Preview
FILED
12/9/2022 4:21 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Margaret Thomas DEPUTY
CAUSE NO. DC-2 1 -04901
TONY EVANS, SR. and ARETHA EVANS, ) IN THE DISTRICT COURT
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 WILLLAMS, )
)
Plaintiffs, )
)
V.
l
TASACOM REAL ESTATE, LLC d/b/a ) 162nd JUDICIAL DISTRICT
HAWTHORN SUITES DALLAS LOVE FIELD, )
HAWTHORN SUITES FRANCHISING, INC, )
WYNDHAM HOTELS & RESORTS, 1NC., )
MOHAMMAD SADIQ NOSHAHI, )
DIAMOND STAFFING SERVICES, LLC, )
WYNDHAM HOTEL GROUP, LLC, )
TASACOM TECHNOLOGIES, INC., SANJEEV )
JAIN and MMAROOFUL CHOUDHURY,
3
Defendants. ) DALLAS COUNTY, TEXAS
To: CDS Protective Services, LLC
Through its Registered Agent:
Craig Swan
8551 La Prada Dr., #1114
Dallas, Texas 75228
PLEASE TAKE NOTICE that you are required to produce the following items by 3:00 p.m., on
January 9, 2023, at The Witherspoon Law Group, 5565 Deer Creek, Unit A, Dallas, Texas 75228
to TaWana Stegall or any other representative at that location or Via email to Emily Taylor at
tavlor@twlglawvers.com.
This Notice is being served in connection with the above-styled lawsuit, involving the shooting
death of minor T.E. and gun-related injuries to Plaintiff Deon Williams, on April 11, 2021, at
Tasacom Real Estate d/b/a Hawthorn Suites Dallas Love Field located at 7900 Brookriver Drive,
Dallas, Texas 75347.
NOTICE - Page 1 of 4
Documents to Produce
. A11 correspondence, including emails, text messages, electronic messages of any kind,
letters, memoranda, and/or notes between CDS Protective Services, LLC, including its
employees, agents, and representatives, and any of the Defendants in the above-styled
lawsuit or their representatives or employees that relate to the Hawthorn Suites by
Wyndham hotel located at 7900 Brookriver Drive, Dallas, Texas 75347.
. All correspondence, including emails, text messages, electronic messages of any kind,
letters, memoranda, and/or notes by or between any employees, representatives, or agents
of CDS Protective Services, LLC, related to the Hawthorn Suites by Wyndham hotel
located at 7900 Brookriver Drive, Dallas, Texas 75347.
. All contracts, work orders, invoicing, written understandings and/ or agreements in the
possession of CDS Protective Services, LLC, that are related to the Hawthorn Suites by
Wyndham hotel located at 7900 Brookriver Drive, Dallas, Texas 75347.
. Documents identifying the employees, agents, and/or representatives of CDS Protective
Services, LLC, that provided security services at the Hawthorn Suites by Wyndham hotel
located at 7900 Brookriver Drive, Dallas, Texas 75347 for the previous three years,
including their full name and last known address and telephone number.
. Documents identifying the payor(s) for all compensation received by CDS Protective
Services, LLC, for services rendered on the premises of the Hawthorn Suites by Wyndham
hotel located at 7900 Brookriver Drive, Dallas, Texas 75 347.
This Notice is being provided pursuant to Texas Rules of Civil Procedure 205.2 and 205.3.
Respectfiilly Submitted,
/s/Nuru Witherspoon /s/Aubrev ”Nick” Pittman
NURU WITHERSPOON AUBREY “NICK” PITTMAN
State Bar No. 24039244 State Bar No. 16049750
witherspoon@twlglawyers.com
THE PITTMAN LAw FIRM, P.C.
EMILY TAYLOR 100 Crescent Court, Suite 700
State Bar No_ 24046951 Dallas, Texas 75201-21 l2
taylor@twlglawyers.com 214-459-3454 — Telephone
214-853-5912 - Fax
WITHERSPOON LAW GROUP pittman@thepittmanlawfirm.com
5565 Deer Creek, Unit A
ATTORNEYS FOR PLAINTIFFS
Dallas, Texas 75228
214-773-1133 — Telephone
972-696-9982 — Fax
NOTICE - Page 2 of 4
CERTIFICATE OF SERVICE
The undersigned certifies that on the 9th day of December 2022, a true and correct copy of
the foregoing document was served Via Rule 21a to all attorneys of record in this lawsuit.
EmilV TaVlor
/s/
Emily Taylor
NOTICE - Page 3 of 4
MEMORANDUM OF ACCEPTANCE
I accepted service of a copy of this notice on [date].
Signature on behalf of CDS Protective
Services, LLC
Printed Name
RETURN
I certify that I served the annexed notice by delivering a copy, in person, at CDS Protective
Services, LLC, through its Registered Agent, Craig Swan, at 8551 La Prada Dr., #1114
Dallas, Texas 75228, on [date].
Signature
Printed Name
Company/Title
NOTICE - Page 4 of 4
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.
