1 Quinn Tessence v Le Conde Inn
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391
Subject
Law
Date
Nov 24, 2024
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59
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K
CASE
BACKGROUND
e
Quinn
Tessence
was
on
the
rise
in
the
world
of
broadcast
news.
Quinn
had
a
reputation
for
getting
stories
that
no
one
else
could
get.
But
some
people
questioned
whether
Quinn
crossed
the
line
on
occasion
with
his/her
dramatic,
if
not
theatrical,
exposés.,
Quinn’s
outspoken
style
and
brashness
has
won
him/her
both
praise
and
condemnation.
In
climbing
the
ladder
to
fame
and
notoriety
in
the
broadcast
venue,
Quinn
made
enemies
along
the
way.
Undeterred,
Quinn’s
latest
exposé
was
on
bed
bugs
in
the
hotel
industry.
At
the
time,
no
other
reporters
had
broken
the
story,
locally
or
nationally,
and
Quinn
planned
to
be
the
first.
Around
the
same
time
that
Quinn
was
trying
to
get
a
story
on
bed
bugs,
he/she
was
also
interviewing
with
a
global
broadcast
cable
network
for
a
position
as
a
host
of
a
ptime
time
news
exposg,
to
be
scheduled
opposite
Nancy
Grace.
During
the
interview,
Quinn
mentioned
that
he/she
was
currently
working
on
an
exposé
of
bed
bugs
in
the
hotel
industry.
After
the
interview,
Quinn
was
certain
he/she
would
be
offered
the
position.
The
general
manager
of
the
global
broadcast
cable
network,
Justin/JTustine
Case,
advised
Quinn
that
a
decision
would
be
made
in
two
weeks.
Case
also
expressed
an
interest
in
seeing
footage
of
the
bed
bug
exposé
when
it
was
completed.
Shortly
thereafter,
Quinn
stayed
a
weekend
at
Le
Condé
Inn
for
a
co-worker’s
wedding
reception.
Le
Condé
Inn
is
a
prestigious
and
well-established
boutique
hotel
in
Indianapolis,
and
for
that
matter,
the
State
of
Indiana.
On
Sunday
morning,
Quinn
found
he/she
experienced
severe
itching,
redness
and
swelling
on
his/her
face,
neck,
hands,
arms
and
back.
Because
Quinn
had
previously
researched
bed
bugs
for
his/her
exposé,
he/she
immediately
recognized
the
symptoms
and
had
a
camera
crew
promptly
capture
the
bed
bug
ridden
bed
in
his/ber
hotel
room
at
Le
Condé
Inn.
The
story
was
aired
a
few
days
later.
Le
Condé
Inn’s
Hotel
Manager,
Jacqué
Garnier,
publicly
accused
Quinn
or
the
news
station
of
planting
the
bed
bugs
to
fabricate
a
story.
After
Quinn’s
exposé
aired,
Le
Condé
Inn
experienced
significant
cancellations
of
reservations,
approximately
75%
of
bookings
for
the
month
of
July,
2008.
The
following
two
quarters
showed
revenue
down
by
a
third
compared
to
the
same
quatters
in
the
past
two
years.
Le
Condé
Inn
claims
that
Quinn’s
defamatory
comments
resulted
in
the
loss
of
income
to
the
hotel.
The
global
broadcast
cable
network
learned
of
Le
Condé
Inn’s
claims
that
the
story
was
fabricated
and
did not
hire
Quinn
for
the
host
position.
Plaintiff’s
Witnesses:
Quinn
Tessence
—
Plaintiff
News
Anchor
Reed
Tayne
—
Treating
Physician/Dermatology
and
Entomology
Expert
Justin/Justine
Case
—~
General
Manager
of
Global
Broadcast
Cable Network:
Defendant’s
Witnesses:
Jacqué
Garnier
—
Defendant’s
Hotel
Manager
Tetry/Terri
Fyde
—
Former
Producer
for
Local
Television
Station
Dee
D.
Tee-
Pest
Control
Expert
The
Case
Background
is
not
to
be
used
as
evidence
in
the
case,
bus
rather
is
provided
for
background
purposes
only.
This
case
is
a
work
of
fiction,
The
names
and
events
described
herein
are
intended
to
be
fictional.
Any
similarity
or
resemblance
of
any
character
to
an
actual
person
or
entity
should
be
regarded
as
only
fictional
for
purposes
of
this
mock
trial
exercise.
2-
STATE
OF
INDIANA
)
IN
THE
MARION
CIRCUIT
COURT
)
SS:
CAUSE
NO.:
49C01-0810-CP-639
COUNTY
OF
MARION
)
QUINN
TESSENCE,
)
)
Plaintiff,
)
)
V.
)
i
)
LE
CONDE
INN,
INC.
)
)
Defendant.
)
COMPLAINT
FOR
DAMAGES
The
Plaintiff,
Quinn
Tessence,
by
counsel,
files
her
complaint
against
the
Defendant,
Le
Condé
Inn,
Inc.,
and
states:
COUNT
I
-
NEGLIGENCE
Plaintiff
Quinn
Tessence
is
a
resident
of
the
State
of
Indiana.
Defendant
Le
Condé
Inn,
Inc.,
is
an
Indiana
corporation
doing business
in
the
State
of
Indiana.
At
all
relevant
times
herein,
Defendant
owned
and
operated
the
Le
Condé
Inn
hotel
located
at
30
Executive
Drive
in
Indianapolis,
Indiana.
On
or
about
July
11,
2008,
through
July
13,
2008,
Plaintiff
was
a
guest
at
the
Le
Condé
ITnn.
Plaintiff
was
exposed
to
bed
bugs
while
a
guest
at
Le
Condé
Inn.
Defendant
had
a
duty
to
exercise
reasonable
care
to
detect
and
prevent
bed
bug
infestation
for
the
protection
of
the
safety
and
health
of
its
guests,
including
the
Plaintiff.
Defendant
negligently
failed
to
exercise
reasonable
care
in
detecting
bed
bugs
from
becoming
infested
in
the
guest
room
at
Le
Condé
Inn
occupied
by
Plaintiff.
As
a
proximate
result
of
Defendant’s
negligence,
Plaintiff
suffered
significant
pain
and
permanent
scars.
WHEREFORE,
Plaintiff
prays
for
judgment
in
his/her
favor
and
against
Defendant,
that
3.
he/she
be
awarded
damages
for
his/her
injuries,
pain and
suffering,
for
costs,
and
all
other
just
and
proper
relief.
COUNT
II
-
DEFAMATION
9.
Plaintiff
incorporates
herein
by
reference
the
allegations
of
paragraphs
1
through
8
of
Count
L.
10.
Plaintiff
was
a
news
anchor
and
investigative
reporter
at
WYBU
at
all
relevant
times
herein.
11.
In
June
and
July
of
2008,
Plaintiff,
as
a
news
reporter
and
anchor
for
WYBU,
worked
on
an
investigative
report
regarding
bed
bug
infestations
at
hotels
in
the
Indianapolis
area.
12.
Plaintiff’s
news
story
of
hotel
bed
bug
infestation
aired
on
the
WYBU
TV
Station
on
July
17,
2010.
13.
Jacqué
Garnier
was
the
hotel
manager
of
Le
Condé
Inn
and
was
acting
in
the
course
and
scope
of his
duties
as
an
employee
or
agent
of
Defendant
at
all
relevant
times
herein.
14.
Jacqué
Garnier
reported
to
the
Indianapolis
Star
that
Plaintiff
fabricated
a
news
and
planted
bed
bugs
at
the
Le
Condé
Inn.
15.
Jacqué
Garnier’s
aforementioned
statements
were
false
and
defamatory.
16.
Jacqué
Garnier
knew
the
statements
to
be
false
or
negligently
failed
to
determine
the
truth
of
the
statements.
17.
The
false
statements
made
about
Plaintiff
implied
misconduct
by
Plaintiff
in
his/her
professional
trade
and
occupation
as
a
news
anchor
and
news
reporter.
18.
The
false
statements
made
about
Plaintiff
were
per
se
defamatory.
19.
The
defamatory
statements
were
primarily
motivated
by
ill-will
and
were
excessively
published.
20.
The
false
statements
made
about
Plaintiff
harmed
Plaintiff’s
reputation
in
the
eyes
of
the
community,
deterred
others
from
associating
with
him/her
and
deterred
third
persons
from
employing
him/her.
|
\
21.
Defendant
is
liable
for
Jacqué
Garnier’s
false
statements
as
an
agent
of
|
Defendant.
1
|
|
22,
As
aresult
of
the
actions
of
the
Defendant,
Plaintiff
has
sustained
substantial
4-
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damages,
including
but not
limited
to
financial
loss,
embarrassment,
and
emotional
distress.
.
23.
Plaintiff’s
injuries
and
damages
were
proximately
caused
by
the
Defendant.
WHEREFORE,
Plaintiff
prays
for
judgment
in
his/her
favor
and
against
Defendant,
that
he/she
be
awarded
damages,
for
costs,
and
all
other
just
and
proper
relief.
/s/
Lee
Gull
LEE
GULL
Attorney
for
Plaintiff
JURY
DEMAND
Plaintiff
respectfully
requests
trial
by
jury.
/s/
Lee
Gull
LEE
GULL
Attorney
for
Plaintiff
STATE
OF
INDIANA
)
IN
THE
MARION
CIRCUIT
COURT
)
SS:
CAUSE
NO.:
49C01-0810-CP-639
COUNTY
OF
MARION
)
QUINN
TESSENCE,
Plaintiff,
v.
LE
CONDE
INN,
INC.
Defendant.
DEFENDANT’S
ANSWER
TO
COMPLAINT
The
Defendant,
Le
Condé
Inn,
Inc.,
for
its
Answer
to
Complaint,
states
as
follows:
COUNT
I
-
NEGLIGENCE
Defendant
is
without
knowledge
or
information
sufficient
to
form
a
belief
as
to
the
truth
of
the
allegations
of
paragraph
1
of
Count
I
of
the
Complaint.
Defendant
admits
the
allegations
of
paragraph
2
of
Count
I
of
the
Complaint.
Defendant
admits
the
allegations
of
paragraph
3
of
Count
I
of
the
Complaint.
Defendant
admits
the
allegations
of
paragraph
4
of
Count
I
of
the
Complaint.
Defendant
is
without
knowledge
or
information
sufficient
to
form
a
belief
as
to
the
truth
of
the
allegations
of
paragraph
5
of
Count
I
of
the
Complaint.
Defendant
admits
the
allegations
of
paragraph
6
of
Count
I
of
the
Complaint.
Defendant
denies
the
allegations
of
paragraph
7
of
Count
I
of
the
Complaint.
Defendant
denies
the
allegations
of
paragraph
8
of
Count
I
of
the
Complaint.
COUNT
II
-
DEFAMATION
Defendant
incorporates
herein
by
reference
its
answers
to
the
allegations
of
paragraphs
1
through
8
of
Count
L.
10.
Defendant
is
without
knowledge
or
information
sufficient
to
form
a
belief
as
to
the
truth
of
the
allegations
of
paragraph
10 of
Count
I
of
the
Complaint.
Defendant
is
without
knowledge
or
information
sufficient
to
form
a
belief
as
to
the
truth
of
the
allegations
of
paragraph
11
of
Count
II
of
the
Complaint,
Defendant
admits
the
allegations
of
paragraph
12
of
Count
II
of
the
Complaint.
Defendant
admits
the
allegations
of
paragraph
13
of
Count
II
of
the
Complaint.
Defendant
admits
the
allegations
of
paragraph
14
of
Count
II
of
the
Complaint,
Defendant
denies
the
allegations
of
paragraph
15
of
Count
II
of
the
Complaint.
Defendant
denies
the
allegaitions
of
paragraph
16
of
Count
I
of
the
Complaint,
Defendant
denies
the
allegations
of
paragraph
17
of
Count
II
of
the
Complaint.
Defendant
denies
the
allegations
of
paragraph
18
of
Count
II
of
the
Complaint.
Defendant
denies
the
allegations
of
paragraph
19
of
Count
I
of
the
Complaint.
Defendant
denies
the
allegations
of
paragraph
20
of
Count
II
of
the
Complaint.
Defendant
denies
the
allegations
of
paragraph
21
of
Count
II
of
the
Complaint.
Defendant
denies
the
allegations
of
paragraph
22
of
Count
II
of
the
Complaint.
Defendant
denies
the
allegations
of
paragraph
23
of
Count
I
of
the
Complaint.
AFFIRMATIVE
DEFENSES
With
regard
to
Count
II,
any
statements
made
by
Defendant,
through
the
scope
of
the
employment
of
Jacque
Garnier,
upon
which
Plaintiff
bases
his/her
claims
for
defamation,
are
true
and
are
therefore
not
actionable.
‘With
regard
to
Count
II,
Plaintiff’s
claims
are
barred
to
the
extent
his/her
damages
were
caused
by
the
publication
of
the
alleged
defamatory
statements
as
referenced
in
Plaintiff’s
Complaint,
by
persons
other
than
the
Defendant,
its
agents,
and
employees.
With
regard
to
Count
II,
Plaintiff’s
claims
for
defamation
fail
due
to
Defendant’s
qualified
privilege.
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WHEREFORE,
Defendant
prays
for
judgment
in
its
favor,
that
Plaintiff
take
nothing
by
way
of
his/her
complaint,
for
costs,
and
all
other
just
and
proper
relief.
/s/
Justice
Hurd
JUSTICE
HURD
Attorney
for
Defendant
STATE
OF
INDIANA
)
COUNTY
OF
MARION
;
>
QUINN
TESSENCE,
Plaintiff,
V.
LE
CONDE
INN,
INC.
Defendant.
[
N
N
N
N
1
IN
THE
MARION
CIRCUIT
COURT
CAUSE
NO.:
49C01-0810-CP-639
LE
CONDE
INN,
INC.
Counterclaimant
V.
QUINN
TESSENCE
and
WYBU,
INC.
Counterclaim
Defendants,
Counterclaimant,
Le
Condé
Inn,
Inc.,
for
its
Counterclaim
against
Counterclaim
NN
N
N
N
N
AN
COUNTERCLAIM
Defendants
Quinn
Tessence
and
WYBU,
Inc.,
states
as
follows:
1.
Le
Condé
Inn,
Inc.
is
an
Indiana
corporation
doing business
in
the
State
of
Indiana.
2.
At
all
relevant
times
herein,
Counterclaimant
owned
and
operated
the
Le
Condé
Inn
hotel
located
at
30
Executive
Drive
in
Indianapolis,
Indiana.
3.
Quinn
Tessence
is
a
resident
of
the
State
of
Indiana.
4.
At
all
relevant
times
herein
Quinn
Tessence
was
a
news
anchor
and
investigative
reporter
employed
by
WYBU.
5.
As
anews
reporter
and
anchor
for
WYBU,
Quinn
Tessence
worked
on
an
investigative
report
regarding
bed
bug
infestations
at
hotels
in
the
Indianapolis
area,
11.
12.
13.
14.
15.
16.
The
news
story
of
hotel
bed
bug
infestation
aired
on
the
WYBU
TV
Station
on
Tuly
17,
2010.
The
news
report
falsely
reported
that
Le
Condé
Inn
puts
its
profits
above
its
guests’
health
and
safety.
The
news
report
falsely
reported
that
Le
Condé
Inn’s
housekeeping
staff
are
overworked
and
rushed,
and bed
bugs
infestations
occur.
The
news
report
falsely
reported
that
Le
Condé
Inn
has
poor
quality
assurance
and
failed
to
have
adequate
safeguards
to
prevent
bed
bugs.
The
aforementioned
statements
were
false
and
defamatory.
Counterclaim
Defendants
knew
the
statements
to
be
false
or
negligently
failed
to
determine
the
truth
of
the
statements.
The
defamatory
statements
were
primarily
motivated
by
ill-will
and
were
excessively
published.
The
false
statements
made
about
Counterclaimant
harmed
Counterclaimant’s
reputation
in
the
eyes
of
the
community,
and
deterred
guests
or
potential
guests
from
booking
or
keeping
reservations
at
the
hotel.
WYBU
is
liable
for
Quinn
Tessence’s
false
statements
as
an
agent
of
WYBU.
As
a
result
of
the
actions
of
the
Counterclaim
Defendants,
Counterclaimant
has
sustained
substantial
financial
loss.
Counterclaimant’s
damages
were
proximately
caused
by
the
Counterlaim
Defendants
defamatory
statements.
WHEREFORE,
Counterclaimant
prays
for
judgment
in
its
favor
and
against
Counterclaim
Defendants,
that
it
be
awarded
damages,
for
costs,
and
all
other
just
and
proper
relief.
/s/
Justice
Hurd
JUSTICE
HURD
Attorney
for
Counterclaimant
-10-
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STATE
OF
INDIANA
)
)
SS:
COUNTY
OF
MARION
)
QUINN
TESSENCE,
Plaintiff,
V.
LE
CONDE
INN,
INC.
Defendant,
e
N
e
e
e
et
s
S
IN
THE
MARION
CIRCUIT
COURT
CAUSE
NO.:
49C01-0810-CP-639
LE
CONDE
INN,
INC.
Counterclaimant
V.
QUINN
TESSENCE
and
WYBU,
INC.
Counterclaim
Defendants,
N
e
e
S
e
N
S
e
S
S
ANSWER
TO
COUNTERCLAIM
Counterclaim
Defendants
Quinn
Tessence
and
WYBU,
Inc.
for
their
Answer
to
Counterclaimant,
Le
Condé
Inn,
Inc.’s
Counterclaim,
state
as
follows:
1.
Counterclaim
Defendants
are
without
knowledge
or
information
sufficient
to
form
a
belief
s
to
the
truth
of
the
allegations
of
paragraph
1
of
the
Counterclaim.
Counterclaim
Defendants
are
without
knowledge
or
information
sufficient
to
form
a
belief
s
to
the
truth
of
the
allegations
of
paragraph
2
of
the
Counterclaim.,
Counterclaim
Defendants
admit
the
allegations
of
paragraph
3
of
the
Counterclaim.
Counterclaim
Defendants
admit
the
allegations
of
paragraph
4
of
the
Counterclaim.
Counterclaim
Defendants
admit
the
allegations
of
paragraph
5
of
the
Counterclaim.
-11-
10.
11,
12.
13.
14.
15,
16.
Counterclaim
Defendants
admit
the
allegations
of
paragraph
6
of
the
Counterclaim.
Counterclaim
Defendants
deny
the
allegations
of
paragraph
7of
the
Counterclaim.
Counterclaim
Defendants
deny
the
allegations
of
paragraph
8
of
the
Counterclaim.
Counterclaim
Defendants
deny
the
allegations
of
paragraph
9
of
the
Counterclaim.,
Counterclaim
Defendants
deny
the
allegations
of
paragraph
10 of
the
Counterclaim.
Counterclaim
Defendants
deny
the
allegations
of
paragraph
11
of
the
Counterclaim.
Counterclaim
Defendants
deny
the
allegations
of
paragraph
12
of
the
Counterclaim.
Counterclaim
Defendants
deny
the
allegations
of
paragraph
13
of
the
Counterclaim.
Counterclaim
Defendants
deny
the
allegations
of
paragraph
14 of
the
Counterclaim.
Countesclaim
Defendants
deny
the
allegations
of
paragraph
15 of
the
Counterclaim.
Counterclaim
Defendants
deny
the
allegations
of
paragraph
16
of
the
Counterclaim,
AFFIRMATIVE
DEFENSES
Any
statements
made
by
Counterclaim
Defendants
upon
which
Counterclaim
bases
its
claims
for
defamation
are
true
and
are
therefore
not
actionable.
Counterclaimant’s
claims
for
defamation
fail
due
to
Counterclaim
Defendants’
common
interest
privilege.
WHEREFORE,
Counierclaim
Defendants
prays
for
judgment
in
its
favor,
that
Counterclaimant
take
nothing
by
way
of
its
counterclaim,
for
costs,
and
all
other
just
and
proper
relief.
/s/
Lee
Gull
LEE
GULL
Attorney
for
Plaintiff/Counterclaimdefendants
-12-
STATE
OF
INDIANA
)
)
SS:
COUNTY
OF
MARION
)
QUINN
TESSENCE,
Plaintiff,
V.
LE
CONDE
INN,
INC.
Defendant.
e
e
N
e
N
e
N
S
IN
THE
MARION
CIRCUIT
COURT
CAUSE
NO.:
49C01-0810-CP-639
LE
CONDE
INN,
INC.
Counterclaimant
V.
QUINN
TESSENCE
and
WYBU,
INC.
Counterclaim
Defendants,
Note:
No
witness
may
contradict
or
deny
knowledge
of
the
facts
contained
in
the
stipulations.
1.
All
exhibits
included
in
these
Case
Materials
are
authentic
and
accurate
in
all
respects;
no
objection
to
the
authenticity
of
these
exhibits
will
be
entertained.
Unless
stated
otherwise
herein,
the
admissibility
of
the
exhibits
on
other
grounds
may
be
challenged.
2.
All
witness
statements
were
signed
under
oath
by
each
witness.
3.
Exhibit
2
(Quinn
Tessence
bed
bug
bites
present
on
the
morning
of
July
13,
2008),
Exhibit
3
and
4
(bed
bugs
present
in
Quinn
Tessence’s
hotel
room
at
Le
Condé
Inn
on
July
13,
2008),
and
Exhibit
5
(the
bed
bug
infested
mattress
with
bed
bug
fecal
stains
present
in
Quinn
Tessence’s
hotel
room
at
Le
Condé
Inn
on
July
13,
2008)
are
the
original
photographs
and
accurately
depict
the
items
shown
N
e
N
N
e
e
N
N
e
S
STIPULATIONS
in
the
photograph
on
July
13,
2008,
13-
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Exhibits
1
and
6
were
made
at
or
about
the
time
of
the
events
by
a
person
with
knowledge
of
the
events,
and
are
kept
in
the
course
of
regularly
conducted
business
activity
of
WYBU,
and
it
is
the
regular
practice
of
WYBU
to
make
such
records.,
Exhibits
1
and
6
do
not
need
to
be
introduced
through
the
custodian
of
the
records,
Exhibit
7
is
admissible,
without
objection.
