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FILED
9/28/2023 9:14 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Janieshia Reed DEPUTY
CAUSE N0.
TONY EVANS, SR... ct 81., § IN THE DISTRICT COURT
§
§
Plaintiffls), §
vs. § I62ND JUDICIAL DISTRICT
'91
TASACOM REAL ESTATE. LLC. et ah. §
§
Defendanfls). § DALLAS COUNTY. TEXAS
RETURN OF SERVICE
Came to my hand on Friday, September 22, 2023 at 5:00 PM,
Executed at: 505 ANNE PRESTON, LOT 52 PARKING LOT, PRAIRIE VIEW, TX 77446
at 5:15 PM, on Saturday, September 23, 2023, by individually and personally delivering to the within
named:
ANIYAH WILLIAMS
a true copy of this
SUBPOENA DUCES TECUM with EXHIBIT A
having first endorsed thereon the date of the delivery.
An $1 [.00 witness fee was tendered.
BEFORE ME, the undersigned authority, on this day personally appeared BERT SCHULZE who afler being duly sworn
on oath states: "My name is BERT SCHULZE. I am a person not less than eighteen (18) years of age and I am competent
to make this oath. I am a resident of the State of Texas; I have personal knowledge of the facts and statements contained
herein and aver that each is true and correct. 1 am not a party to nor related or affiliated with any party to this suit. I have
no interest in the outcome of the suit. I have never been convicted of a felony or of a misdemeanor involving moral
turpitude. I am familiar with the Texas Rules of Civil Procedure, and the Texas Civil
Practice and Remedies Codes as
Judicial Branch Certification Commission to deliver citations and
they apply to service of process. i am certified by the
other notices from any District, County and Justice Counts in and for the State of Texas in compliance with rule Hill and
501.2 of the TRCP."
By: 5QZ
BERT SCHULZE %% éPS 08 EXP 7-31-2024
served@speclaldelivery.com
Subscribed and Sworn to by BERT SCHULZE, Before Me, the undersigned authority, on this
,g 5: day of September, 2023.
Notary Public in and for the State of Texas
ANDREA LUCILLE SHUC K
My Notary ID at 131992352
30 Expires April 29. 2027
THE STATE OF TEXAS
SUBPOENA FOR TESTIMONY AND PRODUCTION OF DOCUMENTS
PURSUANT TO RULE 176 OF TEXAS RULES OF CIVIL PROCEDURE
CAUSE No. DC-21-04901
TONY EVANS, SR., and ARE’I‘HA EVANS, §
individually and on behalf of their minor son, § IN THE DISTRICT COURT OF
T.B., deceased, FAITH TANKSLEY on behalf §
of minor, T.E., III, individually and on behalf of §
his father T.E., deceased, and DEON
WILLIAMS g
§ DALLAS COUNTY, TEXAS
Plaintifllc, §
§
vs.
é
TASACOM REAL ESTATE, LLC, ET AL. § 162‘” JUDICIAL DISTRICT
§
Defendants. §
§u§POENA DUCES TECUM
To: Any person authorized under the laws of the State of Texas to serve subpoenas as provided
in Rule 176 of the Texas Rules of Civil Procedure
YOU ARE HEREBY COMMANDED to summon Aniyah Williams at 2464 Marimont
Lane, Lancaster, Texas 75134 (or wherever he or she may be found), 267.235.3592 to appear for
an in-person deposition at the offices of DLA Piper LLP (US), 845 Texas Avenue, Suite 3800,
Houston, Texas 77002, 713.425. 8449, at 9:00 a.m. (CST) on October 4, 2023, then and there to
testify as a witness in the above-referenced civil action, and to attend from day to day until lawfully
discharged, and to produce and permit inspection and copying of the documents or tangible things
identified in the attached Exhibit A, to be used as evidence in this case.
Duties of Person Served with Subpoena. A person served with a discovery subpoena has
certain rights and obligations. Rule 176.6 provides the following:
(a) Compliance required Except as provided in this subdivision, a person served
with a subpoena must comply with the command stated therein unless discharged
by the court or by the party summoning such witness. A person commanded to
appear and give testimony must remain at the place of deposition, hearing, or trial
from day to day until discharged by the court or by the party summoning the
witness.
(b) Organizations. If a subpoena commanding testimony is directed to a
corporation, partnership, association, governmental agency, or other organization,
and the matters on which examination is requested are described with reasonable
particularity, the organization must designate one or more persons to testify on its
behalf as to matters known or reasonably available to the organization.
