On April 19, 2021 a
Exhibit,Appendix
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.
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FILED
1/11/2023 7:16 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Cassandra Walker DEPUTY
NO. DC-21-04907
BNG MANAGEMENT GROUP, LLC IN THE DISTRICT COURT
§§§§§§§§§§
Plaintiffi
V.
IOIST JUDICIAL DISTRICT
TOZEE CONSTRUCTION, INC.,
GIANT BLUE, INC., AND JIMMY
CHO, INDIVIDUALLY
Defendants. DALLAS COUNTY, TEXAS
DEFENDANTS’ ORIGINAL EXHIBIT LIST
TO THE HONORABLE COURT
DEFENDANTS’, in the above numbered and styled action, brings this DEFENDANTS’
ORIGINAL EXHIBIT LIST and would show the court the following:
I.
Defendants designate the following documents as exhibits for trial in this Matter, this list
does not encompass exhibits that may be called solely for impeachment and/or rebuttal.
NUMBER DESCRIPTION —NAM E—OTHER Admitted?
Exhibit 1 Pages and 2 of the subcontractor agreement- Irving
1
Exhibit 2 Pages 1 and 2 of the subcontractor agreement- Dallas
Exhibit 3 Pages l and 2 of the subcontractor agreement- Carrollton
Exhibit 4 Spreadsheet of payments made by Tozee Construction- Irving
Exhibit 5 Spreadsheet of payments made by Tozee Consnuction- Dallas
Exhibit 6 Spreadsheet of payments made by Tozee Construction- Carrollton
Exhibit 7 Complaint from BNG’s Georgia lawsuit
Exhibit 8 Signed Order on Default judgment in Georgia lawsuit
Exhibit 9 Text messages between Mr. Cho and Kevin Ok regarding the updates on the
construction.
Exhibit 10 Punch list for Carrollton Location
Exhibit ll Punch list for Irving Location
Exhibit 12 Punch list for Dallas Location
DEFENDANTS ORIGINAL EXHIBIT LIST
PAGE 1 0F 2
Defendants cross-designate by reference and incorporates by reference all exhibits
designated by all other parties to this Matter, in their respective exhibit lists, as exhibits,
Defendants’ reserve the right to attempt to admit those exhibits in Defendants’ case in chief.
Respectfully Submitted
By: /s/ William Chu
William Chu
SBN: 04241000
wmchulaw@aol.com
LAW OFFICES 0F WILLIAM CHU
4455 LBJ Freeway, Suite 1008
Dallas, Texas 75244
(T) 972-392-9888
(F) 972-392-9889
ATTORNEY FOR
DEFENDANTS
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 1/ 1 1/2023.
/s/ William Chu
DEFENDANTS ORIGINAL EXHIBIT LIST
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: 71721156
Status as of 1/12/2023 8:56 AM CST
Associated Case Party: BNG MANAGEMENT GROUP, LLC
Name BarNumber Email TimestampSubmitted Status
Tailim Song tsong@songwhiddon.com 1/11/2023 7:16:48 PM SENT
Yuliana Ramirez yuliana@songwhiddon.com 1/11/2023 7:16:48 PM SENT
Administrative Staff admin@songwhiddon.com 1/11/2023 7:16:48 PM SENT
Jordan Whiddon jwhiddon@songwhiddon.com 1/11/2023 7:16:48 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
William Chu wmchulaw@aol.com 1/11/2023 7:16:48 PM SENT
Salina Tariq stariq.wmchulaw@gmail.com 1/11/2023 7:16:48 PM SENT
Jordan Whiddon 24093350 jwhiddon@songwhiddon.com 1/11/2023 7:16:48 PM SENT
Yuliana Ramirez yuliana@tailimsong.com 1/11/2023 7:16:48 PM SENT
Tailim Song tsong@tailimsong.com 1/11/2023 7:16:48 PM SENT
Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 1/11/2023 7:16:48 PM SENT
Chris LValentine cvalentine@tailimsong.com 1/11/2023 7:16:48 PM SENT
Office Efiles wmchulawefile@gmail.com 1/11/2023 7:16:48 PM SENT
Abigael Campbell acampbell@tailimsong.com 1/11/2023 7:16:48 PM SENT
