Hotel Law Blog

Published on: September 2, 2015

FCC says blocking FCC-approved Wi-Fi hotspots is “patently illegal” and imposes $750,000 fine on Smart City.

By Jim Butler and the Global Hospitality Group®

02 September 2015

Blocking Wi-Fi connections is “patently unlawful”

On August 18, 2015, the FCC announced a $750,000 civil penalty and formal Consent Decree with Smart City Holdings for blocking consumers’ personal Wi-Fi access at various convention centers, meeting centers and hotels around the United States. Smart City is an internet and telecommunications provider for such facilities, and had been blocking personal mobile “hotspots” being used by convention and meeting attendees.

Apparently referring to the $80 daily fee charged by Smart City for use of its Wi-Fi at the events, Travis LeBlanc, Chief of the FCC’s Enforcement Bureau said, “It is unacceptable for any company to charge consumers exorbitant fees to access the Internet while at the same time blocking them from using their own personal Wi-Fi hotspots to access the Internet.”

The FCC Enforcement Chief went on to say, “All companies who seek to use technologies that block FCC-approved Wi-Fi connections are on notice that such practices are patently unlawful.”

The FCC is focused on preventing Wi-Fi blocking

The FCC action in the Smart City case really emphasizes how serious the FCC is about stopping the practice of hotels and related facilities from blocking consumer hotspots in order to sell their own more expensive access to the internet.

Starting with high-profile investigation and settlement with Marriott International last year, the FCC has taken the following steps: CONTINUE READING →

Published on: August 31, 2015

What every hotel owner (and operator) needs to know about “data security” after the Wyndham Worldwide case

By Jim Butler and the Global Hospitality Group®

31 August 2015

Click here for the latest articles on Data Technology, Privacy & Security.

Massive data breaches affect hotels and their legal responsibilities. As unauthorized hacking of confidential data explodes in volume and seriousness, minimum expected standards are evolving that hoteliers and others must follow. Interestingly, the latest guidelines are provided in an August 24, 2015 appellate court decision involving Wyndham Worldwide as if to emphasize that these rules (really) apply to the hotel industry. How did this case arise? What are some basic steps that everyone with confidential data is expected to take? What happens if they don’t?

In the article below, my partner Bob Braun, explains the current situation and what it means to our industry.
FTC vs. Wyndham Worldwide – What it Means for Hotel Owners

by
Bob Braun, Hotel Lawyer and Data Security Advisor
Background on the case

On August 24, 2015, the Third Circuit United States Court of Appeals issued its ruling in the case FTC v. Wyndham Worldwide Corporation. The case was highly anticipated by the data security community generally for its expected ruling on the authority of the Federal Trade Commission to regulate data security standards, but nowhere was the anticipation more keen than in the hospitality industry. After all, this decision didn’t deal with retailers, banks or dating sites – it addressed a major hotel player and, by implication, all operators, brands and owners in the industry.

We know that cybercrime is big. In 2014, there were 42.8 million detected security incidents (and, most likely, many more that were never discovered). Estimates of annual cost of cybercrime to the global economy ranges from $375 billion to as much as $575 billion as companies face increased vulnerability, ranging from greater technology available to cybercriminals and new types of cybercrime, like crypto-ransom. CONTINUE READING →

Published on: June 24, 2015

Video: Bill Sipple of HVS Capital discusses hospitality market activity and interest rates – 2015 Hotel Investment and Finance Opportunities

By Jim Butler and the Global Hospitality Group®

24 June 2015

Bill Sipple, Executive Managing Director of HVS Capital, speaks in the video below about activity in different markets, limited service properties, and whether rising interest rates will have an effect on transactional activity.

Bill sat down with Bob Braun, a senior partner in the JMBM Global Hospitality Group®, as part of our video interview series on hotel finance and investment opportunities in 2015.

A transcript follows the video.

Bob Braun: Hi, I’m Bob Braun. I am a Partner at Jeffer Mangels Butler & Mitchell. I’m here at Meet the Money® 2015, our 25th anniversary. I’m here with Bill Sipple, who is the Executive Managing Director of HVS Capital. Bill, thanks for coming by and talking with us.

