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
8/28/2023 10:37 AM
FELICIA PITRE
DISTRICT CLERK
ANUJ ARORA CO" TEXAS
July 24, 92-33AS LY“°h DEPUTY
TONY EVANS VS TASACOM REAL ESTATE “fir?“f’g
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, )
)
Plaintiff, )
) 162ND JUDICIAL DISTRICT
VS )
)
lO TASACOM REAL ESTATE, )
LLc D/B/A HAWTHORN )
ll SUITES DALLAS LOVE )
FIELD, HAWTHORN SUITES )
12 FRANCHISING, INC., )
WYNDHAM HOTELS & )
l3 RESORTS, INC., MOHAMMAD )
SADIQ NOSHAHI, DIAMOND )
l4 STAFFING SERVICES, LLC, )
WYNDHAM HOTEL GROUP, )
15 LLC, TASACOM )
TECHNOLOGIES, INC., )
l6 SANJEEV JAIN AND )
MMAROOFUL CHOUDHURY, )
l7 )
Defendants. ) DALLAS COUNTY, TEXAS
l8
l9 REPORTER'S CERTIFICATE
20 I, Lisa J. Gretarsson, Certified Shorthand
21 Reporter in and for the State of Texas, hereby
22 certify to the following:
23 That the witness, ANUJ ARORA, was duly sworn
24 by the officer and that the transcript of the oral
25 deposition is a true record of the testimony given
Q ESQUIRE 800.211.DEPO (3376)
EsquireSqutions. com
ANUJ ARORA July 24, 2023
TONY EVANS vs TASACOM REAL ESTATE 179
by the witness;
That the deposition transcript was submitted
on August lO, 2023, to the witness or to the
attorney for the witness for examination, signature
and return to me by September 6, 2023;
That the amount of time used by each party at
the deposition is as follows:
Aubrey Pittman —
4:20
Christopher B. Donovan —
0:00
Benjamin Dunn —
0:00
lO
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12
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l4
15
l6
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Q ESQUIRE 800.211.0590 (3376)
EsquireSqutions. com
ANUJ ARORA July 24, 2023
TONY EVANS vs TASACOM REAL ESTATE 180
That pursuant to information given to the
deposition officer at the time said testimony was
taken, the following includes counsel for all
parties of record.
Aubrey Pittman, Attorney for Plaintiff
Christopher B. Donovan, Attorney for Defendant
Benjamin dunn, Attorney for Defendant
I further certify that I am neither counsel
for, related to, nor employed by any of the parties
10 or attorneys in the action in which this proceeding
ll was taken, and further that I am not financially or
12 otherwise interested in the outcome of the action.
l3 Further certification requirements pursuant to
14 Rule 203 of TRCP will be certified to after they
15 have occurred.
l6 Certified to by me this lO day of August,
l7 2023.
18
m... Um in!
19
Lisa J. Gretarsson, CSR, RPR, CRR
2O Texas Certification No. 4486
Expiration Date: April 30, 2024
21
22
23
24
25
Q ESQUIRE 800.211.0590 (3376)
EsquireSqutions. com
ANUJ ARORA July 24, 2023
TONY EVANS vs TASACOM REAL ESTATE 181
FURTHER CERTIFICATION UNDER RULE 203 TRCP
Theoriginal deposition was returned
to the deposition officer on 8/28/2023 ;
If returned, the attached Changes and
Signature page contains any changes and the reasons
therefor;
If returned, the original deposition was
delivered to Aubrey Pittman, Custodial Attorney;
That $184060 deposition officer's
is the
lO charges to the Plaintiff for preparing the original
ll deposition transcript and any copies of exhibits;
l2 That the deposition was delivered in
l3 accordance with Rule 203.3, and that a copy of this
l4 certificate was served on all parties shown herein
15 on and filed with the Clerk.
l6 Certified to by me this 2&h day of
l7 August , 2023.
