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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 Plaintiffs

IN THE UNITED STATES DISTRICT COURT 

IN AND 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

RULE 26(f) JOINT CASE 

MANAGEMENT REPORT

(Assigned to the Hon. Diane J. Humetewa)

Plaintiffs Jenifer Anderson and L.A. and Defendants Mesa Public School District, et. 

al., by and through undersigned counsel, hereby submit their Joint Case Management Report: 

1. List of All Parties

a. Plaintiffs

Jenifer Anderson and L.A.

b. Defendants

Mesa Public Schools District, Mesa Public Schools Governing Board, Elaine Miner, 

John Doe Miner, Ben Smith, John Doe Smith, Kiana Sears, John Doe Sears, Steven Peterson, 

Jane Doe Peterson, Jenny Richardson, John Doe Richardson, Greg Schulz, Jane Doe Schulz, 

Shantele Peterson, John Doe Peterson, Peter Jonovich, Jane Doe Jonovich, Holly Williams, 

John Doe Williams, Peter Lesar, Jane Doe Lesar, Brennan O’Connor, Jane Doe O’Connor, 

Cathy Underwood, John Doe Underwood, John Shea, Christine Shea, Sara Nixon, John Doe 

Nixon, Angelo Paffumi, Jane Doe Paffumi, Tom Brennan, and Jane Doe Brennan.

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2. A short statement of the nature of the case (3 pages or less), including a

description of each claim and each affirmative defense, and identifying the 

factual and legal issues genuinely in dispute.

a. Plaintiffs’ short statement of the nature of the case

L.A. began attending Skyline High School (“Skyline”), which is a part of the Mesa 

Public Schools District (“the District”), in 2013. She immediately joined the Track and Field 

team and earned a varsity letter. John Shea (“Shea”) was a coach for the girls’ Track and Field 

team and was involved in L.A.’s coaching and training. Shea was also a teacher and football 

coach. Prior to Shea being hired, Skyline’s football team was a perennial loser, but became 

successful after his hiring. One of the District’s board members, Steven Peterson (“Peterson”), 

was told about concerns regarding L.A. and Shea during L.A.’s sophomore year. At some 

point, Cathy Underwood (“Underwood”) told Peterson that girls were not wearing shirts over 

their sports bras during track practice, which was against school policy. Underwood also told 

Peterson that she had approached Shea about this matter, but instead of being supported she 

was belittled and made fun of by Shea and the other male coaches. In violation of the District’s 

harassment and anti-bullying policy, L.A. was not protected and the behavior was not reported.

Shea knew that he faced no repercussions based on his inappropriate behavior towards 

L.A. during her sophomore year and began showing increased interest in L.A. during her junior 

year. Shea began picking L.A. up from her house in the morning, giving her rides home from 

school, bringing her food at school, and attending all of her extracurricular activities. This was 

all part of Shea’s plan to get past L.A.’s defenses and prey on her still-developing mind and 

body. Shea also began texting L.A. several times on a daily basis. He took her off-campus 

during school hours for rides in his car, regardless of the fact that Skyline has a closed-campus 

policy. Shea began having L.A. babysit his daughter and also took her to his son’s baseball 

games. He encouraged and allowed L.A. to violate school policy by having her workout in a 

sports bra with no shirt. Shea also began touching L.A. during her workouts. 

Two Skyline employees, Underwood and Nixon, became aware and were alarmed 

about Shea’s behavior. They reported Shea’s immoral behavior to Schulz, Skyline’s Athletic 

Director and Holly Williams (“Williams”). Instead of addressing their concerns, Williams 

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fired Nixon immediately. Nixon was eventually informed that Williams did not have the 

authority to fire her, so she was reinstated, but was asked not to come back as a track coach 

because of her friction with Shea. Schulz did not make any attempt to investigate Underwood 

and Nixon’s concerns about Shea. Instead, Schulz decided to protect Shea, the prized football 

coach, and ignored all complaints against him. Schulz also threatened Underwood and Nixon 

with termination and in turn, they decided to put their careers ahead of L.A.’s well-being and 

failed to take their concerns to someone higher up in the District.

