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.
Preview
FILED
8/17/2022 3:37 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 0n behalf of their minor son,
T.E., deceased, FAITH TANKSLEY 0n behalf of
minor T.E., III, Individually and on behalf 0f
His father, T.E., deceased and
DEON WILLIAMS,
Plaintiffs,
v. 162ND JUDICIAL DISTRICT
TASACOM REAL ESTATE, LLC d/b/a
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
DEFENDANT SANJEEV JAIN’S
FIRST AMENDED ANSWER, VERIFIED DENIAL AND JURY DEMAND
TO THE HONORABLE JUDGE OF SAID COURT:
SANJEEV JAIN, hereinafter referred to below as “Defendant,” in the above styled and
numbered case, files his First Amended Answer, Verified Denial and Jury Demand to Plaintifi‘s
3
Fifth Amended Original Petition and would respectfully show the Court as follows:
I
GENERAL DENIAL
Pursuant to Rule 92 of the Texas Rules of Civil Procedure, Defendant denies all and
singular, each and every material allegation contained in Plaintiffs’ Fifth Amended Original
1
11074997v1
12777.002
Petition and any subsequent petition filed by Plaintiffs and demands strict proof of the same by a
preponderance of the evidence.
II. VERIFIED DENIAL
Pursuant to Rule 93 of the Texas Rules of Civil Procedure, SanjeeV Jain asserts a verified
denial of Plaintiffs’ pleadings. Specifically, Defendant Sanjeev Jain denies that he is liable in the
capacity in which he has been sued and asserts that there is a defect in the parties. Specifically,
Sanjeev Jain is not liable in his individual capacity. The entity that owns and operates Hawthorn
Suites Dallas Love Field is Tasacom Real Estate, LLC. Plaintiffs sued Jain in his individual
capacity but Jain has no liability in his individual capacity. This is a premises liability case. The
premises of which Plaintiffs complain is owned and operated by Tasacom Real Estate, LLC. In
his individual capacity, Jain does not own, operate or control Hawthorn Suites Dallas Love Field.
As a corporate officer of Tasacom Real Estate, LLC., Jain has no liability for the alleged acts or
omissions of the business entity.
Additionally, Defendant Sanjeev Jain Individually, is an improper party as discussed in the
preceding paragraph, was also inappropriately named in the lawsuit. Plaintiffs sued Sanjeev Jain,
Individually.
III.
Pursuant to Rule 216 of the Texas Rules of Civil Procedure, Defendant hereby demands a
trial by jury and tenders the required fee.
WHEREFORE, PREMISES CONSIDERED, Defendant prays that the Plaintifis take
nothing by their suit and that Defendant has judgment for his costs.
11074997v1
12777.002
Respectfully submitted,
THOMPSON, COE, COUSH\IS & IRONS, L.L.P.
By: /s/ Tasha L. Barnes
Tasha L. Barnes
State Bar N0. 00796163
Eva M. C. DeLeon
State Bar No. 24074774
Morgan J. Wells
State Bar N0. 241065 62
701 Brazos Suite 1500
Austin, Texas 78701
Phone: (512) 708-8200
Fax: (512) 708-8777
Email: tbarnes@thompsoncoe.com
Email: edeleon(a)thompsoncoe.com
Email: mwells@thompsoncoe.com
ATTORNEYS FOR DEFENDAN TS
TASACOM REAL ESTATE, LLC D/B/A
HAWTHORN SUITES DALLAS LOVE
FIELD, MOHAMMAD SADIQ NOSHAHI,
DIAMOND STAFFING SERVICES, LLC,
TASACOM TECHNOLOGIES, INC. AND
SANJEEV JAIN
11074997v1
12777.002
VERIFICATION
STATE OF TEXAS
£03090:
COUNTY OF DALLAS
BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared
read the above Defendant‘s
Sanjeev Jain, who, alter being duly sworn, stated under oath that he has
First Amended Answer, Verified Denial & Jury D -
nd and that the factual statements contained
in Section II of Defendant’s First Amened
-
-rified Denial & Jury Demand are within his
personal knowledge and are true and corree
LI?
SUBSCRIBED AND SWORN TO BEFORE ME this the lTM day of August, 2022.
