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...

3. My lofty respect for and confidence in the integrity of Mr. Pfiester … is matched only by my fear and trepidation in regards to the skills Mr. Pfiester  brings 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 (ARLA- Academy of Rail Labor Attorneys) , 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.