Free Motion for Extension of Time - 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. CIV-04-595 PHX MHM

9 ESTATE OF JOSEPH J. STUDNEK, by and through its PERSONAL REPRESENTATIVE, 10 JOSEPH M. STUDNEK, 11 12 v. 13 AMBASSADOR OF GLOBAL MISSIONS UN LIMITED AND HIS SUCCESSORS, A 14 CORPORATION SOLE, a Nevada corporation; EL SHADDAI MINISTRIES 15 AND HIS SUCCESSORS, A CORPORATION SOLE, a Nevada 16 Corporation; SECOND CHANCE CHRISTIAN EVANGELISTIC MINISTRIES, 17 a California corporation; BISHOP OF FAITH VISION NOBLE HOUSE AND HIS 18 SUCCESSORS, A CORPORATION SOLE, a California corporation; JOSEPH L. 19 WILLIAMS and MONICA C. CISNEROS, as husband and wife; WILLIAM JOE LITTLE, 20 JR.; MICHAEL CAMBRA and GLORIA CAMBRA, as husband and wife; JOEL 21 DAVID and CINDY DAVID, as husband and wife; KEITH AARON VANN and TRISHA 22 VANN, as husband and wife, 23 24 25 26 Case 2:04-cv-00595-MHM Document 134 Defendants/Counterclaimants. Plaintiff/Counterdefendant,

MOTION TO EXTEND AUGUST 18, 2006 DISCOVERY DEADLINE

Assigned to the Honorable: Magistrate Mary H. Murguia

Filed 08/17/2006

Page 1 of 3

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Plaintiff, through counsel undersigned, respectfully requests that this Court extend the August 18,

2 2006 discovery deadline in order to allow Wells Fargo time to provide additional documents which have 3 been requested by Plaintiff. 4 On June 19, 2006 this Court held a status hearing and ordered that Jurisdictional discovery be

5 completed by August 18, 2006. The order also states that this Court would not be extending any of the 6 deadlines. Both counsel for Plaintiff and Ms. Fisk received documents from Wells Fargo. Counsel for 7 Plaintiff traveled to Ms. Fisk's office to review the documents and requested additional information 8 regarding a selected few transactions. Counsel for Plaintiff then contacted Wells Fargo and requested 9 the additional documents. Wells Fargo has indicated that the documents will not likely be provided 10 prior to the August 18, 2006 deadline as the representative in charge of the subpoena is "swamped." 11 However, counsel for Plaintiff believes the documents will be provided well in advance of the August 12 31st deadline to amend Plaintiff's response to the Motions to Dismiss as the requested documents relate 13 to merely 13 items; far less than the hundreds of documents provided by Wells Fargo to date. In fact, 14 Ms. Fagan, the Wells Fargo representative on this subpoena, has given counsel the tentative date of 15 August 22, 2006 for the receipt of the documents. 16 At all times herein counsel has been diligent in his efforts to comply with this Court's deadlines.

17 However, counsel does not have control over Wells Fargo's subpoena processing. 18 Therefore, exercising an abundance of caution, Plaintiff requests that the August 18th deadline be

19 extended two weeks in order to allow Wells Fargo the time necessary to provide the additional 20 documents. 21 22 23 24 25 26 Case 2:04-cv-00595-MHM /s/Jeremy S. Geigle Bradley D. Weech, Esq. Jeremy S. Geigle, Esq. 40 North Center Street, Suite 200 Mesa, Arizona 85201 (480) 464-1111 Attorney for Plaintiff Document 134 2 Filed 08/17/2006 Page 2 of 3 DATED this 17th day of August, 2006. JACKSON WHITE, P.C.

1 COPY of the foregoing mailed/ 2 *emailed this 17th day of August, 2006, to: 3 Debra A. Hill 4 OSBORN, MALEDON, P.A. 2929 North Central Avenue, Suite 2100 5 Phoenix, Arizona 85012-2794 Attorneys for Ambassador of Global Missions, 6 El Shaddai Ministries, Second Chance Evangelistic Ministries and Michael Cambra 7 Joseph L. Williams 8 15934 Hesperian Blvd., PMB 311 San Lorenzo, VA 94580 9 Bishop of Faith Vision Noble 10 House and His Successors, a Corporation Sole 35 Shadow Mountain 11 Oakland, CA 94605 12 William Joe Little, Jr. 1503 Mary Jane Ct. 13 Auburn, CA 95603 14 Joel and Cindy David 271 Ano Avenue 15 San Lorenzo, CA 94580-1713 16 Keith and Trisha Vann 35 Shadow Mountain 17 Oakland, CA 94605 18 19 20 21 22 23 24 25 26 Case 2:04-cv-00595-MHM Document 134 3 Filed 08/17/2006 Page 3 of 3 /s/ Catherine Magurany
F:\STU \Studnek, Joe\G lobal M issions\Pldgs\M otion to Extend 081806 D isc D eadline.w pd