Free Motion in Limine - District Court of Arizona - Arizona


File Size: 422.9 kB
Pages: 22
Date: December 5, 2005
File Format: PDF
State: Arizona
Category: District Court of Arizona
Author: unknown
Word Count: 3,791 Words, 21,952 Characters
Page Size: Letter (8 1/2" x 11")
URL

https://www.findforms.com/pdf_files/azd/34649/130-2.pdf

Download Motion in Limine - District Court of Arizona ( 422.9 kB)


Preview Motion in Limine - District Court of Arizona
SAPIRO v. SUNSTONE HOTELS INVESTORS, L.L.C., et al. Case No. CIV03-1555 PHX SRB
Exhibit Index Motion in Limine No. 2 Regarding Evidence of Subsequent Remedial Measures

I';xhibit

A

July 25, 2003 correspondence from plaintift·' attorney to Sunstone

F.xhibit B
I';xhibit

Excerpts from deposition transcript of Jeff ttammcrmeister, taken June 1,
2005

C

Excerpts from deposition transcript of I';van Studer, taken September 15,
2005

Exhibit I) Exhibit F.

News article entitled "Ilealth Risk Shuts Chandler Resort," dated August
31, 2003

Fact sheet and Press Release

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 1 of 22

EXHIBIT A

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 2 of 22

NEW

YORK

WASHINGTON

DC

FLORIDA

CALIFORNIA

NEW

HAMPSHIRE

July 25,2003

CERTIFIED MAIL

RETURN RECEIPT RE0 UESTED
Mr. Robert Alter
Chief Executive Officer

--Sunstene Hotel Investors,
Suite 100 903 Calle Amanecer

San Clemente, California 9673-6212

Re:

Legionnaires Disease at Sheraton San Marcos

Dear Mr. Alter:
This law firm, Boies, Schiller & Flexner LLP, represents Marvin and Gloria Sapiro. Mr. Sapiro was a guest of Sunstone from February 6 through February 11, 2003 at the Sheraton San Marcos in Chandler, Arizona (the "San Marcos").

result of the Sunstone's failure to properly maintain the San Marcos, Mr. Sapiro was exposed to dangerous legionnella bacteria during his stay there and in fact contracted Legionaire's Disease from which he has suffered debilitating repercussions. We detail the basis of the Sapiros' claim against Sunstone in the enclosed Complaint.
a

As

We intend to file this action on Monday, August ll, 2003. Should you be interested in discussing this matter before suit is initiated, please contact me at (305) 5398400 or my partner, David Shapiro at (510) 874-1000.
Sincerely,

Steven W. Davis

SWD/mpw
Enclosure
cc:

Marvin and Gloria Sapiro

Case 180953v 07-25-2003; 11:34:24 Document 130-2 2:03-cv-01555-SRB Doe.#:

Filed 12/05/2005

Page 3 of 22

EXHIBIT B

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 4 of 22

]

IN T}.E JN!TED STATES

DISTRICT COJR·

2
3
4

!N THE D:S±R.C7

COURT OF ARIZONA

PHOENIX ·V olON b·

5
6

MARVIN SAPIRO and GLORIA SAP[RO, his wife,

Plaintiffs,
7
VS.

8 9 I0
i!

SUNSTONE HOTEL INVESTORS, SUNSTONE HOTEL ]INVESTORS,

LLC., LP.,

Defendants.
Case No.

·2

VIDEOTAPE DEPOSITION OF JEFF H·d41·ERMEISTER
15 ·6

Taken Wednesday,

June
to

2005
]·:21

From the Hour of 8:54 a.m.

p.m.

17
!8

Pages i through !14,
Volume Taken by Counsel

inclusive

for Plaintiff

19
at

20
Offices of Heartland Court Reporters ·CO an S'·reet, Suite 308 i.'airbanks, Alaska 997

·'·'

22
23

24 2 L,

Reported by:
CAROL A. McCUE, Heart.!and Court

RMR

Reporters

COPY
Filed 12/05/2005 Page 5 of 22

HEARTLAND COURT REPORTERS 90"7-452-6727

Case 2:03-cv-01555-SRB

Document 130-2

63

i

due

::o ::he

due to

the

water

system.

2
3
4
b

Q.

Uh-hum.