Bill Sipple: It’s good to be here, thanks. CONTINUE READING →

Published on: June 23, 2015

Video: Jack Westergom of Manhattan Hospitality Advisors discusses hotel operating agreements and asset management – 2015 Hotel Investment and Finance Opportunities

By Jim Butler and the Global Hospitality Group®

23 June 2015

Jack Westergom, Managing Director of Manhattan Hospitality Advisors, discusses hotel operating agreements, asset management, and the RFP process in the video below.

Jack spoke with David Sudeck, a senior partner in the JMBM Global Hospitality Group®, as part of our video interview series on hotel finance and investment opportunities in 2015.

A transcript follows the video.

David Sudeck: I’m David Sudeck. I’m a senior attorney with Global Hospitality Group® at Jeffer Mangels Butler & Mitchell. We’re here at the 25th Annual Meet the Money® Conference. I’m here with Jack Westergom, Managing Director of Manhattan Hospitality Advisors. Welcome.

Jack Westergom: Thank you. CONTINUE READING →

Published on: June 22, 2015

City of Los Angeles v. Patel — US Supreme Court voids LA ordinance requiring hotel operators to turn over guest records on demand

By Jim Butler and the Global Hospitality Group®

22 June 2015

US Supreme Court voids Los Angeles ordinance requiring hotel operators to turn over guest records on demand

In a 5-4 opinion rendered on June 22, 2015, the United States Supreme Court held that a Los Angeles municipal code provision violates the US Constitution’s Fourth Amendment prohibition on unreasonable search and seizures. The invalidated LA Code provision requires hotel operators to make guest records available to the police upon request. This case may be significant because many cities throughout the country have similar laws, and they are now all constitutionally suspect. On the other hand, for reasons discussed below, most hotel operators will probably not care to challenge a records request, and there are expedient alternatives available to cities and police, including administrative subpoenas. See below to access the full Supreme Court opinion in City of Los Angeles v. Patel.

Read on to learn more about the Los Angeles City code’s provisions, the history of the challenge in the District Court, appeals to the Ninth Circuit, and the US Supreme Court’s decision. CONTINUE READING →

Published on: June 22, 2015

Video: Vail Brown of STR talks about all-time highs in hotel supply growth, occupancies, and other metrics – 2015 Hotel Investment and Finance Opportunities

By Jim Butler and the Global Hospitality Group®

22 June 2015

Vail Brown, Vice President of STR, discusses all-time highs in the hospitality market for multiple metrics, her predictions for the next few years, and STR’s expansion into food and beverage analysis in the following video.

Vail spoke with David Sudeck, a senior partner in the JMBM Global Hospitality Group®, as part of our video interview series on hotel finance and investment opportunities in 2015.

A transcript follows the video below.

David Sudeck: I’m David Sudeck, I’m with Jeffer Mangels Global Hospitality Group. We’re here at the 2015 Meet the Money® Conference, which is the 25th Annual Meet the Money® Conference. We’re with Vail Brown, Vice President of STR. Welcome.

Vail Brown: Thank you. CONTINUE READING →

Published on: June 19, 2015

Video: Stephen Rushmore, Jr. of HVS talks about hotel values and brand proliferation – 2015 Hotel Investment and Finance Opportunities

By Jim Butler and the Global Hospitality Group®

19 June 2015

Stephen Rushmore, Jr., President and CEO of HVS, speaks in the video below about hotel values in the next few years, new development, and brand proliferation.

Stephen spoke with David Sudeck, a senior partner in the JMBM Global Hospitality Group®, as part of our video interview series on hotel finance and investment opportunities in 2015.

A transcript follows the video.

David Sudeck: We are at the 25th Annual Meet the Money® Conference 2015. I am happy to be here with Stephen Rushmore, President and CEO of HVS. Welcome, Stephen.

Stephen Rushmore, Jr.: Good to be here. Thanks. CONTINUE READING →

Published on: June 18, 2015

Video: Deric Eubanks of Ashford Hospitality Trust talks about the hottest hospitality segments for investors – 2015 Hotel Investment and Finance Opportunities

By Jim Butler and the Global Hospitality Group®

18 June 2015

Deric Eubanks, Chief Financial Officer of Ashford Hospitality Trust, discusses why now is a great time to buy hotels, which segment provides the best opportunities, and how supply growth will affect the hospitality industry over the next few years.