Document Filed Date
January 11, 2023
Case Filing Date
April 19, 2021
Category
CNTR CNSMR COM DEBT
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FILED 1/11/2023 7:16 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Cassandra Walker DEPUTY NO. DC-21-04907 BNG MANAGEMENT GROUP, LLC IN THE DISTRICT COURT §§§§§§§§§§ Plaintiffi V. IOIST JUDICIAL DISTRICT TOZEE CONSTRUCTION, INC., GIANT BLUE, INC., AND JIMMY CHO, INDIVIDUALLY Defendants. DALLAS COUNTY, TEXAS DEFENDANTS’ ORIGINAL EXHIBIT LIST TO THE HONORABLE COURT DEFENDANTS’, in the above numbered and styled action, brings this DEFENDANTS’ ORIGINAL EXHIBIT LIST and would show the court the following: I. Defendants designate the following documents as exhibits for trial in this Matter, this list does not encompass exhibits that may be called solely for impeachment and/or rebuttal. NUMBER DESCRIPTION —NAM E—OTHER Admitted? Exhibit 1 Pages and 2 of the subcontractor agreement- Irving 1 Exhibit 2 Pages 1 and 2 of the subcontractor agreement- Dallas Exhibit 3 Pages l and 2 of the subcontractor agreement- Carrollton Exhibit 4 Spreadsheet of payments made by Tozee Construction- Irving Exhibit 5 Spreadsheet of payments made by Tozee Consnuction- Dallas Exhibit 6 Spreadsheet of payments made by Tozee Construction- Carrollton Exhibit 7 Complaint from BNG’s Georgia lawsuit Exhibit 8 Signed Order on Default judgment in Georgia lawsuit Exhibit 9 Text messages between Mr. Cho and Kevin Ok regarding the updates on the construction. Exhibit 10 Punch list for Carrollton Location Exhibit ll Punch list for Irving Location Exhibit 12 Punch list for Dallas Location DEFENDANTS ORIGINAL EXHIBIT LIST PAGE 1 0F 2 Defendants cross-designate by reference and incorporates by reference all exhibits designated by all other parties to this Matter, in their respective exhibit lists, as exhibits, Defendants’ reserve the right to attempt to admit those exhibits in Defendants’ case in chief. Respectfully Submitted By: /s/ William Chu William Chu SBN: 04241000 wmchulaw@aol.com LAW OFFICES 0F WILLIAM CHU 4455 LBJ Freeway, Suite 1008 Dallas, Texas 75244 (T) 972-392-9888 (F) 972-392-9889 ATTORNEY FOR DEFENDANTS 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 1/ 1 1/2023. /s/ William Chu DEFENDANTS ORIGINAL EXHIBIT LIST 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: 71721156 Status as of 1/12/2023 8:56 AM CST Associated Case Party: BNG MANAGEMENT GROUP, LLC Name BarNumber Email TimestampSubmitted Status Tailim Song tsong@songwhiddon.com 1/11/2023 7:16:48 PM SENT Yuliana Ramirez yuliana@songwhiddon.com 1/11/2023 7:16:48 PM SENT Administrative Staff admin@songwhiddon.com 1/11/2023 7:16:48 PM SENT Jordan Whiddon jwhiddon@songwhiddon.com 1/11/2023 7:16:48 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status William Chu wmchulaw@aol.com 1/11/2023 7:16:48 PM SENT Salina Tariq stariq.wmchulaw@gmail.com 1/11/2023 7:16:48 PM SENT Jordan Whiddon 24093350 jwhiddon@songwhiddon.com 1/11/2023 7:16:48 PM SENT Yuliana Ramirez yuliana@tailimsong.com 1/11/2023 7:16:48 PM SENT Tailim Song tsong@tailimsong.com 1/11/2023 7:16:48 PM SENT Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 1/11/2023 7:16:48 PM SENT Chris LValentine cvalentine@tailimsong.com 1/11/2023 7:16:48 PM SENT Office Efiles wmchulawefile@gmail.com 1/11/2023 7:16:48 PM SENT Abigael Campbell acampbell@tailimsong.com 1/11/2023 7:16:48 PM SENT