Shea, emboldened by the steadfast support Schulz, increased his seduction efforts on 

L.A., who believed Shea was helping her get into college and saw him as a father figure. Shea 

knew L.A. lacked a father figure in her life and seized upon this fact to control her. Shea told 

L.A. he was the only one who could get her into college with an athletic scholarship. She also 

began telling L.A. via text message that her loved her. He also solicited photographs of L.A. 

in her underwear and even convinced her to send him a picture of herself with an exposed 

breast. During the summer between L.A.’s junior and senior years, Shea attempted to meet up 

with L.A. on multiple occasions, outside of school events. Shea sent L.A. a continued barrage 

of text messages and persuaded L.A. to be alone with him, even holding her hand during car 

rides. During this summer, Shea vacationed to Mexico he continued to text L.A. telling her 

that he missed her, in an attempt to keep control over her.

During L.A.’s senior year, prior to her eighteenth birthday, after a night of indulgence 

in alcohol, Shea texted L.A. telling her he would not go home without seeing her because he 

needed her. L.A. snuck out of her home and met Shea in a park, where he put his hands on her 

and caressed her inner thigh. L.A. was nervous and scared by the escalation of physicality, but 

felt she had to allow it to occur or her potential for an athletic scholarship would be 

jeopardized. Shea continued to pursue L.A. at school and seemingly counting down the 

minutes until her eighteenth birthday, he kissed her in November 2016. Peterson received a 

text message from underwood in August or September 2016 with a picture of L.A. in a sports 

bra and Shea with his hands on her body. Peterson also received several reports of L.A. leaving 

with Shea in his truck after practice on multiple occasions. Peterson also claims that coaches 

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and staff approached her with their concerns about Shea because they were fearful of 

retaliation.

Instead of reporting the evidence of sexual harassment, the information was kept under 

wraps for months. On January 27, 2017, Peterson visited a classroom where she knew Shea 

and L.A. would be. Peterson said she observed Shea holding L.A. near the breast area while 

she was wearing only a sports bra. Peterson took a photograph of the scene and brought it and 

all the other information to Tom Brennan (“Brennan”), Skyline’s principal. On the same day, 

Underwood reported seeing L.A. and Shea alone in the classroom. Several staff members at 

Skyline observed and knew of the inappropriate behavior displayed by Shea towards L.A., but 

were afraid to come forward for fear of retaliation. The head football coach, Angelo Paffumi 

(“Paffumi”) admitted to police that he knew of complaints regarding Shea, but stated that he 

had no concerns about the relationship Shea had with L.A. 

After forensically imaging L.A.’s cell phone, several images were not recoverable, 

including images sent to Shea’s cell phone. Mesa Police were able to view over five-thousand 

(5000) messages that were deleted by L.A. to Shea. They also saw deleted facetiming and 

numerous phone calls. Shea sent several inappropriate text messages to L.A., for example: “I 

can’t help it. Your [sic] just so dam [sic] Hot!! [sic]” and “Ok beautiful I gotta get to bed! I 

love you more than words can say!!” Mesa Police also forensically imaged Shea’s phone and 

recovered over 2000 deleted chats, many of which were sexual in nature.

After the news broke and Shea was placed on administrative leave, L.A. was subjected 

to endless harassment, gossip, and bullying by fellow students and Skyline employees. Skyline 

put athletic pursuits of student safety, but it is also important to remember that the District put 

their bottom line ahead of L.A. and other students’ safety and health. The District’s General 

Counsel, Tom Pickrell (“Pickrell”), stated that the District concluded that Mr. Shea engaged 

in unprofessional and immoral conduct, but that the District wanted to “terminate the 

employment relationship by the most efficient and responsible means possible.” Instead of 

having to continue to pay Shea during the dismissal process and employ an independent 

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hearing officer and a second legal counsel, the District chose to give Shea the option to simply 

resign rather than be terminated.

The claims Plaintiffs seek against Defendants are as follows: Count I: Violation of 

Plaintiffs’ Civil Rights Under the Fourteenth Amendment and 42 U.S.C. § 1983 (Against the 

District); Count II: Violation of Plaintiffs’ Civil Rights Under the Fourteenth Amendment and 

U.S.C. § 1983 (Against All Non-Governmental Agency Defendants); Count III: Civil Rights 

Violations—Title IX 20 U.S.C. § 1681 et seq.; Count IV: Intentional Infliction of Emotional 

Distress; Count V: Negligent Failure to Protect; Count VI: Negligence / Gross Negligence; 

Count VII: Negligence Per Se (Against Shea); Count VIII: Negligence Per Se; Count IX: 

Negligent Supervision of Students; Count X: Negligent Hiring, Supervision, and Training 

(Against the District, Brennan, Jonovich, Paffumi, Governing Board, and Members of the 

Governing Board); Count XI: Assault and Battery (Against Shea); Count XII: Aiding and 

Abetting Assault and Battery; Count XII: Civil Conspiracy; and Count XIV: Civil Rights 

Violations – 42 U.S.C. § 1985.

b. Defendants’ short statement of the nature of the case

The Shea Defendants deny any improper physical contact between Mr. Shea and L.A. 

