 39

PLAINTIFFS' RESPONSE TO DEFENDANTS TASACOM REAL ESTATE, LLC D/B/A Page 6 of 8
HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ NOSHAHI, AND DIAMOND
STAFFING SERVICES,LLC'S MOTION FOR LEAVE TO FILE THIRD-PARTY PETITION
is not a necessity, the contribution claim can be asserted separately, and Defendants’ Motion must

be denied.

III. CONCLUSION

Defendants have not sustained their burden of proof to require joinder of Harris for a third-

party defendant contribution claim. Harris is not a necessary party to this litigation; indeed,

Defendants contribution claim is contingent ﬁrst upon liability being found in the current suit. He

also has no claimed interest in this lawsuit, thus there is no risk of duplicity or inconsistent

judgments. Moreover, Defendants dilatory tactic and/or desire to confuse the issues in this lawsuit

should not be permitted, as Plaintiffs would be prejudiced. Plaintiffs ask that Defendants’ Motion

be denied and for any further or additional relief this Court deems warranted.

Respectfully Submitted,

/s/ Nuru Witherspoon /s/ Aubrey “Nick” Pittman
NURU WITHERSPOON AUBREY “NICK” PITTMAN
State Bar No. 24039244 State Bar No. 16049750
witherspoon@twlglawyers.com
THE PITTMAN LAW FIRM, P.C.
EMILY TAYLOR 100 Crescent Court, Suite 700
State Bar No_ 24046951 Dallas, Texas 75201-2112
tay10r@twlg1awyers_com 214-459-3454 — Telephone
214-853-5912 - Fax
WITHERSPOON LAW GROUP pittman@thepittmanlawﬁrm.com
5565 Deer Creek, Unit A
Dallas, Texas 75228
214-773-1133 — Telephone
972-696-9982 — Fax

PLAINTIFFS' RESPONSE TO DEFENDANTS TASACOM REAL ESTATE, LLC D/B/A Page 7 of 8
HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ NOSHAHI, AND DIAMOND
STAFFING SERVICES,LLC'S MOTION FOR LEAVE TO FILE THIRD-PARTY PETITION
CERTIFICATE OF SERVICE
I hereby certify that on July 27, 2022, the foregoing document was submitted to the
representatives of the parties, using the electronic case filing system of the court. The electronic
case ﬁling system sent a “Notice of Service” to all attorneys of record who have consented in
writing to accept this Notice as service of documents by electronic means.

