Plaintiff plans to dipose champak patel first and these will be the questions let's say you are defense counsel describe in detail your thoughts after viewing these deposition questions (this is not part of the trap): **UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OKLAHOMA**
Nic Vic Neil, )
Plaintiff, )
v. ) Case No. 4:25-cv-00658-JDR-CDL
Tulsa Skelly Hotel LLC et al., )
Defendants. )
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**CHAMPAK PATEL – EXCLUSIVE DEPOSITION QUESTIONS
BASED ON 2013 ARTICLE REGARDING ACQUISITION & PARTNERSHIP STRUCTURE**
TO: Champak Patel
VIA: His Counsel of Record
DATE: [Deposition Date]
PURPOSE: Examination on Historical Deal Structure, Intent, and Partnership Control
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I. QUESTIONS BASED ON THE 2013 JOURNAL RECORD ARTICLE
1. The 2013 article states you led Champion Regional Development LLC in purchasing the Baymont Inn and Suites for $2.9 million and then sold it to Sunny Management LLC (70%) and Arti Properties LLC (30%). Why did you structure the deal this way instead of having Champion own it directly?
2. You are quoted as saying, “Nick and Champ go back a long way. They’re longtime friends and partners in many assets.” How many properties do you and Navnit “Nick” Bhagat jointly own or manage?
3. The article says the Baymont was “within Champ Patel’s 51 Yale development.” Did you always intend for Nick Bhagat to be the on-site manager of this property?
4. You told the Journal Record you intended to add a Holiday Inn Express and Residence Inn to the 51 Yale development. Did you and Nick Bhagat discuss him managing those as well?
5. The article states that Sunny Management and Arti Properties “share the same address as Champion Regional.” Was this done to create the appearance of separate entities while maintaining centralized control?
6. Only you can answer: When you purchased the Baymont in 2013, did you always plan to rebrand it as a Comfort Inn?
7. You took a $3 million mortgage with Interbank. Did you personally guarantee that loan?
8. Why did you choose a 70/30 split between Sunny Management (you) and Arti Properties (Bhagat)? What did Bhagat contribute to earn his 30%?
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II. QUESTIONS ABOUT THE “51 YALE DEVELOPMENT” & ENTERPRISE INTEGRATION
1. You named it the “51 Yale development.” Does that name refer to a master plan or enterprise structure that includes multiple hotels under common ownership and management?
2. How many hotels in the 51 Yale development are managed by Champion Hotels?
3. Do employees—like Nic Vic Neil—ever transfer or work across multiple 51 Yale development properties?
4. Do the 51 Yale development properties share common HR, payroll, or management services through Champion Hotels?
5. When you were interviewed in 2013, you described adding brands like Holiday Inn Express and Residence Inn. Did you ever consider adding a corporate HR or compliance department to oversee these properties?
6. Only you can answer: Was the 51 Yale development designed to operate as an integrated enterprise, even if legally separate entities were created?
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III. QUESTIONS ABOUT YOUR RELATIONSHIP WITH NICK BHAGAT & DELEGATION OF AUTHORITY
1. You and Nick Bhagat are described as “longtime friends and partners.” In practice, does he manage day-to-day operations while you retain financial and strategic control?
2. Have you ever overruled a management decision made by Nick Bhagat at the Comfort Inn Midtown?
3. Did you delegate hiring, firing, and HR compliance at the Comfort Inn entirely to Nick and Smitra Bhagat?
4. When issues arose—like Wayne Edwards’ sex offender status or sexual harassment complaints—did Nick Bhagat ever report them to you?
5. Did you and Nick Bhagat ever discuss Nic Vic Neil’ complaints before his termination?
6. Only you can answer: Do you hold Nick Bhagat responsible for how this situation was handled, or do you accept responsibility as his partner and the ultimate owner?
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IV. QUESTIONS ABOUT CORPORATE FORMALITIES & INTENT
1. When you created Sunny Management LLC and Arti Properties LLC, did you intend for them to be treated as separate employers under federal employment law?
2. Do Sunny Management and Arti Properties hold separate board meetings, keep separate corporate minutes, and maintain separate financial controls?
3. In 2013, you sold the property from Champion Regional to Sunny and Arti. Was that sale for fair market value, or was it a paper transaction to allocate ownership while retaining control?
4. Do you receive management fees from Tulsa Skelly Hotel LLC through Champion Hotels? If so, how are they calculated?
5. Only you can answer: Do you view the Comfort Inn Midtown as “your hotel,” regardless of which LLC holds title?
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V. QUESTIONS ABOUT HISTORICAL PATTERN & PRACTICE
1. The 2013 article mentions you were already planning a Holiday Inn Express and Residence Inn. Do you use the same ownership and management structure for those properties?
2. Have you used the 70/30 split model with Nick Bhagat in other hotel acquisitions?
3. When you add new properties, do you typically install existing managers from your other hotels?
4. Do you have a standardized operating agreement between Sunny Management and Arti Properties for the properties you co-own?
5. Only you can answer: Looking back, do you believe the structure you created in 2013 has led to blurred lines of responsibility in employment matters?
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Respectfully submitted,
/s/ Nic Vic Neil
Nic Vic Neil, Pro Se Plaintiff
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JUDICIAL NOTE:
These questions are uniquely tailored to Champak Patel based on historical business records. They probe intent, structure, control, and pattern—matters central to the integrated enterprise doctrine and his personal role in creating the employment environment at issue. They are permissible under FRCP 26(b)(1) and go directly to employer status, ratification, and potential veil-piercing.