(c) Production ofdocuments or tangible things. A person commanded to produce
documents or tangible things need not appear in person at the time and place of
production unless the person is also commanded to attend and give testimony, either
in the same subpoena or a separate one. A person must produce documents as they
are kept in the usual course of business or must organize and label them to
correspond with the categories in the demand. A person may withhold material or
information claimed to be privileged but must comply with Rule 193.3. A
nonparty’s production of a document authenticates the document for use against the
non-party to the same extent as a party’s production of a document is authenticated
for use against the party under Rule 193.7.
(d) Objections. A person commanded to produce and permit inspection and
copying of designated documents and things may serve on the party requesting
issuance of the subpoena—before the time specified for compliance—written
objections to producing any or all of the designated materials. A person need not
comply with the part of a subpoena to which objection is made as provided in this
paragraph unless ordered to do so by the court. The party requesting the subpoena
may move for such an order at any time afier an objection is made.
(e) Protective orders. A person commanded to appear at a deposition, hearing, or
trial, or to produce and permit inspection and copying of designated documents and
things may move for a protective order under Rule l92.6(b)—before the time
specified for compliance—either in the court in which the action is pending or in a
district court in the county where the subpoena was served. The person must serve
the motion on all parties in accordance with Rule 21a. A person need not comply
with the part of a subpoena from which protection is sought under this paragraph
unless ordered to do so by the court. The party requesting the subpoena may seek
such an order at any time afier the motion for protection is filed.
(t) Trial Subpoenas. A person commanded to attend and give testimony, or to
produce documents or things, at a hearing or trial, may object or move for protective
order before the court at the time and place specified for compliance, rather than
under paragraphs (d) and (e).
Contempt. FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO
OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A CONTEMPT
0F THE COURT FROM WHICH THE SUBPOENA IS ISSUED OR A DISTRICT COURT IN
THE COUNTY IN WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED BY
FINE OR CONFINEMENT, 0R BOTH.
D0 NOT FAIL to return this writ to the 162nd District Court of Harris County, Texas, with
either the return showing the manner of execution or the witness’s signed memorandum showing
that the witness accepted the subpoena.
This subpoena is issued at the request of Defendants Wyndham Hotels & Resorts, inc.,
Wyndham Hotel Group, LLC, and Hawthorn Suites Franchising, Inc., whose counsel of record are
Jason Hopkins, DLA Piper LLP (US), 1900 N. Pearl Street, Suite 2200, Dallas, Texas 75201,
214.743.4546, iasonhopkins@us.dlapiper.com, and Christopher B. Donovan, DLA Piper LLP
(US), 845 Texas Ave., Suite 3800, Houston, Texas 77002, 713.425.8449,
christepher.b.donovan@us.dlgpipggcom. Please contact Mr. Hopkins or Mr. Donovan to arrange
a different time or place for compliance.
ISSUED thi322nd day of September 2023. DLA PIPER LLP (US)
lg Christopher B. Dongvgn
Jason M. Hopkins
State Bar No. 24059969
jason.hopkins@dlapiper.com
1900 N. Pearl St. Suite 2200
Dallas, Texas 75201
T: 214.743.4500
F: 214.743.4545
Christopher B. Donovan
State Bar No. 24097614
christopher.b.donovan@dlapiper.com
845 Texas Avenue, Suite 3800
Houston, Texas 77002
T: 713.425.8400
F: 713.425.8401
David S. Sager, pro hac vice
51 John F. Kennedy Parkway, Suite 120
Short Hills, New Jersey 07078
david.sager@us.dlapiper.corn
T: 973.520.2550
F: 973.520.2551
Counselfor Defendants
Wyndham Hotels & Resorts, Ina,
Wyndham Hotel Group, LLC, and
Hawthorn Suites Franchising, Inc.
mum / mum!“
mom / macaw
RETURN 0F SERVICE OF SUBPOENA
I, , delivered a copy of this subpoena to
in person at , in
County, Texas on , 2022 at ‘clock
_m, and tendered to the witness a fee of $ in cash.
l, , was unable to deliver a copy of this subpoena to
for the following reasons:
By Deputy:
Sherifi‘fConstable
, County, Texas
By:
Person authorized by law or written order of the trial
court who has no interest in the lawsuit and is at least
18 years old.
ACCEPTANCE OF SERVICE 0F SUBPOENA BY
WITNESS UNDER TEXAS RQLE QF CIVIL PROCEDURE l7§
I accept service of this subpoena.
