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Relevant
Portions of the
DECLARATION OF CRAIG J. WHITNEY
I, CRAIG J. WHITNEY, declare:
1. I am an attorney at law licensed to practice before all the
courts of the state of California and a partner in Hill, Farrer & Burrill, attorneys
for defendant herein. I am totally familiar with all aspects of this litigation and will
be the trial attorney for defendant.
2... I said then and I say now that I have complete faith in the word of Ed Pfiester
and Vic Russo...
3. My lofty respect for and
confidence in the integrity of Mr. Pfiester and Mr. Russo is matched only by my fear and
trepidation in regards to the skills Mr. Pfiester and Mr. Russo bring to advancing
plaintiffs causes in FELA litigation. I can advise the court that I have known Mr.
Pfiester for more than ten years, and knew of his powerful and creative lawyering in
behalf of railroad employees even before I knew him.
4. I have been involved in FELA litigation and have devoted my
career to the defense of railroads since 1977.
5. My dedication to and longevity in
FELA litigation, however, is far surpassed by that of Mr. Pfiester. He specializes almost
exclusively in the representation of injured railroad workers, promulgates brochures and
other dignified advertising materials, is a founder of a highly esteemed professional
organization of other plaintiffs lawyers involved in railroad litigation, speaks at
meetings of plaintiffs railroad lawyers and of railroad union officials, and has written
extensively on this subject. He has been designated as officially approved counsel in
behalf of railroad workers by a number of railroad union organizations. He takes and
prosecutes his cases involving railroad workers from most of the states of the western
United States, either being directly retained by plaintiffs or upon referral of other
lawyers, etc.
6. One of the factors which sets Mr.
Pfiester apart from other lawyers who attempt to compete with him in signing up new
railroad cases is his "library" of railroad materials. Mr. Pfiester from my own
knowledge collects photographs, other audio visual aids, treatises, and other forms of
evidence concerning railroads in railroad litigation.
If called upon I could competently testify to the foregoing and this
is declared under penalty of perjury this 7th day of April, 1995, in Los Angeles,
California.

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