Electrolux Home Prod v. Whitesell Corp

Filing 876

ORDER that, upon the foregoing, Plaintiff Whitesell Corporation's objections to Defendants' Third Requests for Production, which are appended hereto as Exhibit A, are hereby SUSTAINED IN PART as more particularly delineated in this Order. Signed by Judge J. Randal Hall on 1/10/2017. (jah)

IN THE

UNITED

STATES

DISTRICT

SOUTHERN DISTRICT

OF

COURT

FOR THE

GEORGIA

AUGUSTA DIVISION

WHITESELL CORPORATION,

*
*

Plaintiff,

*
*

v.

*

ELECTROLUX HOME PRODUCTS,

103-050

*

INC.,

CV

*

HUSQVARNA,

A.B.,

and

HUSQVARNA OUTDOOR PRODUCTS,
INC.,

*
*
*

Defendants.

*

ORDER

During the monthly discovery hearing on December 5, 2016,

Plaintiff

Whitesell

Corporation

objections to Defendants'
Documents.1

The

Court

("Whitesell")

raised

Third Request for Production of

heard oral

argument

on

the

issues

presented by the requests arid deferred ruling until this
written Order.

The

objected-to

categories.

The

requests

may

first category

be

grouped

(RFP Nos.

1-4)

into

two

requests

documents including deposition transcripts and declarations of
former

and

current

Whitesell

employees,

expert-related

material, and trial exhibits from unrelated cases in which

1 Whitesell's "Objections to Defendants' Third Request
for Production of Documents" is appended hereto as Exhibit A.

Whitesell

sought

damages

against

third-party

customers

or

suppliers since 2001, including but not limited to the case of

Whitesell
case")

Corporation v.

Whirlpool

Corporation

in the Western District of Michigan.

refer to this category as

("Whirlpool

The Court will

"Damages Testimony."

The second

category (RFP Nos. 6-8) requests the ISO and QS9002 or similar
certificates and "related documentation"

received by any of

Whitesell's manufacturing facilities and all third-party sub-

suppliers

for

Parts

in

Suit

for

the

period

2001-2013.

Defendants also request "all written policies, procedures and

quality manuals reviewed and/or approved in connection with
the ISO and QS900 certificates."

The Court will refer to this

category as "Quality Certifications."

Damacres Testimony

Defendants

contend

that

Damages

cases is highly relevant to this case.

Testimony

from

other

Defendants first point

out that the Whirlpool case is very similar.

In that case,

Whitesell sought damages against Whirlpool, one of Defendants'

major competitors, related to Whitesell's supply of similar
fasteners to Whirlpool during a similar damages period.

fact,

Whitesell

2

The

made

reference

similar

to

"QS900"

allegations

in

the

In

concerning

Requests

for

Production may be a typographical error since the Supply
Agreement and the parties at oral argument referred to
"QS9000."

Whirlpool's

intent

to

breach

their

supply

agreement.

Defendants have obtained trial transcripts in the Whirlpool
case

which

contain

statements

related

to

Whitesell's

production capabilities and profit margins on its fasteners as

well as in the fastener industry in general.

Defendants argue

that the requested additional documents are necessary to test
the assertions in this case respecting production capability

and product costs.3
In response, Whitesell asserts that Defendants' requests

are "clearly irrelevant" and have "no bearing" on the issues
in this case.

conclusion.

The Court,

however,

does not reach this same

Defendants may be able

In fact,

to

show that

Damages Testimony in the Whirlpool case directly bears upon
the issues in this case.

For instance, the Court is swayed by

Defendants' contention that if Whitesell, through its experts

or otherwise, apportions its overhead and expense costs across

all of

its

clients,

then testimony about

apportionment

of

those same or shared costs to Whirlpool is relevant to any

3

Because Defendants focused on drawing similarities to

the Whirlpool case
Defendants

about

at oral argument,
the

actual

breadth

the Court questioned
of

their

requests.

Defendants replied that their requests
for production
encompass any case in which Whitesell's representatives
testified with respect to a damages claim made by Whitesell
against other customers or suppliers.
Defendants stated,
however, that if they had to narrow their requests to the

Whirlpool case, they would do so.

