REED, ET AL. v. HICKORY HOLLOW COOPERATIVE, ET AL. WARD, CARRIE December 19, 2017 Prepared for you by Bi gha Far s S uthfie d • Gra d Rapids Ann Arbor • Detroit • Flint • Jackson • Lansing • Mt. Clemens • Saginaw • Troy WARD, CARRIE December 19, 2017 Page 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE DOROTHY REED, ROBERT EDWARDS, XAVIER EDWARDS, and SHE-NELLE DOMINIQUE BROWN, NEXT FRIEND OF DOMINIQUE SHE-NELLE BERRY, a minor, Plaintiffs, vs. Case No. 17-000606-NO Hon. John H. Gillis, Jr. HICKORY HOLLOW COOPERATIVE and HUNTINGTON MANAGEMENT, L.L.C., Defendants. _____________________________________ The Deposition of CARRIE WARD, Taken at 4000 Town Center, 9th Floor, Southfield, Michigan, Commencing at 10:19 a.m., Tuesday, December 19, 2017 Before Sharon Campbell, CSR-3406. Page 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TABLE OF CONTENTS WITNESS CARRIE WARD EXAMINATION BY MR. HAKALA: APPEARANCES: JUSTIN J. HAKALA Morgan & Meyers, PLC 3200 Greenfield, Suite 260 Dearborn, Michigan 48120 313.961.0130 jhakala@morganmeyers.com Appearing on behalf of the Plaintiffs. RICHARD A. JOSLIN, JR. Collins, Einhorn, Farrell, P.C. 4000 Town Center, Suite 909 Southfield, Michigan 48075-1408 248.355.4141 richard.joslin@ceflawyers.com Appearing on behalf of the Defendants. 4 EXHIBITS Exhibit Page (Exhibits attached to transcript.) DEPOSITION EXHIBIT 1 DEPOSITION EXHIBIT 2 Page 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PAGE 16 24 Page 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Southfield, Michigan Tuesday, December 19, 2017 10:19 a.m. BY Q. A. Q. A. Q. A. Q. A. CARRIE WARD, was thereupon called as a witness herein, and after having first been duly sworn to testify to the truth, the whole truth and nothing but the truth, was examined and testified as follows: EXAMINATION MR. HAKALA: Ma'am, my name is Justin Hakala. I'm going to ask you some questions today. If you don't understand one of my questions, will you please let me know? Will do. Okay. You had an opportunity to sit through Ms. Patterson's deposition a little bit, true? Yes. I will spare you the process, but if I remind you to answer verbally or something, I'm not trying to be rude. That's fine. We went through the organization chart. Is that roughly your understanding? Yes. Pages 1 to 4 WARD, CARRIE December 19, 2017 Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. And so beneath you then you have an office manager, a maintenance staff? A. Yes. Q. What is the office manager's name? A. Currently it's Aaron Franklin. Q. And how long has -- Ms.? A. Mr. Q. Mr. Franklin, how long has he been in that position? A. Since August 30th. Q. Okay. Who was the office manager before him? A. I had a few. Kristina, I can't think of her last name right now, I'm sorry. Q. That's okay. Who is Kevin Sims? A. My maintenance supervisor. MR. JOSLIN: Carrie, you are probably going to have to keep your voice up a little bit. A. Sorry, I talk very soft. MR. JOSLIN: Well, we have the fans blowing. BY MR. HAKALA: Q. How long has Mr. Sims been in that role? A. Kevin has been in that role now just over a year. Q. Okay. Was he the maintenance person when this incident happened? A. Yes. Page 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. HAKALA: Q. Okay. Take me through your educational background, if you would. A. I have a bachelor's in marketing, I have my real estate license, and I have my IREM, accredited real estate management accreditation, and I have been in property manager now since 2005. Q. Where did you get your bachelor's? A. Davenport University. Q. And then you said the IREM, real estate management? A. Yeah. Q. Is it a license? A. It's an accreditation through IREM. Q. Through what? A. IREM, it's -- I can't even think right now. It's an accreditation with residential management. Q. What's involved in getting that accreditation? A. It is a tedious process. Q. I can imagine. A. A six week process, a class that you take, and it just pretty much teaches you everything that you need to know about property management. Q. Just generally what does it cover? A. It goes through leasing, financials, management, and maintenance. Page 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. And are there additional maintenance people beneath him? A. Yes. Q. And how many, just approximately? A. Two. Q. Two. What are their names? A. Steven Miller and Charles Liggins, L-I-G-G-I-N-S. Q. How long have those two been in place? A. Charles a year now and Steven has been with us just over seven years. Q. Do you remember who was there before, was it Charles, you said? A. Charles, we had a vacancy. Q. Okay. Were both of those two around at the time of this incident? A. Charles, he was not. Steven was. Q. Okay. Any other staff members around at the time of this incident that we haven't just covered? A. I can't recall if I had an office manager at the time of the incident because I had a vacancy during that time period, so I'm not sure. Q. If you did have one, who would it have been? A. Let's see. MR. JOSLIN: If you don't remember -A. Yeah, I don't remember. Page 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. What kind of maintenance topics are covered? A. Work order process, property upkeep, and inspections. Q. Does it cover how to actually do the maintenance? A. No. Q. How to actually, for example, install something? A. No. Q. Okay. Do you have any background in the mechanical side of it, meaning if you had to install an appliance or if you had to do something like that? A. No, not in my wheelhouse. Q. Say that again. A. It's not my wheelhouse. Q. Okay. Fair enough. When did you get your bachelor's from Davenport? A. I graduated December 2004. Q. Where did you go to work after you graduated? A. McKinley Properties. Q. How long were you there? A. 2008. Q. Where did you go after that? A. I was with Metro Property Group, and then I came to Huntington Management. Q. How long were you with Metro Property Group? A. It was an 8 month assignment. Q. So did you start with Huntington in '08 or '09, do you Pages 5 to 8 WARD, CARRIE December 19, 2017 Page 9 1 2 3 think? Again, it's okay if you don't remember. A. December 5 was my anniversary, I have been with them four years, so take it back four years. Page 11 1 Q. You have services? 2 A. Service work orders. 3 Q. Oh, okay. I see what you are saying. 4 Q. Four years from now? 4 A. And we have annual inspections, sometimes we have 5 A. Yep. 5 mortgage inspections if the mortgage company needs 6 Q. So that makes it -- 6 mortgage inspections done, and sometimes we have HUD 7 A. 2013. 7 8 Q. So I'm sorry, you were with Metro Property Group 8 Q. And what does the office manager do? 9 A. Office manager does the intake for the certification 9 beginning in 2008? inspections that are required. 10 A. No, I wasn't working for a while. 10 process. They are done every month by the members, so 11 Q. What period of time were you not working? 11 any documentations that are required to be taken in by 12 A. I would say a year. No, I'm sorry, I started working 12 the members, he does that as well as the payments, he 13 with McKinley in 2010, I'm sorry, and then I was with 13 processes those, and assists with the service order 14 Metro Property Group for a year, in 2011, and then I 14 and intake certification process when they come in by 15 wasn't working in 2012, and then I started working 15 the phones or when members come into the office, and 16 with Huntington in 2013. 16 he gets the files together for me so that I can review them to process them for the members. 17 Q. Why did you leave Metro? 17 18 A. My contract was over. It was a contract job. 18 Q. Okay. So you said the intake certification process? 19 Q. Okay. So you began with Huntington around 2013? 19 A. Yes. 20 A. Yes. 20 Q. And is that for new residents or is that ongoing for 21 Q. And then what did you do between -- well, what did you 21 everybody? 22 A. New and old. 22 do before you started with Metro? 23 A. I was home. 23 Q. So tell me what that is. 24 Q. Was that McKinley? 24 A. With the certifications it's for any employment. Any 25 A. Yeah, I was with McKinley, and then I didn't work for 25 benefits that the member or applicant has it has to be Page 10 1 awhile. 2 Q. So you were not working between '05 and what? 3 A. I told you I was with McKinley. 4 Q. So I have lost the timeline, and I apologize. 