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SCOTTSDALE CITY ATTORNEY’S OFFICE

Stephanie Heizer (SBN 023261)

3939 North Drinkwater Boulevard

Scottsdale, Arizona 85251

Telephone (480) 312-2405

Facsimile (480) 312-2548

legal@scottsdaleaz.gov

Attorneys for City Defendants

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

The Satanic Temple and Michelle Shortt,

Plaintiffs,

vs.

City of Scottsdale, Arizona, by its City Council, 

consisting of the Mayor and council members, 

WJ Jim Layne, Suzanne Klapp, Virginia Korte, 

Kathy Littlefield, Guy Phillips, David Smith,

Defendants.

Case No. 18-cv-00621-DGC

DEFENDANTS’ MOTION FOR 

SUMMARY JUDGMENT

Defendant City of Scottsdale moves for summary judgment on Plaintiffs’ remaining

claims related to alleged Establishment Clause and Equal Protection violations. As discovery has 

borne out, and as agreed by counsel at telephonic conference on February 12, 2019, the material 

facts are not in dispute. The remaining legal questions are whether the City’s legislative prayer 

practice violates the Constitution. Case law plainly establishes that the City may open legislative

meetings with sectarian invocations and that the practice of having those invocations given by 

persons/groups with a substantial connection to the City does not run afoul of the Constitution. 

Accordingly, the City is entitled to summary judgment. This motion is supported by the following 

memorandum.

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MEMORANDUM

Statement of Facts

In a tradition dating back to the Continental Congress, the Scottsdale City Council, like 

many legislative bodies across the country, begins its regular meetings with an invocation. The 

invocations are scheduled by an administrative worker, the Management Assistant to the Mayor 

and City Council, Kelli Kuester. [Exhibit “1”, Deposition of Kelli Kuester (“Kuester Depo.”) at 

5:20-6:7] Ms. Kuester typically solicits volunteers to give invocations from a list of faith groups 

with a substantial connection to the City of Scottsdale, meaning they are generally located in or 

near Scottsdale or have a connection through Scottsdale’s residents, either as members or 

congregants. [Exhibit “1”, Kuester Depo. at 6:21-7:8; 28:19-29:9] The list includes non-JudeoChristian organizations, and over the past five years, members of the Muslim, Baha’i, and 

traditional Native American faiths, among others, have given invocations before the City 

Council. [Exhibit “3”, List of religious organizations; Exhibit “4”, Logs of invocation givers 2013 

to 2018; Exhibit “5”, City Council minutes from 2013 to 2018, pp. 11, 70, 80, 99].0F

1 The City has 

no religious test in scheduling invocations and does not exercise any control over their content.

[Exhibit “1”, Kuester Depo. at 27:11-18]

This case arises out of the Satanic Temple’s ongoing and well-publicized campaign to 

attempt to deliver invocations at local government meetings across the country. In February 2016, 

after the Satanic Temple’s request to pray in a Phoenix City Council meeting led Phoenix to

 

1 In regard to Exhibit 5, only the page of the Council minutes that memorializes the invocation is 

included; the remainder of the Minutes are not relevant to the issues presented here. Exhibit 5 is 

numbered consecutively for ease of reference.

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discontinue its invocations, a representative from the newly formed Tucson-based chapter of the 

Satanic Temple first contacted Scottsdale with a similar request. [Doc. 1, Complaint (“Compl.”)

¶¶ 21, 22; Exhibit “1”, Kuester Depo. at 11:2-10; Exhibit “6”, excerpt from the Satanic Temple 

article published 1/17/18]

Before being contacted by the Satanic Temple, Ms. Kuester had never been approached 

by a group requesting to give an invocation, [Exhibit “1”, Kuester Depo. at 9:15-10:11] and the 

City had no written policy regarding invocation givers. [Exhibit “2”, Deposition of Brian 

Biesemeyer (“Biesemeyer Depo”) at 9:2-12] Nevertheless, when contacted by the Satanic 

Temple, Ms. Kuester treated them as she would any other group and scheduled them to deliver 

the invocation for April 5. [Exhibit “1”, Kuester Depo. at 11:2-12:3; Doc. 1, Compl. ¶¶ 26-28]

Ms. Kuester later rescheduled the date to July 6 at Plaintiffs’ request after the person selected to 

give the invocation, Plaintiff Michelle Shortt, was unavailable on the earlier date. [Id.]

