On April 16, 2021 a
Party Discovery
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
10/26/2022 1:30 PM
FELICIA PITRE
DISTRICT CLERK
NAFIZ HOUSSAIN S CO., TEXAS
AUQUSt DEPUTY
TONY EVANS, SR. vs TASACOM REAL ESTATE 3aér§éfi$omas
CAUSE NO. DC-21—O490l
TONY EVANS, SR., and ) IN THE DISTRICT COURT OF
ARETHA EVANS, )
individually and on )
behalf of their minor )
son, T.E., deceased, and )
DEON WILLIAMS, )
)
Plaintiffs, )
)
VS. ) 162nd JUDICIAL DISTRICT
)
TASACOM REAL ESTATE, LLC )
d/b/a HAWTHORN SUITES )
DALLAS LOVE FIELD, )
HAWTHORN SUITES )
FRANCHISING, INC., )
lO WYNDHAM HOTELS & RESORTS, )
INC., MOHAMMAD SADIQ )
ll NOSHAHI, and DIAMOND ) DALLAS COUNTY, TEXAS
STAFFING SERVICES, LLC, )
12 Defendants. )
l3
REPORTER'S CERTIFICATION
l4 DEPOSITION OF NAFIZ HOUSSAIN
August 30, 2022
15 (REPORTED REMOTELY)
l6 I, RENE MULHOLLAND, Certified Shorthand Reporter in
l7 and for the State of Texas, hereby certify tO the
l8 following:
l9 That the witness, NAFIZ HOUSSAIN, was duly sworn by
20 the officer and that the transcript of the oral
21 deposition is a true record of the testimony given by
22 the witness;
23 That the deposition transcript was submitted on
24 943 , 2022, to the witness or to the
25 attorney for the witness for examination, signature,
Q ESQUIRE 800.21 1 .DEPO (3376)
EsquireSolutions. com
NAFIZ HOUSSAIN August 30, 2022
TONY EVANS, SR. vs TASACOM REAL ESTATE 1 18
and return to me by 1040 , 2022;
That the amount of time used by each party at the
deposition is as follows:
Mr. Nick Pittman 2 HOURS, 55 MINUTES
That pursuant to information given to the
deposition officer at the time said testimony was
taken, the following includes all parties of record:
Mr. Aubrey "Nick" Pittman, Attorney for Plaintiffs
Ms. Emily Taylor, Attorney for Plaintiffs
lO Ms. Tasha Barnes, Attorney for Tasacom Defendants
ll Ms. Jason Hopkins, Attorney for Wyndham Defendants
12 I further certify that I am neither counsel for,
l3 related to, nor employed by any of the parties or
l4 attorneys in the action in which this proceeding was
15 taken, and further that I am not financially or
l6 otherwise interested in the outcome of the action.
l7 Further certification requirements pursuant to
l8 Rule 203 of TRCP will be certified to after they have
l9 occurred.
20 Certified to by me this flday of Sept , 2022.
21 12H. mimic mum,
22 _signature_
RENE MULHOLLAND, TCRR, CSR NO. 6050
23 Expiration Date: October 31, 2022
Esquire Deposition Solutions
24 Firm Registration No. 286
1700 Pacific Avenue, Suite lOOO
25 Dallas, Texas 75204
Q ESQUIRE 800.21 1 .DEPO (3376)
EsquireSqutions. com
NAFIZ HOUSSAIN August 30, 2022
TONY EVANS, SR. vs TASACOM REAL ESTATE 1 19
FURTHER CERTIFICATION UNDER RULE 203 TRCP
The original deposition was/was not returned to the
10-10-22
deposition officer on , 2022;
If returned, the attached Changes and Signature
page contains any changes and reasons therefor;
If returned, the original deposition was delivered
to PMnwn,AuMey"NmK' , Custodial Attorney;
That $1§ZZBO is the deposition officer's
charges to the PLAINTIFF for preparing the original
lO deposition transcript and any copies of exhibits;
ll That the deposition was delivered in accordance
12 with Rule 203.3, and that a copy of this certificate
l3 was served on all parties shown herein on
l4 10-23 , 2022, and filed with the Clerk.
Certified this Od-
15 to by me gig day of
l6 2022.
l7 Q tummy mam/gob
l8 _signature_
RENE MULHOLLAND, TCRR, CSR NO. 6050
l9 Expiration Date: October 31, 2022
Esquire Deposition Solutions
20 Firm Registration No. 286
1700 Pacific Avenue, Suite lOOO
21 Dallas, Texas 75204
22
23
24
25
Q ESQUIRE 800.21 1 .DEPO (3376)
EsquireSqutions. com
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.
