On April 16, 2021 a
Party Discovery
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
FILED
7/20/2023 1:01 PM
FELICIA PITRE
DISTRICT CLERK
SAAJAN PATEL June 26, a 3fiitfi§is$fi$$
TONY EVANS vs TASACOM REAL ESTATE a a
CAUSE NO. DC-21—O490l
TONY EVANS, SR., and ) IN THE DISTRICT COURT
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, )
)
Plaintiffs )
)
vs. ) 162nd JUDICIAL DISTRICT
lO )
TASACOM REAL ESTATE, LLc )
ll d/b/a HAWTHORN SUITES )
DALLAS LOVE FIELD, )
12 HAWTHORN SUITES )
FRANCHISING, INC., WYNDHAM)
l3 HOTEL & RESORTS, INC., )
MOHAMMAD SADIQ NOSHAHI, )
l4 DIAMOND STAFFING SERVICES,)
LLc, WYNDHAM HOTEL GROUP, )
15 LLC, TASACOM TECHNOLOGIES,)
INc., SANJEEV JAIN and )
l6 MMAROOFUL CHOUDHURY, )
)
l7 Defendants. ) DALLAS COUNTY, TEXAS
l8
l9 REPORTER'S CERTIFICATE
20 ORAL AND VIDEOTAPED DEPOSITION OF
21 SAAJAN PATEL
22 JUNE 26, 2023
23 (reported remotely)
24
25
Q ESQUIRE 800.211.DEPO (3376)
EsquireSqutions. com
SAAJAN PATEL June 26, 2023
TONY EVANS vs TASACOM REAL ESTATE 185
I, Melanie Smith, Certified Shorthand Reporter in
and for the State of Texas, hereby certify to the
following:
That the witness, SAAJAN PATEL, was duly sworn and
that the transcript of the deposition is a true record
of the testimony given by the witness;
That the deposition transcript was duly submitted on
'W30023 to the witness or to the attorney for
the witness for examination, signature and returned to
10 me by 7/30/2023 .
ll That pursuant to information given to the deposition
12 officer at the time said testimony was taken, the
l3 following includes all parties of record and the amount
l4 of time used by each party at the time of the
15 deposition:
l6 Ms. Emily Taylor (3hour, 53minutes)
Attorney for PLAINTIFFS
l7 Mr. Christopher Donovan (Ohour, Ominutes)
Attorney for DEFENDANTS WYNDHAM HOTELS &
18 RESORTS, INCORPORATED, WYNDHAM HOTEL GROUP,
LLC, AND HAWTHORN SUITES FRANCHISING, INC. AND
l9 THE WITNESS
Mr. David Sager (Ohour, Ominutes)
20 Attorney for DEFENDANTS WYNDHAM HOTELS &
RESORTS, INCORPORATED, WYNDHAM HOTEL GROUP,
21 LLC, AND HAWTHORN SUITES FRANCHISING, INC. AND
THE WITNESS
22 Mr. Benjamin Dunn (Ohour, Ominutes)
Attorney for DEFENDANTS TASACOM REAL ESTATE,
23 LLC, MOHAMMAD SADIQ NOSHAHI, DIAMOND STAFFING
SERVICES, LLC, TASACOM TECHNOLOGIES,
24 INCORPORATED, SANJEEV JAIN, AND MMAROOFUL
CHOUDHURY
25
Q ESQUIRE 800.211.0590 (3376)
EsquireSqutions. com
SAAJAN PATEL June 26, 2023
TONY EVANS vs TASACOM REAL ESTATE 186
I further certify that I am neither counsel for,
related to, nor employed by any of the parties in the
action in which this proceeding was taken, and further
that I am not financially or otherwise interested in the
outcome of this action.
Further certification requirements pursuant to
Rule 203 of the Texas Code of Civil Procedure will be
complied with after they have occurred.
Certified to by me on this 3rd day of
10 July, 2023.
ll
12
13
14
15 MELMWSMLCPV
16 Melanie Smith, CSR
Texas CSR 7954
17 Expiration: 04/30/2025
Court Reporting & Litigation Support
18 Firm Registration No. 821
2208 Judson Road, Suite 104
19 Longview, Texas 75605
(903)758—2183
20 (877)683—2889 FAX
E—mail: services@courtreportingls.com
21
22
23
24
25
Q ESQUIRE 800.211.0590 (3376)
EsquireSqutions. com
SAAJAN PATEL June 26, 2023
TONY EVANS vs TASACOM REAL ESTATE 187
FURTHER CERTIFICATION UNDER TRCP RULE 203
The original deposition was returned to the
deposition officer on 7/20/2023 .
If returned, the attached Changes and Signature
page(s) contain(s) any changes and the reasons therefor.
If returned, the original deposition was delivered
to Ms. Emily Long, Custodial Attorney.
$249&15 is the deposition officer's charges to the
10 Plaintiffs for preparing the original deposition and any
ll copies of exhibits;
12 The deposition was delivered in accordance with
13 Rule 203.3, and a copy of this certificate, served on
14 all parties shown herein, was filed with the Clerk.