In May, the Acting City Manager, Brian Biesemeyer, learned that the Satanic Temple was 

described in media coverage as being Tucson-based and had no obvious substantial connection 

to the City of Scottsdale, unlike previous invocation givers who were “related to the community.”

[Exhibit “2”, Biesemeyer Depo. at 8:3-9:10; Exhibit “1”, Kuester Depo. at 20:12-20] As Acting 

City Manager, Mr. Biesemeyer was the chief administrative officer of the City with final say over 

administrative matters. [Exhibit “2”, Biesemeyer Depo. at 5:3-15] In that capacity, Mr. 

Biesemeyer decided the City would not deviate from its longstanding practice of having the 

invocation given only by representatives from institutions that have a substantial connection to 

the Scottsdale community. [Doc. 1, Compl. ¶ 32, Ex. 7] Mr. Biesemeyer made this decision

without any input from the City Council or Mayor. [Exhibit “2”, Biesemeyer Depo. at 14:24-

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15:3] Mr. Biesemeyer then asked Ms. Kuester to notify the Satanic Temple by email that it would 

not be giving the scheduled invocation. [Id. at 15:4-6] The Satanic Temple did not respond to 

Ms. Kuester’s email or offer the City any evidence of any connection to Scottsdale. [Exhibit “1”, 

Kuester Depo. at 30:5-13] 

Nearly two years later, in February 2018, the Satanic Temple filed this suit. [Doc. 1, 

Compl.] On the City’s motion, this Court dismissed the City Council members as parties and 

dismissed two of Plaintiffs’ claims, leaving only Plaintiffs’ Establishment Clause and Equal 

Protection claims against the City. [Doc. 17, 8-9-18 Minute Entry] The City now seeks Summary 

Judgment on these two claims.

Argument

I. The City’s legislative prayer practice does not violate the Establishment Clause.

The Establishment Clause claims outlined in the Complaint are based upon three primary 

allegations, namely that: 

(A) Scottsdale’s legislative invocations are mainly Christian in nature, making them

divisive and exclusionary. [Doc. 1, Compl. at ¶¶ 10, 18]

(B) Scottsdale’s legislative invocations advance particular religions while excluding the 

Satanic Temple. [Id. at ¶ 11]

(C) Scottsdale allows sectarian prayer at City Council meetings but denies the Satanic 

Temple the right to give an invocation. [Doc. 1, Compl. ¶ 43]

Plaintiffs’ pre-motion letter [Doc. 27], however, articulates their claims differently. The 

pre-motion letter claims: “it violates TST’s Establishment Clause rights for the City to invite only 

Judeo-Christian religious groups” to pray and “to prohibit non-Judeo-Christian Groups from 

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participating in the same ceremony.” [Id. at 2] These claimsfail because there is no Constitutional 

requirement that the City seek out and “invite” non-Judeo-Christian groups to give an invocation

at a legislative meeting. Moreover, even if there was such a requirement, the claim fails because 

the evidence produced during discovery (discussed in detail below) plainly establishes that the 

City has invited non-Judeo-Christian groups in the community to participate in the invocations, 

and that non-Judeo-Christians have given invocations. [See Exhibits “3”, “4” and “5”] 

Regardless of how Plaintiffs frame their Establishment Clause claims, the Supreme Court 

has repeatedly rejected arguments identical to those made by Plaintiffs on similar facts. See e.g. 

Town of Greece v. Galloway, 134 S. Ct. 1811 (2014); Marsh v. Chambers, 103 S. Ct. 3330 (1983). 

The City is entitled to summary judgment.

A. The City may allow sectarian legislative prayers before Council meetings.

Plaintiffs complain that the City’s invocations “are frequently Christian in nature, making 

express sectarian references, such as to Jesus Christ,” thereby making the prayers “divisive and 

exclusionary,” and leaving Plaintiffs feeling unwelcome at City Council meeting “in their own 

State”. [Doc. 1. at ¶¶ 10, 18] However, merely allowing an invocation or prayer at the beginning 

of a legislative meeting does not violate the Constitution. Town of Greece, 134 S. Ct. 1811. In 

Town of Greece, two residents alleged the town violated the Establishment Clause “by preferring 

Christians over other prayer givers and sponsoring sectarian prayers, such as those given ‘in 

Jesus’ name.’” Id. at 117. The residents who attended meetings found these prayers “offensive”, 

“intolerable” and “an affront to a ‘diverse community.’” Id. The Supreme Court rejected their

arguments, confirming existing case law that recognized legislative prayer is part of our nation’s 

tradition from its earliest days, and “while religious in nature, has long been understood as 

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compatible with the Establishment Clause.” Id. at 118; see also, Lund v. Rowan Cty., 863 F.3d 

268, 275 (4th Cir. 2017), cert. denied sub nom. Rowan Cty. v. Lund, 138 S. Ct. 2564 (2018)

(“Owing to its unique history and longstanding role in public life, legislative prayer occupies a 

field of Establishment Clause jurisprudence with its own set of boundaries and guidelines.”) 

