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
FILED
8/25/2023 12:08 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Kellie Juricek DEPUTY
CAUSE NO. DC-21-04901
TONY EVANS, SR., and ARETHA EVANS, IN THE DISTRICT COURT OF
§§§§§§§§§§§§§§
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
DALLAS COUNTY, TEXAS
Plaintiffv,
VS.
TASACOM REAL ESTATE, LLC, ET AL.
Defendants. 162m JUDICIAL DISTRICT
DEFENDANTS WYNDHAM HOTELS & RESORTS, INC., WYNDHAM HOTEL
GROUP, LLC, AND HAWTHORN SUITES FRANCHISING, INC.’S
RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE
(AND OBJECTIONS TO) WYNDHAM DEFENDANTS’ EVIDENCE IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT
Defendants Wyndham Hotels & Resorts, Inc. (“WHRI”), Wyndham Hotel Group, LLC
(“WHG”), and Hawthorn Suites Franchising, Inc. (“HSF”) (collectively, the “Wyndham
Defendants”) file this Response to Plaintiffs’ Motion to Strike (and Objections to) Wyndham
Defendants’ Evidence in Support of Motion for Summary Judgment (“Mtn.”):
1. Plaintiffs make three objections to the evidence appended to the Wyndham
Defendants’ summary judgment motion. Each of those objections lacks merit.
2. First, Plaintiff states that “Wyndham Defendants’ counsel presents ‘argument’ in
the Motion as to Why Defendants believe summary judgment is warranted, but arguments are not
evidence,” citing a one case in which the movant did not append any evidence. See Mtn. § I.A.
Here, it is not clear what point Plaintiffs are trying to make. Of course, like any legal brief, the
Wyndham Defendants make legal arguments in their summary judgment motion, and in doing so
they cite the evidence appended thereto. There is nothing objectionable about that.
3. Next, Plaintiffs object to the Declaration of Rachel Dabrowa, a Vice President at
Wyndham, on multiple grounds. See Mtn. § I.B. First, Plaintiff contends that Ms. Dabrowa’s use
of the term “typical” in describing the Franchise Agreement between HSF and Defendant Tasacom
Real Estate, LLC “is being used as improper expert and legal testimony.” Id. That is incorrect. Ms.
Dabrowa is testifying as to her “personal knowledge of the franchise relationships between HSF
and the franchisees who operate hotels that use the Hawthorn® brand.” See Dabrowa Decl. at 11 5
(Exhibit A to Wyndham Defendants’ Summary Judgment Motion). Ms. Dabrowa is clearly
competent to testify as to what is “typical” based on her personal knowledge of HSF’s franchise
business. Plaintiff also complains that Ms. Dabrowa lacks the requisite personal knowledge for
statements made in her declaration. See Mtn. § I.B. Ms. Dabrowa’s declaration clearly states
otherwise, see Dabrowa Decl. at 1W 4 and Plaintiffs do not submit any evidence calling that
declaration testimony into doubt—despite having deposed Ms. Dabrowa for more than six hours.
Again, Ms. Dabrowa is competently testifying as to her personal knowledge of HSF’s franchise
business. Lastly, Plaintiffs, invoking Texas Rule of Evidence 403, argue that Ms. Dabrowa’s
declaration is somehow confusing and should be excluded on that basis, without offering any
explanation or submitting any evidence calling her testimony into doubt. Each of Plaintiffs’
objections to Ms. Dabrowa’s declaration lacks merit and should be overruled.
4. Lastly, Plaintiffs take issue with the fact that the Wyndham Defendants submitted
the entirety of Deon Williams’s deposition transcript (attached as Exhibit B)—rather than just the
excerpts that the Wyndham Defendants have specifically cited in the brief. The Wyndham
Defendants submitted the entirety of Mr. Williams’s testimony to avoid any suggestion
mischaracterization, and there is nothing improper about that. See TEX. R. EVID. 107 (“If a party
introduces part of an act, declaration, conversation, writing, or recorded statement, an adverse
party may inquire into any other part on the same subject. An adverse party may also introduce
any other act, declaration, conversation, writing, or recorded statement that is necessary to explain
or allow the trier of fact to fully understand the part offered by the opponent. ‘Writing or recorded
statement’ includes a deposition”).
