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Mills + Woods Law, PLLC

5055 North 12th Street, Suite 101

Phoenix, AZ 85014-2555

480.999.4556

Robert T. Mills (Arizona Bar #018853)

Sean A. Woods (Arizona Bar #028930)

Jordan C. Wolff (Arizona Bar #034110)

MILLS + WOODS LAW, PLLC

5055 North 12th Street, Suite 101

Phoenix, Arizona 85014

Telephone 480.999.4556

docket@millsandwoods.com

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

LA,

Plaintiff,

vs.

Mesa Public School District, et. al.,

Defendants.

Case No.: 2:18-cv-00692-DJH

JOINT STIPULATED MOTION TO 

STAY DISCOVERY DEADLINES 

PENDING COMPLETION OF 

MEDIATION AND RESOLUTION 

OF MESA PUBLIC SCHOOL

DISTRICT’S MOTION FOR 

JUDGMENT ON THE PLEADINGS

(Assigned to the Hon. Diane J. Humetewa)

Pursuant to this Court’s Scheduling Order [Dkt. 25], the deadline for participating 

in good-faith settlement discussions is February 1, 2019. Counsel for the parties have 

conferred on the issue of settling this matter. All have agreed that mediation with Chris

Skelly is appropriate to attempt to resolve this case and are finalizing reservations for 

mediation on February 6, 2019. Also pending before the Court is Mesa Unified School 

District’s Motion for Partial Judgment on the Pleadings [Dkt. 29] which is now fully 

briefed [Dkts. 32 & 34].

The Court’s deadline for Plaintiff’s expert disclosures is January 11, 2019 and the 

deadline for fact discovery is February 1, 2019. In the interest of conserving the costs of 

written expert reports and limiting discovery for parties and claims that may be 

dismissed, the parties hereby jointly stipulate and respectfully request that the Court stay 

Case 2:18-cv-00692-DJH Document 38 Filed 01/11/19 Page 1 of 3
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Mills + Woods Law, PLLC

5055 North 12th Street, Suite 101

Phoenix, AZ 85014

480.999.4556

discovery deadlines until 30 days after the completion of mediation or resolution of the 

Motion for Partial Judgment on the Pleadings, whichever is later. 

This Stipulated Motion is not brought for any improper purpose such as delay. 

Rather, it is intended to permit the parties to attempt to resolve the case through 

mediation before incurring significant expenses associated with expert discovery and 

depositions. 

RESPECTFULLY SUBMITTED this 11th day of January 2019. 

MILLS + WOODS LAW, PLLC

By /s/ Sean A. Woods

Robert T. Mills

Sean A. Woods

Jordan C. Wolff

5055 North 12th Street, Suite 101

Phoenix, AZ 85014

Attorneys for Plaintiff

WRIGHT WELKER & PAUOLE PLC

By /s/ Christopher S. Welker (with permission)

Matthew W. Wright

Christopher S. Welker

10429 South 51st Street, Suite 285

Phoenix, Arizona 85044

Attorneys for all Defendants, except John Shea

and Christine Shea

By /s/ Ed Hendricks, Jr. (with permission)

Ed Hendricks, Jr.

3101 North Central Avenue, Suite 970

Phoenix, Arizona 85012

Attorneys for all Defendants John Shea and 

Christine Shea

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Mills + Woods Law, PLLC

5055 North 12th Street, Suite 101

Phoenix, AZ 85014

480.999.4556

CERTIFICATE OF SERVICE

I hereby certify that on January 11, 2019, I electronically transmitted the foregoing 

document to the Clerk’s Office using the ECF System for filing and transmittal of a 

Notice of Electronic Filing to the following ECF registrants:

Matthew W. Wright

mwright@wwpfirm.com

Christopher S. Welker

cwelker@wwpfirm.com

Wright Welker & Pauole PLC

10429 South 51st Street, Suite 285

Phoenix, Arizona 85044

(480) 961-0040

Attorneys for All Defendants, except John Shea and Christine Shea

Ed Hendricks, Jr.

ed@hendricksmurphy.com

3101 North Central Avenue, Suite 970

Phoenix, Arizona 85012

(602) 604-2132

Attorneys for Defendants John and Christine Shea

/s/ Elisabeth A. Small

Case 2:18-cv-00692-DJH Document 38 Filed 01/11/19 Page 3 of 3