Preview
FILED
5/23/2023 3:48 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Debra Clark DEPUTY
CAUSE NO. DC-21-O7509
VICKIE COOK, Individually ) IN THE 134TH JUDICIAL
and as representative of )
the ESTATE OF DOLLIE )
WAFFER, Deceased, )
)
Plaintiffs )
)
VS. ) DISTRICT COURT OF
)
PM MANAGEMENT GARLAND
—
)
NC, LLC; CTLTC REAL )
ESTATE, LLC; GRANITE )
INVESTMENT GROUP; SILVER )
STAR INVESTMENTS, LLC; )
HARDEN HUD HOLDCO, LLC, )
)
lO Defendants. ) DALLAS COUNTY, TEXAS
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ORAL DEPOSITION OF JESMIN NAWAZ
12
APPEARING REMOTELY FROM
13
MCKINNEY, TEXAS
14
APRIL 7, 2022
15
16 ORAL REMOTE DEPOSITION OF JESMIN NAWAZ, produced as
17 a witness at the instance of the PLAINTIFF, and duly
18 sworn, was taken in the above—styled and numbered cause
19 on April 7, 2022, from 9:59 a.m. to 11:09 a.m., before
20 Jannet Solorzano, CSR, appearing remotely from Dallas
21 County, in and for the State of Texas, reported by
22 machine shorthand, at the location of the witness in
23 McKinney, Texas, pursuant to the Texas Rules of Civil
24 Procedure and the provisions stated on the record or
25 attached hereto.
STEN0.00M
(310) 573-8380
JESMIN NAWAZ JOB NO. 243512
APRIL O7, 2022
CHANGES AND SIGNATURE
2 WITNESS NAME: JESMIN NAWAZ DATE: APRIL 7, 2022
3 PAGE LINE CHANGE REASON
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STEN0.00M
(310) 573-8380 Page 42
JESMIN NAWAZ JOB NO. 243512
APRIL 07, 2022
I, JESMIN NAWAZ, have read the foregoing
deposition and hereby affix my signature that same is
true and correct, except as noted above.
JESMIN NAWAZ
THE STATE OF )
COUNTY 0F )
lO Before me, , on this day
ll personally appeared JESMIN NAWAZ, known to me (or proved
l2 to me under oath or through )
l3 (description of identity card or other document) to be
l4 the person whose name is subscribed to the foregoing
15 instrument and acknowledged to me that they executed the
l6 same for the purposes and consideration therein
l7 expressed.
18 Given under my hand and seal of office this
l9 day of ,
20
21
22
NOTARY PUBLIC IN AND FOR
23 THE STATE OF
COMMISSION EXPIRES:
24
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STEN0.00M
(310) 573-8380 Page 43
JESMIN NAWAZ JOB NO. 243512
APRIL 07, 2022
CAUSE NO. DC-21-O7509
VICKIE COOK, Individually ) IN THE 134TH JUDICIAL
and as representative of )
the ESTATE OF DOLLIE )
WAFFER, Deceased, )
)
Plaintiffs, )
)
VS. )
) DISTRICT COURT OF
PM MANAGEMENT —
GARLAND )
NC, LLC; CTLTC REAL )
ESTATE, LLC; GRANITE )
INVESTMENT GROUP; SILVER )
STAR INVESTMENTS, LLC; )
HARDEN HUD HOLDCO, LLC, )
)
lO Defendants. ) DALLAS COUNTY, TEXAS
ll
REPORTER'S CERTIFICATION
12 ORAL REMOTE DEPOSITION OF JESMIN NAWAZ
APRIL 7, 2022
l3
l4 I, Jannet Solorzano, Certified Shorthand Reporter
15 in and for the State of Texas, hereby certify to the
l6 following:
l7 That the witness, JESMIN NAWAZ, was duly sworn by
18 the officer and that the transcript of the oral
l9 deposition is a true record of the testimony given by
20 the witness;
21 That the deposition transcript was submitted on
22 April 25th, 2022 to the witness or to the attorney
23 for the witness for examination, signature and return to
24 me by May 16th, 2022 ;
25 That the amount of time used by each party at the
STEN0.00M
(310) 573-8380 Page 44
JESMIN NAWAZ JOB NO. 243512
APRIL 07, 2022
deposition is as follows:
Ms. Christy Aderemi — 00:51:50
Ms. Megan Pharis — 00:06:32
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:
Ms. Christy Aderemi, Attorney for Plaintiff
Ms. Megan Pharis, Attorney for Defendant
10 I further certify that I am neither counsel for,
11 related to, nor employed by any of the parties or
l2 attorneys in the action in which this proceeding was
13 taken, and further that I am not financially or
l4 otherwise interested in the outcome of the action.
15 Further certification requirements pursuant to Rule
16 203 of TRCP will be certified to after they have
17 occurred.
