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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., Ill, individually and on behalf of )
his father, T.E., deceased, and DEON WILLIAMS, )
)
Plaintiffs, )
)
v. )
)
TASACOM REAL ESTATE, LLC d/b/a ) l62nd JUDICIAL DISTRICT
HAWTHORN SUITES DALLAS LOVE FIELD, )
HAWTHORN SUITES FRANCHISING, INC., )
WYNDHAM HOTELS & RESORTS, INC, )
MOI-MMMAD SADIQ NOSHAHI, )
DIAMOND STAFFING SERVICES, LLC, )
WYNDHAM HOTEL GROUP, LLC, )
TASACOM TECHNOLOGIES, INC, SANJEEV )
JAIN and MMAROOFUL CHOUDHURY, )
I
Defendants. ) DALLAS COUNTY, TEXAS
ORDER 0N PLAINTIFFS’ AMENDED MOTION TO COMPEL PRODUCTION 0F
DOCUMENTS AGAINST HAWTHORN SUITES FRANCHISING, INC., WYNDHAM_
HOTELS & RESORTS. IN C., AND WYNDHAM HOTEL GROUP. LLC
Before the Court is Plaintiffs’ Amended Motion to Compel Production of Documents
Against Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc. and
Wyndham Hotel Group, LLC. After reviewing the written submissions of counsel, as well as
considering their oral arguments, the Court makes the following Orders.
As to the following duplicated Requests for Production propounded on each of these three
Defendants, the Court finds and orders, as follows:
REQUEST FOR PRODUCTION N0. 7: Complete copies of all contracts,
agreements, and memoranda of understanding between You, on the one hand, and
Brookriver Hospitality, LLC, (“Prior Franchisee”) on the other hand.
ORDER ON PLAINTIFFS’ AMENDED MOTION T0 COMPEL PRODUCTION 0F DOCUMENTS AND INTERROGATORY
RESPONSES AGAINST DEFENDANTS HAWTHORN SUITES FRANCHISING, |NC., WYNDHAM HOTELS & RESORTS,
INC., AND WYNDHAM HOTEL GROUP, LLC - Page 1 of4
Court’s Ruling: Granted Denied Granted in part, denied in part:
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REQUEST FOR PRODUCTION NO. 8: Complete copies of communications
with Prior Franchisee regarding all crimes involving allegations of assault,
aggravated assault, sexual assault, rape, robbery, prostitution, manslaughter and/or
murder on the premises for the three years prior to the time Tasacom took over the
/
franchise.
Court’s Ruling: Granted Denied Granted in part, denied in part:
REQUEST FOR PRODUCTION NO. 9: Complete copies ofkCustomer Care;
documentation related to the Prior Franchisee reflecting crimes involving
allegations of assault, aggravated assault, sexual assault, rape, robbery, prostitution,
manslaughter and/or murder on the premises for the three years prior to the time
Tasacom took over
Court’s Ruling: Granted tl7n’chise.
Denied Granted in part, denied in part:
REQUEST FOR PRODUCTION NO. 10: Communications and documents
W%W
addressing all safety and/or security deficiencies that the as
required to address as
70
of the fra chise requirements.
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“WFiazchise
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Court’ Ruling: Granted
KILL par/t?
Denied
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Granted1n part, denled1n part. Swag
REQUEST FOR PRODUCTION N O. l3: All documents, correspondence,
communications, letters, e-mails, memorandums, and notes of oral
communications, sent to, received from, or exchanged between or among You and
Tasacom related to thefiVIinimum Insurance Requirements, as this term is used in
the Standards of Operation and Design Manual produced in this lawsuit.
ORDER ON PLAINTIFFS’ AMENDED MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND INTERROGATORY
RESPONSES AGAINST DEFENDANTS HAWTHORN SUITES FRANCHISING, INC., WYNDHAM HOTELS & RESORTS,
-
|NC., AND WYNDHAM HOTEL GROUP, LLC Page 2 of 4
Court’s Ruling: Granted Denied ll Granted in part, denied in part:
or
REQUEST FOR PRODUCTION N0. 15: Copies of-t-he manuals and guideline?
that Your quality assurance inspectors use(d) to administer those standards
prescribed1_n Your Standards of O eration and Design Manual produced in this
lawsuitfiar, W00— ‘fo Mamm-
Court’s Ruling: Granted I; Denied Granted in part, denied in part: (A
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REQUEST FOR PRODUCTION NO. 27. Produce all documents, including
emails, notes, memoranda, minutes, customer complaints or any other document,
in any format or medium, that reference, refer to, or are related to molest-came“
occurring on the premises for the two years prior to the incident, ss ult
Vate assau crimes involving 1rca sexua assault, rape, robbery,
murder, and/or manslaughter.