The remaining defendants (the “District Defendants”) deny that they ever knew, or 

should have known, of any alleged inappropriate relationship or physical contact between 

defendant John Shea and plaintiff L.A. The District Defendants further deny that they ever 

acted unreasonably toward L.A., or in their dealings with John Shea.

The Shea Defendants pled the following affirmative defenses: failure to comply with 

the requirements of A.R.S. § 12-821.01; failure to timely file under A.R.S. § 12-821; A.R.S. § 

12-820.04; failure to state a claim under which relief may be granted for a variety of reasons, 

including but not limited to: (i) the Complaint does not comply with Rule 8(a) and is thus 

subject to a motion for more definite statement under Rule 12(e), and (ii) the Complaint is 

subject to a motion to strike under Rule 12(f)(1) and 12(f)(2); standing; absolute immunity; 

and qualified immunity. 

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The District Defendants pled the following affirmative defenses: failure to comply with 

the requirements of A.R.S. § 12-821.01; failure to timely file under A.R.S. § 12-821; immunity 

against punitive damages under A.R.S. § 12-820.04; immunity pursuant to A.R.S. § 12-

820.05(B); failure to state a claim under which relief may be granted for a variety of reasons, 

including but not limited to: (i) the Complaint does not comply with Rule 8(a) and is thus 

subject to a motion for more definite statement under Rule 12(e), (ii) the Complaint is subject 

to a motion to strike under Rule 12(f)(1) and 12(f)(2); (iii) the Complaint does not allege that 

a formal policy or custom of the District violated Plaintiffs’ constitutional rights; lack of 

standing; failure to properly serve the summons and complaint; absolute immunity; and 

qualified immunity. 

Defendants cannot identify the legal and factual issues other than those reflected below 

because the Complaint is conclusory and argumentative. Defendants have attempted to state 

generally what they perceive will be factual issues:

(i) Whether Shea sexually abused L.A. Plaintiffs do not allege any specifics on this 

issue. In any event, the Shea Defendants deny that Shea sexually abused L.A.

(ii) Whether Shea could have aided and abetted his alleged assault and battery. 

Plaintiffs allege that he did, and Defendants believe the law is contrary to Plaintiffs’ position.

(iii) Whether Defendants did anything that rises to the level required by the asserted 

Counts.

(iv) What happened when. The Complaint does not specify, and the Shea 

Defendants cannot tell, when something Shea is alleged to have done took place or what was 

allegedly done wrong.

(v) Whether Jenifer Anderson has standing, and which claims are asserted by her 

and which by L.A.

(vi) Whether it is permissible, absent an order of the Court, for L.A. to appear by her 

initials even though she reached the age of majority before the Complaint was filed. 

(vii) What the District Defendants knew, or had reason to know, about the 

relationship between L.A. and Mr. Shea.

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3. Jurisdictional Basis for the Case

This Court has Federal Question jurisdiction under 28 U.S.C. § 1331. Plaintiff has 

brought multiple claims against the Defendants, including civil rights violations under 42 

U.S.C. 1983 and Title IX 20 U.S.C. § 1681, et seq.

4. Parties Which Have Not Been Served; Explanation of Why they Have not 

Been Served; Any Parties Which Have Been Served but Have Not Answered 

or Otherwise Appeared (including fictitious parties)

Plaintiffs contend that all parties have been served and have answered and/or appeared.

(Docs. 14, 15). The Shea Defendants have been served. The District Defendants contend that 

they have not been properly served.

5. Statement of Whether Any Party Expects to Add Additional Parties or 

Otherwise Amend Pleadings

At this time, the parties have no plans to add additional parties to the case. However, as 

investigation continues, the parties may join additional parties as the evidence warrants. The 

parties may add claims but will not know if sufficient facts exist to add those claims until 

discovery is substantially complete. 