18 Certified to by me this 19th day of
19 April, 2022.
2O
21
Jannet Solorzano, Texas CSR 9183
22 Expiration Date: 11/30/2023
STENO, Registration No. 11909
23 1100 Glendon Avenue, Suite 1850
Los Angeles, California 90024
24 (888) 707—8366
25
STEN0.00M
(310) 573-8380 Page 45
JESMIN NAWAZ JOB NO. 243512
APRIL 07, 2022
FURTHER CERTIFICATION UNDER RULE 203 TRCP
The original deposition XXX/was not returned to the
deposition officer on May 16th, 2022 ;
If returned, the attached Changes and Signature
page contains any changes and the reasons therefor;
If returned, the original deposition was delivered
to Christy Aderemi , Custodial Attorney;
That $ 476.45 is the deposition officer's
charges to Ms. Christy Aderemi, for preparing the
10 original deposition transcript and any copies of
11 exhibits;
12 That the deposition was delivered in accordance
13 with Rule 203.3, and that a copy of this certificate was
14 served on all parties shown herein on and filed with the
15 Clerk.
16 Certified to by me this 23rd day of
17 May , 2023.
WM
18
19
20 Jannet Solorzano, Texas CSR 9183
Expiration 11/30/2023
Date:
21 STENO, Registration No. 11909
1100 Glendon Avenue, Suite 1850
22 Los Angeles, California 90024
(888) 707—8366
23
24
25
STEN0.00M
(310) 573-8380 Page 46
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: 75927964
Filing Code Description: Certificate of Deposition
Filing Description: JESMIN NAWAZ
Status as of 5/24/2023 8:57 AM CST
Associated Case Party: PM MANAGEMENT - GARLAND NC LLC
Name BarNumber Email TimestampSubmitted Status
Megan Pharis megan.pharis@qpwblaw.com 5/23/2023 3:48:05 PM SENT
Roseann Gonzales roseann.gonzales@qpwblaw.com 5/23/2023 3:48:05 PM SENT
Frank Alvarez frank.alvarez@qpwblaw.com 5/23/2023 3:48:05 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Patricia McCulloch pmcculloch@tureklawfirm.com 5/23/2023 3:48:05 PM SENT
Douglas Turek dturek@tureklawfirm.com 5/23/2023 3:48:05 PM SENT
Francine Ly fly@da||ascourts.org 5/23/2023 3:48:05 PM SENT
Jacob Runyon jacob@clinesmithfirm.com 5/23/2023 3:48:05 PM SENT
Emily Marr emarr@tureklawfirm.com 5/23/2023 3:48:05 PM SENT
Preview
FILED 5/23/2023 3:48 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Debra Clark DEPUTY CAUSE NO. DC-21-O7509 VICKIE COOK, Individually ) IN THE 134TH JUDICIAL and as representative of ) the ESTATE OF DOLLIE ) WAFFER, Deceased, ) ) Plaintiffs ) ) VS. ) DISTRICT COURT OF ) PM MANAGEMENT GARLAND — ) NC, LLC; CTLTC REAL ) ESTATE, LLC; GRANITE ) INVESTMENT GROUP; SILVER ) STAR INVESTMENTS, LLC; ) HARDEN HUD HOLDCO, LLC, ) ) lO Defendants. ) DALLAS COUNTY, TEXAS ll ORAL DEPOSITION OF JESMIN NAWAZ 12 APPEARING REMOTELY FROM 13 MCKINNEY, TEXAS 14 APRIL 7, 2022 15 16 ORAL REMOTE DEPOSITION OF JESMIN NAWAZ, produced as 17 a witness at the instance of the PLAINTIFF, and duly 18 sworn, was taken in the above—styled and numbered cause 19 on April 7, 2022, from 9:59 a.m. to 11:09 a.m., before 20 Jannet Solorzano, CSR, appearing remotely from Dallas 21 County, in and for the State of Texas, reported by 22 machine shorthand, at the location of the witness in 23 McKinney, Texas, pursuant to the Texas Rules of Civil 24 Procedure and the provisions stated on the record or 25 attached hereto. STEN0.00M (310) 573-8380 JESMIN NAWAZ JOB NO. 243512 APRIL O7, 2022 CHANGES AND SIGNATURE 2 WITNESS NAME: JESMIN NAWAZ DATE: APRIL 7, 2022 3 PAGE LINE CHANGE REASON 4 5 6 7 10 ll 12 l3 l4 15 l6 l7 18 19 20 21 22 23 24 25 STEN0.00M (310) 573-8380 Page 42 JESMIN NAWAZ JOB NO. 243512 APRIL 07, 2022 I, JESMIN NAWAZ, have read the foregoing deposition and hereby affix my signature that same is true and correct, except as noted above. JESMIN NAWAZ THE STATE OF ) COUNTY 0F ) lO Before me, , on this day ll personally appeared JESMIN NAWAZ, known to me (or proved l2 to me under oath or through ) l3 (description of identity card or other document) to be l4 the person whose name is subscribed to the foregoing 15 instrument and acknowledged to me that they executed the l6 same for the purposes and consideration therein l7 expressed. 