Exhibits
8
is
made
at
or
about
the
time
of
the
events
by
a
person
with
knowledge
of
the
events,
and
is
kept
in
the
course
of
regularly
conducted
business
activity
of
Dr.
Tayne’s medical
practice,
and
it
is
the
regular
practice
of
Dr.
Tayne
to
make
such
records.
Dr.
Tayne
is
the
custodian
of
such
record.
Exhibits
9
and
10
were
made
at
or
about
the
time
of
the
events
by
a
person
with
and
knowledge
of
the
events, and
are
kept
in
the
course
of
regularly
conducted
business
activity
of
Le
Condé
Inn,
and
it
is
the
regular
practice
of
Le
Condé
Inn
to
make
such
records.
Exhibits
9
and
10
do
not
need
to
be
introduced
through
the
custodian
of
the
records.
Exhibit
11
is
a
compilation
of
business
records
made
at
or
about
the
time
of
the
events
by
a
person
with
and
knowledge
of
the
events,
and
are
kept
in
the
course
of
regularly
conducted
business
activity
of
Le
Condé
Inn,
and
it
is
the
regular
practice
of
Le
Condé
Inn
to
make
such
records.
And
was
compiled
by
Jacqué
Garnier,
Jacqué
Garnier
is
the
custodian
of
such
record.
Exhibit
12
is
a
true
and
accurate
copy
of
the
original
note
located
in
the
waste
basket
of
Quinn
Tessence’s
hotel
room
at
Le
Condé
Inn
on
July
13,
2008.
The
handwriting
contained
in
Exhibit
12
has
been
confirmed
to
be
that
of
Quinn
Tessence,
per
expert
handwriting
analysis.
Exhibit
12
is
admissible,
without
objection.
_14-
APPLICABLE
LAW
Negligence
—
Definition.
Negligence
is
the
failure
to
use
reasonable
care.
A
person
may
be
negligent
by
acting
or
by
failing
to
act.
A
person
is
negligent
if
he
or
she
does
something
a
reasonably
careful
person
would
not
do
in
the
same
situation
or
fails
to
do
something
a
reasonably
careful
person
would
do
in
the
same
situation.
Reasonable
or
Ordinary
Care
—
Definition.
Reasonable
or
ordinary
care
is
the
care
a
reasonably
careful and
ordinarily
prudent
person
would
use
under
the
same
or
similar
circumstances.
Proximate
Cause
—
Definition.
An
act
or
omission
is
a
proximate
cause
of
an
injury
if
the
injury
is
a
natural
and
probable
consequence
of
the
act
or
omission.
To
establish
that
an
act
was
the
proximate
cause
of
damages,
a
party
must
show:
1.
That
damages
would
not
have
occurred
but
for
another’s
negligence;
and
2.
That
damages
were
reasonably
foreseeable
as
the
natural and
probable
consequence
of
the
other’s
negligence.
Defamation
To
prevail
on
a
cause
of
action
for
defamation,
a
plaintiff
must
prove
four
elements:
(1)
a
communication
with
defamatory
imputation,
(2)
malice,
(3)
publication,
and
(4)
damages.
To
impose
liability
for
defamation,
a
false
statement
of
fact
is
required.
Truth
is
a
complete
defense
in
civil
actions
for
defamation.
A
statement
is
defamatory
if
it
tends
to
harm
a
person
or
company's
reputation
by
lowering
the
person
or
company
in
the
community's
estimation
or
deterring
third
persons
from
dealing
or
associating
with
the
person
or
business.
One
type
of
defamation
action,
alleging
“defamation
per
se,”
arises
when
the
language
of
a
statement
constitutes
an
imputation
of
misconduct
in
a
person's
trade,
profession,
office,
or
occupation.
Qualified
privilege
of
common
interest
that
“applies
to
communications
made
in
good
faith
on
any
subject
matter
in
which
the
party
making
the
communication
has
an
interest
or
in
reference
to
which
he
has
a
duty,
either
public
or
private,
either
legal,
moral,
or
social,
if
made
to
a
person
having
a
corresponding
interest
or
duty.
-15-
W0
LY
LI
W
W)
NOR
DR
DR
N
D
=
ot
2
s
e
e
STATEMENT
OF
QUINN
TESSENCE
My
name
is
Quinn
Tessence.
Iam
a
news
anchor
for
the
6
pm
news
at
WYBU,
Channel
17
in
Indianapolis.
I
also
have
a
weekly
investigative
news
report
exposé
that
airs
on
Thursdays,
called
“No
Apologies.”
1view
myself
as
a
victim’s
advocate
and
someone
who
is
for
the
people.
Having
been
a
victim
myself
in
an
unsolved
crime,
I
made
it
my
mission
to
expose
the
bad
acts
of
people
or
businesses
that
law
enforcement
or
the
government
either
doesn’t
have
the
time
or
inclination
to
pursue,
When
I
go
after
these
bad
people
or
companies,
I
make
no
apologies
for
hitting
them
below
the
belt.
As
far
as
I'm
concerned
they
deserve
to
be
publicly
humiliated.
1
was
born
and
raised
in
Tupelo,
Mississippi,
the
birthplace
of
Elvis
Presley.
Iknew
from
a
young
age
I
would
be
a
star,
too.
I
have
drive
and
determination,
and
there
isn’t
anything
that
gets
in
the
way
of
this
steam-roller.
I
excelled
in
high
school,
both
academically
and
in
sports,
and
received
a
full-ride
scholarship
from
Mizzou
(University
of
Missouri).
Ibhad
several
other
options
with
scholarships,
but
Mizzou
was
my
first
choice.
It
has
been
on
top
of
the
rankings
for
its
Journalism
and
Mass
Communications
programs
since
rankings
have
been
done.
I
received
a
bachelor’s
degree
from
Mizzou
in
Journalism
and
a
minor
in
Mass
Communications
in
1998,
graduating
with
highest
distinction.
I
then
attended
law
school
at
Northwestern
University.
Ileft
law
school before
completing
my
degree
because
I
was
mugged
in
Chicago.
Due
to
the
time
I
spent
in
the
hospital
and
at
home
recuperating
from
broken
ribs
and
a
concussion,
I
could
not
finish
my
third
year
of
law
school.
Idid
not
view
it
as
a
setback,
rather
it
was
an
opportunity
for
me
to
start
a
new
chapter
in
my
life.
When
the
crime
went
unsolved,
T
decided
to
use
my
journalism
skills
and
knowledge
of
the
law
for
other
victims
like
me.
In
2000,
I
began
my
career
as
a
news
reporter
at
a
local
television
station
in
South
Bend,
Indiana.
In
2004,
T
was
hired
at
an
affiliate
station,
WYBU,
in
Indianapolis.
Terry/Terri
Fyde
hired
me
to
start
as
a
morning
anchor
and
news
reporter
on
WYBU’s
First
Light
News.
As
arising
star
at
WYBU,
within
a
year,
I
had
been
promoted
to
anchor
of
the
Evening
News
in
the
prime
time
slot.
I
was
given
quite
a
bit
of
latitude
too.
WYBU
even
agreed
to
let
me
showcase
the
weekly
exposé,
“No
Apologies.”
1
chrived
on
reporting
the
news
and
investigating
timely
events
that
mattered
to
the
people.
News
reporters
gather
information,
prepare
stories,
and
make
broadcasts
that
inform
the
public
about
local,
State,
national,
and
international
events.
We
present
points
of
view
on
current
issues
and
report
on
the
actions
of
public
officials,
corporate
executives,
interest
groups,
and
others
who
exercise
power.
As
a
news
anchor
my
responsibility
is
to
examine,
interpret,
and
broadcast
news
received
from
various
sources.
News
anchors
present
news
stories
and
introduce
videotaped
news
or
live
transmissions
from
on-the-scene
reporters.
Before
I
joined
the
WYBU
team,
other
local
stations
and
Joe
Public
would
joke
about
the
station’s
call
letters
—
“Why
Be
You?”
I
turned
that
all
around
in
a
short
time.
Now,
all
the
other
anchors
and
reporters
want
to
be
like
me.
I've
received
numerous
awards
and
recognitions,
including
the
Writers
Guild
Award
in
2007
for
outstanding
writing,
and,
in
2008,
I
received
the
Society
of
Professional
Journalist
Awards
for
TV
Consumer
Reporting
and
TV
Investigative
Reporting,
as
well
as
the
Indiana
Broadcasters’
Association
Spectrum
Award.
WYBU
was
a
16~
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W
W
W
W
R
MR
A
m
s
s
s
&fiafifié%g%&)fiwwr—o\%gflom#mw»—\O\DOO\]O\LAJALQNHO\DOO\IO\LA#WNH
floundering
station
when
I
began
there
in
2004,
Now
it
is
well
recognized
and
its
ratings
and
market
share
in
the
Indianapolis
market
increased
by
4
times
from
2004
to
2008.
However,
our
market
share
currently
is
only
twice
the
share
we
had
in
2004.
After
the
Le
Condé
Inn
manager
accused
me
of
fabricating
the
story,
and
defamed
myy
character,
we
lost
a
significant
part
of
our
audience.
The
news
I
report and
my
investigative
exposés
are
often
cutting
edge.
I
go
after
the
story
that
no
one
else
can
get,
or
even
thought
to
get.
Ibelieve
that
the
success
of
my news
career
and
the
increased
market
share
is
because
the
viewers
can
relate
to
me.
I
frequently
discuss
issues
from
a
victim’s
rights
standpoint.
Isometimes
get
personal
and
become
emotionally
involved
in
presenting
the
news
story.
This
makes
me
more
real
to
the
audience.
They
can
relate
to
me
and
they
know
I
can
relate
to
them.
I
just
don’t
present
the
news
in
the
same
boring
way
that
has
been
done
before.
Adding
dramatic
flair
to
a
story
doesn’t
change
the
the
news,
it
just
makes
it
more
interesting.
The
viewers
want
some
sensationalism,
they’re
thitsty
for
the
fight
and
for
justice
to
prevail.
They
see
me
as
their
fighter.
I
have
an
outspoken
style
that
has
won
me
both
praise and
condemnation.
The
people
who
condemn
me
are
often
the
people
that
I
have
targeted.
If
a
business
is
ruined
because
I
showed
the
public
the
truth,
then
so
be
it.
News
is
news.
The
truth
is
not
always
nice,
polite,
or
easy
to
go
down.
Sometimes
it's
just
plain
harsh.
One
of
my
award
winning
stories
focused
on
the
victim
of
a
teen
driver
who
was
texting
and
driving.
1
broke
this
story
before
anyone
else,
even
before
Oprah
started
her
campaign
for
“No
Texting
While
Driving”
campaign.
Another
breaking
news
sotry
that
won
an
award
was
a
story
that
aired
on
June
26,
2008.
In
that
piece,
]
interviewed
a
mother
who’s
daughter
had
been
misidentified
in
a
fatal
automobile
accident.
The
daughter
actually
had
not
taken
the
trip
as
planned,
but
instead
had
gone
camping
in
the
wilderness
for
a
week,
while
mom
had
a
funeral
and
buried
the
person
that
she
thought
was
her
daughter.
It
ws
a
very
emotional
story.
Even
now
I
have
goosebumps
telling
it.
The
WYBU
producer
at
the
time
for
the
Evening
News,
Tetry/Terti
Fyde,
wanted
me
to
present
the
story
in
the
traditional
manner.
I
thought
the
story
had
more
impact
by
showing
my
emotional
involvement
in
the
story.
After
interviewing
the
mother,
I
went
back
to
the
studio
and
filmed
a
close
up
of
me
with
a
tear
rolling
down
my
cheek.
Then
I
added
that
clip
to
the
story.
Fyde
suggsted
that
it
crossed
the
ethical
line.
I
didn’t
see
it
that
way.
I
was
emotionally
moved
by
the
story,
even
choked
up,
so
there
was
nothing
unreal
about
it.
Besides,
the
ethical
line
keeps
changing,
and
you
have
to
adjust
with
the
times.
We
filmed
the
interview
of
the
mother
on
June
17,
2008,
and
the
following
day
Terry/Terri
and
I
argued
back
and
forth
about
keeping
the
clip
of
my
tears
in
or
out
of
the
story.
On
June
25",
when
Terry/Terri
learned
that
T
had
put
the
clip
back
in
the
story,
he/she
insisted
that
as
producer,
he/she
had
the
final
say.
So,
I
approached
the
station
manager,
Daryl
Licht,
and
explained
the
effect
I
was
trying
to
achieve
by
adding
that
clip
to
the
story.
Itold
Daryl
that
Terry/Terri
was
out-dated
with
old-fashioned
ideas
about
news
reporting.
Daryl
sided
with
me.
Terry/Terri
was
unwilling
to
make
any
compromise.
He/She
shouted
at
Daryl.
It
was
ugly.
I'was
not
surprised
when
Daryl
fired
Terry/Terri
with
the
way
he/she
talked
to
him.
Plus,
it
was
Terry/Terri’s
time
to
go
—
he/she
had
outlived
his/her
relevancy
in
the
ever-changing
world
of
news
reporting.
The
story
aired
on
June
26",
and
received
the
SPT
Award
for
Best
TV
-17-
O
00~
O
UL
WD
Investigative
Reporting.
I
also
did
an
exposé
on
“No
Apologies”
on
the
infestation
of
bed
bugs
in
hotels.
Twas
the
first
news
reporter,
locally
and
nationally,
to
break
the
story.
Iapproached
it
like
any
other
investigative
reporting
news
story.
Idid
thorough
research
to
learn
about
bed
bugs
—
what
they
look
like,
their
habits,
how
they
can
be
detected,
the
effect
and
treatment
of
their
bites,
and
hotel
protocols
for
detecting
bed
bug
infestations.
After
doing
some
initial
research,
I
met
with
Dr.
Reed
Tayne
on
June
4,
2008.
Dr.
Tayne
not
only
is
a
dermatologist,
but
he/she
also
has
a
background
in
entomology,
so
he/she
was
a
valuable
resource.
I
gave
Dr.
Reed
a
$2,000.00
check
from
WYBU
as
a
retainer
for
his/her
expertise
for
the
story.
Dr.
Reed
was
unable
to
provide
me
with
names
of
bed
bug
victims,
naturally
due
to
confidentiality
issues,
so
I
returned
on
June
9*
and
provided
Dr.
Tayne
with
a
flyer
to
provide
to
patients
with
bed
bug
bites.
Exhibit
1
is
a
true
and
accurate
copy
of
the
flyer.
The
following
day,
I
filmed
an
interview
with
an
exterminator,
Ilearned
that
bed
bugs
can
travel
on
luggage
and
clothing
from
one
hotel
to
another
hotel.
The
exterminator
showed
me
pictures
of
the
bugs
and
of
a
mattress
and
bedding
that
showed
the
bed
bugs
hiding
in
the
folds
of
the
mattress
and
the
stains
they
leave
behind.
He
told
me
where
hotels
should
be
looking
to
find
evidence
of
a
bed
bug
infestation,
and
the
reasonable
steps
a
hotel
should
use
for
the
detection
and
prevention
of
a
bed
bug
infestation,
After
meeting
with
the
exterminator,
I
felt
knowledgeable
enough
to
detect
the
signs
of
a
bed
bug
infestation
for
my
investigative
report.
Later
that
day,
I
scouted
out
several
cheap
or
seedy
hotels
in
the
area
that
likely
would
have
an
infestation
problem,
On
June
14®,
using
my
producer,
Terry/Tetri,
as
the
front
person,
we
booked
a
hotel
room
in
one
of
those
cheap
motel/hotels.
Ilooked
at
the
bed
linens,
pulled
the
bed
sheets
back
and
looked
at
the
matttesses,
but
we
didn’t
find
any
evidence
of
bed
bugs.
When
you’re
breaking
the
story
without
some
news
tip,
sometimes
it
just
takes
time
to
uncover
it.
So,
the
next
day,
June
15%,
we
went
to
another
cheap
motel,
this
time
we
booked
three
rooms
to
increase
the
odds
—
same
inspection,
same
results.
Nothing.
The
following
day,
June
16",
we
struck
out
again
with
the
three
rooms
at
a
different
cheap
hotel.
The
following
week,
on
June
21%
and
22™,
we
went
to
two
different
cheap
hotels
and
booked
four
rooms
at
each.
No
signs
of
bed
bugs.
Terry/Terri
and
Daryl
both
were
getting
pushy
about
getting
the
story.
WYBU
had
invested
some
money
in
it
and
we
weren’t
getting
very
far
with
finding
either
hotels
with
infestations
or
victims.
Daryl
told
me
that
if
we
didn’t
have
a
story
soon
on
bed
bugs,
he
was
going
to
can
it.
1never
said,
“Maybe
we
should
just
plant
some
bed
bugs.”
On
June
23,
2008,
I
met
with
a
dog
trainer
who
uses
canineés
to
detect
bed
bugs.
Ilearned
that
canine
scent
detection
is
an
excellent
way
to
inspect
hotels
with
hundreds
of
rooms.
A
dog
could
check
a
certain
number
of
rooms
on
weekly
or
monthly
basis,
potentially
catching
bed
bug
infestations
in
the
very
eatly
stages.
Very
few
hotels
use
dogs
as
part
of
a
prevention
program
for
bed
bug
infestation.
The
disadvantage
of
canine
scent
detection
is
that
the
dogs
cost
about
$10,000.00
a
piece,
so
there
are
only
a
few
dogs
to
go
around.
The
dog
trainer
showed
me
how
she
trains
the
dogs
using
live
bed
bugs.
The
dogs
can
only
detect
live
bed
bugs.
The
trainer
had
a
vial
or
test
tube
with
live
adult
bed
bugs.
She
then
let
them
loose
on
a
mattress.
The
dog
is
then
trained
to
locate
the
bed
bugs.
I
had
only
seen
pictures
of
the
bed
bugs,
so
I
was
happy
18-
DD
o
et
b
et
e
e
OWVWEONAUNAEARNROWVWR-JRAUNAWN
—
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—
W
L)
W
W
L
D
L
W
SRESEEERUETREY
when
the
trainer
handed
me
a
vial
of
live
adult
bed
bugs
to
look
at
more
closely.
Idid
not
keep
the
vial
of
bed
bugs.
In
the
meantime,
Terry/Terri was
fired
and
my show
on
the
misidentified
daughter
aired
on
June
26",
Bven
before
the
show
received
the
award,
I
knew
it
was
really
god
stuff.
Ihad
seen
a
web
advertisement
for
a
news
host
with
Global
Broadcast
Company
(GBC),
called
“Justice
Prevails.”
1
thought
I
was
just
the
sort
of
person
they
needed
as
the
host
for
a
show
to
20
toe-to-toe
with
Nancy
Grace.
Isent
a
couple
of
my
tapes
from
“No
Apologies”
—
the
Teen
Texting
and
Driving
Accident
story
and
the
Misidentified
Fatality
Victim,
It
was
a
stressful
week
the
following
week.
I
was
anxious
if
I
would
be
called
for
an
interview
with
GBC,
I
no
longer
had
a
producer,
and
I
was
under
pressure
to
get the
bed
bug
story
wrapped
up.
Plus,
it
was
the
4
of
July
weekend,
and
my
family
was
coming
up
from
Tupelo
to
visit.
1had
booked
5
rooms
for
my
family
at
the
prestigious
Le
Condé
Inn
in
Indianapolis.
We
celebrated
the
4"
as
a
family
at
Le
Condé.
The
hotel
had
a
lot
of
activities
for
the
4™
festivities.
I
tried
to
unwind
from
the
stress,
and
apparently
became
pretty
inebriated
that
evening
at
the
hotel,
Iremember
the
hotel
providing
its
limousine
driver
to
return
me
home.
I
don’t
recall
much
of
anything
else
from
that
night.
I
certainly
don’t
remember
saying
anything
threatening
to
anyone.
Besides,
how
much
stock
are
you
going
to
put
into
what
a
drunk
says?
I
don’t
recall
much
from
the
following
day
either.
Ihad
a
hangover,
and
therefore
wasn’t
the
most
pleasant
person
to
be
around.
Iwas
upset
that
the
hotel
charged
me
more
than
the
room
rate
quoted
to
me
when
I
made
the
reservations.
But,
the
manager,
Mr./Ms.
Garnier
made
some
accommodations,
and
gave
me
a
free
night’s
stay
to
use
whenever
I
wanted.
Iheld
no
grudge
against
Le
Condé.
It
sounds
like
I
was
the
jerk.
Also,
I
had
a
reservation
already
booked
for
a
co-worker’s
wedding
reception
at
Le
Condé
for
July
12%.
If
T
held
a
grudge,
why
wouldn’t
I
have
just
cancelled
that
reservation?
On
Monday,
July
7",
Justin/Justine
Case
of
GBC
called
me
to
schedule
an
interview
in
New
York
City
for
the
host
position
of
“Justice
Prevails.”
1
was
thrilled
—
this
was
my
big
break.
But
I
still
had
work
to
do
at
WYBU
-
especially
my
bed
bug
story.
Later
that
day,
called
Dr.
Tayne
and
inquired
if
he/she
had
seen any
bed
bug
bite
victims,
and
whether
there
was
any
way
I
could
obtain
their
names
and
addresses.
I
was
disappointed
that
no
victims
had
contacted
me
from
the
flyers
that
were
distributed,
and
I
was
equally
disappointed
that
I
had
not
yet
found
a
hotel
with
live
bed
bug
infestation.
Sure,
there
were
other
ways
to
go
with
the
story.
