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I don't see any way to do a brake fluid without removing the wheels. It's not impossible, just a hassle. So I bet dealer must have removed it.
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01' 3.0i E53 (M54) with 164,000 miles 
07' 3.0si E83 (N52) with 134,000 miles 
08' 3.0si E70 (N52) with 91,000 miles
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