Motion,Ex Parte: CDC SAN FRANCISCO LLC, A DELAWARE LIMITED VS. WEBCOR BUILDER, INC., A CALIFORNIA CORPORATION

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BARNES & THORNBURG LLP
DAVID W. NELSON (SBN 240040)
dnelson@btlaw.com

2029 Century Park East, Suite 300
Los Angeles, California 90067
Telephone: 310-284-3880
Facsimile: 310-284-3894

DAMON R. LEICHTY (Pro Hac Vice)
dleichty@btlaw.com

EILEEN PRUITT (Pro Hac Vice)
epruitt@btlaw.com

100 North Michigan, Suite 600

South Bend, Indiana 46601

Telephone: 574-237-1160

Facsimile: 574-237-1125

COZEN O'CONNOR

DAVID A. SHIMKIN (SBN 290818)
dshimkin@cozen.com

601 S. Figueroa Street, Suite 3700

Los Angeles, CA 90017

Telephone: 213-892-7900

Facsimile: 213-892-7999

Attorneys for Defendants and Cross-Defendants

ELECTRONICALLY

FILED

Superior Court of California,
County of San Francisco

03/27/2017
Clerk of the Court
BY-JUDITH NUNEZ

Deputy Clerk

Quanex I.G. Systems, Inc. and Truseal Technologies, Inc.

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SAN FRANCISCO

CDC SAN FRANCISCO, LLC, a Delaware
limited liability company,

Plaintiffs,
vs.

WEBCOR BUILDERS, INC., a California
corporation, ARCHITECTURAL GLASS &
ALUMINUM CO., INC., a California
corporation, MIDWEST CURTAINWALLS,
INC., an Ohio corporation, VIRACON, INC., a
Minnesota corporation, QUANEX I.G.
SYSTEMS INC., an Ohio corporation, and
DOES 1 through 100, Inclusive,

Defendants.

AND RELATED CROSS-ACTIONS

Case No.: CGC-15-546222

DECLARATION OF SANDY M. KAPLAN
IN SUPPORT OF DEFENDANTS’ JOINT
MOTION IN LIMINE TO EXCLUDE
PLAINTIFF’S “POTENTIAL
SUPPLEMENTAL WITNESSES” FROM
PROVIDING TESTIMONY OR
OPINIONS AT TRIAL

Assigned to the Hon. Angela Bradstreet
Dept. 624

Action Filed: June 9, 2015
Trial Date: March 16, 2017

DECLARATION OF SANDY M. KAPLAN IN SUPPORT OF DEFENDANTS’ JOINT MOTION
IN LIMINE TO PRECLUDE PLAINTIFF’S “POTENTIAL SUPPLEMENTAL WITNESSES”
FROM PROVIDING TESTIMONY OR OPINIONS AT TRIALom ND

I, Sandy M. Kaplan, declare as follows:

1. Jam an attorney at law duly qualified and licensed to practice before all the courts of
the State of California. I am a partner at the law firm of Gordon & Rees LLP, counsel of record for
defendant, Webcor Builders, Inc. (“Webcor”). I have personal knowledge of the matters set forth
herein, except as to those matters stated upon information and belief, and as to those matters, I am
informed and believe them to be true. If called as a witness to testify, I could and would
competently testify as to the truth of the same if requested to do so.

2. I make this declaration in support of Defendants’ Joint Motion in Limine to Exclude
Plaintiff's “Potential Supplemental Witnesses” From Providing Testimony or Opinions at Trial.

3. Attached hereto as Exhibit A is a true and correct copy of the pertinent pages of the
transcript of the March 16, 2017 hearing before this Court on the parties’ motions in limine.

4. Attached hereto as Exhibit B is a true and correct copy of Plaintiff's Notice of
Potential Supplemental Witnesses in View of Court’s March 16, 2017 Discussion Concerning
People v. Sanchez served on March 24, 2017.

5. Attached hereto as Exhibit C is a true and correct copy of Plaintiff's Expert Witness
Disclosure served on September 19, 2016.

6. Attached hereto as Exhibit D is a true and correct copy of Plaintiff's Supplemental
Expert Witness Disclosure served on October 11, 2016.

7. During discovery, Plaintiff and several Defendants inadvertently attempted to retain
Woodbridge as a consultant or expert. As a result, on September 2, 2016, the parties agreed in
writing that neither side would disclose Steve Siciliani or Woodbridge Glass as a testifying expert in
this case. Plaintiff also agreed not to use Mr. Siciliani or Woodbridge going forward in this case.
Attached hereto as Exhibit E is a true and correct copy of the parties’ September 2, 2016 agreement.

8. Attached hereto as Exhibit F is a true and correct copy of People ex. rel. Reisig v.
Acuna, No. C068868, --- Cal.Rptr.3d ---, 17 Cal. Daily Op. Serv. 1807, 2017 WL 772482 at *2 (Feb.
28, 2017), as modified (Mar. 10, 2017).

1

DECLARATION OF SANDY M. KAPLAN IN SUPPORT OF DEFENDANTS’ JOINT MOTION
IN LIMINE TO PRECLUDE PLAINTIFF’S “POTENTIAL SUPPLEMENTAL WITNESSES”
FROM PROVIDING TESTIMONY OR OPINIONS AT TRIALCom dN nn

9. On information and belief, Plaintiff produced the file of William Nugent to
Defendants on October 18 and 19, 2016.

10. On information and belief, Plaintiff produced the file of James Howard to Defendants
on October 27, 2016.

11. On information and belief, Plaintiff produced the file of Richard Cechner to
Defendants on January 23, 2017.

12. Attached hereto as Exhibit G is a true and correct copy of the pertinent pages of the
deposition transcript of James Howard taken in this action.

13. Attached hereto as Exhibit H is a true and correct copy of James Howard’s “Case
Analysis Notes” marked as deposition exhibit 324 in this action.

14. Attached hereto as Exhibit I is a true and correct copy of an email marked as
deposition exhibit 331 in this action.

15. Attached hereto as Exhibit J is a true and correct copy of pertinent pages of a report
marked as deposition exhibit 282 in this action.

16. Attached hereto as Exhibit K is a true and correct copy of the pertinent pages of the
deposition transcript of William Nugent taken in this action.

17. Attached hereto as Exhibit Lis a true and correct copy of pertinent pages of a report
marked as deposition exhibit 285 in this action.

