Preview
FILED
7/17/2023 12:00 AM
FELICIA PITRE
DISTRICT CLERK
RACHEL DABROWA May
EVANS, SR. V. TASACOM REAL ESTATE magmas-625$
CAUSE NO. DC-21—O4901
TONY EVANS, SR., AND ARETHA IN THE DISTRICT COURT
EVANS, INDIVIDUALLY AND ON
BEHALF OF THEIR MINOR SON,
T.E., DECEASED, FAITH
TANKSLEY ON BEHALF OF MINOR 162ND JUDICIAL DISTRICT
T.E., III, INDIVIDUALY AND ON
BEHALF OF HIS FATHER, T.E.,
DECEASED, AND DEON WILLIAMS,
DALLAS COUNTY, TEXAS
Plaintiffs,
VS.
TASCOM REAL ESTATE, LLC D/B/A
lO HAWTHORN SUITES DALLAS LOVE
FIELD, HAWTHORN SUITES
ll FRANCHISING, INC., WYNDHAM
HOTELS & RESORTS, INC.,
12 MOHAMMAD SADIQ NOSHAHI,
DIAMOND STAFFING SERVICES,
l3 LLC, TASACOM TECHNOLOGIES,
INC., SANJEEV JAIN AND
l4 MMAROOFUL CHOUDHURY,
15 Defendants.
l6
l7
REPORTER'S CERTIFICATE
18
DEPOSITION OF RACHEL ANN DABROWA
19
20
21 I, MARINA MAY RAMOS, Digital Reporter and Notary
Public for the State of Texas, hereby certify to the
22 following:
23 That the witness, RACHEL ANN DABROWA was duly sworn by
me and that the testimony was accurately captured with
24 annotations by me during the proceeding;
25 That the transcript was submitted on 52423 to the
Q ESQUIRE 800.21 1 .DEPO (3376)
EsquireSqutions. com
RACHEL DABROWA May 15, 2023
EVANS, SR. V. TASACOM REAL ESTATE 323
witness for examination, signature, and returned to me
by 6-20 , 2023.
The amount of time used by each party at the
proceeding was as follows:
Aubrey Pittman, Esq. —
06:01:10
Emily Taylor, Esq. —
00:00:00
Christopher Donovan, Esq. —
00:00:00
Benjamin Dunn, Esq. —
00:00:00
Jason M. Hopkins, Esq. —
00:00:00
Tasha Barnes, Esq. —
00:00:00
lO
ll
That $5m7645 is the deposition officer's charges to
12 counsel for preparing the original deposition
transcript and any copies and any copies of exhibits;
13
That pursuant to information given to the deposition
l4 officer at the time said testimony was taken, the
following includes counsel for all parties of record:
15
AUBREY PITTMAN, Esq., Attorney for Plaintiffs
16 EMILY TAYLOR, Esq., Attorney for Plaintiffs
CHRISTOPHER DONOVAN, Esq., Attorney for Defendants
17 Hawthorn Suites Dallas Love Field, Hawthorn Suites
Franchising, Inc., Wyndham Hotels & Resorts, Inc., and
18 Wyndham Hotel Group, LLC
TASHA BARNES, Esq., Attorney for Defendants Tasacom
19 Real Estate, LLC, Mohammad Sadiq Noshahi, Diamond
Staffing Services, LLC, Tasacom Technologies, Inc.,
20 Sanjeev Jain, and Mmarooful Choudhury
BENJAMIN DUNN, Esq., Attorney for Defendants Tasacom
21 Real Estate, LLC, Mohammad Sadiq Noshahi, Diamond
Staffing Services, LLC, Tasacom Technologies, Inc.,
22 Sanjeev Jain, and Mmarooful Choudhury
JASON M. HOPKINS, Esq., Attorney for Defendants
23 Hawthorn Suites Dallas Love Field, Hawthorn Suites
Franchising, Inc., Wyndham Hotels & Resorts, Inc., and
24 Wyndham Hotel Group, LLC
JASON M. HOPKINS, Esq., Attorney for Defendants
25 Hawthorn Suites Dallas Love Field, Hawthorn Suites
Q ESQUIRE 800.21 1 .DEPO (3376)
EsquireSqutions. com
RACHEL DABROWA May 15, 2023
EVANS, SR. V. TASACOM REAL ESTATE 324
Franchising, Inc., Wyndham Hotels & Resorts, Inc., and
Wyndham Hotel Group, LLC
I further certify that I am neither counsel for,
related to, nor employed by any of the parties or
attorneys in the action in which this proceeding was
taken, and further that I am not financially or
otherwise interested in the outcome of the action.
