Free Declaration in Support - District Court of California - California

Case 3:07-cv-04784-EMC

Document 13

Filed 02/12/2008

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BARRY E. HINKLE, Bar No. 071223 CONCEPCIÓN E. LOZANO-BATISTA, Bar No. 227227 KRISTINA M. ZINNEN, Bar No. 245346 WEINBERG, ROGER & ROSENFELD A Professional Corporation 1001 Marina Village Parkway, Suite 200 Alameda, CA 94501-1091 Telephone (510) 337-1001 Attorneys for Plaintiffs

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WEINBERG, ROGER & ROSENFELD A Professional Corporation
1001 Marina Village Parkway Suite 200 Alameda, CA 94501-1091 (510) 337-1001

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA THE BOARD OF TRUSTEES, in their capacities as Trustees of the LABORERS HEALTH AND WELFARE TRUST FUND FOR NORTHERN CALIFORNIA; LABORERS VACATION-HOLIDAY TRUST FUND FOR NORTHERN CALIFORNIA; LABORERS PENSION TRUST FUND FOR NORTHERN CALIFORNIA; and LABORERS TRAINING AND RETRAINING TRUST FUND FOR NORTHERN CALIFORNIA, Plaintiffs, v. CHESTER L. NEAL, Individually and doing business as C.L. NEAL CONSTRUCTION, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. C 07-04784 EMC

DECLARATION OF KRISTINA M. ZINNEN IN SUPPORT OF PLAINTIFFS' REQUEST FOR ENTRY OF DEFAULT

I, Kristina M. Zinnen, declare as follows: 1. I am an attorney at law, admitted to practice before this Court, and an associate with

the law firm of Weinberg, Roger & Rosenfeld, located at 1001 Marina Village Parkway, Suite 200, Alameda, CA 941501-1091, attorneys for Plaintiffs in the above-referenced matter. I make this declaration upon my personal knowledge, and, if called as a witness, I could competently testify to the facts hereinafter stated.

DECLARATION OF KRISTINA M. ZINNEN IN SUPPORT OF PLAINTIFFS' REQUEST FOR ENTRY OF DEFAULT Case No. C 07-04784 EMC
115107/483803

Case 3:07-cv-04784-EMC

Document 13

Filed 02/12/2008

Page 2 of 2

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WEINBERG, ROGER & ROSENFELD A Professional Corporation
1001 Marina Village Parkway Suite 200 Alameda, CA 94501-1091 (510) 337-1001

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Defendant CHESTER L. NEAL, individually and doing business as C.L. NEAL

CONSTRUCTION, has not filed an answer or otherwise responded to Plaintiffs' Complaint, which was filed on September 17, 2007, served by substituted service under California Code of Civil Procedure section 415.20(b) on December 26, 2007, mailed to Defendant on January 9, 2008, for which service was deemed complete under CCP 415.20(b) on January 19, 2008, and for which proofs of service were filed before this Court with the Summons on January 16, 2008, a true and correct copy of which is attached hereto as Exhibit A, and incorporated by reference herein. I declare under penalty of perjury that the foregoing is true and correct. Executed this 12th day of February, 2008, in Alameda, California. ______/s/_________________________ KRISTINA M. ZINNEN

DECLARATION OF KRISTINA M. ZINNEN IN SUPPORT OF PLAINTIFFS' REQUEST FOR ENTRY OF DEFAULT Case No. C 07-04784 EMC -2115107/483803