IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 06-CV-02528-JLK-CBS
______________________________________________________________________________
BRAY et al.,
Plaintiffs,
vs.
QFA ROYALTIES LLC,
Defendant.
______________________________________________________________________________
DECLARATION OF PLAINTIFF ALLISON ABID
______________________________________________________________________________
I, Allison Abid, declare as follows:
1.
I serve on the board of directors of the Toasted Subs Franchisee Association, Inc.
(“TSFA”). My husband Hakim Abid owns and operates Quiznos Store No. 3652, which is
located at 5600 La Centre Avenue, Unit 105, Albertville, Minnesota 55301. He also owns and
operates Quiznos Store No. 3653, which is located at 16362 County Road 30, Maple Grove,
Minnesota 55311. While my husband signed the Franchise Agreements governing these stores, I
am personally familiar with them and the store operations. My husband is not involved in the
management of the TSFA.
2.
Attached to this Declaration as Exhibit A are true and correct excerpts of the June
1, 2002 Franchise Agreement governing Quiznos Store No. 3653. A copy of the May 17, 2002
Franchise Agreement governing Quiznos Store No. 3652 is not currently available, but it is
believed to be nearly identical in form and content with the agreement concerning Store No.
MADISON\733031.1
Case 1:06-cv-02528-JLK Document 8 Filed 12/18/2006 Page 1 of 2
Bray et al v QFA Royalties
Doc. 8
Dockets.Justia.com
3653. 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.
3.
On December 11, 2006, my husband and I received two letters from Frederic C.
Cohen, Esq., an attorney with DLA Piper in Chicago, Illinois. Each letter is dated December 8,
2006 and purports to terminate the franchise relationship with Quiznos in rela