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UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION

KYLE DAVIS and BETTY DAVIS, Case No. 15-cv-11125 

Hon. Judge Arthur Tarnow 

Plaintiffs, Magistrate Elizabeth A. Stafford 

vs. 

TRANE U.S. INC. d/b/a TRANE, 

a foreign corporation, 

Defendant. 

________________________________/ 

JOINT FINAL PRETRIAL ORDER 

The following is the Joint Proposed Final Pretrial Order. 

1. JURISDICTION. 

Subject matter jurisdiction is based on diversity of citizenship under 28 U.S.C. 

§1332 and no party disputes jurisdiction. 

2. CLAIMS. 

A. Plaintiffs’ Claims 

This is a product liability action (pursuant to Mich. Comp. Laws 600.2946(2), 

600.2946a(3) and 600.2949a), an implied warranty action, a breach of express 

warranty action, gross negligence action and willful disregard action against 

Defendant Trane. Plaintiffs seek recovery for Plaintiffs Kyle Davis and Betty Davis 

for the following injuries, including but not limited to: 

 Quadriplegia 

 pain and suffering 

 emotional distress and depression 

 loss of ability to enjoy the normal functions and pleasures of life 

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 loss of bowel and bladder control 

 loss of the ability to use his arms and legs 

 Hospital, nursing and allied care, including round-the-clock home nursing 

care, and the reasonable costs and expenses thereof 

 Housing, transportation, rehabilitation and other related and reasonable 

expenses and costs of his injury 

 Loss of employment and the loss of employment opportunity, and loss of 

wages and earning capacity 

 Humiliation and confinement to a wheelchair for the rest of his life 

 Loss of sexual function 

 As to Betty Davis - loss of consortium of her husband and the daily 

repetition of that loss in each and every facet of her life 

Defendant’s Theories and Defenses 

Plaintiffs bring various product liability claims against Trane including 

defective design, defective warnings, and breach of warranty. Trane designed and 

manufactured a chiller identified as a model RTWD 250 (the “Chiller”). The Chiller 

met or exceeded all industry standards, was safe and was not defective in its design 

and its warnings. The Chiller also did not breach any express or implied warranties. 

Trane is entitled to judgment as a matter of law on all of these claims. Unfortunately, 

Plaintiff Kyle Davis was injured when the Chiller fell off an elevated platform during 

a botched installation at Wayne Memorial High School, in Wayne Michigan. The 

Wayne Westland Community School District selected Plaintiff’s employer Johnson 

& Wood LLC as the contractor to install the Subject Chiller at the high school. 

Plaintiff is at fault for this accident. Plaintiff—trained in the rigging and 

installation of industrial equipment—was the lead foreman responsible for ensuring 

the safe and successful installation of the Chiller. However, Plaintiff ignored Trane’s 

recommended installation methods in Trane’s instruction manuals. He also 

neglected to read available warnings and instructions contained in those manuals and 

on the Chiller itself, including the express warnings that lifting the chiller by the 

non-recommended methods could result in serious injury. Specifically, Trane 

instructed that the Chiller be lifted with either a forklift or overhead rigging support. 

Plaintiff neglected to employ either of those methods (both of which were safely 

employed by subsequent contractors lifting the same model of Trane chiller at the 

same jobsite). Plaintiff instead chose to set the Chiller down one end at a time and 

to lift the Chiller by balancing one end of the Chiller on the head of a hydraulic ram 

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tool (inappropriately being used as a jack) without overhead support. During that 

installation maneuver, the chiller rotated and struck Plaintiff. Plaintiff’s own, unsafe 

rigging and installation methods, not any design feature of the Chiller, were the cause 

of this accident. 

Johnson & Wood is also at fault for this accident. The company purports to 

be an experienced mechanical contractor. It exposed Plaintiff to unreasonable risk 

of harm by sending Plaintiff and his crew to the installation site, under-equipped and 

under-prepared. The company failed: 

 to hire outside professional riggers to complete the installation component 

of the project, as previously promised; 

 to provide the crew with sufficient equipment to allow safe, appropriate 

rigging of the Subject Chiller; 

 to provide necessary manuals to the Subject Chiller and tools they were 

using to install the Chiller; and 

 to develop and/or implement company training and safety policies that 

could have prevented the accident. 