A.
But

They

were

"·.es·{·g it.
they

Or were going to
were

tes[

in the meantime,

going to poss-D·y

ask me to close the ho'·e],
guests,

which means relocate the
off the books for the

6
7

take a!l

our business

immediate fu::ure.
Q.
A.
Did that

8 9
i0

surprise you?

Yes.

Q.
A.

Why did it surprise yo'·?
-'re never had a phone ca!l ·.o close
ever.
a

hotel

12

down,
Q.
c·os·x·

·3

Had you ever heard of other hotels being
Gow..·

A.

N o.

16

Q.

Seems pretty extraordinary,

·hen,

in your

experi ence?
!8 19 20

A.

''ve never heard of
And what was the

it nor experienced it.
and the reason

the hotel

might have to be closed down is because they found th.ls i,eg£oneiia bacteria


2· 22 23 24

the water?

They were
whose name
Q.
i

they were conferring with a
dor:'t recall

a doctor,

Uh-hum.

REPORTERS 9· 7--·5"2-6727

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 6 of 22

64

2
3

Q.
A.

Okay.
on

what

to do.

And he was going to ca".]
it was
i

me

4

back.

'.."hat was but:

if

I recall,

don't

know

the date,

it weuld have been 4:30-ish in the

6

evening,
Q.

end of day.

7
8 9

Let me see if this may help your recollection. MR.
SCHMIDT:
:)t4

We'll and 545.

mark as our next

exhibit

Sunstxxte

THE

·xlt:

OR=nR:

Exhibits

6 and 7

(Exhibits 6 and 7 marked.
!2 13

BY

·.
Q.
A.

SSiiM!DT:

By the way,

did you

USe

Microsoft Outlook at

14
15 16

I

I'm

no%

sure

that

s

the operating

system.
Q.
Blit

yOU

had e-mail

at work?

18 ·9 20

A.

Yes.

your handwrlt/nq?
A.
it

appears to be my handwr!uing,
remember
·

yes.

22

Q.

Do you

receiving

23

Mr.

Studer?
L
)oK·,,·

24
25
at

_£.·o.v·..g

thi s

exact

e-real

i,

received .%L,

you bet.

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 7 of 22

65

Q.

Uh-hum.

Who did Mr.

Studer work for,

do you

2
3
4 5

remember that?
A. Mr.

Studer?

That

at

that ·ime and

cor:tir:uing,
Q.
for?

believe he works

for Bob Alter·

Do you know the name of the entiry he works

6

7
8 9

A.

N o.
Had you ever reported to Mr.

Q.
A.

Studer before?

No.
.But did you

Q.
A.

you knew who he was?

Definitely.
How did you know who he was?

Q.
A.

He's my boss's boss.
Good thing Lo
i 'd

Q.

kr:ow.
e.·

·ike

Lo

Go through yo'dr ha.·dw

16

remarks·
A.

i

believe

they are yours·
are mine.

1"7

No.

They

They are mine.
Number

()kay.
·9
2O

On page 545.
Who
;is

says,

·''

ana

G.S.

in tomorrow·

J.E.?

A.
Q.
A.

That

would be Jonn Eiston and Gary S·ougaa, d. And where did Mr.
:·-''._sLon
E]s·non work?

24 22
23

Okay.
·'"·,·.·.,

!s ·he sen! or vice-Dresider:t of

marke%ing
Q.

for Suns<:one. And Mr.
S·oo,·a·.


24
25

A.

Senior VP,

,·',·-·

and divest!Lures,

if ]

907-452 6"12"1

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 8 of 22

66

zeca£
2

his

back tthen.
Ana does
E:tIS

9.

Right..

mean
[p.

·_n·.o

Lhey were
does that

3
4

flying into %he
mean ``that

let's

say,

tomorrow,

they were coming to San Harcos?
Yes.

A.

Q.
7

Number 2

says,

guests are

gt]ests

notl fied.

What does tha·: mean?
A.

8 9

Noti fy
Uh-hum.

well,

notify

Q.
A.

Meaning,
Okay.

not::[fy

,..he

guests
is

Q.

}%y the way,

this a

list

that you

!2
·3
i4

made as
A.

do you remember making this

list a·.t all?

Oh,

i

mad(;

the

l!st,

definitoely.