I
could
have
made
it
an
educational
piece
—
what
to
look
for,
precautions
one
should
take,
but
I
wanted
it
more
dramatic.
I
wanted
the
hotel
industry
to
be
on
guard
that
“Big
Brother”
was
watching
and
so
they
better
have
good
safeguards
in
place.
It’s
always
better
to
have
a
victim
in
an
exposé.
The
next
day,
July
8%,
I
called
Dr.
Tayne
to
set
up
a
time
to
interview
him/her
for
the
news
story.
Iwas
prepared
to
just
make
the
story
an
educational
piece
rather
than
an
exposé,
There
would
always
be
a
breaking
story
another
day.
Iinterviewed
Dr.
Tayne
on
July
9.
The
interview
with
Dr.
Tayne
went
well,
and
I
knew
I
could
package
the
story
to
make
it
appeal
to
our
audience.
-19-
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1
flew
out
to
New
York
early
the
next
morning
for
the
interview
with
GBC.
The
interview
was
a
success.
The
General
Manager,
Justin/Justine
Case,
was
impressed
with
the
tapes
I
had
submitted.
He/She
was
equally
impressed
with
my
style.
He/She
said
they
were
looking
for
someone
edgy
like
me.
Iwas
confident
throughout
the
entire
interview.
Ieven
told
Mr./Ms.
Case
that
I
was
working
on
the
bed
bug
infestation
story,
and
I
offered
to
give
him/her
a
copy
of
the
tape
when
it
aired.
Mr./Ms.
Case
was
interested
and
I
thought
it
might
factor
into
his/her
decision.
It
was
a
promise
I
intended
to
keep.
I
thought
for
sure
that
would
lock
in
the
position
for
me
as
the
host
of
“Justice
Prevails.”
Not
only
would
I
be
the
star
[
was
destined
to
become,
it
would
also
be
lucrative.
GBC
was
paying
$1.5
million
for the
host
of
the
show.
It
was
a
substantial
increase
from
my
$155,000.00
salary
at
WYBU.
I
was
exhausted
when
1
arrived
at
Le
Condé
on
Friday,
July
11%.
Iput
on
soft
background
music,
pulled
the
drapes,
and
just
relaxed.
The
wedding
reception
the
following
day
was
fun.
Iran
into
Terry/Terri
Fyde
at
the
wedding
reception.
He/She
acted
nervous.
Istayed
out
pretty
late
at
the
reception,
and
was
exhausted
when
I
finally
turned
in
for
the
evening,
When
I
woke
up
the
next
morning
in
my
hotel
room
at
Le
Condé,
I
had
bite
marks
all
over
my
arms,
legs,
back
and
hands.
Exhibit
2
is
a
true
and
accurate
copy
of
some
of
the
bed
bug
bites
[
received
while
staying
at
Le
Condé.
Icouldn’t
stop
scratching.
Iwas
in
excruciating
pain.
My
body
felt
as
if
it
was
on
fire.
I
just
wanted
to
tear
it
off!
Ithought
the
bites
looked
like
the
pictures
of
bed
bug
bites
that
Dr.
Tayne
had
shown
me.
So
I
pulled
back
the
duvet
cover
to
check
the
bed
linens.
Inoticed
the
blood
on
the
bed.
Ibecame
very
upset
and
alarmed,
I
then
pulled
back
the
sheets
and
saw
a
mass
of
bed
bugs
scurrying
around
on
the
mattress
and
dark
reddish-brown
spots
all
over
the
mattress.
Exhibits
3
and
4
are
photographs
of
the
bed
bugs
that
were
present
in
my
hotel
room
at
Le
Condé
Inn,
Exhibit
5
is
a
photograph
of
the
bed
bug
infested
mattress
in
my
hotel
room
at
Le
Condé
Inn.
I
immediately
called
the
hotel’s
front
desk
and
reported
the
incident.
I
also
called
my
camera
crew
to
film
the
bugs,
mattresses
and
my
bites.
While
I
never
intended
to
be
the
victim
of
my
bed
bug
story,
that’s
what
happened.
‘When
the
hotel
manager
came
to
the
room,
he/she
was
very
apologetic
for
exposing
me
to
bed
bugs
and
causing
my
suffering.
He/She
offered
to
set
me
up
in
a
different
room,
give
me
a
week’s
stay,
clean
my
luggage
and
clothing
with
hot
water,
and
take
me
to
get
medical
care.
I
declined
Le
Condé’s
offers.
Instead,
[
went
to
the
person
I
trusted
most.
Dr.
Tayne.
Dr.
Tayne
examined
me
and
confirmed
my
sores
were
bed
bug
bites.
He/She
noted
that
I
was
one
of
the
rare
individuals
who
had
a
severe
allergic
reaction
to
bed
bug
bites.
He/She
gave
me
prescriptions
for
an
antihistamine
and
steroid
to
reduce
my
allergic
reaction,
and
an
ointment
and
an
antibiotic
to
prevent
secondary
infection.
I
continued
being
treated
by
Dr.
Tayne
twice
a
week
for the
next
two
weeks.
Eventually,
the
pain
and
sores
subsided.
Thave
some
scarring
on
my
back
form
the
bed
bug
bites.
1
did not
look
for
bed
bugs
at
the
Le
Condé
during
my
hotel
stay
until
I
woke
up on
Sunday
morning
with
the
bites.
Iknew
how
to
check
for
bed
bugs;
I
simply
didn’t
think
to
do
it.
1
was
tired
from
travelling
on
Friday,
and
on
Saturday
I
had
stayed
out
late
for
the
wedding
reception.
Plus,
this
was
a
prestigious
hotel
—
I
would
have
assumed
that
they
would
have
exercised
reasonable
care
to
prevent
bed
bug
infestations.
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el
e
e
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IR=N
On
Monday,
July
14",
T
had
the
camera
crew
re-film
the
bites
and
sores
I
received.
The
sores
had
become
worse
due
to
my
severe
allergic
reaction,
and
some
of
the
sores
had
become
infected
from
scratching.
The
bed bug
hotel
infestation
exposé
aired
on
“Ne
Apologies”
on
Thursday,
July
17",
Exhibit
6
is
a
true
and
accurate
copy
of
a
part
of
the
transcript
from
that
show.
Isent
a
copy
of
the
tape
to
GBC
that
same
day
by
overnight
courier.
On
Sunday,
July 20®,
a
newspaper
article
appeared
in
the
front
page
of
the
Indianapolis
Star
quoting
Mr./Ms.
Garnier,
the
Hotel
Manager
for
Le
Condé,
that
I
had
fabricated
the
bed
bug
story
by
planting
the
bugs
there
myself.
Exhibif
7
is
a
true
and
accurate
copy
of
the
news
article.
That’s
preposterous
and
an
outright
lie!
Garnier’s
comments
were
defamatory
and
smeared
my
good
name
and
reputation
in
this
community
and
in
the
news
world
as
a
credible
journalist.
Shortly
after
the
news
article
appeared
I
learned
that
GBC
would
no
longer
offer
me
the
host
position
for
“Justice
Prevails.”
Le
Condé’s
claim
that
it
has
been
defamed
is
ridiculous.
Everything
in
my
news
story
is
truthful.
There
is
nothing
defamatory.
Truth
hurts,
On
the
other
had,
Le
Condé’s
statements
to
the
Indianapolis
Star
are
complete
lies!
And
Garnier’s
defamatory
statements
have
caused
me
to
lose
a
career
opportunity
of
a
lifetime
with
earnings
almost
ten
times
my
current
earnings,
besides
the
potential
for
product
endorsements,
and
other
doors
that
could
have
been
opened
to
me.
In
addition,
I'had
to
endure
excruciating
pain
for
weeks,
and
I
have
permanent
scars
from
the
bites.
1
affirm
under
penalty
of
perjury
that
the
foregoing
is
true
and
correct
to
the
best
of
my
belief
and
knowledge.
:
/s/
Quinn
Tessence
QUINN
TESSENCE
21-
O
oI
N
RN~
STATEMENT
OF
REED
TAYNE
My
name
is
Reed
Tayne.
Iam
a
licensed
dermatologist
at
the
Skin
Clinic
Institute
of
Indiana.
Exhibit
8
is
a
true
and
accurate
copy
of
my
curriculum
vitae.
In
addition
to
my
expertise
in
dermatology,
L
have
significant
background
and
experience
in
entomology.
I
earned
my
Bachelor
of
Science
degree
in
Entomology
at
Purdue
University.
I
enhanced
my
knowledge
of
insects
working
as
a
Field
and
Lab
Technician
for
the
USDA
Beneficial
Insect
Laboratories
in
the
biological
control
of
cockroaches.
Ialso
spent
a
short
time
with
E.
I.
DuPont
conducting
field
testing
of
insecticides,
herbicides
and
fungicides.
1
appeared
in
Quinn
Tessence’s
news
story
on
infestation
of
bed
bugs
in
hotels
that
aired
on
WYBU
on
July
17",
2008.
I've
heard
the
piece
has
gone
viral
over
the
Internet.
Thave
gained
some
fame
and
notoriety
because
of
my
appearance
in
the
news
story.
Since
then,
I
have
been
featured
as
an
expert
on
bed
bugs
on
NBC
Dateline,
CBS’s
The
Early
Show,
NBC’s
Today
Show
and
T
have
been
a
repeat
guest
on
National
Public
Radio
(NPR).
Iexpect
to
continue
my
guest
appearances
in
the
immediate
future
because
the
bed
bug
problem
is
epidemic.
I'have seen
an
increase
in
people
with
bedbug
bites.
In
2010,
I
also
edited
the
Bed Bug
Chapter
in
the
dermatology
industry’s
most
well
respected
textbook
reference,
The
Handbook
of
Investigative
Dermatology,
10th
Edition.
1'd
like
to
think
that
I
was asked
to
contribute
to
the
reference
book
because
of
my
blend
of
backgrounds
in
entomology
and
dermatology,
but
I
wasn’¢
very
well
known
among
my
peers
until
Quinn’s
news
repost
on
bed
bugs.
This
has
been
a
lucrative
side
career
and
T
am
scaling
back
on
scheduling
appointments
in
my dermatology
practice.
Tam
looking
into
consulting
and
expert
witness
testimony
in
bed
bug
cases.
Iam
currently
engaged
in
discussions
with
a
plaintiff’s
lawyer
in
a
case
involving
a
Chicago
woman
who
is
suing
a
New
York
hotel
for
$20
million
after
she
woke
up
in
her
bed
with
over
600
bed
bug
bites.
Bed
bugs,
Cimex
lectularius,
are
reddish-brown,
oval-shaped,
flattened
insects
that
are
about
1/4
inch
long.
Nymphs
(immature
bed bugs)
resemble
the
adult
bugs
but
are
often
smaller
and
lighter
in
color.
Exhibits
3
and
4
are
true
and
accurate
photographs
of
bed
bugs.
The
adults
appear
more
reddish
after
feeding
on
blood
meal.
The
nymphs
will
appear
bright
red
after
feeding.
Bed
bugs
require
blood
in
order
to
reproduce
and
coraplete
their
life
cycle.
There
are
five
larval
stages,
and
each
one
requires
a
blood
meal
before
molting
into
the
next
life
cycle
stage.
Both
adult
male
and
female
bed
bugs
feed
on
blood
and
take
repeated
blood meals
during
their
lives.
Females
require
blood
for
the
development
of
eggs.
The
five
larval
stages
are
completed
in
about
a
month
under
suitable
conditions
of
temperature,
humidity,
and availability
of
hosts
for
blood
meals.
Larvae
can
survive
inside
dwellings
for
several
months
without
a
blood
meal,
but
they
do
not
molt
into
the
next
life
cycle
stage
until
they
engorge
on
blood.
Adults
can
survive
even
longer
under
the
same
conditions,
but
do not
develop
eggs
unless
they
feed
on
blood.
Bed
bugs
usually
feed
on
the
blood
of
humans
during
the
nighttime
hours
and
crawl
away
during
the
day
to
hide
in
nearby
cracks,
crevices
and
recesses
of
furniture,
especially
mattresses.
Bed
bugs
detect
carbon
dioxide
emitted
from
warm-blooded
animals
and
respond
to
warmth
and
moisture
as
they
approach
the
potential
host.
On
humans,
they
tend
to
feed
on
exposed
surfaces
such
as
the
face,
neck, arms,
hands
and
back.
A
peculiarity
of
bed
bug
bites
is
22
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el
e
e
el
e
D001
AN
HE
WNEOWIAWUL
S
WN
-
BB
N
NI
NNk
LN
=
O
W
N
S
o
oo
02
—
W
W
W
e
W
[«
R
RSNVt
)
AR
W
W
W
W=
O
Ww
ool
NN
O
B
the
tendency
to
find
several
pink
bumps
lined
up
in
a
row
with
central
red
spots
through
which
blood
is
sucked.
Dermatologists
refer
to
this
as
the
"breakfast,
lunch, and
dinner"
sign,
recognizing
the
sequential
feeding
that
occurs
from
site
to
site.
The
effect
of
bed
bug
bites
varies
among
people,
but
they
eventually
produce
red
welts
that
itch,
If
scratched,
the
bite
areas
can
become
infected.
The
bites
themselves
are
not
painful
and
typically
are
not
felt.
Frequent
feeding
can
disrupt
people’s
sleep
and
make
them
irritable,
and
seeing
bites
may
cause
emotional
distress
in
some
people.
Heavy
rates
of
feeding
can
result
in
significant
blood
loss
and
eventually
lead
to
anemia.
At
least
27
agents
of
human
disease
have
been
found
in
bed
bugs,
including
viruses,
bacteria,
protozoa,
and
parasitic
worms.,
None
of
these
agents
reproduce
or
multiply
within
bed
bugs,
and
very
few survive
for
any
length
of
time
inside
a
bed
bug.
Most
people
experience
itching,
pain
and/or
swelling
of
the
skin
where
a
bed
bug
bite
occurs
within
one
day
of
a
bite,
Although
the
bites
can
cause
considerable
!
discomfort
and
loss
of
sleep,
bed
bugs
do
not
transmit
disease
after
feeding
on
multiple
hosts.
A
|
small
percentage
of
people
expetience
significant
allergic
reactions
to
bed
bug
bites,
causing
greater
swelling,
itching,
and
pain.
Treatment
of
the
bed
bug
bites
consists
of
treating
the
itching
and
inflammation
associated
with
the
bites.
Antihistamines
and/or
corticosteroids
may
be
prescribed
to
reduce
allergic
reactions.
Antimicrobial
ointment
or
antibiotics
may
prevent
secondary
infection,
Bed
bugs
are
sometimes
thought
to
occur
only
in
poor
and
unsanitary
conditions,
This
is
not
the
case.
Bed
bugs
can
be
found
even
in
very
clean
environments.
Eradication
of
a
bed
bug
infestation
is
difficult
and
should
be
performed
with
the
help
of
a
professional
pest
control
company.
Hotels
have
seen
a
significant
rise
in
bed
bug
infestations.
While
the
elimination
of
DDT
has
contributed
to
the
problem,
in
my
opinion,
the
fault
clearly
lies
with
the
hotel
industry.
The
hotel
industry,
in
the
past
several
years
in
light
of
a
difficult
economy,
has
cut
staff,
One
critical
reduction
of
staff
has
been
in
housekeeping.
Housekeeping
no
longer
is
able
to
follow
guidelines
and
protocol
of
the
hotel
industry
because
1
person
is
doing
the
work
of
2
or
3.
The
housekeeping
staff
is
rushed
to
complete
basic
cleaning
tasks.
Housekeeping
staff
does
not
have
adequate
time
to
look
at
bed
linens
to
see
if
brown,
red
or
dark
specks
indicate
bed
bug
infestation.
They
do
not
have
time
to
look
at
the
crevices
of
the
mattresses
to
check
for
bed
bugs.
So,
when
guests
stay
in
hotels,
it
is
important
to
check
the
beds
for
signs
of
bed
bug
!
infestations
and
to
put
your
luggage
on
a
luggage
rack
rather
than
on
the
bed
or
other
places
where
bed
bugs
like
to
be.
I
met
Quinn
Tessence
on
Wednesday
afternoon,
June
4,
2008,
The
office
is
closed
usually
on
Wednesday
afternoons.
Quinn
had
Googled
me.
My
CV
is
posted
on
Skin
Clinic’s
website.
My
article
that
appeared
in
Pediatrics
Annual
in
2006
on
insect
bites
and
infestations
is
also
referenced
on
the
Internet.
Quinn
learned
that
I
had
a
background
in
entomology
and
dermatology.
Prior
to
meeting
Quinn,
I
was
familiar
with
his/her
notoriety
for
advocating
for
victims
as
an
investigative
reporter
and
news
anchor
for
WYBU.
Ihad
admired
Quinn’s
willingness
to
help
victims
and
expose
those
to
blame.
When
Quinn
called,
he/she
explained
that
he/she
was
doing
a
story
on
the
hotel
industry’s
unsafe
practices
and
the
rise
of
bed
bug
infestations.
Quinn
wanted
to
schedule
a
meeting
with
me
to
explore
the
medical
side
of
bed
-23-
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W
oo
~I
NN
RN~
bug
bites.
I
was
enthusiastic
for the
opportunity
to
meet
him/her
and
contribute
to
the
project.
In
our
initial
meeting,
Quinn
stated
that
he/she
wanted
to
retain
my
services
and
that
I
would
be
compensated
at
the
same
hourly
rate
I
charge
patients
for
examinations,
The
proposition
seemed
fair
to
me
because
I
would
be
taking
away
form
patient
time
when
meeting
with
Quinn.,
Quinn
presented
me
a
check
for
$2,000.00
from
WYBU
as
a
retainer
fee
for
consulting
with
him/her
for
the
investigative
report,
which
I
accepted.
We
spent
two hours
in
that
first
meeting
discussing
bed
bugs
—
their
feeding
habits,
clinical
signs
to
look
for
if
you
have
been
bitten
by
a
bed
bug,
possible
medical
effects
from
bed
bug
bites,
and
treatment.
Ishowed
Quinn
photographs
of
the
bugs
and
their
bites
from
one
of
the
medical
textbooks
I
had
in
my
office.
We
also
discussed
how
hotels
could
use
reasonable
care
to
avoid bed
bug
infestation
with
simple
checks
through
housekeeping
of
the
bed
linens
and
the
mattresses.
Quinn
had
clearly
done
his/her
research
prior
to
meeting
with
me.
He/she
asked
probative
questions
and
was
well
versed
on
the
topic.
Nevertheless,
Quinn
furiously
took
notes
while
I
instructed
him/her
on
bed
bugs.
Quinn
asked
me
if
any
patients
had
recently
presented
to
me
with
bed
bug
bites.
I
told
Quinn
that
I
had
seen
a
significant
increase
in
patients
exhibiting
signs
of
bed
bug
bites
in
the
past
several
months.
Quinn
wanted
me
to
provide
some
names
of
patients
with
bed
bug
bites
so
that
he/she
could
interview
them.
Of
course,
under
HIPPA,
T
couldn’t
provide
confidential
information
regarding
a
patient.
But
I
told
Quinn
that
if
a
patient
came
in
I
could
give
the
patient
Quinn’s
name
and
they
could
contact
him/her
if
they
were
interested.
Quinn
stopped
in
my
office
the
following
Monday,
June
9*
and
dropped
off
a
flyer
for
me
to
provide
to
patients
with
bed
bugs.
Iagreed
to
provide
the
flyer
to
patients
for
them
to
make
a
choice
if
they
wanted
to
discuss
the
matter
with
Quinn.
Quinn
offered
to
pay
me
$100.00
for
every
referral
of
a
patient
with
bed
bug
bites.
I
declined
that
offer.
Exhibit
I
isa
true
and
accurate
copy
of
the
flyer
that
Quinn
provided
to
me.
Quinn
and
I
discussed
some
omitted
questions
that
had
occurred
to
him/her
after
our
initial
meeting.
Quinn
wanted
to
know
how
long
it
took
for
the
bite
to
manifest
itself,
and
how
it
could
be
linked
to
exposure
at
a
hotel
if
there
was
delay
in
the
bite
marks.
I
advised
Quinn
that
the
bites
would
manifest
in
one
day.
So,
ordinarily,
the
bites
would
be
visible
on
the
second
day
following
the
exposure
at
a
hotel
or
elsewhere.
-
Quinn
confirmed
the
facts
for
the
story
that
if
a
guest
stayed
at
a
hotel
for
two
nights
that
the
physical
manifestations
from
the
exposure
to
the
human
body
would
be
visible,
the
hotel
guest
would
still
be
present
at
the
hotel
to
look
for
evidence
of
the
bed
bug
in
the
crevices
of
the
mattress,
and
the
guest
could
report
it
to
hotel
management.
Over
the
next
four
weeks,
I
treated
a
handful
of
patients
with
bed
bug
bites.
I
distributed
the
flyers
to
those
patients.
Quinn
called
me
the
afternoon
of
July
7%
and
inquired
if
I
had
treated
any
patients
with
bed
bug
bites.
I
detected
panic
in
Quinn’s
voice.
Itold
Quinn
Ihad
distributed
the
flyers
to
patients
that
I
treated
with
bed
bug
bites,
and
assumed
if
they
were
interested
in
being
part
of
the
news
story
would
call
him/her.
Quinn
told
me
that
he/she
had
not
received
any
phone
calls
from
people
with
bed
bug
bites.
Quinn
seemed
frustrated.
He/she
remarked
that
he/she
“had
hit
a
wall,”
but
that
he/she
had
“invested
too
much
to
throw
the
story
away.”
Quinn
pleaded
with
me
to
give
him/her
the
name
of
a
patient
or
two
with
recent
bed
bug
bites.
He/she
was
convinced
that
if
he/she
could
talk
to
them,
he/she
could
convince
them
to
open
up,
and
make
a
difference
to
reducing
the
growing
bed
bug
infestation
problem.