18. Attached hereto as Exhibit M is a copy of pertinent pages of Richard Cechner taken
in this action.

I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.

Executed this 27™ day of March, 2017, at San Francisco, California.

ae

Sandy M. Kaplan

2

DECLARATION OF SANDY M. KAPLAN IN SUPPORT OF DEFENDANTS’ JOINT MOTION
IN LIMINE TO PRECLUDE PLAINTIFF'S “POTENTIAL SUPPLEMENTAL WITNESSES”
FROM PROVIDING TESTIMONY OR OPINIONS AT TRIALEXHIBIT ACDC San Francisco vs. Webcor Builders

Reporter's Transcript of Proceedings
March 16, 2017

Uitte alata els cre)
Exhibits Transcript If Word Index ]
866.999.8310 | aptusCR.com COURT REPORTINGTranscript of Proceedings CDC San Francisco vs. Webcor Builders
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SAN FRANCISCO

CDC SAN FRANCISCO, LLC, a
Delaware limited liability
company,

Plaintiff,

Case No.
CGC-15-546222

vs.

WEBCOR BUILDERS, INC., a
California corporation;
ARCHITECTURAL GLASS & ALUMINUM
co., INC., a California
corporation; MIDWEST
CURTAINWALLS, INC., an Ohio
corporation; VIRACON, INC., a
Minnesota corporation; QUANEX
I.G. SYSTEMS, INC., an Ohio
corporation; and DOES 1 through
100, inclusive,

Defendants.

REPORTER'S TRANSCRIPT OF PROCEEDINGS
Thursday, March 16, 2017

San Francisco, California

Reported By:
Hanna Kim, CLR, CSR No. 13083

Job No.: 10031309

Page 1
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25

Transcript of Proceedings

cDC

Delaware limited liability
company,

WEBCOR BUILDERS, INC., a
California corporation;
ARCHITECTURAL GLASS & ALUMINUM

Cco.,

corporation; MIDWEST
CURTAINWALLS, INC., an Ohio
corporation; VIRACON, INC., a
Minnesota corporation; QUANEX

I.G.

corporation; and DOES 1 through

100,

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SAN FRANCISCO

SAN FRANCISCO, LLC, a

Plaintiff,

Case No.
CGC-15-546222

vs.

INC., a California

SYSTEMS, INC., an Ohio
inclusive,

Defendants.

REPORTER'S TRANSCRIPT OF PROCEEDINGS,
before the Honorable Angela M. Bradstreet,
Department 624, 400 McAllister Street,

San Francisco, California, on Thursday,
March 16, 2017, beginning at 9:32 a.m.

and ending at 4:09 p.m., before Hanna Kim,
CLR, Certified Shorthand Reporter,

No. 13038.

www.aptusCR.com

CDC San Francisco vs. Webcor Builders24

25

Transcript of Proceedings CDC San Francisco vs. Webcor Builders

"What an expert cannot" -- and cannot is bolded.
"What an expert cannot do is relate as true
case-specific facts asserted in hearsay statements
unless they are independently proven by competent
evidence or are covered by a hearsay exception."

And it goes on to say, "In sum, we adopt
the following rule: When any expert relates to the
jury case-specific out-of-court statements and
treats the content of those statements as true and
accurate to support the expert's opinion, the
statements are hearsay. It cannot logically be
maintained that the statements are not being
admitted for their truth."

And, in the Continental Airlines case, the
Court actually -- so the Court -- the Court of
Appeal upheld the trial court's ruling precluding
the expert from testifying regarding the contents of
a report that was prepared by third parties, but the
Court also said, "However, the trial court erred in
precluding the expert from testifying that he relied
on the cost and price figures submitted to him by
House and Rich in forming his expert opinion on the
cost of repairing the aircraft."

So -- and that is consistent with the

California Supreme Court's recent pronouncement in

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Transcript of Proceedings CDC San Francisco vs. Webcor Builders
this area in the People v. Sanchez case.

So, in this case, Mr. Howard may testify
that -- that he -- and may tell the jury, in general
terms, that he relied on various estimates that he
obtained from various people. He just may not
discuss the specific contents of those estimates
unless they are independently proven up by the
actual people who actually prepared them.

So, I learned a lot about this yesterday.
So that's basically -- so, it's granted in part and
denied in part to the -- that's my ruling.

Anyone want to be heard on this?

MR. HENNIGH: So, Your Honor, just to be
clear, you know, because I think, as you pick up,
Jim Howard is a general contractor. And, as general
contractors are bidding for work, they always go to
the subcontractors and get their estimates. And he
can talk about that process and how he priced the
work.

What you're saying is that, if there is a
specific document, for example, that might be an
estimate that was provided to him by one of the
subcontractors --

THE COURT: Exactly.

MR. HENNIGH: -- that that document can't

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Transcript of Proceedings CDC San Francisco vs. Webcor Builders
from the result -- from the results of the Jordi,"
J-O-R-D-I, "lab test?"

"Answer: As they explained to me, as the
molecular weight decreases -- so, if it starts out
at some level and then, by some phenomenon...the
molecular weight is reduced, then likely the
properties of the material have also been modified."

And I think the key phrase here is "as
they explained to me." And that's -- that's replete
in testimony, that he doesn't just get the data --
so, again, it's not quite on all fours with Sanchez.
He doesn't just get the data from other people.

He's getting their opinion that he's parroting --

THE COURT: Right. I'm with you on that,
because Sanchez says you cannot -- and Sanchez
discusses, you know, you can't -- the expert cannot
repeat the substance of conversations he's had with
others. So, if there is an attempt to repeat the
conversations that he's had with others, I will
sustain the objection and cut you right off,
everybody, if they ever attempt to do that with
their experts.

"Tell me what you discussed with
so-and-so."

"Well, I discussed with so-and-so, and

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Transcript of Proceedings CDC San Francisco vs. Webcor Builders
that person said X, Y, 2."

Unless it falls within an exception to the
hearsay rule, under the California Supreme Court's
ruling in Sanchez, I will sustain the objection and
cut them off. And I will -- I'm admonishing you

right now, I will cut you off myself. So, if the

ex- -- if any expert in the case starts saying, "Oh,
I -- he can see, I talked to so-and-so. He can give
the general -- tell the jury generally, I talked to

so-and-so, I had my people do this, I had my people
do that, that's fine. But what they can't get into
is the contents of the discussions, or the context.
That constitutes hearsay.