The company Johnson & Wood is a non-party-at-fault, to whom fault may be 

appropriately allocated by the jury for any and all of the foregoing reasons. 

Plaintiffs cannot meet their burden of proving that the Chiller is defective under 

Michigan law for at least the following reasons. First, Trane contends that 

Plaintiffs’ product liability claims are completely barred by the Michigan Product 

Liability Act because of Mr. Davis’s decision to lift the Chiller in total disregard of 

the rigging instructions and warnings constitute unforeseeable misuse and 

assumption of the risk. Second, Trane contends Plaintiffs’ warning claims must fail 

because both Mr. Davis and Johnson & Wood were “Sophisticated Users,” 

nullifying any duty to warn as a matter of law in the first place. Even if the law 

imposed a duty to warn under these circumstances (which it does not), Plaintiff 

cannot show that any warnings proximately caused his injuries because he neglected 

to review all warnings (or ignored them) in the first place. Third, Plaintiffs cannot 

meet their burden of proving a defective design, because an alternative design would 

not have prevented the harm caused by Mr. Davis’s unforeseeable misuse. Fourth

Plaintiff’s Warranty claims fail as a matter of law, too. Plaintiffs’ express warranty 

claim fails because they have not identified an actionable representation by Trane 

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and because Trane did not breach any warranties that it actually made. Plaintiffs’ 

implied warranty claims are precluded by Mr. Davis’s misuse and his status as a 

sophisticated user, under Michigan law. Lastly, Trane also is entitled to judgment 

as a matter of law on Plaintiffs’ other claims because they are not available and/or 

Plaintiffs cannot establish prima facie cases. 

4. STIPULATION OF FACTS. 

These facts are based on the statement of facts submitted by the parties with 

respect to the Defendant’s summary judgment motion. 

A. The following facts are not contested by the parties and require no 

proof: 

1. TRANE manufactured a chiller, a machine used for cooling, that is 

identified as a RTWD 250 chiller. 

2. TRANE designed and manufactured the RTWD 250 chiller involved 

in this lawsuit. 

3. Wayne Westland High School purchased a RTWD 250 chiller for 

installation. 

4. Plaintiff Kyle Davis was employed by a company named Johnson and 

Wood. 

5. Johnson and Wood inspected Wayne Westland School and bid to 

install the RTWD 250 chiller. 

6. Johnson and Wood received a submittal for the chiller on January 12, 

2012. 

7. Before the day of the installation, Plaintiff Kyle Davis and the 

Johnson and Wood project manager Brian Johnson, visited Wayne 

Westland High School boiler room to evaluate the installation 

process. 

8. On March 30, 2012, Mr. Davis was the lead foreman of a Johnson and 

Wood crew that included Chris Richardson, Shannon Ewka and 

Steven Ehrmantraut. 

9. At some point prior to the accident, Mr. Ewka left the premise. 

10. While attempting the installation of the Chiller, an accident occurred 

that pinned plaintiff Kyle Davis between the Chiller and the floor. 

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11. Mr. Davis suffered injuries as a result of the accident, including C5-

C7 incomplete quadriplegia 

5. ISSUES OF FACT TO BE LITIGATED. 

How the accident happened and facts supportive of the parties claims and defenses. 

6. ISSUES OF LAW TO BE LITIGATED. 

A. PLAINTIFFS’ ISSUES OF LAW 

1. Negligent/Gross Negligent Design 

a. As to Plaintiff’s negligent/gross negligent design claim, 

that the severity of Plaintiff’s injury was foreseeable by 

the Trane; 

b. that the likelihood of occurrence of the injury was 

foreseeable by Trane at the time of distribution of the 

subject Chiller; 

c. That the use of the Chiller as it existed at the time of the 

incident, by Kyle Davis and his coworkers, was 

reasonably foreseeable to Trane at the time of distribution; 

d. that there was a reasonable alternative design available 

that would have prevented the tipover such as widening of 

the base of the chiller to the same width as the widest 

portion of the chiller as designed by Trane; 

e. that the available alternative design was practicable; 

f. that omission of the available and practicable reasonable 

alternative design rendered defendant’s product not 

reasonably safe. 

g. The alternative design Chiller would not have tipped over 

with the use of a jack and skates. 

h. The tip-over was a direct and proximate result of the 

Chiller's top heavy, unstable design, inaccurate lifting 

instructions and information, and inadequate warnings. 

i. That numerous tipovers of chillers have occurred. 

j. that each time a chiller tips over TRANE fails to 

investigate the root cause, voids all warranties, and forces 

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the installer’s insurer to purchase a new chiller from 

TRANE. 

