Free Stipulation - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 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

17 Second Chance Ministries' and Michael Cambra's motion for a protective order re 18 document subpoena to Wells Fargo, N.A. (the "Wells Fargo Subpoena," a copy of 19 which is attached as Exhibit A to Doc. 113). Pursuant to the Court's May 16, 2006 20 Order (Doc. 120), the parties conferred and stipulated to the following terms. 21 IT IS HEREBY ORDERED that Wells Fargo must produce all documents

22 requested in the Wells Fargo Subpoena as to Defendants Michael Cambra, El Shaddai, 23 and Second Chance to the attention of Ronda Fisk at Osborn Maledon, 2929 N. 24 Central Avenue, Phoenix, Arizona 85012. Wells Fargo may not produce any

25 documents as to Defendants Gloria Cambra and Monica Cisneros unless and until 26 Plaintiff files an proper affidavit of service with the Court, at which time Plaintiff's 27 counsel and counsel for these parties will confer regarding the terms under which 28 Wells Fargo may produce documents pertaining to these defendants. Wells Fargo

Case 2:04-cv-00595-MHM

Document 125-2

Filed 06/07/2006

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1 must produce documents as to the remaining named Defendants to the attention of 2 Jeremy Geigle at Jackson White, 40 North Center, Suite 200, Mesa, Arizona, 85201. 3 IT IS FURTHER ORDERED that Osborn Maledon will notify Plaintiff's

4 counsel within 24 hours of receiving the documents related to Defendants Cambra, El 5 Shaddai, and Second Chance. Plaintiff's counsel will have five business days to 6 review the documents and identify those that may show an alter ego relationship 7 between Defendants Cambra, El Shaddai, and Second Chance and Defendants 8 Ambassador of Global Missions UnLimited and His Sucessors and Joseph L. 9 Williams. Ms. Fisk immediately will review the documents identified by Plaintiff's 10 counsel, confer with Plaintiff's counsel regarding any disputed materials, and 11 promptly copy and produce to Plaintiff's counsel all documents relevant to 12 establishing personal jurisdiction. Osborn Maledon will retain all documents received 13 from Wells Fargo and has no obligation to produce the documents to Plaintiff's 14 counsel unless the Court denies the pending Motions to Dismiss. 15 IT IS FURTHER ORDERED that Plaintiff's counsel promptly will provide

16 Osborn Maledon with a copy of any and all documents it receives directly in response 17 to the Wells Fargo subpoena. 18 IT IS FURTHER ORDERED that given that Wells Fargo will take four to six

19 weeks to process the subpoena and given the need for Plaintiff's counsel to have time 20 to review the documents, the deadline for Plaintiff's counsel to complete limited 21 jurisdictional discovery is extended to seven weeks after the filing date of this Order. 22 If Wells Fargo takes longer than six weeks to respond to the subpoena, Plaintiff's 23 counsel must file a Motion to Extend the Deadline to Complete Limited Discovery 24 before the deadline expires. 25 26 27 28
Case 2:04-cv-00595-MHM Document 125-2 2 Filed 06/07/2006 Page 2 of 2