And that's why Sanchez is so important. I
mean, it's a very important case that just came out
last year. So, you need to -- so, you know, I don't
know if I can be any more clear than that.

MR. SHIMKIN: I have the same argument as
to the other witnesses, but they're in the papers,
Your Honor. I'm not going to repeat them.

THE COURT: Well, again, it's the same
thing that, is that -- is that the -- I will be
following the Sanchez case. And experts may say
what they've done and who they've met with and what

they did and who they relied on and what they relied

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Transcript of Proceedings CDC San Francisco vs. Webcor Builders

COURT REPORTER'S CERTIFICATE
STATE OF CALIFORNIA )
) ss.

COUNTY OF SAN FRANCISCO  )

I, Hanna Kim, hereby certify:

I am a duly-qualified Certified Shorthand
Reporter, in the State of California, holder of
Certificate Number 13083, issued by the Court
Reporters Board of California and which is in full
force and effect.

I am not financially interested in this
action and am not a relative or employee of any
attorney of the parties, or of any of the parties.

I am the reporter that stenographically
recorded the testimony in the foregoing proceeding
and the foregoing transcript is a true record of the

testimony given.

Dated: March 20, 2017

Hanna Kit” CLR, CSR No. 13083

Page 227

www.aptusCR.comEXHIBIT B13382440.2

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HANSON BRIDGETT LLP

SCOTT E. HENNIGH, SBN 184413
shennigh@hansonbridgett.com
ANDREW G. GIACOMINI, SBN 154377
agiacomini@hansonbridgett.com
BRIAN M. SCHNARR, SBN 275587
bschnarr@hansonbridgett.com

425 Market Street, 26th Floor

San Francisco, California 94105
Telephone: (415) 777-3200
Facsimile: (415) 541-9366

Attorneys for Plaintiff
CDC SAN FRANCISCO LLC

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

CDC SAN FRANCISCO LLC. a Delaware
limited liability company,

Plaintiff,
v.

WEBCOR BUILDERS, INC., a California
corporation, ARCHITECTURAL GLASS &
ALUMINUM CO., INGC., a California
corporation, MIDWEST CURTAINWALLS,
INC., an Ohio corporation, VIRACON,
INC., a Minnesota corporation, QUANEX
1.G. SYSTEMS INC., an Ohio corporation,
and DOES 1 through 100, Inclusive,

Defendant.

Case No, CGC15546222

PLAINTIFF'S NOTICE OF POTENTIAL
SUPPLEMENTAL WITNESSES IN VIEW
OF COURT'S MARCH 16, 2017
DISCUSSION CONCERNING PEOPLE v.
SANCHEZ

Assigned to the Hon. Angela Bradstreet

Dept. 624
Complaint Filed: June 9, 2015
Trial Date: March 15, 2017

Case No. CGC15546222

PLAINTIFF'S NOTICE OF POTENTIAL SUPPLEMENTAL WITNESSES IN VIEW OF COURT'S
MARCH 16, 2017 DISCUSSION CONCERNING PEOPLE v. SANCHEZ13382440.2

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At the pretrial conference on March 16, 2017, the Court called all parties’ attention
to People v. Sanchez, 63 Cal.4th 665 (2016), and remarked that neither the Defendants
nor the Plaintiff addressed the case in dealing with Defendants’ request to exclude expert
witness testimony. The hearing transcript reflects the Court's discussion of the issues
that may arise in the application of Sanchez, which the Court indicated it would apply to
all of Defendants’ and Plaintiff's experts. The Court also discussed balancing this against
the holdings in Continental Airlines v. McDonnell Douglas Corp., 216 Cal.App.3d 388
(1989).

Plaintiff believes, based on the Court's discussion, that the testimony from
Plaintiff's experts will be admissible and not violate the Court's concerns. There are two
issues Plaintiff wishes to raise to the Court:

First, People v. Sanchez was a criminal case based largely on the Sixth
Amendment right to confront an accuser in that context. There are no published cases
applying it to a civil case. Plaintiff wishes to call this to the Court's attention and for the
record to object accordingly to its application in a civil context

Second, although Plaintiff anticipates the testimony of its experts will meet the
Court's expectations, out of an abundance of caution, Plaintiff wishes to list the following
individuals as a supplement to its witness list. All of these individuals are known to
Defendants by and through the deposition of Jim Howard and his expert report disclosed
in November 2016. These individuals were subcontractors or suppliers that Jim Howard
analyzed and evaluated in his research toward creating a general contractor estimate for

the replacement work:

Steve Siciliani
Derek Ho
Steve Baldassare
Gregg Tinker
Matt Kamper

Vil

dil

HT

af= Case No. CGC15546222

PLAINTIFF'S NOTICE OF POTENTIAL SUPPLEMENTAL WITNESSES IN VIEW OF COURT'S
MARCH 46, 2017 DISCUSSION CONCERNING PEOPLE v. SANCHEZ1 For the same reason Plaintiff wishes to supplement its witness list with Howard
Jordi as it relates to the testimony of Bill Nugent and Richard Cechner, who obtained
information from Jordi Labs.

DATED: March 24, 2017 HANSON BRIDGETT LLP

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By: Ae a cs
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_SCOTT EHENNI
ANDREW G. GIAGOMINI
BRIAN M. SCHNARR
Attorneys for CDC SAN FRANCISCO LLG

-2- Case No. CGC15546222

PLAINTIFF'S NOTICE OF POTENTIAL SUPPLEMENTAL WITNESSES IN VIEW OF COURT'S
13382440.2 MARCH 16, 2017 DISCUSSION CONCERNING PEOPLE v. SANCHEZ13382440,2

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PROOF OF SERVICE

CDC San Francisco LLC v. Webcor Builders, Inc.
Case No. CGGC15546222

STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO

At the time of service, | was over 18 years of age and not a party to this action. |
am employed in the County of San Francisco, State of California. My business address
is 425 Market Street, 26th Floor, San Francisco, CA 94105.

