1 . 1
[ACKS ON W HITE
2 p ATTORNEYS AT LAW
3 Prokssiohag Eqrpvratimz
40 North Center, Suite 200
4 Mesa, Arizona 85201
(480) 464-1111
5 Attomeys for Plaintiff
By: Bradley D. Weech, Bar No. 01 1 135
6 Jeremy S. Geigle, Bar No. 021786
7 IN THE UNITED STATES DISTRICT COURT
8 FOR THE DISTRICT OF ARIZONA
9 ESTATE OF JOSEPH J. STUDNEK, by and No. CIV-04-595 PHX MHM
through its PERSONAL REPRESENTATIVE,
10 JOSEPH M. STUDNEK,
1 1 Plaintiff/Counterdefendant,
NOTICE OF DEPOSITION
12 v. OF WELLS FARGO BANK,
NATIONAL ASSOCIATION
13 AMBASSADOR OF GLOBAL MISSIONS (Records Only)
UN LIMITED AND HIS SUCCESSORS, A
14 CORPORATION SOLE, a Nevada
corporation; EL SHADDAI MINISTRIES
15 AND HIS SUCCESSORS, A Assigned to the Honorable:
CORPORATION SOLE, a Nevada Magistrate Mary H. Murguia
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
E B 22 VANN, as husband and wife,
§ Q 23 Defendants/Counterclaimants.
§ z 24
cn E
é § 25
" 26
Case 2:04-cv—00595-I\/IHI\/I Document 118 Filed 05/11/2006 Page 1 of 3
1 YOU ARE HEREBY NOTIFIED that, pursuant to Fed.R.Civ.P. 26 and 30, the deposition will be
2 taken upon oral examination of the persons whose names and addresses as stated below at the time and
3 place stated below before an officer authorized by law to administer oaths. Said representative of the
4 company shall provide the documents listed on Exhibit A attached hereto and incorporated herein by
5 reference. If the names are now known, a general description sufficient to identify these persons or the
6 particular classes or groups to which those persons belong is given below.
7 NAME: Wells Fargo Bank, National Association
8 DATE/T IME: Wednesday, May 3, 2006
1:00 p.m.
9
PLACE: Law Offices of Jackson White, P.C. _
10 40 N. Center Street, Suite 200
Mesa, Arizona 85201
11 (480) 467-4362
12
The undersigned certifies that copies of the foregoing Notice of Deposition (Records Only) has
13 (K
been served by mail this 1'> day of April, 2006, to:
14
Debra A. Hill
15 OSBORN, MALEDON, P.A.
2929 North Central Avenue, Suite 2100
16 Phoenix, Arizona 85012-2794
17 Morris-Crowe Court Reporters
2702 N. 3'd Street, #3050
18 Phoenix, Arizona 85004
19
JACKSON WHITE, P.C.
20
21
uq 22 Bradl D. Weech, {
E é Jerem S. Geigle, sq.
T-· ,. 23 40 North Center Street, Suite 200
E Q Mesa, Arizona 85201
EZ) Z3 24 (480) 464-1111
rn E Attomey for Plaintiff
M 2 25
U 1-*
·
Case 2:04-cv—00595-I\/IHI\/I Document 11§ Filed 05/11/2006 Page 2 of 3
1 EXHIBIT A I
Re: AMBASSADOR OF GLOBAL MISSIONS UN LIMITED AND HIS SUCCESSORS, A
CORPORATION SOLE, a Nevada corporation; GLOBAL MISSIONS UNLIMITED; EL
SHADDAI MINISTRIES AND HIS SUCCESSORS, A CORPORATION SOLE, a Nevada
Corporation; SECOND CHANCE CI-IRISTLAN EVANGELISTIC MINISTRIES, a Califomia
corporation; BISHOP OF FAITH VISION NOBLE HOUSE AND HIS SUCCESSORS, A
CORPORATION SOLE, a California corporation; JOSEPH L. WILLIAMS and MONICA C.
CISNEROS, individually and as husband and wife; WILLLAM JOE LITTLE, JR.; MICHAEL
CAMBRA and GLORIA CAIVIBRA, individually and as husband and wife; JOEL DAVID and
CINDY DAVID, individually and as husband and wife; KEITH AARON VANN and TRISHA
VANN, individually and as husband and wife; GLOBAL MISSIONS UNLIMITED.
All documents in the possession or control of Wells Fargo, N.A. relating to financial institution
account information for the period of January, 200l through the present, for the above-listed
individuals/defendants or any entity in which they have or had any interest whatsoever to the
knowledge of Wells Fargo, N.A., either alone or jointly with any other person or persons, including,
but not limited to:
l. Legible copies of all bank statements on all checking accounts, cancelled checks and
deposits, accounting records documenting all debits and credits on all checking accounts,
including, but not limited to, account number 9999405203.
2. Copies of bank statements on all savings accounts and accormting records documenting all
debits and credits on all savings accounts.
3. Copies of any and all certificates of deposit and accounting records documenting all debits
and credits on all certificates of deposit.
4. Copies of any and all loans, notes, contracts, negotiable instruments receivable or accounts
receivable whether due or not due.
5. A copy of all financial statements, expense records, balance sheets, profit and loss
statements.
6. A copy of all documents reflecting interest in all partnerships, companies, businesses,
corporations, whether named as an officer or member in public records including, but not
limited to, bank resolutions and/or minutes thereto; corporate resolutions and/or minutes
thereto; corporation resolutions, and/or minutes thereto, including correspondence and
changes thereto, or any and all other documents relating to transactions reflected in the bank
statements for all accounts. The above records to include, but not limited to, all
correspondence, notes, memoranda, or writings of any kind.
The terms "documents," as used herein, includes any media in which letters, words, or numbers, or
their equivalent, are set down by handwriting, typewriting, printing, photostating, photographing,
magnetic impulse, mechanical or electronic recording, or other form of data compilation.
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