(internal quotations and citations omitted).

In Town of Greece, the Court found no fault in the fact that the invocations given were 

almost exclusively Christian. The Court focused on the local community, finding nothing 

offensive about the Christian invocations, given that the majority of the town’s occupants were 

Christian. Id. at 1824. Nor did the Court find persuasive the residents’ arguments that overtly 

Christian language, i.e., words like “Jesus”, “Holy Spirit” or “Heavenly Father,” was offensive 

or intolerable to them. Id. at 823-824 (“Our tradition assumes that adult citizens, firm in their 

own beliefs, can tolerate and perhaps appreciate a ceremonial prayer delivered by a person of a 

different faith.”).

In this case, Plaintiffs’ first allegations are nearly identical to the complaints of the 

residents in Town of Greece, namely that: (1) the City Council permits sectarian invocations prior 

to the legislative sessions; and (2) many of the invocation givers are from Christian organizations 

and have referenced “Jesus Christ”. The City does not deny these particular allegations. [Doc 3, 

at ¶ 18]. However, as plainly demonstrated by the established case law outlined above, these 

allegations in and of themselves cannot form the basis for an Establishment Clause violation.

B. The City’s invocations do not advance any one faith or disparage any other faith.

Next, Plaintiff Shortt alleges that the City’s invocation practice violates her religious 

liberty by “advancing particular religions while excluding [the Satanic Temple].” [Doc. 1, 

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Compl. ¶ 11] Over time, an invocation can go too far and violate the Constitution if it exploits or 

seeks to advance a particular faith or belief over others, or by disparaging other faiths or beliefs. 

Town of Greece, 134 S. Ct. at 1823, quoting Marsh v. Chambers, 463 U.S. 783, 794-95 (1983).

Invocations that over time “denigrate nonbelievers or religious minorities, threaten damnation or 

preach conversion” may lead to a constitutional violation. Id. For this test, the Court appears to 

have focused the analysis on the content of the invocations, as opposed to identity of the religious 

person/group who is giving the invocation. Id. This is consistent with Marsh v. Chambers, in 

which the Supreme Court approved of a state legislature paying a Christian chaplain to open each 

legislative session for 16 years. 103 S. Ct. 3330, 3338 (“where there is no indication that the 

prayer opportunity has been exploited to proselytize or advance any one, or to disparage any 

other faith or belief... it is not for us to embark” on an evaluation of the content of the prayer). 

Here, there is no evidence to establish that the invocations have been used to advance any 

one faith or belief. The Council minutes (Exhibit “5”) and invocation log (Exhibit “4”) 

demonstrate that members from a wide variety of faiths have given invocations over the years. 

They include members of the Catholic Church, Baptists, Presbyterians, Lutherans, lay leaders of 

the Church of Jesus Christ of Latter-day Saints, police and fire department chaplains and Jewish

Rabbis, to name a few. [Exhibit “4”, Log of Invocation Givers] The City has admitted that some 

of these invocations have referenced “Jesus Christ.” [Doc. 7 ¶ 18] Those words alone are 

insufficient to establish that the City is seeking to advance one faith or belief. Town of Greece, 

134 S. Ct. at 1824. Moreover, even if the law required the City to specifically solicit non-JudeoChristian invocation givers from outside its community, which it does not, the documents show 

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that over the last several years, members of the Muslim community, a Baha’i practitioner, and a 

Native American Spiritual leader have all given invocations. [Exhibit “5”, pp. 11, 70, 80, 99]

The evidence, which is beyond dispute, is fatal to Plaintiffs’ claim that the City has

completely closed its prayer practice to non-Judeo-Christians, and fatal to the notion that the 

City’s prayer practice unconstitutionally endorses any one religion or belief system. Plaintiffs 

have not alleged, and there is no evidence in the record, that the invocations given before 

Scottsdale City Council meetings have over time denigrated, proselytized, or otherwise betrayed 

any impermissible government purpose.

