Contract analysis

I. Purpose and Scope This memorandum consolidates the key testimony from all ten property-level depositions taken during the January 9 – March 17, 2023 fact-deposition window established by the Court's Amended Case Management Order dated November 4, 2022. The purpose of this composite summary is to provide the case team with a single reference document that synthesizes the testimony of property-level personnel, ident

II. Identification of Deponents A. Table of Witnesses The following table identifies each of the ten property-level deponents, their titles, entity affiliations, the properties for which they had relevant responsibility, the date and approximate duration of each deposition, and the examining attorney from Calderwood & Harkness. B. Representation Note All ten deponents were represented by Whitfield, Barrow & Crane LLP

III. Recurring Themes and Key Findings The following subsections identify the principal themes and factual findings that emerged consistently across the ten property-level depositions. These themes are presented in order of significance to Verimark's claims. A. Direction from "Corporate" to Route Bookings Through Suncoast Room Management Inc. Central finding: Across all ten depositions, a consistent and remarkably un

IV. Witness-by-Witness Summaries The following subsections provide individualized summaries of each of the ten depositions, including the key testimony elicited, notable cross-examination exchanges, and the principal exhibits introduced or referenced during each session. A. Raymond Ochoa — General Manager, Verimark Suites – Naples Bayfront (January 12, 2023) Raymond Ochoa has been employed by Gulf Breeze Hospitality

I. Thomas Ingram — General Manager, Verimark Select – Jacksonville Oceanfront (March 8, 2023) Thomas Ingram has been employed by Coastal Palms Franchise Holdings LLC since 2016 and serves as General Manager of the Verimark Select – Jacksonville Oceanfront property. His deposition lasted approximately four hours and was conducted by Carlos Espinoza. Ingram's testimony was notable in several respects. First, as a relat

V. Impeachment Opportunities and Inconsistencies The following subsections identify the principal impeachment opportunities and internal inconsistencies that emerged from the property-level depositions when compared with prior deposition testimony in this case. A. Pham's Testimony vs. Brecker's Deposition Susan Pham's testimony regarding the origin of the Suncoast revenue exclusion methodology is largely consistent w