5 A. I see. 6 Q. You graduated -- 7 A. When I graduated I went straight to McKinley, and then 8 9 I left McKinley in 2010. Q. Okay. So you were there for about five years, yes? 10 A. From 2005 to 2010, and then when I left McKinley I 11 went to Metro Property Group, and then I wasn't 12 13 14 working, and then I went to Huntington. Q. Okay. And did you start at Huntington in the same position you are in now? 15 A. Yes, the residential manager. 16 Q. And what do you do as a residential property manager? 17 A. Residential manager, I oversee all aspects of the 18 property from the office, maintenance, making sure 19 that the member files are up to date. We have 20 certifications almost like lease renewals, we 21 recalculate members' income and household 22 compensations on an annual basis and sometimes on an 23 interim basis if they have any changes to their 24 household compensation. We have services that are 25 called in, sometimes on a daily basis by the members. Page 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. verified, so we send it to the employer, DHS if it's an applicant, landlord verifications, applicants we are to process credit criminals, he does all that for me, and I have to review it to make sure that it's accurate so that it can be processed accordingly. Is this a process that has to be done to maintain the member's eligibility? Yes. And that's because it's a HUD facility? Yes. All right. You were involved in completing the interrogatories, I gather? Yes. Did you review these before the deposition today? Yes. Did you review anything else? No. Other than counsel, have you talked to anybody about the deposition today? Just Ms. Patterson. What did you talk to her about? This. And you are pointing us to the interrogatories? Yes, sir. That's okay. It's all right. So walk me through -- Pages 9 to 12 WARD, CARRIE December 19, 2017 Page 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 15 number 8 indicates that the stove was -- hold on, let 1 me get there so I don't misquote it. All right. It 2 says without waiving objection, defendant 3 A. Uh-huh. affirmatively states that the elevated carbon monoxide 4 Q. -- it occurred later that day? levels reported by the plaintiff appeared to have 5 A. No, it happened when the family was evacuated from the originated with the stove in the unit of Dorothy Reed. 6 home. Who came to that conclusion? 7 Q. Okay. A. That came from Cosumers, Cosumers Energy. 8 A. The fire department, they inspected the home top to Q. All right. Did they do an investigation? 9 Q. So the inspection that you were talking about the day of the incident -- bottom. 10 Q. Were you there for that portion? question, of the incident, but it happened, I want to 11 A. Yes, sir. say if not a few weeks, a month later. 12 Q. Okay. Q. Okay. 13 A. There were no abnormal readings throughout the entire A. Because the night of the incident, they didn't use the 14 stove at all, so a few weeks or a month later, I can't 15 think of the actual date, they were cooking, and the 16 carbon monoxide detector that we had installed went 17 A. No. Where do you have those? off. 18 Q. Well, those are in the EMT reports. You didn't see -- A. Yes. It had happened, not the original night in Q. And how does that -- why does that tell you that the 19 carbon monoxide a month earlier originated from the 20 stove? 21 residence. Q. I saw elevated carbon monoxide levels at 240 parts per million and 140 parts per million. Did you see those? you weren't aware of elevated levels of carbon monoxide the day of the incident? A. No. A. You said a month earlier? 22 Q. Yes, ma'am. 23 form. Are you referring to blood draws or are you 24 referring to -- I think you are referring to something 25 different. MR. JOSLIN: The first incident. A. The first incident when the fire department and MR. JOSLIN: Well, I'm going to object to Page 14 1 Cosumers came out, they couldn't detect where it came 2 from. 3 BY MR. HAKALA: 4 Q. Right. 5 A. Then the fire department, they used a carbon monoxide 6 detector wand, they inspected the basement with the 7 boiler and the hot water tank. They couldn't find any 8 elevated levels. 9 Q. Right. 10 A. Checked the stove, couldn't get any high levels or any 11 abnormal levels. With a gas stove, whenever you first 12 turn it on, there is a burn off, so you are going to 13 get a reading, but once it burns off, it dissipates. 14 That's the only time that the detector went off, so we 15 did that like three or four times. There were no 16 abnormal readings. So we were all perplexed. We 17 couldn't determine where there were any carbon 18 monoxide levels in the home that evening. 19 So a few weeks later when the family was 20 back in the residence and the detector went off, it 21 was determined from Consumers that there was a 22 malfunctioning with the stove, so we ordered the 23 family a new stove and we replaced it. 24 Q. Okay. Let me hit those items one by one. 25 A. No problem. Page 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. HAKALA: Well, let's -MR. JOSLIN: We will work it out. I mean that's fine. MR. HAKALA: We will mark it. That's fine. MARKED FOR IDENTIFICATION: DEPOSITION EXHIBIT 1 10:36 a.m. BY MR. HAKALA: Q. All right. I will mark this as Exhibit 1. It's a 4-page document. It's got the EMS run sheet from the Westland Fire Department, and I'm going to direct you to the narrative on page 2 under remarks, and I will just read it and then I will give it to you to review. The portion I'm referring to is the portion, I think it's third line halfway through starts a CO monitor showed 240 parts per million in the basement, 120 parts per million in the upstairs. Consumers Energy was then contacted to respond to the scene. So first I will hand you Exhibit 1. Have you seen that document, ma'am? A. Yes, I have seen this document. Q. So take a look at that narrative on the second page that I mentioned. Let me know when you are done. A. But it also reads engine 3 tried to isolate the source of the CO without success. Consumers arrived on the Pages 13 to 16 WARD, CARRIE December 19, 2017 Page 17 1 scene. The scene was left with the complex management 2 Consumers Energy truck. There was no source found. 3 4 Q. So let's break that down. We agree there is elevated carbon monoxide identified in that report, true? 5 A. True. 6 Q. We just don't know the source based upon this report? 7 A. True. 8 Q. Does anything about that report indicate it came from 9 the stove? 10 A. No. 11 Q. You told me the stove wasn't being used that morning? 12 A. Yes. 13 Q. And do you have any idea how carbon monoxide can come 14 from a stove that was not in use? 15 A. No. 16 Q. You understand Consumers Energy was out later that 17 day? 18 A. It wasn't that day. 19 Q. You don't believe Consumers Energy was out that day? 20 A. They were out that morning. It wasn't that day. They 21 came out -- it was around the same time that we were 22 there. 23 24 25 Q. The distinction you are making is it was that morning, not later in the day? A. Yeah, the way that you are trying to make it sound -- Page 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 report. A. Do you have the Consumers Energy report? Q. Probably, but it doesn't matter. I want to know what your memory was about what time they got out there. A. Between 5:40, 5:47 in the morning. Q. So your testimony is Consumers Energy arrived between 5:40 and 5:47 in the morning? A. Yes. They were there the same time the paramedics were there. Q. Okay. And tell me what Consumers Energy did when they were there. A. Even -MR. JOSLIN: Don't look at the report. Just listen to this question and answer. A. They walked through the home. They went in the basement, and they tested the boiler and the hot water tank for carbon monoxide levels. They could not find any. They came upstairs and they checked the stove. They turned it on to see if there were any levels. When they first turned it on the siren went off, then it went off again. They turned the stove off, they turned it back on. The alarm did not go off. They went upstairs. They checked for carbon monoxide levels. The levels were normal. They came downstairs. The levels were normal. They went back Page 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 20 Q. I'm not trying mislead you, ma'am. I don't know what 1 time they were there. What time were they there? 2 in the basement. The levels were normal. The fire department, they had their wand. A. They were there, it was within an hour of me arriving. 3 They checked right behind where the Consumers checked. Q. Okay. We agree that's the same day? 4 They got the same readings. They could not determine A. Yes. 5 Q. Were the windows open? 6 A. Yes. 7 Q. The house was ventilated? 