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FILED
4/28/2023 1:36 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Jeremy Jones 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.
TASACOM REAL ESTATE, LLC d/b/a l62nd 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
JAIN and MMAROOFUL CHOUDHURY,
Defendants. DALLAS COUNTY, TEXAS
PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION
OF WYNDHAM DEFENDANTS
TO: Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc. and
Wyndham Hotel Group, LLC., by and through their attorney of record, DLA PIPER LLP
(U S).
PLEASE TAKE NOTICE that Plaintiffs Tony Evans, Sr., and Aretha Evans, 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 (collectively
“Plaintiffs”), by and through their attorneys of record, will take the oral deposition(s) of
Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc. and Wyndham
Hotel Group, LLC (the “Wyndham Defendants”) pursuant to Rule 199.2(b)(2) of the Texas Rules
of Civil Procedure. The deposition(s) will also be videotaped. Said deposition(s) is to be taken on
May 15, 2023, commencing at 9:30 a.m. and continuing day to day thereafter until completed.
Page 1 of 8
The deposition(s) will be conducted Via the Zoom webcast platfonn with log-in credentials to
be provided by the court reporter prior to the deposition. The witness(es) must remain in attendance
Via Zoom from day to day until their respective deposition is completed.
Pursuant to Texas Rule of Civil Procedure 199.2(b)(1) and (2), the Wyndham Defendants
shall designate one or more officers, directors, or managing agents, or other persons who consent
to testify on its behalf, for each individual designated, the matters on which the individual will
testify on each of the topics set forth on Exhibit “B” attached hereto. The person(s) designated
shall testify to matters known or reasonably available to the Wyndham Defendants. The
deposition(s) will be taken before a certified court reporter, may be videotaped, and the videotape
and stenographic copy of the deposition(s) may be used in evidence upon the trial or at any hearing
of the above-referenced cause.
Plaintiffs’ counsel requests that Defendants’ counsel provide notification of the name and
title of each designated corporate representative(s) at least two (2) business days before the
scheduled deposition(s).
Respectfully Submitted,
/s/Nuru Witherspoon /s/Aubrev “Nick” Pittman
NURU WITHERSPOON AUBREY “NICK” PITTMAN
State Bar No. 24039244 State Bar No. 16049750
witherspoon@twlglawyers.com
THE PITTMAN LAW FIRM, P.C.
EMILY TAYLOR 100 Crescent Court, Suite 700
State Bar No. 24046951 Dallas, Texas 75201-21 12
tay10r@m1g1awyers_com
214-459-3454 — Telephone
214-853-5912 - Fax
WITHERSPOON LAW GROUP pittman@thepittmanlawfirm.com
5565 Deer Creek, Unit A
Dallas, Texas 75228
214-773-1133 — Telephone
972-696-9982 — Fax
PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 2 of 8
CERTIFICATE OF SERVICE
I hereby certify that on April 28, 2023, the foregoing document was submitted to the
representatives of the parties, using the electronic case filing system of the court. 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/Emz'lv Tavlor
Emily Taylor
PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 3 of 8
EXHIBIT “A”
DEFINITIONS AND INSTRUCTIONS
This Notice incorporates, without limiting the scope of the Texas Rules of Civil Procedure,
the following definitions:
1. “m,” “m,” and “Wmdham” shall mean and refer to Defendants Hawthorn Suites
Franchising, Inc., Wyndham Hotels & Resorts, Inc. and Wyndham Hotel Group, LLC and each of their
respective present and former officers, directors, employees, agents, drivers, attorneys, partners,
corporate parent, if any, predecessors, subsidiaries, afiiliated companies, and all other persons acting or
purporting to act on behalf of Wyndham.
2. The “Property” and “Hawthorn Suites Dallas Love Field,” shall refer to that property
located at 7900 Brookriver Drive, Dallas, Texas 75247.
3. “Tasacom” shall mean and refer to Defendants Tasacom Real Estate, Tasacom
Technologies, Inc. and all of their present and former officers, directors, employees, agents, drivers,
attorneys, partners, corporate parent, if any, predecessors, subsidiaries, afiiliated companies, and all
other persons acting or purporting to act as an owner of the business known as the Property.