2. Negligent/Gross Negligent Warning 

a. As to Plaintiff’s negligent/gross negligent warning claim, 

that the severity of Plaintiff’s injury was foreseeable by 

the Trane; 

b. That the use of the Chiller at the time of the incident was 

foreseeable to Trane at the time of distribution; 

c. that the likelihood of occurrence of the injury was 

foreseeable by Trane at the time of distribution of the 

subject Chiller; 

d. that TRANE undertook to warn but failed to include 

pertinent information in its warnings including: 

i. TRANE had never measured the height of the CG 

on its chillers; 

ii. TRANE had misidentified the location of the CG on 

its chillers; 

iii. TRANE failed to notify its customers and installers 

that tipovers had occurred in the field while chillers 

were being lifted or moved using common industry 

practices such as skates and jacks; 

iv. TRANE’s only approved methods of lifting and 

moving chillers are often impossible to follow, 

forcing installers to improvise in order to install 

chillers leading to tipover; 

e. that there was a reasonable alternative design available, 

including but not limited to: 

i. actual measurement of the height of the CG 

ii. accurate identification of the location of CG; 

iii. warning installers that tipovers have occurred 

during installation using common industry practices 

such as skates and jacks 

iv. accurately advising that TRANE’s only approved 

methods for lifting or moving chillers are often 

impossible to follow and installers can be forced to 

improvise leading to tipovers; and/or 

v. chillers have tipped over when installed using 

common industry tools such as skates and jacks; 

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f. that the available alternative design was practicable; 

g. that omission of the available and practicable reasonable 

alternative design rendered defendant’s product not 

reasonably safe. 

h. The alternative design Chiller would not have tipped over 

with the use of a jack and skates. 

i. The tip-over was a direct and proximate result of the 

Chiller's top heavy, unstable design, inaccurate lifting 

instructions and information, and inadequate warnings. 

j.

3. Implied Warranty 

a. the Trane Chiller was not reasonably fit for the use or 

purpose anticipated or reasonably foreseeable by the 

defendant, in one or more of the ways claimed by the 

plaintiff 

b. the Trane Chiller was not reasonably fit for the use or 

purpose anticipated or reasonably foreseeable by the 

defendant at the time it left the defendant’s control 

c. the plaintiff was injured 

d. the unstable design and inappropriate 

warnings/instructions was a proximate cause of the 

injuries to plaintiff. 

4. Applicability of product liability cap on noneconomic damages 

5. Meaning and application of MCLA § 600.2945(e) and MCLA § 

600.2947(2). 

DEFENDANT’S ISSUES OF LAW 

1. Defective Design- Negligent Design 

 Consistent with M.C.L. 600.2946, Plaintiff bears the burden of establishing 

that the Trane RTWD 250 was not reasonably safe at the time the Chiller involved 

in this accident left the control of Trane and that, according to generally accepted 

production practices at the time the specific unit of the product left the control of 

the Trane, a practical and technically feasible alternative production practice was 

available that would have prevented the harm without significantly impairing the 

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usefulness or desirability of the product to users and without creating equal or 

greater risk of harm to others. 

 Plaintiff’s alternative design can be deemed “practical” and “feasible” only 

if the technical, medical, or scientific knowledge relating to production of the 

RTWD 250, at the time the specific RTWD 250 at issue in this case left the control 

of Trane, was developed, available, and capable of use in the production of the 

product and was economically feasible for use by the manufacturer. Technical, 

medical, or scientific knowledge is not economically feasible for use by the 

manufacturer if use of that knowledge in production of the product would 

significantly compromise the product’s usefulness or desirability. 

2. Defective Design- Negligent Warning 

 Consistent with M.C.L. 600.2946, Plaintiff bears the burden of establishing 

that the Trane RTWD 250 was not reasonably safe at the time the RTWD 250 

involved in this accident left the control of Trane because of an inadequate warning 

and that, according to generally accepted production practices at the time the 

specific unit of the product left the control of the Trane, a practical and technically 

feasible alternative warning was available that would have prevented the harm 

without significantly impairing the usefulness or desirability of the product to users 

and without creating equal or greater risk of harm to others. 