8 A. Yes, I do. 9 Q. Tell me what your understanding is. A. Yes. where there were any high levels throughout the home. Q. Do you have an understanding of where carbon monoxide comes from in these appliances? Q. Do you know what the purpose for doing that was? 10 A. It was to let out any fumes that were possibly in the 11 combustion in whatever the device is, it kicks off the 12 fumes, and it burns and it has to be released, and so Q. Do you know who did that? 13 that's why it releases these fumes, and it burns off, A. No. 14 and I probably am not explaining it the correct way Q. Did you do that? 15 A. No. 16 Q. Did you interact with anybody from Consumers Energy 17 home. when they came out that day? 18 A. My understanding is when there is a buildup, a because this is not -- I'm not an expert in this. Q. Yeah, that's okay. I just want to know what your understanding is. A. So when we went through the home, and I even A. That morning, yes. 19 Q. Would it help you if I said that morning? 20 A. Yes. 21 Q. Where is the videotape? Q. Give me the time you thought they were out there 22 A. I don't have it with me at this time. 23 Q. Why did you videotape? A. What time is on this report? 24 A. I always videotape when I'm doing inspections. Q. That's the EMS report, not the Consumers Energy 25 Q. Where is the videotape today? I know it's not with again. videotaped it, we didn't have any readings when we walked through the home, so -- Pages 17 to 20 WARD, CARRIE December 19, 2017 Page 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you, but where is it? A. It's probably at my office. Q. Where in your offices is it, is it on a computer, is it on the camera, do you have any idea? A. It's probably on my computer. Q. Do you save the videotape as a matter of course when you videotape an inspection? A. Yes. Q. And do you have a directory on your computer you save them? A. Yes. Q. Would anything else have been saved with the videotape from the inspection, photos, anything like that? A. I think for that eval we had the video. Q. Have you reviewed that videotape for the purpose of this deposition? A. No. Q. When is the last time you looked at the video? A. It has been several months. Q. All right. Okay. Understanding that you are not a CO, carbon monoxide expert, and I don't mean to imply that you are, we agree that all these appliances that burn natural gas or potential causes of carbon monoxide, they call can produce it, at least? A. Uh-huh. Page 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. I mean you just don't recall which? A. No. Q. Do you remember if you were around, you knew about this at the time, or whether this was something you figured out from reviewing records later? A. I'm not sure. Q. Okay. Do you know why they were called out? Was it a smell, was it a CO meter going off, something like that? A. The carbon monoxide detector went off. Q. Was this a new carbon monoxide meter? A. Yes, the one we installed. Q. Was there a carbon monoxide meter in there the day of the first incident? A. No. Q. Were carbon monoxide detectors in some of the town homes? A. Yes. Q. And why were they in some but not others? A. With the city ordinance, with the newer refurbished homes, they were mandated. Q. So does that mean you had installed them when the places were refurbished? A. Yes. Page 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. I'm sorry, you have to say yes or no. A. Yes. Q. Any idea why the carbon monoxide would be higher in the basement than it was upstairs if the stove was the source of the carbon monoxide? A. I do not. Q. The stove was not in the basement, true? A. True. Q. When the incident happens a month later and Consumers Energy came out, were you present for that walkthrough? A. I don't recall. Q. If you would have been, would you have videotaped it? A. Yes, or took pictures. Q. Do you know whether or not you did? A. I don't recall. Q. I know we went through it briefly, but let's go back to make sure I understand. The second time Consumers Energy was called out, do you know who called them? A. I'm not sure. Q. Do you know if it was you or the maintenance staff? A. It would have been -- it could have been the maintenance staff or the member, I'm not sure. Q. Okay. Homeowner -- excuse me, the member could have called them out themselves? Page 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. So was this kind of an ongoing process to get them installed? A. Yes, but we took the initiative and installed them in all 267 homes. Q. After this incident? A. We did it to do them. Q. What? A. We did it with our inspections. Q. What does that mean? A. We do annual inspections. Q. Okay. A. And so we did the initiative and installed them in all of our homes. Q. When was that? A. We did it in -- no, we did it with this annual inspection. Q. Right after this incident? A. We did it with this annual inspection that we just did. Q. You mean weeks ago? A. No, 2017 annual inspection. Q. When was the annual inspection of 2017? A. It was this spring. MARKED FOR IDENTIFICATION: DEPOSITION EXHIBIT 2 Pages 21 to 24 WARD, CARRIE December 19, 2017 Page 25 Page 27 1 A. We sent them out to phase, I think phase 2. We jumped 2 BY MR. HAKALA: 2 on those and got them done, and then we knocked out 3 Q. Okay. I have marked a letter that's dated November 3 1 10:48 a.m. the rest of them when we did our annual inspections. 4 29, 2016 with the Hickory Hollow logo on top and your 4 Q. How many total units are there? 5 name on the bottom regarding carbon monoxide detectors 5 A. 267. 6 as Exhibit 2. 6 Q. And how many are in phase 2 approximately? 7 A. Uh-huh. 7 A. I have to look that up and get it back to you. 8 Q. Go ahead and take a look at that and let me know if 8 Q. How many phases are there? 9 A. 2. 9 you recognize the letter. 10 A. Yes. 10 Q. So is roughly half of them in phase 2? 11 Q. Is that a letter that you prepared? 11 A. No, it's not split right down the middle. 12 A. It is. 12 Q. Do you know if phase 2 is the bigger or the smaller of 13 Q. And was it sent to everybody at the facility? 13 14 A. Yes. 14 A. The bigger. 15 Q. And so some of these places had carbon monoxide at 15 Q. -- the two phases? 16 that time, carbon monoxide detectors, and some of them 16 17 didn't? 17 18 A. Uh-huh. 19 MR. JOSLIN: You have got to say yes or no. the -- So you sent it to phase 2. Does phase 2 have some refurbished town houses in it? 18 A. It's mixed up. 19 Q. So some? 20 A. Yes, sir. 20 A. Yes. 21 BY MR. HAKALA: 21 Q. So a lot of people who already had carbon monoxide 22 Q. Why did you send it to everybody rather than just the 22 23 places that didn't have carbon monoxide detectors? 23 24 25 A. Because we wanted to get them installed, but we didn't finish them all, so we just finished them all this detectors were getting this letter? A. Yes. What we did was a carbon monoxide, smoke 24 detector combo, where some of them they just had a 25 carbon monoxide detector in it, we upgraded it with a Page 26 1 2 spring with our annual inspection. Q. I'm asking about at the time of the letter. You told Page 28 1 hard wire so that it matched with what we already had 2 with the hard wire smoke detector, so now it had one instead of just one battery carbon monoxide detector. 3 me that the facilities that were newly refurbished had 3 4 carbon monoxide detectors, right? 4 So what we did in the Reed's residence 5 A. Uh-huh. 5 after their situation, we gave them a hard wired 6 Q. That was true at the time you sent this letter in 6 carbon monoxide, smoke detector combo. We were able 7 2016? 7 to put that same one in all of the units once we did 8 A. Yes. 8 9 Q. Why didn't you just send the letter to everybody that 9 10 11 didn't have a newly refurbished town home? A. Because our board wanted us to get out and get some of 10 11 them all. Q. What were placed in the refurbished condos, refurbished town homes, excuse me, at the time they were refurbished? 12 them installed, so we sent this out to part of the 12 A. The battery one. 13 property to get them installed to get a jump start on 13 Q. And those were upgraded as part of this? 14 it, and so we finished the rest of them when we did 14 A. The hard wire. 15 our annual inspections. 15 Q. And then as part of the annual inspections in the 16 Q. You said it's part of the property? 16 17 A. Yes. 17 A. Uh-huh. 18 Q. You didn't send it to everybody? 