IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 06-CV-02528-JLK-CBS
BRAY et al.,
QFA ROYALTIES LLC,
DECLARATION OF PLAINTIFF DANIEL G. CARTER, JR.
I, Daniel G. Carter, Jr., declare as follows:
I serve on the board of directors of the Toasted Subs Franchisee Association, Inc.
(“TSFA”). My wife Jody Carter and I, along with my parents Daniel G. Carter, Sr. and
Madeleine Carter, are controlling members of Carter Group LLC (“Carter Group”) and Carter
Group Roseville LLC (“Carter Roseville”)—entities that transact business with Quiznos on our
behalf. Along with my parents, my wife and I own and operate Quiznos Store No. 4199, which
is located at 24955 Gratiot Avenue, Eastpointe, Michigan 48021. We also own and operate
Quiznos Store No. 6514, which is located at 31931 Gratiot Avenue, Roseville, Michigan 48066.
Neither my parents nor my wife are involved in the management of the TSFA.
Attached to this Declaration as Exhibit A are true and correct excerpts of the
September 27, 2002 Franchise Agreement governing Quiznos Store No. 4199. Attached to this
Declaration as Exhibit B are true and correct excerpts of the December 8, 2003 Franchise
Case 1:06-cv-02528-JLK Document 9 Filed 12/18/2006 Page 1 of 2
Bray et al v QFA Royalties
Agreement governing Quiznos Store No. 6514. The full Franchise Agreements for these two
stores are otherwise nearly identical with the full agreement filed as Exhibit A to the Jehad
Majed Declaration in this matter.
On December 9, 2006, I received two letters from Frederic C. Cohen, Esq., an
attorney with DLA Piper in Chicago, Illinois. Each letter is dated Dece