 Plaintiff’s alternative warning is practical and feasible only if the technical, 

medical, or scientific knowledge relating to production of the RTWD 250, at the 

time the specific RTWD 250 at issue in this case left the control of Trane, was 

developed, available, and capable of use in the production of the product and was 

economically feasible for use by the manufacturer. Technical, medical, or scientific 

knowledge is not economically feasible for use by the manufacturer if use of that 

knowledge in production of the product would significantly compromise the 

product’s usefulness or desirability. 

3. Plaintiffs’ Express Warranty Claim 

 Can Plaintiff prove that Trane made a statement or otherwise represented 

(orally, in writing, or by any other means) that the Chiller had certain characteristics 

or would meet certain standards? 

 Can Plaintiff prove that Trane (1) expressly warranted the Chiller in one or 

more ways; (2) that Plaintiff reviewed and relied upon the express warranty; (3) 

that the Chiller failed to meet the terms of the express warranty in any way; (4) that 

the Chiller failed to meet the express warranty terms at the time it left Trane’s 

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control; (5) that Plaintiff was injured; and that Plaintiff’s injury was proximately 

caused by the Chiller’s failure to meet the express warranty, if at all. 

 Can Plaintiff prove that any such express warranty was not limited? 

4. Plaintiffs’ Implied Warranty Claim 

 Can Plaintiff prove (1) that the Chiller was not reasonably fit for the use 

anticipated and reasonably foreseeable by the defendant; (2) that the Chiller was so 

unfit at the time the Chiller left Trane’s control; (3) that the Plaintiff was injured; 

(4) and that those injuries as proximately caused by the defect or unfit condition 

claimed by Plaintiff. 

5. Trane’s Defense-Misuse 

 Did Plaintiff unforeseeably misuse the Trane Chiller, (i.e., “contrary to 

Trane’s instructions and warnings, as defined by MCL § 600.2945(e)), precluding 

liability as a matter of law? 

 

6. Trane’s Defense-Assumption of Risk 

 Did Plaintiff assume the risk of his injury, precluding liability as a matter of 

law? 

7. Duty to Warn/No Duty to Warn Sophisticated User 

 Did Trane owe Plaintiff, a Sophisticated User, a duty to warn Johnson and 

Wood Plaintiff Kyle Davis that misuse was dangerous? Also, was there any 

associated duty to warn a sophisticated user? 

8. Trane’s Defense-Proximate Cause As to Warnings 

 Can Plaintiffs show that inadequate warnings proximately caused his injuries 

where he neglected to review available warnings? 

 

9. Trane’s Defense-No Alternative Design That Would Have Reduced Risk 

 Can Plaintiffs establish a prima facie design defect claim where their 

proposed alternative designs are not practical or feasible and would not have 

reduced the risk of injury posed by his unforeseeable misuse? Also, Plaintiffs never 

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proffered an alternative warning and cannot make the requisite showing under 

Michigan law. 

10. Trane’s Defense- No Express Warranty 

 Can Plaintiffs establish an express warranty claim where Plaintiffs have not 

identified any actionable representation or promise by Trane, and where Trane did 

not breach any existing representation or promise regarding the Chiller’s 

performance? 

11. Trane’s Defense-No Implied Warranty 

 Can Plaintiffs maintain an implied warranty claim where the Chiller was not 

defective and unreasonably dangerous at the time it left Trane’s control, and/or 

Kyle Davis was a Sophisticated User, and misused the Chiller outside of its 

intended use? 

12. Trane’s Defense-Punitive Damages 

 Can Plaintiffs demonstrate the requisite level of conduct necessary to 

establish punitive or exemplary damages? 

13. Trane’s Defense-No Gross Negligence 

 Can Plaintiffs prove a colorable claim of gross negligence claim, given 

Plaintiff Kyle Davis’ and Johnson & Woods’ status as Sophisticated Users, and 

where Trane’s efforts to provide safety warnings and instructions do not show a 

substantial lack of concern for whether injury results? 

14. Trane’s Defense-Comparative Fault of Kyle Davis 

 Was Plaintiff Kyle Davis comparatively at fault and was his comparative 

conduct partially or wholly responsible for his alleged injuries? 

