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
4·
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.
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causingworry, dread Police arrest 19_ in Iraq blast; all had al-Qaida ties
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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
·
·
·
m·
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
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