Free Motion for Reconsideration - 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 reconsider its order denying the Motion of Defendants' Counsel to Withdraw. As an initial matter, defendants have complied fully with the requirements of Local Rule 83.3(b)(1). The rule requires that upon entry of the order permitting the withdrawal of counsel, counsel shall give prompt notice of the order, together with the last known residence and telephone numbers of the clients. Here, there has been no such order entered. Upon entry of such order, counsel will fully comply with the requirements of Local Rule 83.3(b)(1). Counsel understand the current status of the case, but as set forth in Debra Hill's declaration, filed ex parte and under seal with this Court, counsel is unable to continue their representation of the defendants in this case and must withdraw.
Case 2:04-cv-00595-MHM Document 168 Filed 11/21/2006 Page 1 of 3

No. CIV-04-595-PHX-MHM MOTION FOR RECONSIDERATION

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We have advised our corporate clients that they cannot appear in this matter except through licensed counsel. We have also advised them about the possible consequences if they fail to retain new counsel and do not respond to Plaintiffs' Motion to Enforce the Settlement Agreement. 1 In sum, good cause exists for defendants' counsel to withdraw in this case and defendants request that the Court reconsider its initial ruling and permit defendants' counsel to withdraw. DATED this 21st 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 21, 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

Local Rule 83.3 does not require that defendants provide the name of new counsel prior to withdrawal of present counsel. -2Case 2:04-cv-00595-MHM Document 168 Filed 11/21/2006 Page 2 of 3

1

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I hereby certify that on November 21, 2006, I served the attached document by first-class mail on the following, who are not registered participants of the CM/ECF System: Joseph L. Williams 15934 Hesperian Boulevard P.M.B. 311 San Lorenzo, California 94580

s/Karen L. McClain
1438120_1

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