Free Motion for Extension of Time - District Court of Arizona - Arizona

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Debra A. Hill, 012186 Ronda R. Fisk, 022100 OSBORN MALEDON, P.A. 2929 North Central Avenue Suite 2100 Phoenix, Arizona 85012-2793 (602) 640-9000 Attorneys for Defendants Global Missions, El Shaddai Ministries, Second Chance Ministries, and Michael Cambra

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Estate of Joseph J. Studnek, Plaintiff/Counterdefendant, v. Ambassador of Global Missions UN Limited His Successors, et al., Defendants/Counterclaimants. Defendants Global Missions, El Shaddai Ministries, Second Chance Ministries, and Michael Cambra request that the Court grant them an extension of time to file a response to Defendants' Motion to Enforce the Settlement Agreement and Motion for Attorney Fees (Dkt. 165) until the Court has had an opportunity to rule on Defendants' Motion to Reconsider the Court's denial of Defendants' Motion to Withdraw.1 Counsel for defendants moved to withdraw on November 1, 2006. (Dkt. 159). The Court denied the motion. (Dkt. 167). On November 21, 2006, defendants filed a Motion for Reconsideration. (Dkt. 168). As set forth in Ms. Hill's declaration, filed ex parte and under seal, defendants' counsel cannot continue to represent defendants. Given the response date, defendants request that the Court hear this on an expedited basis. Defendants have filed today a Motion for Expedited Consideration.
Case 2:04-cv-00595-MHM Document 171 Filed 11/27/2006 Page 1 of 3
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No. CIV-04-595-PHX-MHM DEFENDANTS' MOTION FOR ADDITIONAL TIME TO RESPOND TO MOTION TO ENFORCE SETTLEMENT AGREEMENT AND FOR ATTORNEY FEES

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Defendants' response to the Motion to Enforce, however, is due on December 4, 2006. Defendants therefore request that the Court grant them an extension to file their response to the Motion to Enforce Settlement Agreement until 30 days after the Court rules on the Motion to Reconsider, which will give defendants sufficient time to retain new counsel and file a response to the pending motions. Plaintiffs will not be prejudiced by this request. Accordingly, defendants request that the Court continue the response date for defendants' responses until 30 days after the Court rules on the pending Motion for Reconsideration. DATED this 27th day of November, 2006. OSBORN MALEDON, P.A.

By s/Debra A. Hill Debra A. Hill Ronda R. Fisk 2929 North Central, Suite 2100 Phoenix, Arizona 85012-2793 Attorneys for Defendants Global Missions, El Shaddai Ministries, Second Chance Ministries, and Michael Cambra

CERTIFICATE OF SERVICE I hereby certify that on November 27, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: · Bradley D. Weech · Jeremy S. Geigle I hereby certify that on November 27, 2006, I served the attached document by first-class mail on the following, who are not registered participants of the CM/ECF System:

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Joseph L. Williams 15934 Hesperian Boulevard P.M.B. 311 San Lorenzo, California 94580

s/Karen L. McClain
1440207_1

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