On April 19, 2021 a
Trial Materials
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
1/12/2023 6:27 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Cassandra Walker DEPUTY
CAUSE NO. DC-2 1-04907
BNG MANAGEMENT GROUP, LLC § IN THE DISTRICT COURT OF
§
Plaintiffi §
§
V. § DALLAS COUNTY, TEXAS
§
TOZEE CONSTRUCTION, INC., §
GLANT BLUE, INC., AND JIMMY CHO, §
INDIVIDUALLY §
§
Defendants. § 10 1 st JUDICIAL DISTRICT
PLAINTIFF’S WITNESS LIST
Plaintiff intends to call the following fact witnesses at trial:
1. Kevin 0k, individually and as corporate representative of BNG Management
Group, LLC
Plaintiff in this action who has personal knowledge of the agreements, payments, the
work done by Defendants, the damage to the properties done by Defendants, and other
relevant facts underlying this case.
David Ahn
Former employee of Plaintiff with knowledge of the meetings between the parties, the
facts, the work done by the Defendants, the damage to the properties done by Defendants,
and other relevant facts underlying this case.
Paragon Roofing, Inc.
Party that repaired the roof issues created by Jimmy Cho and Defendants’ failure to
properly finish the roof.
HK General Contractor, Inc. d/b/a HK Construction
Party that finished construction after Jimmy Cho abandoned the project.
Jimmy Cho
Defendant in this case with knowledge of the work not done by Defendants, the failure to
comply with the timeline, and the amounts he was paid.
Plaintiff also incorporates and cross-designates all witnesses identified by Defendants’ or
any other party to this suit, and reserves the right to elicit testimony from other witnesses
examined herein.
Respectfully submitted,
SONG WHIDDON, PLLC
PLAINTIFF’S WITNESS LIST - PAGE 1 0F 2
/s/ Jordan Whiddon
Jordan Whiddon
State Bar No. 24093350
jwhiddon@songwhiddon.com
8111 LBJ Freeway, Suite 480
Dallas, Texas 75251
(214) 528-8400 Telephone
(214) 528-8402 Facsimile
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was forwarded to all
counsel of record on this 12th day of January, 2023.
/s/ Jordan Whiddon
Jordan Whiddon
PLAINTIFF’S WITNESS 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.
Jordan Whiddon on behalf of Jordan Whiddon
Bar No. 24093350
jwhiddon@songwhiddon.com
Envelope ID: 71764007
Status as of 1/13/2023 9:39 AM CST
Associated Case Party: BNG MANAGEMENT GROUP, LLC
Name BarNumber Email TimestampSubmitted Status
Tailim Song tsong@songwhiddon.com 1/12/2023 6:27:11 PM SENT
Yuliana Ramirez yuliana@songwhiddon.com 1/12/2023 6:27:11 PM SENT
Administrative Staff admin@songwhiddon.com 1/12/2023 6:27:11 PM SENT
Jordan Whiddon jwhiddon@songwhiddon.com 1/12/2023 6:27:11 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
William Chu wmchulaw@aol.com 1/12/2023 6:27:11 PM SENT
Salina Tariq stariq.wmchulaw@gmail.com 1/12/2023 6:27:11 PM SENT
Jordan Whiddon 24093350 jwhiddon@songwhiddon.com 1/12/2023 6:27:11 PM SENT
Yuliana Ramirez yuliana@tailimsong.com 1/12/2023 6:27:11 PM SENT
Tailim Song tsong@tailimsong.com 1/12/2023 6:27:11 PM SENT
Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 1/12/2023 6:27:11 PM SENT
Chris LVaIentine cvalentine@tai|imsong.com 1/12/2023 6:27:11 PM SENT
Office Efiles wmchulawefile@gmail.com 1/12/2023 6:27:11 PM SENT
Abigael Campbell acampbell@tailimsong.com 1/12/2023 6:27:11 PM SENT
Document Filed Date
January 12, 2023
