Free Stipulation - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 This Court granted in part Docket Item 112, Defendant El Shaddai Ministries', v. Ambassador of Global Missions UN Limited His Successors, et al., Defendants. Estate of Joseph J. Studnek, Plaintiff, PROTECTIVE ORDER REGARDING WELLS FARGO SUBPOENA AND ORDER EXTENDING DEADLINE TO COMPLETE LIMITED JURISDICTIONAL DISCOVERY No. CIV-04-595-PHX-MHM IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

20 Second Chance Ministries' and Michael Cambra's motion for a protective order re 21 document subpoena to Wells Fargo, N.A. (the "Wells Fargo Subpoena," a copy of 22 which is attached as Exhibit A to Doc. 113). Pursuant to the Court's May 16, 2006 23 Order (Doc. 120), the parties conferred and stipulated to the following terms. 24 IT IS HEREBY ORDERED that Wells Fargo must produce all documents

25 requested in the Wells Fargo Subpoena as to Defendants Michael Cambra, El Shaddai, 26 and Second Chance to the attention of Ronda Fisk at Osborn Maledon, 2929 N. 27 Central Avenue, Phoenix, Arizona 85012. Wells Fargo may not produce any

28 documents as to Defendants Gloria Cambra and Monica Cisneros unless and until

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1 Plaintiff files an proper affidavit of service with the Court, at which time Plaintiff's 2 counsel and counsel for these parties will confer regarding the terms under which 3 Wells Fargo may produce documents pertaining to these defendants. Wells Fargo 4 must produce documents as to the remaining named Defendants to the attention of 5 Jeremy Geigle at Jackson White, 40 North Center, Suite 200, Mesa, Arizona, 85201. 6 IT IS FURTHER ORDERED that Osborn Maledon will notify Plaintiff's

7 counsel within 24 hours of receiving the documents related to Defendants Cambra, El 8 Shaddai, and Second Chance. Plaintiff's counsel will have five business days to 9 review the documents and identify those that may show an alter ego relationship 10 between Defendants Cambra, El Shaddai, and Second Chance and Defendants 11 Ambassador of Global Missions UnLimited and His Sucessors and Joseph L. 12 Williams. Ms. Fisk immediately will review the documents identified by Plaintiff's 13 counsel, confer with Plaintiff's counsel regarding any disputed materials, and 14 promptly copy and produce to Plaintiff's counsel all documents relevant to 15 establishing personal jurisdiction. Osborn Maledon will retain all documents received 16 from Wells Fargo and has no obligation to produce the documents to Plaintiff's 17 counsel unless the Court denies the pending Motions to Dismiss. 18 IT IS FURTHER ORDERED that Plaintiff's counsel promptly will provide

19 Osborn Maledon with a copy of any and all documents it receives directly in response 20 to the Wells Fargo subpoena. 21 IT IS FURTHER ORDERED that Jurisdiction discovery shall be completed by

22 August 18, 2006. Plaintiff's supplemental response to the motion to dismiss shall be 23 filed by August 31, 2006; and Defendant's amended reply, if necessary, shall be filed 24 by September 8, 2006. 25 26 27 28 2
Order.doc

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