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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

Keith and Tammy Early, a married couple, 

individually and, as to Keith Early as 

Personal Representative and on behalf of 

the estate of their deceased son Neil 

Raymond Early; Lauren Maggi on behalf of 

and as Conservator of MME, a minor child, 

Plaintiffs,

vs.

The State of Arizona, a governmental 

entity; Odie Washington, Senior Vice 

President of Corrections and Jane Doe 

Washington, his wife; Management and 

Training Corporation, a Utah Corporation; 

Correctional Healthcare Companies, a 

Colorado Corporation; Physicians Network 

Association, Inc., a Texas Corporation; 

Melissa and John Doe Johnson, husband 

and wife; Arshad and Jane Doe Tariq, 

husband and wife; Tiffany and John Doe 

Thompson, husband and wife; Toan Lai and 

Jane Doe Lai, husband and wife; John and 

Jane Doe Albanese, husband and wife; 

Giovanni and Jane Doe Gonzalez, husband 

and wife; and John and Jane Does 1-40,

Defendants.

Case No. 2:16-cv-00031-SPL-DMF 

PLAINTIFFS’ NOTICE OF 

VIDEOTAPED DEPOSITION OF 

TOAN LAI

(Assigned to the Honorable Deborah M. 

Fine) 

Case 2:16-cv-00031-SPL-DMF Document 212 Filed 09/19/18 Page 1 of 3
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PLEASE TAKE NOTICE that, pursuant to Rule 30, Federal Rules of Civil Procedure,

testimony will be taken upon oral examination of the person whose name, or general 

description sufficient to identify the person, and address are stated below, at the time and place 

stated below, before an officer authorized by law to administer oaths.

PERSON TO BE EXAMINED: Toan Lai

DATE OF DEPOSITION: September 28, 2018

TIME OF DEPOSITION: 10:00 a.m.

PLACE OF DEPOSITION: Mills + Woods Law, PLLC

5055 North 12th Street

Suite 101

Phoenix, Arizona 85014

COURT REPORTER: Coash & Coash

METHOD OF RECORDING: Video Recorded with a Court Reporter

VIDEO RECORDER: Coash & Coash

PLACEMENT OF CAMERAS: At the end of the table directly facing 

Deponent.

RESPECTFULLY SUBMITTED this 19th day of September 2018.

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 Plaintiffs

Case 2:16-cv-00031-SPL-DMF Document 212 Filed 09/19/18 Page 2 of 3
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CERTIFICATE OF SERVICE

I hereby certify that on September 19, 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:

SANDERS & PARKS, PC

Victoria M. Vaughn

Garrick L. Gallagher

3030 North 3rd Street, Ste 1300

Phoenix, Arizona 85012

Attorneys for Defendants State of Arizona, Odie 

Washington, Management &Training Corporation, John Albanese,

and Giovanni Gonzalez

LEWIS BRISBOIS BISGAARD & SMITH LLP

James K. Kloss

Venus Booth

2929 North Central Ave, Ste 1700

Phoenix Arizona 85012

Attorneys for Defendants Correctional Healthcare

Companies, Inc., Physicians Network Association, Inc., Arshad

Tariq, Toan Lai, and Tiffany Thompson

DICKINSON WRIGHT LLC

Denise Troy

1850 North Central Ave, Ste 1400

Phoenix, Arizona 85004

Attorney for Defendant Melissa Johnson

/s/ Jordan C. Wolff 

Case 2:16-cv-00031-SPL-DMF Document 212 Filed 09/19/18 Page 3 of 3