\
MM
Public in and for
Notary
The State of Texas
CHLOE E JONES
Notary ID #128564034
My umrnission Expires
-
3?: *3 h- vember 7, 2023
11074997“
12777.002
CERTIFICATE OF SERVICE
By my signature above, I hereby certify that a true and correct copy of the foregoing has been
delivered on this the 17th day of August, 2022, to the following counsel of record Via e-serVice:
Nuru Witherspoon Jason Hopkins
Emily Taylor DLA PIPER LLP (U S)
The Witherspoon Law Group, PLLC 1900 N. Pearl St., Suite 2200
5565 Deer Creek, Unit A Dallas, Texas 75201
Dallas, Texas 75228 Jason.hopkins@dlapiper.com
witherspoon@twlglawyers.com
taylor@twlglawyers.com And
ATTORNEYS FOR PLAINTIFF
Christopher B. Donovan
DLA PIPER LLP (US)
1000 Louisiana Street, Suite 2800
Houston, Texas 77002
Christopherb.donovan@dlapiper.com
ATTORNEYS FOR DEFENDANTS
HAWTHORN SUITES FRANCHISING,
INC. AND WYNDHAM HOTELS &
RESORTS, INC.
11074997v1
12777.002
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.
Lisa Villasenor on behalf of Tasha Barnes
Bar No. 00796163
LVillasenor@thompsoncoe.com
Envelope ID: 67400368
Status as of 8/17/2022 3:41 PM CST
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 8/17/2022 3:37:35 PM SENT
Morgan Wells mwells@thompsoncoe.com 8/17/2022 3:37:35 PM 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.
Lisa Villasenor on behalf of Tasha Barnes
Bar No. 00796163
LVillasenor@thompsoncoe.com
Envelope ID: 67400368
Status as of 8/17/2022 3:41 PM CST
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/17/2022 3:37:35 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/17/2022 3:37:35 PM 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.
Lisa Villasenor on behalf of Tasha Barnes
Bar No. 00796163
LVillasenor@thompsoncoe.com
Envelope ID: 67400368
Status as of 8/17/2022 3:41 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
RoseMarie Chambers rose.chambers@dlapiper.com 8/17/2022 3:37:35 PM SENT
NURU WITHERSPOON witherspoon@twlglawyers.com 8/17/2022 3:37:35 PM SENT
Sally Jones sally.jones@dlapiper.com 8/17/2022 3:37:35 PM SENT
Witherspoon Litigation |itigation@twlglawyers.com 8/17/2022 3:37:35 PM SENT
sherry M.fau|kner sherry.faulkner@us.dlapiper.com 8/17/2022 3:37:35 PM 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.
Lisa Villasenor on behalf of Tasha Barnes
Bar No. 00796163
LVillasenor@thompsoncoe.com
Envelope ID: 67400368
Status as of 8/17/2022 3:41 PM CST
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/17/2022 3:37:35 PM SENT
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/17/2022 3:37:35 PM 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.
Lisa Villasenor on behalf of Tasha Barnes
Bar No. 00796163
LVillasenor@thompsoncoe.com
Envelope ID: 67400368
Status as of 8/17/2022 3:41 PM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Nuru Witherspoon witherspoon@twlglawyers.com 8/17/2022 3:37:35 PM SENT
Emily Taylor taylor@twlglawyers.com 8/17/2022 3:37:35 PM SENT
Witherspoon Litigation litigation@twlglawyers.com 8/17/2022 3:37:35 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/17/2022 3:37:35 PM 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.
Lisa Villasenor on behalf of Tasha Barnes
Bar No. 00796163
LVillasenor@thompsoncoe.com
Envelope ID: 67400368
Status as of 8/17/2022 3:41 PM CST
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 8/17/2022 3:37:35 PM SENT
Nuru Witherspoon Witherspoon@twlglawyerscom 8/17/2022 3:37:35 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/17/2022 3:37:35 PM 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.
Lisa Villasenor on behalf of Tasha Barnes
Bar No. 00796163
LVillasenor@thompsoncoe.com
Envelope ID: 67400368
Status as of 8/17/2022 3:41 PM CST
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Nuru Witherspoon Witherspoon@Mlglawyers.com 8/17/2022 3:37:35 PM SENT
Emily Taylor taylor@twlglawyers.com 8/17/2022 3:37:35 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/17/2022 3:37:35 PM 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.
Lisa Villasenor on behalf of Tasha Barnes
Bar No. 00796163
LVillasenor@thompsoncoe.com
Envelope ID: 67400368
Status as of 8/17/2022 3:41 PM CST
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Eva DeLeon edeleon@thompsoncoe.com 8/17/2022 3:37:35 PM SENT