Clerk of the Superior Court

*** Electronically Filed ***

M. De La Cruz, Deputy

10/1/2025 8:47:55 PM

Filing ID 20683091

Laki Syph

4001 N Central Ave

Apt 449

Phoenix, AZ 85012

Email: Lsyph@yahoo.com

Cell: 602.500.6981

IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

IN AND FOR THE COUNTY OF MARICOPA

Laki Syph,

Plaintiff,

v.

BASIS Phoenix Central; Michelle Astwood, Head of School; Michael Hancock, Head of Operations;

BASIS.ed (BASIS Educational Group, LLC),

Defendants.

Case No. CV2025-029701

PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION FOR MORE DEFINITE STATEMENT

INTRODUCTION

Defendants once again move for a more definite statement under Rule 12(e), this time directed at Plaintiff’s

First Amended Complaint. This motion, like their prior motion, is unnecessary and improper. Plaintiff’s First

Amended Complaint clearly sets forth the factual basis of his claims and the legal theories asserted, consistent

with Arizona’s notice pleading standards. Defendants’ filing appears to be another attempt to delay answering

the Complaint and moving the case into discovery.

LEGAL STANDARD

Arizona is a notice pleading state. Under Rule 8, Ariz. R. Civ. P., a complaint need only provide “a short and

plain statement of the claim showing that the pleader is entitled to relief.

” The Arizona Supreme Court has

held that Rule 8 requires only fair notice of the nature and basis of the claim, not detailed evidentiary facts.

Cullen v. Auto-Owners Ins. Co., 218 Ariz. 417, 419 ¶ 6 (2008).

A motion for more definite statement under Rule 12(e) is appropriate only where a pleading is so vague or

ambiguous that the opposing party cannot reasonably be required to frame a response.

ARGUMENT

1. The First Amended Complaint Provides Fair Notice.

Plaintiff’s Amended Complaint sets out the relevant facts of the March 4, 2025 incident, identifies the

individuals involved, describes the resulting arrest and harm, and pleads specific causes of action including

false arrest, negligence, intentional infliction of emotional distress, retaliation, and negligent infliction of

physical harm. These allegations provide Defendants with ample notice of the claims and enable them to file

an Answer.2. Defendants’ Motion Is a Stall Tactic.

Defendants previously filed a motion for more definite statement directed at the original Complaint, which

Plaintiff cured by filing a First Amended Complaint. Rather than answering, Defendants repeat the same tactic,

causing unnecessary delay. This contravenes Rule 1’s mandate that the Rules “be construed, administered,

and employed…to secure the just, speedy, and inexpensive determination of every action.

”

3. The Proper Next Step Is for Defendants to Answer.

Because the Amended Complaint satisfies Rule 8, Defendants should be ordered to file their Answer so that

this case may proceed into discovery.

CONCLUSION

For the foregoing reasons, Plaintiff respectfully requests that this Court:

A. Deny Defendants’ Motion for More Definite Statement; and

B. Order Defendants to file their Answer within ten (10) days.

DATED this 1st day of October 2025.

Respectfully submitted,

_________________________________

Laki Syph

4001 N. Central Ave #449

Phoenix, AZ 85012

Email: Lsyph@yahoo.com

Plaintiff Pro Se