On April 16, 2021 a
Stipulation,Agreement
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-2l-O49OI
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., )
MOHAMMAD SADIQ NOSHAHI, )
DIAMOND STAFFING SERVICES, LLC, )
WYNDHAM HOTEL GROUP, LLC, )
TASACOM TECHNOLOGIES, INC., SANJEEV )
JAIN and MMAROOFUL CHOUDHURY, )
)
Defendants. ) DALLAS COUNTY, TEXAS
AGREED ORDER ON PLAINTIFFS’ MOTION T0 COMPEL PRODUCTION OF
DOCUMENTS AGAINST TASACOM REAL ESTATE, LLC
d/b/a HAWTHORN SUITES DALLAS LOVE FIELD
Before the Court is Plaintiffs’ Motion to Compel Production of Documents Against
Defendant Tasacom Real Estate, LLC d/b/a Hawthorn Suites Dallas Love Field. After reviewing
the written submissions of counsel, as well as considering their oral arguments, the Court makes
the following Orders:
Request for Production N0. 2: Produce all correspondence between you and CDS
Security or any other third-party security provider for the previous three years.
Court’s Ruling: Moot, because Defendant represented no responsive documents were found.
Objections, if any remain, to this request are stricken.
Request for Production No. 3: Produce all written contracts, agreements, work orders,
written understandings, job instructions, job duties and/or invoices between you and CDS
Security, or any other third-party security services provider, for the previous three years.
ORDER ON PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS AGAINST TASACOM REAL
ESTATE, LLC d/b/a HAWTHORN SUITES DALLAS LOVE FIELD - Page 1 of 3
Court’s Ruling: Moot because objections were withdrawn and Defendant represented no
responsive documents were found. Objections, if any remain, to this request are stricken.
Request for Production No. 11: Provide all documents, including all
correspondence, indicating, referring or related to any dividends and/or monetary
payments made to Noshahi, Jain, and/0r Choudhury as a result of their being
members, managers, and/or owners of TasaCOm since February 22, ‘2018 through
the date of the incident.
Court’s Ruling: Granted.
Request for Production No. 14: Provide all documents, including correspondence,
reflecting, referencing, and/0r related to any monetary reimbursement you made to
Tasacom Technologies, Jain, Choudhury, and/or Noshahi since February 22, 2018.
Court’s Ruling: Granted.
Request for Production No. 21: Produce documents identifying any other real
property or assets owned by Tasacom other than the hotel premises and fixtures or
appurtenances thereon.
Court’s Ruling: Denied.
Request for Production No. 24: Produce all correspondence, including emails,
between you and Nafiz Hossain, Sanjeev Jain, and/or Tasacom Technologies
during the two years prior to the incident that relates to security of the premises,
crime or perceived crime on the premises, and/or outside maintenance and/or
upkeep of the premises.
Court’s Ruling: Denied as to “outside maintenance and/or upkeep of the premises.” Granted in
all other respects.
Request for Production No. 25: Produce all your emails to or from
hr@tasacom.com during the two years prior to the incident related to the hotel, its
operations, and/or its employees.
Court’s Ruling: Granted, but the Court will entertain a reconsideration of this ruling if Defendant
presents evidence that this request is overly burdensome.
Request for Production No. 26: Produce all your emails to or from
naf@tasacom.com during the two years prior to the incident related to the hotel, its
operations, and/or its employees.
Court’s Ruling: Moot, as this issue was withdrawn by counsel for Plaintiffs.
ORDER ON PLAINTIFFS’ MOTION TO COMPEL PRODUCTION OF DOCUMENTS AGAINST TASACOM REAL
ESTATE, LLC d/b/a HAWTHORN SUITES DALLAS LOVE FIELD - Page 2 of 3
Request for Production N0. 27: Produce all your emails to or from
sj@tasacom.com during the two years prior to the incident related to the hotel, its
operations, and/or its employees.
Court’s Ruling: Granted, but the Court will entertain a reconsideration of this ruling if Defendant
presents evidence that this request is overly burdensome.
For all Requests for Production granted herein, the documents Ordered to be produced must
)
[j
I
be served on Plaintiffs’ counsel by the day of , 2023.
@VVV(
IT IS SO ORDERED.
/ M
DING JUDGE".
