On December 31, 2015 a
Joinder in Motion to Quash - MOTION - EMERGENCY
was filed
involving a dispute between
Bhambi, Brij,
Green Sequoia Limited Partnership,
Grewal, Hardeep,
Grewal, Mukhtiar,
Grewal, Narinder,
Ramnani, Sunil,
Sharma, Shashi,
Snyp Real Estate Development, Llc,
Softa, Arun,
and
Deloitte & Touche Llp,
Equity Office Management Llc,
Hennessey, Brian,
Northmarq Capital Llc,
Promark Capital Group,
Rkm Capital,
Scandaliato, Richard,
Tatevossian, Narbeh,
Younan Investment Properties, L.P.,
Younan Properties, Inc.,
Younan, Zaya,
for OTHER (CIVIL)
in the District Court of Dallas County.
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FILED
DALLAS COUNTY
12/2/2016 4:01:50 PM
FELICIA PITRE
DISTRICT CLERK
CAUSE NO. DC-16-00007
SUNIL RAMNANI, MUKHTIAR § IN THE DISTRICT COURT
GREWEL and HARDEEP GREWEL, §
Plaintiffs, §
§
v. §
§
ZAYA YOUNAN, YOUNAN §
PROPERTIES, INC., YOUNAN §
INVESTMENT PROPERTIES, INC., §
YOUNAN INVESTMENT § 95TH JUDICIAL DISTRICT
PROPERTIES, L.P., BRIAN §
HENNESSEY, NARBEH §
TATEVOSSIAN, QUENTIN §
THOMPSON, DELOITTE & §
TOUCHE, L.L.P., NORTHMARQ §
CAPITAL, LLC, RICHARD §
SCANDALIATO, EQUITY OFFICE §
MANAGEMENT, L.L.C., §
PROMARK CAPITAL GROUP, §
L.P., AND RKM CAPITAL, §
Defendants. § DALLAS COUNTY, TEXAS
DEFENDANTS BRIAN HENNESSEY AND NARBEH TATEVOSSIAN’S
JOINDER IN EMERGENCY MOTION TO QUASH DEPOSITIONS
TO THE HONORABLE COURT:
Defendants Brian Hennessey and Narbeh Tatevossian (collectively, “Defendants”), join in
Defendants Zaya Younan, Younan Properties, Inc., and Younan Investment Properties, L.P.’s
(collectively, the “Younan Defendants”) Emergency Motion for Protective Order and to Quash the
Amended Deposition Notices of Zaya Younan, Younan Properties, Inc., Younan Investment
Properties, L.P., Brian Hennessey, and Narbeh Tatevossian (“Motion”).
On this date, the Younan Defendants filed their Motion seeking to quash, among others,
the depositions of Brian Hennessey and Narbeh Tatevossian, currently noticed for December 14
and 15, 2016. Defendants hereby join in the Motion for purposes of quashing the Hennessey and
Tatevossian depositions for the reasons set forth in the Motion.
DEFENDANTS BRIAN HENNESSEY AND NARBEH TATEVOSSIAN’S
JOINDER IN MOTION TO QUASH DEPOSITIONS – PAGE 1
WHEREFORE, PREMISES CONSIDERED, Defendants Brian Hennessey and Narbeh
Tatevossian pray that the Motion and their Joinder in the Motion be granted, that the depositions
of Brian Hennessey and Narbeh Tatevossian currently scheduled for December 14, and 15, 2016
be quashed, that those deposition not take place until all Defendants have appeared and answered,
and for such other and further relief to which they may show themselves justly entitled.
Respectfully submitted,
NESBITT, VASSAR & McCOWN, L.L.P.
15851 Dallas Parkway, Suite 800
Addison, Texas 75001
(972) 371-2411
(972) 371-2410 – Telecopier
By: /s/ Jim McCown
James M. McCown
jmccown@nvmlaw.com
State Bar No. 00788002
ATTORNEYS FOR DEFENDANTS BRIAN
HENNESSEY AND NARBEH TATEVOSSIAN
CERTIFICATE OF CONFERENCE
Due to the timing and emergency nature of the Younan Defendants’ Motion, and this
Joinder in that Motion, counsel has not had an opportunity to confer with Plaintiff’s counsel in this
matter, but will update this certificate if counsel later obtains a position regarding the relief
requested herein.