Envelope ID: 69591157
Status as of 10/26/2022 2:55 PM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/26/2022 1:30:03 PM SENT
Emily Taylor taylor@twlglawyers.com 10/26/2022 1:30:03 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 10/26/2022 1:30:03 PM SENT
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/26/2022 1:30:03 PM SENT
Emily Taylor taylor@twlglawyers.com 10/26/2022 1:30:03 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 10/26/2022 1:30:03 PM SENT
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/26/2022 1:30:03 PM SENT
Emily Taylor taylor@twlglawyers.com 10/26/2022 1:30:03 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 10/26/2022 1:30:03 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Josimayra Diaz josi.diaz@dallascityhall.com 10/26/2022 1:30:03 PM SENT
Luz Aguilar luz.aguilar@dallascityhall.com 10/26/2022 1:30:03 PM SENT
RoseMarie Chambers rose.chambers@dlapiper.com 10/26/2022 1:30:03 PM SENT
NURU WITHERSPOON witherspoon@twlglawyers.com 10/26/2022 1:30:03 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.
Envelope ID: 69591157
Status as of 10/26/2022 2:55 PM CST
Case Contacts
Sally Jones sally.jones@dlapiper.com 10/26/2022 1:30:03 PM SENT
Ronald DHinds rdhinds@verizon.net 10/26/2022 1:30:03 PM SENT
sherry M.faulkner sherry.faulkner@us.dlapiper.com 10/26/2022 1:30:03 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 10/26/2022 1:30:03 PM SENT
Morgan Wells mwells@thompsoncoe.com 10/26/2022 1:30:03 PM SENT
LISA V IvilIasenor@thompsoncoe.com 10/26/2022 1:30:03 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 10/26/2022 1:30:03 PM SENT
Ronald DHinds rdhinds@verizon.net 10/26/2022 1:30:03 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 10/26/2022 1:30:03 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 10/26/2022 1:30:03 PM SENT
Ronald DHinds rdhinds@verizon.net 10/26/2022 1:30:03 PM SENT
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 10/26/2022 1:30:03 PM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
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.
Envelope ID: 69591157
Status as of 10/26/2022 2:55 PM CST
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Eva DeLeon edeleon@thompsoncoe.com 10/26/2022 1:30:03 PM SENT
Ronald DHinds rdhinds@verizon.net 10/26/2022 1:30:03 PM SENT
Preview
FILED 10/26/2022 1:30 PM FELICIA PITRE DISTRICT CLERK NAFIZ HOUSSAIN S CO., TEXAS AUQUSt DEPUTY TONY EVANS, SR. vs TASACOM REAL ESTATE 3aér§éfi$omas CAUSE NO. DC-21—O490l TONY EVANS, SR., and ) IN THE DISTRICT COURT OF ARETHA EVANS, ) individually and on ) behalf of their minor ) son, T.E., deceased, and ) DEON WILLIAMS, ) ) Plaintiffs, ) ) VS. ) 162nd JUDICIAL DISTRICT ) TASACOM REAL ESTATE, LLC ) d/b/a HAWTHORN SUITES ) DALLAS LOVE FIELD, ) HAWTHORN SUITES ) FRANCHISING, INC., ) lO WYNDHAM HOTELS & RESORTS, ) INC., MOHAMMAD SADIQ ) ll NOSHAHI, and DIAMOND ) DALLAS COUNTY, TEXAS STAFFING SERVICES, LLC, ) 12 Defendants. ) l3 REPORTER'S CERTIFICATION l4 DEPOSITION OF NAFIZ HOUSSAIN August 30, 2022 15 (REPORTED REMOTELY) l6 I, RENE MULHOLLAND, Certified Shorthand Reporter in l7 and for the State of Texas, hereby certify tO the l8 following: l9 That the witness, NAFIZ HOUSSAIN, was duly sworn by 20 the officer and that the transcript of the oral 21 deposition is a true record of the testimony given by 22 the witness; 23 That the deposition transcript was submitted on 24 943 , 2022, to the witness or to the 25 attorney for the witness for examination, signature, Q ESQUIRE 800.21 1 .DEPO (3376) EsquireSolutions. com NAFIZ HOUSSAIN August 30, 2022 TONY EVANS, SR. vs TASACOM REAL ESTATE 1 18 and return to me by 1040 , 2022; That the amount of time used by each party at the deposition is as follows: Mr. Nick Pittman 2 HOURS, 55 MINUTES That pursuant to information given to the deposition officer at the time said testimony was taken, the following includes all parties of record: Mr. Aubrey "Nick" Pittman, Attorney for Plaintiffs Ms. Emily Taylor, Attorney for Plaintiffs lO Ms. Tasha Barnes, Attorney for Tasacom Defendants ll Ms. Jason Hopkins, Attorney for Wyndham Defendants 12 I further certify that I am neither counsel for, l3 related to, nor employed by any of the parties or l4 attorneys in the action in which this proceeding was 15 taken, and further that I am not financially or l6 otherwise interested in the outcome of the action. l7 Further certification requirements pursuant to l8 Rule 203 of TRCP will be certified to after they have l9 occurred. 