Clerk of the Superior Court

*** Electronically Filed ***

M. De La Cruz, Deputy

10/8/2025 5:20:27 PM

Filing ID 20724845

3075 West Ray Road, Suite 110

Chandler, Arizona 85226

(480) 739-1200

Robert Grasso, Jr., Bar No. 015087

Robert J. Lydford, Bar No. 030649

Pamela L. Judd, Bar No. 022109

rgrasso@grassolawfirm.com

rlydford@grassolawfirm.com

pjudd@grassolawfirm.com

minuteentries@grassolawfirm.com

Attorneys for Defendants

Laki Syph,

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

IN AND FOR THE COUNTY OF MARICOPA

Case No. CV2025-029701

Plaintiff,

vs.

BASIS Phoenix Central; Michelle Astwood,

Head of School, in her individual and official

capacity; Michael Hancock, Head of

Operations, in his individual and official

capacity; BASIS.ed (BASIS Educational

Group, LLC):

DEFENDANTS’ REPLY IN SPPORT OF

MOTION FOR MORE DEFINITE

STATEMENT RE [FIRST AMENDED]

COMPLAINT

(Assigned to the Honorable

Jennifer Ryan-Touhill)

Defendants.

Defendants BASIS Phoenix Central, Michelle Astwood, Michael Hancock, and

BASIS Educational Group, LLC (“Defendants”) hereby file their Reply to Plaintiff’s

Response and in support of their Motion for More Definite Statement re [First Amended]

Complaint.

Defendants previously moved for a more definite statement in response to Plaintiff’s

original Complaint. Plaintiff responded, arguing the sufficiency of his Complaint. On

September 26, 2025, the Court granted Defendants’ original Motion stating, “Defendants

justifiably express doubt regarding the legal basis and factual support for the allegations in

the Complaint” and ordered Plaintiff to amend his Complaint. In the meantime, Plaintiff had

already filed his [First Amended] Complaint on September 17, 2025, prior to the Court issuing

its Order.

Based on Plaintiff’s [First Amended] Complaint having the same deficiencies as his

original Complaint, Defendants again moved for a more definite statement. In his Response

to this second Motion, Plaintiff suggests his [First Amended] Complaint is sufficient.

However, his [First Amended] Complaint added no context or allegations to support his

claims. While Plaintiff’s [First Amended] Complaint alleges certain events as the basis of his

claims, it remains unclear how these events relate to, much less support, his claims. The

allegations do not establish, support or even suggest the possibility that Plaintiff could satisfy

required elements to his claims. For example, Plaintiff continues to assert a medical

negligence claim, but no Defendant is a health care provider and there are no allegations that

any Defendant provided health care to Plaintiff. Similarly, Plaintiff continues to assert a false

arrest/wrongful imprisonment claim but he never alleges any Defendant (or Defendant

representative) detained him without his consent. Quite simply, Plaintiff’s claims remain

greatly misplaced.

Plaintiff’s Response fails to take into consideration the nature of the claims he asserts.

While Arizona follows a notice pleading standard, this standard requires that a Plaintiff “give

the opponent fair notice of the nature and basis of the claim and indicate generally the type

of litigation involved.” Cullen v. Auto-Owners Ins. Co., 218 Ariz. 417, 419 (2008) (citing

Mackey v. Spangler, 81 Ariz. 113, 115 (1956) (emphasis added)). Defendants understand

generally the factual underpinning of Plaintiff feeling aggrieved, but his [First Amended]

Complaint fails to provide any basis for his claims. Defendants are seeking clarification of

the basis of the claims asserted by Plaintiff to respond appropriately thereto.

Contrary to Plaintiff’s suggestion, the present Motion is not a “stall tactic”, rather, an

effort for clarification. And the Court’s prior Order granting Defendants’ Motion for a More

Definitive Statement relating to the original Complaint supports the need for clarification, as

the legal and factual basis of Plaintiff’s claims were not clarified through the [First Amended]

Complaint.

Based on the foregoing, pursuant to Arizona Rule of Civil Procedure 12(e), Plaintiff

should be required to file an amended Complaint to provide notice of the basis of his claims

and allow Defendants to respond to the merit thereof.

DATED this 8th day of October, 2025.

GRASSO LAW FIRM, P.C.

By /s/ Pamela L. Judd

Robert Grasso, Jr.

Robert J. Lydford

Pamela L. Judd

3075 West Ray Road, Suite 110

Chandler, Arizona 85226

Attorneys for Defendants

ORIGINAL e-filed and e-served via AZTurboCourt

and e-mailed and mailed via First Class Mail

this 8th day of October, 2025, upon:

Laki Syph

4001 N. Central Avenue, Apt. 449

Phoenix, AZ 85012

Lsyph@yahoo.com

Plaintiff Per Pro

By /s/ D. Bock

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