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Robert T Mills (Arizona Bar #018853)

Sean A Woods (Arizona Bar #028930)

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

STIPULATED [SECOND] MOTION 

TO EXTEND DEADLINES

(Assigned to the Honorable Deborah M. 

Fine)

Undersigned counsel representing Plaintiffs Keith and Tammy Early, a married 

couple, individually and, as to Keith Early as Personal Representative and on behalf of 

Case 2:16-cv-00031-SPL-DMF Document 97 Filed 11/22/16 Page 1 of 3
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the estate of their deceased son Neil Raymond Early, and Lauren Maggi on behalf of 

and as Conservator of MME, a minor child, hereby submits this Stipulated [Second] 

Motion to Extend Deadlines on behalf of all the parties. 

The parties hereby jointly request under Fed. R. Civ. P. 6(b) that this Court 

extend the time of deadlines currently set [Doc. 55]. No party will be prejudiced by this 

Motion.

The parties jointly request that the Court extend the deadlines as follows:

1. Deadline for Plaintiffs’ Expert Disclosures April 31, 2017

2. Deadline for Plaintiffs to Provide Each and Every Date that 

Disclosed Experts are Available For Depositions.

May 15, 2017

3. Deadline for Defendants’ Expert Disclosures June 15, 2017

4. Deadline for Defendants to Provide Each and Every Date 

that Disclosed Experts are Available For Depositions

June 24, 2017

5. Deadline for Rebuttal Expert Disclosures July 31, 2017

6. Deadline for Plaintiffs’ Counsel to Complete All Expert 

Depositions 

August 30, 2017

7. Deadline for Defense Counsel to Complete All Expert 

Depositions

September 29, 2017

8. Deadline to Engage in Good Faith Settlement Talks October 27, 2017

9. Deadline for Completion of Fact Discovery November 15, 2017

10. Deadline for Dispositive Motions January 15, 2018

This Motion is made in good faith and not for the purpose of delay. Plaintiffs’ 

counsel and Defendants’ counsel therefore respectfully request that the Court grant this 

Stipulated Motion to Extend Deadlines.

DATED this 22nd day of November, 2016. 

Case 2:16-cv-00031-SPL-DMF Document 97 Filed 11/22/16 Page 2 of 3
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MILLS + WOODS LAW PLLC

By /s/ Sean A. Woods

Sean A. Woods

Robert T. Mills

5055 North 12th Street, Ste 101

Phoenix, Arizona 85014

Attorneys for Plaintiffs

CERTIFICATE OF SERVICE

I hereby certify that on this 22nd day of November, 2016, I electronically 

transmitted the foregoing document to the Clerk’s office using the Court’s CM/ECF 

Filing System and forwarded copies to the following parties via electronic mail:

SANDERS & PARKS, PC

Victoria 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/ Sean A. Woods

Case 2:16-cv-00031-SPL-DMF Document 97 Filed 11/22/16 Page 3 of 3