Free Motion for Extension of Time - District Court of Arizona - Arizona

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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

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Debra A. Hill, 012186 Ronda R. Fisk, 022100 OSBORN MALEDON, P.A. 2929 North Central Avenue Suite 2100 Phoenix, Arizona 85012-2794 (602) 640-9000 Attorneys for Defendant/Counterclaimants Global Missions Unlimited and Joseph L. Williams

IN THE UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF ARIZONA
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ESTATE OF JOSEPH J. STUDNEK, by and through its PERSONAL REPRESENTATIVE, JOSEPH M. STUDNEK, Plaintiff/Counterdefendant 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 DEFENDANTS' GLOBAL MISSIONS UN LIMITED AND JOSEPH L. WILLIAMS UNOPPOSED MOTION TO EXTEND TIME TO FILE AN ANSWER TO THE SECOND AMENDED COMPLAINT

Case 2:04-cv-00595-MHM

Document 71

Filed 11/29/2005

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Pursuant to Fed. R. Civ. P. 6(b), Defendants Global Missions UN Limited and Joseph L. Williams hereby move for a fifteen-day extension of time in which to file their answer to Plaintiff's Second Amended Complaint. Plaintiff does not oppose this motion. In support of this motion, Defendants state as follows: 1. Pursuant to Rule 15(a), Defendants' answer is due December 1, 2005. 2. Counsel for Defendants are preparing for a trial that starts on December 1, 2005 in another matter. 3. The undersigned counsel has consulted with Jeremy Geigle, counsel for Plaintiff in this matter, and he does not oppose Defendants' request for additional time. 4. This request is made for good cause and will not delay the disposition of this matter. For the reasons stated above, Defendants ask the Court to enter their proposed order, extending until December 16, 2005, the time within which they may file their answer to Plaintiff's Second Amended Complaint. RESPECTFULLY SUBMITTED this 29th day of November, 2005. 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 Defendant/ Counterclaimants Global Missions Unlimited and Joseph L. Williams I hereby certify that on November 29, 2005, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Bradley D. Weech Jeremy S. Geigle JACKSON WHITE 40 North Center Street, Suite 200
Document 71

Case 2:04-cv-00595-MHM

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Mesa, Arizona 85201 Attorneys for Plaintiff/Counterdefendant [email protected] [email protected]

s/ Lindsay B. Jensen

Case 2:04-cv-00595-MHM

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