Are these notes that you took while he (;ailed
ye'd

?
A.

Could have

could have been

'" '"'
been
as
right

·7
e.
",_he
·).·o..(.

·,
cali
to

.myse.·

fecal

!

uhe

2,9

Q.

Okay.

Number 3

says,

precaut:ionary

steps,

2· 22
23

believe
A.
·

Do you remember what Lhat meant?
think that

no,

:

don't

recall

exactly

what

meanr· by <%ha<:.

No.
for me.

Q.
2b

Can you read Number 4
what: :.he
(.

can't reaily

·'

..c·K(.

OUt

says.

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 9 of 22

6"I

Unexpected and ex
boiler.
3
4

i

don't

know.

Work to

Q.
A.

Do you remember what that meant? No. How about Number 5?

5
6

Q.
A.
water.

Alleged bacteria in and/or potential,

<·hen

7
8 9

Q.
A.

}!20?
Water.

Q.
ii

Yeah.

Right.

Do you remember what tha:

meant?
A.
Q.
A.
NO,

!2 13

Humber 6.
That would be a not.e of where we would be
guests,

1.5 16

moving our hotel

hhe Holiday

:nn

in Mesa,

if they couldn't

fit iohere,

to an alternative

17

ho·oe!
Q.

And t:hat Holiday inn was

another Sunstone

19 20 2:

proper·-y, right?
A.
Q.

At. that t. ime,
That

yes.
Do you remember how many

time

and elate.

22
23

guests were .·..oved to the Hesa?
A.
Q.
A.
l

don'


:_o

24

How about Number ??

A

no'·.e

myself,

we're going

to

have an

HEARTLAND COURT REPORT?:RS 987 452 6727

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 10 of 22

88

i

De

o·e

for

the

K·cne,.,·; one for the

restaurar'4:,

one

for

2
3
4 5

different areas.

Q.
note,

And the remarks area,
new business name.

the __rst remark says,
in the

Do you see that,

bottom remarks?

6
7
8

Okay.

Yes.

Do you know why there was a new business name

for the San Marcos at this time?
A.
The

9

Sheraton sign came off the building on

!O

September Ist,
Q.

I believe.

Okay.

And do you believe that's what that

]2

refers to?
A.
Riqht.

13

says,
15 16
17

advisory,

remedJation efforts that were undertaken ar the
San Mattes.
A.

18 19

Okay.
7 'd like to review them with you to see if
,,ectlo·,

Q.

2O
21

they meet with your recol
l<,

of what was done.
.·ea,_e·
ant

says,
ed.

the hot

ii.nes were s·e·
·

23

A.

24
2b

remember this being done?
Q.

Case 2:03-cv-01555-SRB

·
·

22

hyperc

Do you remember

·,ha·

'n Do i remember them wr·t· g this or do i

No.

That

i<: was

that it was done?

,:EAR,·,AND COURT Rt, 0·...RS ·' ·;' "·

907-452-6727

Document 130-2

Filed 12/05/2005

Page 11 of 22

89

wasn't_

in charge of doing that,
e mails,

but

i'm

2
3

in t%har

series

of

it: was

done.

Q.

Okay.
Ri ght.

Boilers were installed?

A

5
6

Q
A

New backflow prevention to the city?

Right.
Installed new water heaters at the lodge?

"7
8 9 0
·

A
Q
units

Right.
Rep aced two
water

storage tanks with new

1!

A
Q

Righz.
Al! showerheads have been replaced?

i2
13

A
Q

Right:.
All

aerators at the hand sinks have been

ib

replaced?
A.

16

Yes.
Nine
c[rc'dlation

·7
18
19

Q.

pumps have been replaced?

A.
Q.
A.

Yes.

Piping to t.he boilers have been replaced?
Yes
Water tower has

20 2!

O.
A.

sodium nitrate additive?

22
23

Okay.
Was
i

O.
A.

that done,

do you

know?

24
2.%

don't know.
Do you have any reason to believe that

()kay.

iiEARTLAND COURT

RF, i;ORT!'IRS

9,91-452

6"127

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 12 of 22

9O

i

the insnecuor would not

know what was done or nor?

2
3

A.

]

have no reason to believe that

this is

inaccurate.
Q.