Later in the proceeding,

Defendants returned their focus exclusively to the Whirlpool
case.

apportionment

in

this

case

Nevertheless,

Defendants

during

the

same

can only speculate,

time period.
no matter how

reasoned and despite the representations of counsel at other

hearings, as to what Whitesell's experts will do in this case.
As yet,

there are no expert reports;

thus,

it remains to be

seen how the experts will calculate the profit margins in this
case,

among other things,

and upon what evidence they will

rely.

In short,

premature.

Defendants'

request for Damages Testimony is

Upon further development of

the record through

fact depositions and expert witness discovery, Defendants may
be

able

to

materials

margins.

establish

to

the

the

issues

relevance

of

of product

Whirlpool

case

capability and profit

Until that time, and without prejudice to Defendants

to re-urge the matter,

Whitesell's objections to the request

for Damages Testimony are sustained.

preclude

the

Defendants

deposition

about

from

their

inquiring
testimony

This ruling does not

of
or

fact

witnesses

involvement

at

in

the

that the Quality Certifications

are

Whirlpool case.

Quality Certifications

Defendants
relevant

argue

to their defense

that

their

failure

to

transition

certain parts (particularly the Brunner parts) was largely due

to Whitesell's
parts

that met

inability to produce qualified parts,
the

qualification

standards.

i.e.,

In response,

Whitesell agreed to produce its Quality Certifications for its
manufacturing
"related

facilities

documentation"

from
or

2001

the

to

2013,

policies,

but

not

the

procedures

and

quality manuals reviewed and/or approved in connection with
Quality Certifications,

on the basis that the requests are

overbroad and irrelevant to any claim or defense in the case.4
In the Supply Agreement between the parties,
makes

certain

quality

commitments.

As

those

Whitesell

commitments

relate to the Quality Certifications, Whitesell commits
[t]o maintain inspection documents and certificates
of conformance, upon request to allow for review,
for any article/shipment, shipped, as requested by
each Electrolux
location.
Since
Whitesell
is
ISO9002 and OS9000 certified, if it maintains its
certifications in good standing it shall therefore
be deemed to have met an even higher manufacturing

standard and shall constitute full
compliance
without further need or audit by Electrolux.

(Supply Agreement, t 12.3 (emphasis added).)

By its terms

then, Whitesell's commitment to Defendants with respect to the

Quality Certifications is met if Whitesell maintained its

4 Whitesell also points out that the written policies,
procedures and quality manuals prior to 2006 are unorganized
and are not in digital format; therefore, it would be unduly
burdensome to produce these documents.
The Court will not
find that having to examine hard copies of documents is per se
unduly burdensome. Indeed, that is how discovery occurred for
decades before the digital age, and it remains a party's

responsibility to produce relevant and responsive documents in
this manner unless there is a sufficient showing of burden.

Quality Certifications in good standing.

Stated another way,

the only relevant issue created by the Supply Agreement is
whether Whitesell maintained its Quality Certifications.
Defendants contend that the supporting documentation and

information underlying the Quality Certifications will inform
the inquiry into whether Whitesell was capable of producing

qualified parts.

However, the Quality Certifications are not

issued on a part-by-part basis; they do not pertain to any one
part or even category of parts.
that

a

manufacturing

producing

a

facility

qualified

part.

Thus,
is

or

they do not signify
is

not

Rather,

capable

the

of

Quality

Certifications are issued to a facility upon review of that

facility's overarching quality management system.
Certifications

ensure

efficient,

quality management and control;

facility can

or will

meet

qualification standards.

consistent,

The Quality

and

effective

they do not ensure that a

a particular part's

design and

The Court agrees with Whitesell that

the question of whether it was capable of producing qualified
parts instead involves the Production Part Approval Process or
PPAP, which ensures that a component part supplier can design

and

produce

an

individual

requirements for the part.

part

according

to

the

quality

In short;, Defendants have failed

to establish that the process by which Whitesell obtained the

Quality Certifications is relevant to their claims involving
the quality of individual parts.
Upon the foregoing, Whitesell's objections to RFP Nos. 68

are

sustained

response
and/or

except

to Request

QS9000

manufacturing

or

for

that

Production Nos.

similar

facilities,

Whitesell

shall

6

certifications

both domestic

and

for

and

produce

(in

7)

all

ISO

each

of

its

international,

that supplied Parts in Suit to Defendants for the period of
2001

to

2013.