Further certification requirements pursuant to 203 of
TCRP will be certified to after they have occurred.
Certified to me this 24 May, 2023.
Y/
f/
lO MARINA MAY RAMOS
Notary Commission No. 13405676—9
ll Commission Expires: November 9, 2026
Firm Registration No. 3
12
13
l4
15
16
17
18
19
20
21
22
23
24
25
Q ESQUIRE 800.21 1 .DEPO (3376)
EsquireSqutions. com
RACHEL DABROWA May 15, 2023
EVANS, SR. V. TASACOM REAL ESTATE 325
FURTHER CERTIFICATION UNDER RULE 203 TCRP
The original deposition was/was not returned to the
deposition officer on 62023 ,
If returned, the attached Change and Signature page
contains any changes and the reasons therefore;
If returned, the original deposition was delivered to
AUBREY PITTMAN, Esq., Custodial Attorney.
That $387645 is the depositicm1<3fficer's charges to
the custodial party for preparing the original
deposition transcript and any copies of exhibits.
That the deposition was delivered in accordance with
lO Rule 203.3, and that a copy of this certificate was
served on all parties shown herein on Z4423 and
ll files with the Clerk.
12 Certified to me by this l4 July, 2023
13
l4
l5
l6 MARINA MAY RAMOS
Notary Commission No. 13405676—9
l7 Commission Expires: November 9, 2026
Firm Registration No. 3
l8
l9
20
21
22
23
24
25
Q ESQUIRE 800.21 1 .DEPO (3376)
EsquireSqutions. com
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.
Envelope lD: 77558700
Filing Code Description: Certificate of Deposition
Filing Description: RACHEL ANN DABROWA
Status as of 7/17/2023 9:23 AM CST
Associated Case Party: TONY EVANS
Name BarN um ber Email TimestampSubmitted Status
Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 7/15/20231:00:57 PM SENT
Emily Taylor taylor@twlglawyers.com 7/15/2023 1:00:57 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 7/15/2023 1:00:57 PM SENT
Associated Case Party: T. E.
Name BarN um ber Email TimestampSubmitted Status
Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 7/15/20231:00:57 PM SENT
Emily Taylor taylor@twlglawyers.com 7/15/2023 1:00:57 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 7/15/2023 1:00:57 PM SENT
Associated Case Party: ARETHA EVANS
Name BarN um ber Email TimestampSubmitted Status
Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 7/15/20231:00:57 PM SENT
Emily Taylor taylor@twlglawyers.com 7/15/2023 1:00:57 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 7/15/2023 1:00:57 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 7/15/2023 1:00:57 PM SENT
LISA V lvillasenor@thompsoncoe.com 7/15/2023 1:00:57 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
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.