18 Q. You have got to say yes or no. 19 A. Yes. 19 A. Yes. 20 Q. I thought you sent them to everybody. You told me 20 Q. Does that mean with the annual inspections that each 21 22 that earlier. A. No, we sent them out to part of the property to get a 21 spring of '17, you did the rest of them? town home was actually inspected? 22 A. Yes. Q. And so as part of the inspection, somebody looked to 23 jump start on it, and then we finished the rest of 23 24 them when we did our annual inspections. 24 see which smoke detector or carbon monoxide detector 25 was there? 25 Q. Which part of the property did you send it to? Pages 25 to 28 WARD, CARRIE December 19, 2017 Page 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. And they were all upgraded to hard wired combination units? A. Yes. Q. Which brand do you use? A. I don't know. I have to get back to you on that. Q. Do you know how much they cost? A. I want to say they are -- I think we got a deal on those for about 20, $25, because we ordered them in bulk. Q. You said you videoed the day of the incident. Did you take photos as well? A. No. Q. Do you have a video camera that you use for this that stays in your office or do you just pull out your cell phone? A. My cell phone. Q. Okay. Do you have a camera when you take photos for inspections that you use that's in the office? A. I do, but a lot of times I use my cell phone. Q. Do you have an understanding that in 2013 a boiler was replaced in this unit? A. I don't know the specific date, but I know that it was replaced. Q. And I understand from seeing the interrogatory Page 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was the one that was replaced was the original boiler in the unit? A. No, I don't know. Q. Do you have any knowledge about the details of that job? A. I was not the manager. I don't know. Q. Have you been a manager for a boiler replacement since -- with Michigan Mechanical? A. Yes, but just not with Hickory. Q. What do you mean not with Hickory? A. I was at another property. Q. Have any boilers been replaced since you have been there? A. Yes. Q. When a boiler is replaced, what is your involvement? A. I generally contact the company. They come out and they remove the old boiler and install the new one. Q. Okay. A. I generally just contact them. Q. So the paper you get is what, do you get an initial work order? A. No, I just get the invoice after the fact, and it just details the work that's done. Q. Okay. Let's walk through the process. How does it come about where a boiler needs to be replaced from Page 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. responses that it was, the company was what, Michigan Mechanical or Michigan Mechanic? Mechanical. Is that a company that Hickory Hollow has used in the past? We used them frequently. Do you use them for all of the boiler replacements? We used to. Okay. When did that change? I believe it was 2015. And why did you stop using them? We just weren't satisfied with their services any longer. We have another company that we prefer. Who is the company you use now? Burton & Sons. How many boilers throughout the entire facility do you think have been replaced over the years by Michigan Mechanical? I'm not sure. If you had to estimate, would you estimate between one and ten or ten and fifty or over a hundred? I couldn't guess. You have a memory of doing it more than once, though? Yes. When this one was replaced in 2013, do you know if it Page 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 your standpoint, meaning you're not in the suite -- or you're not in the town home. Somebody contacts you, right? A. Uh-huh. Q. And is it the member or is it the maintenance staff or how does it work? A. A member contacts us stating that there is an issue with the boiler. Generally they don't have heat. Maintenance will come out to assess it to see what's going on with it. If they can't troubleshoot it to get it to work, then we contact the contractor to come out to take a look at it. The contractor will try and see if they can troubleshoot it to get it to work. If they can't, then they will diagnose it to determine that it needs to be replaced. They will reach out to us in the office, and we will get a quote for a replacement from their office, and we will get it approved, and then we will schedule the replacement. Generally it's the next day if not the same day that it's replaced, and then we get the bill for the replacement, and generally Burtons give us a detailed report of what was done to replace it. Q. What does the detailed report look like? A. It's pretty detailed of what they originally came out and saw wrong with the boiler to determine what was Pages 29 to 32 WARD, CARRIE December 19, 2017 Page 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 done and try to get it to work, and then what it was replaced with, and the cost. Q. That's something that Burton does? A. Uh-huh. Q. You have got to say yes or no. A. Yes. Q. Is it incorporated then into a file somewhere? A. Yes. Q. Have you ever seen one of those from Michigan Mechanical, a similar summary that they did? A. No. Q. Did they just basically give you the invoices to your knowledge? A. Yes. Q. And if you wanted to check whether there was anything other than the invoice in 2013 for this boiler replacement, where would you go look? A. With Michigan Mechanical, it's -- I'm not sure if we can get one from them because we don't use them. Q. I'm asking a little different question. I'm asking if Michigan Mechanical invoiced you in 2013 -A. Uh-huh. Q. -- would you have kept that invoice? A. I wasn't the manager -Q. Okay. Page 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. They told you they didn't have anything? A. They are not the most cooperative company. Q. Who did you talk to? A. Just a representative. Q. How did you know to call them? A. Because that's the company that replaced the boiler. Q. But how did you know that? A. Because that's what my maintenance staff told me. That was the last company that we used, the last HVAC company that we used on site. Q. How do you know that the boiler had been replaced in 2013, though? A. Because that's the last company that we used. That's the tag that's on it, Michigan Mechanical. That's the last company that we used to replace that boiler. Q. Is there a tag on the boiler that says replaced 2013? A. And we have the invoice in our -- not the invoice, but the -- in our system we have an electronic invoices system where we put in for our billing, and for the record it shows Michigan Mechanical was the billing for that, so I don't have an actual paper invoice, but for our -- for where we cut our checks, Michigan Mechanical was the one that billed us for that. Q. That's an accounting entry? A. Yeah. Page 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. -- so I don't have those records. Q. Let me back up. If Michigan Mechanical invoiced you in 2013 and the manager at the time kept it, where would it have been put? A. It would have been put in their file. Q. There is a specific file for the Reed's residence? A. No, for Michigan Mechanical file. Q. Okay. A. But I don't have it. Q. Any idea where it went? A. I have no clue. That manager is no longer with the company. Q. So the manager -- well, the manager left, there is no file, you have no way of finding it, it's not there? A. No. Q. Do you have a contact with Michigan Mechanical that you would call if you had a question? A. No. Sorry. Q. That's okay. A. I tried. Q. You tried? A. Yes. Q. What did you do to try? A. I reached out to them to retrieve the record, and very unsuccessful. Page 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. And then you said there is something on the boiler itself that says Michigan Mechanical? A. I believe there is a tag on it that says Michigan Mechanical. It's like their -Q. Did you take a photo of that when you saw it? A. No, I didn't take a photo. Q. It's still there, though, presumably? A. I believe so. Q. Anybody at Consumers Energy tell you that they believed the cause of the carbon monoxide on Thanksgiving of 2016 was the stove? A. They couldn't determine. Q. I know, but we started down that road, and you said, well, Consumers Energy came to that conclusion, and what I am trying to figure out is did they write down that, did they give you a report that says this is what happened or did somebody walk you through it or anything like that? A. The only thing from that evening I can recall is when we turned on the stove, you get that initial burn, and the detector went off, but it dissipated and it went away. That's the only thing that happened that evening. I don't have a copy of the report that they gave me from that evening, what they wrote down to reflect on it. Pages 33 to 36 WARD, CARRIE December 19, 2017 Page 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. So they come out a month later, they find some Page 39 1 2 issue with the stove? morning? A. No. The only thing they had on the counter was a crock pot. A. Yes. 3 Q. What was the issue they found with the stove? 