IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

DANIEL MEDINA and NIKITA GROSS,

Plaintiffs, Civil Action No.

Cook County Circuit Case No.

PUBLIC STORAGE, INC., a Maryland Real 2011-L-011664
Estate Investment Trust, WILLIS INSURANCE
SERVICES OF CALIFORNIAN, INC., a
California Corporation, and PS ILLINOIS
TRUST,

Defendants.

AFFIDAVIT OF ALAN GROSSMAN IN SUPPORT OF

DEFENDANT PUBLIC STORAGE’S NOTICE OF REMOVAL
I, Alan Grossman, declare as follows:
1. I am over the age of 18 and am competent to make this declaration. I have personal
knowledge of the facts stated herein as a result of my employment with Public Storage (“Public
Storage”) and, if called to testify concerning them, could do so competently.
2. I am employed by Public Storage. I am the Senior Vice President and Chief Financial
Officer Public Storage’s Self-Storage Operations. I have held this position for approximately six
years. In total, I have been with the company for more than 20 years. As Senior Vice President
and Chief Financial Officer, I oversee the financial reporting of the self-service storage business
and help to develop the policies and procedures of the self-service storage operations.

3. On December 11, 2011, Public Storage first received notice of this action when it
was served with process and the Complaint in this action in the Circuit Court of Cook County,
Illinois under the caption Medina, et al. v. Public Storage, Inc., et al., Case No. 2011L011664.

4. Public Storage is a Maryland Real Estate Investment Trust organized under the
laws of the state of Maryland. Its principal place of business is in California. Its headquarters are
located at 701 Western Avenue, Glendale, California, which is where much of the company’s

management, operational, and administrative personnel are located.


5. PS Illinois Trust is a Delaware Corporation with its principal place of business in
Glendale, California.

6. Public Storage owns and operates over 2,000 storage facilities, totaling over
129,000,000 in net rentable square feet, in at least 38 states. Although the number of storage
units at each facility varies, in general each storage facility has at least a few hundred and can
have as many as a few thousand storage units that are regularly rented to the public. From
December 2007 to the present, Public Storage has had more than 5,000,000 storage tenants
nationwide.

7. Based on the Complaint, it is my understanding that plaintiffs are seeking to
invalidate certain paragraphs of the rental agreement(s) that Public Storage utilizes at its storage
facilities in Illinois, which would necessarily affect the rental agreement(s) Public Storage
utilizes at its storage facilities in various other states as well. If plaintiffs are successful in
invalidating the challenged paragraphs of Public Storage’s rental agreement(s), Public Storage
will be forced to spend hundreds of thousands of man hours in revising and re-issuing its rental
agreement(s), retooling its training programs and materials, retraining thousands of Public
Storage property managers and employees who present and explain contracts to customers
throughout the country, and communicate with potentially millions of customers across the
nation, among other things. I estimate that it would cost us over $3,000,000 in hard costs and
man hours to address these issues alone.

8. Moreover, it is my further understanding that plaintiff is seeking to invalidate a
portion of the Insurance Election Addendum to Rental Agreement (“insurance agreement”)
offered to individuals who rent storage units from Public Storage. This would present many of
the problems noted above in paragraph 7. Plus, Public Storage would be forced to renegotiate
the terms of its agreement with defendant Willis Insurance Services of California, Inc. or
potentially find a new insurance company to provide storage insurance to Public Storage’s
customers. In addition to the time and expense associated with these negotiations, Public

Storage will also be forced to spend thousands of man hours retraining thousands of Public


Storage employees who present the Willis storage insurance program to our customers on behalf
of Willis across the country regarding the change of insurance coverage, contacting tens or
hundreds of thousands of current Public Storage customers on behalf of Willis who have signed
insurance agreements containing the challenged language, and issue new insurance agreements
nationwide, among other things. I estimate that it would cost us over $1,000,000 in hard costs
and man hours to address the invalidation of requested portion of the insurance agreement.

9. Furthermore, it appears that plaintiffs are also attacking the security measures
implemented by Public Storage nationwide as indicated by their Eighth Cause of Action.
Although the complaint is not specific, if Public Storage’s security measures are found to be
lacking in any way, then Public Storage will most likely be forced to undergo a time consuming
investigation and analysis of its nationwide security measures and potentially invest thousand of
man hours re-tooling its security protocols, retraining its property managers and employees in the
revised security measures, and re-issuing its security protocols, among other things. Without
knowing the full extent of the challenges to Public Storage’s security measures and protocols that
plaintiffs are challenging or what they are seeking to change, | estimate that a general overhaul
of Public Storage’s security measures and protocols will cost us over $1,000,000 in hard costs
and man hours.

I declare under penalty of perjury under the laws of the State of California and the United
States of America that the foregoing is true and correct, and that this Declaration was executed

on January 10, 2012, at Glendale, California.

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Alan Grossman