Free Declaration in Support - District Court of California - California

Case 3:07-cv-04999-EMC

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Filed 05/28/2008

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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. ) ) GEERTZ PRINTING CO., etc., ) ) Defendant. ) ________________________________________ )

NO. C 07 4999 EMC 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, GEERTZ PRINTING CO., INC., 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 on February 17, 2006 by letter and on October 11, 2006 and October 12, 2006 by telephone contact. Attached hereto and
DECLARATION OF RONALD D. CHANDLER IN SUPPORT OF MOTION FOR DEFAULT JUDGMENT 1

Case 3:07-cv-04999-EMC

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collectively marked Exhibit 3 is a copy of our letter and our telephone log. 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 16, 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