On April 16, 2021 a
Clerk Notice
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
3/22/2023 9:40 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 TANKSLEY on behalf of )
minor T.E., III, individually and on behalf of )
his father, T.E., deceased, and DEON WILLIAMS, )
)
Plaintiffs, )
)
V.
g
TASACOM REAL ESTATE, LLC d/b/a ) 162nd JUDICIAL DISTRICT
HAWTHORN SUITES DALLAS LOVE FIELD, )
HAWTHORN SUITES FRANCHISING, INC., )
W Y NDHAM HOTELS & RESORTS, INC., )
MOHAMMAD SADIQ NOSHAHI, )
DIAMOND STAFFING SERVICES, LLC, )
W Y NDHAM HOTEL GROUP, LLC,
TASACOM TECHNOLOGIES, INC., SANJEEV l
JAIN and MMAROOFUL CHOUDHURY, )
)
Defendants. ) DALLAS COUNTY, TEXAS
Please take notice that Plaintiffs’ Amended Motion to Compel Production of Documents
and Motion to Compel Depositions Against Defendants Hawthorn Suites Franchising, Inc.,
Wyndham Hotels & Resorts, Inc., and Wyndham Hotel Group, LLC and Plaintiffs’ Verified
Motion for Continuance of Defendants’ Summary Judgment Hearing that were filed on March
15, 2023, respectively, will be heard in-person on April 12, 2023, at 10:30 a.m., in the 162ml
Judicial District Court of Dallas County Texas, located at George L. Allen, Sr. Courts
Building, 600 Commerce Street, Dallas, Texas 75202 before the Honorable Michael J. Neill,
Visiting judge.
Respectfully Submitted,
/s/ Nuru Witherspoon
NURU WITHERSPOON
NOTICE OF HEARING - Page 1 of 2
State Bar No. 2403 9244
witherspoon@tw1glawyers.com
EMILY TAYLOR
State Bar No. 24046951
taylor@twlg1awyers.com
WITHERSPOON LAW GROUP
5565 Deer Creek, Unit A
Dallas, Texas 75228
214-773-1133 — Telephone
972-696-9982 — Fax
”
/s/ Aubrey “Nick Pittman
AUBREY “NICK” PITTMAN
State Bar No. 16049750
THE PITTMAN LAW FIRM, P.C.
100 Crescent Court, Suite 700
Dallas, Texas 75201-2112
214-459-3454 — Telephone
214-853-5912 - Fax
pittrnan@thepittmanlawfirm.com
CERTIFICATE OF SERVICE
I hereby certify that on March 22, 2023, the foregoing document was submitted to the
representatives of the parties, using the electronic case filing system of the court according to TEX.
R. CIV. P. 21a. 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
NOTICE OF HEARING - 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: 73889730
Filing Code Description: Notice Of Hearing / Fiat
Filing Description: RE: PLAINTIFF MTN COMPEL/ MTN CONTINUANCE
Status as of 3/22/2023 10:30 AM CST
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 3/22/2023 9:40:38 AM SENT
LISA V IvilIasenor@thompsoncoe.com 3/22/2023 9:40:38 AM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 3/22/2023 9:40:38 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 3/22/2023 9:40:38 AM SENT
Taylor Reed Taylor.reed@us.dlapiper.com 3/22/2023 9:40:38 AM SENT
Associated Case Party: MONIQUE PERKINS
Name BarNumber Email TimestampSubmitted Status
RoseMarie Chambers rose.chambers@dlapiper.com 3/22/2023 9:40:38 AM SENT
NURU WITHERSPOON witherspoon@twlglawyers.com 3/22/2023 9:40:38 AM SENT
Sally Jones sally.jones@dlapiper.com 3/22/2023 9:40:38 AM SENT
sherry M.fau|kner sherry.fauIkner@us.dlapiper.com 3/22/2023 9:40:38 AM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 3/22/2023 9:40:38 AM SENT
Associated Case Party: ARETHA 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: 73889730
Filing Code Description: Notice Of Hearing / Fiat
Filing Description: RE: PLAINTIFF MTN COMPEL/ MTN CONTINUANCE
Status as of 3/22/2023 10:30 AM CST
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 3/22/2023 9:40:38 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 3/22/2023 9:40:38 AM SENT
Nuru Witherspoon litigation@twlglawyers.com 3/22/2023 9:40:38 AM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email Timestam pSubmitted Status