C. The City may use reasonable practices to determine who can give an invocation 

at a legislative meeting.

The final part of Plaintiffs’ Establishment Clause claims involves allegations that the 

Satanic Temple was excluded from giving invocations based on the City’s practice that only 

members of groups with a substantial connection to the Scottsdale community are permitted to 

give the invocation. [Doc. 1, Compl. ¶¶ 32, 43] Because this practice is reasonable and facially 

neutral, courts have expressly upheld similarly worded policies against Establishment Clause 

challenges. 

For instance, in Rubin v. City of Lancaster, after a challenge to its prayer practice, the city 

adopted a formal policy of soliciting volunteers from “religious congregations with an established 

presence” in the city. 710 F.3d 1087, 1089 (9th Cir. 2013). The Ninth Circuit upheld the city’s 

policy, noting that it was facially neutral and did not affiliate the city with any sect, regardless of 

whether the policy resulted in a higher amount of Christian invocations due to the demographics 

of the volunteers. Id. at 1099-1100. Courts in other jurisdictions have reached similar conclusions 

regarding similar prayer practices. See also Simpson v. Chesterfield Cty. Bd. of Sup’rs, 404 F.3d 

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276, 279 (4th Cir. 2005) (approving policy under which Board of Supervisors invited religious 

leaders from congregations within Chesterfield County by taking addresses from phone book); 

Jones v. Hamilton Cty., 891 F. Supp. 2d 870, 887 (E.D. Tenn. 2012) (policy allowing invocations 

from religious congregations with an established presence in the local community), aff’d sub 

nom. Jones v. Hamilton Cty. Gov’t, 530 F. App’x 478 (6th Cir. 2013).

The City of Scottsdale’s practice, which requires a “substantial connection” to the 

community, is similar to the policies approved in these cases. [Exhibit “2”, Biesemeyer Depo. at 

8:3-9:10] Nothing in the practice discriminates against or favors any religion or belief system, 

and the only criteria (a substantial connection to the community) is one that can be filled without 

regard to any religious belief. See Rubin, 710 F.3d at 1099-1100; Larson v. Valente, 456 U.S. 

228, 244 (1982) (“The clearest command of the Establishment Clause is that one religious 

denomination cannot be officially preferred over another.”). The list of religious organizations

(Exhibit “3”) the City staff uses to solicit volunteers and the records of past invocation givers 

(Exhibit “4”) demonstrate that invocation givers have are drawn from groups with substantial 

community ties. [Exhibit “1”, Kuester Depo. at 6:21-7:8; 28:19-29:9] This longstanding practice, 

which dates back as far as the City’s records, predates the Satanic Temple’s existence and is 

consistent with the traditional purpose of the invocation, which is to lend gravity to the 

proceedings by inviting reflection on the community’s “shared ideals and common ends.” Town 

of Greece, 134 S. Ct. at 1823.

Plaintiffs are not members of the Scottdale community nor do they have any substantial 

connection to Scottsdale. Mr. Biesemeyer, Acting City Manager at the time Plaintiffs requested 

to give the invocation, learned that Plaintiffs were based out of Tucson and did not have a 

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connection to Scottsdale. Therefore, based upon the policy as he understood it, he made the 

decision not to allow the Satanic Temple’s invocation. [Exhibit “2”, Biesemeyer Depo. at 8:3-

9:10] The practice is not unconstitutional simply because Plaintiffs believe the City should have 

investigated more thoroughly its community ties or provided an appeals process, [see Doc. 27, 

Plaintiffs’ pre-motion letter at 2] particularly where the Satanic Temple never responded to the 

City’s denial or offered any proof of its ties to Scottsdale once it learned of the City’s rationale. 

[Exhibit “1”, Kuester Depo. at 30:5-13] 

Additionally, the City’s reliance on its previous practice rather than a written prayer policy 

does not make it unconstitutional. In Snyder v. Murray City Corp., the Tenth Circuit upheld the 

Murray City’s prayer practice, challenged on Establishment Clause grounds by a citizen opposed 

to public prayers. 159 F.3d 1227, 1228 (10th Cir. 1998). The plaintiff had initially sought 

publicity and media coverage by requesting to give “invocations” in Salt Lake City, in which the 

content would have called for an end to public prayers and mocked public officials. Id. at 1228-

12299. After Salt Lake City decided to end the prayer practice rather than allow this plaintiff to 

recite an invocation, he requested a chance to pray before the Murray City Council. Id. at 1229. 