18 Given under my hand and seal of office this l9 day of , 20 21 22 NOTARY PUBLIC IN AND FOR 23 THE STATE OF COMMISSION EXPIRES: 24 25 STEN0.00M (310) 573-8380 Page 43 JESMIN NAWAZ JOB NO. 243512 APRIL 07, 2022 CAUSE NO. DC-21-O7509 VICKIE COOK, Individually ) IN THE 134TH JUDICIAL and as representative of ) the ESTATE OF DOLLIE ) WAFFER, Deceased, ) ) Plaintiffs, ) ) VS. ) ) DISTRICT COURT OF PM MANAGEMENT — GARLAND ) NC, LLC; CTLTC REAL ) ESTATE, LLC; GRANITE ) INVESTMENT GROUP; SILVER ) STAR INVESTMENTS, LLC; ) HARDEN HUD HOLDCO, LLC, ) ) lO Defendants. ) DALLAS COUNTY, TEXAS ll REPORTER'S CERTIFICATION 12 ORAL REMOTE DEPOSITION OF JESMIN NAWAZ APRIL 7, 2022 l3 l4 I, Jannet Solorzano, Certified Shorthand Reporter 15 in and for the State of Texas, hereby certify to the l6 following: l7 That the witness, JESMIN NAWAZ, was duly sworn by 18 the officer and that the transcript of the oral l9 deposition is a true record of the testimony given by 20 the witness; 21 That the deposition transcript was submitted on 22 April 25th, 2022 to the witness or to the attorney 23 for the witness for examination, signature and return to 24 me by May 16th, 2022 ; 25 That the amount of time used by each party at the STEN0.00M (310) 573-8380 Page 44 JESMIN NAWAZ JOB NO. 243512 APRIL 07, 2022 deposition is as follows: Ms. Christy Aderemi — 00:51:50 Ms. Megan Pharis — 00:06:32 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: Ms. Christy Aderemi, Attorney for Plaintiff Ms. Megan Pharis, Attorney for Defendant 10 I further certify that I am neither counsel for, 11 related to, nor employed by any of the parties or l2 attorneys in the action in which this proceeding was 13 taken, and further that I am not financially or l4 otherwise interested in the outcome of the action. 15 Further certification requirements pursuant to Rule 16 203 of TRCP will be certified to after they have 17 occurred. 18 Certified to by me this 19th day of 19 April, 2022. 2O 21 Jannet Solorzano, Texas CSR 9183 22 Expiration Date: 11/30/2023 STENO, Registration No. 11909 23 1100 Glendon Avenue, Suite 1850 Los Angeles, California 90024 24 (888) 707—8366 25 STEN0.00M (310) 573-8380 Page 45 JESMIN NAWAZ JOB NO. 243512 APRIL 07, 2022 FURTHER CERTIFICATION UNDER RULE 203 TRCP The original deposition XXX/was not returned to the deposition officer on May 16th, 2022 ; If returned, the attached Changes and Signature page contains any changes and the reasons therefor; If returned, the original deposition was delivered to Christy Aderemi , Custodial Attorney; That $ 476.45 is the deposition officer's charges to Ms. Christy Aderemi, for preparing the 10 original deposition transcript and any copies of 11 exhibits; 12 That the deposition was delivered in accordance 13 with Rule 203.3, and that a copy of this certificate was 14 served on all parties shown herein on and filed with the 15 Clerk. 16 Certified to by me this 23rd day of 17 May , 2023. WM 18 19 20 Jannet Solorzano, Texas CSR 9183 Expiration 11/30/2023 Date: 21 STENO, Registration No. 11909 1100 Glendon Avenue, Suite 1850 22 Los Angeles, California 90024 (888) 707—8366 23 24 25 STEN0.00M (310) 573-8380 Page 46 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: 75927964 Filing Code Description: Certificate of Deposition Filing Description: JESMIN NAWAZ Status as of 5/24/2023 8:57 AM CST Associated Case Party: PM MANAGEMENT - GARLAND NC LLC Name BarNumber Email TimestampSubmitted Status Megan Pharis megan.pharis@qpwblaw.com 5/23/2023 3:48:05 PM SENT Roseann Gonzales roseann.gonzales@qpwblaw.com 5/23/2023 3:48:05 PM SENT Frank Alvarez frank.alvarez@qpwblaw.com 5/23/2023 3:48:05 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Patricia McCulloch pmcculloch@tureklawfirm.com 5/23/2023 3:48:05 PM SENT Douglas Turek dturek@tureklawfirm.com 5/23/2023 3:48:05 PM SENT Francine Ly fly@da||ascourts.org 5/23/2023 3:48:05 PM SENT Jacob Runyon jacob@clinesmithfirm.com 5/23/2023 3:48:05 PM SENT Emily Marr emarr@tureklawfirm.com 5/23/2023 3:48:05 PM SENT