Free Amended Document (NOT Motion/Complaint) - District Court of Arizona - Arizona

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RICHARD J. MCDANIEL, P.C. ATTORNEY AT LAW 11811 N. TATUM BLVD., SUITE 1051 PHOENIX, ARIZONA 85028 Telephone (602) 953-8721 FAX (602) 953-8731 Richard J. McDaniel #013329 Attorney for Defendants Woodcock IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Case No. CIV 04-78-FJM SHIMKO & PISCITELLI, Plaintiff, v. PAUL and BOBBI WOODCOCK, et. al. Defendants. ) DEFENDANT PAUL WOODCOCK'S AFFIDAVIT

) )ss County of Maricopa ) Defendant Paul Woodcock declares, under penalty of perjury,

State of Arizona

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the following:
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1.
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I am a defendant in the present lawsuit. I never agreed to personally pay Shimko's attorneys' fees and costs. Shimko never sent a bill to me. All of his

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attorneys' fees and costs were paid by the CORF entities.
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3.
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Shimko did not advise or warn me of the potential conflicts involved in his representation of multiple clients at the same time.

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4. Shimko did not advise me that my interests might differ from those of Ross; Goldfarb; Guenther; corporate officers and employees, such as Brill and Richtie; the general partner; CORF Management Services, L.P.; and CORP Licensing Services, L.P. 5 Shimko never advised me that because he represented multiple parties, he would not be able to cut a deal for a settlement, such as offering my testimony in return for dismissal of claims against me. 6 Shimko never advised me to seek independent counsel, even when he believed that some of the other defendants were not following his advice to minimize our exposure in the underling CORF-related litigations. 7. I did not waive the conflicts involved in Shimko's representation of multiple parties because he did not make me aware of the potential conflicts. 8. Shimko did not tell me that he had lent money to the CORP entities until after the fact. 9. Shimko did not provide me with details of the transaction or advise me to have outside counsel review Shimko's business transactions with some of his clients. 10. Shimko never explained to me how he allocated payments he received from CORF between legal bills and loan repayment.

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11. Shimko also acquired an ownership interest in Aztec Medical Group, a tissue supply bank, in exchange for legal work. 12. Shimko did not advise me to have outside counsel review his business dealings with the CORP entities and individual defendants. 13. Shimko never asked for and never obtained my written consent to his business transactions with his clients. 14. In April 2003, Shimko demanded that I pledge my home to pay his ongoing attorneys' fees. 15. I refused because I had never agreed to be personally responsible for his fees. 16. Shimko never inquired about my personal assets or how they were held or indicated to me how my interests might differ from those of his other multiple clients, including the other limited partners, the general partner, the business entities, and CORP employees and P/ M/t-- C, ©G G4,0 officers.

O/vo

SUBSCRIBED AND S ORN by Paul Woo cock to and before me, the L undersigned Notary Public, this day of March 2008.
OFFICIAL SEAL NOTARY PUBLIC - State of Arizona MARICOPA COUNTY My Comm. Expires Apnl 16, 2009

DAYLE A. MOSES

My Commission Expires:

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