I'told
DA-
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O
00~
AN
WA
UGN
e
Quinn
I
would
not
violate
HIPPA
by
disclosing
private
patient
information.
I
suggested
alternatives
to
Quinn,
such
as
using
textbook
pictures
instead
of
videoing
a
patient’s
bites.
Quinn
appreciated
the
suggestion
but
said
that
viewers
relate
to
real
people,
Isuggested
to
Quinn
that
there
was
no
urgency
to
airing
the
story
by
any
specific
date
and
that
the
bed
bug
infestation
was
not
going
to
go
away
overnight.
I
think
Quinn
may
have been
worried
that
someone
else
was
going
to
air
a
similar
story
before
he/she
could.
The
next
day,
Quinn
called
me
to
schedule
a
time
to
meet
on
Wednesday,
July
9™
to
tape
me
for
the
bed
bug
news
story.
Quinn
was
in
much
better
spirits.
We
briefly
discussed
the
questions
that
Quinn
planned
to
ask
me
in
the
interview.
Inever
felt
coached
by
Quinn
to
say
anything
Thadn’t
planned
on
saying
anyway.
Ididn’t
ask
Quinn
how
he/she
was
presenting
the
victim’s
story.
Iassumed
Quinn
had
located
someone
with
bed
bug
bites
~
maybe
even
one
of
my
patients,
who
had
received
a
flyer,
and
decided
to
call.
In
any
event,
on
July
9®,
Quinn
came
to
my
office
with
the
WYBU
camera
crew
for
the
scheduled
interview.
Quinn
made
me
feel
relaxed
in
front
of
the
cameras
and
with
the
crew
adjusting
my
coat
and
microphone.
The
interview
taping
was
like
an
orchestra
playing
a
Mozart
Concerto.
The
questions
and
answers
were
in
a
synchronized
rhythm.
The
voice
inflections,
body
movements,
and
nonverbal
cues
harmonized.
Quinn
was
dynamic
and
energized.
I
could
tell
by
his/her
expressions
and
voice
that
Quinn
was
genuinely
concerned
about
the
victims
of
bed
bug
bites
and
controlling
the
problem
before
it
became
an
epidemic.
It
wasn’t
rehearsed
but
it
came
together
as
if
the
smallest
detail
had
been
planned.
Quinn
said
that
he/she
hoped
to
have
it
aired
the
following
week.
On
Sunday,
July
13%,
Quinn
called
me
at
home
and
said,
unequivocally,
that
he/she
had
bed
bug
bites.
Quinn
certainly
had
enough
information
through
his/her
investigative
reporting
on
the
topic
to
identify
the
cause
for
his/her
itching,
bumps,
and
swelling.
I
met
Quinn
at
my
office
an
hour
later,
and
confirmed
Quinn’s
lay
diagnosis.
Quinn
had
severe
bites,
at
least
150,
all
over
his/her
face,
neck,
hands,
arms
and
back.
Exhibit
2
is
a
true
and
accurate
picture
of
the
bites
[
observed
on
Quinn’s
back.
The
bites
to
his/her
hands,
arms
and
face
were
of
a
similar
nature.
Quinn
showed
signs
of
having
a
severe
allergic
reaction
to
the
bites,
and
was
in
significant
pain.
I
provided
Quinn
with
prescriptions
for
an
antihistamine
and
corticosteroids
to
reduce
his/her
allergic
reaction,
and
antimicrobial
ointment
and
an
antibiotic
to
prevent
secondary
infection.
I
continued
to
see
Quinn
as
a
patient
twice
a
week
over
the
next
two
weeks
to
monitor
the
possibility
of
infection.
Quinn
endured
significant
pain
during
that
period
of
time.
‘While
I
was
examining
the
sores
during
one
of
the
visits,
Quinn
remarked,
“T’d
do
it
all
over
again
to
get
the
story.”
Eventually,
the
bites
dissipated,
and
except
for
a
few
small
scars
on
his/her
back,
Quinn
healed
well,
without
any
long-term
effect.
I
did not
maintain
a
medical
record
for
Quinn
for
the
diagnosis
or
treatment.
I
suppose
I
was
Quinn’s
treating
physician,
but
Quinn’s
visits
seemed
more
like
an
extension
of
the
news
story.
Even
though
I
was
Quinn’s
treating
physician
when
he/she
suffered
from
the
bed
bug
bites,
I
didn’t
charge
Quinn.
Rather,
I
just
charged
the
cost
of
my
services
to
the
retainer
that
Quinn
previously
provided
to
me.
Quinn
has
provided
me
with
a
separate
fee,
however,
for
my
testimony
for
this
statement
and
if
called
to
testify
as
his/her
treating
physician
and
as
an
expert
in
dermatology
and
entomology.
My
fee
for
this
statement
and
trial
testimony
is
$4,000.00
205
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O
001N
R
LN
—_
=
[
—
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——
(O
I
know
there
have
been
accusations
that
Quinn
fabricated
the
story.
I
don’t
believe
it
for
aminute!
Isaw
for
myself
the
severity
of
the
bites
Quinn
received.
That
certainly
wasn’t
fabricated.
And,
Le
Condé
doesn’t
deny
there
were
bed
bugs
in
Quinn’s
hotel
room.
So,
that’s
not
fabricated.
The
idea
that
Quinn
would
purposefully
plant
the
bugs
in
the
room
and
suffer
the
bites
is
illogical.
Why
would
anyone
do
that,
even
to
get
a
story?
I've
spent
some
time
with
Quinn
as
he/she
was
developing
this
story.
If
Quinn
cared
more
about
getting
the
story
and
not
the
facts,
Quinn
would
have
coached
me
more
in
the
interview.
I've
watched
Quinn’s
news
story
on
bed
bug
infestation
and
I
believe
it
is
fairly
presented.
1
affirm
under
penalty
of
petjury
that
the
foregoing
is
true
and
correct
to
the
best
of
my
belief
and
knowledge.
/s/
Reed
Tayne,
MD
REED
TAYNE,
MD
_26-
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e
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STATEMENT
OF
JUSTIN/JUSTINE
CASE
My
name
is
Justin/Justine
Case.
Tam
the
General
Manager
of
the
New
York
office
for
Global
Broadcast
Company
{GBC),
a
global
broadcast
cable
network.
Global
Broadcast
Company
has
grown
exponentially
over
the
past
ten
years.
What
started
as
a
single
London
station
became
the
company
responsible
for the
first
global
broadcast
cable
television
network.
GBC’s
business
has
appeal
in
the
global
markets,
particularly
the
European
markets.
GBC
has
been
expanding
its
market
in
the
States,
and
opened
a
New
York
office
five
years
ago
to
concentrate
our
efforts
in
appealing
to
the
American
market,
Between
our
London
and
New
York
offices,
GBC
stays
connected
equally
with
its
audiences
and
their
viewing
wants
and
needs.
In
2008,
GBC’s
strategic
plan
was
to
target
certain
primetime
audiences.
GBC’s
philosophy
is
that
to
stay
relevant,
you
have
to
reinvent.
GBC
continues
to
rebrand
and
reinvigorate
its
established
programming.
GBC’s
2008
strategic
plan
included
a
news
exposé
to
be
scheduled
opposite
Nancy
Grace
at
8
pm
and
10
pm
daily.
The
program
would
be
credible
news
reports
but
expose
industries
and
people
for
bad
practices
or
acts.
No
one
or
industry
was
above
reproach.
I
transferred
from
the
GBC
London
office
to
become
the
first
General
Manager
of
the
GBC
New
York
office
in
2005.
Thave
twelve
years
of
professional
tenure
including
project
management,
newsroom
staff
training
and
management,
contract
negotiations,
and
board
governance.
Lhave
a
proven
track
record
of
award-winning
writing,
producing,
editing,
reporting,
anchoring,
and
management.
1
was
born
and
raised
in
Liverpool
in
the
UK
(United
Kingdom).
I
graduated
from
the
National
Broadcasting
School
in
Liverpool.
For
several
years,
I
worked
as
a
writer,
and
later
producer,
in
radio
broadcasting.
I
wanted more
from
my
career,
so
I
returned
to
school
and
subsequently
received
an
MLA.
in
Television
Journalism
from
Goldsmiths,
University
of
London.
The
Department
of
Media
and
Communications
at
Goldsmiths
is
one
of
the
UK’s
leaders
in
the
field
of
media
theory
and
media
practice.
After
receiving
my
M.A.,
I
started
my
career
at
GBC
in
London
for
seven
years,
rising
up
in
the
ranks
until
I
received
a
transfer
to
GBC
in
New
York.
Ihave
been
working
in
New
York
at
GBC
for
five
years
as
the
General
Manager.
As
the
General
Manager,
I
routinely
recruit,
train,
cultivate,
and
manage
freelance,
temporary,
and
contract
writers,
editors,
producers,
reporters,
anchors,
and
hosts
maintaining
a
high
quality
control
standard
while
ensuring
expenses
remain
within
budget.
It
is
my
job
to
coordinate
news-gathering
resources
and
to
shape
the
content
of
the
broadcast,
exercising
final
editorial
control.
GBC
of
New
York
has
received
the
Edward
R.
Murrow
Award
and
George
Foster
Peabody
Award
to
my
credit.
Ifind
my
career
gratifying.
But,
don’t
get
me
wrong
-
I
do not
intend
to
glamorize
the
world
of
the
broadcast
network
industry.
It
is
not
for
the
faint
of
heart.
Long
hours,
tight
deadlines,
frazzled
nerves, and
chronic
under
staffing
often
result
in
emotional
outbusts,
which
are
a
daily
occurrence
at
GBC,
or
any
other
network.
News
anchors,
reporters,
and
correspondents
gather
information,
prepare
stories,
and
make
broadcasts
that
inform
the
27~
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DO
B
B
b
=
el
e
e
e
e
e
L)
U3
L
WD
L)
W
LY
LW
public
about
local,
State,
national,
and
international
events;
present
points
of
view
on
current
issues;
and
report
on
the
actions
of
public
officials,
corporate
executives,
interest
groups,
and
others
who
exercise
power,
News
anchors
or
hosts
examine,
interpret,
and
broadcast
news
received
from
various
sources.
News
anchors
or
hosts
present
news
stories
and
introduce
videotaped
news
or
live
transmissions
from
on-the-scene
reporters.
In
June,
2008,
we
decided
to
implement
our
strategic
plan
for
a
prime
time
news
exposé.
We
had
performed
test
markets
on
focus
groups,
The
show
would
be
called
Justice Prevails.
The
position
for
host
of
the
show
was
advertised
on
our
website,
and
we
had
contacted
specific
higher
profile
personalities
for the
position.
GBC
was
looking
for
someone
who
was
“edgy.”
Our
ratings
had
slipped
to
some
of
the
other
networks.
To
keep
the
andience
attention
and
have
them
turn
the
channel
to
our
network
every
day,
we
needed
someone
who
offered
a
dramatic
flair
and
wasn’t
afraid
to
take
an
occasional
risk.
Our
records
show
that
on
June
27%,
Quinn Tessence
submitted
his/her
tapes
from
a
television
station
out
of
Indianapolis,
WYBU.
I
do
not
recall
now
the
specifics
of
the
tapes
that
were
submitted;
I
saw
so
many
from
numerous
candidates
at
the
time.
Iknow,
however,
that
based
upon
Quinn’s
tapes,
we were
impressed
enough
to
bring
him/her
to
GBC
for
an
interview.
There
were
only
two
other
candidates
that
made
the
same
cut.
Quinn’s
tapes
stood
out
above
all
the
others,
however.
Quinn’s
tapes
showcased
his/her
flair
for
the
dramatic,
if
not
theatrical,
presentation
of
the
story.
The
exposés
were
cutting-edge.
That’s
what
we
were
looking
for
in
a
host
for
Justice
Prevails.
In
this
day and
age
of
technology,
news
is
available
from
a
variety
of
sources
24/7,
365
days
a
week.
Our
audiences
don’t
want
just
ordinary
news
anymore,
They
want
sensationalism.
After
reviewing
Quinn’s
tapes,
I
studied
Quinn’s
market
appeal
in
Indianapolis.
Quinn’s
audiences
responded
to
him/her
as
well.
Most
viewed
Quinn
favorably
as
his/her
persona
was
as
a
victim’s
rights
advocate
—
someone
who
was
“for
the
people.”
Regardless
of
whether
viewers
perceived
Quinn
favorably
or
unfavorably,
he/she
had
people’s
attention
and
they
tuned
into
him/her
at
WYBU.
WYBU’s
ratings
and
market
share
in
the
Indianapolis
market
had
increased
by
4
times
since
Quinn
had
joined
the
WYBU
team.
I
contacted
Quinn
on
Monday
morning,
July
7,
2008
and
interviewed
him/her
in
New
York
on
Thursday,
July
10,
2008.
The
interview was
equally
impressive.
Quinn
has
a
nose
for
news,
persistence,
initiative,
poise,
resourcefulness,
a
good
memory,
and
physical
stamina,
as
well
as
the
emotional
stability
to
deal
with
pressing
deadlines,
irregular
hours,
and
dangerous
assignments.
Quinn
is
intelligent,
but
in
a
way
that
is
relatable
to
viewers.
Quinn
has
street
smarts,
too.
Quinn
thinks
outside
the
box
to
solicit
information
from
news
sources.
As
a
reporter
ot
host,
Quinn
could
corner
even
the
toughest
interviewee.
Quinn
is
confident,
almost
cocky.
Quinn
could
be
condescending
too,
if
you
were
the
target
of
his/her
exposé,
Quinn
was
definitely
edgy.
In
the
interview,
it
was
clear
that
Quinn’s
outspoken
style,
and
brashness
with
his/her
adversaries,
would
be
an
asset
for
Justice
Prevails.
Quinn
was
the
fresh
face
we
needed.
T
even
did
some
test
runs
of
Quinn
in
front
of
our
cameras.
Tusually
don’t
take
the
time
for
camera
test
runs
if
I'm
not
inclined
to
hire
the
person.
After
the
test
run,
I
readily
recognized
that
Quinn
would
be
comfortable
on
camera
as
the
host
of
our
show.
I
advised
Quinn
that
a
decision
would
be
made
within
the
next
two
weeks.
At
the
time
of
228-
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el
N
e
R
SR
Quinn’s
interview,
there
were
two
other
candidates
that
I
had
planned
to
interview,
who
were
equally
impressive,
even
though
their
reporting
styles
may
not
have
been
as
theatrical.
But
GBC
was
also
teetering
on
finding
the
right
balance
of
capturing
the
audience
attention
versus
the
shock
factor
employed
by
some
less
credible
“news”
outlets
and
television
programming.
GBC’s
tag
line
is
“news
you
can
trust.”
We
didn’t
want
to
lose
sight
of
that.
We
still
wanted
to
report
and
present
the
news
credibly,
albeit
dressed
up
a
little
more.
Some
were
concerned
that
Quinn
was
maybe
more
edgy
than
the
direction
we
had
planned
to
go.
During
the
interview,
Quinn
described
to
me
a
project
he/she
was
currently
working
on
for
WYBU.
It
was
an
exposé
on
the
hotel
industry’s
standards
in
housekeeping,
and
specifically
bed
bug
infestation
in
hotels.
Quinn
claimed
that
his/her
investigative
journalism
had
uncovered
that
housekeeping
staff
were
given
unreasonable
quotas
for
cleaning
rooms.
Consequently,
Quinn
said
the
staff
was
often
rushed
and
failed
to
do
their
jobs
properly
for
a
clean,
sanitary,
and
healthy
environment.
Quinn
said
the
exposé
would
show
that
housekeeping
staff
did
not
follow
hotel
policies
by
examining
beds
for
signs
of
bed
bug
infestation.
The
exposé
was
to
include
footage
of
hotel
beds
infested
with
bed
bugs, and
victims
with
bed
bug
bites.
Quinn
agreed
to
provide
me
with
the
footage.
I
was
interested
in
the
story
because
at
that
time,
to
my
knowledge,
it
had
not
been
covered
globally
or
nationally.
At
the
time
of
the
interview,
I
had
no
intention
of
factoring
in
the
bed
bug
exposé
in
my
hiring
decision.
However,
I
suppose
Quinn
may
have
thought
it
was
critical
to
my
decision
for
the
position.
I
was
more
curious
than
anything.
I
had
heard
some
talk
about
New
York
hotels
with
bed
bug
problems.
No
one
else
had
thought
to
cover
the
story
at
the
time.
Now
it
is
big
news,
of
course.
[
wish
now
GBC
had
broken
the
story.
Quinn
delivered
on
his/her
promise
to
send
me
a
copy
of
the
tape
of
his/her
exposé
on
the
bed
bug
problem
of
hotels.
Ireceived
an
overnight
package
of
the
story on
July
18",
Quinn’s
note
along
with
the
tape
said
that
the
piece
had
aired
on
WYBU
on
July
17,
Actually,
that
was
pretty
good
timing
on
Quinn’s
part
because
that
gave
me
the
weekend
to
review
the
entire
piece.
Typically
my
hectic
schedule
would
allow
time
for
a
look
at
only
a
brief
clip.
Also,
I
had
completed
the
last
of
the
interviews
for
the
prime
time
host
position
on
that
same
Friday,
the
18"
Upon
reviewing
the
tape,
I
was
reminded
of
Quinn’s
abilities
and
style.
I
thought
the
story
had
some
real
appeal.
It
was
gritty,
and
would
be
universally
interesting
to
viewers
because
it
didn’t
just
target
the
cheap
hotels,
but
targeted
even
a
premier
hotel
like
the
Le
Condé.
1have
to
admit,
I
was
a
bit
taken
aback
that
Quinn
was
the
victim
in
the
story.
Reporters
or
anchors
aren’t
the
news
themselves,
rather
they
only
present
the
news.
But
in
this
case,
it
really
personalized
Quinn
with
the
viewers,
and
perhaps
this
was
the
type
of
edge
we
needed
to
increase
our
market
share.
GBC
has
succeeded
by
trying
to
be
different
and
doing
things
no
one
expected.
Quinn’s
bed
bug
exposé
put
him/her
over
the
top
in
my
view.
Quinn
was
my
number
one
choice,
Quinn
was
the
quintessential
persona
for
the
GBC
Justice
Prevails
host
position.
Thad
planned
on
meeting
with
the
Executive
Producer
and
News
Director
on
Monday,
July
21%,
to
make
my
recommendation
in
favor
of
hiring
Quinn.
However,
as
I
mentioned,
there
were
two
other
candidates
for
consideration.
If
the
other
decision-makers
thought
Quinn’s
style
was
too
brash,
another
candidate
might
be
preferred.
The
News
Director
had
expressed
some
concerns
to
me
that
Quinn’s
outspoken
nature
could
invite
lawsuits.
Also,
one
of
the
other
-29-
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W
LI
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W
BB
R
B
DN
PR
=
e
e
e
e
e
e
candidates
would
be
a
hire
from
within
GBC
—
one
was
a
foreign
correspondent
of
GBC,
the
other
candidate
hosted
our
Just
In
Time
in
the
early
morning
time
slot
The
candidate
currently
hosting
Just
In
Time
had
a
certain
celebrity
quality
with
an
established
audience
who
likely
would
follow
him
to
the
evening
time
slot
and
show.
In
addition,
he
had
worked
with
our
executive
producer
and
therefore
was
a
known
quantity.
But
I
thought
we
needed
a
new
face
or
persona.
I
felt
confident
we
would
hire
Quinn
because
my
hiring
recommendations
are
usually
followed
-
-
but
not
always.
Our
London
Office
was
the
final
decision
maker.
On
Monday,
July
21,
2008,
I
received
an
anonymous
voicemail
that
advised
me
to
check
the
online
addition
of
the
Indianapolis
Star
for
a
story
about
Quinn
Tessence.
Idid
just
that.
Exhibit
7
is
a
true
and
accurate
copy
of
the
news
article.
Ilearned
that
Le
Condé
accused
Quinn
and
WYBU
of
fabricating
the
story.
Le
Condé
didn’t
deny
that
bed
bugs
were
found
in
Quinn’s
room,
but
rather
questioned
how
the
bugs
got
there.
The
voicemail
also
described
a
separate
incident
where
Quinn
edited
a
piece
to
fake
a
tear
in
reaction
to
a
story.
In
any
event,
the
accusations
made
by
Le
Condé’s
hotel
manager,
Jacqué
Garnier,
killed
the
deal
for
Quinn
to
host
Justice
Prevails.
Reporters,
anchors,
and
hosts
should
be
dedicated
to
providing
accurate
and
impartial
news.
Accuracy
is
important
both
to
serve
the
public
and
because
untrue
or
libelous
statements
can
lead
to
lawsuits.
1
notified
the
other
decision-makers
to
pull
Quinn
from
consideration
for
the
host
position.
Talways
had
a
back-up
plan,
just
in
case
it
didn’t
work
out
with
Quinn.
So,
later
that
day,
we
made
the
decision
to
promote
from
within
and
offer
the
position
to
our
foreign
correspondent,
Lara
Morgan,
who
already
had
some
name
and
face
recognition
with
our
current
audience,
and
also
is
a
known
factor
to
GBC
based
upon
our
expetience
with
her.
We
pulled
back
from
the
decision
to
go
with
edginess.
You
have
to
have
the
right
person
to
move
in
that
direction,
and
Quinn
was
that
person.
I
contacted
Quinn
by
phone
the
following
day.
Iinformed
Quinn
that
we
had
learned
about
Le
Condé’s
accusations
and
other
stories
about
questionable
ethics.
He/she
sounded
shocked.
Quinn
said,
“the
ethics
line
is
always
moving.”
Then
he/she
said,
“this
really
backfired.”
It
may
appear
that
because
the
hotel’s
accusations
against
Quinn
killed
the
deal
for
him/her
that
I
believed
that
Quinn’s
bed
bug
story
had
been
fabricated.
