Geraldine made detailed lists of exceptions for items in a facility that were not in proper working order, many of which were never properly rectified and disrupted efficient use. As late as April 2002, Geraldine was still trying to fix issues on the exception list. The document argues that from January 2002, Geraldine operated the facility that was not in good repair with limitations, and the landlord did not provide written notice of required maintenance items, so claims of damage before October 2002 cannot be valid.