Brisia Mendoza on behalf of Emily Taylor
Bar No. 24046951
mendoza@twlglawyers.com
Envelope ID: 70884173
Status as of 12/12/2022 7:58 AM CST
Associated Case Party: TONY EVANS
Name BarN um ber Email TimestampSubmitted Status
Emily Taylor taylor@twlglawyers.com 12/9/2022 4:21 :40 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 12/9/2022 4:21:40 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 12/9/2022 4:21:40 PM SENT
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 12/9/2022 4:21:40 PM SENT
Morgan Wells mwells@thompsoncoe.com 12/9/2022 4:21:40 PM SENT
LISA V lvillasenor@thompsoncoe.com 12/9/2022 4:21:40 PM SENT
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email Timestam pSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 12/9/2022 4:21:40 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 12/9/2022 4:21:40 PM SENT
Ronald DHinds rdhinds@verizon.net 12/9/2022 4:21:40 PM SENT
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email Timestam pSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 12/9/2022 4:21:40 PM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 12/9/2022 4:21:40 PM SENT
Ronald DHinds rdhinds@verizon.net 12/9/2022 4:21:40 PM SENT
Case Contacts
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.
Brisia Mendoza on behalf of Emily Taylor
Bar No. 24046951
mendoza@twlglawyers.com
Envelope ID: 70884173
Status as of 12/12/2022 7:58 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
NURU WITHERSPOON witherspoon@twlglawyers.com 12/9/2022 4:21 :40 PM SENT
Sally Jones sally.jones@dlapiper.com 12/9/2022 4:21:40 PM SENT
RoseMarie Chambers rose.chambers@dlapiper.com 12/9/2022 4:21:40 PM SENT
sherry M.fau|kner sherry.faulkner@us.dlapiper.com 12/9/2022 4:21:40 PM SENT
Associated Case Party: T. E.
Name BarN um ber Email TimestampSubmitted Status
Emily Taylor taylor@tw|glawyers.com 12/9/2022 4:21 :40 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 12/9/2022 4:21:40 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 12/9/2022 4:21:40 PM SENT
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Emily Taylor taylor@tw|glawyers.com 12/9/2022 4:21 :40 PM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 12/9/2022 4:21:40 PM SENT
Nuru Witherspoon litigation@twlglawyers.com 12/9/2022 4:21:40 PM SENT
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 12/9/2022 4:21 :40 PM SENT
Eva DeLeon edeleon@thompsoncoe.com 12/9/2022 4:21:40 PM SENT
Preview
FILED 12/9/2022 4:21 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Margaret Thomas DEPUTY CAUSE NO. DC-2 1 -04901 TONY EVANS, SR. and ARETHA EVANS, ) IN THE DISTRICT COURT 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 WILLLAMS, ) ) Plaintiffs, ) ) V. l TASACOM REAL ESTATE, LLC d/b/a ) 162nd JUDICIAL DISTRICT HAWTHORN SUITES DALLAS LOVE FIELD, ) HAWTHORN SUITES FRANCHISING, INC, ) WYNDHAM HOTELS & RESORTS, 1NC., ) MOHAMMAD SADIQ NOSHAHI, ) DIAMOND STAFFING SERVICES, LLC, ) WYNDHAM HOTEL GROUP, LLC, ) TASACOM TECHNOLOGIES, INC., SANJEEV ) JAIN and MMAROOFUL CHOUDHURY, 3 Defendants. ) DALLAS COUNTY, TEXAS To: CDS Protective Services, LLC Through its Registered Agent: Craig Swan 8551 La Prada Dr., #1114 Dallas, Texas 75228 PLEASE TAKE NOTICE that you are required to produce the following items by 3:00 p.m., on January 9, 2023, at The Witherspoon Law Group, 5565 Deer Creek, Unit A, Dallas, Texas 75228 to TaWana Stegall or any other representative at that location or Via email to Emily Taylor at tavlor@twlglawvers.com. This Notice is being served in connection with the above-styled lawsuit, involving the shooting death of minor T.E. and gun-related injuries to Plaintiff Deon Williams, on April 11, 2021, at Tasacom Real Estate d/b/a Hawthorn Suites Dallas Love Field located at 7900 Brookriver Drive, Dallas, Texas 75347. NOTICE - Page 1 of 4 Documents to Produce . A11 correspondence, including emails, text messages, electronic messages of any kind, letters, memoranda, and/or notes between CDS Protective Services, LLC, including its employees, agents, and representatives, and any of the Defendants in the above-styled lawsuit or their representatives or employees that relate to the Hawthorn Suites by Wyndham hotel located at 7900 Brookriver Drive, Dallas, Texas 75347. . All correspondence, including emails, text messages, electronic messages of any kind, letters, memoranda, and/or notes by or between any employees, representatives, or agents of CDS Protective Services, LLC, related to the Hawthorn Suites by Wyndham hotel located at 7900 Brookriver Drive, Dallas, Texas 75347. . All contracts, work