That’s
not
necessarily
true.
Let’s
just
say
I
did
not
completely
dismiss
the
hotel’s
claims.
IThad
doubts.
In
light
of
the
hotel’s
accusations
and
the
edited
tearful
reaction
in
the
other
story,
it
wasn’t
worth
the
risk
or
the
loss
of
our
credible
reputation.
Our
decision
to
hire
Lara
in
Quinn’s
stead
reflects
the
importance
of
maintaining
credibility
with
our
viewers.
Rather
than
hiring
an
outspoken,
brash
host,
Justice
Prevails
temains
infetesting
because
it
does
not
repeat
mainstream
news,
but
rather
it
is
an
honest
reflection
of
issues
that
matter
to
the
audience.
Had
we
hired
Quinn
as
the
host
of
Justice
Prevails,
the
salary
offered
was
$1,500,000.00
annually.
The
contract
for
employment
would
have
only
been
for
a
one-year
period
that
could
be
renewed,
at
our
discretion.
Of
course,
there
was
no
guarantee
that
the
contract
would
be
renewed
beyond
the
first
year.
GBC
had
taken
risks
with
other
cutting-edge
shows
and
had
been
-30-
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O
00~
W=
10
successful
with
most,
but
some
didn’t
fare
as
well,
and
were
cut
after
a
year.
The
show
under
the
format
with
Lara
Morgan
as
host
has
been
successful.
In
the
case
with
Quinn,
a
contract
renewal
was
tenuous
because
we
had
no
idea
whether
the
edgy,
dramatic
style
would
have
been
well
received
by
our
viewers.
T
affirm
under
penalty
of
perjury
that
the
foregoing
is
true
and
correct
to
the
best
of
my
belief
and
knowledge.
/s/
Justin/Justine
Case
JUSTIN/JUSTINE
CASE
31
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STATEMENT
OF
JACQUE
GARNIER
My
name
is
Jacqué
Garnier.
I
am
the
Hotel
Manager
for
Le
Condé
Inn
at
30
Executive
Drive
in
Indianapolis,
Indiana.
Tam
French
Canadian;
I
was
born
and
raised
in
Quebec.
I
am
now
a
United
States
citizen.
I
came
to
the
United
States
in
1997
to
attend
Purdue
University
in
Lafayette,
Indiana.
In
2001,
I
received
my
Bachelor
of
Science
degree
from
Purdue
in
Hospitality
and
Tourism
Management
with
a
Marketing/Sales
concentration.
Purdue
has
always
had one
of
the
leading
programs
in
Hospitality,
In
2002,
Purdue
was
ranked
the
number
one
school
in
the
country
for
Hospitality
and
Tourism
Management.
Ihave
continued
to
keep
abreast
of
the
latest
information
and
developments
in
hospitality
management
by
taking
additional
classes
at
Purdue,
including
Facilities
Management,
Business
Etiquette
for
Managers,
and
Consumer
Behavior
in
Hospitality
&
Tourism.
Le
Condé
is
a
member
of
the
Indiana
Hotel
and
Lodging
Association
and
the
American
Hotel and
Lodging
Association.
AHLA
and
THLA
also
provide
educational
seminars
and
resources.
Ihave
taken
advantage
of
these
seminars
every
year,
as
well
as
the
training
resources
available
to
me
through
IHLA
and
AHLA.
1also
annually
attend
the
Hoosier
Hospitality
Conference,
co-sponsored
by
IHLA,
and
receive
the
latest
industry
information
on
a
variety
of
topics.
Ihave
received
information
on
safeguards
and
prevention
of
bed
bug
infestation
through
Purdue,
IHLA,
AHLA,
and
the
Hoosier
Hospitality
Conference
from
2007
through
the
present.
1
joined
the
staff
at
Le
Condé
in
2007.
Le
Condé
Inn
is
a
boutique,
luxury
hotel
with
fifteen
guest
floors,
150
guest
rooms
(10
per
floor),
30
deluxe
suites
(2
per
floor),
and
one
honeymoon
or
executive
suite,
which
occupies
the
entire
sixteenth
floor.
Le
Condé
is
the
premier
hotel
in
the
Indianapolis
area
and
a
Iegend
in
Indiana
hotel
history.
The
hotel
was
the
vision
of
John
Houghton,
a
millionaire
of
the
time.
In
1925,
Mr.
Houghton
set
out
to
create
a
hotel
that
would
reflect
the
elegance
and
luxury
of
hotels
in
Europe.
The
construction
of
the
hotel
began
in
1926,
and
opened
its
doors
in
1928.
Mr.
Houghton’s
vision
incotporated
the
novel
idea
at
the
time
of
including
bathroom
facilities
within
the
guest
room
rather
than
guests
using
a
common
bathing
area.
The
hotel
quickly
became
the
city’s
business
and
social
center
for
the
who’s
who
among
the
elite.
The
hotel
has
had
many
famous
guests,
including
John
F.
Kennedy,
Harry
Truman,
the
Duke
of
Windsor,
Madonna,
Michael
Jackson,
Lady
Gaga,
David
Letterman,
Dario
Franchitti
and
Ashley
Judd.
Despite
the
Depression
a
year
after
the
hotel
opened,
the
hotel
has
thrived.
Through
the
years,
this
boutique
hotel
has
developed
customer
loyalty.
In
the
1980’s,
amid
the
country’s
recession,
the
hotel
was
purchased
by
Boutique
Inn
Group
(BIG)
to
become
its
sighature
hotel
in
the
States,
The
hotel
was
renamed
Le
Condé
Inn.
A
$17
million
renovation
in
2007
revived
its
prestige
and
luxury.
I
was
hired
at
Le
Condé
in
2007
to
oversee
the
renovation.
The
renovation
was
completed
in
March,
2008,
Through
the
renovation,
Le
Condé
continues
its
tradition
of
prestige
and
excellence.
Once
a
vision
of
a
single
man,
now
it’s
a
city’s
pride
and
joy.
Le
Condé
takes
luxury
to
the
next
level.
The
luxury
starts
with
a
lavish
lobby
with
crystal
chandeliers,
spacious
rooms
(550
sq.
feet)
with high
ceilings,
bathrooms
of
Spanish
Ramora
marble,
plasma
TVs
with
LCD
screens
in
the
bathroom,
5”
pillow
top
feather
beds,
Egyptian
cotton
sheets
and
European
white
goose
down
comforters.
32-
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The
luxury
continues
with
impeccable
personal
setvice,
attentive
to
the
guests’
every
need.
Prior
to
joining
Le
Condé
in
2007,
I
started
my
career
in
the
hotel
industry
as
the
Assistant
Hotel
Manager
at
Hotel
Célestin
Quebec
from
2001
to
2004.
Célestin
is
another
boutique
hotel
of
BIG.
As
the
Assistant
Manager,
I
maintained
the
highest
standards
of
services,
including
overseeing
maintenance
and
cleanliness
for
guest
rooms
and
the
facilities.
I
was
responsible
for
ensuring
the
cleanliness
of
all
food
and
beverage
facilities,
banquet
rooms,
and
storage
rooms.
I
also
coordinated
and
implemented
marketing
activities
for the
hotel,
I
was
then
promoted
to
Associate
Hotel
Manager
at
Hotel
Célestin
and
served
in
that
position
until
January,
2007.
As
the
Associate
Manager,
I
was
fully
responsible
for
coordinating
and
managing
the
staff
and
hotel
operations.
In
January,
2007,
BIG
promoted
me
to
the
position
of
Hotel
Manager
at
their
Indianapolis
boutique
hotel,
Le
Condé.
As
the
hotel
manager
at
Le
Condé,
in
addition
to
overseeing
the
$17 million
renovation,
I
was,
and
continue
to
be
in
charge
of
ensuring
employees
are
trained
for
their
positions
to
maximize
service,
production
and
efficiency,
Iam
also
in
charge
of
managing
the
property
operations
to
assure
optimum
performance
and
property
appearance.
I
ensure
that
the
hotel’s
property
is
well
maintained
and
all
mechanical
equipment
is
in
good
working
order.
Ihandle
any
concerns
arising
with
guests
or
visitors
to
the
hotel
including
billing
issues.
In
the
year
2000,
the
hospitality
industry
did
not
want
to
adopt
bed
bug
action
plans.
Having
a
bed
bug
action plan
was
like
admitting
your
hotel
had
bed
bugs.
About
five
to
seven
years
ago,
the
AHLA
recommended
hotels
to
change
some
of
their
housekeeping
protocols
as
a
way
to
identify
a
problem
early.
Now,
if
your
hote!
does
not
have
bed bug
action
plan,
you
are
at
risk
of
losing
your
reputation
and
a
lawsuit.
In
the
hotel
industry
it
is
deemed
below
the
standard
of
reasonable
care
if
the
hotel
does
not
have
a
reasonable
bed bug
detection
program
in
place,
and
if
the
hotel
does
not
implement
or
adhere
to
the
protocol.
Le
Condé
had
implemented
a
bed
bug
action plan
prior
to
my
taking
the
position
as
the
Hotel
Manager.
However,
1
continually
review
and
improve
the
protocol
as
we
learn
more
in
the
hotel
industry
to
increase
employee
awareness,
training,
and
eradication
of
potential
infestations.
The
management
of
the
Le
Condé
takes
the
issue
of
bed
bugs
very
seriously
as
the
safety
and
comfort
of
our
guests
are
our
top
priorities.
Let
me
first
say,
there
is
no
way
to
stop
bed
bugs
from
being
brought
into
any
hotel,
New
guests
are
arriving
every
day
from
all
over
the
world,
and
bringing
their
potentially
infested
luggage
with
them.
Your
hotel
can
be
bed
bug
free
one day
and
infested
in
multiple
rooms
the
next.
So
prevention,
in
the
lodging
industry,
is
early
detection.
Bed
bugs
must
be
detected
very
quickly
after
they
are
brought
in,
hopefully,
before
they
bite
someone.
To
facilitate
this
early
bed
bug
detection,
all
of
Le
Condé
hotel
employees
receive
some
bed
bug
identification
training.
This
includes
the
reception
staff,
maids,
facilities
personnel,
hotel
managers,
event
planners,
maintenance
staff,
catering
staff,
bellhops,
cooks,
janitors,
and
absolutely
everyone
else.
Why
everyone?
Because
our
employees
are
located
all
over
the
hotel,
and
if
everybody
is
looking
for
bed
bugs
there
is
greater
chance
that
you
will
discover
them
quickly.
After
our
renovation
was
completed
in
March,
2008,
I
wanted
to
implement
the
highest
quality
of
standards
for
Le
Condé.
Raising
employee
awareness
on
the
issues
surrounding
bed
bug
infestations
has
become
a
critical
element
in
hotel
property
operations.
Trained
and
33
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knowledgeable
housekeeping
staff
is
one
of
the
best
lines
of
defense,
along
with
having
regular
pest
control
inspections.
Bed
bugs
can
crawl
out
of
a
traveler’s
suitcase
and
establish
themselves
in
hotel
rooms.
The
process
of
eliminating
bed
bugs
from
hotel
rooms
can
be
quite
expensive
and
lead
to
litigation,
large
settlements
and
loss
of
business.
So,
beginning
in
March,
2008,
T
contracted
with
the
best
pest
management
company
in
the
Indianapolis
area,
DDT
Pest
Control,
to
train
our
employees
for
early
bed
bug
detection
and
to
perform
regular
pest
control
inspections,
DDT
Pest
Control
trained
our
housekeeping
personnel
to
know
what
bed
bugs
and
their
fecal
stains
look
like
so
they
can
then
alert
management
immediately
if
they
think
they
see
bed
bug
evidence
in
a
hotel
room.
This
early
detection
helps
to
identify
infestations
before
they
get
started,
The
trained
bed
bug
staff
members
also
serve
as
handy
inspectors
if
a
guest
complains
about
bites
or
bed
bugs
in
their
room,
an
incident
we
have
never
had
to
deal
with
except
in
the
case
of
Quinn
Tessence’s
alleged
complaint.
The
protocol
at
Le
Condé
requires
that
as
beds
are
being
stripped,
the
linens
and
pillowcases
used
by
hotel
guests
be
checked
for
small
blood
stains
that
look
like
small
reddish
brown
spots.
The
mattress
also
is
checked
by
closely
examining
the
seams
for
brown
spots
that
could
be
bug
feces,
shed
skin
or
actual
bed
bugs.
Bed
bugs
can
hide
in
the
smallest
spaces
between
headboards
and
walls.
Headboards
are
checked
thoroughly,
as
well
as
under
the
bed
skirting,
and
especially
pleated
seams.
We
also
check
draperies,
molding,
pictures,
and
baseboards,
especially
ones
near
beds.
Housekeeping
personnel
are
provided
with
flashlights
to
check
small
cracks
and
crevices.
Thorough vacuuming
is
important
as
well.
Le
Condé,
under
my
direction,
has
also
taken
measures
to
remove
clutter
from
the
guest
rooms
where
bed
bugs
can
hide
and
if
any
cracks
or
ctevices
are
detected
they
are
sealed
to
remove
hiding
places.
All
of
these
measures
were
in
place
in
2008
when
Quinn
Tessence
was
a
guest
at
Le
Condé.
Exhibit
9
is
a
true
and
accurate
copy
of
the
Bed
Bug
Inspection
Protocol
information
sheet
that
is
distributed
to
employees
of
Le
Condé
in
the
training
for
bed
bug
inspections,
and
that
was
used
in
2008.
It
is
also
posted
in
the
housekeeping
area
of
the
hotel.
The
Protocol
has
not
changed
materially
since
that
time.
We
do
not
use
canines
to
detect
bed
bugs.
It
is
costly,
about
$10,000.00
per
inspection.
Also,
not
all
dogs
are
100%
accurate
(but
usually
they
are
above
90%
accurate).
The
Bed
Bug
Inspection
Protocol
is
required
of
all
housekeeping
employees,
in
addition
to
their
routine
housekeeping
functions.
Exkibit
10
is
a
true
and
accurate
copy
of
the
Housekeeper
Task
List,
which
details
the
tasks
required
of
the
housekeeping
staff
member
for
the
cleaning
of
each
guest
room.
In
addition
to
these
tasks,
the
housekeeper
also
has
the
responsibility
for
stocking
their
carts,
and
removing
roll
away
beds
or
cribs,
previously
performed
by
housemen.
Due
to
the
economic
downturn
the
housemen
positions
wete
eliminated
and
assigned
to
the
housekeeping
staff.
The
reassignment
of
these
tasks
is
not
substantial,
in
my
opinion,
because
guests
at
luxury
hotels
rarely
ask
for
roll
away
beds
or
cribs.
Moreover,
the
stocking
of
the
housekeeper’s
cart
can
be
performed
rather
expeditiously.
We
had
to
make
several
tough
decisions
due
to
the
economic
downturn,
In
2007,
when
I
became
manager
at
Le
Condé,
housekeepers
had
a
14-room
quota.
In
March,
2008,
I
downsized
the
housekeeping
staff
and
required
a
20-room
quota
for
room
cleaners,
not
including
turndowns.
This
quota
would
apply
in
all
conditions,
whether
a
cleaner
is
covering
suites,
double
.34-
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W3
W
WY
L
LY
WD
NN
NN
RN
/o
s
s
e
e
or
single
rooms,
and
whether
a
room
cleaner
has
to
travel
to
multiple
floors.
The
increased
quota
does
not
impair
the
quality
of
our
housekeeping
services.
Our
renovation
in
March,
2008,
significantly
reduced
the
time
and
effort
required
of
our
housekeeping
staff
because
everything
is
in
new,
pristine
condition.
We
installed
bathroom
surfaces
and
flooring
that
are
easier
to
clean,
and
our
newly
installed
heating,
cooling
ventilation
system
includes
an
air
filtration
system.
With
the
new
filtration
system
and
the fan
running
full
time,
all
the
air
goes
through
the
filtration
system
four
times
per
hour
and
virtually
removes
all
dust
particles.
So,
there
is
little
dusting
required
by
the
housekeeping
staff.
Previously,
under
the
14-room
quota,
housekeepers
were
expected
to
clean
each
room
in
approximately
thirty
minutes.
With
the
20-room
quota,
housekeepers
have
approximately
twenty
minutes
to
clean
each
room.
Ihave
had
no
complaints
from
any
housekeeping
staff
that
the
new
quota
is
too
cumbersome.
Nor
have we
had
any
significant
complaints
that
a
room
is
not
cleaned
to
a
guest’s
expectations.
Of
course,
there
are
always
minor
complaints,
such
as
amenities
not
sufficiently
supplied,
or
an
occasional
complaint
of
a
dirty
towel
left
behind
the
bathroom
door,
but
nothing
of
any
significance.
There
has
been
no
change
in
the
number
of
these
minor
complaints
after
the
housekeeping
room
quota
increased.
However,
subsequent
to
the
incident
involving
Quinn
Tessence,
we
decreased
the
room-quota
for
our
housekeeping
staff
to
the
previous
14-room
quota
and
we
hired
additional
housekeeping
staff.
T
am
familiar
with
Quinn
Tessence.
Mr./Ms.
Tessence
was
a
guest
at
Le
Condé
Inn
the
weekend
of
July
11-13,
2008.
Prior
to
that
weekend,
I
also
had
two
encounters
with
Mr./Ms.
Tessence
on
the
weekend
of
July
4,
2008,
to
resolve
certain
problems
concerning
him/her,
Prior
to
these
occasions,
I
was
familiar
with
Quinn
Tessence
through
his/her
news
reporting/anchor
position
at
WYBU.
Thave
never
been
fan
of
Mr./Ms.
Tessence.
His/her
reporting
style
seems
to
me
to
lack
credibility
and
integrity,
He/she
goes
for the
dramatic
effect
rather
than
merely
reporting
the
facts.
I
think
the
news
should
impartially
report
facts
and
not
attempt
to
manipulate
them
to
achieve
a
certain
appeal
and
turn
it
into
a
“story.”
I
held
these
opinions
of
Mr./Ms.
Tessence
long
before
the
incidents
involving
Mr./Ms.
Tessence
at
our
hotel.
Now,
I
can
say
with
firsthand
knowledge,
that
Mr./Ms.
Tessence
is
a
liar,
and
fabricates
things
just
to
create
a
“story.”
With
regard
to
the
July
4™
weekend,
Mr./Ms.
Tessence
had
booked
five
rooms
for
family
members
for
a
one
night
stay
on
Friday,
July
4",
Mr./Ms.
Tessence
was
not
a
guest
at
the
hotel
for
that
evening.
However,
Mr./Ms.
Tessence
was
a
visitor
at
the
hotel
and
participated
in
some
of
the
hotel
festivities
for the
July
4"
weekend.
At
approximately
1:30
a.m.,
on
Saturday,
July
5,
my
assistant
manager
called
me
to
handle
an
intoxicated
guest
in
our
Le
Fantastique
Lounge.
‘When
I
arrived
shortly
thereafter,
I
observed
Mr./Ms.
Tessence
in
a
drunken,
loud,
raucous,
and
obnoxious
state
harassing
other
hotel
guests,
visitors,
and
our
staff.
The
bartender
had
refused
to
serve
Mr./Ms.
Tessence
with
any
further
alcohol,
which
resulted
in
Mr./Ms.
Tessence
becoming
belligerent.
1learned
from
my
assistant
manager
that
the
bartender
and
the
assistant
manager
had
already
tried
to
subdue
Mr./Ms.
Tessence.
When
I
spoke
with
Mr./Ms.
Tessence,
1
introduced
myself
as
manager
of
the
hotel.
When
my
efforts
to
quiet
him/her
down
failed,
and
guests
were
leaving
due
to
the
annoyance
of
Mr./Ms.
Tessence’s
conduct,
I
offered
to
have
our
limousine
driver
take
Mr./Ms.
Tessence
to
his/her
home.
Iinformed
him/her
that
the
only
other
option
was
for
me
to
call
the
police
and
report
him/her
for
public intoxication.
Mr./Ms,
35-
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O
00
I
N
B
L
N
s
Tessence
was
visibly
angry.
He/she
shouted,
“Do
you
know
who
Iam?
Iam
a
celebrity.
I'm
the
star
news
anchor
at
WYBU.
If
I
want,
[
can
ruin
you
and
this
hotel,
just
like
that,”
and
then
he/she
tried
to
snap
his/her
fingers
but
couldn’t
because
he/she
was
drunk,
Mr./Ms.
Tessence
speech
was
slurred,
but
'm
pretty
sure
that’s
what
he/she
said.
I
could
decipher
most
of
what
he/she
was
saying.
In
any
event,
he/she
understood
my
resolve
to
end
the
disruption
to
our
hotel,
and
our
limousine
driver
took
him/her
home
a
few
minutes
later.
That
was
not
the
end
of
our
problems
with
Mr./Ms.
Tessence.
On
July
5"
approximately
around
noon,
Mr./Ms.
Tessence
had
returned
to
the
hotel
and
became
belligerent
again
when
checking
out
the
rooms
for
his/her
family.
A
billing
issue
was
the
source
of
the
problem
this
time.
I
think
that
Mr./Ms.
Tessence,
in
his/her
hangover
state,
was
still
holding
a
grudge
because
he/she
had
been
escorted
out
of
the
building
due
to
the
lounge
incident.
In
any
event,
Mr./Ms,
Tessence
claimed
that
he/she
had
been
quoted
a
special
rate
of
$199.00
per
night
for
each
of
the
5
rooms
rather
than
our
standard
rate
of
$279.00
per
night.
However,
the
$199.00
room
rate
was
applicable
only
if
you
booked
the
room
for
a
two-night
stay.
Tused
the
“LAST”
approach
to
deal
with
Mr./Ms.
Tessence’s
complaint,
which
stands
for
listen,
apologize,
solve,
and thank.
