On April 19, 2021 a
Party Notice
was filed
involving a dispute between
Bng Management Group, Llc,
Pk Restaurant Group Inc,
and
Cho, Jimmy,
Giant Blue Inc,
Tozee Construction Inc,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
FILED
8/5/2022 12:39 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Cassandra Walker DEPUTY
N0. DC-21-04907
PK RESTAURANT GROUP, LLC, AND § IN THE DISTRICT COURT
BNG MANAGEMENT GROUP, LLC §
§
Plaintiffs, §
§
V. § lOlST JUDICIAL DISTRICT
§
TOZEE CONSTRUCTION INC., GIANT §
BLUE, INC., AND JIMMY CHO, §
INDIVIDUALLY §
§
Defendants. § DALLAS COUNTY, TEXAS
NOTICE OF INTENT TO TAKE ORAL DEPOSITION
TO SHIM KANG by and through attorney of record, Jordan Whiddon,
jwhiddon@songwhiddon.com.
PLEASE TAKE NOTICE that Defendants will take the oral deposition of Shim Kang. The
deposition will commence at SONG WHIDDON, PLLC, 8111 LBJ Freeway, Suite 480, Dallas,
Texas 75251, on August 11, 2022 at 9:30 AM and will continue from day to day until completed
or otherwise agreed to by the parties or their counsel of record. All parties are invited to attend and
examine the Witness as prescribed by the Texas Rules of Civil Procedure.
Respectfully Submitted
By: /s/ William Chu
William Chu
SBN: 04241000
wmchulaw@aol.com
LAW OFFICES OF WILLIAM CHU
4455 LBJ Freeway, Suite 1008
Dallas, Texas 75244
(T) 972-392-9888
(F) 972-392-9889
ATTORNEY FOR
DEFENDANTS
NOTICE 0F INTENT To TAKE DEPOSITION
PAGE 1 0F 2
CERTIFICATE OF SERVICE
Pursuant to Texas Rules of Civil Procedure 21a, the undersigned certifies that a true and correct
copy of this document was contemporaneously E-served to all parties or their counsel of record
Via efile.txcourts.gov to their email address on file therein on August 5, 2022.
/s/ William Chu
NOTICE 0F INTENT To TAKE DEPOSITION
PAGE 2 0F 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.
William Chu
Bar No. 04241000
wmchulaw@aol.com
Envelope ID: 67011079
Status as of 8/5/2022 12:50 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Yuliana Ramirez yuliana@tailimsong.com 8/5/2022 12:39:08 PM SENT
william Knisley knisley.wmchulaw@gmail.com 8/5/2022 12:39:08 PM SENT
Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 8/5/2022 12:39:08 PM SENT
Tailim Song tsong@tai|imsong.com 8/5/2022 12:39:08 PM SENT
Chris LValentine cvalentine@tailimsong.com 8/5/2022 12:39:08 PM SENT
Office Efiles wmchulawefile@gmail.com 8/5/2022 12:39:08 PM SENT
Abigael Campbell acampbell@tailimsong.com 8/5/2022 12:39:08 PM SENT
Jordan Whiddon 24093350 jwhiddon@songwhiddon.com 8/5/2022 12:39:08 PM SENT
William Chu wmchulaw@aol.com 8/5/2022 12:39:08 PM SENT
Document Filed Date
August 05, 2022
Case Filing Date
April 19, 2021
Category
CNTR CNSMR COM DEBT
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FILED 8/5/2022 12:39 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Cassandra Walker DEPUTY N0. DC-21-04907 PK RESTAURANT GROUP, LLC, AND § IN THE DISTRICT COURT BNG MANAGEMENT GROUP, LLC § § Plaintiffs, § § V. § lOlST JUDICIAL DISTRICT § TOZEE CONSTRUCTION INC., GIANT § BLUE, INC., AND JIMMY CHO, § INDIVIDUALLY § § Defendants. § DALLAS COUNTY, TEXAS NOTICE OF INTENT TO TAKE ORAL DEPOSITION TO SHIM KANG by and through attorney of record, Jordan Whiddon, jwhiddon@songwhiddon.com. PLEASE TAKE NOTICE that Defendants will take the oral deposition of Shim Kang. The deposition will commence at SONG WHIDDON, PLLC, 8111 LBJ Freeway, Suite 480, Dallas, Texas 75251, on August 11, 2022 at 9:30 AM and will continue from day to day until completed or otherwise agreed to by the parties or their counsel of record. All parties are invited to attend and examine the Witness as prescribed by the Texas Rules of Civil Procedure. Respectfully Submitted By: /s/ William Chu William Chu SBN: 04241000 wmchulaw@aol.com LAW OFFICES OF WILLIAM CHU 4455 LBJ Freeway, Suite 1008 Dallas, Texas 75244 (T) 972-392-9888 (F) 972-392-9889 ATTORNEY FOR DEFENDANTS NOTICE 0F INTENT To TAKE DEPOSITION PAGE 1 0F 2 CERTIFICATE OF SERVICE Pursuant to Texas Rules of Civil Procedure 21a, the undersigned certifies that a true and correct copy of this document was contemporaneously E-served to all parties or their counsel of record Via efile.txcourts.gov to their email address on file therein on August 5, 2022. /s/ William Chu NOTICE 0F INTENT To TAKE DEPOSITION PAGE 2 0F 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. William Chu Bar No. 04241000 wmchulaw@aol.com Envelope ID: 67011079 Status as of 8/5/2022 12:50 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Yuliana Ramirez yuliana@tailimsong.com 8/5/2022 12:39:08 PM SENT william Knisley knisley.wmchulaw@gmail.com 8/5/2022 12:39:08 PM SENT Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 8/5/2022 12:39:08 PM SENT Tailim Song tsong@tai|imsong.com 8/5/2022 12:39:08 PM SENT Chris LValentine cvalentine@tailimsong.com 8/5/2022 12:39:08 PM SENT Office Efiles wmchulawefile@gmail.com 8/5/2022 12:39:08 PM SENT Abigael Campbell acampbell@tailimsong.com 8/5/2022 12:39:08 PM SENT Jordan Whiddon 24093350 jwhiddon@songwhiddon.com 8/5/2022 12:39:08 PM SENT William Chu wmchulaw@aol.com 8/5/2022 12:39:08 PM SENT