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Case 2:13-cv-01995-MMM-PJW Document 26 Filed 08/16/13 Page 1 of 2 Page ID #:182

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ROSENFELD

A Professional Corporation

1001 Marina Village Parkway, Suite 200

WEINBERG, ROGER &

Alameda, California 94501

(510) 337-1001

LINDA BALDWIN JONES, Bar No. 178922
KRISTINA M. ZINNEN, Bar No. 245346
DANIEL S. BROME, Bar No. 278915
WEINBERG, ROGER & ROSENFELD
A Professional Corporation
1001 Marina Village Parkway, Suite 200
Alameda, California 94501
Telephone (510) 337-1001
Fax (510) 337-1023
E-Mail:[email protected]
Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

No. 13-cv-01995-MMM-PJWx

DECLARATION OF KRISTINA
M. ZINNEN IN SUPPORT OF
OPPOSITION TO MOTION TO
COMPEL ARBITRATION

THE BOARD OF TRUSTEES, in their
capacities as Trustees of the BUTCHER
AND PROVISION WORKERS
PENSION FUND OF SOUTHERN
CALIFORNIA,

Plaintiffs,

v.

SPECIALTY MEATS, INC.; JAFACO
HOLDING, INC.; DOES 1 through 20,

Defendants.

I, KRISTINA M. ZINNEN, declare as follows:
1.

I am an attorney at the law firm of Weinberg, Roger & Rosenfeld,

located at 1001 Marina Village Parkway, Suite 200, Alameda, California, 94501-
1091, the attorneys for Plaintiffs in this matter. I have knowledge of the facts stated
in this Declaration and I could and would testify competently thereto.

2.

On July 23, 2013, after agreeing to a briefing schedule in this matter,
Defendant Jafaco Holding, Inc. (“Jafaco”) filed a Demand for Arbitration with the
American Arbitration Association (“AAA”). A true and correct copy of the

DECLARATION OF KRISTINA M. ZINNEN IN SUPPORT OF OPPOSITION TO MOTION TO COMPEL ARBITRATION
Case No. 13-cv-01995-MMM-PJWx

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Case 2:13-cv-01995-MMM-PJW Document 26 Filed 08/16/13 Page 2 of 2 Page ID #:183

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ROSENFELD

A Professional Corporation

1001 Marina Village Parkway, Suite 200

WEINBERG, ROGER &

Alameda, California 94501

(510) 337-1001

Demand for Arbitration is attached as Exhibit A.

3.

On August 2, 2013, Plaintiffs, the Board of Trustees of the Butcher
and Provision Workers Pension Fund of Southern California (“Pension Fund”)
responded to the Demand for Arbitration by requesting an extension to answer and
file a counterclaim until after the Court ruled on Defendant’s Motion to Compel
Arbitration. A true and correct copy of the Pension Fund’s Request for Extension is
attached as Exhibit B.

4.

On August 15, 2013, the Pension Fund and Jafaco signed and

submitted a Stipulation to Extend Deadline for Pension Fund to Answer and File
Counterclaim with the AAA until fifteen days after the Court issues its Order on
Jafaco’s motion to compel arbitration. A true and correct copy of the Stipulation to
Extend Deadline is attached as Exhibit C.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 15th day of August 2013, at Alameda, California.

/s/ Kristina Zinnen

KRISTINA M. ZINNEN
Attorneys for Plaintiffs

127871/730210

DECLARATION OF KRISTINA M. ZINNEN IN SUPPORT OF OPPOSITION TO MOTION TO COMPEL ARBITRATION
Case No. 13-cv-01995-MMM-PJWx

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