/s/ Nuru Witherspoon
NURU WITHERSPOON

PLAINTIFFS' RESPONSE TO DEFENDANTS TASACOM REAL ESTATE, LLC D/B/A Page 8 of 8
HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ NOSHAHI, AND DIAMOND
STAFFING SERVICES,LLC'S MOTION FOR LEAVE TO FILE THIRD-PARTY PETITION
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
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 66703925
Status as of 7/27/2022 8:56 AM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Aubrey "Nick" Pittman pittman@thepittmanlawﬁrm.com 7/27/2022 8:48:24 AM SENT
Emily Taylor taylor@twlglawyers.com 7/27/2022 8:48:24 AM SENT
Witherspoon Litigation litigation@twlglawyers.com 7/27/2022 8:48:24 AM SENT
Nuru Witherspoon witherspoon@twlglawyers.com 7/27/2022 8:48:24 AM SENT
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
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 66703925
Status as of 7/27/2022 8:56 AM CST
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Aubrey "Nick" Pittman pittman@thepittmanlawﬁrm.com 7/27/2022 8:48:24 AM SENT
Emily Taylor taylor@twlglawyers.com 7/27/2022 8:48:24 AM SENT
Nuru Witherspoon Witherspoon@twlglawyers.c0m 7/27/2022 8:48:24 AM SENT
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
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 66703925
Status as of 7/27/2022 8:56 AM CST
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 7/27/2022 8:48:24 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawﬁrm.com 7/27/2022 8:48:24 AM SENT
Nuru Witherspoon Witherspoon@twlglawyers.com 7/27/2022 8:48:24 AM SENT
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
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 66703925
Status as of 7/27/2022 8:56 AM CST
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 7/27/2022 8:48:24 AM SENT
Morgan Wells mwells@thompsoncoe.com 7/27/2022 8:48:24 AM SENT
Keith M. Aurzada Kaurzada@reedsmith.com 7/27/2022 8:48:24 AM SENT
Samantha Jeffers sjeffers@thompsoncoe.com 7/27/2022 8:48:24 AM SENT
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
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 66703925
Status as of 7/27/2022 8:56 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Josimayra Diaz josi.diaz@dallascityhall.com 7/27/2022 8:48:24 AM SENT
Luz Aguilar luz.aguilar@dallascityhall.com 7/27/2022 8:48:24 AM SENT
RoseMarie Chambers rose.chambers@dIapiper.com 7/27/2022 8:48:24 AM SENT
NURU WITHERSPOON witherspoon@twlg|awyers.com 7/27/2022 8:48:24 AM SENT
Bradley J. Purcell bpurcell@reedsmith.com 7/27/2022 8:48:24 AM SENT
Alicia Nixon anixon@reedsmith.com 7/27/2022 8:48:24 AM SENT
Ronald DHinds rdhinds@verizon.net 7/27/2022 8:48:24 AM SENT
Charletta Dawson cdawson@reedsmith.com 7/27/2022 8:48:24 AM SENT
Shikendra Rhea srhea@reedsmith.com 7/27/2022 8:48:24 AM SENT
Devan J. DalCol ddalcol@reedsmith.com 7/27/2022 8:48:24 AM SENT
Sally Jones sally.jones@dlapiper.com 7/27/2022 8:48:24 AM SENT
Witherspoon Litigation litigation@twlglawyers.com 7/27/2022 8:48:24 AM SENT
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
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 66703925
Status as of 7/27/2022 8:56 AM CST
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/27/2022 8:48:24 AM SENT
Ronald DHinds rdhinds@verizon.net 7/27/2022 8:48:24 AM SENT
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/27/2022 8:48:24 AM SENT
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
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 66703925
Status as of 7/27/2022 8:56 AM CST
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/27/2022 8:48:24 AM SENT
Ronald DHinds rdhinds@verizon.net 7/27/2022 8:48:24 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/27/2022 8:48:24 AM SENT
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
Bar No. 24046951
taylor@twlglawyers.com
Envelope ID: 66703925
Status as of 7/27/2022 8:56 AM CST
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Eva DeLeon edeleon@thompsoncoe.com 7/27/2022 8:48:24 AM SENT
Ronald DHinds rdhinds@verizon.net 7/27/2022 8:48:24 AM SENT

Case Info

Judge

WYSOCKI, ASHLEY Track Judge’s New Case

Case No.

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Document Filed Date

July 27, 2022

Case Filing Date

April 16, 2021

County

Parties

AURZADA, KEITH M Attorney for the Defendant
BARNES, TASHA L Attorney for the Defendant
CHOUDHURY , MMAROOFUL Defendant
DIAMOND STAFFING SERVICES, LLC Defendant
DONOVAN, CHRISTOPHER BRYAN Attorney for the Defendant
EVANS, ARETHA Plaintiff
EVANS, TONY, Sr. Plaintiff
HAWTHORN SUITES FRANCHISING, INC. Defendant
HINDS, RONALD D Attorney for the Defendant
HOPKINS, JASON M. Attorney for the Defendant
JAIN , SANJEEV Defendant
JEFFERS, SAMANTHA C Attorney for the Defendant
MILES, ANDREA Attorney for the Plaintiff
MURGOR, EVE Attorney for the Defendant
NOSHAHI, MOHAMMAD SADIQ Defendant
PERKINS, MONIQUE Plaintiff
TANKSLEY, FAITH Plaintiff
TASACOM REAL ESTATE, LLC Defendant
TASACOM TECHNOLOGIES INC Defendant
WELLS, MORGAN J Attorney for the Defendant
WILLIAMS, DEON Plaintiff
WITHERSPOON, NURU Attorney for the Plaintiff
WYNDHAM HOTEL GROUP, LLC Defendant
WYNDHAM HOTELS & RESORTS, INC. Defendant
Josimayra Diaz Attorneys for Defendants
Emily Taylor Attorney
Aubrey Pittman Attorney
Devan Dal Col Attorneys for Defendants
Eva DeLeon Attorneys for Defendants
Lisa Blue Attorney
Taylor Reed Attorney
Bradley Purcell Attorney
Benjamin Dunn Attorney
Tasha Barnes Attorney
Parker Dunn Attorney
David Saag Attorney

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Motion,Ex Parte: TONY EVANS, Sr., et al vs. TASACOM REAL ESTATE, LLC, et al

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