Envelope ID: 77558700
Filing Code Description: Certificate of Deposition
Filing Description: RACHEL ANN DABROWA
Status as of 7/17/2023 9:23 AM CST
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/15/2023 1:00:57 PM SENT
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/15/2023 1:00:57 PM SENT
Ronald DHinds rdhinds@verizon.net 7/15/2023 1:00:57 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 7/15/2023 1:00:57 PM SENT
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/15/2023 1:00:57 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/15/2023 1:00:57 PM SENT
RoseMarie Chambers rose.chambers@dlapiper.com 7/15/2023 1:00:57 PM SENT
Judy Calderon judy.calderon@dlapiper.com 7/15/2023 1:00:57 PM SENT
Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 7/15/2023 1:00:57 PM SENT
Taylor Reed Taylor.reed@us.dlapiper.com 7/15/2023 1:00:57 PM SENT
Sally Jones sally.jones@dlapiper.com 7/15/2023 1:00:57 PM SENT
ECFX DLA DLAPiper@ecfxmail.com 7/15/2023 1:00:57 PM SENT
Docket Chicago docketingchicago@dlapiper.com 7/15/2023 1:00:57 PM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 7/15/2023 1:00:57 PM SENT
Associated Case Party: TASACOM TECHNOLOGIES INC
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.
Envelope ID: 77558700
Filing Code Description: Certificate of Deposition
Filing Description: RACHEL ANN DABROWA
Status as of 7/17/2023 9:23 AM CST
Associated Case Party: TASACOM TECHNOLOGIES INC
Name BarNumber Email TimestampSubmitted Status
Benjamin Dunn bdunn@thompsoncoe.com 7/15/2023 1:00:57 PM SENT
Associated Case Party: MMAROOFUL CHOUDHURY
Name BarNumber Email TimestampSubmitted Status
Morgan Wells mwells@thompsoncoe.com 7/15/2023 1:00:57 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Josimayra Diaz josi.diaz@dallascityhall.com 7/15/2023 1:00:57 PM ERROR
Luz Aguilar luz.aguilar@dallascityhall.com 7/15/2023 1:00:57 PM SENT
NURU WITHERSPOON witherspoon@twlglavwerscom 7/15/2023 1:00:57 PM SENT
Ronald DHinds rdhinds@verizon.net 7/15/2023 1:00:57 PM SENT
Sally Jones sally.jones@dlapiper.com 7/15/2023 1:00:57 PM SENT
sherry M.faulkner sherry.faulkner@us.dlapiper.com 7/15/2023 1:00:57 PM SENT
Preview
FILED 7/17/2023 12:00 AM FELICIA PITRE DISTRICT CLERK RACHEL DABROWA May EVANS, SR. V. TASACOM REAL ESTATE magmas-625$ CAUSE NO. DC-21—O4901 TONY EVANS, SR., AND ARETHA IN THE DISTRICT COURT EVANS, INDIVIDUALLY AND ON BEHALF OF THEIR MINOR SON, T.E., DECEASED, FAITH TANKSLEY ON BEHALF OF MINOR 162ND JUDICIAL DISTRICT T.E., III, INDIVIDUALY AND ON BEHALF OF HIS FATHER, T.E., DECEASED, AND DEON WILLIAMS, DALLAS COUNTY, TEXAS Plaintiffs, VS. TASCOM REAL ESTATE, LLC D/B/A lO HAWTHORN SUITES DALLAS LOVE FIELD, HAWTHORN SUITES ll FRANCHISING, INC., WYNDHAM HOTELS & RESORTS, INC., 12 MOHAMMAD SADIQ NOSHAHI, DIAMOND STAFFING SERVICES, l3 LLC, TASACOM TECHNOLOGIES, INC., SANJEEV JAIN AND l4 MMAROOFUL CHOUDHURY, 15 Defendants. l6 l7 REPORTER'S CERTIFICATE 18 DEPOSITION OF RACHEL ANN DABROWA 19 20 21 I, MARINA MAY RAMOS, Digital Reporter and Notary Public for the State of Texas, hereby certify to the 22 following: 23 That the witness, RACHEL ANN DABROWA was duly sworn by me and that the testimony was accurately captured with 24 annotations by me during the proceeding; 25 That the transcript was submitted on 52423 to the Q ESQUIRE 800.21 1 .DEPO (3376) EsquireSqutions. com RACHEL DABROWA May 15, 2023 EVANS, SR. V. TASACOM REAL ESTATE 323 witness for