20 Certified to by me this flday of Sept , 2022. 21 12H. mimic mum, 22 _signature_ RENE MULHOLLAND, TCRR, CSR NO. 6050 23 Expiration Date: October 31, 2022 Esquire Deposition Solutions 24 Firm Registration No. 286 1700 Pacific Avenue, Suite lOOO 25 Dallas, Texas 75204 Q ESQUIRE 800.21 1 .DEPO (3376) EsquireSqutions. com NAFIZ HOUSSAIN August 30, 2022 TONY EVANS, SR. vs TASACOM REAL ESTATE 1 19 FURTHER CERTIFICATION UNDER RULE 203 TRCP The original deposition was/was not returned to the 10-10-22 deposition officer on , 2022; If returned, the attached Changes and Signature page contains any changes and reasons therefor; If returned, the original deposition was delivered to PMnwn,AuMey"NmK' , Custodial Attorney; That $1§ZZBO is the deposition officer's charges to the PLAINTIFF for preparing the original lO deposition transcript and any copies of exhibits; ll That the deposition was delivered in accordance 12 with Rule 203.3, and that a copy of this certificate l3 was served on all parties shown herein on l4 10-23 , 2022, and filed with the Clerk. Certified this Od- 15 to by me gig day of l6 2022. l7 Q tummy mam/gob l8 _signature_ RENE MULHOLLAND, TCRR, CSR NO. 6050 l9 Expiration Date: October 31, 2022 Esquire Deposition Solutions 20 Firm Registration No. 286 1700 Pacific Avenue, Suite lOOO 21 Dallas, Texas 75204 22 23 24 25 Q ESQUIRE 800.21 1 .DEPO (3376) EsquireSqutions. com 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. Envelope ID: 69591157 Status as of 10/26/2022 2:55 PM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/26/2022 1:30:03 PM SENT Emily Taylor taylor@twlglawyers.com 10/26/2022 1:30:03 PM SENT Nuru Witherspoon litigation@twlglawyers.com 10/26/2022 1:30:03 PM SENT Associated Case Party: T. E. Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/26/2022 1:30:03 PM SENT Emily Taylor taylor@twlglawyers.com 10/26/2022 1:30:03 PM SENT Nuru Witherspoon litigation@twlglawyers.com 10/26/2022 1:30:03 PM SENT Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/26/2022 1:30:03 PM SENT Emily Taylor taylor@twlglawyers.com 10/26/2022 1:30:03 PM SENT Nuru Witherspoon litigation@twlglawyers.com 10/26/2022 1:30:03 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Josimayra Diaz josi.diaz@dallascityhall.com 10/26/2022 1:30:03 PM SENT Luz Aguilar luz.aguilar@dallascityhall.com 10/26/2022 1:30:03 PM SENT RoseMarie Chambers rose.chambers@dlapiper.com 10/26/2022 1:30:03 PM SENT NURU WITHERSPOON witherspoon@twlglawyers.com 10/26/2022 1:30:03 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. Envelope ID: 69591157 Status as of 10/26/2022 2:55 PM CST Case Contacts Sally Jones sally.jones@dlapiper.com 10/26/2022 1:30:03 PM SENT Ronald DHinds rdhinds@verizon.net 10/26/2022 1:30:03 PM SENT sherry M.faulkner sherry.faulkner@us.dlapiper.com 10/26/2022 1:30:03 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 10/26/2022 1:30:03 PM SENT Morgan Wells mwells@thompsoncoe.com 10/26/2022 1:30:03 PM SENT LISA V IvilIasenor@thompsoncoe.com 10/26/2022 1:30:03 PM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 10/26/2022 1:30:03 PM SENT Ronald DHinds rdhinds@verizon.net 10/26/2022 1:30:03 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 10/26/2022 1:30:03 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Jason Hopkins 24059969 jason.hopkins@dlapiper.com 10/26/2022 1:30:03 PM SENT Ronald DHinds rdhinds@verizon.net 10/26/2022 1:30:03 PM SENT Christopher BDonovan Christopher.B.Donovan@dlapiper.com 10/26/2022 1:30:03 PM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI 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. Envelope ID: 69591157 Status as of 10/26/2022 2:55 PM CST Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Eva DeLeon edeleon@thompsoncoe.com 10/26/2022 1:30:03 PM SENT Ronald DHinds rdhinds@verizon.net 10/26/2022 1:30:03 PM SENT