In addition, all Defendants claim as affirmative defenses that the Complaint is subject 

to a Rule 12(f) motion to strike and a Rule 12(e) motion for a more definite statement. Many, 

many paragraphs in the Complaint contain scandalous material, and those paragraphs should 

be stricken. Plaintiffs’ counsel have refused to cure these defects voluntarily. At this time, 

Defendants identify the following as the paragraphs of the Complaint subject to a Rule 12(f) 

motion to strike: 52, 53, 57, 58, 60, 64, 65, 66, 74 (“Much like Joe Paterno protecting Jerry 

Sandusky, Schulz directly enabled the actions of Shea”), 75, 78, 79, 86, 89, 91, 92, 94, 97, 

101, 106, 108, 110, 113, 125, 127, 131, 132, 134, 142, 143, 144, 145, 148, 159, 163, 165, 174, 

175, 176, 177, 188, 195, 198, 205, 207, 213, 219, 223, 228, 239, 243, 247, 250, 255, 259, 266, 

273, 278, 281.

6. A List of Contemplated Motions and a Statement of the Issues to Be Decided 

by These Motions

At this stage, it is difficult to ascertain what dispositive motions will be filed. Plaintiff 

anticipates potentially filing a Motion for Partial Summary Judgment on liability after more 

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discovery has been achieved. Defendants intend to file a Rule 12(f) and a Rule 12(e) motion. 

Counsel for Shea requested that counsel for Plaintiffs voluntarily cure the defects in the 

Complaint, but counsel for Plaintiffs refused.

The District Defendants intend to file a motion to dismiss Plaintiff Jenifer Anderson’s 

state–law claims on the grounds that she failed to timely serve a valid notice of claim pursuant 

to A.R.S. § 12-821.01, and failed to timely file her claims in this action. The District 

Defendants also intend to file a motion to dismiss Plaintiffs’ claim against them for punitive 

damages. The District Defendants’ counsel requested that Plaintiffs voluntarily dismiss their 

claim for punitive damages, but Plaintiffs refused. Finally, all defendants intend to file 

motions for summary judgment on Plaintiffs’ claims following the completion of some initial 

discovery.

Plaintiffs note that the Shea Defendants already filed an Answer to Plaintiffs’ 

Complaint. (Doc. 14). Plaintiff’s position is that a motion under Fed. R. Civ. P. 12(e) and (f) 

is not proper. The Shea Defendants disagree. Under the pilot program, the Shea Defendants 

were required to file an answer regardless of any Rule 12 motions that they anticipated filing.

Additionally, from Plaintiffs’ perspective, on May 5, 2017, District Defendants’

previous counsel acknowledged receipt of Plaintiffs’ Notice of Claim and stated he was 

authorized to accept service on behalf of the individual District Defendants. It is Plaintiffs’

position that Plaintiffs’ brought claims against all District Defendants under civil rights 

violations under 42 U.S.C. § 1983, 1985. Plaintiffs contend that is well established that 

punitive damages are an available remedy against all individual defendants. Smith v. Wade, 

461 U.S. 30, 33, 103 S. Ct. 1625, 1628, 75 L. Ed. 2d 632 (1983); Braillard v. Maricopa County, 

224 Ariz. 481, 495, ¶ 43, 232 P.3d 1263, 1277 (App. 2010). Therefore, Plaintiffs assert that 

any motion under Fed. R. Civ. P. 12(e) and (f) or a motion to dismiss punitive damages would 

be futile and directly conflict with Fed. R. Civ. P. 1.

7. Whether the Parties Will Consent to the Assignment of this Action to a 

United States Magistrate Judge in Accordance with 28 U.S.C. § 636(c)

The parties do not all consent to the assignment of this action to a Magistrate Judge.

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8. The Status of Related Cases Pending Before Other Courts or Other Judges 

of this Court

N/A

9. A Statement of When the Parties Exchanged or Will Exchange Fed. R. Civ. 

P. 26(a) Initial Disclosures

The parties understand that the MIDP Program supersedes the requirements of Rule 

26(a). See General Order 17-08, at 1. The parties will serve their responses to the court-ordered 

discovery requests on May 24, 2018.

10. Any Issues Relating to Disclosure or Discovery of Electronically Stored 

Information, Including the Form or Forms in Which it Will be Produced

The parties anticipate that they will work together to properly tailor the scope of the 

electronically stored information (“ESI”) sought by either party and will agree on the form(s) 

in which it will be produced. The parties anticipate that emails will be produced in native form 

or, otherwise, in PDF form with native form available upon request.

11. Any Issues Relating to Claims of Privilege or Work Product

The parties anticipate that they will be able to work through any issues that may arise 

without the involvement of the Court. The parties will inform the Court if they cannot come 

to an agreement. 