Let's put: it tha% way
And the last
item says,

Okay.

ch!orine
water

dioxide
6
._o.,

in3ec<:zon sys·.em

on o·d

to treat al

the oily. Al!

7
8 9
chio..·:,e

right.

Do you remember anything about a

dioxide injection

system?

A.

I believe that was the ·hird phase of the

remediation program.
!i

Q.

Okay.

Is there any reason why these measures

12
13

cou]d not ..ave been taken in 2002?
·

MR. Assumes
facts

Object·ion

!.'oundatton.
t_he

no·:

in evidence,

specifically
Assumes

lack of

any reported case of l,egionella.
16

insufficient

faces upon which to base a hypothetical.
·T'NW
"m WI,T' N.,SS

·.7
18 19 2@

Ana the q·esL10.. WaS?

MR

SCHM!DT

Would you ·epea·

·ne muestion,

please.
(The requested record was read.
W TNESS

21 22
23

No

BY MR.
Q.

8CHKIDTt

:l'd like to show you what !' iX mark as

24
25

Exhibt%?
THE REPORTER:
15.

.·AR_·AN.· COURT



R·-RS 907-452-6727

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 13 of 22

EXHIBIT

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 14 of 22

IN THE UNITED STATES D!STICT COURT

·E

D]S!RICI

CO,]R·

OF ARIZONA

PHOENIX DIVISION

HARVlN SAPIR0,

and GLORIA

SAPIRO,

his wife,

Plaintiffs

VS.

Case CIV 03

1555

PHX SRB

SUNSTONE HOTEL INVESTORS SUNSTONE HOTEL INVESTORS

LLC)

LP,

Defendants.

DEPOSITION OF EVAN STUDER
SAN CLEMENTE,

CALIFORNIA
2005

THURSDAY,

SEPTEMBER !5,

REPORTED BY:
LISA C. CSR NO.

PUETTMANN-HAWTON

11368,
176969

CCR NO.

52!.

JOB No.

COPY
ESQUIREI)EPOSITION SI{RVICES
1-800 944-9454

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 15 of 22

Page 73
1 2
3

Q

Do you remember who that person was?

Chief Investment Officer was Mark Mance.
i'm

sorry,

I mean the Risk Management person. I think so but

4

You're taxing my memory here.

I·m not i00 percent sure and his name escapes me.
6

My memory is going bad.
Pau!.
Q
i

I want to say it's

7
8 9
i0

can't remember his last name.
As
a

result of receiving this communication,

did Sunstone's senior management take any action?
MR. KLEIFIELD:

Objection;

foundation,

II
12
13

irrelevant,

subsequent remedial measures.

THE WITNESS: MR·
SCHMIDT:

Going off what I recall?
Yes.
When it was received,

14
15

THE WITNESS:

there was,

again, as I recall,

we believe we

went out and

1.6
17
18 19 2o

immediately hired a firm to come in and do a testing of
the water system and that was done.

We were notified the results and then much
more extensive action took place after that.

BY MR.
Q

SCHMIDT:

21 22
23

When you say much more extensive action,

what

do you mean?

A

They closed the hotel down and changed out a
I don't know if significant is the right

24
2B

significant
word,

but we changed out a number of pieces of

I{SQUIRE DEI)OSITION
1-800 944-945

·,

SERVICI{S

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 16 of 22

EXHIBIT D

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 17 of 22

FOOD
Z·SS p()RTSM ONI!YIiN'I I!I).TAIN MI!N'I·COM MIZ N ITII!S IIiAI.TI
i

busines YI!STRAVI%I.SttOPCASINO seli·vot
usa

IIOMF.

Care·rt
real est. rentals _service:

persom
today news

Health risk shuts Chandler resort
World & Nation the buzz Weather

Legionnaires' bacteria found in water at San Marcos
Lindsey Collom The Arizona Republic Aug. 31,2003 12:00 AM

Army
foresees doubling·p
tours

-stuff
slte ma

Educatiort
Traffic Info Scottsdale

MotivatiorL
focus send foreign-born students soaring

Republic
Photo Galleries

he!p phoo·
schools maps

Video Qal!er,g News Multimedia

The Sheraton San Marcos Resort in Chandler has been closed since Wednesday due to the discovery of bacteria that cause Legionnaires' disease. The resort's water system was tested for legionella bacteria after an elderly man who stayed there in February reported that he contracted the disease·