4 Q. The crock pot is a plug in unit? A. That it was emersed in carbon monoxide. 5 A. Yes. Q. And did you get a document that said that? 6 Q. Is there a maintenance person that helped you go A. Yes, I believe we had a Consumers report. I'm not 7 8 sure if you got a copy of it or not. Q. What would that be called, a Consumers Energy report? 9 A. I'm not sure what it's called. 10 Q. And so is it fair for me to -- strike that. 11 through the unit or take carbon monoxide measurements or anything like that? A. To walk through the unit, we had on the scene one of my on call guys, Steven Miller. He was there, but he didn't take any readings. 12 Q. He was there? conclusion that the stove caused the first incident 13 A. He was there with the fire department and the based upon what was discovered during that second 14 incident? 15 Q. Anybody else there that you can recall? A. I'm not sure what caused it. 16 A. Kevin Sims, he came later on that morning. Q. Okay. So on question number 8 it says, and this is 17 Q. And do you remember what Kevin Sims did? the interrogatories, it says defendant affirmatively 18 A. He was there with Consumers as we just wrapped up the states that the elevated carbon monoxide levels 19 reported by the plaintiff appeared to have originated 20 with a stove in the unit of Dorothy Reed, but as you 21 sit here today you don't know whether or not the stove 22 caused those elevated levels; is that true? 23 It sounds like you have come to the Consumers Energy. unit. Q. All right. Let me check my notes, and I will finish up here. Do you know who installed any of the other appliances in the basement in the Reed's townhouse? A. True. That's -- 24 A. As in what, appliances? Q. You just have an understanding that the stove caused 25 Q. Well, I don't know what else was down there, but I Page 38 1 elevated levels a month later? 2 A. Yes. 3 Q. Are you relying -- strike that. 4 5 When you originally answered this question number 8, were you relying on anything else? 6 A. No. 7 Q. Any other information that caused you to come to that 8 9 10 conclusion? A. No. Like I stated, when we walked through, the only thing when we first turned it on, it did it, so -- 11 Q. It did what? 12 A. It caused the carbon monoxide detector to go off. 13 They didn't have a detector that evening. We 14 installed one for them. So I don't know. 15 16 17 Q. Hold on. When you said you first turned on the stove, it caused the carbon monoxide detector to go off? A. No, it caused the wand, the handheld wand to go off, 18 but then when she would shake the wand to clear to get 19 a good read, it didn't go off anymore. 20 Q. Okay. 21 A. But the Reed family, they said that they weren't 22 cooking that evening? 23 Q. That morning? 24 A. Well, evening, early morning, so I don't know. 25 Q. Did you see any evidence that they were cooking that Page 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 assume there is a water heater down there? A. I'm not sure. Q. Do you know if there are any other appliances in the basement? A. Anything else they would have installed themselves or had someone else install. Q. But there is no other appliances other than the water heater and the boiler that are installed by Hickory Hollow? A. No. Q. Do you know if any service has been done on the -strike that. Do you know if any service was done on the boiler or the water heater or anything else in the basement in the year or so before that? A. Not that I'm aware of. Q. Any other carbon monoxide incidents since you have been at Hickory Hollow? A. No, as in -Q. Anybody ever complain of their carbon monoxide detectors going off? A. Yes. Q. And when that has happened, have you ever found any sources of carbon monoxide? A. It may have been a boiler that may have needed to be Pages 37 to 40 WARD, CARRIE December 19, 2017 Page 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 cleaned or just a faulty carbon monoxide detector. Q. When you think it's the boiler that needs to be cleaned, what happens? A. We call our HVAC technician to come out to service the unit. Q. And is that an employee of Hickory Hollow? A. Either our employee comes out to see what's going on and then we call Burton & Sons. Q. Burton & Sons is the HVAC contractor? A. Yes. Q. Roughly how many times do you think that has happened? A. I'm not sure. Q. Have you had to replace any other boilers because of carbon monoxide issues? A. Yes. Q. How many times do you think that's happened? A. I'm not sure. Q. Is that before or after this incident? A. After. Q. Any before? A. No. Q. Have you ever had to replace any other items before this incident, water heaters, boiler, anything like that due to carbon monoxide? A. No. Page 43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No. Actually yes, they came out -- did they come out that evening? No, Consumers came out after. No, they did come out after this incident. Q. They did or they didn't? A. They did. Q. When do you think they came out? A. They came out before they vacated. Q. And do you know when that was? A. I do not. Q. Do you have any idea why they came out? A. They had a heating issue. Q. Do you know what was done? A. I do not. Q. Do you have a record of that? A. Yes. Q. You just don't remember what it says? A. No. Q. Do you agree that Hickory Hollow is responsible if the appliances are causing elevated carbon monoxide levels? MR. JOSLIN: Object to form. BY MR. HAKALA: Q. You can answer. A. Responsible how? Q. I mean -- well, let me ask you this way. Would Page 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. So this was the first -- strike that. Do you know how many boilers you have replaced since this incident? A. How many boilers I have replaced? Q. Yeah. A. I have replaced several boilers. Q. Do you know how many of them are related to carbon monoxide? A. No. Q. Is it more than five? A. No. Q. So maybe a handful, one, two, three, four, any idea? A. There was more than one. Q. And how -- in those incidences, how did you come to the conclusion that there was a carbon monoxide problem? A. A carbon monoxide detector. Q. And are we talking about the handheld wand or are we talking about the overhead unit? A. Overhead unit, and then the HVAC technician. Q. Okay. The tech has come to the conclusion? A. Yes. Q. And is that Burton & Sons? A. Yes. Q. Is Burton & Sons been out to the Reed's residence? Page 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. somebody else be responsible? Responsible how? Do you know what the word responsible means? I do, but responsible in what respect? I don't know what you mean. I don't know what you mean either. All right. I'm going to give you a hypothetical and see if you can -- if we can make sense of it that way. So let's assume that the appliances in a given town home aren't installed correctly for whatever reason, and they are causing elevated carbon monoxide levels in a given time. Uh-huh. If that's hypothetically true, whose responsibility is that from the perspective of who should fix it? Responsible for the landlord to fix the issue. I'm sorry, what? It's the responsibility of the landlord to fix the issue. Okay. And then if somebody gets hurt as a result of that, whose responsibility is that? MR. JOSLIN: Object to form. It calls for a legal conclusion. You can answer. If it's due to neglect, then it's the landlord's fault. Pages 41 to 44 WARD, CARRIE December 19, 2017 Page 45 Page 47 1 BY MR. HAKALA: 1 removed that, we went and purchased them an additional 2 Q. And, well, do we agree it's not the tenant's fault if 2 exhaust hose and installed it properly for them. This 3 was a precaution. 3 they didn't know about it, right? Q. I asked you five minutes ago if there were any other 4 A. Correct. 4 5 Q. And do you have an understanding of carbon monoxide 5 appliances in the basement. You told me no. 6 such that you know what safe and unsafe levels are? 6 A. I did tell you yes. I said anything else they installed themselves. 