4. “Previous Franchisee” shall mean and refer to the owner of the Hawthorn Suites Dallas
Love Field immediately before Tasacom’s purchase of it and each of their respective present and former
officers, directors, employees, agents, drivers, attorneys, partners, corporate parent, if any, predecessors,
subsidiaries, affiliated companies, and all other persons acting or purporting to act as an owner of the
business known as known as the Property.
5. “Incident in question” shall refer to the shooting incident at Hawthorn Suites Dallas
Love Field on April 1 1, 2021, where Decedent Tony Evans, Jr., was killed and Decedent Deon Williams
was injured.
PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 4 of 8
6. “Document” means any writing and any other tangible thing in Your custody,
possession, or control, Whether printed, recorded, reproduced by any process, or written or contained in
a computer (mainframe or otherwise) or on a computer disc, tape, software or electronic media of any
kind or data compilation or produced by hand. Set forth below is a list of examples of writings and
tangible things which are included within this definition. The list is not an exclusive list of the writings
and tangible things included within this definition, but rather are intended to aid you in producing the
documents that are requested. Examples of writings and tangible things included within the definition
of “document” are as follows:
Letters; e-mails; faxes; reports; agreements; intracompany and intercompany
communications; correspondence; text messages, telegrams; memoranda; summaries or
records of conversations; diaries; calendars; photographs; tape recordings; models;
charts; plans; drawings; agendas; minutes or records of conferences or meetings;
expressions or statements of policy; lists of persons attending meetings or conferences;
summaries; investigations; opinions or reports of consultants; appraisals; records;
brochures; pamphlets; advertisements; circulars; trade letters; reports, summaries or
analyses prepared by or for any governmental entity or agency; press releases; drafts of
any documents; revisions of drafts of any documents; canceled checks; bank statements;
invoices; receipts; and notes.
7. “Communication” and “communications” means any contact or act by which any
information or knowledge is transmitted or conveyed between two or more persons and shall include,
without limitation, written contact by such means as letters, memoranda, e-mails, “instant messages,”
telegrams, telex, or by any document, and oral contact by such means as face-to-face meetings and
telephone conversations.
” and
8. The words “o_r,
’7
an ,” “fl,” “eve_ry, ,3 ‘6
any,
,3
each,” “one or more.” including
similar words of guidance are intended merely as such and should not be construed as words of
limitation. The words “o_r” an “fl” shall include each other whenever possible to expand, not restrict,
the scope of the request. The word “including” shall not limit any general category or description that
PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 5 of 8
‘ 3’ 9’ ‘6
fly,
6 66
precedes it. The words “a_11,” eveg, each,” and “one or more” shall include each other, when
appropriate, to expand, not restrict, the scope of the Request.
9. The words “refer to,” “relate to,” “reflect” and “concern” a given subject means
concerning, referring to, alluding to, responding to, connected with, commenting on, in respect of, about,
regarding, discussing, showing, describing, mentioning, reflecting, analyzing, constituting, evidencing,
identifying or in any way pertinent to that certain subject.
10. The word “m1” means any natural person or any business, legal or governmental
entity or association, including, but not limited to, private and public partnerships, associations,
corporations, joint ventures, sole proprietorships, firms, and governments.
l l. The use of the singular form of any word includes the plural and vice versa.
12. This Notice seeks disclosure to the full extent of the Texas Rules of Civil Procedure and
applicable laws and shall be interpreted as inclusive rather than exclusive.
PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 6 of 8
EXHIBIT “B”
Organization, general structure, and interrelationship of the Wyndham Defendants;
Contracts You have and had with Tasacom;
Contracts You have had with the Previous Franchisee;
Circumstances behind the sale or transfer of the Premises from the Previous Franchisee to
Tasacom;
Training You supplied and/or made available to Tasacom regarding premises safety and
security;
Training You supplied and/or made available to Tasacom regarding the Quality Assurance
Process, as that term is used in Your Standards of Operation and Design Manual;
Training You supplied and/ or made available to Tasacom regarding the Property
Improvement Plan as that term is used in Your Standards of Operation and Design Manual;
The implementation of the Property Improvement Plan that is appended to the Franchise
Agreement between Hawthorn Suites Franchising, Inc. and Tasacom Real Estate, LLC and
how the term Property Improvement Plan is used in Your Standards of Operation and
Design Manual;
The implementation of the Quality Assurance Process as it relates to the franchise
relationship between Hawthorn Suites Franchising, Inc. and Tasacom Real Estate, LLC
and how the Quality Assurance Process is used according to Your Standards of Operation
and Design Manual.
