This is class action product liability matter against a major commercial appliance manufacturer. The main issue in this case centers around allegedly defective refrigerators in North Dakota. In these units, water is collecting in a key system due to an alleged defective component used to prevent frost formation from condensation. As a result of multiple failures, a number of restaurants and commercial food suppliers have suffered property damage and product spoilage through leakage of stored water via the bottom of the fridge’s freezer. It was claimed that the appliances were defectively designed or manufactured by the defendant company.

I have extensive knowledge of refrigerator and refrigeration systems, including refrigerator and refrigeration evaporator system designs and repairs. This includes the requirements for evaporator defrost and condensation draining. I was trained in refrigeration and appliance service. I have been a technician for operational and maintenance service, including repairs and corrections. In a previous instance, the type of screws used to mount the bracket around and under the evaporator was the root cause of the issue. I also have dealt with industrial refrigeration evaporators and ensuring the condensation from their drain pans was appropriately being drained out without causing the drain lines from freezing, causing blockage and water damage. I have taken technical calls and helped others address issue that they had. I am presently helping with the development of a inspection and maintenance document that will include and address evaporator maintenance and their associated condensation drainage systems.

1. Do you have extensive knowledge of refrigerator systems? 2. Do you have hands on experience with the design and engineering of refrigerators?

Location: Maryland A.A.S., Refrigeration and Appliance Service, Dunwoody Industrial Institute B.S., Industrial Technology, University of Wisconsin-Stout Certified, Industrial Refrigeration Operator, RETA/CARO/CIRO Certified, Universal Refrigeration Transition and Recovery, ACCA Internship, Maintenance Engineer, Marriot Corporation Former R************ T********* E***** R************ Former M********** T********* (**** R************* C** C********** Former C******** P****** E******* O**** M**** F**** C********** Former F********* E********** M****** S*** L** C********** Former P**** U******** M****** P**************** N**** A****** Former U******** a** F********* S****** M****** D******* G**** I** C**** D******* Former D******* o* R************ A******** L******** Current D******* o* S******** a** S***** w******* l****** i******** o* a****** r************

Midwest

North Dakota

This expert has over 25 years of experience in refrigeration maintenance. He received his associates degree in Refrigeration and Appliance service as well as a bachelors degree in science and industrial technology. He is a certified industrial refrigeration operator as well as certified by the ACCA in universal refrigeration transition and recovery. He began his career in industrial refrigeration technologies as an intern for The Marriot Corporation as a Maintenance Engineer. He then went on to work as a maintenance technician where he performed operations and maintenance of HVAC, refrigeration, lighting, plumbing, electrical, and general utilities and facilities. He has also previously been employed by the Sara Lee Corporation as a Facilities Engineering Manager where he performed and Oversaw Capital & Expense Projects involving expansions, renovations, and modification of the facilities, utilities, Ammonia refrigeration, HVAC, production equipment, high voltage, and boilers. He now works for the international institute of ammonia refrigeration where he provides responses to technical requests for the working knowledge of industrial refrigeration applications.

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