Guests
are
less
likely
to
leave
frustrated
if
we have
genuinely
and
actively
listened
to
the
complaint,
demonstrated
understanding
and
thanked
them
after
the
problem
has
been
resolved
to
reassure
them
that
the
hotel
does
not
begrudge
them
the
right
to
speak
up.
Iasked
Mr./Ms.
Tessence
to
come
to
my
office
to
resolve
the
problem
because
he/she
was
yelling
in
the
lobby
area
and
disturbing
our
other
guests.
Once
in
my
office,
after
listening
to
his/her
complaint,
I
explained
that
the
discounted
rate
was
our
way
of
increasing
hotel
occupancy
for
more
than
just
the
July
4®
evening,
as
we
expected
near
full
occupancy
for
the
4®.
However,
July
5%
is
often
less
than
full
occupancy,
so
we
offered
the
special
two-night
room
rate.
I
even
showed
Mr./Ms.
Tessence
the
website
page
that
showed
the
special
room
rate
was
for
a
two-night
stay.
To
resolve
the
problem
and
to
maintain
good
customer
relations,
I
offered
to
discount
the
$279.00
rate
to
$259.00
per
night
and
offered
to
give
Mr./Ms.
Tessence
a
free
night’s
hotel
stay
on
another
occasion.
Mr./Ms.
Tessence
still
wanted
to
argue
with
me
—
I
take
it
he/she
doesn’t
like
to
concede
on
any
point
—
but
he/she
finally
agreed
to
the
compromise.
When
he/she
left
my
office,
Mr./Ms.
Tessence
said,
“You
haven’t
heard
the
last
of
me
yet!”
I
didn’t
know
what
he/she
was
referring
to
at
the
time,
but
after
he/she
made
the
bed
bug
complaint,
I
knew
this
was
his/her
way
of
getting
back
at
the
hotel,
Mr./Ms.
Tessence
had
previously
booked
a
guest
room
for
July
12%
as
part
of
a
block
of
rooms
that
was
reserved
for the
Roberts-Keeley
wedding
reception.
However,
on
July
10,
2010,
Quinn
Tessence
called
the
hotel
to
book
an
extra
night
stay,
arriving
on
July
11%,
instead
of
the
12%,
He/she
indicated
he/she
was
using
the
free
night
stay
that
Thad
given
as
a
concession
to
him/her
to
resolve
the
prior
billing
dispute.
Nothing
unusual
occurred
over
the
weekend
until
the
morning
of
July
13,
On
that
morning,
approximately
at
9
a.m.,
Mr./Ms.
Tessence
called
our
front
desk
and
reported
bed
bug
bites
and
infestation.
Our
Associate
Manager
called
me
immediately,
and
we
rushed
to
the
room.
When
we
arrived,
the
camera
crew from
WYBU
was
already
present
with
their
cameras
and
other
equipment
filming
the
hotel
room,
and
more
specifically
a
mattress
inundated
with
bed
bugs,
along
with
evidence
of
bed
bug
fecal
stains
on
the
mattress.
The
camera
crew,
at
-
36-
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e
e
el
e
S
ey
VoAU
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fi_noxooo\lo\ur
X3
Tessence’s
direction,
turned
toward
me
to
film
my
reaction.
Naturally,
I
was
shocked
—
and
honestly
—
horrified.
Such
an
incident
can
kill
a
hotel’s
business.
Mr./Ms,
Tessence
was
scratching
his/her
bites,
which
they
filmed,
while
accusing
the
hotel
of
poor
quality
assurance
measures
in
our
housekeeping
protocols
for
bed
bug
prevention.
I
went
into
automatic
mode
of
using
the
LAST
approach
in
dealing
with
hotel
guest
complaints.
When
I
apologized
to
Mr./Ms.
Tessence,
it
was
not
intended
as
an
admission
that
the
hotel
had
been
negligent.
I
told
him/her
that
we
would
waive
the
bill,
and
offered
a
free
week’s
stay
whenever
he/she
wanted.
1
merely
was
trying
to
alleviate
any
frustration
experienced
by
a
hotel
guest.
You
know,
“the
customer
is
always
right”
approach.
Ididn’t
realize
the
cameras
were
turned
on
me,
and
captured
the
apology
like
the
hotel
was
guilty
of
neglect.
The
events
that
occurred
that
morning
were
cut
and
pasted
together
for
the
exposé
to
create
a
“better
story.”
Tessence
manipulated
statements
out
of
context.
T
offered
to
provide
Mr./Ms.
Tessence
another
room
in
the
hotel,
but
he/she
said,
“No,
I
have
a
story
to
report.”
I
offered
to
wash
Tessence’s
clothing
and
scrub
down
his/her
luggage
so
that
any
bed
bugs
would
nof
be
transported
elsewhere.
It's
a
known
fact that
bed
bugs
spread
from
place
to
place
by
way
of
luggage
and
clothing.
Mr./Ms.
Tessence
declined
my
offer.
Terry/Terri
Fyde
approached
me
when
all
of
the
commotion
was
going
on,
and
said
“Things
are
now
always
as
they
seem.
Give
me
a
call,”
and
then
he/she
gave
me
a
piece
of
paper
with
his/her
name
and
phone
number
on
it.
Thad
no
idea
what
he/she
meant
at
the
time,
and
didn’t
give
it
much
thought.
At
the
time,
I
was
preoccupied
that
we
had
an
infestation
of
bed
bugs
in
our
hotel.
T
don’t
deny
that
there
were
bed
bugs
in
the
room
occupied
by
Quinn
Tessence.
I
saw
them
for
myself.
Not
only
did
I
see
the
mattress
with
the
bed
bugs
scurrying
in
the
crevices
and
folds
of
the
mattress,
but
I
also
saw
the
fecal
stains.
Exhibit
5
is
a
true
and
accurate
picture
of
the
bed
bugs
and
stains
appearing
on
the
mattress
in
the
guest
room
occupied
by
Quinn
Tessence
at
Le
Condé.
The
question
is
not
whether
the
bed
bugs
were
there;
it’s
a
question
of
when
and
how
they
got
there.
I
feel
confident
that
our
hotel
housekeeping
staff
exercises
exemplary
care
and
skill
in
cleaning
rooms
and
inspecting
for
bed
bugs.
Mr./Ms.
Tessence
left
an
hour
later.
We
called
DDT
Pest
Control,
who
arrived
within
the
hour
and
began
an
inspection
and
extermination
of
the
bed
bugs.
A
complete
detailed
inspection
was
performed
of
the
room
occupied
by
Tessence.
Other
than
the
mattress,
all
areas
of
the
room
were
inspected
with
no
evidence
of
any
infestation
found.
We
also
systematically
checked
each
hotel
room,
as
guests
checked
out.
No
other
rooms
showed
any
evidence
of
bed
bugs.
In
fact,
other
than
Quinn
Tessence’s
complaint,
we
have
never
before
and
never
since
had
any
complaints
or
signs
of
bed
bugs.
I
called
Quinn
Tessence
at
the
WYBU
station
and
reported
the
results
of
the
inspection,
but,
of
course,
the
fact that
there
wasn’t
any
other
evidence
of
bed
bugs
did
not
make
his/her
“news
story.”
Quinn
Tessence’s
news
exposé
on
bed
bugs
in
the
hotel
industry
aired
on
Thutsday
evening,
July
17"
during
histher
“No
Apologies”
investigative
news
segment.
Exhibit
6
is
a
true
and
accurate
copy
of
the
transcript
of
part
of
the
“report.”
on
No
Apologies.”
He/She
should
be
apologizing
for
fabricating
a
story
that
caused
the
hotel
its
reputation
and
business.
Le
Condé
is
-37-
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w
G
LY
L
L)
W)
(S
SRS
SIS
S
S
e
el
e
el
sl
e
ey
depicted
in
the
show
as
a
hotel
with
poor
quality
assurance
and
cleanliness.
The
story
was
one-
sided.
Mr./Ms.
Tessence
did
not
report
that
it
was
the
only
guest
room
where
bed
bugs
were
detected.
He/she
also
did
not
report
that
a
pest
control
expert
immediately
eradicated
the
infestation,
The
story
seems
to
infer
that
the
problem
was
widespread
at
Le
Condé.
1was
furious
with
Quinn
Tessence’s
exposé,
and
particularly
how
he/she
targeted
Le
Condé,
It
was
as
if
he/she
knew
it
made
his/her
story
better
by
having
a
luxury
hotel
with
bed
bugs.
The
story
was
damaging
to
Le
Condé.
As
a
result
of
Tessence’s
fabricated
story,
the
hotel
experienced
a
significant
loss
of
business.
Approximately
75%
of
reservations
for the
remainder
of
July,
2008,
were
cancelled.
The
following
two
quarters
showed
revenue
down
by
a
third
compared
to
the
same
quarters
in
the
past
two
years.
Exhibit
11
is
a
true
and
accurate
summary
of
the
revenue
compatisons
for
third
and
fourth
quarters
of
2006
through
2008,
Le
Condé
Inn
claims
that
Quinn
Tessence’s
defamatory
comments
resulted
in
the
loss
of
income
to
the
hotel.
When
we
prepared
the
room
for
eradication
of
the
bed
bugs,
we
bagged
everything
in
the
room,
The
mattress
was
of
course,
discarded,
and
the
linens
had
since
been
washed
and
dried
in
high
heat.
On
Saturday,
July
19,
after the
room
and
its
contents
were
re-inspected
and
cleared
for
re-use,
we
began
to
return
objects
to
the
room.
It
was
then,
that
I
noticed
a
note
crumbled
in
a
wastebasket
that
had
been
previously
bagged.
Exhibit
12
is
a
true
and
accurate
copy
of
the
handwritten
note
that
was
found
in
the
guest
room
occupied
by
Quinn
Tessence.
Obviously,
the
handwritten
note
shows
that
Mr./Ms.
Tessence
was
planning
to
expose
himself/herself
to
the
bed
bugs
at
our
hotel,
He/she
knew
it
would
take
at
least
24
hours
for
the
bites
to
show,
and
that
if
he/she
scratched
the
bites,
the
sores
would
worsen.
The
notation
for
the
camera
crew
to
be
there
in
the
morning
is
the
smoking
gun.
Tt
shows
that
this
was
a
staged
event,
Why
else
would
he/she
make
a
notation
for
the
camera
crew
to
be
there
in
the
morning?
When
I
saw
the
note,
T
remembered
Mr./Ms.
Fyde’s
comment
and
suggestion
that
I
call
him/her.
I
called
Mr./Ms.
Fyde
on
the
19".
He/she
informed
me
that
he/she
had
been
a
producer
for
the
WYBU
news,
but
had
been
fired
because
he/she
took
issue
with
Quinn
Tessence’s
unethical
reporting.
Mr./Ms.
Fyde
then
told
me
that
before
he/she
left
WYBU,
he/she
had
been
working
with
Tessence
to
produce
the
story
on
hotel
bed
bug
infestation.
Ilearned
that
Tessence
had
struck
out
hotel
after
hotel
in
finding
bed
bugs
and
the
story
was
going
to
be
canned
by
the
station.
Tessence
could
not
even
locate
any
victims
with
bites.
He/She
was
desperate.
I
also
Jearned
that
Quinn
Tessence
had
been
given
a
vial
of
live
bed
bugs
from
a
source
for the
story.
Right
then
and
there,
I
knew
that
Mr./Ms.
Tessence
planted
the
bed
bugs
in
the
hotel
room
at
Le
Condé
Inn.
Mr./Ms.
Fyde
has
agreed
voluntarily
to
come
forward
to
testify
in
this
case.
But,
at
the
time,
he/she
requested
that
I
maintain
the
confidentiality
of
his/her
identity
as
the
source
of
my
information
because
he/she
was
terrified
that
Quinn
would
make
sure
that
he/she
would
never
get
a
job
in
the
industry
again.
Irespected
his/her
wish.
Isubsequently
hired
Mr./Ms,
Fyde
to
produce
an
advertising
piece
for
the
hotel.
It’s
not
a
big
job,
but
I
thought
he/she
helped
Le
Condé
in
its
time
of
trouble,
that
T
would
help
him/her
out.
Besides,
he/she
does
excellent
work,
and
as
a
freelance
producer,
it
is
a
cost
savings
for
a
project
I
had
planned
to
do
anyway.
Later
that
Saturday,
I
contacted
a
local
newspaper
reporter
and
gave
them
the
“real
story”
how
Quinn
Tessence
planted
the
bed
bugs
in
the
room
and
fabricated
the
bed
bug
infestation
at
Le
Condé.
The
story
appeared
in
the
newspaper
on
Sunday,
July 20",
Front
page
news.
Finally,
-38-
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—
e
e
e
W
—
OOV
-dJXth
»hWN—
Tessence
got
a
taste
of
his/her
own
poison.
Exhibit
7
is
a
true
and
accurate
copy
of
the
news
article,
and
accurately
reports
what
I
said
to
the
reporter.
1did
not
discuss
the
news
article
to
any
person
or
entity,
other
than
to
employees
of
Le
Condé
Inn
or
BIG.
I
was
unaware
at
the
time
that
Mr./Ms.
Tessence
was
interviewing
for
a
position
at
GBC.
T
affirm
under
penalty
of
perjury
that
the
foregoing
is
true
and
correct
to
the
best
of
my
belief
and
knowledge.
/s/
Jacqué
Garnier
JACQUE
GARNIER
-30.
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LY
LD
)
LY
W
LW
W
BB
DI
DO
B
DN
DD
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D)
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b
et
ek
e
e
el
e
i
e
STATEMENT
OF
TERRY/TERRI
FYDE
My
name
is
Terry/Terri
Fyde.
Iam
a
former
employee
of
WYBU.
Iworked
at
WYBU
for
14
years.
I
started
as
an
associate
producer
for
the
morning
news
program,
First
Light
News.
After
a
few
years
I
became
producer
of
the
show,
and
later
took
on
added
responsibilities
of
producing
our
late
night
newscast.
The
station
management
recognized
my
work
as
a
producer
for
those
two
news
segments.
Consequently,
in
2000,
I
was
asked
to
produce
our
primetime
newscast,
the
Evening
News,
an
hour-long
program.
The
other
newscasts
were
only
half
hour
time
slots.
Iremained
Producer
of
the
Evening
News
at
WYBU
throughout
the
remainder
of
my
employment
with
WYBU.
I
was
fired
from
WYBU
on
June
25,
2008,
when
a
dispute
arose
involving
what
I
believed
to
be
unethical
reporting
by
Quinn
Tessence.
I
called
him/her
out
on
it.
T
am
a
straight-shooting
sort
of
person.
Icall
‘em
the
way
I
see
‘em.
Ibelieve
that
quality
has
gained
me
respect
in
this
industry
and
at
WYBU
because
people
know
I'm
going
to
tell
it
like
it
is.
They
always
know
where
I'm
coming
from.
And,
when
I
look
in
the
mirror
at
the
end
of
the
day,
I
know
my
integrity
is
intact.
1
am
presently
unemployed.
After
leaving
WYBU,
I
found
it
very
difficult
to
find
work
as
a
producer.
I
think
Quinn
blacklisted
me.
However,
I
have
several
projects
in
the
works
as
a
freelance
producer.
I
produced
an
advertisement
for
Le
Condé
Inn.
It
was
a
small
project.
I
received
only
$3,000.00
for
the
entire
project
-
writing,
producing,
directing,
and
editing.
Currently,
I
am
writing,
producing
and
directing
my
own
documentary,
a
sort
of
behind
the
scenes
look
at
the
TV
news
industry
and
what
it
has
become.
Ihave
strong
opinions
regarding
the
current
state
of
affairs
in
the
world
of
TV
broadcast
news.
The
news
no
longer
impartially
disseminates
facts.
Instead,
we’ve
become
accustomed
to
the
news
using
drama
and
theatrical
antics.
Quinn
Tessence
is
the
quintessential
new
age
news
anchor
that
I
abhor.
He/She
is
all
about
sensationalism
and
drama,
and
less
about
facts,
He/She
is
brash
and
outspoken,
not
for
the
purpose
of
uncovering
the
facts,
but
only
because
that
style
sells.
Quinn’s
not
a
reporter
of
the
news.
Rather,
Quinn
tries
to
make
the
news.
The
stories
on
today’s
news
broadcasts
aren’t
always
newsworthy
but
instead
grab
attention
long
enough
to
keep
a
viewer
from
turning
the
channel.
And
some
of
the
most
newsworthy
news
ends
up
on
the
cutting
room
floor.
My
documentary
explores
the
news
of
yesterday
and
the
news
of
today.
It’ll
be
an
eye-opener.
When
it
airs,
I
believe
it
will
be
award
winning
and
open
up
many
doors
for
me.
The
documentary
hasn’t
been
distributed
yet
because
I
need
some
additional
funding.
[
suppose
my
testimony
in
this
case
might
help
promote
the
documentary.
But,
that’s
not
why
I'm
testifying.
Once
again,
I
feel
the
need
to
stand
up
for
what’s
right
and
to
make
sure
the
truth
is
known,
That’s
why
I'm
testifying
in
this
case.
Ididn’t
come
forward
initially
in
this
case
because
I
was
terrified
that
Quinn would
ruin
me
completely
if
I
revealed
him/her
for
who
he/she
really
is
—
a
fake.
He/she
had
already
managed
to
have
me
fired
at
WYBU,
and
[
was
struggling
to
find
another
job
as
a
producer,
A
lot
of
doors
had
been
shut
in
my
face.
I
did,
however,
speak
up
regarding
the
bed
bug
issue;
I
spoke
with
Jacqué
Garnier.
But,
I
asked
that
my
identity
remain
confidential,
I
never
spoke
with
anyone
else
about
the
Le
Condé
bed
bug
story.
1had
heard
through
the
grapevine
that
Quinn
was
in
the
running
for
a
TV
show
host
on
a
cable
network
around
the
time
the
hotel
bed
bug
infestation
story
was
being
aired.
But
-40-
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—_
_
O
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Twouldn’t
have
had
the
first
idea
as
to
the
cable
show
or
the
person
interviewing
Quinn.
Besides
I
had
learned
my
lesson
that
whether
the
news
is
manipulated
doesn’t
seem
to
matter
to
the
networks;
all
they
seem
to
care
about
is
if
the
news
has
flashy
appeal
to
the
viewers.
As
the
producer
at
WYBU,
I
transformed
what
was
often
a
poorly-timed
hodgepodge
of
unrelated
news
stories
and
segments
into
streamlined
and
cohesive
shows
with
an
artfully
written
continuity
that
flowed
gracefully
between
hard
news
blocks,
newsmaker
interviews,
and
feature
segments
-~
consistently
timed
perfectly
down
to
the
second.
Everyday,
I
shaped
the
news
show
by
stacking
--
ordering,
arranging,
and
timing
of
the
entire
show,
performing
much
of
the
writing,
line
producing,
and
all
of
the
copy
editing.
As
a
producer,
I
wrote
and
coordinated
feature-length
videotaped
packages,
culling
the
tape
and
supervising
the
videotape
editor
in
the
final
cutting
of
the
packages.
It
was
also
my
responsibility
to
oversee
the
screening
of
all
videotape
and
graphics
for
editorial
content
and
quality
control.
I’ve
written,
edited,
and
produced
an
estimated
3,500
television
news
broadcasts
over
the
past
14
years
-
working
with
enormous
volumes
of
material
under
extremely
tight
deadlines,
consistently
turning
out
award-
winning
material.
I
was
also
instrumental
in
the
decision
to
hire
Quinn
Tessence
as
a
news
reporter
for
WYBU,
and
later
in
the
decision
to
promote
him/her
to
the
anchor
of
the
Evening
News.
Thired
Quinn
and
had
been
at
WYBU
ten
more
years
than
Quinn,
so
imagine
my
surprise
when
I
was
the
one
fired
when
a
dispute
arose
between
us
over
news
content.
Thave
no
doubt
in
my
mind
that
Quinn
Tessence
fabricated
the
bed
bug
infestation
at
Le
Condé
Inn.
It
would
not
be
the
first
time
that
Quinn
crossed
the
ethical
line.
Some
may
call
me
a
purist,
but
I
strongly
believe
that
you
cannot
manipulate
the
news.
As
a
reporter,
you
can’t
direct
the
person
you’re
filming
or
interviewing
to
do
something
or
say
something
other
than
what
naturally
occurs.
Sure,
as
a
producer,
we're
not
going
to
air
every
second
of
the
interview
or
film.
Thete
are
time
constraints
and
you
have
to
make
it
interesting.
Quinn
went
beyond
routine
editing.
For
example,
Quinn
once
reported
on
a
story
of
the
rise
of
homeless
people,
especially
affecting
children.
The
news
report
was
significant
as
it
was,
but
Quinn
wanted
to
make
it
even
more
dramatic.
So,
he/she
directed
a
homeless
seven-year-old
child
to
take
a
donut
out
of
a
nearby
trash
container
and
take
a
bite.
Quinn
had
placed
the
broken
donut
on
top
of
the
trash,
with
the
child’s
knowledge,
moments
before
filming
the
child.
Texercised
my
right
as
producer
to
delete
that
portion
of
the
story
before
it
aired.
If
it
had
occurred
in
real
life
—
and
it
could
easily
have
occurred
on
another
day
or
at
anothet
time
~
but
in
this
instance,
it
was
staged.
Under
my
watch,
we’re
not
going
to
create
something
that
didn’t
happen
then
and
there.
Quinn
is
highly
competitive,
and
has
the
attitude
of
the
“ends
justify
the
means.”
There
was
one
instance
when
Quinn
told
a
source
he/she
loved
them
just
to
get
information,
Even
in
a
simple
golf
game,
Quinn
doesn’t
play
on
the
up
and
up.
I've
played
golf
with
Quinn
on
prior
occasions.