10. Inspections and site visits You made of the Property during 2017-2021 as well as the
parameters and purposes thereof, and all personnel who visited the site and/or supervised
or managed said personnel regarding the inspections and site visits;
11. Quality Assurance Evaluations reports issued by You during 2016-2021 related to the
Property;
12. General details regarding the method and procedure for tracking customer complaints
about criminal activity, safety and security related to the risk of crime, and the upkeep of
the premises during 2017-2021 regarding the Property, actions taken with regard thereto,
and personnel involved therewith;
13. The process and procedures You used to review and approve insurance coverage for the
Property, and the date You became aware of the nature and scope of insurance in effect on
the Property in 2021;
14. The process and procedures You used to review and approve the financial well-being of all
owners of the Property during 2017-2021;
PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 7 of 8
15. The process and procedures You use to determine whether a franchise can or should be
involuntarily terminated;
16. When You became aware that the Property had been designated by the City of Dallas as a
Habitual Criminal Property and the attendant circumstances surrounding such knowledge;
17. The process and procedures by which you became aware of allegations of criminal activity
at or in the immediate vicinity of the Property and actions taken as a result thereof during
2016-2021;
18. Typical formats of documents the Property owners used to transmit information to You
regarding criminal activity at or in the immediate Vicinity of the Property during 2016-
2021;
19. When You became aware of the Incident in Question and the attendant circumstances
surrounding such knowledge;
20. Investigations of the incident in question performed by You, including:
a. Dates of the investigation(s);
b. Identities of those conducting the investigations;
c. CCTV tapes of the Incident in Question;
d. Written and oral statements of witnesses;
e. Notes of interviews with witnesses;
f. Tape recordings of any and all oral statements and/or interviews of witnesses;
g. Transcriptions of any tape recordings of any and all oral statements and/or
interviews of witnesses;
h. Reports regarding the results of any and all investigations;
i. Correspondence received from or sent to Plaintiffs, if any;
j. Correspondence received from or sent to any other Defendant;
k. Correspondence received from or sent to any person other than privileged
communication to counsel;
l. Documents relating to or evidencing discussions between Defendants regarding the
Incident in Question;
m. Documents received from or sent to any person (other than attorney/client
communication) regarding the Incident in Question;
21. Advertising and/or marketing of the Property during 2018-2021; and
22. Advertising and/or marketing of Your franchisees in the DFW area during 2018-2021.
PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 8 of 8
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: 75133727
Filing Code Description: Discovery
Filing Description: FIRST AMENDED NOTICE OF DEPOSTION OF
WYNDHAM
Status as of 5/1/2023 1:03 PM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 4/28/2023 1:36:11 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 4/28/20231:36:11 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 4/28/2023 1:36:11 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 4/28/2023 1:36:11 PM SENT
LISAV lvillasenor@thompsoncoe.com 4/28/2023 1:36:11 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 4/28/2023 1:36:11 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 4/28/2023 1:36:11 PM SENT
Ronald DHinds rdhinds@verizon.net 4/28/2023 1:36:11 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 4/28/2023 1:36:11 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 4/28/2023 1:36:11 PM SENT
Ronald DHinds rdhinds@verizon.net 4/28/2023 1:36:11 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.
