Free Declaration in Support - District Court of California - California

Case 3:07-cv-04830-VRW

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FRED H. ALTSHULER (SBN 43878) LINDA LYE (SBN 215584) JAMIE L. CROOK (SBN 245757) (Application for Admission pending) ALTSHULER BERZON LLP 177 Post Street, Suite 300 San Francisco, California 94108 Telephone: (415) 421-7151 Facsimile: (415) 362-8064 E-Mail: [email protected] E-Mail: [email protected] E-Mail: [email protected] Attorneys for Plaintiffs Robert M. Evitt, Sr., Joel Ortega, Loretta Evitt, and the proposed Plaintiff Class UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO/OAKLAND DIVISION ROBERT M. EVITT, Sr., JOEL ORTEGA, and LORRETTA EVITT on behalf of themselves and a class of those similarly situated, ) ) ) ) ) ) Plaintiffs, ) ) v. ) ) MACK TRUCKS, INC. and MACK ) HEALTH, DISABILITY AND LIFE ) BENEFITS FOR UAW EMPLOYEES, ) ) Defendants. _____________________________________ ) Case No. C-07-4830-VRW CLASS ACTION DECLARATION OF LORETTA R. EVITT IN SUPPORT OF PRELIMINARY INJUNCTION

DECLARATION OF LORETTA R. EVITT, Case No. C-07-4830-VRW

Case 3:07-cv-04830-VRW

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I, Loretta R. Evitt, declare as follows: 1. I am married to Robert Evitt, a retiree of Mack Trucks, Inc. Since my husband

retired, I have received healthcare benefits provided by Mack Trucks as the dependent of a Mack Trucks retiree. I live in Hayward, California. 2. 3. I am 76 years old. I regularly visit doctors in Hayward and Union City, California. I purchase

prescription medications at the Kaiser pharmacy in Hayward. 4. I worked as a spot welder for Eimac, which later became part of Varian, in

San Carlos, California, from 1967 until my retirement in 1993. I do not receive any retiree health benefits from Varian. 5. My husband worked for Mack Trucks from 1966 until approximately

1980. He retired in 1993. While employed with Mack Trucks he was represented by the union that represents Mack employees, the United Auto Workers ("UAW"). He is now a retiree member of the UAW. 6. Before my husband retired, we thought that Mack Trucks would provide our

health insurance for the rest of our lives. This gave us peace of mind that we would be able to receive complete medical care during our retirement. We relied on that promise of lifetime health care, and we really need it because without it we could not afford the health care we need. 7. Now that Mack Trucks is threatening to take away our health care, I'm frustrated

and scared. As you get older you start to have more medical problems, and I worry that I will need serious medical care in the future that we will be unable to afford without the healthcare coverage that Mack Trucks currently provides. The uncertainty about whether Mack Trucks will continue to cover us in the future is causing me extreme anxiety. 8. I regularly see a gynecologist for female troubles and an orthopaedic surgeon for

a hand injury. I also see my medical doctor for high blood pressure. I take three prescription medications that I cannot stop taking without threatening my health. 9. My doctor is still trying to diagnose my female troubles. I don't know how this will

come out, and I may need costly medical care after my doctor finally makes a diagnosis. I may also

DECLARATION OF LORETTA R. EVITT, Case No. C-07-4830-VRW

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Case 3:07-cv-04830-VRW

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