Conclusion

Upon the foregoing, Whitesell's objections to Defendants'
Third Requests for Production are hereby SUSTAINED IN PART as

more particularly delineated in this Order.

ORDER ENTERED at Augusta, Georgia, this
January,

Id ^Cday of

2 017.

HONQRAgME J.

RANDAL HALL

UNITED^TATES DISTRICT JUDGE
SOUTHERN DISTRICT OF GEORGIA

IN THE UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF GEORGIA
AUGUSTA DIVISION

WHITESELL CORPORATION,
Plaintiff,
CASE NO. 1:03-cv-00050-JRH

v.

ELECTROLUX HOME PRODUCTS, INC.,
HUSQVARNA A.B. and HUSQVARNA
OUTDOOR PRODUCTS, INC.,
Defendants.

WHITESELL CORPORATION'S OBJECTIONS TO DEFENDANTS'

THIRD REQUEST FOR PRODUCTION OF DOCUMENTS

Plaintiff, WHITESELL CORPORATION ("Whitesell"), through its counsel, and pursuant

to Fed. R. Civ. P. 26 and 34, hereby serves its Objections to the Defendants' Third1 Request for
Production of Documents served by Defendants, ELECTROLUX HOME PRODUCTS, INC.

("EHP") and HUSQVARNA HOME PRODUCTS, INC. ("HOPI") (collectively, "Defendants").
REQUESTS FOR PRODUCTION

1.

Please produce any and all deposition transcripts, including videotaped copies of

all depositions, and related exhibits of Whitesell current and former employees, including
corporate designees testifying pursuant to Rule 30(b)(6), in cases against customers or suppliers
in which Whitesell sought damages since 2001, including but not limited to, Whitesell Corporation
v. Whirlpool Corporation, No. 1:05-cv-00679 (W.D. Mich. 2005).

The Third Request for Production of Documents is actually the Defendants' fifth Request for Production.

Exhibit A

CASE NO. 1:03-cv-00050-JRH

RESPONSE:

Whitesell objects to this Request as overbroad, harassing, irrelevant to any party's
claim or defense, and not proportional to the needs of this case. This Request fails to
identifyany specific subject area of interest to the Defendants or in any way related
to this case, and amounts to a classic fishing expedition that seeks information which
is irrelevant and not reasonably calculated to lead to the discovery of admissible
evidence. Accordingly, the Request places a burden on Whitesell that is
disproportionate to any benefit the discovery might provide to Defendants.

Whitesell believes that Defendants may be seeking information about Whitesell's use

of theTOOLS and IFS systems referenced inWhitesell's 30(b)(6) deposition taken on

January 14,2016 and its inability to provide per-part cost data for the Parts in Suit.
AH available information has previously been provided in Whitesell's priordiscovery

responses and, in thecase of per-part cost data, Whitesell has repeatedly explained to
Defendants and to the Court via on the record statements through counsel that such

per part cost data does not exist. Accordingly, the request is unreasonably cumulative
orduplicative to Whitesell's prior discovery and other responses on those issues.
Notwithstanding Whitesell's prior objections, if Defendants narrow the Request to
seek information concerning the use orfunctioning ofthe TOOLS and IFS systems in
connection with the Parts in Suit, Whitesell will agree to search for and produce any
responsive documents not previously produced.

2. Please produce any and all declarations submitted by Whitesell current and former

employees in cases against customers or suppliers in which Whitesell sought damages since 2001,
including but not limited to, Whitesell Corporation v. Whirlpool Corporation, No. 1:05-cv-00679
(W.D.Mich. 2005).
RESPONSE:

Whitesell objects to this Request as overbroad, harassing, irrelevant to any party's

claim or defense, and not proportional to the needs ofthis case. This Request fails to

identify any specific subject area ofinterest to the; Defendants or in any way related

to this case, and amounts to aclassic fishing expedition that seeks information which

is irrelevant and not reasonably calculated to lead to the discovery of admissible

evidence. Accordingly, the Request places a burden on Whitesell that ««
disproportionate to any benefit the discovery might provide to Defendants.

is

2

KUUCBK, KAPLAN, S.LVURMAN. KAT7.I5N &UiVIKIi. P.L.- M.AM. C.iNW.H. 27TH R.OOR. 20! So. BlSCAWE BLVD.. M.AM.. Ft. 33131 •305.379.9000

CASE NO. 1:03-cv-00050-JRH

Whitesell believes that Defendants may be seeking information about Whitesell's use
of the TOOLS and IFS systems referenced in Whitesell's 30(b)(6) deposition taken on

January 14,2016 and its inability to provide a per-part cost data for the Parts in Suit.