Court’s Ruling: Granted Denied Granted in part, denied in part:
REQUEST FOR PRODUCTION NO. 32: Produce all documents related to any
warnings you provided to the hotel regarding the hotel’s operation, including with
regard to safety and security, as a result of the incident and for the three years prior
to the incident.
Court’s Ruling: Granted Denied k Granted in part, denied in part:
ORDER ON PLAINTIFFS' AMENDED MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND INTERROGATORY
RESPONSES AGAINST DEFENDANTS HAWTHORN SUITES FRANCHISING, |NC., WYNDHAM HOTELS 81 RESORTS,
-
INC., AND WYNDHAM HOTEL GROUP, LLC Page 3 of4
REQUEST FOR PRODUCTION NO. 45: Produce all documents related to the
hotel’s operation, safety and security policies and procedures, management, and/or
employee and/or management training, including any suggestions you have made
to the hotel regarding the operation of the hotel, the safety and security of the
premises, the hotel’s management, and/or aining of the hotel’s personnel and/or
management.
Court’s Ruling: Granted Denied Granted in part, denied in part:
For all Requests for Production granted in whole or in part herein, the documents
and information are HEREBY ORDERED to be produced and served on Plaintiffs’ counsel by the
g lad" day of April 2023.
IT IS so ORDEREDW I990???)
fit! Mom
PRESIDING
'
IUD¢
ORDER ON PLAINTIFFS‘ AMENDED MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND INTERROGATORY
RESPONSES AGAINST DEFENDANTS HAWTHORN SUITES FRANCHISING, |NC., WYNDHAM HOTELS 8: RESORTS,
|NC., AND WYNDHAM HOTEL GROUP, LLC - Page 4 of 4
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., Ill, individually and on behalf of ) his father, T.E., deceased, and DEON WILLIAMS, ) ) Plaintiffs, ) ) v. ) ) TASACOM REAL ESTATE, LLC d/b/a ) l62nd JUDICIAL DISTRICT HAWTHORN SUITES DALLAS LOVE FIELD, ) HAWTHORN SUITES FRANCHISING, INC., ) WYNDHAM HOTELS & RESORTS, INC, ) MOI-MMMAD SADIQ NOSHAHI, ) DIAMOND STAFFING SERVICES, LLC, ) WYNDHAM HOTEL GROUP, LLC, ) TASACOM TECHNOLOGIES, INC, SANJEEV ) JAIN and MMAROOFUL CHOUDHURY, ) I Defendants. ) DALLAS COUNTY, TEXAS ORDER 0N PLAINTIFFS’ AMENDED MOTION TO COMPEL PRODUCTION 0F DOCUMENTS AGAINST HAWTHORN SUITES FRANCHISING, INC., WYNDHAM_ HOTELS & RESORTS. IN C., AND WYNDHAM HOTEL GROUP. LLC Before the Court is Plaintiffs’ Amended Motion to Compel Production of Documents Against Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc. and Wyndham Hotel Group, LLC. After reviewing the written submissions of counsel, as well as considering their oral arguments, the Court makes the following Orders. As to the following duplicated Requests for Production propounded on each of these three Defendants, the Court finds and orders, as follows: REQUEST FOR PRODUCTION N0. 7: Complete copies of all contracts, agreements, and memoranda of understanding between You, on the one hand, and Brookriver Hospitality, LLC, (“Prior Franchisee”) on the other hand. ORDER ON PLAINTIFFS’ AMENDED MOTION T0 COMPEL PRODUCTION 0F DOCUMENTS AND INTERROGATORY RESPONSES AGAINST DEFENDANTS HAWTHORN SUITES FRANCHISING, |NC., WYNDHAM HOTELS & RESORTS, INC., AND WYNDHAM HOTEL GROUP, LLC - Page 1 of4 Court’s Ruling: Granted Denied Granted in part, denied in part: WW H2 / mew! REQUEST FOR PRODUCTION NO. 8: Complete copies of communications with Prior Franchisee regarding all crimes involving allegations of assault, aggravated assault, sexual assault, rape, robbery, prostitution, manslaughter and/or murder on the premises for the three years prior to the time Tasacom took over the / franchise. Court’s Ruling: Granted Denied Granted in part, denied in part: REQUEST FOR