orders, invoicing, written understandings and/ or agreements in the possession of CDS Protective Services, LLC, that are related to the Hawthorn Suites by Wyndham hotel located at 7900 Brookriver Drive, Dallas, Texas 75347. . Documents identifying the employees, agents, and/or representatives of CDS Protective Services, LLC, that provided security services at the Hawthorn Suites by Wyndham hotel located at 7900 Brookriver Drive, Dallas, Texas 75347 for the previous three years, including their full name and last known address and telephone number. . Documents identifying the payor(s) for all compensation received by CDS Protective Services, LLC, for services rendered on the premises of the Hawthorn Suites by Wyndham hotel located at 7900 Brookriver Drive, Dallas, Texas 75 347. This Notice is being provided pursuant to Texas Rules of Civil Procedure 205.2 and 205.3. Respectfiilly Submitted, /s/Nuru Witherspoon /s/Aubrev ”Nick” Pittman NURU WITHERSPOON AUBREY “NICK” PITTMAN State Bar No. 24039244 State Bar No. 16049750 witherspoon@twlglawyers.com THE PITTMAN LAw FIRM, P.C. EMILY TAYLOR 100 Crescent Court, Suite 700 State Bar No_ 24046951 Dallas, Texas 75201-21 l2 taylor@twlglawyers.com 214-459-3454 — Telephone 214-853-5912 - Fax WITHERSPOON LAW GROUP pittman@thepittmanlawfirm.com 5565 Deer Creek, Unit A ATTORNEYS FOR PLAINTIFFS Dallas, Texas 75228 214-773-1133 — Telephone 972-696-9982 — Fax NOTICE - Page 2 of 4 CERTIFICATE OF SERVICE The undersigned certifies that on the 9th day of December 2022, a true and correct copy of the foregoing document was served Via Rule 21a to all attorneys of record in this lawsuit. EmilV TaVlor /s/ Emily Taylor NOTICE - Page 3 of 4 MEMORANDUM OF ACCEPTANCE I accepted service of a copy of this notice on [date]. Signature on behalf of CDS Protective Services, LLC Printed Name RETURN I certify that I served the annexed notice by delivering a copy, in person, at CDS Protective Services, LLC, through its Registered Agent, Craig Swan, at 8551 La Prada Dr., #1114 Dallas, Texas 75228, on [date]. Signature Printed Name Company/Title NOTICE - Page 4 of 4 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. Brisia Mendoza on behalf of Emily Taylor Bar No. 24046951 mendoza@twlglawyers.com Envelope ID: 70884173 Status as of 12/12/2022 7:58 AM CST Associated Case Party: TONY EVANS Name BarN um ber Email TimestampSubmitted Status Emily Taylor taylor@twlglawyers.com 12/9/2022 4:21 :40 PM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 12/9/2022 4:21:40 PM SENT Nuru Witherspoon litigation@twlglawyers.com 12/9/2022 4:21:40 PM SENT Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 12/9/2022 4:21:40 PM SENT Morgan Wells mwells@thompsoncoe.com 12/9/2022 4:21:40 PM SENT LISA V lvillasenor@thompsoncoe.com 12/9/2022 4:21:40 PM SENT Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email Timestam pSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 12/9/2022 4:21:40 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 12/9/2022 4:21:40 PM SENT Ronald DHinds rdhinds@verizon.net 12/9/2022 4:21:40 PM SENT Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email Timestam pSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 12/9/2022 4:21:40 PM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 12/9/2022 4:21:40 PM SENT Ronald DHinds rdhinds@verizon.net 12/9/2022 4:21:40 PM SENT Case Contacts 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. Brisia Mendoza on behalf of Emily Taylor Bar No. 24046951 mendoza@twlglawyers.com Envelope ID: 70884173 Status as of 12/12/2022 7:58 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status NURU WITHERSPOON witherspoon@twlglawyers.com 12/9/2022 4:21 :40 PM SENT Sally Jones sally.jones@dlapiper.com 12/9/2022 4:21:40 PM SENT RoseMarie Chambers rose.chambers@dlapiper.com 12/9/2022 4:21:40 PM SENT sherry M.fau|kner sherry.faulkner@us.dlapiper.com 12/9/2022 4:21:40 PM SENT Associated Case Party: T. E. Name BarN um ber Email TimestampSubmitted Status Emily Taylor taylor@tw|glawyers.com 12/9/2022 4:21 :40 PM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 12/9/2022 4:21:40 PM SENT Nuru Witherspoon litigation@twlglawyers.com 12/9/2022 4:21:40 PM SENT Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Emily Taylor taylor@tw|glawyers.com 12/9/2022 4:21 :40 PM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 12/9/2022 4:21:40 PM SENT Nuru Witherspoon litigation@twlglawyers.com 12/9/2022 4:21:40 PM SENT Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 12/9/2022 4:21 :40 PM SENT Eva DeLeon edeleon@thompsoncoe.com 12/9/2022 4:21:40 PM SENT