7 A. Yes. 7 8 Q. So I put the report in front of you that had levels of 8 Q. They installed the dryer themselves? 9 A. Yes. We do not install appliances. Their dryer and 9 10 240 and 100 some parts per million. Do you have an understanding that those are unsafe levels? 10 washing machine, we do not install those. 11 A. Yes. 11 Q. So when you observed the dryer, when was that? 12 Q. If you had been made aware that there were unsafe 12 A. We installed -- we saw that when we did the stove, I want to say. 13 levels of carbon monoxide in a town home, what would 13 14 you do to fix it? 14 Q. And you observed the exhaust was duct taped? 15 A. Find the source and get rid of the source. 15 A. Yes. 16 Q. And how do you find the source? 16 Q. And did you ever observe any leaks from the exhaust? 17 A. Have a licensed professional come in to find the 17 A. Well, we didn't know if it was leaking or not, but we 18 19 20 source. Q. All right. And did you ever do that with the Reed's 18 just saw that it was not installed properly, the 19 carbon monoxide detector went off, so we installed it properly for them. 20 residence? Q. Do you know if the dryer was operating the day of the 21 A. We had professionals out to try to find the source. 21 22 Q. Who? 22 23 A. Consumers were there, the fire department were there. 23 A. I do not. incident? 24 We had Burton & Sons there. We could not find the 24 Q. Would that be on that video you have? 25 source. When we did find the source, we removed the 25 A. No. Page 46 1 source and replaced the source. 2 Q. You told me Burton & Sons was there months later? 3 A. We had Consumers there. We had the fire department 4 there. We could not find the source. 5 Q. Okay. So Burton & Sons was not there the day of? 6 A. Right, not the day of. 7 Q. They were not there the month later? 8 A. We had Consumers there -- 9 Q. Stay with my question. 10 A. I understand. 11 12 MR. JOSLIN: She is trying to answer your question. 13 A. I am. 14 BY MR. HAKALA: 15 Q. Go ahead. 16 A. We had Consumers there and the fire department there 17 18 the morning of the incident. We could not find the source that day. 19 Q. Okay. 20 A. When we got the alarm, the next incident, Consumers 21 were out, we found the source was the stove. We 22 removed the source, we ordered a replacement, and we 23 installed it. To go an additional step, in their 24 basement we saw that they had their dryer vent, the 25 hose going to the exterior of the home duct taped. We Page 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Q. A. Q. No, you didn't check that on the video? No, because it wasn't on. What wasn't on? The dryer. Okay. Any other appliances in the basement that you are aware of regardless of who installed them? A. I don't know. I don't know if they have a deep freezer or anything, but they have a washer and a dryer. Q. So there is a washer, there is a dryer, there is a hot water heater, and there is a boiler? A. Yes. Q. Anything else to your knowledge? A. (Nodding). Q. Say no. MR. JOSLIN: You have got to say yes or no. A. No. BY MR. HAKALA: Q. The fire department was not looking for the source of the carbon monoxide, true? A. I'm sorry? MR. JOSLIN: Foundation. BY MR. HAKALA: Q. The fire department to your knowledge was not looking for the source of the carbon monoxide leak when they Pages 45 to 48 WARD, CARRIE December 19, 2017 Page 49 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 were there, true? A. Yes, they were. Q. Okay. What did they do to look for it? A. As I previously stated, they had their carbon monoxide detector wand. They checked the boiler, they checked the hot water tank. They checked the stove to see if there were leaks. Q. They didn't find any? A. They didn't find anything. Q. At the point they were doing that, were the windows already open? A. When I arrived everything was open. Q. And the same thing was true then when Consumers Energy arrived? A. Yes. Q. How long do you think the fire department stayed to look for the carbon monoxide leak? A. They were there -- we were all walking around for at least two hours, I want to say. Q. And how much of it do you think you videoed? A. I'm not sure how long the video is. It probably is just a few minutes, if that. Q. All the times Burton & Sons would have been called out, either to the Reed's place or somewhere else, you said there would be a report and a file? Page 51 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE OF NOTARY STATE OF MICHIGAN ) ) SS COUNTY OF WAYNE ) I, SHARON CAMPBELL, certify that this deposition was taken before me on the date hereinbefore set forth; that the foregoing questions and answers were recorded by me stenographically and reduced to computer transcription; that this is a true, full and correct transcript of my stenographic notes so taken; and that I am not related to, nor of counsel to, either party nor interested in the event of this cause. SHARON CAMPBELL, CSR-3406 Notary Public, Wayne County, Michigan My Commission expires: June 9, 2019 Page 50 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Uh-huh. Yes? Yes. And it would be under the Burton & Sons file? Yes. As opposed to a specific town home's file? Yes. So you could just take that file and take a look at when they had been out and what they had done? Yes. And what would you call that file? Burton & Sons. Okay. If I were to ask you for it, would I just ask for the Burton & Sons file? Yes. MR. HAKALA: Okay. That's all I have. MR. JOSLIN: That's it. (The deposition was concluded at 11:24 a.m. Signature of the witness was not requested by counsel for the respective parties hereto.) Pages 49 to 51 WARD, CARRIE December 19, 2017 Page 52 A aaron 5:5 able 28:6 abnormal 14:11 14:16 15:13 accounting 35:24 accreditation 7:6,13,16,17 accredited 7:5 accurate 12:5 actual 13:16 35:21 additional 6:1 46:23 47:1 affirmatively 13:4 37:18 ago 24:20 47:4 agree 17:3 18:4 21:22 43:18 45:2 ahead 25:8 46:15 alarm 19:22 46:20 anniversary 9:2 annual 10:22 11:4 24:10,15 24:18,21,22 26:1,15,24 27:3 28:15,20 answer 4:20 19:14 43:23 44:23 46:11 answered 38:4 answers 51:9 anybody 12:18 18:17 36:9 39:15 40:20 anymore 38:19 apologize 10:4 appearances 2:1 appeared 13:5 37:20 appearing 2:9 2:17 appliance 8:8 appliances 20:7 21:22 39:23,24 40:3,7 43:19 44:9 47:5,9 48:5 applicant 11:25 12:2 applicants 12:2 approved 32:18 approximately 6:4 27:6 arent 44:10 arrived 16:25 19:6 49:12,14 arriving 18:3 asked 47:4 asking 26:2 33:20,20 aspects 10:17 assess 32:9 assignment 8:24 assists 11:13 assume 40:1 44:9 attached 3:12 august 5:9 aware 15:19 40:16 45:12 48:6 awhile 10:1 B bachelors 7:4,8 8:13 back 9:3 14:20 19:22,25 22:17 27:7 29:6 34:2 background 7:2 8:7 based 17:6 37:14 basement 14:6 16:16 19:16 20:1 22:4,7 39:23 40:4,15 46:24 47:5 48:5 basically 33:12 basis 10:22,23 10:25 battery 28:3,12 began 9:19 beginning 9:9 behalf 2:9,17 believe 17:19 30:10 36:3,8 37:7 believed 36:10 beneath 5:1 6:2 benefits 11:25 berry 1:7 bigger 27:12,14 bill 32:20 billed 35:23 billing 35:19,20 bit 4:17 5:16 blood 15:23 blowing 5:19 board 26:11 boiler 14:7 19:16 29:21 30:7 31:1,7,15 31:17,25 32:8 32:25 33:16 35:6,11,15,16 36:2 40:8,14 40:25 41:2,23 48:11 49:5 boilers 30:16 31:12 41:13 42:2,4,6 bottom 15:9 25:5 brand 29:5 break 17:3 briefly 22:17 brown 1:6 buildup 20:10 bulk 29:10 burn 14:12 21:23 36:20 burns 14:13 20:12,13 burton 30:15 33:3 41:8,9 42:23,25 45:24 46:2,5 49:23 50:4,12,14 burtons 32:21 C call 21:24 34:17 35:5 39:10 41:4,8 50:11 called 4:6 10:25 22:19,19,25 23:8 37:9,10 49:23 calls 44:22 camera 21:4 29:14,18 campbell 1:22 51:6,22 cant 5:11 6:19 7:15 13:15 32:10,14 carbon 13:4,17 13:20 14:5,17 15:15,19 17:4 17:13 19:17,23 20:6 21:21,23 22:3,5 23:11 23:12,14,17 25:5,15,16,23 26:4 27:21,23 27:25 28:3,6 28:24 36:10 37:5,19 38:12 38:16 39:7 40:17,20,24 41:1,14,24 42:7,15,17 43:19 44:11 45:5,13 47:19 48:20,25 49:4 49:17 carrie 1:17 3:4 4:5 5:15 case 1:9 cause 36:10 51:14 caused 37:13,16 37:23,25 38:7 38:12,16,17 causes 21:23 causing 43:19 44:11 ceflawyers 2:16 cell 29:15,17,20 center 1:18 2:13 certificate 51:1 certification WARD, CARRIE December 19, 2017 Page 53 11:9,14,18 certifications 10:20 11:24 certify 51:6 change 30:9 changes 10:23 charles 6:7,9,11 6:13,16 chart 4:23 check 33:15 39:20 48:1 checked 14:10 19:18,23 20:3 20:3 49:5,5,6 checks 35:22 circuit 1:2 city 23:21 class 7:20 cleaned 41:1,3 clear 38:18 clue 34:11 collins 2:12 com 2:8,16 combination 29:2 combo 27:24 28:6 combustion 20:11 come 11:14,15 17:13 31:16,25 32:9,11 37:1 37:12 38:7 41:4 42:14,21 43:1,3 45:17 comes 20:7 41:7 commencing 1:20 commission 51:25 company 