Free Affidavit in Opposition to Motion - District Court of California - California

Case 4:08-cv-01849-SBA

Document 17

Filed 07/09/2008

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Daniel P. Iannitelli - 203388 FOTOUHI · EPPS · HILLGER · GILROY LLP 160 Pine Street, Suite 710 San Francisco, CA 94111 Tel: 415.362.9300 Fax: 415.358.5521 Email: [email protected] Email: [email protected] Attorneys for Plaintiff RANDALL SLOAN

UNITED STATES DISTRICT COURT NORTHER DISTRICT OF CALIFORNIA OAKLAND DIVISION RANDALL J. SLOAN, ) ) Plaintiff, ) vs. ) ) PFIZER, INC., a Delaware corporation; and ) DOES 1 through 40, inclusive, ) ) Defendants. ) ) No. CV 08-1849 SBA DECLARATION OF DANIEL P. IANNITELLI IN SUPPORT OF P OPPOSITION TO PFIZER'S MOTION TO TRANSFER VENUE Date: Time: Place: Court: July 29, 2008 1:00 p.m. Courtroom 3 Hon. Saundra B. Armstrong

I, Daniel P. Iannitelli, declare: 1. I am an attorney duly licensed to practice law in the State of California and am a

partner in the law firm FOTOUHI · EPPS · HILLGER · GILROY LLP, attorneys of record herein for Plaintiff Randall Sloan in the above-captioned case. 2. I have personal knowledge of the matters set forth herein, and if called upon as a

witness could competently testify thereto. 3. Mr. Randall Sloan is presently without an income and his been unemployed

since January 8, 2007. He is living on limited means and is seeking social security benefits. He is nearly destitute relying on the financial assistance of others, including Government agencies and community resources. Mr. Sloan's mental and physical health, according to his physicians whom I recently consulted with, are in poor states.
1 DECLARATION OF DANIEL P. IANNITELLI- CV 08-1849

Case 4:08-cv-01849-SBA

Document 17

Filed 07/09/2008

Page 2 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

4.

The following witnesses have information relating to the claims asserted by Mr.

Randall Sloan in this lawsuit and are expected to testify to such: (a) (b) Randall Sloan, 563 Webster, Apt. F, San Francisco, California. Denise Bouvier, St. Mary's Medical Center, 450 Stanyan St., San Francisco, California. (c) (d) Robert E. O'Brien, MD, 2250 Hayes Street, San Francisco, California. Dr. Lory D. Wiviott, 2100 Webster St., Suite 404, San Francisco, California. (e) Bridgett Stringer, PA-C, St. 2235 Hayes Street, 5th Floor, San Francisco, California. (f) (g) 5. Dr. Rick Loftus, 45 Castro Street, Suite 415, San Francisco, California. California Pacific Medical Center, San Francisco, California.

I have conducted research and have identified several operations centers and/or

business offices of Pfizer, Inc., within the State of California, including locations in South San Francisco, Sacramento, La Jolla and Irvine. I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct. Executed this 9th day of July, 2007, at San Francisco, California.

/s/ Daniel P. Iannitelli Daniel P. Iannitelli

2

DECLARATION OF DANIEL P. IANNITELLI- CV 08-1849