Ten
Cgmmandmen!s

Famou· in
Arizona

Legionnaires' disease

fi·Lht isn't
throwback to old Alabama thankfully

Police Scanners
Web Cam-s EdiDrials/O·prEd Benson Cartoons Columnists Plugged In /
\

·oupo· ncwspa ads
tickets

A severe respiratory
infection resembling acute pneumonia. Symptoms of the flulike disease include fever, chills and a cough. Some patients experience muscle

litics
2003 Elections Arizona Repub!i· Print Edition Front Pages Obituaries E-mail Newsletters

Results Tuesday indicated there was an abnormally high concentration of the bacteria in aches, headache, tiredness one of the hotel's water tanks. and loss of appetite.

today's snapshot
What

Space,¢om
Special Reports AP en Espafio!
Estados Unidos Politica Latinoamdrica Internacional

Guests were transferred Wednesday to other local hotels. The Maricopa County Department oftteath Services was notified on Thursday.

The disease was named after a 1976 outbreak during an American Legion convention

do snoops look for in office trash?
news as it

[]

Philadelphia's BellevueStratford Hotel. More than 200 people contracted the
at

happens

Regular operations are expected to resume within 10 days, a resort official said.

disease, and 34 of them died of it.

HospiIal debt AIMS
causingworry, dread Police arrest 19_ in Iraq blast; all had al-Qaida ties

Advanced

search· tips

Case 2:03-cv-01555-SRB

·

[Aii

"No guests or any employee other than this person who notified us has complained of any infection," said Gary A. Stougaard, executive vice president of SunstoneItotel Properties, the owners· "We notified all ()four employees and said if they feel ill, they should see a doctor·"

Suppliers wer· profit guzz!¢r-s in gas
crisis Mixed race

I.egionnaires' resembles acute pneumonia and is contracted through ingesting contaminated water, it cannot be transmitted from person to person. No cases of the respiratory disease have been reported in Arizona in the past year, said Doug Itauth, spokesman Ibr the county health department.

adoptions, marriages grow in U.S. U.S. policy

Document 130-2

Filed 12/05/2005

Page 18 of 22

Legionella typicalIy attacks people with weakened immune systems. It's possible for the bacteria to pass through an otherwise healthy person without causing illness, tIauth
added.
The disease was named for an incident in July 1976 in which a number of American Legion members were stricken with the illness at a convention in Philadelphia. More than 200 people fell ill, and 34 eventually died.

makes mound· o[mi!k Future wilI

require immigrants by
millions·_for

iobs·report
sa25s Documents

detail U.S,
Rapist's sentence

·o lqas· bu.y

According to the federal Centers for Disease Control and Prevention, 8,000 to 18,000 cases occur each year in the United States. From 5 to 15 percent of those are fatal.

.......
harsh? Bush's rosy
holiday view toned in black by DCm· 'Enquirer'
archiyes

acts

Procedures to rid the resort of the bacteria arc under way. The

process involves superheating the water and running chlorine through the system,
It is not uncommon for legionella to be present in large water systems, said Bob England, state epidemiologist.

doomed
"We have scattered Iegionella all the time," England said.

Strip·e_d j·fl
uniforms

"People will try to blame a single source, but it's a ubiquitous organism found in half of all the plumbing systems in all large buildings and about a quarter of all houses."
species of bacteria that Officials have yet contracted Legionnaires' is the same infected the man who strain found at the resort. County health officials arc trying to contact his doctor, Hauth said.
to determine if the

re·ai_n popularitz as guide to status
Moonshine

common in
Atlanta, study

finds At Coney
Island, life
imitates

Although the San Marcos may be closed for as long as two weeks, its owners say they're not concerned about losing
][.ate summer is traditionally a slow time for the resort,

Ifrcaky· yidc9 garn·

10.000
Harl·ys
celebrate in

Stougaard said.

parade Man blows

Reporter

Kerry Fehr-Snyder contributed to this article.

up after bizarre robbery claim Migrant·
cheer election

changes

'A p·rtholc to
the past' Recai_l may hing· ·?n Latinos

ttamas
militants, girl. 8· killed by

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 19 of 22

EXHIBIT E

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

Page 20 of 22

Sheraton San Marcos

Fact Sheet
8/27/03

ttotel management learned yesterday that bacteria had been found in one of its boilers in the East Wing

building.