l8
figmg fimmw
l9
2O
Lisa J. Brannon, CSR, RPR, CRR
21 Texas Certification No. 4486
Expiration Date: April 30, 2024
22
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Q ESQUIRE 800.211.0590 (3376)
EsquireSqutions. com
DocuSign Envelope ID: 6726686D-18A5-400F-91A6-11BE74A13012
ANUJ ARORA July 24, 2023
TONY EVANS vs TASACOM REAL ESTATE 176
CHANGES AND SIGNATURE
12345678
WITNESS NAME: ANUJ ARORA
DATE TAKEN: JULY 24, 2023
PAGE LINE CORRECT ION REASON
Pg 8 16 22 Sylvan Way Incorrect Address
Replace property with Hotel lncorreCt
Pg 9 7
pg 1 1 6 Replace H3M with HVM Incorrect
pg 14 13 Replace resourced to a resource Incorrect
Pg 65 12 Replace My Program with My Portal Incorrect
10 Pg 156 16 Replace difficult with typical Incorrect
ll
12
l3
l4
15
l6
l7
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l9
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Q ESQUIRE 800.211.DEPO (3376)
EsquireSqutions. com
DocuSign Envelope ID: 6726686D-18A5-400F-91A6-11BE74A13012
June 25, 1979
My name is Anuj Arora, my date of birth is and
4917 Kess1er Dr, Frisco, TX 75033 USA
my address is
(Street) (City) (State) (Country)
I declare under penalty of perjury that the foregoing is true and correct.
, Denton Texas
Executed 1n County, State of ,
on the 28th day of Augus" ,2023.
DocuSigned by:
[1mm
‘ am,
Declarant, Anuj Arora
Tex. CiV. Prac. And Rem. Code Ann. §132.001(d)(West 2016).
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: 78965175
Filing Code Description: Certificate of Deposition
Filing Description: ANUJ ARORA
Status as of 8/29/2023 9:54 AM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 8/28/2023 10:37:31 AM SENT
Nuru Witherspoon litigation@twlglawyers.com 8/28/2023 10:37:31 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/28/2023 10:37:31 AM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 8/28/2023 10:37:31 AM SENT
LISA V lvillasenor@thompsoncoe.com 8/28/2023 10:37:31 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Josimayra Diaz josi.diaz@dallascityhall.com 8/28/2023 10:37:31 AM SENT
Luz Aguilar luz.aguilar@dallascityhall.com 8/28/2023 10:37:31 AM SENT
Ronald DHinds rdhinds@verizon.net 8/28/2023 10:37:31 AM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/28/2023 10:37:31 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/28/2023 10:37:31 AM SENT
Ronald DHinds rdhinds@verizon.net 8/28/2023 10:37:31 AM 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 ID: 78965175
Filing Code Description: Certificate of Deposition
Filing Description: ANUJ ARORA
Status as of 8/29/2023 9:54 AM CST
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/28/2023 10:37:31 AM SENT
RoseMarie Chambers rose.chambers@dlapiper.com 8/28/2023 10:37:31 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/28/2023 10:37:31 AM SENT
Ronald DHinds rdhinds@verizon.net 8/28/2023 10:37:31 AM SENT
Judy Calderon judy.calderon@dlapiper.com 8/28/2023 10:37:31 AM SENT
Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 8/28/2023 10:37:31 AM SENT
Sally Jones sally.jones@dlapiper.com 8/28/2023 10:37:31 AM SENT
Taylor Reed Taylor.reed@us.dlapiper.com 8/28/2023 10:37:31 AM SENT
ECFX DLA DLAPiper@ecfxmail.com 8/28/2023 10:37:31 AM SENT
Docket Chicago docketingchicago@dlapiper.com 8/28/2023 10:37:31 AM SENT
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 8/28/2023 10:37:31 AM SENT
Nuru Witherspoon litigation@twlglawyers.com 8/28/2023 10:37:31 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/28/2023 10:37:31 AM SENT
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 8/28/2023 10:37:31 AM SENT
Nuru Witherspoon litigation@twlglawyers.com 8/28/2023 10:37:31 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.