11:5 30:1,4,13,14 31:16 34:12 35:2,6,9,10,13 35:15 compensation 10:24 compensations 10:22 complain 40:20 completing 12:11 complex 17:1 computer 21:3,5 21:9 51:10 concluded 50:18 conclusion 13:7 36:14 37:13 38:8 42:15,21 44:23 condos 28:9 consumers 14:21 16:17,25 17:2,16,19 18:17,25 19:2 19:6,10 20:3 22:9,18 36:9 36:14 37:7,9 39:14,18 43:2 45:23 46:3,8 46:16,20 49:13 contact 31:16,19 32:11 34:16 contacted 16:18 contacts 32:2,7 contents 3:1 contract 9:18,18 contractor 32:11,12 41:9 cooking 13:16 23:14 29:11 32:19,19 46:5 46:6,18 47:21 deal 29:8 dearborn 2:6 december 1:21 4:2 8:15 9:2 deep 48:7 defendant 13:3 37:18 defendants 1:13 2:17 department 13:25 14:5 15:8 16:11 20:2 39:13 45:23 46:3,16 48:19,24 49:16 deposition 1:17 3:14,15 4:17 12:14,19 16:6 21:16 24:25 50:18 51:7 detailed 32:21 32:23,24 details 31:4,23 detect 14:1 detector 13:17 14:6,14,20 23:11 27:24,25 D 28:2,3,6,24,24 daily 10:25 36:21 38:12,13 date 10:19 13:16 38:16 41:1 29:23 51:7 42:17 47:19 dated 25:3 49:5 davenport 7:9 detectors 23:17 8:14 25:5,16,23 day 15:1,4,20 26:4 27:22 17:17,18,19,20 40:21 17:24 18:4,18 determine 14:17 38:22,25 cooperative 1:11 35:2 copy 36:23 37:8 correct 20:14 45:4 51:11 correctly 44:10 cost 29:7 33:2 cosumers 13:8,8 14:1 couldnt 14:1,7 14:10,17 30:22 36:12 counsel 12:18 50:20 51:13 counter 39:2 county 1:2 51:4 51:24 course 21:6 court 1:2 cover 7:23 8:3 covered 6:18 8:1 credit 12:3 criminals 12:3 crock 39:3,4 csr3406 1:22 51:22 currently 5:5 cut 35:22 20:4 32:14,25 36:12 determined 14:21 device 20:11 dhs 12:1 diagnose 32:14 didnt 9:25 13:14 15:18 20:19 25:17,23,24 26:9,10,18 35:1 36:6 38:13,19 39:11 43:4 45:3 47:17 48:1 49:8,9 different 15:25 33:20 direct 16:11 directory 21:9 discovered 37:14 dissipated 36:21 dissipates 14:13 distinction 17:23 document 16:10 16:20,21 37:6 documentations 11:11 doesnt 19:3 doing 18:10 20:24 30:23 49:10 dominique 1:6,7 dont 4:13 6:24 6:25 9:1 13:2 17:6,19 18:1 19:13 20:22 21:21 22:12,16 WARD, CARRIE December 19, 2017 Page 54 31:3,6 32:8 33:19 34:1,9 35:21 36:23 37:22 38:14,24 39:25 43:16 44:5,6 48:7,7 dorothy 1:4 13:6 37:21 downstairs 19:25 draws 15:23 dryer 46:24 47:8 47:9,11,21 48:4,9,10 duct 46:25 47:14 due 41:24 44:24 duly 4:7 E earlier 13:20,22 26:21 early 38:24 educational 7:2 edwards 1:4,5 einhorn 2:12 either 41:7 44:6 49:24 51:13 electronic 35:18 elevated 13:4 14:8 15:15,19 17:3 37:19,23 38:1 43:19 44:11 eligibility 12:7 emersed 37:5 employee 41:6,7 employer 12:1 employment 11:24 ems 16:10 18:25 emt 15:18 energy 13:8 16:17 17:2,16 17:19 18:17,25 19:2,6,10 22:10,19 36:9 36:14 37:9 39:14 49:13 engine 16:24 entire 15:13 30:16 entry 35:24 estate 7:5,6,10 estimate 30:20 30:20 evacuated 15:5 eval 21:14 evening 14:18 36:19,23,24 38:13,22,24 43:2 event 51:13 everybody 11:21 25:13,22 26:9 26:18,20 evidence 38:25 examination 3:6 4:10 examined 4:9 example 8:5 excuse 22:24 28:10 exhaust 47:2,14 47:16 exhibit 3:11,14 3:15 16:6,9,19 24:25 25:6 exhibits 3:9,12 expert 20:15 21:21 expires 51:25 explaining 20:14 exterior 46:25 first 4:7 13:24 13:25 14:11 16:18 19:20 23:15 37:13 38:10,15 42:1 F five 10:9 42:10 facilities 26:3 47:4 facility 12:9 fix 44:15,16,18 25:13 30:16 45:14 fact 31:22 floor 1:18 fair 8:13 37:11 follows 4:9 family 14:19,23 foregoing 51:8 15:5 38:21 form 15:23 fans 5:18 43:21 44:22 farrell 2:12 forth 51:8 fault 44:25 45:2 found 17:2 37:4 faulty 41:1 40:23 46:21 fifty 30:21 foundation figure 36:15 48:22 figured 23:6 four 9:3,3,4 file 33:7 34:5,6,7 14:15 42:12 34:14 49:25 franklin 5:5,8 50:4,6,8,11,14 freezer 48:8 files 10:19 11:16 frequently 30:6 financials 7:24 friend 1:6 find 14:7 19:17 front 45:8 37:1 45:15,16 full 51:11 45:17,21,24,25 fumes 18:11 46:4,17 49:8,9 20:12,13 finding 34:14 G fine 4:22 16:3,4 gas 14:11 21:23 finish 25:25 gather 12:12 39:20 generally 7:23 finished 25:25 31:16,19 32:8 26:14,23 32:19,21 fire 13:25 14:5 getting 7:17 15:8 16:11 27:22 20:2 39:13 45:23 46:3,16 gillis 1:10 48:19,24 49:16 give 16:13 18:22 32:21 33:12 36:16 44:7 given 44:9,12 go 8:16,20 19:22 22:17 25:8 33:17 38:12,16 38:17,19 39:6 46:15,23 goes 7:24 going 4:12 5:15 14:12 15:22 16:11 23:9 32:10 40:21 41:7 44:7 46:25 good 38:19 graduated 8:15 8:16 10:6,7 greenfield 2:5 group 8:21,23 9:8,14 10:11 guess 30:22 guys 39:10 H hakala 2:3 3:7 4:11,12 5:20 7:1 14:3 16:1,4 16:8 25:2,21 43:22 45:1 46:14 48:18,23 50:16 half 27:10 halfway 16:15 hand 16:19 handful 42:12 handheld 38:17 42:18 happened 5:24 13:10,11 15:5 WARD, CARRIE December 19, 2017 Page 55 36:17,22 40:23 41:11,16 happens 22:9 41:3 hard 28:1,2,5,14 29:2 havent 6:18 heat 32:8 heater 40:1,8,14 48:11 heaters 41:23 heating 43:11 help 18:20 helped 39:6 hereinbefore 51:8 hereto 50:20 hickory 1:11 25:4 30:4 31:9 31:10 40:8,18 41:6 43:18 high 14:10 20:5 higher 22:3 hit 14:24 hold 13:1 38:15 hollow 1:11 25:4 30:4 40:9,18 41:6 43:18 home 9:23 14:18 15:6,8 18:12 19:15 20:5,18 20:20 26:10 28:21 32:2 44:10 45:13 46:25 homeowner 22:24 homes 23:18,22 24:4,13 28:10 50:6 hon 1:10 hose 46:25 47:2 hot 14:7 19:16 48:10 49:6 hour 18:3 hours 49:19 house 18:8 household 10:21 10:24 houses 27:17 hud 11:6 12:9 hundred 30:21 huntington 1:12 8:22,25 9:16 9:19 10:12,13 hurt 44:20 hvac 35:9 41:4,9 42:20 hypothetical 44:7 hypothetically 44:14 44:17 48:21 49:21 imagine 7:19 imply 21:21 incidences 42:14 incident 5:24 6:15,18,20 13:11,14,24,25 15:2,20 22:9 23:15 24:5,17 29:11 37:13,15 41:18,23 42:3 43:3 46:17,20 47:22 incidents 40:17 income 10:21 incorporated 33:7 indicate 17:8 indicates 13:1 information 38:7 initial 31:20 I 36:20 idea 17:13 21:4 initiative 24:3 22:3 34:10 24:12 42:12 43:10 inspected 14:6 identification 15:8 28:21 16:5 24:24 inspection 15:1 identified 17:4 21:7,13 24:16 im 4:12,20 5:12 24:18,21,22 6:21 9:8,12,13 26:1 28:23 15:22 16:11,14 inspections 8:2 18:1 20:15,24 11:4,5,6,7 22:1,20,23 20:24 24:8,10 23:7 26:2 26:15,24 27:3 30:19 33:18,20 28:15,20 29:19 33:20 37:7,10 install 8:5,8 37:16 40:2,16 31:17 40:6 41:12,17 44:7 47:9,10 installed 13:17 23:13,23 24:2 24:3,12 25:24 26:12,13 38:14 39:22 40:5,8 44:10 46:23 47:2,7,8,12,18 47:19 48:6 intake 11:9,14 11:18 interact 18:17 interested 51:13 interim 10:23 interrogatories 12:12,23 37:18 interrogatory 29:25 investigation 13:9 invoice 31:22 33:16,23 35:17 35:17,21 invoiced 33:21 34:2 invoices 33:12 35:18 involved 7:17 12:11 involvement 31:15 irem 7:5,10,13 7:15 isolate 16:24 issue 32:7 37:2,4 43:11 44:16,19 issues 41:14 items 14:24 41:22 J jhakala 2:8 job 9:18 31:5 john 1:10 joslin 2:11,16 5:15,18 6:24 13:24 15:22 16:2 19:13 25:19 43:21 44:22 46:11 48:16,22 50:17 jr 1:10 2:11 jump 26:13,23 jumped 27:1 june 51:25 justin 2:3 4:12 K keep 5:16 kept 33:23 34:3 kevin 5:13,22 39:16,17 kicks 20:11 kind 8:1 24:1 knew 23:4 knocked 27:2 know 4:14 7:22 16:23 17:6 18:1,10,13 19:3 20:16,25 22:15,17,19,21 23:8 25:8 27:12 29:6,7 29:23,23 30:25 31:3,6 35:5,7 35:11 36:13 37:22 38:14,24 39:22,25 40:3 40:11,13 42:2 42:7 43:8,12 44:3,5,6 45:3,6 WARD, CARRIE December 19, 2017 Page 56 47:17,21 48:7 longer 30:13 48:7 34:11 knowledge 31:4 look 16:22 19:13 33:13 48:13,24 25:8 27:7 kristina 5:11 32:12,23 33:17 49:3,17 50:8 L looked 21:18 landlord 12:2 28:23 44:16,18 looking 48:19,24 landlords 44:24 lost 10:4 leak 48:25 49:17 lot 27:21 29:20 leaking 47:17 M leaks 47:16 49:7 lease 10:20 maam 4:12 leasing 7:24 13:23 16:20 leave 9:17 18:1 left 10:8,10 17:1 machine 47:10 34:13 maintain 12:6 legal 44:23 maintenance 5:2 letter 25:3,9,11 5:14,23 6:1 26:2,6,9 27:22 7:25 8:1,3 levels 13:5 14:8 10:18 22:21,23 14:10,11,18 32:5,9 35:8 15:15,19 19:17 39:6 19:19,24,24,25 making 10:18 20:1,5 37:19 17:23 37:23 38:1 malfunctioning 43:20 44:11 14:22 45:6,8,10,13 management license 7:5,12 1:12 7:6,10,16 licensed 45:17 7:22,24 8:22 liggins 6:7,7 17:1 line 16:15 manager 5:2,10 listen 19:14 6:19 7:7 10:15 little 4:17 5:16 10:16,17 11:8 33:20 11:9 31:6,7 logo 25:4 33:24 34:3,11 long 5:6,8,21 6:8 34:13,13 8:18,23 49:16 managers 5:4 49:21 mandated 23:22 mark 16:4,9 marked 16:5 24:24 25:3 marketing 7:4 matched 28:1 matter 19:3 21:6 mckinley 8:17 9:13,24,25 10:3,7,8,10 mean 16:2 21:21 23:2,23 24:9 24:20 28:20 31:10 43:25 44:5,6 meaning 8:8 32:1 means 44:3 measurements 39:7 mechanic 30:2 mechanical 8:7 30:2,3,18 31:8 33:10,18,21 34:2,7,16 35:14,20,23 36:2,4 member 10:19 11:25 22:23,24 32:5,7 members 6:17 10:21,25 11:10 11:12,15,17 12:7 memory 19:4 30:23 mentioned 16:23 meter 23:9,12 23:14 metro 8:21,23 9:8,14,17,22 10:11 meyers 2:4 michigan 1:1,19 2:6,14 4:1 30:1 30:2,17 31:8 33:9,18,21 34:2,7,16 35:14,20,22 36:2,3 51:2,24 middle 27:11 miller 6:7 39:10 million 15:16,16 16:16,17 45:9 minor 1:7 minutes 47:4 49:22 mislead 18:1 misquote 