Witness
Date
Fee for service of Subpoena: $
EXI-HBIT A
I. DEFINITIONS
The following definitions are an integral part of these requests for documents, and they are
applicable throughout:
A. The terms “document” and “documents” are to be construed broadly and are
defined to be synonymous in meaning and equal in scope to the usage of such terms in Rule 192.3
of the Texas Rules of Civil Procedure. Such terms include, without limitation, any medium upon
or by which information is or can be recorded, including but not limited to papers, books, letters,
labels (and other identifying markings), e-mails, social media, electronically-stored information,
facsimile transmissions, notes, drafts, diaries, reports, analyses, studies, invoices, promotional
literature, sales literature, profit projections, computer generated information, audits, checks, bank
statements, calendars, records, correspondence, memoranda, notebooks, photographs, pictures,
diagrams, graphs, charts, drawings and sketches, non-written material such as videotapes, video
recordings, audiotapes, tape recordings, CDs, and electronic and computer data compilations,
translated, if indicated, into a reasonably usable format.
B. The terms “referring,” “relating to,” and “concerning” include in whole or in part
directly or indirectly, analyzing, containing, supporting, concerned with, connected with, dealing
with, constituting, describing, relevant to or pertaining to the identified person, document or
subject matter.
C. The terms “communicate” and “communication” mean every manner or means of
disclosure, transfer, or exchange, and every disclosure, transfer, or exchange of information,
whether made or accomplished orally or by document, whether face-to-face, by telephone, mail,
telex, facsimile, electronic mail, personal delivery, social media, or otherwise without limitation.
D. The term “photograph” includes all corresponding metadata.
E. The terms “person” and “persons” any natural person, individual, corporation,
proprietorship, partnership, association, joint venture, limited liability company, trust, company,
firm, or other form of legal entity, organization, or arrangement.
F. The term “social media” includes any form of electronic communication through
which users create online communities or relationships to share in-formation, ideas, personal
messages, and other content—including, but not limited to, Facebook, Myspace, WhatsApp,
Twitter, Instagram, Tumblr, Pinterest, Google+, Linkedln, WeChat, Snapchat, Telegram, Reddit,
You'l‘ube, Venmo, Cash App, and Tik Tok.
G. “Activity Log” means any activity log, account history, or other data or
generatable/downloadable report reflecting activity on a social media account. That includes, but
is not limited to, data and outputs that are accessible by following guidance provided by Facebook,
lnstagram, and Snapchat at the following URLs, respectively:
- Facebook |
Find your Faceboak activity log
https://www.facebook.com/hclpf28906682779l446
- Instagram See your Instagram account history
|
https://help.instagram.com/4604l 1 10881 1350
- Snapchat How do I download my datafiom Snapchat,
|
httpsz/Ihelp.snapchat.com/hc/en-us/articles/701230537l lSé-How-do-I-
download-my-data-from-Snapchat-
H. The word “all” includes “any”; the word “any” includes “all.”
l. The use of the terms “and,” “or,” and “and/or” should be construed conjunctively
and disjunctively for the broadest possible meaning.
J. Whenever appropriate to bring within the sc0pe of these requests information that
could lead to the discovery of relevant evidence, the singular form of a word shall also mean the
plural.
II. INSTRUCTIONS
The following instructions apply to each request made herein.
A. To the extent materials requested are maintained in hard copy form, they may be
scanned and produced in electronic format, as long as the electronic scan accurately reflects the
complete contents of the hard copy document.
B. lf the requested documents are maintained in a file, the file folder is to be included
as part of the materials produced.
C. Electronically stored information shall be produced its native format.
electronically stored information may be produced in the first instance in PDF or other readable
format, provided that (i) the produced document accurately and completely reflects the contents of
the electronically stored information, and (ii) the subpoenaing parties afierward may insist on the
production of documents in native format insofar as they deem it necessary and/or appropriate.
III. REQUESTS FOR DOCUMENTS
l. Produce all documents and communications referring or relating to the shooting
that occurred on or around April ll,
2021 on the premises of the hotel located at
7900 Brookriver Drive, Dallas, Texas 75247 (the “Hotel”), as well as all events
leading up to that incident.
2. Produce all documents and communications sent to or received from the Dallas
Police Department or the Dallas County District Attomey’s Office (or any other
law enforcement or prosecutorial agency or government body), regarding, relating
to, or in connection with the shooting that occurred at the Hotel on or around April
l l, 2021.
