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  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
  • TONY EVANS, Sr., et al  vs. TASACOM REAL ESTATE, LLC, et alOTHER PERSONAL INJURY document preview
						
                                

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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