Free Objection - District Court of Arizona - Arizona

1 2 3 40 North Center, Suite 200 4 Mesa, Arizona 85201 (480) 464-1111 5 Attorneys for Plaintiff By: Bradley D. Weech, Bar No. 011135 6 Jeremy S. Geigle, Bar No. 021786 7 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA No. 2:04-CV-00595-PHX-MHM

9 ESTATE OF JOSEPH J. STUDNEK, by and through its PERSONAL 10 REPRESENTATIVE, JOSEPH M. STUDNEK, 11 Plaintiff/Counterdefendant, 12 v. 13 AMBASSADOR OF GLOBAL 14 MISSIONS UN LIMITED AND HIS SUCCESSORS, A CORPORATION 15 SOLE, a Nevada corporation; EL SHADDAI MINISTRIES AND HIS 16 SUCCESSORS, A CORPORATION SOLE, a Nevada Corporation; SECOND 17 CHANCE CHRISTIAN EVANGELISTIC MINISTRIES, a California corporation; 18 BISHOP OF FAITH VISION NOBLE HOUSE AND HIS SUCCESSORS, A 19 CORPORATION SOLE, a California corporation; JOSEPH L. WILLIAMS and 20 MONICA C. CISNEROS, as husband and wife; WILLIAM JOE LITTLE, JR.; 21 MICHAEL CAMBRA and GLORIA CAMBRA, as husband and wife; JOEL 22 DAVID and CINDY DAVID, as husband and wife; KEITH AARON VANN and 23 TRISHA VANN, as husband and wife, 24 25 26 Case 2:04-cv-00595-MHM Document 161 Defendants/Counterclaimants.

PLAINTIFF'S OBJECTION TO OSBORN MALEDON'S MOTION TO WITHDRAW AS COUNSEL Assigned to the Honorable: Mary H. Murguia

Filed 11/06/2006

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Plaintiff, Estate of Joseph J. Studnek, ("Studnek") objects to Osborn Maledon's Motion to

2 Withdraw as Counsel in the above matter, for the following reason that they have not provided the 3 name, last known residence and last known telephone numbers of their clients. 4 5 6 7 8 F.R.Civ P. LRCiv 83.3(b)(1) states: When such application bears the written approval of the client, it shall be accompanied by a proposed written order and may be presented to the Court, ex parte. The withdrawing attorney shall give prompt notice of the entry of such order, together with the name, last known residence and last known telephone numbers of the client, to all other parties or their attorneys. Osborn Maledon's motion was not filed ex parte, does not indicate that a form of order was

9 filed and does not include the names, the last known addresses or telephone numbers of their clients 10 or include in an order that Osborn Maledon is ordered to provide such, as required by the Rule. As 11 the file in this case reflects, Plaintiff had to expend great effort to locate and serve several of the 12 defendants and should not be required to locate them again. In fact, at the settlement conference 13 before Judge Duncan, Judge Duncan required that Mr. Williams provide an address for use in this 14 case, and subsequent to the conference, Judge Duncan also mandates that the Davids provide the 15 same. 16 THEREFORE, Studnek respectfully requests that any Order allowing withdrawal require

17 Osborn Maledon to provide the required contact information, as a condition of withdrawal. 18 19 20 21 22 23 24 25 26 Case 2:04-cv-00595-MHM Document 161 2 Filed 11/06/2006 Page 2 of 3 /s/ Bradley D. Weech By: Bradley D. Weech, No. 011135 40 North Center Street, Suite 200 Mesa, Arizona 85201 Attorneys for Plaintiff DATED this 6 th day of November, 2006. JACKSON WHITE

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I hereby certify that I electronically transmitted the attached document to the Clerk's Office

2 using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following 3 CM/ECF registrants, and mailed a copy of same to any non-registrants this 6 th day of November, 4 2006: 5 Debra A. Hill, Esq. OSBORN, MALEDON, P.A. 6 2929 North Central Avenue, Suite 2100 Phoenix, Arizona 85012-2794 7 Attorneys for Ambassador of Global Missions, El Shaddai Ministries, Second Chance Evangelistic 8 Ministries and Michael Cambra 9 Joseph L. Williams 15934 Hesperian Blvd., PMB 311 10 San Lorenzo, VA 94580 11 Bishop of Faith Vision Noble House and His Successors, a Corporation Sole 12 35 Shadow Mountain Oakland, CA 94605 13 William Joe Little, Jr. 14 1503 Mary Jane Ct. Auburn, CA 95603 15 Joel and Cindy David 16 271 Ano Avenue San Lorenzo, CA 94580-1713 17 Keith and Trisha Vann 18 35 Shadow Mountain Oakland, CA 94605 19 20 21 /s/ Terri Thompson 22 23 24 25 26 Case 2:04-cv-00595-MHM Document 161 3 Filed 11/06/2006 Page 3 of 3