On April 16, 2021 a
Motion-Secondary
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
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 TANKSLEY on behalf of §
minor T.E., III, individually and on behalf of §
his father, T.E., deceased, and DEON WILLIAMS, §
§
Plaintiffs, §
§
V.
é
TASACOM REAL ESTATE, LLC d/b/a § 162nd 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 g
JAIN and MMAROOFUL CHOUDHURY, §
§
Defendants. § DALLAS COUNTY, TEXAS
ORDER
ON PLAINTIFFS’ MOTION TO COMPEL DEPOSITIONS
Came on to be heard Plaintiffs’ Motion to Compel Depositions (the “Motion”) against
Defendants Wyndham Hotels & Resorts, Inc., Wyndham Hotel Group, LLC, and Hawthorn Suites
Franchising, Inc. (collectively, the “Wyndham Defendants”) regarding deposition scheduling.
After considering the Motion, response and argument, the Court rules on the Motion as follows:
IT IS ORDERED that, within seven (7) days of this Order, Wyndham Defendants must
provide Plaintiffs’ counsel with at least three (3) dates before the date for affirmative expert
designations, for each deponent, upon which Plaintiffs may take the depositions of the following,
pursuant to the deposition notices:
(a) Corporate Representative of Wyndham Hotels & Resorts, Inc.;
(b) Corporate Representative of Wyndham Hotel Group, LLC;
(c) Corporate Representative of Hawthorn Suites Franchising, Inc.; and
(d) Rachel Dabrowa.
SIGNED this day of April 2023.
PRESIDING JUDGE
ORDER ON PLAINTIFFS’ MOTION TO COMPEL DEPOSITIONS - Page 2 of 2
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.
Brisia Mendoza on behalf of Emily Taylor
Bar No. 24046951
mendoza@twlglawyers.com
Envelope ID: 74480204
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PL-Proposed Order on Amended Motion to Compel
Against Hawthorne and Wyndham
Status as of 4/1 1/2023 8:15 AM CST
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 4/10/2023 1:50:37 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 4/10/2023 1:50:37 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 4/10/2023 1:50:37 PM SENT
LISA V IvilIasenor@thompsoncoe.com 4/10/2023 1:50:37 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 4/10/2023 1:50:37 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 4/10/2023 1:50:37 PM SENT
Ronald DHinds rdhinds@verizon.net 4/10/2023 1:50:37 PM SENT
Taylor Reed Taylor.reed@us.dlapiper.com 4/10/2023 1:50:37 PM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 4/10/2023 1:50:37 PM SENT
Eva DeLeon edeleon@thompsoncoe.com 4/10/2023 1:50:37 PM SENT
Associated Case Party: TONY 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.
Brisia Mendoza on behalf of Emily Taylor
Bar No. 24046951
mendoza@twlglawyers.com
Envelope ID: 74480204
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PL-Proposed Order on Amended Motion to Compel
Against Hawthorne and Wyndham
Status as of 4/1 1/2023 8:15 AM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 4/10/2023 1:50:37 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 4/10/2023 1:50:37 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 4/10/2023 1:50:37 PM SENT
Leslie Montano montano@twlglawyers.com 4/10/2023 1:50:37 PM SENT
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 4/10/2023 1:50:37 PM SENT
Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 4/10/20231:50:37 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 4/10/2023 1:50:37 PM SENT
Associated Case Party: ARETHA EVANS
Name BarN um ber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 4/10/2023 1:50:37 PM SENT
Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 4/10/20231:50:37 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 4/10/2023 1:50:37 PM SENT
Preview
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 TANKSLEY on behalf of § minor T.E., III, individually and on behalf of § his father, T.E., deceased, and DEON WILLIAMS, § § Plaintiffs, § § V. é TASACOM REAL ESTATE, LLC d/b/a § 162nd 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 g JAIN and MMAROOFUL CHOUDHURY, § § Defendants. § DALLAS COUNTY, TEXAS ORDER ON PLAINTIFFS’ MOTION TO COMPEL DEPOSITIONS Came on to be heard Plaintiffs’ Motion to Compel Depositions (the “Motion”) against Defendants Wyndham Hotels & Resorts, Inc., Wyndham Hotel Group, LLC, and Hawthorn Suites Franchising, Inc. (collectively, the “Wyndham Defendants”) regarding deposition scheduling. After considering the Motion, response and argument, the Court rules on the Motion as follows: IT IS ORDERED that, within seven (7) days of this Order, Wyndham Defendants must provide Plaintiffs’ counsel with at least three (3) dates before the date for affirmative expert designations, for each deponent, upon which Plaintiffs may take the depositions of the following, pursuant to the deposition notices: (a) Corporate Representative of Wyndham Hotels & Resorts, Inc.; (b) Corporate Representative of Wyndham Hotel Group, LLC; (c) Corporate Representative of Hawthorn Suites Franchising, Inc.; and (d) Rachel Dabrowa. SIGNED this day of April 2023. PRESIDING JUDGE ORDER ON PLAINTIFFS’ MOTION TO COMPEL DEPOSITIONS - Page 2 of 2 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. Brisia Mendoza on behalf of Emily Taylor Bar No. 24046951 mendoza@twlglawyers.com Envelope ID: 74480204 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PL-Proposed Order on Amended Motion to Compel Against Hawthorne and Wyndham Status as of 4/1 1/2023 8:15 AM CST Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 4/10/2023 1:50:37 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 4/10/2023 1:50:37 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 4/10/2023 1:50:37 PM SENT LISA V IvilIasenor@thompsoncoe.com 4/10/2023 1:50:37 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 4/10/2023 1:50:37 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 4/10/2023 1:50:37 PM SENT Ronald DHinds rdhinds@verizon.net 4/10/2023 1:50:37 PM SENT Taylor Reed Taylor.reed@us.dlapiper.com 4/10/2023 1:50:37 PM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 4/10/2023 1:50:37 PM SENT Eva DeLeon edeleon@thompsoncoe.com 4/10/2023 1:50:37 PM SENT Associated Case Party: TONY 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. Brisia Mendoza on behalf of Emily Taylor Bar No. 24046951 mendoza@twlglawyers.com Envelope ID: 74480204 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PL-Proposed Order on Amended Motion to Compel Against Hawthorne and Wyndham Status as of 4/1 1/2023 8:15 AM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 4/10/2023 1:50:37 PM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 4/10/2023 1:50:37 PM SENT Nuru Witherspoon litigation@twlglawyers.com 4/10/2023 1:50:37 PM SENT Leslie Montano montano@twlglawyers.com 4/10/2023 1:50:37 PM SENT Associated Case Party: T. E. Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 4/10/2023 1:50:37 PM SENT Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 4/10/20231:50:37 PM SENT Nuru Witherspoon litigation@twlglawyers.com 4/10/2023 1:50:37 PM SENT Associated Case Party: ARETHA EVANS Name BarN um ber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 4/10/2023 1:50:37 PM SENT Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 4/10/20231:50:37 PM SENT Nuru Witherspoon litigation@twlglawyers.com 4/10/2023 1:50:37 PM SENT