On March 24, 2017, | served true copies of the following document(s) described as
PLAINTIFF'S NOTICE OF POTENTIAL SUPPLEMENTAL WITNESSES IN VIEW OF
COURT'S MARCH 16, 2017 DISCUSSION CONCERNING PEOPLE v. SANCHEZ on
the interested parties in this action as follows:

SEE ATTACHED SERVICE LIST
BY ELECTRONIC SERVICE: | electronically served the document(s) described
above via File & ServeXpress, on the recipients designated on the Transaction Receipt
located on the File & ServeXpress website (https://secure.fileandservexpress.com)
pursuant to the Court Order establishing the case website and authorizing service of
documents.

| declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.

Executed on March 24, 2017, at San Francisco, California.

Gina A. Anthony

-3- Case No, CGC15546222

PLAINTIFF'S NOTICE OF POTENTIAL SUPPLEMENTAL WITNESSES IN VIEW OF COURT'S
MARCH 16, 2017 DISCUSSION CONCERNING PEOPLE v. SANCHEZ13382440.2

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SERVICE LIST
CDC San Francisco LLC v. Webcor Builders, Inc.
Case No. CGGC15546222

Sandy M. Kaplan

Gordon & Rees

275 Battery Street, Suite 2000
San Francisco, CA 94111
Attorneys for Defendant
WEBCOR BUILDERS, INC.

Telephone: (415) 986-5900
Facsimile: (415) 986-8054
Email: skaplan@gordonrees.com

Brandt L. Wolkin

David F. Myers

Wolkin Curran LLP

111 Maiden Lane, Sixth Floor

San Francisco, CA 94108

Attorneys for Defendant and Cross-
Complainant

ARCHITECTURAL GLASS & ALUMINUM

CO., INC.

Telephone: (415) 982-9390

Facsimile: (415) 982-4328

Email: bwolkin@wolkincurran.com
dmyers@wolkincurran.com

Eileen Pruitt

Damon R. Leichty

Barnes & Thornburg LLP

700 1st Source Bank Center
100 North Michigan

South Bend, IN 46601
Attomeys for Defendant
QUANEX IG SYSTEMS, INC.

Telephone: (574) 233-1171
Facsimile: (574) 237-1125
Email: eileen.pruitt@btlaw.com

Eric J. Nystrom

John C. Ekman

Fox Rothschild LLP

222 South Ninth street, Suite 2000
Minneapolis, MN 55402-3338
Attorneys for Defendant
VIRACON, INC.

Telephone: (612) 607-7000
Facsimile: (612) 607-7100
Email:

enystrom@foxrothschild.com
iekman@foxrothschild.com

James J. Ficenec

Archer Norris

2033 North Main Street, Suite 800
Walnut Creek, CA 94596
Attorneys for Defendant
VIRACON, INC.

Telephone: (925) 952-5572
Facsimile: (925) 930-6620
Email: jficenec@archernorris.com

Kenneth A. Calderone

Hanna Campbell & Powell LLP
3737 Embassy Parkway, Suite 100
Akron, OH 44333

Attorneys for Defendant
MIDWEST CURTAINWALLS, INC.

Telephone: (330) 670-7324
Facsimile: (330) 670-7440
Email: kcalderone@hcplaw.net
aA Case No. CGC15546222

PLAINTIFF'S NOTICE OF POTENTIAL SUPPLEMENTAL WITNESSES IN VIEW OF COURT'S
MARCH 16, 2017 DISCUSSION CONCERNING PEOPLE v. SANCHEZ43382440,2

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Eric S. Wong

ioe Elser Moskowitz Edelman & Dicker
525 Market Street, 17th Floor

San Francisco, CA 94105

Attorneys for Defendant

MIDWEST CURTAINWALS, INC.

Telephone: (415) 625-9271
Facsimile: (415) 434-1370
Email: eric.wonq@wilsonelser.com

Richard E. McGreevy

Brian Leach

Leach & McGreevy, LLP

2833 Laguna Street

San Francisco, CA 94123
Attorneys for Defendant
MIDWEST CURTAINWALLS, INC.
Telephone: (415) 775-4455
Facsimile: (415) 775-7435
Email: Imlawsf@aol.com

John J. McDonough (pro hac vice)
Cozen O'Connor

45 Broadway Atrium, Suite 1600
New York, NY 10006

Attorneys for Defendants and Cross-
Defendants

QUANEX 1.G. SYSTEMS, INC. AND
TRUSEAL TECHNOLOGIES, INC.

Telephone: (212) 908-1266
Facsimile: (866) 263-1342
Email: jmcdonough@cozen.com

Summer Smith

Archer Norris

One Embarcadero Center, Suite 360
San Francisco, CA 94111-3753
Attorneys for Defendant

VIRACON, INC.

Telephone: (415) 653-1480
Facsimile: (415) 653-1481
Email: ssmith@archernorris.com

5

David W. Nelson

Barnes & Thornburg LLP

2029 Century Park East, Suite 300
Los Angeles, CA 90067

Attorneys for Defendant

QUANEX I.G. SYSTEMS, INC.

Telephone: (310) 284-3770
Facsimile: (310) 284-3894
Email: dnelson@btlaw.com

David A. Shimkin

Cozen O'Connor

601 S. Figueroa Street, Suite 3700
Los Angeles, CA 90017

Attorneys for Defendants and Cross-
Defendants

QUANEX 1.G. SYSTEMS, INC. AND
TRUSEAL TECHNOLOGIES, INC.

Telephone: (213) 892-7900
Facsimile: (213) 892-7999
Email: dshimkin@cozen.com

Jennifer K. Stinnett

James C. Keowen

Christensen Ehret LLP

2485 Natomas Park Drive, Suite 315
Sacramento, CA 95833

Attorneys for Defendant
ARCHITECTURAL GLASS &
ALUMINUM CO., INC.

Telephone: (916) 443-6909
Facsimile: (916) 313-0645
Email:

jstinnett@christensenlaw.com
jkeowen@christensenlaw.com

Louis H. Castoria

Kaufman Dolowich & Voluck, LLP

425 California Street, Suite 2100

San Francisco, CA 94104

Co-Counsel for Defendant QUANEX 1.G.
SYSTEMS, INC. and TRUESEAL
TECHNOLOGIES, INC.