PRODUCTION NO. 9: Complete copies ofkCustomer Care; documentation related to the Prior Franchisee reflecting crimes involving allegations of assault, aggravated assault, sexual assault, rape, robbery, prostitution, manslaughter and/or murder on the premises for the three years prior to the time Tasacom took over Court’s Ruling: Granted tl7n’chise. Denied Granted in part, denied in part: REQUEST FOR PRODUCTION NO. 10: Communications and documents W%W addressing all safety and/or security deficiencies that the as required to address as 70 of the fra chise requirements. M “WFiazchise 0'1 Court’ Ruling: Granted KILL par/t? Denied moon» flak 0m Granted1n part, denled1n part. Swag REQUEST FOR PRODUCTION N O. l3: All documents, correspondence, communications, letters, e-mails, memorandums, and notes of oral communications, sent to, received from, or exchanged between or among You and Tasacom related to thefiVIinimum Insurance Requirements, as this term is used in the Standards of Operation and Design Manual produced in this lawsuit. ORDER ON PLAINTIFFS’ AMENDED MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND INTERROGATORY RESPONSES AGAINST DEFENDANTS HAWTHORN SUITES FRANCHISING, INC., WYNDHAM HOTELS & RESORTS, - |NC., AND WYNDHAM HOTEL GROUP, LLC Page 2 of 4 Court’s Ruling: Granted Denied ll Granted in part, denied in part: or REQUEST FOR PRODUCTION N0. 15: Copies of-t-he manuals and guideline? that Your quality assurance inspectors use(d) to administer those standards prescribed1_n Your Standards of O eration and Design Manual produced in this lawsuitfiar, W00— ‘fo Mamm- Court’s Ruling: Granted I; Denied Granted in part, denied in part: (A %l WWW/(Wham. REQUEST FOR PRODUCTION NO. 27. Produce all documents, including emails, notes, memoranda, minutes, customer complaints or any other document, in any format or medium, that reference, refer to, or are related to molest-came“ occurring on the premises for the two years prior to the incident, ss ult Vate assau crimes involving 1rca sexua assault, rape, robbery, murder, and/or manslaughter. Court’s Ruling: Granted Denied Granted in part, denied in part: REQUEST FOR PRODUCTION NO. 32: Produce all documents related to any warnings you provided to the hotel regarding the hotel’s operation, including with regard to safety and security, as a result of the incident and for the three years prior to the incident. Court’s Ruling: Granted Denied k Granted in part, denied in part: ORDER ON PLAINTIFFS' AMENDED MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND INTERROGATORY RESPONSES AGAINST DEFENDANTS HAWTHORN SUITES FRANCHISING, |NC., WYNDHAM HOTELS 81 RESORTS, - INC., AND WYNDHAM HOTEL GROUP, LLC Page 3 of4 REQUEST FOR PRODUCTION NO. 45: Produce all documents related to the hotel’s operation, safety and security policies and procedures, management, and/or employee and/or management training, including any suggestions you have made to the hotel regarding the operation of the hotel, the safety and security of the premises, the hotel’s management, and/or aining of the hotel’s personnel and/or management. Court’s Ruling: Granted Denied Granted in part, denied in part: For all Requests for Production granted in whole or in part herein, the documents and information are HEREBY ORDERED to be produced and served on Plaintiffs’ counsel by the g lad" day of April 2023. IT IS so ORDEREDW I990???) fit! Mom PRESIDING ' IUD¢ ORDER ON PLAINTIFFS‘ AMENDED MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND INTERROGATORY RESPONSES AGAINST DEFENDANTS HAWTHORN SUITES FRANCHISING, |NC., WYNDHAM HOTELS 8: RESORTS, |NC., AND WYNDHAM HOTEL GROUP, LLC - Page 4 of 4