On May 25, 2017 a
Motion-Secondary
was filed
involving a dispute between
Mcguigan Kathryn T.,
and
Academy Focus Point,
Bell Michael,
County Of Los Angeles,
Los Angeles Department Of Mental Health,
Mcdonald Brian,
Pasadena Unified School District,
Raney Kelly,
Roe Parent 11-15,
Roe Parent 1-5,
Roe Parent 6-10,
for Intentional Infliction of Emotional Distress (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
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07/03/2018 14:23 GENERAL
® eo 795 5832 P.003/011
FILED
Superior Court of California
NANCYP. DOUMANIAN, ESQ., SBN: 168925 County of Los Angeles
DOUMANIAN & ASSOCIATES
418 North Fair Oaks Avenue, Suite 202 JUL 03:2018
Pasadena, California 91103 Sherri R. Carger, Execw pitcer/Clerk of Court
Telephone (626) 795-5802
Facsimile (626) 795-5832 B Deputy
Attomeys for Defendant,
PASADENA UNIFIED SCHOOL DISTRICT, a public entity, COUNTY OF LOS
ANGELES, a public entity, BRIAN MCDONALD, MICHAEL BELL, KELLY RANEY,
public employees
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
10
11 JANE DOE, a minor, by and through her CASE NO. BC662842
guardian ad ‘litem, KA [Assigned to the Honorable Malcolm H.
12 MCGUIGAN, Mackey,
13 Plaintiff, PASADENA UNIFIED SCHOOL
DISTRICT’S REPLY TO PLAINTIFF'S
14 Vv OPPOSITION TO DEMURRER TO
PLAINTIFF’S SECOND AMENDED
15 PASADENA UNIFIED SCHOOL COMPLAINT; MEMORANDUM OF
DISTRICT, BRIAN MCDONALD, in His POINTS AND AUTHORITIES
16 Official Capacity as Superintendent of
Pasadena Unified School District, FOCUS DATE: JULY 11, 2018
17 POINT ACADEMY, MICHAEL BELL, in TIME; 8:
His Official Capacity as Principal of Focus DEPT: “ 3
18 Point Academy, KELLY RANEY, in Her RES ID: 180426309550
Official Capacity as Teacher at Focus Point
19 Academy, COUNTY OF LOS ANGELES, a
public entity, LOS ANGELES
20 DEPARTMENT OF MENTAL HEALTH,
ROE 1, A MINOR, ROE PARENT 1-5; ROE
21 2, A MINOR, AND ROE PARENT 6-10,
ROE 3, A MINOR, AND ROE PARENT 11-
22 15, AND DOES 1-100, INCLUSIVE,
23 Defendants.
24
25 COMES NOW, Defendant, Pasadena Unified School District and hereby submits its
26 reply to Plaintiff's Opposition to Defendant’s Demurrer to Plaintiff's Second Amended
27 Complaint,
a
28 Mt
ede
PASADENA UNIFIED SCHOOL DISTRICT’S REPLY TO PLAINTIFF'S OPPOSITION TO DEMURRER TO
PLAINTIFFS SBCONDVAMENDED COMPLAINT
Document Filed Date
July 03, 2018
Case Filing Date
May 25, 2017
Category
Intentional Infliction of Emotional Distress (General Jurisdiction)
Status
Jury Verdict 08/23/2022
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\ 07/03/2018 14:23 GENERAL ® eo 795 5832 P.003/011 FILED Superior Court of California NANCYP. DOUMANIAN, ESQ., SBN: 168925 County of Los Angeles DOUMANIAN & ASSOCIATES 418 North Fair Oaks Avenue, Suite 202 JUL 03:2018 Pasadena, California 91103 Sherri R. Carger, Execw pitcer/Clerk of Court Telephone (626) 795-5802 Facsimile (626) 795-5832 B Deputy Attomeys for Defendant, PASADENA UNIFIED SCHOOL DISTRICT, a public entity, COUNTY OF LOS ANGELES, a public entity, BRIAN MCDONALD, MICHAEL BELL, KELLY RANEY, public employees SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 10 11 JANE DOE, a minor, by and through her CASE NO. BC662842 guardian ad ‘litem, KA [Assigned to the Honorable Malcolm H. 12 MCGUIGAN, Mackey, 13 Plaintiff, PASADENA UNIFIED SCHOOL DISTRICT’S REPLY TO PLAINTIFF'S 14 Vv OPPOSITION TO DEMURRER TO PLAINTIFF’S SECOND AMENDED 15 PASADENA UNIFIED SCHOOL COMPLAINT; MEMORANDUM OF DISTRICT, BRIAN MCDONALD, in His POINTS AND AUTHORITIES 16 Official Capacity as Superintendent of Pasadena Unified School District, FOCUS DATE: JULY 11, 2018 17 POINT ACADEMY, MICHAEL BELL, in TIME; 8: His Official Capacity as Principal of Focus DEPT: “ 3 18 Point Academy, KELLY RANEY, in Her RES ID: 180426309550 Official Capacity as Teacher at Focus Point 19 Academy, COUNTY OF LOS ANGELES, a public entity, LOS ANGELES 20 DEPARTMENT OF MENTAL HEALTH, ROE 1, A MINOR, ROE PARENT 1-5; ROE 21 2, A MINOR, AND ROE PARENT 6-10, ROE 3, A MINOR, AND ROE PARENT 11- 22 15, AND DOES 1-100, INCLUSIVE, 23 Defendants. 24 25 COMES NOW, Defendant, Pasadena Unified School District and hereby submits its 26 reply to Plaintiff's Opposition to Defendant’s Demurrer to Plaintiff's Second Amended 27 Complaint, a 28 Mt ede PASADENA UNIFIED SCHOOL DISTRICT’S REPLY TO PLAINTIFF'S OPPOSITION TO DEMURRER TO PLAINTIFFS SBCONDVAMENDED COMPLAINT