WHEREFORE, the Wyndham Defendants respectfully request that each of Plaintiffs’
objections to the evidence appended to the summary judgment motion be overruled.
Date: August 25, 2023 Respectfully submitted,
DLA PIPER LLP (US)
/s/ Jason Hopkins
Jason Hopkins
State Bar No. 24059969
jason.hopkins@dlapiper.com
1900 N. Pearl St. Suite 2200
Dallas, Texas 75201
T: 214.743 .4500
F: 214.743.4545
Christopher B. Donovan
State Bar No. 24097614
christopherb.donovan@dlapiper.com
845 Texas Avenue, Suite 3800
Houston, Texas 77002
T: 713.425.8400
F: 713.425.8401
Counsel for Defendants
Wyndham Hotels & Resorts, Inc.,
Wyndham Hotel Group, LLC, and
Hawthorn Suites Franchising, Inc.
CERTIFICATE 0F SERVICE
I certify that, on August 25, 2023, a true and correct copy of the foregoing document was
served on counsel of record in accordance with the Texas Rules of Civil Procedure Via the court’s
electronic filing system.
/s/ Christopher Donovan
Christopher Donovan
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.
Sherry Faulkner on behalf of Jason Hopkins
Bar No. 24059969
sherry.faulkner@dlapiper.com
Envelope ID: 78921684
Filing Code Description: Response
Filing Description: Defendants Wyndham Hotel & Resorts, Inc. Wyndham
Hotel Group, LLC and Hawthorn Suites Franchising, lnc.'s Response to
Plaintiffs‘ Motion To Strike (And Obj to ) Wyndham Defendants‘ Evidence
ISO Motion for Summary Judgment
Status as of 8/25/2023 12:37 PM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/25/2023 12:08:43 PM SENT
Emily Taylor taylor@twlglawyers.com 8/25/2023 12:08:43 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 8/25/2023 12:08:43 PM SENT
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/25/2023 12:08:43 PM SENT
Emily Taylor taylor@twlglawyers.com 8/25/2023 12:08:43 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 8/25/2023 12:08:43 PM SENT
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/25/2023 12:08:43 PM SENT
Emily Taylor taylor@twlglawyers.com 8/25/2023 12:08:43 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 8/25/2023 12:08:43 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 8/25/2023 12:08:43 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.
Sherry Faulkner on behalf of Jason Hopkins
Bar No. 24059969
sherry.faulkner@dlapiper.com
Envelope ID: 78921684
Filing Code Description: Response
Filing Description: Defendants Wyndham Hotel & Resorts, Inc. Wyndham
Hotel Group, LLC and Hawthorn Suites Franchising, lnc.'s Response to
Plaintiffs‘ Motion To Strike (And Obj to ) Wyndham Defendants‘ Evidence
ISO Motion for Summary Judgment
Status as of 8/25/2023 12:37 PM CST
Associated Case Party: TASACOM REAL ESTATE, LLC
LISA V Ivillasenor@thompsoncoe.com 8/25/2023 12:08:43 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/25/2023 12:08:43 PM SENT
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/25/2023 12:08:43 PM SENT
Ronald DHinds rdhinds@verizon.net 8/25/2023 12:08:43 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 8/25/2023 12:08:43 PM SENT
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/25/2023 12:08:43 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/25/2023 12:08:43 PM SENT
RoseMarie Chambers rose.chambers@dlapiper.com 8/25/2023 12:08:43 PM SENT
Judy Calderon judy.calderon@d|apiper.com 8/25/2023 12:08:43 PM SENT
Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 8/25/2023 12:08:43 PM SENT
Taylor Reed Taylor.reed@us.dlapiper.com 8/25/2023 12:08:43 PM SENT
Sally Jones sally.jones@dlapiper.com 8/25/2023 12:08:43 PM SENT
ECFX DLA DLAPiper@ecfxmai|.com 8/25/2023 12:08:43 PM SENT
Docket Chicago docketingchicago@dlapiper.com 8/25/2023 12:08:43 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.
