Free Declaration - District Court of California - California

Case 3:08-cv-00094-DMS-AJB

Document 15

Filed 03/14/2008

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Gordon & Rees LLP 633 West Fifth Street Suite 4900 Los Angeles, CA 90071

STEPHEN E. RONK (SBN: 164333) JOSHUA B. WAGNER (SBN: 199570) MOLLIE BURKS-THOMAS (SBN: 222112) GORDON & REES LLP 633 West Fifth Street, Suite 4900 Los Angeles, CA 90071 Telephone: (213) 576-5000 Facsimile: (213) 680-4470 Attorneys for Defendant AKAL SECURITY, INC. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA DAVID LOERA, for himself and on ) behalf of all others similarly situated and ) the general public, ) ) Plaintiffs, ) ) v. ) ) AKAL SECURITY, INC., a corporation; ) and DOES 1-100, inclusive, ) ) Defendants. ) ) ) ) ) ) ) ) ) ) ) /// /// /// /// /// ///
1 DECLARATION OF JANET GUNN

CASE NO. 08CV0094 DMS AJB DECLARATION OF JANET GUNN IN SUPPORT OF DEFENDANT AKAL SECURITY, INC.'S OPPOSITION TO MOTION FOR REMAND AND REQUEST FOR ATTORNEYS' FEES AND COSTS (28 U.S.C. § 1447(c)) [Memorandum of Points and Authorities in Opposition to Motion and Declaration of Mollie BurksThomas filed concurrently herewith] Date: March 28, 2008 Time: 1:30 p.m. Courtroom: 10

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Case 3:08-cv-00094-DMS-AJB

Document 15

Filed 03/14/2008

Page 2 of 2

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Gordon & Rees LLP 633 West Fifth Street Suite 4900 Los Angeles, CA 90071

DECLARATION OF JANET GUNN I, JANET GUNN, declare as follows: 1. I am employed by Defendant AKAL Security, Inc. ("AKAL") as its Vice President, Human Resources. In addition, I am one of its Custodians of Record and have personal knowledge of how the records are maintained in the ordinary course of AKAL's business, including the Collective Bargaining Agreement at issue in this litigation. I make this Declaration of my own true knowledge, and if called upon as a witness, could and would competently testify to the truth of same. 2. Attached hereto as Exhibit D is a true and correct copy of the Collective Bargaining Agreement between AKAL Security, Incorporated and the Security, Police and Fire Professionals of America ("SPFPA"), Amalgamated Local 165, dated October 31, 2003. 3. Attached hereto as Exhibit E is a true and correct copy of the Letter of Understanding between AKAL Security, Incorporated and the SPFPA, Amalgamated Local 165, dated November 29, 2006. 4. Exhibits D and E comprise the contract governing the employment of AKAL security officers employed at the Department of Homeland Security Immigration Detention Center (formerly known as the INS Services Processing Center) in El Centro, California, from October 31, 2003 through the present. Executed this 14th day of March, 2008 at Espanola, New Mexico. I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct. /s/ Janet Gunn Janet Gunn, Declarant

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AKAL/1039887/5508733v.1

2 DECLARATION OF JANET GUNN