Free Declaration in Support - District Court of California - California

Case 5:07-cv-04808-JF

Document 57

Filed 07/25/2008

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KURT OSENBAUGH (State Bar No. 106132) DEBORAH YOON JONES (State Bar No. 178127)
WESTON, BENSHOOF, ROCHEFORT, RUBALCA VA & MacCUISH LLP 333 South Hope Street, Sixteenth Floor Los Angeles, California 90071
Telelhone: (213) 576-1000

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SA Y AKA KARIT ANI (State Bar No. 240122)

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Facsimile: (213) 576-1100
kosenbaugh~wbcounsel .com

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d j ones($wbcounsel. com skari tann~wbcounsel. com

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Attorneys for Plaintiff and Counter-Defendant
BP WEST COAST PRODUCTS LLC

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
BP WEST COAST PRODUCTS LLC, a Delaware Limited Liability Company,
Plaintiff,

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Case No.: C07 04808 JF

DECLARATION OF ELIZABETH CHANG IN SUPPORT OF REPLY BRIEF IN
SUPPORT OF BP WEST COAST

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SA YED FAQUIRY AN, an individual; and AMENDED COMPLAINT MAGHUL FAQUIRY AN, an individual; and A V A GLOBAL ENTERPRISE, LLC, a California limited (Filed concurrently with Reply Briefs in Support liability company, of Motions for Summary Judgment as to Second Amended Complaint and Counterclaim; Defendants. Additional Declaration of Deborah Y oon Jones; Evidentiary Objections to Declaration of Sayed Faquiryan and John Michael; and Appendix of
Authorities. J

PRODUCT LLC'S MOTION FOR SUMMARY JUDGMENT, OR IN THE STTN ENTERPRISES, INC., a California AL TERNA TIVE, PARTIAL SUMMARY Corporation; NAZIM FAQUIRYAN, an individual; JUDGMENT AS TO THE SECOND

v.

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Date: Time: Crtm:

August 8, 2008 (reserved)
9:00 a.m.

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Honorable Jeremy Fogel

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Filing Date:

September 17,2007

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AND RELATED CROSS-ACTION

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DECLARATION OF ELIZABETH CHANG

Case 5:07-cv-04808-JF
J u \-24-2QD8 02: 05pm
From-CREDIT DEPT

Document 57

+746705492

Filed 07/25/2008

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F-064

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I, Elizabeth Chang, declare and state as follows:
1.

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I am clUently a Financial Analyst in the Credit Department of BP W est Coa~, t

Products LLC ("BPWCP"). As a Financial Analyst, I review new dealer/franchisee applicants anit
monitor receivables for current customers to ensure accounts are CUITent.

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2.

I am responsible for maintaining the account balance that pertaiiis to S Tn r

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Enterprises, Inc. ("STTN") and the former ARCO-branded gasoline station and am/pm mini marh t
located at 631 San Felipe Road, Hollster, Califonùa (the "Station"). I have prepared the attache, I

report which reflects the gasoline deliveries and payments from approximately Januar 1, 2007
thTOllgh August 19, 2007, as well as other amounts including royalties, product advances an 1
deposits. Based upon my accounting, the following is lnte:
(a)

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As of May 4, 2007, the total outstanding balance for gasoliii ~

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deliveries made to the Station) bUt not paid for by STTN, was $184,075.50;
(b)
Between May 4) 2007 and July is, 2007, STTN's payments fer

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gasoline included additiona1 amounts which totaled $28,679.09 for this time period;
(c)

Between July 16, 2007 and August 15, 2007, STTN's payments fer

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gasoline included additional amounts which totaled $15,019.42 fOr this time peil0d;
(d)

As of August 24, 2007, the total outstanding balance for gasolin ~

deliveries made to the Station, but not paid for by STTN, was $138,394.77;
(e)
As of September 6, 2007, which I understand is the date of the Notie:;:

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ofTeiminatiol1, the total outstanding balance for gasoline deliveries made to the Station, but not pa: i

for by STTN, was $126,394.77, which takes into consideration the "prodnct advance" deposit (f
$11,200.00 and securty deposit of$1,OOO.

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I declare under penalty of perjury "under the laws of the State of California that tÌ e
foregoing is tTUe and correct.
Executed on July 2tf , 2008, at I. (?.9vN' tt , California.

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i%g;~/
Case No.: C07 04808 .1 F

DECLARTlON OF ELIZABETH CHAN :;
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Case 5:07-cv-04808-JF

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