L
‘55? :5..._..?.; -.'\.,H;._T
HIE-lime e. U fie-ii
El
Senior Judge 5th Ceurt 0f Appeals
Sitting By Assignment
Agreed as to form, only:
/S/ Emily Tavlor
Attorney for Plaintiffs
/s/ Eva DeLeon
Attorney for Defendant
Tasacom Real Estate, LLC
ORDER ON PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS AGAINST TASACOM REAL
ESTATE, LLC d/b/a HAWTHORN SUITES DALLAS LOVE FIELD - Page 3 of 3
Preview
CAUSE NO. DC-2l-O49OI 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., ) MOHAMMAD SADIQ NOSHAHI, ) DIAMOND STAFFING SERVICES, LLC, ) WYNDHAM HOTEL GROUP, LLC, ) TASACOM TECHNOLOGIES, INC., SANJEEV ) JAIN and MMAROOFUL CHOUDHURY, ) ) Defendants. ) DALLAS COUNTY, TEXAS AGREED ORDER ON PLAINTIFFS’ MOTION T0 COMPEL PRODUCTION OF DOCUMENTS AGAINST TASACOM REAL ESTATE, LLC d/b/a HAWTHORN SUITES DALLAS LOVE FIELD Before the Court is Plaintiffs’ Motion to Compel Production of Documents Against Defendant Tasacom Real Estate, LLC d/b/a Hawthorn Suites Dallas Love Field. After reviewing the written submissions of counsel, as well as considering their oral arguments, the Court makes the following Orders: Request for Production N0. 2: Produce all correspondence between you and CDS Security or any other third-party security provider for the previous three years. Court’s Ruling: Moot, because Defendant represented no responsive documents were found. Objections, if any remain, to this request are stricken. Request for Production No. 3: Produce all written contracts, agreements, work orders, written understandings, job instructions, job duties and/or invoices between you and CDS Security, or any other third-party security services provider, for the previous three years. ORDER ON PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS AGAINST TASACOM REAL ESTATE, LLC d/b/a HAWTHORN SUITES DALLAS LOVE FIELD - Page 1 of 3 Court’s Ruling: Moot because objections were withdrawn and Defendant represented no responsive documents were found. Objections, if any remain, to this request are stricken. Request for Production No. 11: Provide all documents, including all correspondence, indicating, referring or related to any dividends and/or monetary payments made to Noshahi, Jain, and/0r Choudhury as a result of their being members, managers, and/or owners of TasaCOm since February 22, ‘2018 through the date of the incident. Court’s Ruling: Granted. Request for Production No. 14: Provide all documents, including correspondence, reflecting, referencing, and/0r related to any monetary reimbursement you made to Tasacom Technologies, Jain, Choudhury, and/or Noshahi since February 22, 2018. Court’s Ruling: Granted. Request for Production No. 21: Produce documents identifying any other real property or assets owned by Tasacom other than the hotel premises and fixtures or appurtenances thereon. Court’s Ruling: Denied. Request for Production No. 24: Produce all correspondence, including emails, between you and Nafiz Hossain, Sanjeev Jain, and/or Tasacom Technologies during the two years prior to the incident that relates to security of the premises, crime or perceived crime on the premises, and/or outside maintenance and/or upkeep of the premises. Court’s Ruling: Denied as to “outside maintenance and/or upkeep of the premises.” Granted in all other respects. Request for Production No. 25: Produce all your emails to or from hr@tasacom.com during the two years prior to the incident related to the hotel, its operations, and/or its employees. Court’s Ruling: Granted, but the Court will entertain a reconsideration of this ruling if Defendant presents evidence that this request is overly burdensome. Request for Production No. 26: Produce all your emails to or from naf@tasacom.com during the two years prior to the incident related to the hotel, its operations, and/or its employees. Court’s Ruling: Moot, as this issue was withdrawn by counsel for Plaintiffs. ORDER ON PLAINTIFFS’ MOTION TO COMPEL PRODUCTION OF DOCUMENTS AGAINST TASACOM REAL ESTATE, LLC d/b/a HAWTHORN SUITES DALLAS LOVE FIELD - Page 2 of 3 Request for Production N0. 27: Produce all your emails to or from sj@tasacom.com during the two years prior to the incident related to the hotel, its operations, and/or its employees. Court’s Ruling: Granted, but the Court will entertain a reconsideration of this ruling if Defendant presents evidence that this request is overly burdensome. For all Requests for Production granted herein, the documents Ordered to be produced must ) [j I be served on Plaintiffs’ counsel by the day of , 2023. @VVV( IT IS SO ORDERED. / M DING JUDGE". L ‘55? :5..._..?.; -.'\.,H;._T HIE-lime e. U fie-ii El Senior Judge 5th Ceurt 0f Appeals Sitting By Assignment Agreed as to form, only: /S/ Emily Tavlor Attorney for Plaintiffs /s/ Eva DeLeon Attorney for Defendant Tasacom Real Estate, LLC ORDER ON PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS AGAINST TASACOM REAL ESTATE, LLC d/b/a HAWTHORN SUITES DALLAS LOVE FIELD - Page 3 of 3