Sherry Faulkner on behalf of Jason Hopkins
Bar No. 24059969
sherry.faulkner@dlapiper.com
Envelope ID: 78921684
Filing Code Description: Response
Filing Description: Defendants Wyndham Hotel & Resorts, Inc. Wyndham
Hotel Group, LLC and Hawthorn Suites Franchising, lnc.'s Response to
Plaintiffs‘ Motion To Strike (And Obj to ) Wyndham Defendants‘ Evidence
ISO Motion for Summary Judgment
Status as of 8/25/2023 12:37 PM CST
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 8/25/2023 12:08:43 PM SENT
Associated Case Party: TASACOM TECHNOLOGIES INC
Name BarNumber Email TimestampSubmitted Status
Benjamin Dunn bdunn@thompsoncoe.com 8/25/2023 12:08:43 PM SENT
Associated Case Party: MMAROOFUL CHOUDHURY
Name BarNumber Email TimestampSubmitted Status
Morgan Wells mwells@thompsoncoe.com 8/25/2023 12:08:43 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Josimayra Diaz josi.diaz@dallascityhall.com 8/25/2023 12:08:43 PM SENT
Luz Aguilar luz.aguilar@da||ascityhall.com 8/25/2023 12:08:43 PM SENT
NURU WITHERSPOON witherspoon@twlg|awyers.com 8/25/2023 12:08:43 PM SENT
Ronald DHinds rdhinds@verizon.net 8/25/2023 12:08:43 PM SENT
Sally Jones sally.jones@dlapiper.com 8/25/2023 12:08:43 PM SENT
sherry M.faulkner sherry.fauIkner@us.dlapiper.com 8/25/2023 12:08:43 PM SENT
Preview
FILED 8/25/2023 12:08 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Kellie Juricek DEPUTY CAUSE NO. DC-21-04901 TONY EVANS, SR., and ARETHA EVANS, IN THE DISTRICT COURT OF §§§§§§§§§§§§§§ 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 DALLAS COUNTY, TEXAS Plaintiffv, VS. TASACOM REAL ESTATE, LLC, ET AL. Defendants. 162m JUDICIAL DISTRICT DEFENDANTS WYNDHAM HOTELS & RESORTS, INC., WYNDHAM HOTEL GROUP, LLC, AND HAWTHORN SUITES FRANCHISING, INC.’S RESPONSE TO PLAINTIFFS’ MOTION TO STRIKE (AND OBJECTIONS TO) WYNDHAM DEFENDANTS’ EVIDENCE IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT Defendants Wyndham Hotels & Resorts, Inc. (“WHRI”), Wyndham Hotel Group, LLC (“WHG”), and Hawthorn Suites Franchising, Inc. (“HSF”) (collectively, the “Wyndham Defendants”) file this Response to Plaintiffs’ Motion to Strike (and Objections to) Wyndham Defendants’ Evidence in Support of Motion for Summary Judgment (“Mtn.”): 1. Plaintiffs make three objections to the evidence appended to the Wyndham Defendants’ summary judgment motion. Each of those objections lacks merit. 2. First, Plaintiff states that “Wyndham Defendants’ counsel presents ‘argument’ in the Motion as to Why Defendants believe summary judgment is warranted, but arguments are not evidence,” citing a one case in which the movant did not append any evidence. See Mtn. § I.A. Here, it is not clear what point Plaintiffs are trying to make. Of course, like any legal brief, the Wyndham Defendants make legal arguments in their summary judgment motion, and in doing so they cite the evidence appended thereto. There is nothing objectionable about that. 3. Next, Plaintiffs object to the Declaration of Rachel Dabrowa, a Vice President at Wyndham, on multiple grounds. See Mtn. § I.B. First, Plaintiff contends that Ms. Dabrowa’s use of the term “typical” in describing the Franchise Agreement between HSF and Defendant Tasacom Real Estate, LLC “is being used as improper expert and legal testimony.” Id. That is incorrect. Ms. Dabrowa is testifying as to her “personal knowledge of the franchise relationships between HSF and the franchisees who operate hotels that use the Hawthorn® brand.” See