13:2 mixed 27:18 monitor 16:15 monoxide 13:4 13:17,20 14:5 14:18 15:15,20 17:4,13 19:17 19:23 20:6 21:21,24 22:3 22:5 23:11,12 23:14,17 25:5 25:15,16,23 26:4 27:21,23 27:25 28:3,6 28:24 36:10 37:5,19 38:12 38:16 39:7 40:17,20,24 41:1,14,24 42:8,15,17 43:19 44:11 45:5,13 47:19 48:20,25 49:4 49:17 month 8:24 11:10 13:12,15 13:20,22 22:9 37:1 38:1 46:7 months 21:19 46:2 morgan 2:4 morganmeyers 2:8 morning 17:11 17:20,23 18:19 18:20 19:5,7 38:23,24 39:1 39:16 46:17 mortgage 11:5,5 11:6 N name 4:12 5:4 5:11 25:5 names 6:6 narrative 16:12 16:22 natural 21:23 need 7:21 needed 40:25 needs 11:5 31:25 32:15 41:2 neglect 44:24 new 11:20,22 14:23 23:12 31:17 newer 23:21 newly 26:3,10 night 13:10,14 nodding 48:14 normal 19:24,25 20:1 WARD, CARRIE December 19, 2017 Page 57 notary 51:1,23 notes 39:20 51:12 november 25:3 number 13:1 37:17 38:5 50:13,16 old 11:22 31:17 once 14:13 28:7 30:23 ongoing 11:20 24:1 open 18:6 49:11 O 49:12 object 15:22 operating 47:21 43:21 44:22 opportunity objection 13:3 4:16 observe 47:16 opposed 50:6 observed 47:11 order 8:2 11:13 47:14 31:21 occurred 15:4 ordered 14:22 office 5:1,4,10 29:9 46:22 6:19 10:18 orders 11:2 11:8,9,15 21:2 ordinance 23:21 29:15,19 32:16 organization 32:17 4:23 offices 21:3 original 13:10 oh 11:3 31:1 okay 4:16 5:1,10 originally 32:24 5:13,23 6:1,14 38:4 6:17 7:2 8:1,7 originated 13:6 8:13 9:1,19 13:20 37:20 10:9,13 11:3 overhead 42:19 11:18 12:25 42:20 13:13 14:24 oversee 10:17 15:7,12 18:4 P 19:10 20:16 page 3:3,11 21:20 22:24 16:12,22 23:8 24:11 paper 31:20 25:3 29:18 35:21 30:9 31:18,24 33:25 34:8,19 paramedics 19:8 part 26:12,16,22 36:1 37:1,17 26:25 28:13,15 38:20 42:21 28:23 44:20 46:5,19 parties 50:20 48:5 49:3 parts 15:15,16 16:16,17 45:9 party 51:13 patterson 12:20 pattersons 4:17 payments 11:12 people 6:1 27:21 period 6:21 9:11 perplexed 14:16 person 5:23 39:6 perspective 44:15 phase 27:1,1,6 27:10,12,16,16 phases 27:8,15 phone 29:16,17 29:20 phones 11:15 photo 36:5,6 photos 21:13 29:12,18 pictures 22:14 place 6:8 49:24 placed 28:9 places 23:24 25:15,23 plaintiff 13:5 37:20 plaintiffs 1:8 2:9 plc 2:4 please 4:14 plug 39:4 point 49:10 pointing 12:23 portion 15:10 16:14,14 position 5:8 10:14 possibly 18:11 pot 39:3,4 potential 21:23 precaution 47:3 prefer 30:13 prepared 25:11 present 22:10 presumably 36:7 pretty 7:21 32:24 previously 49:4 probably 5:15 19:3 20:14 21:2,5 49:21 problem 14:25 42:16 process 4:19 7:18,20 8:2 11:10,14,17,18 12:3,6 24:1 31:24 processed 12:5 processes 11:13 produce 21:24 professional 45:17 professionals 45:21 properly 47:2 47:18,20 properties 8:17 property 7:7,22 8:2,21,23 9:8 9:14 10:11,16 10:18 26:13,16 26:22,25 31:11 public 51:23 pull 29:15 purchased 47:1 purpose 18:10 21:15 put 28:7 34:4,5 35:19 45:8 Q question 13:11 19:14 33:20 34:17 37:17 38:4 46:9,12 questions 4:13 4:14 51:8 quote 32:16 R reach 32:15 reached 34:24 read 16:13 38:19 reading 14:13 readings 14:16 15:13 20:4,19 39:11 reads 16:24 real 7:4,5,10 reason 44:10 recalculate 10:21 recall 6:19 22:12 22:16 23:2 36:19 39:15 recognize 25:9 record 34:24 35:20 43:14 recorded 51:9 records 23:6 34:1 reduced 51:10 reed 1:4 13:6 37:21 38:21 reeds 28:4 34:6 39:23 42:25 WARD, CARRIE December 19, 2017 Page 58 45:19 49:24 referring 15:23 15:24,24 16:14 reflect 36:25 refurbished 23:21,24 26:3 26:10 27:17 28:9,10,11 regarding 25:5 regardless 48:6 related 42:7 51:12 released 20:12 releases 20:13 relying 38:3,5 remarks 16:12 remember 6:11 6:24,25 9:1 23:4 39:17 43:16 remind 4:19 remove 31:17 removed 45:25 46:22 47:1 renewals 10:20 replace 32:22 35:15 41:13,22 replaced 14:23 29:22,24 30:17 30:25 31:1,12 31:15,25 32:15 32:20 33:2 35:6,11,16 42:3,4,6 46:1 replacement 31:7 32:17,18 32:21 33:17 46:22 replacements 30:7 report 17:4,6,8 18:24,25 19:1 19:2,13 32:22 32:23 36:16,23 37:7,9 45:8 49:25 reported 13:5 37:20 reports 15:18 representative 35:4 requested 50:19 required 11:7 11:11 residence 14:20 15:14 28:4 34:6 42:25 45:20 residential 7:16 10:15,16,17 residents 11:20 respect 44:4 respective 50:20 respond 16:18 responses 30:1 responsibility 44:14,18,21 responsible 43:18,24 44:1 44:2,3,4,16 rest 26:14,23 27:3 28:16 result 44:20 retrieve 34:24 review 11:16 12:4,14,16 16:13 reviewed 21:15 reviewing 23:6 richard 2:11,16 seeing 29:25 seen 16:19,21 33:9 send 12:1 25:22 26:9,18,25 sense 44:8 sent 25:13 26:6 26:12,20,22 27:1,16 service 11:2,13 40:11,13 41:4 services 10:24 11:1 30:12 set 51:8 seven 6:10 shake 38:18 sharon 1:22 51:6,22 S sheet 16:10 safe 45:6 shenelle 1:5,7 satisfied 30:12 showed 16:16 save 21:6,9 shows 35:20 saved 21:12 side 8:8 saw 15:15 32:25 signature 50:19 36:5 46:24 similar 33:10 47:12,18 sims 5:13,21 saying 11:3 39:16,17 says 13:3 35:16 sir 12:24 15:11 36:2,3,16 25:20 37:17,18 43:16 siren 19:20 scene 16:18 17:1 sit 4:16 37:22 17:1 39:9 site 35:10 schedule 32:18 situation 28:5 second 16:22 six 7:20 22:18 37:14 smaller 27:12 see 6:23 10:5 smell 23:9 11:3 15:16,18 smoke 27:23 19:19 28:24 28:2,6,24 32:9,13 38:25 soft 5:17 41:7 44:8 49:6 somebody 28:23 rid 45:15 right 5:12 7:15 12:11,25 13:2 13:9 14:4,9 16:9 20:3 21:20 24:17 26:4 27:11 32:3 39:20 44:7 45:3,19 46:6 road 36:13 robert 1:4 role 5:21,22 roughly 4:24 27:10 41:11 rude 4:21 run 16:10 32:2 36:17 44:1,20 sons 30:15 41:8 41:9 42:23,25 45:24 46:2,5 49:23 50:4,12 50:14 sorry 5:12,17 9:8,12,13 22:1 34:18 44:17 48:21 sound 17:25 sounds 37:12 source 16:24 17:2,6 22:5 45:15,15,16,18 45:21,25,25 46:1,1,4,18,21 46:22 48:19,25 sources 40:24 southfield 1:19 2:14 4:1 spare 4:19 specific 29:23 34:6 50:6 split 27:11 spring 24:23 26:1 28:16 ss 51:3 staff 5:2 6:17 22:21,23 32:5 35:8 standpoint 32:1 start 8:25 10:13 26:13,23 started 9:12,15 9:22 36:13 starts 16:15 state 1:1 51:2 stated 38:9 49:4 WARD, CARRIE December 19, 2017 Page 59 states 13:4 37:19 stating 32:7 stay 46:9 stayed 49:16 stays 29:15 stenographic 51:11 stenographica... 51:9 step 46:23 steven 6:7,9,16 39:10 stop 30:11 stove 13:1,6,15 13:21 14:10,11 14:22,23 17:9 17:11,14 19:18 19:21 22:4,7 36:11,20 37:2 37:4,13,21,22 37:25 38:15 46:21 47:12 49:6 straight 10:7 strike 37:11 38:3 40:12 42:1 success 16:25 suite 2:5,13 32:1 summary 33:10 supervisor 5:14 sure 6:21 10:18 12:4 22:18,20 22:23 23:7 30:19 33:18 37:8,10,16 40:2 41:12,17 49:21 sworn 4:7 system 35:18,19 T table 3:1 tag 35:14,16 36:3 take 7:2,20 9:3 16:22 25:8 29:12,18 32:12 36:5,6 39:7,11 50:8,8 taken 1:18 11:11 51:7,12 talk 5:17 12:21 35:3 talked 12:18 talking 15:1 42:18,19 tank 14:7 19:17 49:6 taped 46:25 47:14 teaches 7:21 tech 42:21 technician 41:4 42:20 tedious 7:18 tell 11:23 13:19 19:10 20:9 36:9 47:6 ten 30:21,21 tenants 45:2 tested 19:16 testified 4:9 testify 4:7 testimony 19:6 thanksgiving 36:11 thats 4:22 5:13 12:9,25 14:14 16:3,4 18:4,25 20:13,16 25:3 29:19 31:23 33:3 34:19 35:6,8,13,13 35:14,14,24 36:22 37:24 41:16 44:14 50:16,17 thing 36:19,22 38:10 39:2 49:13 think 5:11 7:15 9:1 13:16 15:24 16:14 21:14 27:1 29:8 30:17 41:2,11,16 43:6 49:16,20 third 16:15 thought 18:22 26:20 three 14:15 42:12 time 6:14,17,19 6:21 9:11 14:14 17:21 18:2,2,22,24 19:4,8 20:22 21:18 22:18 23:5 25:16 26:2,6 28:10 34:3 44:12 timeline 10:4 times 14:15 29:20 41:11,16 49:23 today 4:13 12:14 12:19 20:25 37:22 told 10:3 17:11 26:2,20 35:1,8 46:2 47:5 top 15:8 25:4 topics 8:1 total 27:4 town 1:18 2:13 23:17 26:10 27:17 28:10,21 32:2 44:9 45:13 50:6 townhouse 39:23 transcript 3:12 51:11 transcription 51:10 tried 16:24 34:20,21 troubleshoot 32:10,13 truck 17:2 true 4:17 17:4,5 17:7 22:7,8 26:6 37:23,24 44:14 48:20 49:1,13 51:11 truth 4:7,8,8 try 32:12 33:1 34:23 45:21 trying 4:20 17:25 18:1 36:15 46:11 tuesday 1:21 4:2 turn 14:12 turned 19:19,20 19:21,22 36:20 38:10,15 two 6:5,6,8,14 27:15 42:12 49:19 U uhhuh 15:3 21:25 25:7,18 26:5 28:17 32:4 33:4,22 44:13 50:1 understand 4:13 17:16 22:18 29:25 46:10 understanding 4:24 20:6,9,10 20:17 21:20 29:21 37:25 45:5,10 unit 13:6 29:22 31:2 37:21 39:4,7,9,19 41:5 42:19,20 units 27:4 28:7 29:3 university 7:9 unsafe 45:6,10 45:12 unsuccessful 34:25 upgraded 27:25 28:13 29:2 upkeep 8:2 upstairs 16:17 19:18,23 22:4 use 13:14 17:14 29:5,14,19,20 30:7,14 33:19 V vacancy 6:13,20 vacated 43:7 vent 46:24 ventilated 18:8 verbally 4:20 WARD, CARRIE December 19, 2017 Page 60 verifications 12:2 verified 12:1 video 21:14,18 29:14 47:24 48:1 49:21 videoed 29:11 49:20 videotape 20:21 20:23,24,25 21:6,7,12,15 videotaped 20:19 22:13 voice 5:16 vs 1:9 17:20 33:24 48:2,3 water 14:7 19:16 40:1,7 40:14 41:23 48:11 49:6 way 17:25 20:14 34:14 43:25 44:8 wayne 1:2 51:4 51:24 week 7:20 weeks 13:12,15 14:19 24:20 went 4:23 10:7 10:11,12 13:17 W 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