The parties will work together to determine the need and propriety of a Stipulated 

Protective Order in this case. Should the parties agree that a Stipulated Protective Order is 

necessary to protect a party or person from disclosure of proprietary and confidential 

information, or from undue burden or expense, they will submit a proposed Stipulated 

Protective Order for the Court’s good cause review.

12. A Discussion of the Parties’ Compliance to Date with the MIDP; Whether 

Any Issues Have Arisen Under the MIDP; If Issues Have Arisen, A 

Description of Those Issues

The parties agree to comply with the MIDP. 

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13. Necessary Discovery

a. The extent, nature, and location of discovery anticipated by the 

parties

Plaintiffs’ counsel plans to conduct discovery under Fed R. Civ. P. 30-34, and 36. 

Plaintiffs expect initial discovery of ESI, including but limited to record conversations, emails, 

written correspondence, Defendant School District’s policies and procedures, Defendants’ 

employment records, and documentation of any investigation the Defendant School District 

conducted regarding the facts alleged in the Complaint. Plaintiffs’ counsel plans to conducts 

additional discovery of non-parties under Fed R. Civ. P. 45.

Defendants’ counsel anticipate an initial wave of written discovery to the parties, 

including requests for ESI relating, by way of examples only, to social media, text, emails, and 

direct messages on social media platforms. That first wave will be followed by a second wave 

of written discovery on non-parties, depending on what is discovered in the first wave. 

Defendants’ counsel then anticipate depositions of the Plaintiffs and third parties.

b. The scope of discovery and whether discovery should be 

conducted in phases or should be limited to focus on particular 

issues

The parties do not see a need for phased discovery or discovery limited in focus on 

particular issues.

c. Suggested changes, if any, to the discovery limitations imposed by 

the Fed. R. Civ. P.

The parties do not believe changes to the discovery limitations imposed by the Rules 

will be necessary.

d. The number of hours permitted for each deposition, unless 

modified by agreement of the parties

The parties believe that the 7 hours provided in the rule will be adequate. If the 

circumstances require that more time be allotted, counsel will first seek to stipulate with all 

counsel on an extended amount of time. Only if such agreement cannot be reached will 

counsel seek the assistance of the Court.

14. When the Parties Served Their MIDP Responses

May 24, 2018

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15. Proposed Specific Dates

a. Deadline for completion of fact discovery:

February 1, 2019

b. Dates for complete expert disclosures under Fed. R. Civ. P.

26(a)(2)(A)-(E):

The parties propose January 11, 2019 for Plaintiffs’ expert disclosures; March 8, 2019

for Defendants’ expert disclosures; and April 12, 2019 for Plaintiffs’ rebuttal expert 

disclosures.

c. Deadline for completion of all expert depositions:

June 28, 2019

d. Deadline for filing dispositive motions:

August 2, 2019

e. Date by which the parties shall have engaged in face-to-face good

faith settlement talks:

February 1, 2019

16. Whether A Jury Trial Has Been Requested and Whether the Request for A

Jury Trial Is Contested. If the Request for A Jury Trial Is Contested, The

Reasons Why

A jury trial has been requested.

17. The Estimated Length of Trial

Two weeks.

18. The Prospects for Settlement, Including Any Request to Have A Settlement

Conference Before Another United States District Judge or A Magistrate

Judge, Or Any Other Request of The Court for Assistance In Settlement

Efforts

The parties are open-minded with respect to settlement discussions. Also, the parties 

have determined that they may seek mediation before a private mediator at an appropriate time.

RESPECTFULLY SUBMITTED this 23rd day of May 2018

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MILLS + WOODS LAW, PLLC

By /s/ Sean A. Woods

Sean A. Woods

Robert T. Mills

Jordan C. Wolff

5055 N 12th Street, Suite 101

Phoenix, AZ 85014

Attorneys for Plaintiffs

HENDRICKS MURPHY, PLLC 

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

Ed Hendricks, Jr. 

David W. Cowles 

3101 North Central Avenue, Suite 970 

Phoenix, Arizona 85012 

Attorneys for Defendants John Shea and 

Christine Shea

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

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CERTIFICATE OF SERVICE 

I hereby certify that on May 23, 2018, 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 

David W. Cowles 

david@hendricksmurphy.com 

HENDRICKS MURPHY, PLLC 

3101 North Central Avenue, Suite 970 

Phoenix, Arizona 85012 

(602) 604-2190

Attorneys for Defendants 

John Shea and Christine Shea

/s/ Jordan C. Wolff

Case 2:18-cv-00692-DJH Document 18 Filed 05/23/18 Page 13 of 13