Telephone: (415) 926-7600
Facsimile: (415) 926-7601
Email: Icastoria@kdvlaw.com
Case No. CGC15546222

PLAINTIFF'S NOTICE OF POTENTIAL SUPPLEMENTAL WITNESSES IN VIEW OF COURT'S
MARCH 16, 2017 DISCUSSION CONCERNING PEOPLE v. SANCHEZEXHIBIT CESERVICE
eSeRuice

N\A
59580538 \ \
Sep 19 2016
02:03PM

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
Including Professional Corporations
SCOTT E. HENNIGH, Cal. Bar No. 184413
shenni he@esheppardmullin.com
MATHEW R. TROUGHTON, Cal. Bar No. 151752
mtroughton@sheppardmullin.com
BRIAN M. SCHNARR, Cal. Bar No. 275587
bschnarr@sheppardmullin.com
ROBIN V. OHEA. Cal. Bar No. 261086
roshea@sheppardmullin.com
Four Embarcadero Center, 17th Floor
San Francisco, California 94111-4109
Telephone: 415.434.9100
Facsimile: 415.434.3947

zz

Attorneys for Plaintiff
CDC SAN FRANCISCO LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
CDC SAN FRANCISCO LLC, a Delaware | Case No. CGC15546222
limited liability company,
PLAINTIFF CDC SAN FRANCISCO

Plaintiffs, LLC’S EXPERT WITNESS
DISCLOSURE; DECLARATION OF
v. MATHEW R. TROUGHTON
WEBCOR BUILDERS, INC., a California Complaint Filed: — June 9, 2015
corporation, ARCHITECTURAL GLASS Trial Date: November 7, 2016

& ALUMINUM CO., INC., a California
corporation, MIDWEST
CURTAINWALLS, INC., an Ohio
corporation, VIRACON, INC., a
Minnesota corporation, QUANEX L.G.
SYSTEMS INC., an Ohio corporation, and
DOES | through 100, Inclusive,

Defendants.

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
In accordance with Code of Civil Procedure sections 2034.210, et seq., Plaintiff
CDC San Francisco, LLC (“CDC”), hereby designates the following individuals as expert

witnesses in this matter:

“fe
SMRH:479221208.3 PLAINTIFF°S EXPERT WITNESS DISCLOSURE1. James Howard. Howard-Young International of Nevada, Inc., 5602 E.

Montecito Avenue, Phoenix, Arizona 85018.

Tom McCune. Parsons Corporation, 44 Montgomery Street, Suite 880, San

Francisco, CA 94104.

3. Suzanne R. Mellen. HVS, 100 Bush Street, Suite 750, San Francisco,

California 94104.

4, Joseph Minor. P.O. Box 603, Rockport, Texas 7838 1.

wn

William Nugent. Wiss, Janney, Elstner Associates, Inc., 330 Pfingsten

Road, Northbrook, Illinois 60062.

CDC also reserves the right to call any expert designated by any Defendant as may

be necessary at the time of trial.

CDC further reserves the right to call any additional

expert witnesses as may be required to rebut or refute testimony or any other evidence

given on behalf of Defendants, and each of them, or to testify concerning evidence

developed or discovered between this date and the date of trial.

Attached to this expert disclosure is the attorney declaration as required by Code of

Civil Procedure section 2034.260(c).

Dated: September 19, 2016

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

SCOTT E. HENNIGH
MATHEW R. TROUGHTON
BRIAN M. SCHNARR

ROBIN V. O°SHEA

Attorneys for Plaintiff
CDC SAN FRANCISCO LLC

“PLAINTIFFS EXPERT WITNESS DISCLOSUREDECLARATION OF MATHEW R. TROUGHTON

I, Mathew R. Troughton, declare as follows:

1. 1am an attorney duly admitted to practice before this Court. [am special
counsel with the law firm of Sheppard Mullin Richter & Hampton, LLP, counsel of record
for Plaintiff CDC San Francisco, LLC (“CDC”). I have personal knowledge of the facts
set forth below, and if called as a witness, could and would testify competently thereto.

2. CDC has designated the following individuals as expert witnesses in this
litigation.

3. James Howard. Mr. Howard is President of Howard-Young International
and is responsible for managing the overall business operations of the firm as well as
major engagements. Based in Henderson, Nevada, his practice includes consulting and
expert witness testimony in construction, real estate and government contracts disputes and
related issues. His practice also includes consulting services for project oversight, capital
projects development, project management, construction contract delivery systems and
other services related to the development of new facilities/physical plants. Prior to
establishing Howard- Young International, Mr. Howard spent over 25 years in the
construction and real estate industries with over 12 years in executive management roles
responsible for all business operations. He has a B.S. in Construction Engineering, a
B.S.E. in Mechanical Engineering, and an M.B.A. in Business Administration from
Arizona State University. A true and correct copy of Mr. Howard’s curriculum vitae
setting forth his professional qualifications is attached hereto as Exhibit A.

4. Mr. Howard has agreed to testify at trial. The general substance of the
testimony Mr. Howard is expected to give at trial concerns CDC's damages, and related
issues; the standard of care for general contractors and what would reasonably constitute a
breach of such standard, and related issues; the schedule, sequence, steps, procedures,
means, methods, costs, and duration for repairing the curtainwall system of the Hotel, and

related issues.

23:

SMRH:4 7922120835. Mr. Howard is sufficiently familiar with the pending action to submit to a
meaningful oral deposition concerning any opinion he expects to give at trial and the bases
for that opinion,

6. Mr. Howard’s hourly rate for testimony is $742.50 per hour.

7. Tom McCune. Mr. McCune is the Program Director of Public/Commercial

Facilities at Parsons Corporation. In that role, he manages comprehensive planning,

design, construction, and management programs for major buildings serving public

agencies and major corporations. Mr. McCune is a highly experienced financial man
corporate real estate and facilities manager, and architect with a wide range of experience
in all aspects of corporate real estate, construction project management, building design,
and facility planning. His specialties include long-range and strategic facility planning,
corporate real estate portfolio management, “alternative work” facilities (Office Hotelling,
Work From Anywhere, etc.), urban and regional planning, brand management and
advertising programs, management of corporate real estate, facilities, & services programs,

construction project management, and construction claims, forensics, and loss prevention.

A true and correct copy of Mr. McCune’s curriculum vitae setting forth his profess
qualifications is attached hereto as Exhibit B.

