Free Declaration in Support - District Court of California - California

Case 3:07-cv-05032-MMC

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Filed 05/21/2008

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ERSKINE & TULLEY A PROFESSIONAL CORPORATION MICHAEL J. CARROLL (ST. BAR #50246) 220 Montgomery Street, Suite 303 San Francisco, CA 94104 Telephone: (415) 392-5431 Facsimile: (415) 392-1978 Attorneys for Plaintiff

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

BOARD OF TRUSTEES OF THE PRINTING SPECIALTIES, etc.,

) ) ) Plaintiff, ) ) vs. ) ) CLOISTER PRESS, etc., ) ) Defendant. ) ________________________________________ )

NO. C 07 5032 EDL DECLARATION OF RONALD D. CHANDLER IN SUPPORT OF MOTION FOR DEFAULT JUDGMENT

I, RONALD D. CHANDLER, declare: 1. I am a Partner of the firm of Miller, Kaplan, Arase & Co., LLP, Certified Public

Accountants with business offices located at 4123 Lankershim Boulevard, North Hollywood, CA 91602. If called as a witness, I could competently testify from my own personal knowledge to the following facts: 2. I am custodian of and familiar with the books and records of Miller, Kaplan, Arase &

Co., LLP, Certified Public Accountants as they relate to the defendant in this case, CLOISTER PRESS, a California corporation. 3. My firm performs compliance tests on contributing employers for the Board of Trustees of the Printing Specialties and Paper Products Joint Employer and Union Health and Welfare Fund. 4. My office requested access to the books and records of this employer by telephone contact on April 7, 2006, April 24, 2006 and November 2, 2006 . Attached hereto and collectively marked Exhibit
DECLARATION OF RONALD D. CHANDLER IN SUPPORT OF MOTION FOR DEFAULT JUDGMENT 1

Case 3:07-cv-05032-MMC

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3 is a copy of our telephone log and copies of our letters dated February 17, 2006 and December 28, 2006. The defendant failed and refused to arrange for an audit of its books and records. I declare under penalty of perjury that the foregoing is true and correct. Executed on April 9, 2008 at North Hollywood, California.

/s/ Ronald D. Chandler RONALD D. CHANDLER

DECLARATION OF RONALD D. CHANDLER IN SUPPORT OF MOTION FOR DEFAULT JUDGMENT 2