Deric sat down with Bob Braun, a senior partner in the JMBM Global Hospitality Group®, as part of our video interview series on hotel finance and investment opportunities in 2015.

A transcript follows the video below.

Bob Braun: Hi, I’m Bob Braun. I am a Partner at Jeffer Mangels Butler & Mitchell and I’m a senior member of our Global Hospitality Group, and I’m here with Deric Eubanks, who is the CFO of Ashford Hospitality Trust. We wanted to take a chance to talk about what you see in the market, and importantly, how Ashford is reacting to what you see in the market.

Deric Eubanks: Sure. CONTINUE READING →

Published on: June 17, 2015

Video: Alice Gao of ICBC talks about the world’s largest bank – 2015 Hotel Investment and Finance Opportunities

By Jim Butler and the Global Hospitality Group®

17 June 2015

Alice Gao, Senior Vice President of the Industrial and Commercial Bank of China, discusses ICBC’s global reach, its U.S. lending program, and recent deals in the video below.

Alice spoke with David Sudeck, a senior partner in the JMBM Global Hospitality Group®, as part of our video interview series on hotel finance and investment opportunities in 2015.

A transcript follows the video.

David Sudeck: We’re here at the Meet the Money® Conference 2015, which is the 25th Annual Hotel Investment Conference for JMBM. I’m sitting here with Alice Gao, Senior Vice President and Head of Commercial Banking with ICBC. Thank you for joining us. Nice to see you.

Alice Gao: Hi David, thank you for inviting me. CONTINUE READING →

Published on: June 16, 2015

Video: Don Li of Interstate Hotels discusses Chinese investment in U.S. hotels – 2015 Hotel Investment and Finance Opportunities

By Jim Butler and the Global Hospitality Group®

16 June 2015

Don Li, head of Asia Investment for Interstate Hotels, speaks in the video below about what drives Chinese investment in U.S. assets, why an understanding of language and cultural issues is important, and what types of hotels foreign investors are looking for.

Don sat down with David Sudeck, a senior partner in the JMBM Global Hospitality Group®, as part of our video interview series on hotel finance and investment opportunities in 2015.

A transcript follows the video.

David Sudeck: I’m David Sudeck. I’m a partner with JMBM’s Global Hospitality Group®. We’re here at the 2015 Meet the Money® Conference which is the 25th Annual Meet the Money® Conference. Thank you for joining us. I’m here with Don Li, the head of Asia Investment for Interstate Hotels.

Don Li: Yes. Thank you. CONTINUE READING →

Jim Butler

Jim Butler is recognized as one of the top hotel lawyers in the world. He devotes 100% of his practice to hospitality, representing hotel owners, developers and lenders. Jim leads JMBM’s Global Hospitality Group® — a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion.
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Robert Braun

Robert Braun is a partner in JMBM's Corporate Department and a senior member of JMBM's Global Hospitality Group® -- a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion. Bob represents owners in both transactional and operational issues. He advises clients with respect to business formation, financing, mergers and acquisitions, venture capital financing, joint ventures and strategic partnerships. He has represented hotel owners in the negotiation of several hundred management agreements, as well as spa management and franchise agreements. Bob also advises hotel owners regarding telecommunications, software, internet, e-commerce, data processing and outsourcing agreements. To read Bob's articles, go to www.HotelLawBlog.com and select "Management Agreements." For more information, please contact Bob Braun at 310.785.5331 or rbraun@jmbm.com.

Marta Fernandez

Marta Fernandez is a partner in JMBM's Employment and Labor Department and a senior member of JMBM’s Global Hospitality Group® -- a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion. As a management labor lawyer with more than 20 years of experience, Marta specializes in representing hospitality industry clients in all aspects of labor and employment including labor-management relations such as union prevention, collective bargaining for single as well as multi-employer bargaining units, neutrality agreements and defense of unfair labor practice charges before the NLRB. She defends employers in administrative and litigation claims, such as employee claims of sexual harassment and discrimination and counsels clients in preventative strategies such as executive training, arbitration enforcement, and policies and procedures. To read Marta's articles, go to www.HotelLawBlog.com and select "Labor & Employment." For more information, please contact Marta Fernandez at 310.201.3534 or at mfernandez@jmbm.com.