8. Mr. McCune has agreed to testify at trial. The general substance of the
testimony Mr. McCune is expected to give at trial concerns the design and as-built

condition of the curtainwall s

ystem at the Hotel, including the performance of the insulated

ting

glass units and the and curtainwall system and their components, as well as related ¢

and future property damage, and related issues; the glass industry, including without
limitation, industry custom, practice, and terminology use for terms such as “film,”
“hermetic seal,” and “failure,” and related issues.

9 Mr. McCune is sufficiently familiar with the pending action to submit to a
meaningful oral deposition concerning any opinion he expects to give at trial and the bases
for that opinion.

10. Mr. McCune’s hourly rate for testimony is $300 per hour.

-4-

SMRECI792212083 DE

ARATION OF MATHEW R. TROUGHTON

t11. Suzanne Mellen. Ms. Mellen is the Senior Managing Director and Practice
Leader of HVS. She has appraised thousands of hotels and related real estate throughout

the world and is national recognized for her industry expertise. With over forty years”

experience in the hotel industry, Ms. Mellen specializes in analyzing hotel operations, with
particular emphasis in the San Francisco/Bay Area market. Her practice includes
analyzing operations, rates, costs, and profitability of hotels, as well as the impacts on an
operating hotel and its bookings due to events such as construction activities. Her prior
professional experience includes consulting and appraisal positions with: HVS New York;
Morgan Guaranty Trust; Laventhol & Horwath; Helmsley-Spear Hospitality Services, Inc.
in New York City; and Harley-Little Associates in Toronto, Canada. She gained her
operational experience at the Plaza Hotel in New York. Ms. Mellen earned her B.S.
degree in Hotel Administration from Cornell University. A true and correct copy of Ms.
Mellen’s curriculum vitae setting forth her professional qualifications is attached hereto as
Exhibit C.

12. Ms. Mellen has agreed to testify at trial. The general substance of the
testimony Ms. Mellen is expected to give at trial concerns the damages the Hotel has

incurred and will incur as a result of repairing the defective insulated glass units and

curtainwall system, including lost revenues, profits, and additional costs expended, as well!
as related issues.

13. Ms. Mellen is sufficiently familiar with the pending action to submit a
meaningful oral deposition concerning any opinion she expects to give at trial and the
bases for that opinion.

14. Ms. Mellen’s hourly rate for testimony is $600 per hour.

15. Joseph Minor. Joseph Minor is an expert and consulting engineer in the
performance of window and curtain wall systems of commercial buildings, with over 45
years of experience in forensic analysis and research in that field. He obtained a B.S. in
Civil Engineering from Texas A&M University in 1959, a Masters degree in Civil

Engineering from Texas A&M University in 1960, and a Ph.D. in Civil Engineering from

SMRH:479221208.3 : DECLARATION OF MATHEW R. TROUGHTONTexas Tech University in 1974. He also served in the U.S. Army Corps of Engineers from
1960 to 1962, as a Senior Research Engineer at the Southwest Research Institute from
1962 to 1969, and as a P.W. Horn Professor and Director of Institute for Disaster and
Glass Research and Testing Laboratory at Texas Tech University from 1969 to 1988. Mr.
Minor was also a Thomas H. Reese Professor at the Missouri University of Science and
Technology from 1988 to 1995, the Chairman of the Department of Civil Engineering

from 1988 to 1993, and a Research Professor, Graduate Center for Materials Research,

from 1993 to 2000. He has been a Visiting Professor and Lecturer with Texas A&M

University-Kingsville on a part time basis from 2003 through 2011. Mr. Minor is a
licensed Professional Engineer in the States of Texas, Missouri and Florida and an active

Fellow in the American Society of Civil Engineers and member of both the National

Society of Professional Engineers and ASTM, Inc. From 1985 to 1988, he served as the
President of the Insulating Glass Certification Counsel (“IGCC”), an organization that
reviews and certifies insulated glass products to ensure quality and performance of those
products in commercial and residential construction. His special area of expertise is the
science and engineering of window glass, including insulated glass units within curtain
walls and other window systems. He has supervised investigations into more than sixty
instances of damage to such systems due to natural elements, including windstorms, hail
and climate exposure. A true and correct copy of Mr. Minor’s curriculum vitae setting
forth his professional qualifications is attached hereto as Exhibit D.

lo. Mr. Minor has agreed to testify at trial. The general substance of the
testimony Mr. Minor is expected to give at trial concerns the design and as-built condition
of the curtainwall system at the Hotel, including the performance of the insulated glass
units and the curtainwall system, as well as related existing and future property damage,
and related issues: the glass industry, including without limitation, industry custom,
practice, and terminology use for terms such as “film,” “hermetic seal,” and “failure,” and
related issues; and the certification of insulated glass units within the industry, as well as
other related issues.

-6-
SMITA 792212083 ; Bee DECLARATION OF MATHEW

TROUGHTONtw

17. Mr. Minor is sufficiently familiar with the pending action to submit a
meaningful oral deposition concerning any opinion he expects to give at trial and the bases
for that opinion.

18. Mr. Minor’s hourly rate for testimony is $500 per hour.

19, William Nugent. William Nugent is a civil and structural engineer with
over 40 years of experience as a forensic expert in the study of structural and product

failures in a commercial setting, with a focus on window and curtainwall designs. He

began his work as an expert consultant for Wiss, Janney, Elstner Associates, Inc. in 1976.

Wiss, Janney is a nationally recognized team of engincers, architects, and materials
scientists who work in the field of construction. The firm has extensive experience with
virtually every type of construction material, structural system, and architectural
component used today. Since becoming an expert, he has personally completed over five
hundred investigation, testing, and repair design projects and has gained firsthand
experience reviewing curtain wall designs, and investigating curtain wall, glass, and
cladding system failures. Mr. Nugent is proficient with laboratory testing and load testing
of components for failure analysis, and designing repair and rehabilitation plans. He
obtained a Bachelor of Science in Civil Engineering from the University of Notre Dame in
1973, and a Master of Science in Structural Engineering from the University of Hlinois at
Urbana-Champaign in 1977. He is a licensed Civil Engineer in the State of California,
and hold active engineering licenses in over 46 different states. Mr. Nugent has also
served as the President of the Safety Glazing Certification Council (“SGCC”), and has
been a member of the Board of Directors of the SGCC for over twenty-five years. He
currently serves on the SGCC’s American National Standards Institute (“ANSI”) technical
committee for Safety Glazing Materials. A true and correct copy of Mr. Nugent's
curriculum vitae setting forth his professional qualifications is attached hereto as Exhibit
E.

