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—2 1 -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
AMENDED ORDER
ON PLAINTIFFS’ MOTION FOR DISCOVERY SANCTIONS
On this date came to be heard Plaintiffs’ Motion for Discovery Sanction (the “Motion”)
against Wyndham Hotels & Resorts, Inc., Wyndham Hotel Group, LLC, and Hawthorn Suites
Franchising, Inc., (collectively, the “Wyndham Defendants”) and after considering said Motion,
the Wyndham Defendants’ Response, and oral argument, the Court is of the opinion the Motion
should be GRANTED, and rules on the Motion as follows:
IT IS ORDERED that the Wyndham Defendants shall pay the court reporter and
videographer fees incurred for the last minute cancellation of the deposition of Anuj Arora;
IT IS ORDERED that, within three (3) days of this Order, Wyndham Defendants must
provide Plaintiffs’ counsel with at least three (3) dates before July 27, 2023, upon which Plaintiffs
may take the deposition of Anuj Arora;
It is further ORDERED that:
A. The hearing set for July 14, 2023, on Wyndham Defendants’ Motion for Summary
Judgment will be vacated and removed from the Court’s calendar; and
B. To the extent the Wyndham Defendants choose to reset the Motion for Summary
Judgment, it shall not be set until at least thirty (30) days after Plaintiffs have
obtained the requested discovery from the Wyndham Defendants;
IT IS FURTHER ORDERED that the Wyndham Defendants must submit to Plaintiffs’
counsel within 7 days of the entry of this Order the sum of $ , which constitutes
the payment of reasonable and necessary attorneys’ fees related to this discovery dispute and the
Motion.
SIGNED this day of , 2023.
PRESIDING DISTRICT JUDGE
ORDER ON PLAINTIFFS’ MOTION FOR SANCTIONS - 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: 77022237
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED AMENDED ORDER ON PLTF/MOTION
DISCOVERY SANCTIONS
Status as of 6/28/2023 8:24 AM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@tw|glawyers.com 6/27/2023 4:29:42 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 6/27/2023 4:29:42 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 6/27/2023 4:29:42 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 6/27/2023 4:29:42 PM SENT
LISA V |vi|lasenor@thompsoncoe.com 6/27/2023 4:29:42 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 6/27/2023 4:29:42 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 6/27/2023 4:29:42 PM SENT
Ronald DHinds rdhinds@verizon.net 6/27/2023 4:29:42 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 6/27/2023 4:29:42 PM SENT
RoseMarie Chambers rose.chambers@dlapiper.com 6/27/2023 4:29:42 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 6/27/2023 4:29:42 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: 77022237
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED AMENDED ORDER ON PLTF/MOTION
DISCOVERY SANCTIONS
Status as of 6/28/2023 8:24 AM CST
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Ronald DHinds rdhinds@verizon.net 6/27/2023 4:29:42 PM SENT
Judy Calderon judy.calderon@dlapiper.com 6/27/2023 4:29:42 PM SENT
Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 6/27/2023 4:29:42 PM SENT
Sally Jones sally.jones@dlapiper.com 6/27/2023 4:29:42 PM SENT
Taylor Reed Taylor.reed@us.dlapiper.com 6/27/2023 4:29:42 PM SENT
Associated Case Party: TASACOM TECHNOLOGIES INC
Name BarNumber Email TimestampSubmitted Status
Benjamin Dunn bdunn@thompsoncoe.com 6/27/2023 4:29:42 PM SENT
Associated Case Party: MMAROOFUL CHOUDHURY
Name BarNumber Email TimestampSubmitted Status
Morgan Wells mwells@thompsoncoe.com 6/27/2023 4:29:42 PM SENT
Preview
CAUSE NO. DC—2 1 -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 AMENDED ORDER ON PLAINTIFFS’ MOTION FOR DISCOVERY SANCTIONS On this date came to be heard Plaintiffs’ Motion for Discovery Sanction (the “Motion”) against Wyndham Hotels & Resorts, Inc., Wyndham Hotel Group, LLC, and Hawthorn Suites Franchising, Inc., (collectively, the “Wyndham Defendants”) and after considering said Motion, the Wyndham Defendants’ Response, and oral argument, the Court is of the opinion the Motion should be GRANTED, and rules on the Motion as follows: IT IS ORDERED that the Wyndham Defendants shall pay the court reporter and videographer fees incurred for the last minute cancellation of the deposition of Anuj Arora; IT IS ORDERED that, within three (3) days of this Order, Wyndham Defendants must provide Plaintiffs’ counsel with at least three (3) dates before July 27, 2023, upon which Plaintiffs may take the deposition of Anuj Arora; It is further ORDERED that: A. The hearing set for July 14, 2023, on Wyndham Defendants’ Motion for Summary Judgment will be vacated and removed from the Court’s calendar; and B. To the extent the Wyndham Defendants choose to reset the Motion for Summary Judgment, it shall not be set until at least thirty (30) days after Plaintiffs have obtained the requested discovery from the Wyndham Defendants; IT IS FURTHER ORDERED that the Wyndham Defendants must submit to Plaintiffs’ counsel within 7 days of the entry of this Order the sum of $ , which constitutes the payment of reasonable and necessary attorneys’ fees related to this discovery dispute and the Motion. SIGNED this day of , 2023. PRESIDING DISTRICT JUDGE ORDER ON PLAINTIFFS’ MOTION FOR SANCTIONS - 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: 77022237 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED AMENDED ORDER ON PLTF/MOTION DISCOVERY SANCTIONS Status as of 6/28/2023 8:24 AM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@tw|glawyers.com 6/27/2023 4:29:42 PM SENT Nuru Witherspoon litigation@twlglawyers.com 6/27/2023 4:29:42 PM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 6/27/2023 4:29:42 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 6/27/2023 4:29:42 PM SENT LISA V |vi|lasenor@thompsoncoe.com 6/27/2023 4:29:42 PM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 6/27/2023 4:29:42 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 6/27/2023 4:29:42 PM SENT Ronald DHinds rdhinds@verizon.net 6/27/2023 4:29:42 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 6/27/2023 4:29:42 PM SENT RoseMarie Chambers rose.chambers@dlapiper.com 6/27/2023 4:29:42 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 6/27/2023 4:29:42 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: 77022237 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED AMENDED ORDER ON PLTF/MOTION DISCOVERY SANCTIONS Status as of 6/28/2023 8:24 AM CST Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Ronald DHinds rdhinds@verizon.net 6/27/2023 4:29:42 PM SENT Judy Calderon judy.calderon@dlapiper.com 6/27/2023 4:29:42 PM SENT Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 6/27/2023 4:29:42 PM SENT Sally Jones sally.jones@dlapiper.com 6/27/2023 4:29:42 PM SENT Taylor Reed Taylor.reed@us.dlapiper.com 6/27/2023 4:29:42 PM SENT Associated Case Party: TASACOM TECHNOLOGIES INC Name BarNumber Email TimestampSubmitted Status Benjamin Dunn bdunn@thompsoncoe.com 6/27/2023 4:29:42 PM SENT Associated Case Party: MMAROOFUL CHOUDHURY Name BarNumber Email TimestampSubmitted Status Morgan Wells mwells@thompsoncoe.com 6/27/2023 4:29:42 PM SENT