Guy Maisnik

Guy Maisnik is a partner in JMBM's Real Estate Department and a senior member of JMBM's Global Hospitality Group® -- a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion. Guy's deep and broad transactional practice includes complex real estate finance and venture capital transactions, including project finance, commercial finance, leveraged leasing and real estate acquisitions. He assists clients with development, leasing and disposition, loan portfolio acquisitions, loan and debt restructure, workouts and real estate exchanges. Go to www.HotelLawBlog.com for current information in these areas. For more information, please contact Guy Maisnik at 310.201.3588 or mgm@jmbm.com.

David Sudeck

David Sudeck is a Partner in JMBM's Real Estate Department and a senior member of JMBM’s Global Hospitality Group® -- a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion. David has significant experience in the vacation ownership arena, focusing on the formation and registration of condominiums, timeshares and fractional interest regimes. He negotiates hotel, spa and restaurant management agreements, and assists client in the development, acquisition, sale and leasing of hotels, golf courses and restaurants. For David's take on current issues in the timeshare arena, go to www.HotelLawBlog.com and click on the topic, "Timeshare." For more information, please contact David Sudeck at 310.201.3518 or dsudeck @jmbm.com.

Robert Kaplan

Robert Kaplan is a partner in JMBM's Bankruptcy, Insolvency and Restructurings Group and a senior member of the Global Hospitality Group® -- a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion. Bob represents lenders, special servicers, hard money lenders, community banks, national banking associations, distressed debt investors, and equity investors, positioning them for the best possible outcome by acting expeditiously to preserve value and increase cash flow. His industry experience and his knowledge of the current capital markets -- where distressed assets often include complex deal structures and securitized loans -- allows him to bring creative and effective strategies to the table. When aggressive litigation is the best strategy, he is a vigorous and effective advocate for his clients. Bob represented the securitized lender in the Chapter 11 bankruptcy case filed by the Clift Hotel in San Francisco, and in the subsequent negotiations and successful sale of the loan to a third party. The lender -- acting by and through GMAC Commercial Mortgage Corporation as special servicer -- was the holder of a $60 million loan secured by a Deed of Trust on the Clift Hotel. He has also served as counsel to CapMark, J.E. Robert Company, Inc., AMRESCO Management Inc. and Midland Loan Servicer in their capacity as special servicers on troubled hotel loans in CMBS pools. For more information, contact Robert Kaplan at 415.984.9673 or rkaplan@jmbm.com.

Martin Orlick

Martin Orlick is a partner in JMBM's Real Estate Department and a senior member of JMBM's Global Hospitality Group® -- a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion. Marty specializes in representing hospitality industry clients in Americans With Disabilities Act (ADA) compliance and defense. He has represented more than 500 businesses in ADA issues, many of them hotels and restaurants, as well as hotel mixed-use properties. Marty is a member of the American College of Real Estate Lawyers (ACREL) and a frequent speaker on the ADA and other topics. To read Marty's articles, go to www.HotelLawBlog.comand select "ADA." For more information, please contact Marty Orlick at 415.984.9667 or morlick@jmbm.com.

Scott Brink

Scott Brink is a senior member of JMBM's Global Hospitality Group® and a partner in JMBM's Labor & Employment Law Department. Scott is a management labor lawyer with more than two decades of experience representing employers in all aspects of labor relations and employment law including union prevention, collective bargaining negotiations, defense of unfair labor practice charges before the NLRB, wrongful discharge litigation, individual and class action employment discrimination and wage-and-hour claims, sexual-harassment litigation, arbitrations, personnel policies, California wage and hour law, and employee discipline and discharge. An experienced trial attorney, Scott has litigated a number of high-profile and complex cases involving a wide range of labor and employment law matters. For more information, contact Scott Brink at RSB@jmbm.com or 310.785.5365.