15. Trane’s Defense-Non-Party At Fault Johnson & Wood 

 Was Plaintiff Kyle Davis’ employer, Johnson & Woods, at fault and was its 

fault partially or wholly responsible for Plaintiffs’ injuries or damages? 

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7. EVIDENCE PROBLEMS LIKELY TO ARISE AT TRIAL. 

Plaintiffs’ Likely Evidence Problems: 

 Admissibility of the 2012 IOM for the Chiller 

 Admissibility of the warnings or literature associated with the Westward jack 

used during the installation of the Chiller 

 Admissibility of testimony regarding subsequent remedial measures as to the 

re-installation of the subject chiller and replacement chiller, including but not 

limited to Kevin Jouppi 

 Admissibility of hearsay contained in testimony of Nicholas Thornton as to 

alleged conversations with Brian Johnson 

 Admissibility of written Steven Ehrmantrout statement post-accident as 

inadmissible hearsay 

 Ability of Defendant’s experts to render any testimony regarding rigging 

 Admissibility of testimony of MIOSHA representatives, including MIOSHA 

representatives’ qualifications and foundation 

Defendant’s Likely Evidence Problems: 

 Admissibility of subsequent remedial measures or the communications 

surrounding the remedial measure (See Motion In Limine (Docket #148) and 

Court’s December 12, 2019, ruling at page 12.) 

 Admissibility of any of the purported OSIs (See Motions In Limine (Docket 

# 143, 145, and 147) and Court’s December 12, 2019, ruling at pages 2-10.) 

 Admissibility of Plaintiff’s purported animation 

 Chain of custody of hydraulic ram and skates 

 Admissibility of prototype documents not representative of the RTWD 250 

chiller 

 Admissibility of any documentation other than the RTWD 250 

 Admissibility of any isolator photographs taken years after the accident 

 Admissibility of the “complete” files of experts as one exhibit 

8. WITNESSES. 

A. Plaintiffs’ Witnesses: See Document No. 234 – Plaintiffs’ Rule 26 

Pretrial Disclosure Witness List. (Objected to by Defendant) 

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B. Defendant’s Witnesses: See Document No. 211 – Defendant’s Rule 

26 Pretrial Disclosure Witness List.

9. EXHIBITS. 

A. Plaintiffs’ Exhibits. - See Document No. 233 – Plaintiffs’ Rule 26 

Pretrial Disclosure Exhibit List. (Objected to by Defendant) 

B. Defendant’s Exhibits: See Document No. 212 - Defendant’s Rule 26 

Pretrial Disclosure Exhibit List. 

C. As to the following exhibits, the party against whom the exhibit is to 

be offered objects to the admission of the exhibit and offers the 

objection stated below: 

1. Plaintiffs’ Objections to Defendant’s Exhibits 

Plaintiffs object to the admission of any material regarding the 

Westward Ram including the Westward Ram manual or any other literature 

regarding the Westward Ram used by the Plaintiff at the time of the incident. 

Plaintiffs object to the admission of any MIOSHA material regarding 

investigation of the incident in this case, or any violations or citations issued 

in response to the incident at issue in this case. 

Plaintiffs object to the admission of documents created by Nicholas 

Thornton. 

Plaintiffs object to the admission of the 2012 IOM regarding the 

RTWD Chiller 

Plaintiffs object to testimony regarding subsequent remedial measures 

as to the re-installation of the subject chiller and replacement chiller 

Plaintiffs object to introduction of information regarding workers 

compensation insurance 

Plaintiffs object to expert testimony and opinions outside of those 

contained within Defendant’s expert Rule 26 disclosures and object to 

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demonstrative exhibits offered in connection with expert testimony as said 

Defendant’s experts lack the necessary qualifications to testify regarding 

rigging and the conditions contained within the demonstrative exhibits are in 

no way substantially similar to the event in question and is therefore 

misleading. Plaintiffs would ask that the Court rule consistent with the 

exclusion of Defendant expert Jason Mattice’s newly disclosed opinions. 

Plaintiffs further rely on all motions in limine filed with this Court for 

objections related to exhibits. 

Plaintiffs further attach a chart of their objections to Defendant’s 

exhibits. 

2. Defendant’s Objections to Plaintiff’s Exhibits 

 Defendants intend to file as a separate filing a chart of their objections 

to Plaintiffs’ exhibits. 