All available information has previously been provided in Whitesell's prior discovery

responses and, in the case ofper-part cost data, Whitesell has repeatedly explained to
Defendants and to the Court via on the record statements through counsel that such
per part cost data does not exist.
Accordingly, the request is unreasonably
cumulative or duplicative to Whitesell's prior discovery and other responses on those
issues.

Notwithstanding Whitesell's prior objections, if Defendants narrow the Request to
seek information concerning the use or functioning oftheTOOLS and IFS systems in
connection with the Parts in Suit, Whitesell will agree to search for and produce any
responsive documents not previously produced.

3.

Please produce any and all deposition transcripts, including videotaped

copies of all depositions, and related exhibits of experts retained by Whitesell in cases against
customers or suppliers in which Whitesell sought damages since 2001, including but not limited

to, Whitesell Corporation v. Whirlpool Corporation, No. 1:05-cv-00679 (W.D.Mich. 2005).

RESPONSE:

Whitesell objects to this Request as overbroad, harassing, irrelevant to any party's
claim or defense, and not proportional to the needs of this case. This Request fails to
identify any specific subject area of interest to the Defendants or in any way related
to this case, and amounts to a classic fishing expedition that seeks information which

is irrelevant and not reasonably calculated to lead to the discovery of admissible
evidence.
Accordingly, the Request places a burden on Whitesell that is
disproportionate to any benefit the discovery might provide to Defendants.
Whitesell believes that Defendants may be seeking information about Whitesell's use
of the TOOLS and IFS systems referenced in Whitesell's 30(b)(6) deposition taken on
January 14,2016 and its inability to provide a per-part cost data for the Parts in Suit.
All available information has previously been provided in Whitesell's prior discovery
responses and, in the case of per-part cost data, Whitesell has repeatedly explained to
Defendants and to the Court via on the record statements through counsel that such
per part cost data does not exist. Accordingly, the request is unreasonably cumulative
or duplicative to Whitesell's prior discovery and other responses on those issues.

Notwithstanding Whitesell's prior objections, if Defendants narrow the Request to
seek information concerning the use or functioning of the TOOLS and IFS systems in

3

Kl.UGUR,KAPUK>SlLVER1MAK,KAT/XN &
LEVWE.P.L* MIAMI CENTER, 27tH FLOOR, 201 SO. BISCAYNBBLVD., MIAMI, FL 33131•305.379.9000

CASE NO. l:03-cv-00050-JRH

connection with the Parts in Suit, Whitesell will agree to search for and produce any
responsive documents not previously produced.
4.

Please produce any and all trial exhibits from Whitesell Corporation v.

Whirlpool Corporation, No. 1:05-cv-00679 (W.D.Mich. 2005).
RESPONSE:

Whitesell objects to this Request as overbroad, harassing, irrelevant to any party's
claim or defense, and not proportional to the needs of this case. This Request fails to
identify any specific subject area of interest to the Defendants or in any way related
to this case, and amounts to a classic fishing expedition that seeks information which
is irrelevant and not reasonably calculated to lead to the discovery of admissible
evidence. Accordingly, the Request places a burden on Whitesell that is
disproportionate to any benefit the discovery might provide to Defendants.

Whitesell believes that Defendants may be seeking information about Whitesell's use
of the TOOLS and IFS systems referenced in Whitesell's 30(b)(6) deposition taken on

January 14,2016 and its inability to provide a per-part cost data for theParts in Suit.
All available information has previously been provided in Whitesell's prior discovery

responses and, in the case of per-part cost data, Whitesell's has repeatedly explained
to Defendants and to the Court via on the record statements through counsel that

such per part cost data does not exist. Accordingly, the request is unreasonably
cumulative or duplicative to Whitesell's prior discovery and other responses on those
issues.

Notwithstanding Whitesell's prior objections, if Defendants narrow the Request to
seek information concerning the useor functioning of the TOOLS and IFS systems
in connection with the Parts in Suit, Whitesell will agree to search for and produce

any responsive documents not previously produced.

5.