15 Certified to by me on this 20m day of
16 July , 2023 .
17
18
19
Melanie Smith, CSR
2O Texas CSR 7954
Expiration: 04/30/2025
21 Court Reporting & Litigation Support
Firm Registration No. 821
22 2208 Judson Road, Suite 104
Longview, Texas 75605
23 (903)758—2183
(877)683—2889 FAX
24 E—mail: services@courtreportingls.com
25
Q ESQUIRE 800.211.0590 (3376)
EsquireSqutions. com
ERRATA FOR DEPOSITION 0F SAAJAN PATEL
- Page 13 Line 24
Change “That’s not me” to “That’s me”
Reason: Typographical error
- Page 39 Line 20
Change “We used 10 percent” to “I got 10 percent”
Reason: Missooke
- Page 75 Lines 12-13
Change “the houser has” to “they house any”
Reason: Tvnoaranhical error/missooke
- Page 104 Line 24-25
Change “agreed wi
” to
“grad
”
Reason: Tvnoaranhical error
- Page 124 Line 24
Change “creating” to “grading”
Reason: Tvnomohical error
- Page 136 Line 12
Change “wo
” to
“working”
Reason: Tvnogranhical ermr/missmke
STATE or TEXAS
_LL/_rJ
COUNTY OF do
SAAJAN PATEL,
4 ”MEL IQ. WA
Before me, , on this day personally appeared
known to me or proved to me on the oath of 01’
through $712045 DL :5: __ (description of identity card or other document)
to be the person whose name is subscribed to the foregoing instrument and acknowledged to me
that he/she executed the same for the purpose and consideration therein expressed
Given under mv hand and seal ofoffice on this P‘w/ __ _ day of July 2023.
I SAAJAN PATEL. have read the foregoing deposition and hereby affix my signature
mat same is true and correct. excent as noted above.
SAAJ PATEL
Sworn to and subscribed before me this 207$): of July 2023.
W4M,
NOTARY PUBLIC
My Commission Expires: / 745/ 2';
MICHAEL R GORDON »
Notary Public
STATE OF TEXAS
Iomonsaa-o I
M Comm. Exa. Dec. 3. 2025
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: 77719930
Filing Code Description: Certificate of Deposition
Filing Description: OF SAAJAN PATEL
Status as of 7/21/2023 8:38 AM CST
Associated Case Party: TONY EVANS
Name BarN um ber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 7/20/2023 1:01 :58 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 7/20/2023 1:01:58 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 7/20/20231:O1:58 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 7/20/2023 1:01:58 PM SENT
LISA V lvillasenor@thompsoncoe.com 7/20/2023 1:01:58 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Josimayra Diaz josi.diaz@dallascityhall.com 7/20/2023 1:01:58 PM SENT
Luz Aguilar luz.aguilar@dallascityhall.com 7/20/2023 1:01:58 PM SENT
Ronald DHinds rdhinds@verizon.net 7/20/2023 1:01:58 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/20/2023 1:01:58 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/20/2023 1:01:58 PM SENT
Ronald DHinds rdhinds@verizon.net 7/20/2023 1:01:58 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, 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 lD: 77719930
Filing Code Description: Certificate of Deposition
Filing Description: OF SAAJAN PATEL
Status as of 7/21/2023 8:38 AM CST
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 7/20/2023 1:01 :58 PM SENT
RoseMarie Chambers rose.chambers@dlapiper.com 7/20/2023 1:01:58 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 7/20/2023 1:01:58 PM SENT
Ronald DHinds rdhinds@verizon.net 7/20/2023 1:01:58 PM SENT
Judy Calderon judy.calderon@dlapiper.com 7/20/2023 1:01:58 PM SENT
Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 7/20/2023 1:01:58 PM SENT
Sally Jones sally.jones@dlapiper.com 7/20/2023 1:01:58 PM SENT
Taylor Reed Taylor.reed@us.dlapiper.com 7/20/2023 1:01:58 PM SENT
ECFX DLA DLAPiper@ecfxmail.com 7/20/2023 1:01:58 PM SENT
Docket Chicago docketingchicago@dlapiper.com 7/20/2023 1:01:58 PM SENT
Associated Case Party: T. E.
Name BarN um ber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 7/20/2023 1:01:58 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 7/20/2023 1:01:58 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 7/20/20231:01:58 PM SENT
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 7/20/2023 1:01:58 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 7/20/2023 1:01:58 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.
Envelope lD: 77719930
Filing Code Description: Certificate of Deposition
Filing Description: OF SAAJAN PATEL
Status as of 7/21/2023 8:38 AM CST
Associated Case Party: ARETHA EVANS
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 7/20/2023 1:01 :58 PM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 7/20/2023 1:01:58 PM SENT
Associated Case Party: MMAROOFUL CHOUDHURY
Name BarNumber Email TimestampSubmitted Status
Morgan Wells mwells@thompsoncoe.com 7/20/2023 1:01:58 PM SENT
Associated Case Party: TASACOM TECHNOLOGIES INC
Name BarNumber Email TimestampSubmitted Status
Benjamin Dunn bdunn@thompsoncoe.com 7/20/2023 1:01:58 PM SENT