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

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40 North Center, Suite 200
4 Mesa, Arizona 85201
(480) 464-1111
5 Attorneys for Plaintiff
1 By: Bradley D. Weech, Bar No. 011135
6
7 IN THE UNITED STATES DISTRICT COURT
8 FOR THE DISTRICT OF ARIZONA
9 ESTATE OF JOSEPH J. STUDNEK, by and No. CIV-04-595 PHX MHM
through its PERSONAL REPRESENTATIVE,
10 JOSEPH M. STUDNEK, PLAINTIFF’S MOTION FOR ONE
WEEK EXTENSION TO FILE:
1 1 P1aintiff/ Counterdefendant,
1. FORM OF JUDGMENT AND
12 v. AFFIDAVIT OF ATTORNEYS FEES I
AND COSTS DOCUMENTS
13 AMBASSADOR OF GLOBAL MISSIONS CONSISTENT WITH THE COURT’S
UN LIMITED AND HIS SUCCESSORS, A APRIL 11, 2007, ORDER
14 CORPORATION SOLE, a Nevada
corporation; EL SHADDAI MINISTRIES 2. RESPONSES TO WILLIAMS’:
15 AND HIS SUCCESSORS, A
CORPORATION SOLE, a Nevada A) Motion to Dismiss
16 Corporation; SECOND CHANCE
CHRISTIAN EVANGELISTIC MHQISTRIES, B) Memorandum of Law
17 a California corporation; BISHOP OF FAITH
VISION NOBLE HOUSE AND HIS C) Request for Judicial Notice
18 SUCCESSORS, A CORPORATION SOLE, a
California corporation; JOSEPH L. D) Notice of Motion to Dismiss
19 WILLIAMS and MONICA C. CISNEROS, as
husband and wife; WILLIAM JOE LITTLE, E) Motion for Fees, Sanctions and
20 JR.; MICHAEL CAMBRA and GLORIA Contempt
( CAMBRA, as husband and wife; JOEL
21 DAVID and CINDY DAVID, as husband and REQUEST TO EXPEDITE RULING
wife; KEITH AARON VANN and TRISHA
ml 22 lVANN, as husband and wife, Assigned to the Honorable: ,
IIT li Mary H. Murguia i
g E; 23 Defendants/Counterclaimants. i
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g 24 Plaintiff, Estate of Joseph J. Studnek (“Studnek"), moves this Court for a one week extension I
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5 25 to tile the documents noted in the caption (above). This extension is requested for the reasons that
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P`; 26 Studnek’s counsel has been out sick with pneumonia, and counsel is also awaiting information for
Case 2:04-cv-00595-I\/IHI\/I Document 202 Filed O4/24/2007 Page 1 of 2 i
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1 the judgment, fee/cost affidavit and responses, including a transcript of Mr. Williams’
2 representations to the Alameda County, California Superior Court that he had, in fact, settled the two
3 { California casesl as part ofthe Settlement Agreement in this case, and, additional information from l i
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41 Studne1<’s California counsel (retained to defend against Mr. Williams’ California lawsuits).
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5 Plaintiff requests the Court to expedite it’s ruling for the reason that the Form of Judgment
6 and Affidavit of Attorneys Fees and Costs documents are due on Wednesday, April 25, 2007, and,
7 the Responses to Defendant Williams’ Motions are due on Thursday, April 26, 2007.
8 1 i
§ Dated this 24th day of April, 2007.
9 1
` JACKSON WHITE, P.C.
10
By: /s/ Bradley D. Weech
11 Bradley D. Weech
Attorneys for Plaintiff
12
ORIGINAL of the foregoing filed
13 with the Clerk of the United States
I District Court this 24m day of
141 April, 2007
15 COPY emailed to: _
Honorable Mary H. Murguria
16 401 W. Washington
Phoenix, AZ 85003
17
COPY of the foregoing
18 mailed this same date to:
19 Joseph L. Williams
15934 Hesperian Blvd? P.M.B. 311
20 San Lorenzo, California 94580
21 By: /s/ Yvonne Salatas
F:\STb\Studne1<, Joe\Globa1 Missious\P1dgs\Motion for Extension to Respondwpd
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E 23 I Mr. Williams has been labeled a vexatious litigant by the Alameda County, California Superior
Z 24 Court. According to the Estate’s California counsel, Mr. Williams is prohibited from filing anything in the _
O California courts without first obtaining permission from the presiding judge of the Alameda County Superior Court. §
Q To be labeled a vexatious litigant in California, a person must have filed and lost, or had dismissed, five cases in a
U li 25 , seven year period. At the Order to Show Cause hearing, Mr. Williams apparently argued that he had settled both of l
v-(Elf llhis cases against the Estate (and others) as part of the Settlement Agreement in this Arizona District Court case, and, l
26 {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 202

Filed 04/24/2007

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Case 2:04-cv-00595-MHM

Document 202

Filed 04/24/2007

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