examination, signature, and returned to me by 6-20 , 2023. The amount of time used by each party at the proceeding was as follows: Aubrey Pittman, Esq. — 06:01:10 Emily Taylor, Esq. — 00:00:00 Christopher Donovan, Esq. — 00:00:00 Benjamin Dunn, Esq. — 00:00:00 Jason M. Hopkins, Esq. — 00:00:00 Tasha Barnes, Esq. — 00:00:00 lO ll That $5m7645 is the deposition officer's charges to 12 counsel for preparing the original deposition transcript and any copies and any copies of exhibits; 13 That pursuant to information given to the deposition l4 officer at the time said testimony was taken, the following includes counsel for all parties of record: 15 AUBREY PITTMAN, Esq., Attorney for Plaintiffs 16 EMILY TAYLOR, Esq., Attorney for Plaintiffs CHRISTOPHER DONOVAN, Esq., Attorney for Defendants 17 Hawthorn Suites Dallas Love Field, Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc., and 18 Wyndham Hotel Group, LLC TASHA BARNES, Esq., Attorney for Defendants Tasacom 19 Real Estate, LLC, Mohammad Sadiq Noshahi, Diamond Staffing Services, LLC, Tasacom Technologies, Inc., 20 Sanjeev Jain, and Mmarooful Choudhury BENJAMIN DUNN, Esq., Attorney for Defendants Tasacom 21 Real Estate, LLC, Mohammad Sadiq Noshahi, Diamond Staffing Services, LLC, Tasacom Technologies, Inc., 22 Sanjeev Jain, and Mmarooful Choudhury JASON M. HOPKINS, Esq., Attorney for Defendants 23 Hawthorn Suites Dallas Love Field, Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc., and 24 Wyndham Hotel Group, LLC JASON M. HOPKINS, Esq., Attorney for Defendants 25 Hawthorn Suites Dallas Love Field, Hawthorn Suites Q ESQUIRE 800.21 1 .DEPO (3376) EsquireSqutions. com RACHEL DABROWA May 15, 2023 EVANS, SR. V. TASACOM REAL ESTATE 324 Franchising, Inc., Wyndham Hotels & Resorts, Inc., and Wyndham Hotel Group, LLC I further certify that I am neither counsel for, related to, nor employed by any of the parties or attorneys in the action in which this proceeding was taken, and further that I am not financially or otherwise interested in the outcome of the action. Further certification requirements pursuant to 203 of TCRP will be certified to after they have occurred. Certified to me this 24 May, 2023. Y/ f/ lO MARINA MAY RAMOS Notary Commission No. 13405676—9 ll Commission Expires: November 9, 2026 Firm Registration No. 3 12 13 l4 15 16 17 18 19 20 21 22 23 24 25 Q ESQUIRE 800.21 1 .DEPO (3376) EsquireSqutions. com RACHEL DABROWA May 15, 2023 EVANS, SR. V. TASACOM REAL ESTATE 325 FURTHER CERTIFICATION UNDER RULE 203 TCRP The original deposition was/was not returned to the deposition officer on 62023 , If returned, the attached Change and Signature page contains any changes and the reasons therefore; If returned, the original deposition was delivered to AUBREY PITTMAN, Esq., Custodial Attorney. That $387645 is the depositicm1<3fficer's charges to the custodial party for preparing the original deposition transcript and any copies of exhibits. That the deposition was delivered in accordance with lO Rule 203.3, and that a copy of this certificate was served on all parties shown herein on Z4423 and ll files with the Clerk. 