Envelope ID: 78965175
Filing Code Description: Certificate of Deposition
Filing Description: ANUJ ARORA
Status as of 8/29/2023 9:54 AM CST
Associated Case Party: ARETHA EVANS
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/28/2023 10:37:31 AM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 8/28/2023 10:37:31 AM SENT
Associated Case Party: MMAROOFUL CHOUDHURY
Name BarNumber Email TimestampSubmitted Status
Morgan Wells mwells@thompsoncoe.com 8/28/2023 10:37:31 AM SENT
Associated Case Party: TASACOM TECHNOLOGIES INC
Name BarNumber Email TimestampSubmitted Status
Benjamin Dunn bdunn@thompsoncoe.com 8/28/2023 10:37:31 AM SENT
Preview
FILED 8/28/2023 10:37 AM FELICIA PITRE DISTRICT CLERK ANUJ ARORA CO" TEXAS July 24, 92-33AS LY“°h DEPUTY TONY EVANS VS TASACOM REAL ESTATE “fir?“f’g 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, ) ) Plaintiff, ) ) 162ND JUDICIAL DISTRICT VS ) ) lO TASACOM REAL ESTATE, ) LLc D/B/A HAWTHORN ) ll SUITES DALLAS LOVE ) FIELD, HAWTHORN SUITES ) 12 FRANCHISING, INC., ) WYNDHAM HOTELS & ) l3 RESORTS, INC., MOHAMMAD ) SADIQ NOSHAHI, DIAMOND ) l4 STAFFING SERVICES, LLC, ) WYNDHAM HOTEL GROUP, ) 15 LLC, TASACOM ) TECHNOLOGIES, INC., ) l6 SANJEEV JAIN AND ) MMAROOFUL CHOUDHURY, ) l7 ) Defendants. ) DALLAS COUNTY, TEXAS l8 l9 REPORTER'S CERTIFICATE 20 I, Lisa J. Gretarsson, Certified Shorthand 21 Reporter in and for the State of Texas, hereby 22 certify to the following: 23 That the witness, ANUJ ARORA, was duly sworn 24 by the officer and that the transcript of the oral 25 deposition is a true record of the testimony given Q ESQUIRE 800.211.DEPO (3376) EsquireSqutions. com ANUJ ARORA July 24, 2023 TONY EVANS vs TASACOM REAL ESTATE 179 by the witness; That the deposition transcript was submitted on August lO, 2023, to the witness or to the attorney for the witness for examination, signature and return to me by September 6, 2023; That the amount of time used by each party at the deposition is as follows: Aubrey Pittman — 4:20 Christopher B. Donovan — 0:00 Benjamin Dunn — 0:00 lO ll 12 l3 l4 15 l6 l7 l8 l9 20 21 22 23 24 25 Q ESQUIRE 800.211.0590 (3376) EsquireSqutions. com ANUJ ARORA July 24, 2023 TONY EVANS vs TASACOM REAL ESTATE 180 That pursuant to information given to the deposition officer at the time said testimony was taken, the following includes counsel for all parties of record. Aubrey Pittman, Attorney for Plaintiff Christopher B. Donovan, Attorney for Defendant Benjamin dunn, Attorney for Defendant I further certify that I am neither counsel for, related to, nor employed by any of the parties 10 or attorneys in the action in which this proceeding ll was taken, and further that I am not financially or 12 otherwise interested in the outcome of the action. l3 Further certification requirements pursuant to 14 Rule 203 of TRCP will be certified to after they 15 have occurred. l6 Certified to by me this lO day of August, l7 2023. 18 m... Um in! 19 Lisa J. Gretarsson, CSR, RPR, CRR 2O Texas Certification No. 4486 Expiration Date: April 30, 2024 21 22 23 24 25 Q ESQUIRE 800.211.0590 (3376) EsquireSqutions. com ANUJ ARORA July 24, 2023 TONY EVANS vs TASACOM REAL ESTATE 181 FURTHER CERTIFICATION UNDER RULE 203 TRCP Theoriginal deposition was returned to the deposition officer on 8/28/2023 ; If returned, the attached Changes and Signature page contains any changes and the reasons therefor; If returned, the original deposition was delivered to Aubrey Pittman, Custodial Attorney; That $184060 deposition officer's is the lO charges to the Plaintiff for preparing the original ll deposition transcript and any copies of exhibits; l2 That the deposition was delivered in l3 accordance with Rule 203.3, and that a copy of this l4 certificate was served on all parties shown herein 15 on and filed with the Clerk. l6 Certified to by me this 2&h day of l7 August , 2023. l8 figmg fimmw l9 2O Lisa J. Brannon, CSR, RPR, CRR 21 Texas Certification No. 4486 Expiration Date: April 30, 2024 22 23 24 25 Q ESQUIRE 800.211.0590 (3376) EsquireSqutions. com