We immediately closed the building.
a

An environmental testing service has reported

to us

that this

contamination is likely a form of Legionella,

bacteria that can cause Legionnaire's disease (Legionellosis). We
as

have notified the Maricopa County Health Department, as well
occurence and we are

the Arizona Department of Iealth Services of this
a Level

currently tbI!owing OSIIA guidelines tbr
tests

One Investigation. This environmental
is safe to

testing setwice has conducted

throughout the affected building, which will remain cIosed until it
water

reopen. All heating and cooling and hot and coId
have
o fail
no reason to

systems in all hotel buildings are being tested today. We

think that we will find any additional bacteria in the hotel. We expect the testing and disinfecting
to

hotel systems

require about 14 days to complete.

Our check of the affected boiler was prompted by the recent receipt of information confirming the ilIness of
a

former out-of-state guest of the hotel. Six months had elapsed since the guest's stay. Prior to this notification, we

had received no other complaints or reports of illness. Alter a preliminary call from the environmental testing firm yesterday confirmed the presence of the

bacteria, we immediately commenced

a

thorough testing program at the hotel.
a

No other guests

or

employees have reported

diagnosis of Legionnellosis, the symptoms for which
at

generally resemble pneumonia (see Center for Disease Control
experiencing pneumonia or llu-like symptoms, there
is

www.cdc.gov). OSHA suggests that if you

are not

no need to see a doctor.

We have arranged for an answer line staffed by independent health professionals to talk confidentially with

any of our employees or guests as needed

to address their

questions as they arise. In addition, the Maricopa County

Department of tlealth Services is available to

answer

questions, as is the Arizona Department of IIeaIth Services.

Contact:

Gary A. Stougaard
Executive Vice President
Office: 949.369.4280

Cei!: 619.709.4461

www.OSIIA.gov/SLTC/etools/legionnaires/sample letter.htmI

903 Calle Amanecer Suite 100 San Clemente, CA 92673-6212 Tel. 949.369.4000 Fax 949.369.4210

SUNSTI31
Page 21 of 22

Case 2:03-cv-01555-SRB

Document 130-2

Filed 12/05/2005

S nston

San Mercos Resort and Confsrence Cmf·r

F·'· Sham
9/i0/03

The San Mattes P·san anxi Conference C·mter w·ll r·-olxm mmo·ow
·
·

hotel.

In ttddhion, major componems oF the domestic wmer system hove been replaced, {nclud·g boilcms, ta·ks,
circulation pum]·s and showerheads,

The disinfection procedures wer· d·veloped and s·pelvised by ·m ·lvirunmemal managemtmt specialist Thereafter, wamr samples w¢re and wee* corn·Ictrd over a fom-d·y period frmn A·gust 28 through August 31 takes from throughout the resort. Th¢· test results on these snmpies were r0caived by hotel manag·mt this

Throughout this p·cess, hotal m·nagernemt h· rem·ained in close contact with o·cial· from thr Mm'·copa

Cotmty Health Drpamnc·nt and the City of Chandler,
Ths San Mattes Resort and Conf·renc· Center is a 295 morn hotel and ccmf·sr·nce faci]i·y which includes
an g hole golf cours· and is located in the City of Chandler, ArLzona

Gary A. Stougaard,
Exscutive Vice Prealdont
Office: 949 369.4280

90:3 Cal}e Amanecer

SBn Glomon·o, CA 92673-6212
Tot, B49.3·g,4000 Few fl49 369.4210

Case 2:03-cv-01555-SRB

Document 130-2

·

·

·



p· ·e ·ceipt of rest ·sulm ·dic·g by M·t to disinfe· ·e d·esfic ·tsr systems ·mu·out the mso· ·s successful. ·e ·o· cMs· on confi·od ·e p·s·n· of Legi·olia bavaria in a ho· wa·r sys·m in one s·lio· of ·c A·st 27.2·3, aRer
·isi·

·o·

reso· b·ed upoo

Hotc· ·" 9:00 ·t ·e ·g*m·t h·

·.

·,

Suite 100

Filed 12/05/2005

SUNST276 Page 22 of 22