Quinn’s
one
of
those
golfers
that
if
you’re
not
looking,
he/she
will
pick
up
the
ball
or
nudge
it
with
a
foot
to
put
it
in
a
more
favorable
position
to
hit.
This
lawsuit
is
just
another
example.
Quinn
fabricates
a
story
and then
manipulates
the
situation
so
it
appears
like
he/she
is
the
victim
of
defamation.
4]-
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WL
W
W
W
B
DD
DO
PO
DY
D)
DD
bty
b
e
e
e
b
By
mid-2008,
as
Quinn
gained
celebrity
status
and
the
arrogance
that
accompanies
it,
Quinn
and
I
were
constantly
at
odds
because
of
Quinn’s
brazen
disregard
for
factual
reporting.
1
want
the
news
to
be
real.
Quinn
did
not
hesitate
to
manipulate
the
facts
for
a
good
story.
Quinn
knew
how
to
pull
in
the
audiences.
Quinn
portrayed
himself/herself
as
a
victim’s
advocate,
someone
who
was
“for
the
people.”
From
the
time
that
Quinn
was
hired
in
2004
through
mid-
2008,
WYBU'’s
ratings
and
market
share
in
the
Indianapolis
market
had
increased
by
4
times.
For
such
short
time
frame,
the
quadruple
increase
of
market
share
is
a
huge
leap
in
this
industry,
and
particularly
for
this
market.
Quinn’s
claim
to
fame
was
his/her
special
investigative
exposés
that
aired
on
Thursday
nights
called
“No
Apologies.”
No
person
or
industry
was
spared
if
it
made
a
good
story
for
Quinn.
With
the
increase
in
market
share,
Quinn
thought
he/she
was
above
reproach.
Quinn
had
planned
to
air
another
manipulated
story
on
“No
Apologies”
in
June,
2008.
Quinn
had
filmed
the
story
on
June
17®.
The
story
centered
on
a
mother’s
angst
after
learning
that
her
daughter
had
been
misidentified
as
a
victim
in
an
automobile
accident,
only
to
learn
later
that
the
daughter
had
not
made
the
fateful
trip
with
friends
but
had
gone
camping
in
the
wilderness
for
a
week
instead.
The
story
was
good,
Powerful.
Emotional.
But
Quinn
couldn’t
leave
well
enough
alone.
After
shooting
the
interview,
Quinn
decided
to
film
his/her
reaction
to
the
mother’s
heartfelt
story.
So,
back
at
the
studio,
Quinn
mustered
up
a
tear
streaming
from
his/her
eye,
filmed
it,
and edited
it
to
the
tape
of
the
interview
with
the
mother
has
if
the
tear
had
occurred
simultaneously
with
the
interview.
On
June
18,
T
expressed
my
concern
to
Quinn
that
he/she
had
crossed
the
ethics
line,
1
told
Quinn
I
was
cutting
the
clip
of
the
faked
tear.
On
June
25%,
a
day
before
the
story
was
to
be
aired,
I
learned
that
Quinn
had
reinserted
the
clip
of
the
faked
tear.
I
told
the
production
crew
that
I
had
the
final
call
as
the
producer,
and
the
faked
tear
would
not
be
part
of
the
story.
Quinn
went
over
my
head
and
complained
to
the
WYBU
General
Manager,
Daryl
Licht.
Ioverheard
Quinn
telling
Daryl
that
I
was out-dated
with
old-fashioned
ideas
about
news
reporting,
Daryl
called
me
to
his
office
to
sort
out
the
dispute.
To
keep
Quinn
happy,
Daryl
suggested
that
I
let
this
one
go.
Daryl
reminded me
that
Quinn
had
been
good
for the
station’s
ratings
and
market
share.
Icouldn’t
compromise
on
ethics.
I
started
shouting
at
Licht
with
righteous
indignation.
I'm
not
one
to
hide
behind
superficial
niceties.
I
gave
him
an
ultimatum.
I
said
I
would
not
be
part
of
producing
Quinn’s
“No
Apologies”
segments
in
the
future
if
I
didn’t
have
full
editorial
control
and
if
the
fake
tear
was
left
in
the
story.
I
was
fired
that
day
—
insubordination
they
said
—
and
the
story,
fake
teardrop
and
all,
aired
the
next
day,
June
26",
on
the
“No
Apologies”
segment.
The
story
later
received
some
journalism
and
media
awards,
even
though
it
was
faked.
Before
I
was
fired,
I
had
been
working
with
Quinn
to
produce
a
story
on
bed
bug
infestations
in
hotels.
I
thought
the
story
had
some
real
promise
at
the
time.
I
had
heard about
some
New
York
hotels
that
had
problems
with
bed
bugs,
but
the
story
had
not
been
broken
either
nationally
or
locally.
Ithought
it
would
be
a
coup
for
WYBU
to
be
the
first
to
break
the
story.
Quinn
had
been
working
on
the
story
for
weeks.
Besides
the
theatrics
and
sensationalism,
two
strengths
that
catapulted
Quinn’s
success
were
(1)
Quinn’s
tireless
devotion
to
get
a
story,
and
(2)
Quinn’s
dedication
to
researching
the
topic
backwards
and
forwards.
By
the
time
the
bed
bug
story
aired,
Quinn
probably
knew
more
about
bed
bugs
than
any
expert.
A42-
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NN
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N
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O
In
early June,
Quinn
started
with
interviewing
a
physician,
Reed
Tayne,
to
learn
about
the
clinical
manifestations
of
bed
bug
bites,
the
effects,
and
treatment.
WYBU,
per
my
authorization,
advanced
$3,000.00
to
retain
Dr.
Tayne
as
our
medical
expert
for the
story.
Quinn
attempted
to
find
victims
of
bed
bugs
through
Dr.
Tayne
as
well.
On
June
10,
2010,
Quinn
interviewed
on
film
an
exterminator,
learning
more
about
bed
bugs
hiding
spots,
telltale
signs
of
bed
bugs,
and
what
procedures
should
be
in
place
for
a
hotel
to
prevent
bed bug
infestation.
Then,
Quinn
began
his/her
quest
to
find
bed
bugs
in
a
local
hotel
or
motel.
Acting
undercover,
WYBU
would
check
into
a
hotel
and
carefully
look
for
bed
bugs.
I
usually
was
the
person
who
went
to
the
front
desk
to
check
into
the
motel
because,
as
the
show’s
producer,
I
was
not
a
face
that
would
be
recognized
by
the
general
public.
Quinn
had
scouted
out
the
places
in
advance,
and
selected
all
the
cheap,
seedy
motels.
He/She
was
convinced
that
bed
bugs
would
be
readily
found.
We
checked
into
the
first
motel
on
June
14",
and
found
nothing.
We
checked
into
three
or
four
rooms
on
June
15"
and
June
16™.
Nothing
again.
Quinn
didn’t
give
up.
On
June
21*
and
again
on
the
22™,
we
booked
five
rooms
each
day
in
cheap
hotels,
and
likewise
struck
out.
After
three
weeks
on
the
story,
Quinn
had
no
victims
of
bed
bug
bites
and
no
evidence
of
bed
bug
infestation
at
any
hotels
or
motels.
Quinn
was
frustrated.
Irecall
Quinn
said,
“maybe
I
should
just
plant
some
bugs.
We
know
they
exist.”
I
assumed
he/she
was
just
joking.
Before
I
was
fired,
Daryl
had
communicated
to
Quinn
and
me
that
he
was
going
to
can
the
story
if
something
didn’t
materialize
soon.
WYBU
had
invested
money
to
get
a
story
that
was
going
nowhere.
When
Quinn
heard
the
possibility
that
the
story
might
be
canned,
he/she
was
desperate.
Quinn
didn’t
like
to
be
defeated.
On
June
23",
Quinn
interviewed
and
filmed
a
dog
trainer,
who
specifically
trains
dogs
to
find
bed
bugs
in
hotels,
motels
and lodges.
Ilearned
that
dogs
are
pretty
efficient
and
proficient
at
finding bed
bugs.
They
can
search
an
entire
hotel
with
100
rooms
in
a
couple
of
hours,
However,
they
can
only
detect
live
bed
bugs,
so
they
cannot
locate
evidence
of
past
infestations.
Quinn
tried
to
get the
dog
trainer
to tell
us
a
hotel
or
motel
where
the
dog
had
detected
live
bed
bugs,
but
the
trainer
didn’t
want
to
lose
business
because
of
the
lack
of
confidentiality.
The
dog
trainer
demonstrated
for us
how
the
dogs
are
trained
to
find
bed
bugs.
She
had
several
sealed
test
tubes
of
live
bed
bugs.
She
simply
released
the
bed
bugs
on
the
mattress
for
a
dog
to
locate.
I
was
surprised
the
bugs
were
still
alive
in
the
enclosed
tubes,
but
I
learned
that
bed
bugs
could
survive
in
the
test
tubes
or
anywhere,
except
high
heat,
for
6
months
to
year
without
feeding.
I
saw
the
dog
trainer
hand
a
test
tube
of
several
live
bed
bugs
to
Quinn.
I
presumed
she
gave
it
to
Quinn
to
keep
for
his/her
research.
I
was
at
Le
Condé
Inn
for
the
Roberts-Keeley
wedding
reception
the
weekend
of
July
11-
13.
Thad
been
a
co-worker
of
the
groom
and
wouldn’t
have
missed
the
wedding
and
reception
for
the
world.
At
the
time
of
the
wedding
reception,
I
had
moved
to
Florida
to
live
with
my
parents
because
I
was
out
of
a
job,
out
of
money,
and
needed
to
get
away.
The
wedding
reception
was
on
Saturday,
July
12%,
but
since
I
was
traveling,
I
arrived
a
day
early.
I
was
hoping
Quinn
would
be
to
busy
with
his/her celebrity
status
to
make
the
wedding
and
reception,
but
I
saw
him/her
show
up.
We
avoided
each
other
at
the
reception.
Around
8:30
a.m.
on
July
13,
as
T
was
loading
up
my
luggage
in
my
car
in
Le
Condé’s
parking
Iot,
I
saw
one
of
the
cameramen
that
T
had
worked
with
at
WYBU
scurrying
to
retrieve
-43-
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—_
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camera
equipment
from
his
van.
He
told
me
that
Quinn
had
finally
got
his/her
bed
bug
story,
only
he/she
was
the
victim.
He
said
Quinn
had
numerous
bites
and
the
mattress
was
completely
infested
with
bed
bugs.
1knew
then
that
Quinn,
like
he/she
had
done
before,
fabricated
a
story.
Quinn
must
have
planted
the
bed
bugs
from
the
tube
he/she
received
from
the
dog
trainer.
He/She
needed
the
story
to
materjalize
before
Daryl
canned
it.
I've
heard
Quinn
say
on
more
than
one
occasion,
“Desperate
times,
call
for
desperate
measures.”
I
followed
the
cameraman,
and
watched
the
commotion.
Ieven
saw
Quinn
nailing
the
hotel
manager,
who
was
profusely
apologetic
and
in
a
state
of
disbelief.
I
gave
the
hotel
manager
my
name
and
telephone
number
and
told
him/her
to
call
me
for
the
real
story
because
I
had
learned
with
Quinn
that
things
aren’t
always
as
they
seem.
My
stay
at
Le
Condé
was
nothing
short
of
luxurious.
The
housekeeping
was
impeccable.
It
would
pass
any
white
glove
test.
1cannot
believe
that
a
hotel
with
such
high
quality
standards
would
have
a
bed
bug
infestation
problem.
1
affirm
under
penalty
of
perjury
that
the
foregoing
is
true
and
correct
to
the
best
of
my
belief
and
knowledge.
/s/
Terry/Terri
Fyde
TERRY/TERRI
FYDE
A4
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QWO
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My
name
is
Dee
D.
Tee.
Iown
and
operate
DDT
Pest
Control
located
at
2132
Calabro
Dr.,
Indianapolis,
Indiana.
Iregularly
participate
in
national
seminars
focusing
on
insects,
their
behavior,
biology
and
control,
and
I
consult
with
other
pest
control
companies
on
a
variety
of
pest
issues
in
both
commercial
and
residential
settings.
In
2006,
I
was
recognized
as
one
of
the
top
40
professionals
in
the
pest
control
industry
under
the
age
of
40
years
old.
Bed
bugs
were
once
all
but
eradicated
in
the
United
States
with
broad-spectrum
pesticides
such
as
DDT,
which
killed
a
wide
variety
of
bug
types.
Concerns
about
health
and
the
environment
led
to
many
of
these
pesticides
being
removed
from
the
market.
Bed
bug
infestations
have
increased
in
the
U.S.
because
of
immigration
and
travel
from
other
countries,
and
restricting
stronger
pesticides.
Today,
pest
control
methods
are
more
focused.
Pesticides
are
designed
to
kill
a
particular
species
(like
cockroaches).
Bed
bugs,
are
not
specifically
being
targeted,
and
therefore
are
slipping
through
the
cracks
-
literally.
(That’s
pest
controllers’
humor.)
The
bugs
also
have
developed
a
resistance
to
other
pesticides.
While
bed
bugs
are
often
found
when
sanitation
conditions
are
poot,
bed
bugs
can
also
live
and
thrive
in
clean
environments.
Crowded
living
quarters
facilitate
the
spread
of
bed bugs.
Bed
bugs
travel
surprisingly
well,
and
are
quite
comfortable
stowing
away
in
luggage
and
even
clothing.
The
bugs
are
increasingly
found
hiding
in
beds,
upholstered
furniture
and
behind
baseboards
in
urban
hotels
in
America.
Since
they
tend
to
stow
away
and
travel
with
humans,
any
place
that
sees
a
number
of
world
travelers
is
susceptible.
Pilots,
wealthy
people,
and
business
travelers
can
bring
bed
bugs
along
unwittingly.
Hotels
are
easy
targets
for
bed
bug
infestations
because
bed
bugs
can
arrive
on
the
clothing
or
in
the
suitcases
of
guests
from
infested
homes
or
other
hotels
harboring
the
pests.
Once
established,
bed
bugs
can
then
move
throughout
a
building
by
crawling
or
hitch-hiking
on
items
used
during
travel
such
as
suitcases,
outerwear
and
other
belongings.
Most
people
with
any
knowledge
of
bed
bugs
know
that
if
you
stay
in
any
hotel,
the
first
thing
you
should
do
is
check
for
bed
bugs.
It’s
something
that
can
be
easily
and
quickly
done
by
lifting
up
the
bed
linens
and
checking
the
crevices
of
the
mattress
for
bugs
or
stains.
Even
if
you
don't
see
any
signs
of
bed
bugs
in
your
hotel,
you
should
be
careful
not
to
allow
any
bugs
the
opportunity
to
hiich
a
ride
home
with
you.
Don't
put
your
clothes
on
the
carpet
or
on
upholstered
chairs.
Likewise,
keep
your
suitcase
off
the
floor
and
the
bed.
Use
a
metal
snitcase
rack,
if
one
is
available.
Bed
bugs
can
live
in
tiny
cracks
in
furniture
as
well
as
on
textiles
and
upholstered
furniture.
They
tend
to
be
most
common
in
areas
where
people
sleep
and
generally
concentrate
in
beds,
including
mattresses,
box
springs,
and
bed frames.
Being
very
flat,
they
are
able
to
find
a
number
of
places
in
which
to
hide.
Typical
hiding
places
include
beneath
loose
flooring,
behind
loose
wallpaper,
inside
box
springs,
in
mattresses,
and
in
upholstered
furniture.
One
common
hiding
place
in
hotel
rooms
is
behind
bed
headboards
that
are
fastened
to
the
wall
and
another
is
behind
moldings
just
above
the
floor.
_45-
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[UCREEVIR
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el
There
is
only
one
species
of
bed
bug
in
Indiana,
Cimex
lectularius.
This
species
is
a
pest
of
humans
worldwide,
including
the
entire
U.
S.,
and
has
over
50
common
names,
among
them
“mahogany
flat,”
“redcoat,”
“wall
louse,”
and
“bed
louse.”
Bed
bugs
typically
are
active
at
night
and
hide
during
the
daytime.
Thus
bed
bugs
living
with
humans
typically
feed
at
night
while
a
person
sleeps,
but
they
also
will
feed
during
the
day
in
dark
structures
such
as
infested
theaters
with
upholstered
seats.
Male
and
female
adults
usually
feed
every
3-4
days
and
become
engorged
with
blood
in
about 10-15
minutes.
Early
detection
is
key
to
preventing
an
infestation.
In
March,
2008,
Jacqué
Garnier
of
Le
Condé
Inn
hired
DDT
Pest
Control
to
perform
regular
inspections
at
the
hotel
for
bed
bugs
the
first
of
each
month,
and
to
train
its
employees
in
the
detection
of
bed
bug
infestations.
I
conducted
three
two-hour
training
sessions
for the
Le
Condé
employees
—
an
initial
training
in
March,
a
refresher
training
with
Q
&
A
in
April,
and
then
a
make-up
session
in
May
for
any
person
who
did
not
make
the
other
two
sessions.
My
training
of
the
hotel
staff
emphasized
the
importance
of
taking
time
to
look
around.
Bed
bugs
are
large
enough
to
see.
Iinstruct
the
staff
to
look
particularly
under
the
mattress
and
in
the
seams,
in
and
around
the
bed
frame,
and
along
any
cracks
or
peeling
paint
in
the
wall
or
picture
frames.
T
also
emphasize
it
is
important
to
check
for
bed
bugs
in
the
cracks
of
any
wooden
furniture,
particularly
antiques.
You
can
also
spot
droppings
from
bed
bugs,
which
may
be
tinged
with
blood.
While
fecal
stains
and
skin
casts
suggest
that
bed
bugs
have
been
present,
these
do not
confirm
that
the
infestation
is
still
active.
Observing
the
bed
bugs
themselves
is
definitive
confirmation
that
an
area
is
infested.
To
aid
in
the
hotel
staff’s
identification
of
evidence
of
bed
bug
infestation,
[
used
a
PowerPoint
presentation
with
various
pictures
showing
evidence
of
bed
bug
infestations,
including
the
presence
of
actual
bugs,
their
light-brown
skins
(shed
during
metamorphosis
into
adulthood),
egg
cases,
dark
spots
of
excrement
and
blood
spots
or
stains.
The
employees
are
instructed
that
when
looking
for
an
infestation,
they
should
use
a
flashlight
and
be
sure
to
carefully
and
systematically
check
the
following
areas:
bedding
(sheets,
blankets,
duvets,
pillowcases),
along
mattress
seams,
under
the
gauze
covering
of
box
springs
(where
fabric
is
stapled
to
the
wooden
frame),
upholstered
furniture,
behind
wall
mounted
objects
and
bed
headboards,
inside
cracks
and
crevices
of
furniture
(and
undemeath
furniture),
cracks
in
wood
molding,
and
under
the
edge
of
wall
to
wall
carpeting.
When
I
returned
for
the
refresher
course
training
in
April,
2008,
I
observed
the staff
performing
the
inspections
as
I
had
instructed
them
in
the
previous
training
session.
I
conducted
the
training
again
in
May,
2008
for
a
handful
of
hote!
staff
members
who
had
not
received
the
prior
training,
Based
upon
my
observations,
[
was
of
the
opinion
that
though
my
training,
the
housekeeping
staff
was
sufficiently
knowledgeable
in
identification
of
bed
bug
infestations.
I
observed
the
housekeeping
staff
systematically
and
thoroughly
checking
the
rooms
for
bed
bugs
as
they
had
been
trained.
Iwas
impressed
with
the
level
of
dedication
of
the
employees.
They
took
pride
in
their
jobs
and
the
hotel.
They
appeared
to
want
to
keep
the
hotel’s
reputation
at
the
highest
level
and
were
willing
to
take
on
these
extra
tasks
to
that
end.
Ialso
reviewed
the
protocol
that
Le
Condé
had
provided
to
its
employees.
Exhibit
9
is
a
true
and
accurate
copy
of
Le
Condé’s
Protocol
of
Bed
Bug
Prevention.
In
my
opinion,
the
protocol
establishes
a
reasonable
bed
bug
infestation
detection
control,
provided
the
employees
routinely
follow
the
A46-
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protocol.
During
the
training
exercise,
the
bed
bug
infestation
inspection
took
approximately
4
to
5
minutes
per
room.
During
the
Q &
A
session
in
the
staff
training,
a
few
of
the
employees
asked
if
I
would
speak
to
the
hotel
manager
to
hire
more
staff
and
reduce
the
room
quota
so
that
they
would
have
sufficient
time
to
perform
the
bed
bug
inspections.
1was
surprised
to
learn
they
had
a
20-room
quota
and
only
had
20
minutes
per
room
for
performing
the
traditional
housekeeping
tasks
in
addition
to
the
bed bug
inspections.
Most
hotels
that
I
provide
similar
training
have
12-
14
room
quotas
and
at
least
30
minutes
per
room
for
cleaning
and
inspections.
It
isn’t
my
job,
of
course,
to
manage
the
hotel,
and
I
thought
it
was
inappropriate
for
me
to
go
to
the
manager
to
ask
him/het,
on
behalf
of
the
staff,
to
hire
more
staff
and
reduce
the
room
quota.
So,
I
didn’t
mention
the
staff’s
concerns
to
the
manager.
However,
I
did
express
some
concern
to
the
Manager
of
Le
Condé
that
the
inspections
would
take
4-5
minutes
and
a
20-minute
timeframe
to
clean
and
inspect
the
room
was
not
ideal.
Of
course,
I
realize
that
some
of
that
time
can
be
ovetlapped
with
other
housekeeping
duties,
such
as
pulling
the
dirty
linens
from
the
mattresses.
Still,
I
thought
it
was
a
tight
schedule.
I
was
satisfied,
however,
with
Mr./Ms.
Garniet’s
explanation
that
the
recent
hotel
renovation
had
eliminated
or
reduced
time
for
dusting
and
cleaning
the
bathroom
floors
and
surfaces.