DocuSign Envelope ID: 6726686D-18A5-400F-91A6-11BE74A13012 ANUJ ARORA July 24, 2023 TONY EVANS vs TASACOM REAL ESTATE 176 CHANGES AND SIGNATURE 12345678 WITNESS NAME: ANUJ ARORA DATE TAKEN: JULY 24, 2023 PAGE LINE CORRECT ION REASON Pg 8 16 22 Sylvan Way Incorrect Address Replace property with Hotel lncorreCt Pg 9 7 pg 1 1 6 Replace H3M with HVM Incorrect pg 14 13 Replace resourced to a resource Incorrect Pg 65 12 Replace My Program with My Portal Incorrect 10 Pg 156 16 Replace difficult with typical Incorrect ll 12 l3 l4 15 l6 l7 18 l9 20 21 22 23 24 25 Q ESQUIRE 800.211.DEPO (3376) EsquireSqutions. com DocuSign Envelope ID: 6726686D-18A5-400F-91A6-11BE74A13012 June 25, 1979 My name is Anuj Arora, my date of birth is and 4917 Kess1er Dr, Frisco, TX 75033 USA my address is (Street) (City) (State) (Country) I declare under penalty of perjury that the foregoing is true and correct. , Denton Texas Executed 1n County, State of , on the 28th day of Augus" ,2023. DocuSigned by: [1mm ‘ am, Declarant, Anuj Arora Tex. CiV. Prac. And Rem. Code Ann. §132.001(d)(West 2016). 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: 78965175 Filing Code Description: Certificate of Deposition Filing Description: ANUJ ARORA Status as of 8/29/2023 9:54 AM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 8/28/2023 10:37:31 AM SENT Nuru Witherspoon litigation@twlglawyers.com 8/28/2023 10:37:31 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/28/2023 10:37:31 AM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 8/28/2023 10:37:31 AM SENT LISA V lvillasenor@thompsoncoe.com 8/28/2023 10:37:31 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Josimayra Diaz josi.diaz@dallascityhall.com 8/28/2023 10:37:31 AM SENT Luz Aguilar luz.aguilar@dallascityhall.com 8/28/2023 10:37:31 AM SENT Ronald DHinds rdhinds@verizon.net 8/28/2023 10:37:31 AM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/28/2023 10:37:31 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/28/2023 10:37:31 AM SENT Ronald DHinds rdhinds@verizon.net 8/28/2023 10:37:31 AM 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 ID: 78965175 Filing Code Description: Certificate of Deposition Filing Description: ANUJ ARORA Status as of 8/29/2023 9:54 AM CST Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/28/2023 10:37:31 AM SENT RoseMarie Chambers rose.chambers@dlapiper.com 8/28/2023 10:37:31 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/28/2023 10:37:31 AM SENT Ronald DHinds rdhinds@verizon.net 8/28/2023 10:37:31 AM SENT Judy Calderon judy.calderon@dlapiper.com 8/28/2023 10:37:31 AM SENT Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 8/28/2023 10:37:31 AM SENT Sally Jones sally.jones@dlapiper.com 8/28/2023 10:37:31 AM SENT Taylor Reed Taylor.reed@us.dlapiper.com 8/28/2023 10:37:31 AM SENT ECFX DLA DLAPiper@ecfxmail.com 8/28/2023 10:37:31 AM SENT Docket Chicago docketingchicago@dlapiper.com 8/28/2023 10:37:31 AM SENT Associated Case Party: T. E. Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 8/28/2023 10:37:31 AM SENT Nuru Witherspoon litigation@twlglawyers.com 8/28/2023 10:37:31 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/28/2023 10:37:31 AM SENT Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 8/28/2023 10:37:31 AM SENT Nuru Witherspoon litigation@twlglawyers.com 8/28/2023 10:37:31 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. Envelope ID: 78965175 Filing Code Description: Certificate of Deposition Filing Description: ANUJ ARORA Status as of 8/29/2023 9:54 AM CST Associated Case Party: ARETHA EVANS Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/28/2023 10:37:31 AM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 8/28/2023 10:37:31 AM SENT Associated Case Party: MMAROOFUL CHOUDHURY Name BarNumber Email TimestampSubmitted Status Morgan Wells mwells@thompsoncoe.com 8/28/2023 10:37:31 AM SENT Associated Case Party: TASACOM TECHNOLOGIES INC Name BarNumber Email TimestampSubmitted Status Benjamin Dunn bdunn@thompsoncoe.com 8/28/2023 10:37:31 AM SENT