12 Certified to me by this l4 July, 2023 13 l4 l5 l6 MARINA MAY RAMOS Notary Commission No. 13405676—9 l7 Commission Expires: November 9, 2026 Firm Registration No. 3 l8 l9 20 21 22 23 24 25 Q ESQUIRE 800.21 1 .DEPO (3376) EsquireSqutions. com 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. Envelope lD: 77558700 Filing Code Description: Certificate of Deposition Filing Description: RACHEL ANN DABROWA Status as of 7/17/2023 9:23 AM CST Associated Case Party: TONY EVANS Name BarN um ber Email TimestampSubmitted Status Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 7/15/20231:00:57 PM SENT Emily Taylor taylor@twlglawyers.com 7/15/2023 1:00:57 PM SENT Nuru Witherspoon litigation@twlglawyers.com 7/15/2023 1:00:57 PM SENT Associated Case Party: T. E. Name BarN um ber Email TimestampSubmitted Status Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 7/15/20231:00:57 PM SENT Emily Taylor taylor@twlglawyers.com 7/15/2023 1:00:57 PM SENT Nuru Witherspoon litigation@twlglawyers.com 7/15/2023 1:00:57 PM SENT Associated Case Party: ARETHA EVANS Name BarN um ber Email TimestampSubmitted Status Aubrey"Nick" Pittman pittman@thepittmanlawfirm.com 7/15/20231:00:57 PM SENT Emily Taylor taylor@twlglawyers.com 7/15/2023 1:00:57 PM SENT Nuru Witherspoon litigation@twlglawyers.com 7/15/2023 1:00:57 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 7/15/2023 1:00:57 PM SENT LISA V lvillasenor@thompsoncoe.com 7/15/2023 1:00:57 PM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. 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. Envelope ID: 77558700 Filing Code Description: Certificate of Deposition Filing Description: RACHEL ANN DABROWA Status as of 7/17/2023 9:23 AM CST Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/15/2023 1:00:57 PM SENT Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/15/2023 1:00:57 PM SENT Ronald DHinds rdhinds@verizon.net 7/15/2023 1:00:57 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 7/15/2023 1:00:57 PM SENT Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/15/2023 1:00:57 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/15/2023 1:00:57 PM SENT RoseMarie Chambers rose.chambers@dlapiper.com 7/15/2023 1:00:57 PM SENT Judy Calderon judy.calderon@dlapiper.com 7/15/2023 1:00:57 PM SENT Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 7/15/2023 1:00:57 PM SENT Taylor Reed Taylor.reed@us.dlapiper.com 7/15/2023 1:00:57 PM SENT Sally Jones sally.jones@dlapiper.com 7/15/2023 1:00:57 PM SENT ECFX DLA DLAPiper@ecfxmail.com 7/15/2023 1:00:57 PM SENT Docket Chicago docketingchicago@dlapiper.com 7/15/2023 1:00:57 PM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 7/15/2023 1:00:57 PM SENT Associated Case Party: TASACOM TECHNOLOGIES INC 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. Envelope ID: 77558700 Filing Code Description: Certificate of Deposition Filing Description: RACHEL ANN DABROWA Status as of 7/17/2023 9:23 AM CST Associated Case Party: TASACOM TECHNOLOGIES INC Name BarNumber Email TimestampSubmitted Status Benjamin Dunn bdunn@thompsoncoe.com 7/15/2023 1:00:57 PM SENT Associated Case Party: MMAROOFUL CHOUDHURY Name BarNumber Email TimestampSubmitted Status Morgan Wells mwells@thompsoncoe.com 7/15/2023 1:00:57 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Josimayra Diaz josi.diaz@dallascityhall.com 7/15/2023 1:00:57 PM ERROR Luz Aguilar luz.aguilar@dallascityhall.com 7/15/2023 1:00:57 PM SENT NURU WITHERSPOON witherspoon@twlglavwerscom 7/15/2023 1:00:57 PM SENT Ronald DHinds rdhinds@verizon.net 7/15/2023 1:00:57 PM SENT Sally Jones sally.jones@dlapiper.com 7/15/2023 1:00:57 PM SENT sherry M.faulkner sherry.faulkner@us.dlapiper.com 7/15/2023 1:00:57 PM SENT