Eva DeLeon edeleon@thompsoncoe.com 3/22/2023 9:40:38 AM SENT
Preview
FILED 3/22/2023 9:40 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 TANKSLEY on behalf of ) minor T.E., III, individually and on behalf of ) his father, T.E., deceased, and DEON WILLIAMS, ) ) Plaintiffs, ) ) V. g TASACOM REAL ESTATE, LLC d/b/a ) 162nd JUDICIAL DISTRICT HAWTHORN SUITES DALLAS LOVE FIELD, ) HAWTHORN SUITES FRANCHISING, INC., ) W Y NDHAM HOTELS & RESORTS, INC., ) MOHAMMAD SADIQ NOSHAHI, ) DIAMOND STAFFING SERVICES, LLC, ) W Y NDHAM HOTEL GROUP, LLC, TASACOM TECHNOLOGIES, INC., SANJEEV l JAIN and MMAROOFUL CHOUDHURY, ) ) Defendants. ) DALLAS COUNTY, TEXAS Please take notice that Plaintiffs’ Amended Motion to Compel Production of Documents and Motion to Compel Depositions Against Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc., and Wyndham Hotel Group, LLC and Plaintiffs’ Verified Motion for Continuance of Defendants’ Summary Judgment Hearing that were filed on March 15, 2023, respectively, will be heard in-person on April 12, 2023, at 10:30 a.m., in the 162ml Judicial District Court of Dallas County Texas, located at George L. Allen, Sr. Courts Building, 600 Commerce Street, Dallas, Texas 75202 before the Honorable Michael J. Neill, Visiting judge. Respectfully Submitted, /s/ Nuru Witherspoon NURU WITHERSPOON NOTICE OF HEARING - Page 1 of 2 State Bar No. 2403 9244 witherspoon@tw1glawyers.com EMILY TAYLOR State Bar No. 24046951 taylor@twlg1awyers.com WITHERSPOON LAW GROUP 5565 Deer Creek, Unit A Dallas, Texas 75228 214-773-1133 — Telephone 972-696-9982 — Fax ” /s/ Aubrey “Nick Pittman AUBREY “NICK” PITTMAN State Bar No. 16049750 THE PITTMAN LAW FIRM, P.C. 100 Crescent Court, Suite 700 Dallas, Texas 75201-2112 214-459-3454 — Telephone 214-853-5912 - Fax pittrnan@thepittmanlawfirm.com CERTIFICATE OF SERVICE I hereby certify that on March 22, 2023, the foregoing document was submitted to the representatives of the parties, using the electronic case filing system of the court according to TEX. R. CIV. P. 21a. 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 NOTICE OF HEARING - 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: 73889730 Filing Code Description: Notice Of Hearing / Fiat Filing Description: RE: PLAINTIFF MTN COMPEL/ MTN CONTINUANCE Status as of 3/22/2023 10:30 AM CST Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 3/22/2023 9:40:38 AM SENT LISA V IvilIasenor@thompsoncoe.com 3/22/2023 9:40:38 AM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 3/22/2023 9:40:38 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 3/22/2023 9:40:38 AM SENT Taylor Reed Taylor.reed@us.dlapiper.com 3/22/2023 9:40:38 AM SENT Associated Case Party: MONIQUE PERKINS Name BarNumber Email TimestampSubmitted Status RoseMarie Chambers rose.chambers@dlapiper.com 3/22/2023 9:40:38 AM SENT NURU WITHERSPOON witherspoon@twlglawyers.com 3/22/2023 9:40:38 AM SENT Sally Jones sally.jones@dlapiper.com 3/22/2023 9:40:38 AM SENT sherry M.fau|kner sherry.fauIkner@us.dlapiper.com 3/22/2023 9:40:38 AM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 3/22/2023 9:40:38 AM SENT Associated Case Party: ARETHA 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: 73889730 Filing Code Description: Notice Of Hearing / Fiat Filing Description: RE: PLAINTIFF MTN COMPEL/ MTN CONTINUANCE Status as of 3/22/2023 10:30 AM CST Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 3/22/2023 9:40:38 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 3/22/2023 9:40:38 AM SENT Nuru Witherspoon litigation@twlglawyers.com 3/22/2023 9:40:38 AM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email Timestam pSubmitted Status Eva DeLeon edeleon@thompsoncoe.com 3/22/2023 9:40:38 AM SENT