Travis Gemoets

Travis Gemoets is an experienced trial attorney and represents management in all facets of labor and employment law, including wage/hour class actions, claims of discrimination, harassment, wrongful termination, trade secrets and unfair competition, union/management relations and workplace violence. He is a member of JMBM's Global Hospitality Group(r), in which capacity he negotiates union contracts and resolves labor disputes throughout the country, defends class action claims, develops strategies for the mass onboarding and separation of employees, and recommends proactive changes to employers' policies and practices in order to minimize potential liability risks. Reach him at 310.785.5387 or tgemoets@jmbm.com.

Mark S. Adams

Mark S. Adams is an experienced trial lawyer and a member of JMBM's Global Hospitality Group® and Chinese Investment Group™. He focuses his practice on business litigation including contracts, corporate and partnership disputes, and hospitality disputes and litigation. On behalf of hotel and resort owners, Mark has successfully litigated the termination of long-term, no-cut, hotel management agreements, franchise agreements, fiduciary duty issues, investor-owner disputes, TOT assessments, and more. He has wide-ranging trial experience in a variety of commercial disputes, including complex multi-party litigation and class actions. He has tried numerous cases in state courts, federal courts, and in domestic and international arbitrations, and is a frequent author and speaker on trial practice. Mark's trial wins have been covered by Forbes, Reuters, and other publications. He has obtained two of California's annual 50 largest jury verdicts in the same year. Mark has taken or defended nearly 1,000 depositions throughout North America, Europe and the Middle East. He has been quoted as an expert on noncompete agreements in the Wall Street Journal. For more information, contact Mark at 949. 623.7230 or markadams@jmbm.com.

Bennett Young

Bennett Young is a partner in JMBM's Bankruptcy, Insolvency and Restructurings Group and a senior member of the Global Hospitality Group® -- a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion. His clients include lenders, financial institutions, secured and unsecured creditors, distressed investment funds, businesses, receivers, special servicers and creditors' committees. Ben represented the owner of a partially completed multi-billion dollar resort property in the restructuring of its finances and has represented lenders to hotels and casinos. For more information, contact Ben Young at 415.984.9626 or byoung@jmbm.com

Sheri Bonstelle

Sheri Bonstelle is a partner in JMBM's Government, Land Use, Environment and Energy Department, and a member of JMBM's Global Hospitality Group®. She represents owners and developers in land use, zoning, environmental, litigation and construction matters. She manages all aspects of the entitlement process, including representing clients before local and state agencies, commissions and councils. Sheri also represents clients in a variety of land use and real estate litigation matters in state and federal courts, including cases arising under CEQA and other environmental laws. Her hotel experience includes handling the adaptive reuse of an historic office building as a luxury boutique hotel. For more information, please contact Sheri Bonstelle at 310.712.6847 or SBonstelle@jmbm.com.

Kevin McDonnell

Kevin McDonnell is a partner in JMBM's Government, Land Use, Environment and Energy Department, and a member of JMBM's Global Hospitality Group®. Kevin represents developers and owners of hotels in a broad range of land use and zoning issues including entitlements, code enforcement, easements and parking requirements, as well as related Parcel Map and Tract Map subdivision issues. His hospitality experience includes hotels, condo-hotels and mixed-use projects. A registered Civil Engineer and Structural Engineer in California, and a former building official for the City of Los Angeles, Kevin brings unique experience and insight in Zoning and Building Code applications and Code Enforcement issues. For more information, please contact Kevin McDonnell at 310.201.3590 or kkm@jmbm.com.

Jamie Ogden

Jamie Ogden is a tax lawyer at Jeffer Mangels Butler & Mitchell LLP. He advises individuals and businesses on a range of tax planning, tax controversy and estate planning matters. Jamie’s experience includes all tax aspects with respect to the hospitality industry, including acquisitions and dispositions (including Section 1031 exchanges), financing and management agreements. He also serves as lead tax counsel on M&A transactions, financing, internal corporate restructurings and deferred compensation matters. Jamie also works frequently with litigators on the tax aspects of litigation, judgments and settlements. Jamie has extensive experience with foreign compliance matters, including each variation of the IRS amnesty programs. In addition to his experience in private practice, Jamie also brings several years of service from both state and federal government. For more information, contact Jamie at JOgden@jmbm.com or 310.201.3510.

