Free Other Notice - District Court of Arizona - Arizona

Case 2:04-cv—00595-I\/IHI\/I D0cument215—2 Filed 05/17/2007 Page10f3 _

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40 North Center, Suite 200
4 Mesa, Arizona 85201
(480) 464-1 111
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 N0. CIV-04-595 PHX MHM
and through its PERSONAL
10 REPRESENTATIVE, JOSEPH M. LOCAL RULE 54.2(d)(1)
STUDNEK, STATEMENT OF CONSULTATION
11
Plaintiff/Counterdefendant,
12
iv.
13 Assigned to the Honorable:
AMBASSADOR OF GLOBAL Mary H. Murguia
14 MISSIONS UN LIMITED AND HIS
SUCCESSORS, A CORPORATION
15 SOLE, a Nevada corporation; EL
SHADDAI MINISTRIES AND HIS
16 SUCCESSORS, A CORPORATION
SOLE, a Nevada Corporation; SECOND
17 CHANCE CHRISTIAN EVANGELISTIC
MINISTRIES, a California corporation;
18 BISHOP OF FAITH VISION NOBLE
HOUSE AND HIS SUCCESSORS, A
19 CORPORATION SOLE, a California
corporation; JOSEPH L. WILLIAMS and
20 MONICA C. CISNEROS, as husband and
wife; WILLIAM JOE LITTLE, JR.;
21 MICHAEL CAMBRA and GLORIA
CAMBRA, as husband and wife; JOEL
me 22 DAVID and CINDY DAVID, as husband
E and wife; KEITH AARON VANN and
§ Q 23 TRISHA VANN, as husband and wife,
gig 24 Defendants/Counterclaimant.
on 1..
§ Q 25
>-S4:
26
Case 2:04-cv—00595-I\/IHI\/I Document 215-2 Filed 05/17/2007 Page 2 of 3

1 Pursuant to Local Rule 54.2(d)(1), undersigned counsel certifies that, as the Court is aware,
2 the Settling Defendants have been unwilling to compromise on any issues since the September 19,
3 2006 settlement conference and have even been unwilling to sign the Settlement Agreement or to
4 dismiss the two California cases, as agreed to before Magistrate Judge Duncan.
5 Further, the corporate Settling Defendants are not represented by counsel.
6 Further, Plaintiffs attorney fee and cost documentation is due the same date as Plaintiffs
7 response to Mr. Williams and Mr. Cambra’s Motions for Reconsideration; and, based on those
8 motions, it is clear that the Settling Defendants will not agree to any attomey fees and/or costs.
9 Assuming the Court denies the Motions for Reconsideration and still desires Plaintiff and the
10 Settling Defendants to discuss agreement on fees and costs, Plaintiff will participate in such a
11 discussion. However, based on the actions ofthe Settling Defendants over the last many years that
12 this case has been ongoing, Plaintiff believes that such discussion will only require additional time
13 and expense, and will not result in any agreement. Therefore, Plaintiff requests that the Court waive
14 this requirement and rule on fees and costs after allowing time for any objection and reply to be
15 filed.
16 Dated this 17"‘ day of May, 2007.
17 JACKSON WHITE, P.C.
18
By: /s/ Bradley D. Weech
19 Bradley D. Weech
Attorneys for Plaintiff
20
21 I hereby certify that 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
Ln 22 CM/ECF registrants, and mailed a copy of same to any non-registrants on May 17, 2007:
1* E
E E 23 Honorable Mary H. Murguia Joseph L. Williams and Michael Cambra
B fj 401 W. Washington 15934 Hesperian Blvd., P.M.B. 311
g Z 24 Phoenix, AZ 85003 San Lorenzo, CA 94580
on 5
5 § 25
jj By: /s/ Aaron Terryl Weech
I F:\STU\Studnek, .l0e\Gl0bnl Missi0ns\PIdgs\Statement 0fC0nsulta1l0n.wpd
Case 2:04-cv—00595-I\/IHI\/I Document 215?2 Filed 05/17/2007 Page 3 of 3 i

Case 2:04-cv-00595-MHM

Document 215-2

Filed 05/17/2007

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Case 2:04-cv-00595-MHM

Document 215-2

Filed 05/17/2007

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Case 2:04-cv-00595-MHM

Document 215-2

Filed 05/17/2007

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