declaration of daire lordan in support of defendants motion for summar

Cal. Super. - 1st Dist.February 3, 2020

9 10 Richard J. Finn, State Bar No. 099659 Gl'cgol'y H. McCormick, State Bar No. 164461 "I'heresa M. Brick, State Bar No. 318716 BURNI IAM BROWN A Professional Lav Corporation P.O. Box 119 Oakland, California 94604-0119 1901 I larrison Street, Suite 1400 Oakltnid, California 94612-3523 Telephone: (5101 444-6800 Facsimile: (510) 835-6666 Email: rfmn(iilburnltambrown.cmn gmccormickPa,burnhambrown.corn tbrick(nJburnhambrown.corn A ttoi'Ileys lol'efelldatlts M SQUARIJD CONSTRUCTION, IN(:. AND CI'fY AND COUN'I'Y OF SAN FRANCIS(.'.0 13 SUPL'RIOR COIJR'I OF CALII'ORNIA, COIJNTY OF SAN FRANCISCO UNI.IMI'I'I!D JURISDICTION 17 18 19 MELISSA HACKER, an individual, Plaintiff, M SQUARL'D CONSTRUCTION, INC., an entity, CITY AND COUNTY OF SAN FRANCISCO, an entity, and DOLS 1-100, Defendants. No. CGC-18-572316 DECLARATION OF DAIRE LORDAN IN SUPPORT OF DEFENDANTS'OTIONF'R SUMMARY JUDGMENT Date: January 23, 2020 Time: 9:30 a.m. Dept.: 302 Judge: Hon. Ethan P. Schulman Reservation Nou 010090123-02 Complaint Filed: December 24, 2018 'I'rial Date: February 24, 2020 26 27 I, Daire Lordan, declare and state: I. I am etnttloyed by M Squaretl Construction Inc. as a fiekl enginccr. If called atld swofil in as a witness, I could and would competently testify to the following; 2. As a field engineer for M Sqllai'cd Construction Inc. I oversee projects to completion through a hands-on approach by directly managing front-line workers. I DECLARATION OF DAIRE I ORDAN IN SUPPORT OF DEFENDANTS'o. CGC-18-672316 MOTION FOR SllMIM Altv JUDGMENT ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 11/08/2019 Clerk of the Court BY: RONNIE OTERO Deputy Clerk 3. I physically inspect M Squared Construction Inc,'s job sites on a daily basis and prepare 2 Daily Reports specific to each job. 3 4. Attached to the index of exhibits as I".xhibit E are true auld correct copies ol'Daily 4 Reports I completed for work on the polk Streelscape project spanning November 27, 2017 through December 8, 2017. 6 5. These IJaily Reports were prepared during thc regular course of business to document the 7 scope of work ctrmpletcd on a daily basis. 8 6. I personal lv visit the jobsitcs and communicate with the foremen of the crews completing 9 the work in order to maintain the accuracy of these reports. 10 7. There is no Dailv Report for January 20,2018 because M Squared Construction Inc. II work crews did not work the weekend of January 20, 2018 on the Polk Stluetscape 12 Project. 13 8. M Squared Construction Inc. does not use concrete filled buckets for sign posts, M 14 Squared uses leg flame barricades. a true and correct photograph of M Squared's leg 15 I'rame barricades are attached to the index of exhibits as Exhibit "L." 16 9. I declare under penalty of perjury under the laws of the State of California that the 17 foregoing is trna and correct and that this declaration was executed at San Francisco, 18 Calif'ornia. DAIRE 1vDRDAN 22 23 24 4992-9269-9924, v. I 26 27 DECLAItATION OF DAIRE LORDAN IN SUPPORT OF DEFENDANTS'OTIN I'Olt SUIvIMARY,IUDGMENT No. c0c- I 8-5723 16