Drooz‟s declaration were: a September 6, 2006 fire department “Equipment Performance Certificate” which indicated there were no defects in the elevators ; an October 2, 2006 fire department document entitled “Fire Pump Performance Test” which stated the fire pump room was very clean and in good operating condition ; a memorandum dated November 16, 2006 indicating there only minor discrepancies as a result of testing by Atlantic Electric; and the November 25, 2006 results of the 2006 Regulation 4 testing. All of the deficiencies were corrected. One document possessed by defendants indicated that during an August 22, 2006 inspection, it was discovered that the event level rear hallways quartz lamps needed to be relamped and an exit sign near the broadcast scoreboard was not lit. Another document indicatedwere proceedings. Also attached to Ms. Drooz‟s declaration was a December 4, 2006 letter from Tim Fikre, the group‟s executive vice president and general counsel, to Paula Madison, the president and general manager of the station. According to Mr. Fikre, Mr. Snepp had misinterpreted documents relative to fire safety systems testing which occurred prior to the issuance of the occupancy permit. Mr. Fikre‟s letter was responded to on December 7, 2006, by Jennifer S. Domintz, a legal affairs vice president for NBC Universal. Ms. Domintz indicated that her client disagreed with many of Mr. Fikre‟s assessments. She wrote: “However, rather than engage in an extended exchange of letters, we propose that the more productive and appropriate forum in which to discuss the issues you have raised is the