Please produce any and all documents that have been obtained from third

parties related to this litigation.
RESPONSE:

Whitesell has received documents from Bamal and Martin. Whitesell understands

that such documents were provided to Mr. Sentell by Whitesell's prior counsel.
There are no other documents responsive to this request.

4

KLUGER, KAP1.AN. SILVERMAN, KAT7.EN &LEVIN!-:, P.L.* MIAMI CENTER, 27TH FLOOR, 201 So. BlSCAYNE BLVD., MIAMI, FL 33131 • 305.379.9000

CASE NO. l:03-cv-00050-JRH

6.

Please produce a copy ofall International Organization for Standardization

("ISO") certificates and related documentation received by any of Whitesell's manufacturing
plants and/or facilities, both domestic and international, as well as all third party sub-suppliers
used by Whitesell to supply Parts in Suit to Defendants for the period 2001-2013, including but
not limited to 9002 and 9001 certifications. This request includes documents indicating the name
of the registrar(s) issuing the certificate(s), the identity of the plant and/or facility to which the
certificate(s) relates, the effective dates of each such certification, all recertification audits that the

plant and/or facility underwent and the resultof such recertification audits(s).
RESPONSE:

The request for "all .

♦

, certificates and related documentation received by anv of

Whitesell's manufacturing plants and/or facilities, both domestic and international,

as well as all third party sub-suppliers used by Whitesell to supply Parts in Suit to
Defendants for the period 2001-2013" is overbroad, harassing, irrelevant to any
party's claim or defense, and not proportional to the needs of this case. Accordingly,
the Request places a burden on Whitesell that is disproportionate to any benefit the
discovery might provide to Defendants.

Notwithstanding Whitesell's objections, if Defendants narrow the Request to seek
only certificates regarding the Parts in Suit, Whitesell will agree to search for and

produce any responsive documents as they are maintained in the ordinary course of
business, as provided for in the parties' Stipulated Protocol for the Production of
Documents.

7. Please produce a copy of all QS900 or similar certifications and related documentation
received by the Whitesell Corporation, as well as all third party sub-suppliers used by Whitesell

to supply Parts in Suit to Defendants for the period 2001-2013. This request includes documents

indicating the name of the registrar(s) issuing the certificate(s), the identity of the plant and/or

facility to which the certificate(s) relates, the effective dates of each such certification, all
recertification audits that the Company underwent and the result of such recertification audits(s).
5

K\\ia^,VL\VUK>S\V.\m\lMAN,KAT;.UN &LEV1NE.P.U' MIAMI CENTER, 27TH FLOOR. 201 So. BlSCAYNE BLVD., MIAMI, FL 33131 •305.379.9000

CASE NO. 1:03-cv-00050-JRH

RESPONSE:

The request for "all . . . certificates and related documentation received by anv of
Whitesell's manufacturing plants and/or facilities, both domestic and international,

as well as all third party sub-suppliers used by Whitesell to supply Parts in Suit to
Defendants for the period 2001-2013" is overbroad, harassing, irrelevant to any

party's claim or defense, and not proportional to the needs of this case. Accordingly,
the Request places a burden on Whitesell that is disproportionate to any benefit the
discovery might provide to Defendants.

Notwithstanding Whitesell's objections, if Defendants narrow the Request to seek
only certificates regarding Parts in Suit, Whitesell will agree to search for and

produce any responsive documents as they are maintained in the ordinary course of
business, as provided for in the parties' Stipulated Protocol for the Production of
Documents.

8.

Please produce copies of all written policies, procedures and quality manuals

reviewed and/or approved in connection with the ISO and QS900 certificates described in the two
preceding requests for production.
RESPONSE:

Whitesell objects to this Request as overbroad, harassing, irrelevant to any party's
claim or defense, and not proportional to the needs of this case. Requests 6-8

presumably seek information concerning the quality of Parts in Suit. To the extent
any ofthe documents requested in Requests 6-8 contain such information, it would
be contained in the certificates responsive to Requests 6-7, which Whitesell has

offered to produce, as noted above. The additional documentation requested in
Request 8would provide no information concerning the quality ofParts in Suit, nor
is itin any way related to issues in this case, and amounts to aclassic fishing expedition
that seeks information which is irrelevant and not reasonably calculated to lead to the

discovery of admissible evidence. Accordingly, the Request places a burden on
Whitesell that is disproportionate to any benefit the discovery might provide to
Defendants.