Wei Deng

Wei Deng is General Counsel of Bosen American Capital, Inc. where in addition to his legal duties, he is responsible for sourcing, evaluating and proposing United States investment opportunities to the company. Wei was previously with JMBM, where he focused on transactional and litigation matters.

Jay Thompson

Jay Thompson has extensive experience representing private companies, business owners, family offices and investors in mergers and acquisitions, private equity and venture capital transactions and private securities offerings. Jay serves as general counsel to many of his clients, their management, and board of directors, helping to shape and execute their business strategies, facilitate growth and liquidity, as well as to advise them on day-to-day legal and other strategic issues. He is known for his practical approach to business issues. Contact Jay at JThompson@jmbm.com or 949.623.7258

Marianne Martin

Marianne Martin has nearly fifteen years of experience advising clients on a variety of commercial, financing, bankruptcy, restructuring and M&A matters, with a particular niche dealing with distressed and/or turnaround situations. Her clients frequently include private equity and hedge funds, independent sponsors, family offices, public and private corporations, financial institutions and banks, healthcare-related companies, municipalities and venture capital funds. She has represented clients in various capacities, including as borrowers/debtors, lenders, acquirers, and agents/trustees in negotiating and documenting complex commercial transactions, out-of-court restructuring transactions and advising on purchasing considerations in secondary market debt transactions. Contact Marianne at MMartin@jmbm.com or 310.201.3531

Trevor Countryman

Trevor Countryman is an associate in the firm's Real Estate Department. He advises clients in all aspects of real estate transactions including property acquisitions and dispositions, financing, leasing, development and construction. Trevor's clients range from large funds to individual developers and opportunistic investors, engaged in deals involving office, retail, multi-family, single-family, mixed-use and hotel properties. Contact Trevor Countryman at 310.201.3546 or TCountryman@jmbm.com.

Vanessa Han

Vanessa Han is an associate in JMBM's Corporate group. Vanessa can be reached at VHan@jmbm.com or 310.785.5383

Vince Farhat

Vince Farhat is Chair of JMBM's White Collar Defense and Investigations practice. Vince has extensive jury trial experience and focuses his practice on representing companies and individuals in criminal and civil investigations and prosecutions by government enforcement agencies, as well as complex federal litigation. He also advises companies in connection with complex and sensitive internal investigations. Prior to joining JMBM, Vince served as an assistant United States attorney in the Major Frauds Section of the U.S. Attorney's Office for the Central District of California. Contact Vince Farhat at 310.785.5382 or VFarhat@jmbm.com.

Sarah G. Hartman

Sarah G. Hartman is a partner in JMBM's Litigation Group and a member of JMBM's Global Hospitality Group® -- a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion. Sarah is an experienced litigator who advises and represents clients through all aspects of litigation, from inception through trial and appeal. She advises and represents clients in the hospitality industry, including the termination of hotel management agreements and franchise agreements. Sarah also advises and represents clients on women's health technology issues, intellectual property matters, and complex commercial disputes, including breach of fiduciary duty, fraud, breach of contract, unfair competition, products liability, employment litigation, class action defense, false advertising and other complex financial disputes. Contact Sarah Hartman at 949.623.7243 or SGHartman@jmbm.com.

Michael H. Strub, Jr.

Michael H. Strub, Jr. is a partner in JMBM's Litigation Group and a member of JMBM's Global Hospitality Group® -- a team of seasoned professionals who have helped clients around the world with more than 4,700 hospitality properties worth more than $125 billion. He is a highly skilled trial and appellate attorney who has handled high-stakes, complex commercial and business cases for 30 years including disputes arising out of hotel construction, lending, and bankruptcy. In addition, he has represented plaintiffs and defendants in business and commercial disputes in a variety of areas. Contact Michael H. Strub, Jr. at 949.623.7233 or MStrub@jmbm.com.

Ask the Hotel Lawyer™ is a quarterly column that I write for JMBM's Global Hospitality Advisor®. If you have a question you would like to submit to Ask the Hotel Lawyer™ please use the comments box below. While your question may not be of sufficient general interest for the column, I will try to respond to you individually if you leave your contact information below.
Jim Butler.

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