20. Mr. Nugent has agreed to testify at trial. The general substance of the
testimony Mr. Nugent is expected to give at trial concerns the design and as-built condition

-7-
DECLARATION OF MATHEW R. TROUGHTONof the curtainwall system at the Hotel, including the performance of the insulated glass
units and curtainwall system, as well as related existing and future property damage, and
related issues; the defective PIB-sealant; the importance of properly formulating PIB
sealant, and related issues; and the progressive nature of harm to the insulated glass units

and curtainwall system, and other related iss

es.

21. Mr. Nugent is sufficiently familiar with the pending action to submit a
meaningful oral deposition concerning any opinion he expects to give at trial and the bases
for that opinion.

22. Mr. Nugent’s hourly rate for testimony is $315 per hour.

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.

Executed on September 19, 2016 in San Franci

-8-

SMRIEAT9 DECLARATION OF MATHEW R. TROUGHTONEXHIBIT APage 1 of 2

Howard-Young International of Nevada, Inc.

Construction Industry Advisors

Resume For
James W. Howard

Mr. Howard is President of Howard-Young International and is responsible for managing the overall
business operations of the firm as well as major engagements. Based in Henderson, Nevada, his
practice includes consulting and expert witness testimony in Construction, Real ate and
Government Contracts disputes and related issues. His practice also includes consulting services for
project oversight, capital projects development, project management, construction contract delivery
systems and other services related to the development of new facilities/physical plant. Prior to
establishing Howard-Young International, Mr. Howard spent over 25 years in the construction and
real estate industries with over 12 years in executive management roles responsible for all business
operations.

Employment History

1998 - Present
President, Howard-Young International. Responsible for management of overall company operations
and selected construction consulting engagements related to real estate and construction matters in
“the areas: of project delivery systems; project oversight and project development for new capital
projects; litigation consulting and expert witness for all ty of construction disputes with particular
“emphasis on construction technology, scheduling and contr: ministration a

1996 - 1998

Director, Coopers & Lybrand National Construction Litigation group. Responsible for managing and
developing the firm's construction litigation practice in the western United States. Managed

engagements in construction and real estate consulting in the areas described above.

1989 - 1996

President and CEO, Kitchell Contractors, Inc., Irvine, California. Responsible for managing all
of company operations. Provided both strategic and operating leadership for all company
ies including sales/marketing, estimating, management, construction operations, and
general/administrative/financial operations.

1986 - 1989

ident, Kitchell Development Company, Phoenix, Arizona. Managed project development
for commercial real estate projects including f analysis, pro forma development,
financing/loan negotiations, project construction, leasing, and property management functions.

1983 - 1985

Vice President, Division Manager, Kitchell Contractors Inc. of Texas, Dallas, Texas. Directed all
company operations including sales/marketing, estimating and construction operations.

.. Applying the experience of seasoned industry executives to assist you in today’s industry challenges.Page 2 of 2

1980 - 1983

Sr. Project Manager, Project Manager, Kitchell Contractors Inc. of Arizona, Phoenix, Arizona.
Managed all aspects of company services on construction projects. Full accountability for success
and profitability of projects managed.

1976 - 1980

Project Manager, Assistant Project Manager - Mardian Construction Co, (now Perini Building
Company), Phoenix, Arizona. Managed all aspects of company services on construction projects.
Full accountability for success and profitability of projects managed.

1974 - 1976

Project Engineer, Mardian Construction Company (Perini), Phoenix, Arizona. Activities included
expediting, submittal processing, change order processing/estimali cost. engineering/analysis,
scheduling and construction detailing.

1971 - 1974

Carpenter, apprentice carpenter - Mardian Construction Company (Perini), Phoenix, Arizona, All
phases and types of carpentry activities on commercial building projects

1968 = 1971

Miscellaneous office, yard, and field labor assignments, Donnelly Construction Company, Phoenix,
Arizona.

Co ring
Graduated with "High Distinction"

truction Engin

Arizona State University

BSE - Mechanical Engineering - Arizona State University
Graduated "Magna Cum Laude"

MBA - Masters in Business Administration - Arizona State Universi

Member of the following academic achievement honor fraternities:

Pi. Tau Sigma - National - Mechanical Engineering
Tau Beta Pi - National - General Engineering
Phi Kappa Phi - National - General Academic

Affiliations

Young Presidents Organizations (YPO)
Associated General Contractors
American Bar Association

Project Management Institute

«Applying the experience of seasoned industry executives to assist you in today’s industry challenges...EXHIBIT B44 Montgomery St. #Suite 880 | San Francisco, CA 94104
PARSONS Main: +1 445.490.2400 | www parsons.com

Thomas McCune

Program Director

EXPERIENCE SUMMARY

Experienced professional with broad background in all aspects of:

« Facility planning and building design

* Corporate real estate portfolio planning & site selection

* Construction management, operations, and facility maintenance

¢ Forensic construction investigations and remediation projects

e Capital budgeting, forecasting, reporting, and financial management

« Permitting & compliance

* Due-diligence inspections and reviews for lenders and property investors

EXPERIENCE
* Parsons Corporation, San Francisco, CA; 7/16 to present
- Position: Program Director, Public/Commercial Buildings
- Manage teams developing new facilities for public agencies and major corporations

- Provide construction consulting services

* Kobalt Brands, Inc., San Francisco, CA; 3/10 to 7/16
- Position: Sr. Consultant & CFO

- Manage forensic consulting, planning, design, and environmental branding projects for clients
including Intercontinental Hotels

- Manage all financial, administrative, HR, and facilities functions for this facility planning,
environmental branding, and consulting firm.

« NELSON & Assoc.., San Mateo, CA & Philadelphia (headquarters); 2/06 to 2/11

- Position: Managing Director

- Manage major real estate planning, building design, consulting, facility management, project
management, and sustainability contracts with HSBC Bank, Sun Microsystems, Bank of America, Cisco
Systems, Verizon, Aetna, and others.

- Manage the firm's California profit center

Parsons PLUS envision more* AE Pragmatics, Inc., San Mateo, CA; 9/98 to 2/06

- Position: Sr. Facilities Consultant & CFO

- | Manage major real estate/facilities outsourcing and consulting contracts with Sun Microsystems,
Cisco Systems, Lam Research, Stanford University, and others.