Dabrowa Decl. at 11 5 (Exhibit A to Wyndham Defendants’ Summary Judgment Motion). Ms. Dabrowa is clearly competent to testify as to what is “typical” based on her personal knowledge of HSF’s franchise business. Plaintiff also complains that Ms. Dabrowa lacks the requisite personal knowledge for statements made in her declaration. See Mtn. § I.B. Ms. Dabrowa’s declaration clearly states otherwise, see Dabrowa Decl. at 1W 4 and Plaintiffs do not submit any evidence calling that declaration testimony into doubt—despite having deposed Ms. Dabrowa for more than six hours. Again, Ms. Dabrowa is competently testifying as to her personal knowledge of HSF’s franchise business. Lastly, Plaintiffs, invoking Texas Rule of Evidence 403, argue that Ms. Dabrowa’s declaration is somehow confusing and should be excluded on that basis, without offering any explanation or submitting any evidence calling her testimony into doubt. Each of Plaintiffs’ objections to Ms. Dabrowa’s declaration lacks merit and should be overruled. 4. Lastly, Plaintiffs take issue with the fact that the Wyndham Defendants submitted the entirety of Deon Williams’s deposition transcript (attached as Exhibit B)—rather than just the excerpts that the Wyndham Defendants have specifically cited in the brief. The Wyndham Defendants submitted the entirety of Mr. Williams’s testimony to avoid any suggestion mischaracterization, and there is nothing improper about that. See TEX. R. EVID. 107 (“If a party introduces part of an act, declaration, conversation, writing, or recorded statement, an adverse party may inquire into any other part on the same subject. An adverse party may also introduce any other act, declaration, conversation, writing, or recorded statement that is necessary to explain or allow the trier of fact to fully understand the part offered by the opponent. ‘Writing or recorded statement’ includes a deposition”). WHEREFORE, the Wyndham Defendants respectfully request that each of Plaintiffs’ objections to the evidence appended to the summary judgment motion be overruled. Date: August 25, 2023 Respectfully submitted, DLA PIPER LLP (US) /s/ Jason Hopkins Jason Hopkins State Bar No. 24059969 jason.hopkins@dlapiper.com 1900 N. Pearl St. Suite 2200 Dallas, Texas 75201 T: 214.743 .4500 F: 214.743.4545 Christopher B. Donovan State Bar No. 24097614 christopherb.donovan@dlapiper.com 845 Texas Avenue, Suite 3800 Houston, Texas 77002 T: 713.425.8400 F: 713.425.8401 Counsel for Defendants Wyndham Hotels & Resorts, Inc., Wyndham Hotel Group, LLC, and Hawthorn Suites Franchising, Inc. CERTIFICATE 0F SERVICE I certify that, on August 25, 2023, a true and correct copy of the foregoing document was served on counsel of record in accordance with the Texas Rules of Civil Procedure Via the court’s electronic filing system. /s/ Christopher Donovan Christopher Donovan 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. Sherry Faulkner on behalf of Jason Hopkins Bar No. 24059969 sherry.faulkner@dlapiper.com Envelope ID: 78921684 Filing Code Description: Response Filing Description: Defendants Wyndham Hotel & Resorts, Inc. Wyndham Hotel Group, LLC and Hawthorn Suites Franchising, lnc.'s Response to Plaintiffs‘ Motion To Strike (And Obj to ) Wyndham Defendants‘ Evidence ISO Motion for Summary Judgment Status as of 8/25/2023 12:37 PM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/25/2023 12:08:43 PM SENT Emily Taylor taylor@twlglawyers.com 8/25/2023 12:08:43 PM SENT Nuru Witherspoon litigation@twlglawyers.com 8/25/2023 12:08:43 PM SENT Associated Case Party: T. E. Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/25/2023 12:08:43 PM SENT Emily Taylor taylor@twlglawyers.com 8/25/2023 12:08:43 PM SENT Nuru Witherspoon litigation@twlglawyers.com 8/25/2023 12:08:43 PM SENT Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 8/25/2023 12:08:43 PM SENT Emily Taylor taylor@twlglawyers.com 8/25/2023 12:08:43 PM SENT Nuru Witherspoon litigation@twlglawyers.com 8/25/2023 12:08:43 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 8/25/2023 12:08:43 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. Sherry Faulkner on behalf of Jason Hopkins Bar No. 24059969 sherry.faulkner@dlapiper.com Envelope ID: 78921684 Filing Code Description: Response Filing Description: Defendants Wyndham Hotel & Resorts, Inc. Wyndham Hotel Group, LLC and Hawthorn Suites Franchising, lnc.'s Response to Plaintiffs‘ Motion To Strike (And Obj to ) Wyndham Defendants‘ Evidence ISO Motion for Summary Judgment Status as of 8/25/2023 12:37 PM CST Associated Case Party: TASACOM REAL ESTATE, LLC LISA V Ivillasenor@thompsoncoe.com 8/25/2023 12:08:43 PM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/25/2023 12:08:43 PM SENT Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/25/2023 12:08:43 PM SENT Ronald DHinds rdhinds@verizon.net 8/25/2023 12:08:43 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 8/25/2023 12:08:43 PM SENT Christopher BDonovan Christopher.B.Donovan@dlapiper.com 8/25/2023 12:08:43 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 8/25/2023 12:08:43 PM SENT RoseMarie Chambers rose.chambers@dlapiper.com 8/25/2023 12:08:43 PM SENT Judy Calderon judy.calderon@d|apiper.com 8/25/2023 12:08:43 PM SENT Sherry Faulkner Sherry.Faulkner@us.dlapiper.com 8/25/2023 12:08:43 PM SENT Taylor Reed Taylor.reed@us.dlapiper.com 8/25/2023 12:08:43 PM SENT Sally Jones sally.jones@dlapiper.com 8/25/2023 12:08:43 PM SENT ECFX DLA DLAPiper@ecfxmai|.com 8/25/2023 12:08:43 PM SENT Docket Chicago docketingchicago@dlapiper.com 8/25/2023 12:08:43 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. Sherry Faulkner on behalf of Jason Hopkins Bar No. 24059969 sherry.faulkner@dlapiper.com Envelope ID: 78921684 Filing Code Description: Response Filing Description: Defendants Wyndham Hotel & Resorts, Inc. Wyndham Hotel Group, LLC and Hawthorn Suites Franchising, lnc.'s Response to Plaintiffs‘ Motion To Strike (And Obj to ) Wyndham Defendants‘ Evidence ISO Motion for Summary Judgment Status as of 8/25/2023 12:37 PM CST Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 8/25/2023 12:08:43 PM SENT Associated Case Party: TASACOM TECHNOLOGIES INC Name BarNumber Email TimestampSubmitted Status Benjamin Dunn bdunn@thompsoncoe.com 8/25/2023 12:08:43 PM SENT Associated Case Party: MMAROOFUL CHOUDHURY Name BarNumber Email TimestampSubmitted Status Morgan Wells mwells@thompsoncoe.com 8/25/2023 12:08:43 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Josimayra Diaz josi.diaz@dallascityhall.com 8/25/2023 12:08:43 PM SENT Luz Aguilar luz.aguilar@da||ascityhall.com 8/25/2023 12:08:43 PM SENT NURU WITHERSPOON witherspoon@twlg|awyers.com 8/25/2023 12:08:43 PM SENT Ronald DHinds rdhinds@verizon.net 8/25/2023 12:08:43 PM SENT Sally Jones sally.jones@dlapiper.com 8/25/2023 12:08:43 PM SENT sherry M.faulkner sherry.fauIkner@us.dlapiper.com 8/25/2023 12:08:43 PM SENT