Case Filing Date
April 19, 2021
Category
CNTR CNSMR COM DEBT
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FILED 1/12/2023 6:27 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Cassandra Walker DEPUTY CAUSE NO. DC-2 1-04907 BNG MANAGEMENT GROUP, LLC § IN THE DISTRICT COURT OF § Plaintiffi § § V. § DALLAS COUNTY, TEXAS § TOZEE CONSTRUCTION, INC., § GLANT BLUE, INC., AND JIMMY CHO, § INDIVIDUALLY § § Defendants. § 10 1 st JUDICIAL DISTRICT PLAINTIFF’S WITNESS LIST Plaintiff intends to call the following fact witnesses at trial: 1. Kevin 0k, individually and as corporate representative of BNG Management Group, LLC Plaintiff in this action who has personal knowledge of the agreements, payments, the work done by Defendants, the damage to the properties done by Defendants, and other relevant facts underlying this case. David Ahn Former employee of Plaintiff with knowledge of the meetings between the parties, the facts, the work done by the Defendants, the damage to the properties done by Defendants, and other relevant facts underlying this case. Paragon Roofing, Inc. Party that repaired the roof issues created by Jimmy Cho and Defendants’ failure to properly finish the roof. HK General Contractor, Inc. d/b/a HK Construction Party that finished construction after Jimmy Cho abandoned the project. Jimmy Cho Defendant in this case with knowledge of the work not done by Defendants, the failure to comply with the timeline, and the amounts he was paid. Plaintiff also incorporates and cross-designates all witnesses identified by Defendants’ or any other party to this suit, and reserves the right to elicit testimony from other witnesses examined herein. Respectfully submitted, SONG WHIDDON, PLLC PLAINTIFF’S WITNESS LIST - PAGE 1 0F 2 /s/ Jordan Whiddon Jordan Whiddon State Bar No. 24093350 jwhiddon@songwhiddon.com 8111 LBJ Freeway, Suite 480 Dallas, Texas 75251 (214) 528-8400 Telephone (214) 528-8402 Facsimile ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was forwarded to all counsel of record on this 12th day of January, 2023. /s/ Jordan Whiddon Jordan Whiddon PLAINTIFF’S WITNESS 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. Jordan Whiddon on behalf of Jordan Whiddon Bar No. 24093350 jwhiddon@songwhiddon.com Envelope ID: 71764007 Status as of 1/13/2023 9:39 AM CST Associated Case Party: BNG MANAGEMENT GROUP, LLC Name BarNumber Email TimestampSubmitted Status Tailim Song tsong@songwhiddon.com 1/12/2023 6:27:11 PM SENT Yuliana Ramirez yuliana@songwhiddon.com 1/12/2023 6:27:11 PM SENT Administrative Staff admin@songwhiddon.com 1/12/2023 6:27:11 PM SENT Jordan Whiddon jwhiddon@songwhiddon.com 1/12/2023 6:27:11 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status William Chu wmchulaw@aol.com 1/12/2023 6:27:11 PM SENT Salina Tariq stariq.wmchulaw@gmail.com 1/12/2023 6:27:11 PM SENT Jordan Whiddon 24093350 jwhiddon@songwhiddon.com 1/12/2023 6:27:11 PM SENT Yuliana Ramirez yuliana@tailimsong.com 1/12/2023 6:27:11 PM SENT Tailim Song tsong@tailimsong.com 1/12/2023 6:27:11 PM SENT Law Offices ofWilliam Chu docs.wmchulaw@gmail.com 1/12/2023 6:27:11 PM SENT Chris LVaIentine cvalentine@tai|imsong.com 1/12/2023 6:27:11 PM SENT Office Efiles wmchulawefile@gmail.com 1/12/2023 6:27:11 PM SENT Abigael Campbell acampbell@tailimsong.com 1/12/2023 6:27:11 PM SENT