Produce all documents and communications reflecting who was present at the Hotel
on April ll, 2021.
Produce all of your communications from April 2021 onward with anyone who was
present at Hotel on Aprilll,
2021.
Produce all of your social media content, including any Activity Log reflecting or
relating to such content, from April 10, 2021 through April 12, 2021.
Preview
FILED 9/28/2023 9:14 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Janieshia Reed DEPUTY CAUSE N0. TONY EVANS, SR... ct 81., § IN THE DISTRICT COURT § § Plaintiffls), § vs. § I62ND JUDICIAL DISTRICT '91 TASACOM REAL ESTATE. LLC. et ah. § § Defendanfls). § DALLAS COUNTY. TEXAS RETURN OF SERVICE Came to my hand on Friday, September 22, 2023 at 5:00 PM, Executed at: 505 ANNE PRESTON, LOT 52 PARKING LOT, PRAIRIE VIEW, TX 77446 at 5:15 PM, on Saturday, September 23, 2023, by individually and personally delivering to the within named: ANIYAH WILLIAMS a true copy of this SUBPOENA DUCES TECUM with EXHIBIT A having first endorsed thereon the date of the delivery. An $1 [.00 witness fee was tendered. BEFORE ME, the undersigned authority, on this day personally appeared BERT SCHULZE who afler being duly sworn on oath states: "My name is BERT SCHULZE. I am a person not less than eighteen (18) years of age and I am competent to make this oath. I am a resident of the State of Texas; I have personal knowledge of the facts and statements contained herein and aver that each is true and correct. 1 am not a party to nor related or affiliated with any party to this suit. I have no interest in the outcome of the suit. I have never been convicted of a felony or of a misdemeanor involving moral turpitude. I am familiar with the Texas Rules of Civil Procedure, and the Texas Civil Practice and Remedies Codes as Judicial Branch Certification Commission to deliver citations and they apply to service of process. i am certified by the other notices from any District, County and Justice Counts in and for the State of Texas in compliance with rule Hill and 501.2 of the TRCP." By: 5QZ BERT SCHULZE %% éPS 08 EXP 7-31-2024 served@speclaldelivery.com Subscribed and Sworn to by BERT SCHULZE, Before Me, the undersigned authority, on this ,g 5: day of September, 2023. Notary Public in and for the State of Texas ANDREA LUCILLE SHUC K My Notary ID at 131992352 30 Expires April 29. 2027 THE STATE OF TEXAS SUBPOENA FOR TESTIMONY AND PRODUCTION OF DOCUMENTS PURSUANT TO RULE 176 OF TEXAS RULES OF CIVIL PROCEDURE CAUSE No. DC-21-04901 TONY EVANS, SR., and ARE’I‘HA EVANS, § individually and on behalf of their minor son, § IN THE DISTRICT COURT OF T.B., deceased, FAITH TANKSLEY on behalf § of minor, T.E., III, individually and on behalf of § his father T.E., deceased, and DEON WILLIAMS g § DALLAS COUNTY, TEXAS Plaintifllc, § § vs. é TASACOM REAL ESTATE, LLC, ET AL. § 162‘” JUDICIAL DISTRICT § Defendants. § §u§POENA DUCES TECUM To: Any person authorized under the laws of the State of Texas to serve subpoenas as provided in Rule 176 of the Texas Rules of Civil Procedure YOU ARE HEREBY COMMANDED to summon Aniyah Williams at 2464 Marimont Lane, Lancaster, Texas 75134 (or wherever he or she may be found), 267.235.3592 to appear for an in-person deposition at the offices of DLA Piper LLP (US), 845 Texas Avenue, Suite 3800, Houston, Texas 77002, 713.425. 8449, at 9:00 a.m. (CST) on October 4, 2023, then and there to testify as a witness in the above-referenced civil action, and to attend from day to day until lawfully discharged, and to produce and permit inspection and copying of the documents or tangible things identified in the attached Exhibit A, to be used as evidence in this case. Duties of Person Served with Subpoena. A person served with a discovery subpoena has certain rights and obligations. Rule 176.6 provides the following: (a) Compliance required Except as provided in this subdivision, a person served with a subpoena must comply with the command stated therein unless discharged by the court or by the party summoning such witness. A person commanded to appear and give testimony must remain at the place of deposition, hearing, or trial from day to day until discharged by the court or by the party summoning the witness. (b) Organizations. If a subpoena commanding testimony is directed to a corporation, partnership, association, governmental agency, or other organization, and the matters on which examination is requested are described with reasonable particularity, the organization must designate one or more persons to testify on its behalf as to matters known or reasonably available to the organization. (c) Production ofdocuments or tangible things. A person commanded to produce documents or tangible things need not appear in person at the time and place of production unless the person is also commanded to attend and give testimony, either in the same subpoena or a separate one. A