/s/ Jim McCown____________
James M. McCown
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing was served via
electronic mail on this 2nd day of December, 2016 to all counsel of record in this proceeding.
/s/ Jim McCown____________
James M. McCown
DEFENDANTS BRIAN HENNESSEY AND NARBEH TATEVOSSIAN’S
JOINDER IN MOTION TO QUASH DEPOSITIONS – PAGE 2
Preview
FILED DALLAS COUNTY 12/2/2016 4:01:50 PM FELICIA PITRE DISTRICT CLERK CAUSE NO. DC-16-00007 SUNIL RAMNANI, MUKHTIAR § IN THE DISTRICT COURT GREWEL and HARDEEP GREWEL, § Plaintiffs, § § v. § § ZAYA YOUNAN, YOUNAN § PROPERTIES, INC., YOUNAN § INVESTMENT PROPERTIES, INC., § YOUNAN INVESTMENT § 95TH JUDICIAL DISTRICT PROPERTIES, L.P., BRIAN § HENNESSEY, NARBEH § TATEVOSSIAN, QUENTIN § THOMPSON, DELOITTE & § TOUCHE, L.L.P., NORTHMARQ § CAPITAL, LLC, RICHARD § SCANDALIATO, EQUITY OFFICE § MANAGEMENT, L.L.C., § PROMARK CAPITAL GROUP, § L.P., AND RKM CAPITAL, § Defendants. § DALLAS COUNTY, TEXAS DEFENDANTS BRIAN HENNESSEY AND NARBEH TATEVOSSIAN’S JOINDER IN EMERGENCY MOTION TO QUASH DEPOSITIONS TO THE HONORABLE COURT: Defendants Brian Hennessey and Narbeh Tatevossian (collectively, “Defendants”), join in Defendants Zaya Younan, Younan Properties, Inc., and Younan Investment Properties, L.P.’s (collectively, the “Younan Defendants”) Emergency Motion for Protective Order and to Quash the Amended Deposition Notices of Zaya Younan, Younan Properties, Inc., Younan Investment Properties, L.P., Brian Hennessey, and Narbeh Tatevossian (“Motion”). On this date, the Younan Defendants filed their Motion seeking to quash, among others, the depositions of Brian Hennessey and Narbeh Tatevossian, currently noticed for December 14 and 15, 2016. Defendants hereby join in the Motion for purposes of quashing the Hennessey and Tatevossian depositions for the reasons set forth in the Motion. DEFENDANTS BRIAN HENNESSEY AND NARBEH TATEVOSSIAN’S JOINDER IN MOTION TO QUASH DEPOSITIONS – PAGE 1 WHEREFORE, PREMISES CONSIDERED, Defendants Brian Hennessey and Narbeh Tatevossian pray that the Motion and their Joinder in the Motion be granted, that the depositions of Brian Hennessey and Narbeh Tatevossian currently scheduled for December 14, and 15, 2016 be quashed, that those deposition not take place until all Defendants have appeared and answered, and for such other and further relief to which they may show themselves justly entitled. Respectfully submitted, NESBITT, VASSAR & McCOWN, L.L.P. 15851 Dallas Parkway, Suite 800 Addison, Texas 75001 (972) 371-2411 (972) 371-2410 – Telecopier By: /s/ Jim McCown James M. McCown jmccown@nvmlaw.com State Bar No. 00788002 ATTORNEYS FOR DEFENDANTS BRIAN HENNESSEY AND NARBEH TATEVOSSIAN CERTIFICATE OF CONFERENCE Due to the timing and emergency nature of the Younan Defendants’ Motion, and this Joinder in that Motion, counsel has not had an opportunity to confer with Plaintiff’s counsel in this matter, but will update this certificate if counsel later obtains a position regarding the relief requested herein. /s/ Jim McCown____________ James M. McCown CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing was served via electronic mail on this 2nd day of December, 2016 to all counsel of record in this proceeding. /s/ Jim McCown____________ James M. McCown DEFENDANTS BRIAN HENNESSEY AND NARBEH TATEVOSSIAN’S JOINDER IN MOTION TO QUASH DEPOSITIONS – PAGE 2