Brisia Mendoza on behalf of Emily Taylor
Bar No. 24046951
mendoza@twlglawyers.com
Envelope ID: 75133727
Filing Code Description: Discovery
Filing Description: FIRST AMENDED NOTICE OF DEPOSTION OF
WYNDHAM
Status as of 5/1/2023 1:03 PM CST
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Taylor Reed Taylor.reed@us.dlapiper.com 4/28/2023 1:36:11 PM SENT
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 4/28/2023 1:36:11 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 4/28/20231:36:11 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 4/28/2023 1:36:11 PM SENT
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 4/28/2023 1:36:11 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 4/28/20231:36:11 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 4/28/2023 1:36:11 PM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 4/28/2023 1:36:11 PM SENT
Eva DeLeon edeleon@thompsoncoe.com 4/28/2023 1:36:11 PM SENT
Preview
FILED 4/28/2023 1:36 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Jeremy Jones 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. TASACOM REAL ESTATE, LLC d/b/a l62nd 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 JAIN and MMAROOFUL CHOUDHURY, Defendants. DALLAS COUNTY, TEXAS PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION OF WYNDHAM DEFENDANTS TO: Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc. and Wyndham Hotel Group, LLC., by and through their attorney of record, DLA PIPER LLP (U S). PLEASE TAKE NOTICE that Plaintiffs Tony Evans, Sr., and Aretha Evans, 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 (collectively “Plaintiffs”), by and through their attorneys of record, will take the oral deposition(s) of Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc. and Wyndham Hotel Group, LLC (the “Wyndham Defendants”) pursuant to Rule 199.2(b)(2) of the Texas Rules of Civil Procedure. The deposition(s) will also be videotaped. Said deposition(s) is to be taken on May 15, 2023, commencing at 9:30 a.m. and continuing day to day thereafter until completed. Page 1 of 8 The deposition(s) will be conducted Via the Zoom webcast platfonn with log-in credentials to be provided by the court reporter prior to the deposition. The witness(es) must remain in attendance Via Zoom from day to day until their respective deposition is completed. Pursuant to Texas Rule of Civil Procedure 199.2(b)(1) and (2), the Wyndham Defendants shall designate one or more officers, directors, or managing agents, or other persons who consent to testify on its behalf, for each individual designated, the matters on which the individual will testify on each of the topics set forth on Exhibit “B” attached hereto. The person(s) designated shall testify to matters known or reasonably available to the Wyndham Defendants. The deposition(s) will be taken before a certified court reporter, may be videotaped, and the videotape and stenographic copy of the deposition(s) may be used in evidence upon the trial or at any hearing of the above-referenced cause. Plaintiffs’ counsel requests that Defendants’ counsel provide notification of the name and title of each designated corporate representative(s) at least two (2) business days before the scheduled deposition(s). Respectfully Submitted, /s/Nuru Witherspoon /s/Aubrev “Nick” Pittman NURU WITHERSPOON AUBREY “NICK” PITTMAN State Bar No. 24039244 State Bar No. 16049750 witherspoon@twlglawyers.com THE PITTMAN LAW FIRM, P.C. EMILY TAYLOR 100 Crescent Court, Suite 700 State Bar No. 24046951 Dallas, Texas 75201-21 12 tay10r@m1g1awyers_com 214-459-3454 — Telephone 214-853-5912 - Fax WITHERSPOON LAW GROUP pittman@thepittmanlawfirm.com 5565 Deer Creek, Unit A Dallas, Texas 75228 214-773-1133 — Telephone 972-696-9982 — Fax PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 2 of 8 CERTIFICATE OF SERVICE I hereby certify that on April 28, 2023, the foregoing document was submitted to the representatives of the parties, using the electronic case filing system of the court. 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/Emz'lv Tavlor Emily Taylor PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 3 of 8 EXHIBIT “A” DEFINITIONS AND INSTRUCTIONS This Notice incorporates, without limiting the scope of the Texas Rules of Civil Procedure, the following definitions: 1. “m,” “m,” and “Wmdham” shall mean and refer to Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc. and Wyndham Hotel Group, LLC and each of their respective present and former officers, directors, employees, agents, drivers, attorneys, partners, corporate parent, if any, predecessors, subsidiaries, afiiliated companies, and all other persons acting or purporting to act on behalf of Wyndham. 2. The “Property” and “Hawthorn Suites Dallas Love Field,” shall refer to that property located at 7900 Brookriver Drive, Dallas, Texas 75247. 3. “Tasacom” shall mean and refer to Defendants Tasacom Real Estate, Tasacom Technologies, Inc. and all of their present and former officers, directors, employees, agents, drivers, attorneys, partners, corporate parent, if any, predecessors, subsidiaries, afiiliated companies, and all other persons acting or purporting to act as an owner of the business known as the Property. 