Free Reply in Support of Motion - District Court of Arizona - Arizona

1 2 3
The Phoenix Plaza 21 st Floor 2929 North Central Avenue Phoenix, Arizona 85012-2793 P.O. Box 36379 Phoenix, Arizona 85067-6379 Telephone Facsimile 602.640.9000 602.640.9050

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Debra A. Hill, 012186 Ronda R. Fisk, 022100 OSBORN MALEDON, P.A. 2929 N. Central Avenue, Suite 2100 Phoenix, Arizona 85012-2793 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, by and through its PERSONAL REPRESENTATIVE, JOSEPH M. STUDNEK, Plaintiff/Counterdefendant v. AMBASSADOR OF GLOBAL MISSIONS UN LIMITED HIS SUCCESSORS, A CORPORATION SOLE, a Nevada corporation sole; EL SHADDAI MINISTRIES AND HIS SUCCESSORS, A CORPORATION SOLE, a Nevada Corporation; SECOND CHANCE CHRISTIAN EVANGELISTIC MINISTRIES, a California corporation; BISHOP OF FAITH VISION NOBLE HOUSE AND HIS SUCCESSORS, A CORPORATION SOLE, a California corporation; JOSEPH L. WILLIAMS and MONICA C. CISNEROS, as husband and wife; WILLIAM JOE LITTLE, MICHAEL CAMBRA and GLORIA CAMBRA, as husband and wife; JOEL DAVID and CINDY DAVID, as husband and wife; KEITH AARON VANN and TRISHA VANN, as husband and wife, Defendants/Counterclaimants.

No. CIV-04-595-PHX-MHM

REPLY IN SUPPORT OF MOTION FOR LEAVE TO WITHDRAW AS COUNSEL

Case 2:04-cv-00595-MHM

Document 162

Filed 11/09/2006

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
1

Plaintiff's objection to Osborn Maledon, P.A.'s motion to withdraw as counsel is based on a misreading of the language of Local Rule Civ. 83.3(b). Plaintiff objects that the motion failed to provide "the name, last known residence, and last known telephone number to their clients." The quoted language in Plaintiff's motion, however, makes clear that this information need not be provided until "entry of such order." LR Civ. 83.3(b)(1). Osborn Maledon, P.A. intends to fully comply with the rule at the time directed by the rule, i.e., once the Court enters the order allowing withdrawal.1 Thus, Osborn Maledon, P.A. respectfully requests that the Court promptly enter the order allowing it, Debra Hill, and Ronda Fisk to withdraw as counsel. DATED this 9th day of November, 2006. OSBORN MALEDON, P.A.

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

Case 2:04-cv-00595-MHM

Plaintiff counsel's implication that he does not know how to "locate" the Represented Defendants is belied by the facts in the record. For example, Plaintiff admits that Joseph L. Williams provided his contact information on the record (and, in fact, is included in the certificate of service on Plaintiff's opposition), and Plaintiff knows that Mr. Williams is the principal of Global Missions. Plaintiff has numerous documents obtained through discovery with the contact information for the other Represented Defendants. 1428819 -2Document 162 Filed 11/09/2006 Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

I hereby certify that on November 9, 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 Jackson White 40 N. Center Street, Suite 200 Mesa, AZ 85201 Attorneys for Plaintiff/Counterdefendant [email protected] [email protected] I hereby certify that on November 9, 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 Blvd. P.M.B. 311 San Lorenzo, CA 94580 s/ Lindsay B. Jensen

Case 2:04-cv-00595-MHM

Document 162

-3-

1428819

Filed 11/09/2006

Page 3 of 3