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4845-9982-4796.1

Mills + Woods Law, PLLC

5055 North 12th Street, Suite 101

Phoenix, AZ 85014-2555

480.999.4556

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

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Keith and Tammy Early, et al, 

Plaintiffs,

vs.

The State of Arizona, et al,

Defendants.

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

JOINT STIPULATED MOTION TO 

EXTEND THE DISMISSAL DATE

(Assigned to the Honorable Steven P. 

Logan)

Plaintiffs and Defendants, by and through undersigned counsel, submit this Joint 

Stipulated Motion to Extend the Dismissal Date. 

On May 1, 2019, this Court issued an Order, which stated “... that this case will be 

dismissed with prejudice on July 9, 2019 unless a stipulation to dismiss or request for 

reinstatement on the Court’s trial calendar is filed prior to the dismissal date.” (Doc. 272) 

(emphasis in original). 

Heretofore, Defendants Tiffany Thompson, Toan Lai, Tariq Aziz and Melissa 

Johnson were voluntarily dismissed from this litigation with prejudice. The remaining 

parties have agreed to settle the remaining claims in this matter; however, one of the 

plaintiffs is a minor and probate is required to approve to the settlement. As of July 9, 

2019, the final details have not been completed and probate filings have not been made. 

The Plaintiffs believe that the details of the final settlement agreement will be complete 

in the next seven (7) days and that the probate court filings will then be made. Therefore, 

the Plaintiffs and Defendants Correctional Healthcare Companies, Inc. and Physician’s 

Case 2:16-cv-00031-SPL-DMF Document 273 Filed 07/09/19 Page 1 of 3
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4845-9982-4796.1 2

Mills + Woods Law, PLLC

5055 North 12th Street, Suite 101

Phoenix, AZ 85014

480.999.4556

Network Association, Inc., by and through their undersigned counsel, hereby request that 

the Court maintain this matter on its inactive calendar for an additional sixty (60) days to 

either submit a stipulation to dismiss this matter in its entirety as to all remaining claims 

and Defendants, request for additional time for submission of a stipulation to dismiss this 

matter in its entirety, or request for reinstatement on the Court’s trial calendar in the 

unlikely event the Arizona probate court rejects the settlement arrived at between the 

parties. 

RESPECTFULLY SUBMITTED this 9th day of July 2019. 

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

LEWIS BRISBOIS BISGAARD & SMITH LLP

By /s/ Michael B. Smith (with permission)

Kevin C. Nicholas

Michael B. Smith

Bruce C. Smith

2929 North Central Ave, Ste 1700

Phoenix Arizona 85012

Attorneys for Defendants Correctional 

Healthcare Companies, Inc. and Physicians 

Network Association, Inc.

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4845-9982-4796.1 3

Mills + Woods Law, PLLC

5055 North 12th Street, Suite 101

Phoenix, AZ 85014

480.999.4556

CERTIFICATE OF SERVICE

I hereby certify that on July 9, 2019, 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:

LEWIS BRISBOIS BISGAARD & SMITH LLP

Kevin C. Nicholas

Michael B. Smith

Bruce C. Smith

2929 North Central Ave, Ste 1700

Phoenix Arizona 85012

Attorneys for Defendants Correctional Healthcare

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

/s/ Jordan C. Wolff

Case 2:16-cv-00031-SPL-DMF Document 273 Filed 07/09/19 Page 3 of 3