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-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.
2
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
ORDER ON
PLAIN TIFFS’ MOTION TO STRIKE (AND OBJECTIONS TO) WYNDHAM
DEFENDANTS’ EVIDENCE IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT
Came on to be heard Plaintiffs’ objections to, and motion to strike, evidence submitted by
Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc. and Wyndham Hotel
Group, LLC in support of the Motion for Summary Judgment. After considering the motion, objections
and argument of counsel, the Court rules follows:
l. As to the legal conclusions on Page 2 of the Motion, the objection is hereby:
SUSTAINED: OVERRULED:
2. As to the legal conclusions on Page 3 of the Motion, the objection is hereby:
SUSTAINED: OVERRULED:
Page 1 of 2
3. As to the legal conclusions on Page 3 of the Motion, the objection is hereby:
SUSTAINED: OVERRULED:
4. As to the legal conclusions on Page 4 of the Motion, the objection is hereby:
SUSTAINED: OVERRULED:
5. As to the legal conclusions on Page 6—7 of the Motion, the objection is hereby:
SUSTAINED: OVERRULED:
6. As to the legal conclusions on Page 7-8 of the Motion, the objection is hereby:
SUSTAINED: OVERRULED:
7. As to Paragraph 5 of the Declaration of Rachel Dabrowa, the objection is hereby:
SUSTAINED: OVERRULED:
8. As to Paragraph 6 of the Declaration of Rachel Dabrowa, the objection is hereby:
SUSTAINED: OVERRULED:
9. As to all portions of the Deposition of Deon Williams that are not specifically referenced
in the Motion, the objection is hereby:
SUSTAINED: OVERRULED:
SIGNED this day of 2023.
PRESIDING JUDGE
ORDER ON PLAINTIFFS’ OBJECTIONS TO
DEFENDANTS’ SUMMARY JUDGMENT EVIDENCE - 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: 78673002
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED ORDER ON PLTF/MOTION STRIKE &
OBJECTION
Status as of 8/21/2023 9:32 AM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 8/18/2023 9:59:01 AM SENT
Nuru Witherspoon litigation@twlglawyers.com 8/18/2023 9:59:01 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/18/2023 9:59:01 AM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 8/18/2023 9:59:01 AM SENT
LISA V IvilIasenor@thompsoncoe.com 8/18/2023 9:59:01 AM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/18/2023 9:59:01 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/18/2023 9:59:01 AM SENT
Ronald DHinds rdhinds@verizon.net 8/18/2023 9:59:01 AM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/18/2023 9:59:01 AM SENT
RoseMarie Chambers rose.chambers@dlapiper.com 8/18/2023 9:59:01 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/18/2023 9:59:01 AM 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: 78673002
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED ORDER ON PLTF/MOTION STRIKE &
OBJECTION
Status as of 8/21/2023 9:32 AM CST
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Judy Calderon judy.calderon@dlapiper.com 8/18/2023 9:59:01 AM SENT
Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 8/18/2023 9:59:01 AM SENT
Sally Jones sally.jones@dlapiper.com 8/18/2023 9:59:01 AM SENT
Taylor Reed Taylor.reed@us.dlapiper.com 8/18/2023 9:59:01 AM SENT
ECFX DLA DLAPiper@ecfxmail.com 8/18/2023 9:59:01 AM SENT
Docket Chicago docketingchicago@dlapiper.com 8/18/2023 9:59:01 AM SENT
Associated Case Party: T. E.
