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 7 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA No. CIV-04-595 PHX MHM PLAINTIFF'S SECOND MOTION FOR TWO WEEK EXTENSION TO FILE: 1. FORM OF JUDGMENT AND AFFIDAVIT OF ATTORNEYS FEES AND COSTS DOCUMENTS CONSISTENT WITH THE COURT'S APRIL 11, 2007, ORDER 2. RESPONSES TO WILLIAMS': A) Motion to Dismiss B) Memorandum of Law C) Request for Judicial Notice D) Notice of Motion to Dismiss E) Motion for Fees, Sanctions and Contempt REQUEST TO EXPEDITE RULING Assigned to the Honorable: Mary H. Murguia

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 Defendants/Counterclaimants. Plaintiff/Counterdefendant,

Plaintiff, Estate of Joseph J. Studnek ("Studnek"), moves this Court for an additional two
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week extension to file the documents noted in the caption (above). For the economy and benefit of
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responding to what is already pending, this extension is requested for the following reasons: 1)
Case 2:04-cv-00595-MHM Document 212 Filed 05/02/2007 Page 1 of 3

1 Studnek's counsel requests the opportunity to review the new documents received on May 1, 2007, 2 from Defendants Williams and Cambra mailed on April 21, 2007 but not filed until April 25, 2007, 3 which may or may not require a response; 2) Studnek's counsel is still awaiting receipt of a court 4 transcript of Mr. Williams' representations to the Alameda County, California Superior Court that 5 he had, in fact, settled the two California cases1 as part of the Settlement Agreement in this case, 6 and, additional information from Studnek's California counsel (retained to defend against 7 Mr. Williams' California lawsuits); and, 3) Studnek's counsel has two trials scheduled next week, 8 one in the Maricopa County Superior Court and one in Pinal County Superior Court. Studnek's 9 counsel will attempt to submit it's responses earlier, if at all possible. 10

Plaintiff requests the Court to expedite it's ruling for the reason that the Form of Judgment

11 and Affidavit of Attorneys Fees and Costs documents, and, the Responses to Defendant Williams' 12 Motions are due on Thursday, May 3, 2007. 13

Dated this 2nd day of May, 2007.
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JACKSON WHITE, P.C.
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By: /s/ Bradley D. Weech Bradley D. Weech Attorneys for Plaintiff ORIGINAL of the foregoing filed

18 with the Clerk of the United States

District Court this 2nd day of 19 May, 2007
20 COPY emailed to:

Honorable Mary H. Murguria
21 401 W. Washington

Phoenix, AZ 85003
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Mr. Williams has been labeled a vexatious litigant by the Alameda County, California Superior Court. According to the Estate's California counsel, Mr. Williams is prohibited from filing anything in the California courts without first obtaining permission from the presiding judge of the Alameda County Superior Court. To be labeled a vexatious litigant in California, a person must have filed and lost, or had dismissed, five cases in a seven year period. At the Order to Show Cause hearing, Mr. Williams apparently argued that he had settled both of his cases against the Estate (and others) as part of the Settlement Agreement in this Arizona District Court case, and, thus, had not lost them. Obviously, Mr. Williams statement further supports the award of all fees, costs, sanctions and other relief requested by the Estate in this case.
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Case 2:04-cv-00595-MHM

Document 212 2

Filed 05/02/2007

Page 2 of 3

1 COPY of the foregoing

mailed this same date to:
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Joseph L. Williams
3 15934 Hesperian Blvd., P.M.B. 311

San Lorenzo, California 94580
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By: /s/ Yvonne Salatas
5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Case 2:04-cv-00595-MHM Document 212 3 Filed 05/02/2007 Page 3 of 3
F:\STU\Studnek, Joe\Global Missions\Pldgs\Second Request to File Responses to Motions.wpd