4. “Previous Franchisee” shall mean and refer to the owner of the Hawthorn Suites Dallas Love Field immediately before Tasacom’s purchase of it and each of their respective present and former officers, directors, employees, agents, drivers, attorneys, partners, corporate parent, if any, predecessors, subsidiaries, affiliated companies, and all other persons acting or purporting to act as an owner of the business known as known as the Property. 5. “Incident in question” shall refer to the shooting incident at Hawthorn Suites Dallas Love Field on April 1 1, 2021, where Decedent Tony Evans, Jr., was killed and Decedent Deon Williams was injured. PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 4 of 8 6. “Document” means any writing and any other tangible thing in Your custody, possession, or control, Whether printed, recorded, reproduced by any process, or written or contained in a computer (mainframe or otherwise) or on a computer disc, tape, software or electronic media of any kind or data compilation or produced by hand. Set forth below is a list of examples of writings and tangible things which are included within this definition. The list is not an exclusive list of the writings and tangible things included within this definition, but rather are intended to aid you in producing the documents that are requested. Examples of writings and tangible things included within the definition of “document” are as follows: Letters; e-mails; faxes; reports; agreements; intracompany and intercompany communications; correspondence; text messages, telegrams; memoranda; summaries or records of conversations; diaries; calendars; photographs; tape recordings; models; charts; plans; drawings; agendas; minutes or records of conferences or meetings; expressions or statements of policy; lists of persons attending meetings or conferences; summaries; investigations; opinions or reports of consultants; appraisals; records; brochures; pamphlets; advertisements; circulars; trade letters; reports, summaries or analyses prepared by or for any governmental entity or agency; press releases; drafts of any documents; revisions of drafts of any documents; canceled checks; bank statements; invoices; receipts; and notes. 7. “Communication” and “communications” means any contact or act by which any information or knowledge is transmitted or conveyed between two or more persons and shall include, without limitation, written contact by such means as letters, memoranda, e-mails, “instant messages,” telegrams, telex, or by any document, and oral contact by such means as face-to-face meetings and telephone conversations. ” and 8. The words “o_r, ’7 an ,” “fl,” “eve_ry, ,3 ‘6 any, ,3 each,” “one or more.” including similar words of guidance are intended merely as such and should not be construed as words of limitation. The words “o_r” an “fl” shall include each other whenever possible to expand, not restrict, the scope of the request. The word “including” shall not limit any general category or description that PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 5 of 8 ‘ 3’ 9’ ‘6 fly, 6 66 precedes it. The words “a_11,” eveg, each,” and “one or more” shall include each other, when appropriate, to expand, not restrict, the scope of the Request. 9. The words “refer to,” “relate to,” “reflect” and “concern” a given subject means concerning, referring to, alluding to, responding to, connected with, commenting on, in respect of, about, regarding, discussing, showing, describing, mentioning, reflecting, analyzing, constituting, evidencing, identifying or in any way pertinent to that certain subject. 10. The word “m1” means any natural person or any business, legal or governmental entity or association, including, but not limited to, private and public partnerships, associations, corporations, joint ventures, sole proprietorships, firms, and governments. l l. The use of the singular form of any word includes the plural and vice versa. 12. This Notice seeks disclosure to the full extent of the Texas Rules of Civil Procedure and applicable laws and shall be interpreted as inclusive rather than exclusive. PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 6 of 8 EXHIBIT “B” Organization, general structure, and interrelationship of the Wyndham Defendants; Contracts You have and had with Tasacom; Contracts You have had with the Previous Franchisee; Circumstances behind the sale or transfer of the Premises from the Previous Franchisee to Tasacom; Training You supplied and/or made available to Tasacom regarding premises safety and security; Training You supplied and/or made available to Tasacom regarding the Quality Assurance Process, as that term is used in Your Standards of Operation and Design Manual; Training You supplied and/ or made available to Tasacom regarding the Property Improvement Plan as that term is used in Your Standards of Operation and Design Manual; The implementation of the Property Improvement Plan that is appended to the Franchise Agreement between Hawthorn Suites Franchising, Inc. and Tasacom Real Estate, LLC and how the term Property Improvement Plan is used in Your Standards of Operation and Design Manual; The implementation of the Quality Assurance Process as it relates to the franchise relationship between Hawthorn Suites Franchising, Inc. and Tasacom Real Estate, LLC and how the Quality Assurance Process is used according to Your Standards of Operation and Design Manual. 