Notwithstanding Whitesell's prior objections, Whitesell will agree to produce

responsive documents to the extent they are reasonably available in electronic form,
which primarily consists of materials from 2006 and later. Based on Whitesell's

review, these documents in electronic form would be approximately 3,400 pages.

Earlier, hard copy documents might be contained in boxed files that are currently in

storage. These files are not categorized in any manner that would allow Whitesell to
easily search for responsive material, and the cost and burden ofretrieving those files,
6

KLUGER, KAPLAN. SILVERMAN. KATZEN &Ll-VINE, P.L- MIAMI CENTER, 27TH FLOOR, 201 SO. BlSCAYNU BLVD., MIAMI, FL 33131 • 305.379.9000

CASE NO. l:03-cv-O0O50-JRH

searching for potentially responsive materials among primarily non-responsive and
irrelevant materials, and producing such materials is far outweighed by the fact that
the materials (to the extent they can even be located) will produce no useful or
relevant information beyond what Whitesell has offered to produce in response to

Requests 6-7.2

Accordingly, Whitesell will not produce hard-copy documents

responsive to this request.
Dated: June 6, 2016.

Respectfully submitted,
Bv:/s/ Steve I. Silverman

Alan J. Kluger, Esq. {admittedpro hoc vice)
Fla. Bar No. 200379

[e-mail]
Steve I. Silverman {admittedpro hac vice)
Fla. Bar No. 5 J 6831

[e-mail]
Terri Meyers, Esq. {admittedpro hac vice)
Fla. Bar No. 881279

Lisa J. Jerles, Esq. {admittedpro hac vice)
Fla. Bar No. 56092

KLUGER, KAPLAN, SILVERMAN,
KATZEN & LEVINE, P.L.
Miami Center* 27th Floor

201 South Biscayne Boulevard
Miami, Florida 33131

Telephone: [phone]
Facsimile: [phone]

Attorneysfor Whitesell Corporation

2If it becomes necessary should defendants file a motion to compel directed to this Request,
Whitesell will provide a declaration concerning the burden imposed bythis Request as stated
above.
7

KLUGER, KAPLAN, SILVERMAN, KAT/.liN &LEVINE, P.L.« MIAMI CENTER, 27TII FLOOR, 201 So. BiSCAVNE BLVD., MIAMI. FL 33131 •305.379.9000

CASE NO. l:03-cv-00050-JRH

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on June6, 2016, a true and correct copy of the foregoing has

been furnished via electronic mail on the parties identified in the Service List below.

By: /s/Steve I. Silverman
Steve I. Silverman

SERVICE LIST

Michael P. Kenny
Kyle G.A. Wallace
Elizabeth H. Helmer

Alston & Bird, LLP
One Atlantic Center

James M. Brogan (Pro Hac Vice
Matthew a. Goldberg (Pro Hac Vice)
Brian J. Bogle (Pro Hac Vice)
DLA Piper LLP
One Liberty Place

1201 W. Peachtree St.

1650 Market Street, Suite 4900

Atlanta, GA 30309-3424

Philadelphia, PA 19103

404-881-7000

215-656-3300

404-881-7777 (fax)

215-656-3301 (fax)
[e-mail]
[e-mail]

[e-mail]
[e-mail]

[e-mail]

[e-mail]

Electrolux Home Products, Inc.

Husqvama AB and Husqvama Outdoor
Products, Inc.

R. Perry Sentell, III

HalJ. Leitman

Laurel P. Landon

Todd H. Surden

KilpatrickTownsend & Stockton, LLP

Macey, Wilensky & Hennings, LLC

1450 Greene St

303 Peachtree Street, N.E.

Enterprise Mill Suite 230
Augusta, GA 30901

Suite 4420

706-823-4202

404-584-1200

706-828-4453 (fax)

404-681-4355 (fax)

[e-mail]
[e-mail]
Husqvama Outdoor Products, Inc.; and

[e-mail]
tsurden@macevwi lenskv.com

Atlanta, GA 30308

Whitesell Corporation

Husqvama, A.B.

KLUGER, KAPl,\N, SILVERMAN, KATO*; &\ALV\KE, P.L« MIAMI CENTER, 27TH FLOOR, 201 So. BlSCAYNK BLVD., MIAMI, FL 33131 •305.379.9000