person must produce documents as they are kept in the usual course of business or must organize and label them to correspond with the categories in the demand. A person may withhold material or information claimed to be privileged but must comply with Rule 193.3. A nonparty’s production of a document authenticates the document for use against the non-party to the same extent as a party’s production of a document is authenticated for use against the party under Rule 193.7. (d) Objections. A person commanded to produce and permit inspection and copying of designated documents and things may serve on the party requesting issuance of the subpoena—before the time specified for compliance—written objections to producing any or all of the designated materials. A person need not comply with the part of a subpoena to which objection is made as provided in this paragraph unless ordered to do so by the court. The party requesting the subpoena may move for such an order at any time afier an objection is made. (e) Protective orders. A person commanded to appear at a deposition, hearing, or trial, or to produce and permit inspection and copying of designated documents and things may move for a protective order under Rule l92.6(b)—before the time specified for compliance—either in the court in which the action is pending or in a district court in the county where the subpoena was served. The person must serve the motion on all parties in accordance with Rule 21a. A person need not comply with the part of a subpoena from which protection is sought under this paragraph unless ordered to do so by the court. The party requesting the subpoena may seek such an order at any time afier the motion for protection is filed. (t) Trial Subpoenas. A person commanded to attend and give testimony, or to produce documents or things, at a hearing or trial, may object or move for protective order before the court at the time and place specified for compliance, rather than under paragraphs (d) and (e). Contempt. FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A CONTEMPT 0F THE COURT FROM WHICH THE SUBPOENA IS ISSUED OR A DISTRICT COURT IN THE COUNTY IN WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED BY FINE OR CONFINEMENT, 0R BOTH. D0 NOT FAIL to return this writ to the 162nd District Court of Harris County, Texas, with either the return showing the manner of execution or the witness’s signed memorandum showing that the witness accepted the subpoena. This subpoena is issued at the request of Defendants Wyndham Hotels & Resorts, inc., Wyndham Hotel Group, LLC, and Hawthorn Suites Franchising, Inc., whose counsel of record are Jason Hopkins, DLA Piper LLP (US), 1900 N. Pearl Street, Suite 2200, Dallas, Texas 75201, 214.743.4546, iasonhopkins@us.dlapiper.com, and Christopher B. Donovan, DLA Piper LLP (US), 845 Texas Ave., Suite 3800, Houston, Texas 77002, 713.425.8449, christepher.b.donovan@us.dlgpipggcom. Please contact Mr. Hopkins or Mr. Donovan to arrange a different time or place for compliance. ISSUED thi322nd day of September 2023. DLA PIPER LLP (US) lg Christopher B. Dongvgn Jason M. Hopkins State Bar No. 24059969 jason.hopkins@dlapiper.com 1900 N. Pearl St. Suite 2200 Dallas, Texas 75201 T: 214.743.4500 F: 214.743.4545 Christopher B. Donovan State Bar No. 24097614 christopher.b.donovan@dlapiper.com 845 Texas Avenue, Suite 3800 Houston, Texas 77002 T: 713.425.8400 F: 713.425.8401 David S. Sager, pro hac vice 51 John F. Kennedy Parkway, Suite 120 Short Hills, New Jersey 07078 david.sager@us.dlapiper.corn T: 973.520.2550 F: 973.520.2551 Counselfor Defendants Wyndham Hotels & Resorts, Ina, Wyndham Hotel Group, LLC, and Hawthorn Suites Franchising, Inc. mum / mum!“ mom / macaw RETURN 0F SERVICE OF SUBPOENA I, , delivered a copy of this subpoena to in person at , in County, Texas on , 2022 at ‘clock _m, and tendered to the witness a fee of $ in cash. l, , was unable to deliver a copy of this subpoena to for the following reasons: By Deputy: Sherifi‘fConstable , County, Texas By: Person authorized by law or written order of the trial court who has no interest in the lawsuit and is at least 18 years old. ACCEPTANCE OF SERVICE 0F SUBPOENA BY WITNESS UNDER TEXAS RQLE QF CIVIL PROCEDURE l7§ I accept service of this subpoena. Witness Date Fee for service of Subpoena: $ EXI-HBIT A I. DEFINITIONS The following definitions are an integral part of these requests for documents, and they are applicable throughout: A. The terms “document” and “documents” are to be construed broadly and are defined to be synonymous in meaning and equal in scope to the usage of such terms in Rule 192.3 of the Texas Rules of Civil Procedure. Such terms include, without limitation, any medium upon or by which information is or can be recorded, including but not limited to papers, books, letters, labels (and other identifying markings), e-mails, social media, electronically-stored