At the time, Murray City had no formal written policy, but plaintiff was told that the city’s 

practice was to allow only invocations that solemnized, rather than denigrated the council’s work. 

Id. at 1229-1330. Murray City was permitted to exclude plaintiff from giving the invocation 

because his prayer did not meet the city’s criteria. Id. at 1235. The lack of a formal policy at the 

time did not affect the ultimate determination that the practice was constitutional:

Prior to the events at issue in this case, the city had never received an unsolicited 

request from a private individual to give a prayer at a council meeting. In light of 

this historical practice, Murray City had no written policy on its council prayers, 

and it had no formal guidelines for the content of its council prayers.

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Id. at 228. Likewise, Scottsdale has no record of ever receiving an unsolicited request to 

give the invocation before this, and had no formal written policy, but did have a longstanding 

practice that it consistently applied. But even if the City had enacted some new policy in response 

to these events, that would not make it unconstitutional. A newly enacted, but facially neutral 

and evenly applied policy requiring substantial community ties would not violate the 

Establishment Clause. See, e.g., Rubin, 710 F.3d at 1099-1100 (approving facially neutral prayer 

policy adopted after challenge to prayer practice); Bormuth v. County of Jackson, 870 F.3d 494, 

514 (6th Cir. 2017) (rejecting challenge to commissioner-led prayer practice that was exclusively 

Christian where county maintained a facially neutral, nondiscriminatory prayer policy).

Taken together, the facts in this case establish only that, while the Satanic Temple does 

not like Scottsdale’s practice, the practice is facially neutral and was applied consistently. The 

Establishment Clause does not require that Scottsdale end its prayer practice, dictate the religious 

content of invocations, or relinquish control over the Council microphone to anyone who 

demands it. The City is entitled to summary judgment.

D. Plaintiffs other allegations are irrelevant to the Establishment Clause analysis.

Plaintiffs’ other allegations—that the policy was unilaterally imposed by the Mayor, or 

was just a pretext to deny them a constitutional right—are directly contradicted by the facts and 

do not entitle Plaintiffs to any relief under the Establishment Clause. [See Doc. 1, Compl. ¶ 37,

Doc. 27, Plaintiffs’ pre-motion letter at 2] In their depositions, both the Management Assistant 

and the Acting City Manager testified that the Mayor and City Council had no input on whether 

a group could give an invocation and played no role in the City’s decision not to allow the Satanic 

Temple to give the invocation. [Exhibit “1”, Kuester Depo. at 21:23-22:1; Exhibit “2”, 

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Biesemeyer Depo. at 14:24-15:3] And while the Mayor and members of the Council publicly 

voiced their displeasure with the idea that the Satanic Temple could give an invocation in the 

press and in campaign materials, [Doc 1, Compl. Exs. 5, 8, 9] the Council members’ own emails, 

attached to the Complaint, also make clear that they didn’t have “a say on the issue one way or 

the other.” [Id., Ex.1]

II. Plaintiffs’ equal protection claim fails as a matter of law.

Plaintiffs’ second claim alleges that “it violates [the Satanic Temple’s] Equal Protection 

rights for the City to permit Judeo-Christian religious groups to participate in the ceremony, but 

to preclude [the Satanic Temple] from participating in the same ceremony.” [Doc. 27, Plaintiffs’ 

pre-motion letter at 2] This claim fails for two reasons: (1) equal protection analysis does not 

apply to individual claims of exclusion from the opportunity to give an invocation, and (2) 

Plaintiffs do not meet the essential element of an equal protection claim—that they were treated 

differently from those who were similarly situated. 

Legislative prayer cases, in which individuals challenge either the practice of permitting 

invocations at government meetings or claim a denial of the right to participate in the invocations, 

are governed only by the Establishment Clause, and not the Equal Protection Clause. See, e.g.,

Simpson, 404 F.3d at 288 (4th Cir. 2005) (affirming district court’s rejection of equal protection 

challenge brought by Wiccan who was denied opportunity to give invocation at county meeting 

on grounds that invocation, even when given by citizen, was government speech “subject only to 

the proscriptions of the Establishment Clause”) (citing Rosenberger v. Rector, 515 U.S. 819, 833 

(1995)); Fields v. Speaker of the Pa. House of Reps., 251 F. Supp. 3d 772, 792 (M.D. Pa. 2017) 

(“We join the unanimous consensus of courts before us to conclude that legislative prayer is 

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subject to review under the Establishment Clause alone.”); Coleman v. Hamilton Cty., 104 F. 

