Free Declaration - District Court of Arizona - Arizona

1 William L. Robinson (CA State Bar No. 087647)
Carrie Kienholz Flynn (CA State Bar No. 211776)
2 NIXON PEABODY LLP
2040 Main Street, Suite 850
3 Irvine, CA 92614
Telephone: (949) 475-6900
4 Facsimile: (949) 475-6910
5 Stephen C. Yost (AZ State Bar No. 011149)
CAMPBELL, YOST, CLARE & NORELL, P.C.
6 101 North First Avenue, suite 2500
Phoenix, AZ 85003
7 Telephone: (602) 322-1600
Facsimile: (602) 322-1604
8
Attorneys for Defendants AEROSPATIALE,
9 SOCIETE NATIONALE INDUSTRIELLE, S.A.
10 AND EUROCOPTER, S.A.
11 UNITED STATES DISTRICT COURT
12 DISTRICT OF ARIZONA
13
14 UNITED STATES AVIATION Case No. CIV 02-0824-PHX-EHC
UNDERWRITERS, INC., Manager, United
15 States Aircraft Insurance Group, a New York DECLARATION OF WILLIAM L.
corporation, and ROCKY MOUNTAIN ROBINSON IN SUPPORT OF
16 HOLDINGS, LLC, a Utah limited liability DEFENDANTS’ UNOPPOSED
company, MOTION FOR TRIAL
1 7 C ONTINUANCE
Plaintiffs,
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vs.
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AEROSPATIALE, SOCIETE NATIONALE
20 INDUSTRIELLE, S.A. aka Societe Nationale
Industrielle Aerospatiale, a French entity, and
21 EUROCOPTER S.A. aka Eurocopter France, a
French entity,
22
Defendants.
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24 I, William L. Robinson, declare as follows:
25 1. I am a partner with the law firm of Nixon Peabody, counsel for defendants
26 Aerospatiale, Societe Nationale Industrielle, S.A. and Eurocopter, S.A. (“Eurocopter" or
27 "Defendants"). I have been admitted pm imc vice to practice before this Court in this case.
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DECLARATION OF WILLIAM L. ROBINSON IN SUPPORT S5106’[8_‘l
or nsFnm>ANrs» usoppossu Morrow ron TRIAL
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1 2. I am the lead trial counsel for Defendants. I have been intimately involved in the
2 defense of this matter from its inception, and am the attorney most familiar with the issues of
3 the case, the relevant documents, and the witnesses. Neither my assisting associate, Ms.
4 Carrie Flynn, nor our assisting local counsel, Mr. Stephen Yost of the firm Campbell, Yost,
5 Clare & Norell, P.C, nor any other counsel, can be prepared to adequately defend the interests
5 of Defendants in the short time remaining before trial is scheduled to commence. I have been
7 involved in the defense of many cases on behalf of Defendants during the past 20 years, and
8 am the attorney they wish to have representing them at trial.
9 3. Within the past 3 weeks, I was diagnosed with a serious medical condition that
10 requires immediate assessment and treatment. I am scheduled for a critical diagnostic test on
1 1 October 3, the earliest it could be arranged after my preliminary diagnosis. I will be
12 consulting with one or more physicians within a day or two after taking the subject test, to
13 decide upon a treatment plan and schedule. Whatever the results of the test, I have been
14 advised that within the next several weeks I will have to undergo in—patient treatment at a
15 1 hospital for several days, followed by at least several weeks of rest and recuperation.
15 4. Due to privacy concerns, I prefer not to disclose further details about my condition. I
17 ‘ will, however, provide the Court with further information in camera if desired.
18 5. I did not bring this matter to the Court’s attention sooner because I was hopeful that
19 the matter would be continued due to the Court’s own scheduling conflicts. I received notice
20 from the Court on Friday, September 23, that trial would proceed on October 4. I
21 immediately contacted J on Kodani, lead counsel for Plaintiffs, and advised him of the
22 situation. He very graciously expressed his sympathy and indicated that he would not oppose
23 the request for continuance.
24 6. I have every reason to believe that my medical condition will be favorably resolved
25 within the next 30 to 60 days, and that trial can be rescheduled for sometime after February l,
26 2006. g
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1 3E%'t%%2£K?$T2IU`§%§$3ZLB‘§`i3$$?$??i?eE§`—?EFIS“I ‘2’ S5‘°“8·‘ i
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1 I declare under penalty of perjury under the laws of the State of California that the
2 foregoing is true and correct.
2 3 Executed this 27m day of September, 2005, at Irvine, California.
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5 ~ /s/ William L. Robinson A
6 William L. Robinson
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DECLARATION OF WILLIAM L. ROBINSON IN SUPPORT -3- S5'4Q6']8_1
or i>m¤aNuANrs= unovposmi Morrow ron TRIAL
“t$§‘§él*’§‘;5I2-cv-00824-Euc Document 76 Filed 09/27/2005 Page a or 4

1 A CERTIFICATE OF SERVICE
2
3 The undersigned hereby certifies that the original and one copy were filed with the
4 Clerk of the United States District Court this 27th day of September, 2005.
5 The undersigned hereby certifies that a true and correct copy of the foregoing
instrument was served on this 27th day of September, 2005, by facsimile and U.S. Mail, on
6 the following counsel of record
7 John A. Kodani, Esq.
8 Jeffrey J. Williams, Esq.
LAW OFFICES OF JON A. KODANI
9 2200 Michigan Avenue
10 Santa Monica, CA 90404
Tele: (3l0) 453-6762
11 Fax: (310) 229-3240
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13 /s/ William L. Robinson
William L. Robinson
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DECLARATION OF WILLIAM L. ROBINSON IN SUPPORT -4- S51Q618_*]
or DEFENDANTS’ uivoprosnn Morrow Fon rum.
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