10. Inspections and site visits You made of the Property during 2017-2021 as well as the parameters and purposes thereof, and all personnel who visited the site and/or supervised or managed said personnel regarding the inspections and site visits; 11. Quality Assurance Evaluations reports issued by You during 2016-2021 related to the Property; 12. General details regarding the method and procedure for tracking customer complaints about criminal activity, safety and security related to the risk of crime, and the upkeep of the premises during 2017-2021 regarding the Property, actions taken with regard thereto, and personnel involved therewith; 13. The process and procedures You used to review and approve insurance coverage for the Property, and the date You became aware of the nature and scope of insurance in effect on the Property in 2021; 14. The process and procedures You used to review and approve the financial well-being of all owners of the Property during 2017-2021; PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 7 of 8 15. The process and procedures You use to determine whether a franchise can or should be involuntarily terminated; 16. When You became aware that the Property had been designated by the City of Dallas as a Habitual Criminal Property and the attendant circumstances surrounding such knowledge; 17. The process and procedures by which you became aware of allegations of criminal activity at or in the immediate vicinity of the Property and actions taken as a result thereof during 2016-2021; 18. Typical formats of documents the Property owners used to transmit information to You regarding criminal activity at or in the immediate Vicinity of the Property during 2016- 2021; 19. When You became aware of the Incident in Question and the attendant circumstances surrounding such knowledge; 20. Investigations of the incident in question performed by You, including: a. Dates of the investigation(s); b. Identities of those conducting the investigations; c. CCTV tapes of the Incident in Question; d. Written and oral statements of witnesses; e. Notes of interviews with witnesses; f. Tape recordings of any and all oral statements and/or interviews of witnesses; g. Transcriptions of any tape recordings of any and all oral statements and/or interviews of witnesses; h. Reports regarding the results of any and all investigations; i. Correspondence received from or sent to Plaintiffs, if any; j. Correspondence received from or sent to any other Defendant; k. Correspondence received from or sent to any person other than privileged communication to counsel; l. Documents relating to or evidencing discussions between Defendants regarding the Incident in Question; m. Documents received from or sent to any person (other than attorney/client communication) regarding the Incident in Question; 21. Advertising and/or marketing of the Property during 2018-2021; and 22. Advertising and/or marketing of Your franchisees in the DFW area during 2018-2021. PLAINTIFFS’ FIRST AMENDED NOTICE OF DEPOSITION - Page 8 of 8 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: 75133727 Filing Code Description: Discovery Filing Description: FIRST AMENDED NOTICE OF DEPOSTION OF WYNDHAM Status as of 5/1/2023 1:03 PM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 4/28/2023 1:36:11 PM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 4/28/20231:36:11 PM SENT Nuru Witherspoon litigation@twlglawyers.com 4/28/2023 1:36:11 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 4/28/2023 1:36:11 PM SENT LISAV lvillasenor@thompsoncoe.com 4/28/2023 1:36:11 PM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 4/28/2023 1:36:11 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 4/28/2023 1:36:11 PM SENT Ronald DHinds rdhinds@verizon.net 4/28/2023 1:36:11 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 4/28/2023 1:36:11 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 4/28/2023 1:36:11 PM SENT Ronald DHinds rdhinds@verizon.net 4/28/2023 1:36:11 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. Brisia Mendoza on behalf of Emily Taylor Bar No. 24046951 mendoza@twlglawyers.com Envelope ID: 75133727 Filing Code Description: Discovery Filing Description: FIRST AMENDED NOTICE OF DEPOSTION OF WYNDHAM Status as of 5/1/2023 1:03 PM CST Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Taylor Reed Taylor.reed@us.dlapiper.com 4/28/2023 1:36:11 PM SENT Associated Case Party: T. E. Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 4/28/2023 1:36:11 PM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 4/28/20231:36:11 PM SENT Nuru Witherspoon litigation@twlglawyers.com 4/28/2023 1:36:11 PM SENT Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 4/28/2023 1:36:11 PM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 4/28/20231:36:11 PM SENT Nuru Witherspoon litigation@twlglawyers.com 4/28/2023 1:36:11 PM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 4/28/2023 1:36:11 PM SENT Eva DeLeon edeleon@thompsoncoe.com 4/28/2023 1:36:11 PM SENT