- Performed due-diligence inspections and risk management reviews for new property acquisitions

- Established this new company to provide corporate real estate consulting, strategic facility planning,
construction project management, and tactical facility services to corporate customers. Staff of 25.

* Hellmuth, Obata & Kassabaum. Inc.; San Francisco, CA; 1/97 to 9/98

Position: Sr. Vice President/Director, Corporate Services

- Managed a major outsourcing contract with Sun Microsystems responsible for corporate real estate
portfolio planning, space planning, project management, and facility design. Staff of 75.

* Tennessee Valley Authority; Knoxville, TN; 6/92 to 1/97
- Position: Vice President/General Manager, Property Services & Development
- Managed complete real estate and facilities program responsible for site selection, real estate
transactions, environmental sustainability, planning, design, construction, operations, and
maintenance of facilities and utility systems plus environmental remediation, contracting and
procurement. Qualified as a federal procurement official. Capital budgets to $140 million, operating,
budgets to $35 million, staff of 600.

« Hellmuth, Obata & Kassabaum, Inc.; San Francisco, CA; 2/86 to 6/92

- Position: Vice President/Director, Quality Assurance
- Managed forensic, loss prevention, and quality assurance for the firm, worldwide
Personally designed building projects and managed multi-disciplinary design teams for major projects

- Prepared forensic investigations of building failures, analyzed claims, and oversaw remediation projects

+ Wagner-Hohns-Inglis; Overland Park, KS; 8/85 to 2/86
- Position: Construction consultant (forensic)
- Analyzed building failures and construction disputes

- Performed design reviews for lenders

PARSONS 2* PKG Group; Lawrence, KS; 7/76 to 8/85
- Positions: Principal, construction manager, project manager
Prepared building designs and managed multi-disciplinary design teams
- Managed construction projects in the field

- Managed project controls (cost and schedule)

EDUCATION, LICENSES AND CERTIFICATIONS

Master of Business Administration (with honors), Vanderbilt University.

Bachelor of Architecture (with honors), University of Kansas.

B.S. Engineering (Highest Distinction) University of Kansas.
University College London
CoreNet MCR Certification (Master of Corporate Real Estate)

Registered Architect: California, Oregon, Washington, Colorado, Kansas, Missouri, Pennsylvania; NCARB
Certificate

INCIDENTAL EMPLOYMENT (part time and consulting basis concurrent with other)
+ City of Belmont, CA

Chairman, City Planning Commission

Finance commissioner

* Architects and Engineers Insurance Company

- Board of Directors for underwriter of professional liability insurance (1990 - 1992)

* Washington University in St. Louis
Adjunct faculty. Taught classes in architectural technology. (1988 - 1992)

* Richard Muther & Assoc.

Staff planner for internationally recognized site selection, industrial engineering, & material handling
firm (1973 - 1986)

MEMBERSHIPS, HONORS, & ACADEMIC AWARDS
American Institute of Architects; Former National Chair, Corporate Architects Committee
CoreNet (Corporate Real Estate Executives Network) MCR Certification
IMFA, The International Facility Management Association

Phi Kappa Phi, Beta Gamma Sigma

PARSONSEXHIBIT CSuzanne R. Mellen, CRE, MAI, FRICS, ISHC

EMPLOYMENT
1985 to present HVS

San Francisco and Los Angeles, California; Las Vegas, Nevada

Senior Managing Director - Consulting and Valuation Division

President - Gaming Services Division

(Hotel-Gaming Valuations, Market Studies, Feasibility Reports, and Investment Counseling)
1981 to L985 HOSPITALITY VALUATION SERVICES

Mineola, New York

Director of Consulting and Valuation Services

(Hotel-Motel Valuations, Market Studies, Feasibility Reports, and Investment Counseling)
1980 to 1981 MORGAN GUARANTY TRUST COMPANY

New York, New York

Real Estate Appraiser and Consultant

(Real Estate Investment Valuation and Analysis)
1980 LAVENTHOL & HORWATH

New York, New York

Senior Consultant

(Management Advising Services Market and Feasibility Studies)
1976 to 1978 WESTERN INTERNATIONAL HOTELS

The Plaza, New York City

Management Trainee

{Rooms Operations, Accounting}
1976 HARLEY, LITTLE ASSOCIATES.

Toronto, Canada

Junior Consultant

(Food Facilities Design, Market Studies)

HVS San Francisco, Los Angeles, & Las Vegas Qualifications of Suzanne R. Mellen, CRE, MAI, FRICS, ISHC iltPROFESSIONAL
AFFILIATIONS

EDUCATION

STATE CERTIFICATION

ARTICLES AND.
PUBLICATIONS

Appraisal Institute Member (MAI)
Board of Directors ~ San Francisco Bay Area Chapter (1994, 1995)
Education Committee Chairperson - Northern California Chapter 11
Workshop Committee Chairperson ~ Northern California Chapter 11
Division of Courses National Committee
Continuing Education Committee - New York Committee
Director, Real Estate Computer Show - New York Chapter
‘American Society of Real Estate Counselors - Member (CRE)

* Vice Chair ~ Northern California Chapter (1994, 1995)

«Chair ~ Northern California Chapter (1996)
National Association of Review Appraisers & Mortgage Underwriters (CRA)
International Society of Hospitality Consultants ~ Member (ISHC)
Fellow of the Royal Institution of Chartered Surveyors (FRICS)
Cornell Center for Real Estate and Finance - Fellow
Cornell Hotel Society
Cornell University School of Hotel Administration - Dean's Advisory Board
American Hotel & Motel Association
California Hotel & Motel Association
Urban Land Institute

eee eee

BS, School of Hotel Administration, Cornell University

Liberal Arts Undergraduate Study, Carnegie Mellon University
Completion of MAI course work, Appraisal Institute

New York University, School of Continuing Education Real Estate Division

Arizona, California, Colorado, Georgia, Hawaii, Illinois, lowa, Louisiana, New Jersey, Oregon,
Pennsylvania, Texas, Utah, Washington, Washington DC

“Stead Cap Rates Support Strong Hotel Value Gains," The HVS Journal - ALIS Edition, January 2015

“Hotel Capitalization Rates and the Impa