Name BarN um ber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 8/18/2023 9:59:01 AM SENT
Nuru Witherspoon litigation@twlglawyers.com 8/18/2023 9:59:01 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/18/2023 9:59:01 AM SENT
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 8/18/2023 9:59:01 AM SENT
Nuru Witherspoon Iitigation@twlglawyers.com 8/18/2023 9:59:01 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/18/2023 9:59:01 AM SENT
Associated Case Party: TASACOM TECHNOLOGIES INC
Name BarNumber Email TimestampSubmitted Status
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: 78673002
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED ORDER ON PLTF/MOTION STRIKE &
OBJECTION
Status as of 8/21/2023 9:32 AM CST
Associated Case Party: TASACOM TECHNOLOGIES INC
Benjamin Dunn bdunn@thompsoncoe.com 8/18/2023 9:59:01 AM SENT
Associated Case Party: MMAROOFUL CHOUDHURY
Name BarNumber Email TimestampSubmitted Status
Morgan Wells mwells@thompsoncoe.com 8/18/2023 9:59:01 AM SENT
Preview
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. 2 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 ORDER ON PLAIN TIFFS’ MOTION TO STRIKE (AND OBJECTIONS TO) WYNDHAM DEFENDANTS’ EVIDENCE IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT Came on to be heard Plaintiffs’ objections to, and motion to strike, evidence submitted by Defendants Hawthorn Suites Franchising, Inc., Wyndham Hotels & Resorts, Inc. and Wyndham Hotel Group, LLC in support of the Motion for Summary Judgment. After considering the motion, objections and argument of counsel, the Court rules follows: l. As to the legal conclusions on Page 2 of the Motion, the objection is hereby: SUSTAINED: OVERRULED: 2. As to the legal conclusions on Page 3 of the Motion, the objection is hereby: SUSTAINED: OVERRULED: Page 1 of 2 3. As to the legal conclusions on Page 3 of the Motion, the objection is hereby: SUSTAINED: OVERRULED: 4. As to the legal conclusions on Page 4 of the Motion, the objection is hereby: SUSTAINED: OVERRULED: 5. As to the legal conclusions on Page 6—7 of the Motion, the objection is hereby: SUSTAINED: OVERRULED: 6. As to the legal conclusions on Page 7-8 of the Motion, the objection is hereby: SUSTAINED: OVERRULED: 7. As to Paragraph 5 of the Declaration of Rachel Dabrowa, the objection is hereby: SUSTAINED: OVERRULED: 8. As to Paragraph 6 of the Declaration of Rachel Dabrowa, the objection is hereby: SUSTAINED: OVERRULED: 9. As to all portions of the Deposition of Deon Williams that are not specifically referenced in the Motion, the objection is hereby: SUSTAINED: OVERRULED: SIGNED this day of 2023. PRESIDING JUDGE ORDER ON PLAINTIFFS’ OBJECTIONS TO DEFENDANTS’ SUMMARY JUDGMENT EVIDENCE - 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: 78673002 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED ORDER ON PLTF/MOTION STRIKE & OBJECTION Status as of 8/21/2023 9:32 AM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 8/18/2023 9:59:01 AM SENT Nuru Witherspoon litigation@twlglawyers.com 8/18/2023 9:59:01 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/18/2023 9:59:01 AM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 8/18/2023 9:59:01 AM SENT LISA V IvilIasenor@thompsoncoe.com 8/18/2023 9:59:01 AM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/18/2023 9:59:01 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/18/2023 9:59:01 AM SENT Ronald DHinds rdhinds@verizon.net 8/18/2023 9:59:01 AM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/18/2023 9:59:01 AM SENT RoseMarie Chambers rose.chambers@dlapiper.com 8/18/2023 9:59:01 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/18/2023 9:59:01 AM 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: 78673002 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED ORDER ON PLTF/MOTION STRIKE & OBJECTION Status as of 8/21/2023 9:32 AM CST Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Judy Calderon judy.calderon@dlapiper.com 8/18/2023 9:59:01 AM SENT Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 8/18/2023 9:59:01 AM SENT Sally Jones sally.jones@dlapiper.com 8/18/2023 9:59:01 AM SENT Taylor Reed Taylor.reed@us.dlapiper.com 8/18/2023 9:59:01 AM SENT ECFX DLA DLAPiper@ecfxmail.com 8/18/2023 9:59:01 AM SENT Docket Chicago docketingchicago@dlapiper.com 8/18/2023 9:59:01 AM SENT Associated Case Party: T. E. Name BarN um ber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 8/18/2023 9:59:01 AM SENT Nuru Witherspoon litigation@twlglawyers.com 8/18/2023 9:59:01 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/18/2023 9:59:01 AM SENT Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 8/18/2023 9:59:01 AM SENT Nuru Witherspoon Iitigation@twlglawyers.com 8/18/2023 9:59:01 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/18/2023 9:59:01 AM SENT Associated Case Party: TASACOM TECHNOLOGIES INC Name BarNumber Email TimestampSubmitted Status 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: 78673002 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED ORDER ON PLTF/MOTION STRIKE & OBJECTION Status as of 8/21/2023 9:32 AM CST Associated Case Party: TASACOM TECHNOLOGIES INC Benjamin Dunn bdunn@thompsoncoe.com 8/18/2023 9:59:01 AM SENT Associated Case Party: MMAROOFUL CHOUDHURY Name BarNumber Email TimestampSubmitted Status Morgan Wells mwells@thompsoncoe.com 8/18/2023 9:59:01 AM SENT