Mr./Ms.
Garnier
called
me
on
the
morning
of
July
13,
2008,
and
reported
that
Le
Condé
had
a
bed
bug
infestation.
Iarrived
at
the
hotel
around
10:00
am.
I
first
inspected
the
hotel
room
where
the
infestation
had
been
reported.
I
confirmed
evidence
of
the
presence
of
bed
bugs
by
examining
the
mattress
and
observing
the
fecal
stains.
Exhibit
5
is
a
true
and
accurate
photograph
of
the
mattress
in
the
Le
Condé
hotel
room
containing
bed
bug
fecal
stains.
I
then
observed
the
actual
presence
of
live
bed
bugs.
Exhibits
3
and
4
are
true
and
accurate
photographs
of
bed
bugs
located
in
the
Le
Condé
hotel
room.
In
continuing
my
examination,
I
noted
that
the
mattress
showed
a
significant
number
of
bed
bugs.
However,
oddly
enough,
the
bed
bugs
present
were
all
adults,
There
were
no
nymphs
or
eggs.
I
wasn’t
sure
what
to
make
of
that
finding.
Without
the
presence
of
nymphs
or
eggs,
that
told
me
that
the
adult
bed
bugs
had
not
been
residing
in
the
room
or
mattress
for
any
significant
period
of
time.
I
could
understand
the
lack
of
finding
of
no
nymphs
or
eggs
if
there
were
only
a
few
adults
present.
If
only
a
few
were
present,
the
logical
coriclusion
would
be
that
some
guest
had
recently
transported
the
bugs
to
the
room
on
their
clothing
or
luggage.
However,
the
mattress
had
numerous
bed
bugs,
The
other
odd
finding
is
that
with
so
many
bed
bugs
present
in
the
room,
I
can’t
imagine
any
housekeeper
performing
even
a
cursory
inspection
missing
the
signs,
unless
they
completely
neglected
their
duties.
Furthermore,
again
with
so
many
bed
bugs
present,
I
would
have
expected
other
guests
occupying
that
room
to
complain
of
bites.
Finally,
after
1
inspected
all
other
guests’
rooms
in
the
entire
hotel,
I
found
no
other
rooms
with
any
evidence
of
bed
bug
infestation.
With
the
amount
of
infestation
that
was
present,
I
would
have
expected
to
find
at
least
rooms
on
the
same
floor
with
bed
bugs
as
they
can
attach
to
clothing
and
luggage
and
easily
travel
to
otber
areas
in
the
hotel.
Nothing
about
this
infestation
was
typical,
In
my
opinion,
I
believe
that
a
significant
number
of
adult
bed
bugs
were
intentionally
placed
in
that
hotel
room
during
the
weekend
of
July
11-13",
I
didn’t
raise
these
suspicions
at
the
time
of
my
inspection,
or
even
for
several
days,
until
I
saw
the
newspaper
article
when
47-
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O
00
~I
QNP
WD
Mr./Ms.
Garnier
accused
Quinn
Tessence
of
planting
the
bugs.
Ihad
been
racking
my
brain
trying
to
figure
out
why
there
was
an
unusually
high
number
of
adults,
no
nymphs,
no
eggs,
and
no
other
bites
or
infestations
in
the
hotel.
I
was
beginning
to
think
these
were
mutant
bed
bugs
that
reproduced
without
going
through
normal
larvae
stages.
Intentionally
planting
the
bugs
was
the
only
logical
explanation
under
the
circumstances.
I'm
not
saying
Quinn
Tessence
planted
them
there,
but
I
believe
someone
did.
I'll
admit
that
my
reputation
and
business
is
on
the
line
if
I
missed
a
significant
infestation
like
this
when
I
performed
my
monthly
inspection
the
first
week
of
July,
but
that
still
doesn’t
change
the
fact
that
the
infestation
in
that
hotel
room
was
not
typical
in
any
way.
So,
after
completing
my
inspection
of
all
hotel
rooms
and
common
areas,
and
being
satisfied
that
there
were
no
other
infestations,
I
proceeded
to
have
all
furnishings,
linens,
mattresses,
and
wall
hangings
bagged
to
prevent
any
further
spread
of
the
bugs.
Then,
I
proceeded
to
eradicate
the
little
beasts.
Insect
repellents
are
not
effective
against
bed
bugs.
Iuse
a
combination
approach
of
heat
and
pesticides.
Some
pest
control
companies
only
use
chemicals
because
it
costs
less.
Others
just
use
heat
because
there
are
not
harmful
chemicals
present
in
the
air
and
chemical
treatments
usually
have
to
be
repeated
two
to
three
times
within
30
days.
The
National
Pest
Control
Association,
however,
recommends
using
a
combination
of
heat
and
chemicals.
So,
first
I'used
a
deep
cleaning
pesticide
and
scrubbed
infested
surfaces
with
a
stiff
brush
to
remove
eggs,
then
dismantled
bed
frames
and
furniture,
filled
cracks
in
floors,
walls,
and
moldings,
and
used
a
powerful
vacuum
on
cracks
and
crevices.
Then
I
used
blasts
of
heat,
hot
enough
to
warm
an
Easter
ham.
Bedbugs
can't
survive
above
113
degrees.
I
poked
flexible
black
tubing,
18
inches
in
diameter,
through
the
windows
of
the
room,
blowing
hot
air
from
my
trailer
below,
where
1
have
an
industrial-size
furnace.
I
also
used
a
half
dozen
industrial-size
fans
scattered
on
the
floor
circulating
the
heat
like
a
convection
oven.
I
kept
the
temperature
toasty
for
several
hours
inside
the
hotel
room.
1
billed
Le
Condé
$50,000.00
for the
inspection
and
extermination.
Previously,
I
had
billed
Le
Condé
$5,000.00
for
each
training
session,
and
my
monthly
inspections
are
typically
$1,000.00
per
month
unless
the
hotel
enters
into
a
one-year
contract,
then
the
cost
reduces
to
$850.00
per
month.
Le
Condé
executed
the
one-year
contract
for
my
services.
Although
the
cost
of
bed
bug
prevention
and
extermination
is
expensive,
the
overall
financial
loss
caused
by
these
pests
can
be an
immeasurable
amount.
I
believe
Le
Condé
values
my
services
as
Mr./Ms.
Garnier
has
referred
me
to
other
hotels
locally
and
throughout
the state
through
his/her
associations
in
IHLA.
Referrals
are the
key
to
any
successful
service
business.
I
affirm
under
penalty
of
petjury
that
the
foregoing
is
true
and
correct
to
the
best
of
my
belief
and
knowledge.
/s/
Dee
D,
Tee
DEE
D.
TEE
48~
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-
DO
YOU
HAVE
BED
BUG
BITER?
DID
YOU
STAY
AT
A
HOTEL
OR
MOTEL
RECENTLY?
If
you
answered
yes
to
both
questions,
I
would
like
to
interview
YOU!
Unclean
and
unsafe
practices
in
the
hotel
industry
are
widespread.
Hotels
have
cut
housekeeping
staff
allowing
infestation
bed
bugs.
Don't
let
hotels
allow
you
to
be
a
meal
ticket
(literally)
to
their
bigger
profits.
Make
the
hotels
clean
up
their
act!
I
can
help
by
exposing
these
practices,
but
I
need
YOU!
Call
me,
day
or
night:
Quinn
Tessence,
WYBU
(Channel
17)
News
Anchor
and
Investigative
Reporter
317-232-4611
EXHIBIT
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Partial
Transcript
of
Bed
Bugs
Live!
In
most
hotels,
housekeepers
must
clean
15
or
more
rooms
per
day.
Hotel
housekeepers
must
rush
to
meet
their
daily
quota.
In
recent
years,
hotels
have
increased
both
the
pace
and
the
amount
of
work
performed
by
housekeepers.
Most
hotels
have
recently
introduced
new
room
amenities
without
reducing
the
number
of
rooms
assigned
to
housekeepers
each
day.
Luxury
beds with
heavier
mattresses
and
linens,
triple-sheeting,
duvets
and
extra
pillows
are
increasingly
common.
Other
add-ons
like
coffee
pots
and
large
hard-to-clean
mitrors
make
room
cleaning
more
difficult
and
time-consuming.
Many
hotel
housekeepers
report
that
the
hotels
are
understaffed
and
they
face
time
pressure
to
maintain
a
quality guest
experience.
Martha
White,
a
housekeeper
at
Infinity
Hotel
says,
“There
is
so
much
to
do on
the
new
bed
that
we have
to
rush
constantly.
“Yeats
ago
we
usually
did
12
and
14
rooms,
Now
the
company
has
added
more
rooms,
15
and
16.
They
brought
on
heavy
duvets,
more
amenities
in
the
room,
more
towels.
Our
workload
is
more
time-consuming.”
In
recent
years,
the
workload
that
hotel
companies
demand
housekeepers
perform
has
increased
significantly.
Chronic
understaffing,
coupled
with
the
addition
of
time-consuming
amenities
have
placed
guests
at
risk
of
bed
bug
bites.
That’s
right
.
.
.
bed
bugs
are
prevalent
in
the
United
States
once
again
due
to
the
elimination
of
DDT
and
the
increase
in
travel
from
other
countries.
The
nasty
bugs
hide
in
the
mattress
in
your
hotel
room,
and
while
you're
sleeping
with
visions
of
sugar
plums
dancing
in
your
head,
they’re
attacking
you.
Twenty-four
hours
later,
sometimes
after
you’ve
checked
out
of
the
hotel
unless
you’'ve
stayed
two
nights,
you
find
yourself
in
excruciating
pain
from
where
the
bed
bug
slurped
some
bloed
out
of
you.
I
can
relate
this
story
firsthand
to
you,
folks,
because
I
am
a
victim
of
inadequate
inspection
of
a
hotel
room
where
the
bed
bugs
were
overlooked
and
allowed
to
dine
on
me
through
the
night.
Look
at
my
bites.
Imagine
my
pain.
Iam
on
4
different
presctiption
medications
to
alleviate
the
pain
and
infection.
Iwant
to
protect
you
from
suffering
the
way
I'm
suffering
with
these
bites.
In
this
day and
age,
no
one
should
have
to
suffer
bed
bug
bites.
If
a
hotel
simply
implements
reasonable
steps
for
the
prevention
of
bed
bug
infestation,
they
can
detect
the
bed
bugs
before
they
take
a
bite
out
of
you.
But
with
hotels
decreasing
staff
and
adding
more
work
to
housekeeping
staff,
the
staff
just
doesn’t
have
time
to
look
for
the
bed
bugs.
It’s
more
about
the
hotel
keeping
their
room
quotas
than
it
is
about
your
safety
and
health.
Even
in
a
prestigious,
luxury
hotel,
like
Le
Condé
Inn,
housekeeping
staff
are
overworked
and
ushed,
and
bed
bugs
infestations
occur.
That’s
where
I
was
attacked
by
bed
bugs
in
the
night.
Watch
this
clip
of
the
mattress
infested
with
bed
bugs
and
their
excrement
in
my
hotel
room
at
Le
Condé
Inn.
I
was
a
guest
at
the
hotel
the
weekend
of
July 11%.
T
woke
up
Sunday
morning
in
horrible
pain
and
bites
all
over
me.
Hotels,
like
Le
Condé
Inn,
are
putting
their
profits
above
your
health
and
safety.
It’s
simply
a
matter
of
poor
quality
assurance
and
negligence
for
failing
to
have
adequate
safeguards,
which
are
impossible
to
maintain
if
your
staff
is
understaffed
so
that
they
cannot
check
for
bed
bugs
adequately.
We
gave
Le
Condé’s
hotel
manager
a
chance
to
defend
the
hotel’s
inability
to
detect
the
bed
bugs
that
attacked
me
in
swarms.
All
Jacqué
Garnier
had
to
say
was
“I’m
sorry
for
exposing
you
to
bed
bugs
and
causing
any
suffering.”
Hey,
but
Garnier
offered
me
a
week’s
stay
at
the
hotel
“for
my
trouble!”
No
thanks
.
.
.
your
bed
bugs
are
your
suckers,
not
me!
EXHIBIT
6
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WYBU
ANCHOR
TESSENCE
ACCUSED
OF
FABRICATING
HOTEL
BED
BUGS
STORY
Le
Condé
Inn
Hotel
Manager
Jacque
Garnier
on
Friday
accused
WYBU
Anchor
Quinn
Tessence
of
planting
bed
bugs
at
the
Le
Condé
Inn
to
fabricate
a
story
for
an
exposé
on
hotel
bed
bugs
for
the
WYBU
“Breaking
News
Investigations”
segment
that
aired
on
Thursday.
Garnier
said,
“I’'m
outraged
that
Quinn
Tessence
and
WYBU
would
stoop
to
such
unethical
conduct
to
make
up
a
story
and
damage
the
fine,
long-standing
reputation
of
Le
Condé
Inn.
There
is
no
basis
to
WYBU’s
story.”
According
to
Garnier,
Le
Condé
Inn
follows
the
hotel
industry
protocol
for
ensuring
the
hotel’s
cleanliness
and
to
minimize
bed
bug
infestation,
“We’re
meticulous.
We’ve
never
had
any
problems
in
the
past,
and
we
certainly
don’t
have
any
problems
currently
either,”
Garnier
said.
No
bed
bugs
were
discovered
after
a
full
inspection
of
Le
Condé
on
Sunday
except
the
one
room
occupied
by
Quinn
Tessence
over
the
weekend.
“Don’t
you
think
that’s
odd?”
asked
Garnier.
Bed
bugs
typically
spread
rapidly
in
hotels
due
to
movement
of
guests
within
the
hotel
and
the
bugs
attaching
to
luggage
or
clothing.
Bed
bugs
are
rarely
confined
to
one
room.
Garnier claimed,
based
upon
a
reliable
inside
source,
Quinn
Tessence’s
bed
bug
exposé
was
going
to
be
canned
by
the
station
because
no
evidence
of
bed
bugs
had
been
uncovered
after
weeks
of
investigation.
Garnier
claims
that
Tessence
resorted
to
planting
the
bed
bugs
out
of
desperation.
Le
Condé
was
a
target
for
the
ruse,
according
to
Garnier,
because
the
hotel
and
Tessence
had
a
recent
dispute
over
a
bill
from
the
July
4h
weekend,
Garnier
claims
that,
according
to
the
inside
source,
Quinn
Tessence
frequently
crosses
the
line
in
ethical
news
reporting.,
Garnier
said,
Quinn
Tessence
doesn’t
care
about
the
facts,
it’s
all
about
drama
and
shock
value.”
Quinn
Tessence
was
unable
to
be
reached
for
comment.
EXHIBIT
7
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CURRICULUM
VITAE
REED
TAYNE,
M.D.
Education:
Undergraduate:
Purdue
University,
BS
in
Entomology,
1994
Medical
School:
Indiana
University,
MD,
1998
Residency:
Dermatology,
Indiana
University,
2002
Licensure
and
Certification:
Medical
License,
Indiana
Certified,
American
Board
of
Dermatology,
2002
Academic
Appointments:
Clinical
Instructor;
St.
Francis
Hospital
Center,
Department
of
Family
Practice,
Beech
Grove,
IN
Clinical
Instructor,
Indiana
University,
School
of
Medicine
Department
of
Dermatology,
Indianapolis,
IN
Hospital
Appointments:
Wishard
Memorial
Hospital,
Indianapolis,
IN
Methodist
HospitalIndianapolis,
IN
St.
Francis
Hospitals,
Beech
Grove,
IN
Community
Health
Network,
Indianapolis,
IN
Hendricks
Regional
Health,
Danville,
IN
Johnson
Memorial
Hospital, Franklin,
IN
‘Women'’s
Hospital,
Indianapolis,
IN
St.
Vincent
Hospitals,
Indianapolis,
IN
Employment
History:
Skin
Clinic
Institute
of
Indiana,
Indianapolis,
IN
2006-present
The
Dermatology
Center
of
Indiana,
PC,
Plainfield,
Indiana
2002-2006
Professional
Affiliations:
American
Medical
Association
American
Society
for
Dermatologic
Surgery
Indiana
Dermatological
Society
Indiana
State
Medical
Association
Indianapolis
Medical
Society
International
Society
of
Tropical
Dermatology
Society
of
Investigative
Dermatology
Publications:
Insect
and
arachnid
stings,
bites,
infestations,
and
repellents.
Pediatr.
Ann
2006.
Insect
bites
and
infestations.
Textbook
of
Dermatology,
21st
edition,
McGraw-Hill
2009.
What’s
New
in
Dermatology
Therapy:
Tticks
of
the
Trade.
Journal
of
Dermatology.
March
23,
2010.
Editor,
Bed
Bug
Chapter
in
The
Handbook
of
Investigative
Dermatology
10th
Edition
(2010).
Honors
and
Recognitions:
Featured
as
an
expert
on
NBC
Dateline,
CBS’s
The
Early
Show,
NBC’s
Today
Show
and
a
repeat
guest
on
National
Public
Radio
{NPR)
Dermatology
Foundation
Research
Award
Recipient,
2006
Qutstanding
Medical
Student
by
the
Dept.
of
Dermatology,
2002
EXHIBIT
8
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BED
BUG
INSPECTION
PROTOCOL
IDENTIFY
A
BED
BUG
INFESTATION
BEFORE
GUESTS
DO
*
Inspect
rooms
upon
vacancy
and
when
a
guest
complains
about
bed
bugs.
¢
Look
for
living
or
dead
bed
bugs, small
bloodstains
from
crushed
insects,
or
dark
spots
from
droppings
on:
o
linens,
mattress
and
its
seams,
bed
springs,
behind
the
headboard,
seams
of
upholstered
furniture,
between
floor
boards.
Pay
special
attention
to
cracks
and
spaces.
Vacuum
thoroughly.
Discard
the
used
vacuum
bag
in
a
sealed
plastic
bag
before
using
the
vacuum
in
another
room.
Repair
cracks
in
plaster
and
loose
wallpaper.
Seal
cracks
around
baseboards
completely
with
caulking
material.
O
0O
0O
O
0
WHEN
A
GUEST
COMPLAINS
ABOUT
BED
BUGS
OR
BITES:
Immediately
offer
a
new
room
to
the
guest.
Reassure
the
guest
that
bed
bugs
are
not
known
to
spread
disease,
Thoroughly
inspect
the
guest’s
luggage
and
clothing,
as
well
as
the
infested
hotel
room
and
the
new
room
to
which
the
guest
was
moved.
If
a
room
is
infested,
all
machine-washable
bedding,
curtains,
rugs,
towels,
and
bathrobes
should
be
cleaned
separately
in
the
hottest
water
and
dried
on
the
hottest
recommended
cycle.
Scrub
mattress
seams
with
a
stiff
brush
to
dislodge
bed
bugs
and
their
eggs.
Offer
to
launder
the
guest’s
clothes.
Bring
in
a
licensed
pest
control
professional
for
a
complete
inspection
and
treatment
of
the
room.
Don’t
use
the
infested
room
until
a
pest
control
professional
certifies
it
free
of
bed
bugs.
Place
infested
mattresses
or
box
springs
in
zippered
plastic
covers
and
store
them
for
at
least
one
year
before
using
them
again.
Securely
bag
all
discarded
materials
to
prevent
further
infestation.
Reinspect
the
room
periodically
to
ensure
that
bed
bugs
are
gone.
EXHIBIT
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HOUSEKEEPER
TASK
LIST
Bedroom
Tasks:
AN
NN
N
N
N
N
N
N
T
U
U
N
U
N
NS
Remove
all
room
service
items
from
room
Strip
beds
of
all
sheets,
blankets,
duvets
Place
bottom
sheet
on
each
bed and
tuck
8
times
Place
top
sheets
and
blanket
on
each
bed
and
tuck
8
times
Spread
duvet
on
bed
Remove
§
pillowcases
per
bed
and
stuff
pillows
into
fresh
cases
Dust
all
nightstands
and
desk
Restock
and
arrange
pens,
papers
and
room
service
menus
on
desk
Dust
armoire,
including
behind
the
TV
Clean
TV
screen
Retrieve
TV
remote
and
rearrange
TV
channel
guide
Pick
up
trash
and
empty
bedroom’s
wastebasket
Wash
and
dry
ice
bucket
and
rearrange
on
counter
Collect,
wash
and
dry
dirty
glasses
Dust
Vents
Put
away
all
ironing
boards,
luggage
racks,
and
all
other
equipment
Vacuum
all
floors
Bathroom
Tasks:
AN
N
N
N
N
N
N
N
N
N
N
NN
T
SR
Pick
up
soiled
towels
and
place
on
cart
Replace
soiled
towels
Clean
and
disinfect
toilet
bowl
Wipe
down
top
and
side
of
toilet
Restock
Toilet
paper
Wipe
down
counter
tops
Clean
sinks
and
polis
faucets
Replace
and
arrange
toiletries
Clean
bathroom
mirror
Wash
and
dry
coffeepot
and
cups
and
rearrange
on
counter
Scrub
inside
of
bathtub
Replace
shower
curtain
Clean
bath
and
shower
walls
Pick
up
trash
and
empty
bathroom
waste
basket
Mop
floor
Dust
vents
EXHIBIT
10
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LE
CONDE
INN
REVENUE
COMPARISON
THIRD
&
FOURTH
QUARTERS
2006
-
2008
Quarter
2006
2007
2008
Third
$3,223,338.89
$3,332,541.77
$2,105,112.42
Fourth
$3,561,442.60
$3,454,246.21
$2,338,337.68
EXHIBIT
11
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LE
CONDE
INN
30
Executive
Drive
Indianapolis,
Indiana
24
howrs
-
bites
seratching
worsens
problems
use
antihistamines
and
stervolds
—
Later
COMmEra
crew
—
a.m.
www.lecondeinn.com
EXHIBIT
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