10. DAMAGES. 

Plaintiffs’ damages include: 

Economic damages include lost earning capacity, household services, 

caretaking services (professional care), medical care (including equipment, 

therapies, doctor visits, etc.). 

The economic value of these items is approximately as follows (it should 

be noted that the numbers provided do not account for present cash reduction of 

future damages): 

Lost earning capacity (past and future): $ 4,257,773 

Household services (past and future): $ 1,289,636 (2 hours/day) 

to 

$ 1,934,455 (3 hours/day) 

Future medical expenses: $ 28,389,506 

Past medical expenses: $5,236,317.47 

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Approximate total economic damages: $39,173,232.47 

to 

$39,818,051.47 

The past medical expenses amount as well as the past earning capacity 

amounts will have changed by the time of trial because some of the future amounts 

will be actual amounts paid by then. The numbers will be updated and clarified 

before trial. 

Non-economic damages include pain & suffering, emotional distress, 

humiliation, embarrassment, loss of consortium, etc., for both Kyle and Betty 

Davis. These damages inherently are not subject to precise calculation and are left 

within the sound discretion of the jury based on the evidence. 

Defendant’s Objection to Plaintiffs’ Damages Claims: Defendant contests 

some of the purported damages and the damage calculations proposed by 

Plaintiffs’ experts. Defendant also contends that Plaintiffs cannot make the 

requisite showing to establish that punitive and/or exemplary damages are 

warranted. The record in this case lacks sufficient evidence for Plaintiffs to prove 

an entitlement to punitive or exemplary damages. Further, punitive damages are 

not recoverable as a matter of law. 

11. TRIAL. 

 A. This is a jury trial. 

 B. Length of trial. 

Plaintiffs believe that the trial will take three weeks assuming full trial days. 

Defendants believe the trial will take much longer if the existing scheduling order 

is modified. When the parties originally estimated trial length at 3 weeks, 

Defendant was proceeding under the assumption that Judge Cohn’s previously 

imposed limitations, never withdrawn or modified by this Court, were applicable. 

If Plaintiffs are allowed to call 23 fact witnesses, live or by deposition, and 5 

damage experts, the length of this trial cannot be less than 5 weeks assuming full 

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trial days. If the court is inclined to go shorter days, the estimated trial will be 

considerably longer. 

12. SETTLEMENT. 

The parties have engaged in settlement discussions previously, with the 

Court. The discussions have not resulted in settlement. 

SO ORDERED. 

 s/Arthur J. Tarnow 

 ARTHUR J. TARNOW 

 SENIOR U.S. DISTRIC JUDGE 

March 10, 2020 

Respectfully submitted, 

 /s/ Courtney E. Morgan Jr. (P29137) 

 Courtney E. Morgan Jr. (P29137) 

Brian T. Keck (P77668) 

Law Offices of Courtney Morgan PLLC 

3200 Greenfield, Ste. 355 

Dearborn, MI 48120 

(313) 395-2568 

cmorgan@courtneymorganlaw.com

bkeck@courtneymorganlaw.com

Richard M. Goodman (P14169) 

Kathleen J. Kalahar (P60301) 

Attorneys for Plaintiffs 

1394 East Jefferson Ave. 

Detroit, MI 48207 

(313) 567-6165 

rgoodman@goodmankalahar.com 

kkalahar@goodmankalahar.com 

Case 2:15-cv-11125-AJT-EAS ECF No. 244, PageID.9367 Filed 03/10/20 Page 15 of 16
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Paul A. Zebrowski (P44427) 

Thomas A. Biscup (P40380) 

Co-Counsel for Plaintiffs 

45952 Schoenherr Rd. 

Shelby Township, MI 48315 

(586) 566-7266 

paul@zebrowskilaw.com 

tom@zebrowskilaw.com 

 DYKEMA GOSSETT, PLLC 

By: /s/ James P. Feeney (P13335) 

James P. Feeney (P13335) 

Harold D. Pope (P34882) 

Brian T. Smith (P56174) 

Bryce Rucker (P79455) 

39577 Woodward Avenue 

Suite 300 

Bloomfield Hills, MI 48304 

(248) 203-0700 

jfeeney@dykema.com 

hpope@dykema.com 

btsmith@dykema.com 

brucker@dykema.com 

Attorneys for Defendant Trane U.S. Inc., 

d/b/a Trane

Dated: March 2, 2020

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