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 81 Defendants/Counterclaimants. Plaintiff/Counterdefendant,

PLAINTIFF'S MOTION FOR ONE DAY EXTENSION TO FILE RESPONSE TO: DEFENDANT JOSEPH L. WILLIAMS' MOTION TO DISMISS AND PLAINTIFF'S MOTION FOR SANCTIONS REQUEST TO EXPEDITE RULING Assigned to the Honorable: Mary H. Murguia

Filed 01/10/2006

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Counsel for Plaintiff moves this Court for a one-day extension to file Plaintiff's Response to

2 Defendant Joseph L. Williams' Motion to Dismiss due to counsel for Plaintiff having been ill, which 3 prevented him from finalizing and filing the Response and Motion for Sanctions as intended. A request 4 is made for an expedited ruling on this Motion. 5 6 7 8 9 ORIGINAL of the foregoing filed 10 with the Clerk of the United States District Court this 10th day of 11 January, 2006 12 Judge Mary H. Murguia 401 W. Washington 13 Phoenix, AZ 85003 14 COPY of the foregoing mailed this same date to: 15 Debra A. Hill 16 OSBORN, MALEDON, P.A. 2929 North Central Avenue, Suite 2100 17 Phoenix, Arizona 85012-2794 Attorney for Defendants 18 19 By: 20 21 22
F:\STU\Studnek, Joe\Global Missions\Pldgs\Motion for One Day Extension to File Response to MTD.wpd

Dated this 10th day of January, 2006. JACKSON WHITE, P.C. By: /s/ Jeremy S. Geigle Bradley D. Weech Jeremy S. Geigle Attorneys for Plaintiff

/s/ Catherine R. Magurany

23 24 25 26 Case 2:04-cv-00595-MHM Document 81 2 Filed 01/10/2006 Page 2 of 2