1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Wright Welker & Pauole PLC 

10429 South 51st Street, Suite 285 

Phoenix, Arizona 85044 

(480) 961-0040

Matthew W. Wright (014104) 

Christopher S. Welker (020060) 

WRIGHT WELKER & PAUOLE PLC 

10429 South 51st Street, Suite 285 

Phoenix, Arizona 85044 

(480) 961-0040 

mwright@wwpfirm.com

cwelker@wwpfirm.com

Attorneys for all Defendants, except John Shea and Christine Shea 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

Jenifer Anderson, a single woman; L.A., a 

single woman, 

 Plaintiffs, 

vs. 

Mesa Public School District, et. al., 

 Defendants. 

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

Maricopa County Superior Court 

Cause No. CV2017-011087 

NOTICE OF NON-PARTY 

AT FAULT 

In accordance with Ariz. Rev. Stat. §§ 12-2505 and 12-2506 and Ariz. R. Civ. P. 

26(b)(5), all defendants, except John and Christine Shea, identify the following nonparty at 

fault. Defendants reserve the right to supplement this notice as discovery proceeds. 

 1. Jenifer Anderson 

 c/o Sean A. Woods and Jordan Wolff 

 Mills Woods Law, PLLC 

 5055 N. 12th Street, Suite 101 

Phoenix, AZ 85014 

Case 2:18-cv-00692-DJH Document 27 Filed 09/19/18 Page 1 of 4
2 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Jenifer Anderson is plaintiff L.A.’s mother.

1

 Plaintiff L.A. apparently alleges in this 

action that employees of defendant Mesa Unified School District (aka Mesa Public Schools) 

should have discovered the nature of her alleged relationship with defendant John Shea and 

should have intervened to prevent the relationship. These defendants deny Plaintiff’s 

allegations and assert that Plaintiff has not stated a viable cause of action against them. 

However, upon information and belief, Jenifer Anderson observed her daughter with 

defendant John Shea, was aware that Mr. Shea provided rides to L.A. on occasion, and was 

aware of other encounters between L.A. and Mr. Shea. And according to Plaintiff L.A.’s 

theories and allegations against the school district employees, Jenifer Anderson should have 

intervened and prevented the alleged relationship between John Shea and L.A., and should 

have otherwise supervised L.A. to prevent L.A.’s alleged encounters with Mr. Shea. 

Accordingly, the jury must allocate fault for Plaintiff L.A.’s alleged injuries to Ms. 

Anderson. 

Discovery is ongoing and defendants reserve the right to designate additional 

nonparties at fault identified during discovery. 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

                                                           

1

 Jenifer Anderson was originally a plaintiff in this action. The parties, however, have filed 

a stipulation with the Court to dismiss her claims. Accordingly, defendants identify Jenifer 

Anderson as a non-party at fault in light of the imminent dismissal of her claims. 

Case 2:18-cv-00692-DJH Document 27 Filed 09/19/18 Page 2 of 4
3 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 DATED this 19th day of September, 2018. 

 WRIGHT WELKER & PAUOLE PLC 

 By s/Christopher S. Welker 

 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 

Case 2:18-cv-00692-DJH Document 27 Filed 09/19/18 Page 3 of 4
4 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

CERTIFICATE OF SERVICE

 I hereby certify that on September 19, 2018, I electronically transmitted the foregoing 

document to the Clerk’s Office using the CM/ECF System for filing and service to the 

following: 

Robert T. Mills 

Sean A. Woods 

Jordan C. Wolff 

Mills + Woods Law, PLLC 

5055 N. 12th Street, Suite 101 

Phoenix, AZ 85014 

Attorneys for Plaintiffs 

Ed Hendricks, Jr. 

Hendricks Murphy PLLC 

3101 N. Central Avenue, Suite 970 

Phoenix, AZ 85012 

Attorneys for Defendants John Shea and Christine Shea 

/s/Debi Handrahan 

6927-1321 

Case 2:18-cv-00692-DJH Document 27 Filed 09/19/18 Page 4 of 4