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  • GODOFREDO PIQUE VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • GODOFREDO PIQUE VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • GODOFREDO PIQUE VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • GODOFREDO PIQUE VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview 
						
                                
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                                MADELINE L. BUTY [SBN 157186]

WILLIAM J. EDGAR [SBN 245473] ELECTRONICALLY
BUTY & CURLIANO LLP onic

555 — 12" Street, Suite 1280 FILED
Oakland, California 94607 Superior Court of California,
Tel: 510.267.3000 County of San Francisco
Fax: 510.267.0117 AUG 20 2009

GORDON PARK-LI, Clerk
BY: JUANITA D. MURPHY
Deputy Cler}
Attorneys for Defendant

PACCAR INC [sued herein as DOE 1]

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO — UNLIMITED JURISDICTION

GODOFREDO PIQUE, No. 274659
Plaintiff,
DECLARATION OF DON MacRITCHIE
IN SUPPORT OF PACCAR INC.’S
MOTION FOR SUMMARY JUDGMENT
OR, IN THE ALTERNATIVE,
SUMMARY ADJUDICATION

v.
ASBESTOS DEFENDANTS (B¢P), etc.

Defendants.
Date:
Time:
Dept:

Complaint Filed: May 8, 2008
Trial Date: December 14, 2009

Te Ne Ne

I, Don MacRitchie, hereby declare as follows:
1. Tam not a named party to this action, nor have I been offered any reward or
inducement for the execution of this declaration. I have personal knowledge of and am

competent to testify to the facts set forth herein, and if called upon would do so.

1

Declaration of Don MacRitchieCe WA HM BW NY =

eo
=— oS

2. Iam a private investigator, licensed in the State of California under license
number P114459. I am the owner of Neilson and MacRitchie Investigators. Neilson and
MacRitchie Investigators were retained by the Buty and Curliano, LLP law firm on behalf of
Paccar, Inc, in the matter of Godofredo Pique vs Asbestos Defendants, San Francisco County
Superior Court case number 274659. Our assignment was to locate a former co-worker of Mr.
Pique, who worked with him at All Trans Express in San Francisco, California, The former co-
| worker was believed to be named Leon “Samson” or possibly Leon “Sampson”.

3. On August 18, 2009 Kendall Welch of my office identified a Leon Simpson of
San Francisco, California as the person who formerly worked with Mr, Pique at All Trans
Express, In a telephone conversation with Mr. Simpson, Ms. Welch confirmed that Mr. Simpson
worked as a mechanic at All Trans Express in San Francisco from 1973 to 1977. Mr. Simpson
also told Ms. Welch that he did not recall any Kenworth or Peterbilt brand trucks being present at
All Trans Express during his tenure at the company.

4. On August 19, 2009 I spoke with Mr. Simpson by telephone about the possibility

of his executing a declaration in this matter. Mr. Simpson stated that he would consider
executing a declaration, but that prior commitments would not allow him to address the matter
on the morning of August 19, 2009. During our telephone conversation, Mr. Simpson again
confirmed to me that he was employed as a mechanic at All Trans Express in San Francisco
between 1973 and 1974 and the he did not believe that any Kenworth or Peterbilt brand trucks

were present at All Trans Express during the time period of his employment.

I declare under the penalty of perjury under the laws of the States of California and

Illinois that the foregoing is true and correct.

Executed this 19" day of August, 2009 in San Francisco County, California.
y y: .

Don MacRitchie

Declaration of Don MacRitchie