Free Reply to Response to Motion - District Court of Arizona - Arizona

1 2 3
The Phoenix Plaza 21 st Floor 2929 North Central Avenue Phoenix, Arizona 85012-2794 P.O. Box 36379 Phoenix, Arizona 85067-6379 Telephone Facsimile 602.640.9000 602.640.9050

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Debra A. Hill, 012186 Ronda R. Fisk, 022100 OSBORN MALEDON, P.A. 2929 North Central Avenue, Suite 2100 Phoenix, Arizona 85012-2793 [email protected] [email protected] (602) 640-9000 Attorneys for Defendants Global Missions Un Limited and El Shaddai Ministries

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ESTATE OF JOSEPH J. STUDNEK, by and through its PERSONAL REPRESENTATIVE, JOSEPH M. STUDNEK, Plaintiff/Counterdefendants v. AMBASSADOR OF GLOBAL MISSIONS UN LIMITED HIS SUCCESSORS, A CORPORATION SOLE, a Nevada corporation sole; EL SHADDAI MINISTRIES AND HIS SUCCESSORS, A CORPORATION SOLE, a Nevada Corporation; SECOND CHANCE CHRISTIAN EVANGELISTIC MINISTRIES, a California corporation; BISHOP OF FAITH VISION NOBLE HOUSE AND HIS SUCCESSORS, A CORPORATION SOLE, a California corporation; JOSEPH L. WILLIAMS and MONICA C. CISNEROS, as husband and wife; WILLIAM JOE LITTLE, MICHAEL CAMBRA and GLORIA CAMBRA, as husband and wife; JOEL DAVID and CINDY DAVID, as husband and wife; KEITH AARON VANN and TRISHA VANN, as husdand and wife, Defendants/Counterclaimants. No. CIV-04-595-PHX-MHM REPLY IN SUPPORT OF DEFENDANT GLOBAL MISSIONS' MOTION TO AMEND RULE 16 SCHEDULING ORDER

Case 2:04-cv-00595-MHM

Document 98

Filed 02/10/2006

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Plaintiff has indicated that he is not opposed to Defendant Global Missions Un Limited's ("Global Missions") Motion to Amend the Rule 16 Scheduling Order. Specifically, Global Missions requested that the Court vacate the February 13, 2006 discovery deadline and the March 30, 2006 dispositive motion deadline and suggested that the Court schedule a status conference with all parties and their counsel to establish new deadlines once all parties have been served and have answered. Plaintiff suggests that the Court "reset all deadlines to ninety (90) days later than currently set." Global Missions is not opposed to resetting the February 13 and March 30 deadlines by 90 days, but if Plaintiff has failed to serve all defendants with sufficient time for them to file responsive pleadings within the new deadlines, then Global Missions and potentially other Defendants will need to request an additional extension of time. We thought it would be simpler to wait until all new Defendants have been served and answered so that all attorneys can be present to set a new scheduling order. Nevertheless, if the Court wants to adopt Plaintiff's suggestion for the February 13 and March 30 deadlines, we have no objection. DATED this 10th day of February, 2006. OSBORN MALEDON, P.A.

By s/Ronda R. Fisk Debra A. Hill Ronda R. Fisk 2929 North Central, Suite 2100 Phoenix, Arizona 85012-2794 Attorneys for Defendants Global Missions UN Limited and El Shaddai Ministries

-2Case 2:04-cv-00595-MHM Document 98 Filed 02/10/2006 Page 2 of 3
1179198

1

CERTIFICATE OF SERVICE
2

I hereby certify that on February 10, 2006, I electronically transmitted
3

the attached document to the Clerk's Office using the CM/ECF System for filing and
4

transmittal of a Notice of Electronic Filing to the following CM/ECF registrants:
5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

· Jeremy Scott Geigle, [email protected] · Bradley D. Weech, [email protected] I hereby certify that on February 10, 2006, I served the attached document by first-class mail on the Honorable Mary H. Murguia, United States District Court, Sandra Day O'Connor U.S. Courthouse, Suite 525, 401 West Washington Street, SPC 53, Phoenix, Arizona 85003-2154.

I hereby certify that on February 10, 2006, I served the attached document by first-class mail on the following, who are not registered participants of the CM/ECF System: Joseph L. Williams 15934 Hesperian Blvd. P.M.B. 311 San Lorenzo, CA 94580

s/ Lindsay B. Jensen

-3Case 2:04-cv-00595-MHM Document 98 Filed 02/10/2006 Page 3 of 3
1179198