information, facsimile transmissions, notes, drafts, diaries, reports, analyses, studies, invoices, promotional literature, sales literature, profit projections, computer generated information, audits, checks, bank statements, calendars, records, correspondence, memoranda, notebooks, photographs, pictures, diagrams, graphs, charts, drawings and sketches, non-written material such as videotapes, video recordings, audiotapes, tape recordings, CDs, and electronic and computer data compilations, translated, if indicated, into a reasonably usable format. B. The terms “referring,” “relating to,” and “concerning” include in whole or in part directly or indirectly, analyzing, containing, supporting, concerned with, connected with, dealing with, constituting, describing, relevant to or pertaining to the identified person, document or subject matter. C. The terms “communicate” and “communication” mean every manner or means of disclosure, transfer, or exchange, and every disclosure, transfer, or exchange of information, whether made or accomplished orally or by document, whether face-to-face, by telephone, mail, telex, facsimile, electronic mail, personal delivery, social media, or otherwise without limitation. D. The term “photograph” includes all corresponding metadata. E. The terms “person” and “persons” any natural person, individual, corporation, proprietorship, partnership, association, joint venture, limited liability company, trust, company, firm, or other form of legal entity, organization, or arrangement. F. The term “social media” includes any form of electronic communication through which users create online communities or relationships to share in-formation, ideas, personal messages, and other content—including, but not limited to, Facebook, Myspace, WhatsApp, Twitter, Instagram, Tumblr, Pinterest, Google+, Linkedln, WeChat, Snapchat, Telegram, Reddit, You'l‘ube, Venmo, Cash App, and Tik Tok. G. “Activity Log” means any activity log, account history, or other data or generatable/downloadable report reflecting activity on a social media account. That includes, but is not limited to, data and outputs that are accessible by following guidance provided by Facebook, lnstagram, and Snapchat at the following URLs, respectively: - Facebook | Find your Faceboak activity log https://www.facebook.com/hclpf28906682779l446 - Instagram See your Instagram account history | https://help.instagram.com/4604l 1 10881 1350 - Snapchat How do I download my datafiom Snapchat, | httpsz/Ihelp.snapchat.com/hc/en-us/articles/701230537l lSé-How-do-I- download-my-data-from-Snapchat- H. The word “all” includes “any”; the word “any” includes “all.” l. The use of the terms “and,” “or,” and “and/or” should be construed conjunctively and disjunctively for the broadest possible meaning. J. Whenever appropriate to bring within the sc0pe of these requests information that could lead to the discovery of relevant evidence, the singular form of a word shall also mean the plural. II. INSTRUCTIONS The following instructions apply to each request made herein. A. To the extent materials requested are maintained in hard copy form, they may be scanned and produced in electronic format, as long as the electronic scan accurately reflects the complete contents of the hard copy document. B. lf the requested documents are maintained in a file, the file folder is to be included as part of the materials produced. C. Electronically stored information shall be produced its native format. electronically stored information may be produced in the first instance in PDF or other readable format, provided that (i) the produced document accurately and completely reflects the contents of the electronically stored information, and (ii) the subpoenaing parties afierward may insist on the production of documents in native format insofar as they deem it necessary and/or appropriate. III. REQUESTS FOR DOCUMENTS l. Produce all documents and communications referring or relating to the shooting that occurred on or around April ll, 2021 on the premises of the hotel located at 7900 Brookriver Drive, Dallas, Texas 75247 (the “Hotel”), as well as all events leading up to that incident. 2. Produce all documents and communications sent to or received from the Dallas Police Department or the Dallas County District Attomey’s Office (or any other law enforcement or prosecutorial agency or government body), regarding, relating to, or in connection with the shooting that occurred at the Hotel on or around April l l, 2021. Produce all documents and communications reflecting who was present at the Hotel on April ll, 2021. Produce all of your communications from April 2021 onward with anyone who was present at Hotel on Aprilll, 2021. Produce all of your social media content, including any Activity Log reflecting or relating to such content, from April 10, 2021 through April 12, 2021.