Supp. 3d 877, 891 (E.D. Tenn. 2015) (“[L]egislative prayer cases—such as this one—are subject 

to analysis only under the Establishment Clause of the First Amendment, and not under the Equal 

Protection Clause of the Fourteenth Amendment.”); Atheists of Fla., 779 F. Supp. 2d 133, 1342 

(same); cf. Barker v. Conroy, 282 F. Supp. 3d 346, 364 (D.D.C. 2017) (in case involving 

challenge to legislative prayer, plaintiff could not “salvage his failed First Amendment claim by 

cloaking it in a Fifth Amendment due process (equal protection component) mantle”). These 

cases make it clear that Plaintiffs’ Equal Protection claim fails as a matter of law.

However, even if equal protection applied, Plaintiffs are not entitled to any relief on the 

facts before this Court. “The equal protection clause of the fourteenth amendment guarantees like 

treatment to all persons who are similarly situated; it does not, however, deny a state the power 

to treat different classes of people in different ways as long as the classification is reasonable.” 

State v. Beckerman, 168 Ariz. 451, 453, 814 P.2d 1388, 1390 (App. 1991). Here, Plaintiffs were 

denied the opportunity to give an invocation because they are not similarly situated to the 

members of the community who have given legislative invocations. [See Exhibit “2”, Biesemeyer 

Depo. at 8:3-9:10] Plaintiffs do not allege that they are Scottsdale residents, that the Satanic 

Temple has a physical presence in or near Scottsdale, or that Plaintiffs are otherwise substantially 

connected to the community like the groups permitted by the City’s practice. See Engquist v. Or. 

Dep’t of Agric., 553 U.S. 591, 601 (2008) (Parties are similarly situated for equal protection 

analysis only when they are “arguably indistinguishable”). In fact, after being told that they were 

rejected from giving the invocation for lack of a substantial connection to Scottsdale, Plaintiffs 

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declined to even respond or offer any evidence of a connection to the City. [Exhibit “1”, Kuester 

Depo. at 30:5-13] 

Nor can Plaintiffs allege that the City’s “substantial connection” requirement is 

unreasonable. In the context of a local municipal meeting, restricting invocation givers to those 

with substantial connections to the municipality is a reasonable restriction to affect the purpose

of the invocation by drawing the community together through “shared ideals and common ends.”

Town of Greece, 134 S. Ct. at 1823. Local groups include those who serve the community and 

represent the citizens and patrons of Scottsdale. Those are the persons who have “shared ideals 

and common ends” as described by the case law, as it is those local groups who have a vested 

interest in the City and its governance that outside groups cannot match. 

Likewise, there is no evidence that other groups were not subject to the same facially 

neutral policy or that the City’s practice was inconsistently applied. Rather, the evidence shows

only that the City considered Plaintiffs’ request but decided to continue its practice of allowing

only groups that have a substantial connection to the community to give the invocation, as is the 

City’s right. 

Conclusion

Because the uncontested facts demonstrate that the City’s legislative prayer practice is 

consistent with established Establishment Clause law, and Plaintiffs’ can state no claim for an 

Equal Protection violation, the City is entitled to summary judgment on these claims.

/ / /

/ / /

/ / /

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DATED this 1st day of March, 2019.

SCOTTSDALE CITY ATTORNEY’S OFFICE

By: /s/ Stephanie Heizer

Stephanie Heizer, Assistant City Attorney

3939 North Drinkwater Boulevard

Scottsdale, Arizona 85251

Attorneys for City Defendants

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CERTIFICATE OF SERVICE

I hereby certify that on this 1st day of March, 2019, I electronically transmitted the attached 

document to the Clerk’s office using CM/ECF System for filing, and transmittal of a Notice of 

Electronic Filing to the following CM/ECF registrants:

Stuart P. de Haan

de Haan Law Firm, PLLC

100 N Stone Ave., Suite 512

Tucson AZ, 85701

Attorneys for Plaintiffs

By: /s/ Vickie Frost

An Employee of the Scottsdale City Attorney’s Office

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