On May 25, 2017 a
Miscellaneous
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
Electronically FILED by Superior Court of California, County of Los Angeles on 07/28/2022 09:44 AM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Salcido,Deputy Clerk
1 NANCY P. DOUMANIAN, ESQ., SBN: 168925
DOUMANIAN & ASSOCIATES
2 837 South Fair Oaks Avenue, Suite 200
Pasadena, California 91105
3 Telephone (626) 795-5802
Facsimile (626) 795-5832
4 Email: nancy@nancylaw.com
5 Attorneys for Defendant,
PASADENA UNIFIED SCHOOL DISTRICT, a public entity,
6
PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’ T. CODE § 6103
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES – SOUTH DISTRICT
10
11 JANE DOE, a minor, by and through her CASE NO. BC662842
guardian ad litem, KATHRYN T. [Assigned to the Honorable Patrick Madden,
12 MCGUIGAN, Department S28]
13 Plaintiff, DEFENDANT’S EX PARTE
APPLICATION FOR A COURT ORDER
14 v. ISSUING TERMINATING SANCTIONS
IN THE FORM OF A DISMISSAL OF
15 PASADENA UNIFIED SCHOOL THE OPERATIVE COMPLAINT OR, IN
DISTRICT, BRIAN MCDONALD, in His THE ALTERNATIVE, EVIDENTIARY,
16 Official Capacity as Superintendent of ISSUE OR OTHER SANCTIONS
Pasadena Unified School District, FOCUS AGAINST PLAINTIFF AND HER
17 POINT ACADEMY, MICHAEL BELL, in ATTORNEYS OF RECORD, GIVEN
His Official Capacity as Principal of Focus WILLFUL SUPPRESSION OF
18 Point Academy, KELLY RANEY, in Her MATERIAL EVIDENCE IN DISCOVERY
Official Capacity as Teacher at Focus Point RELATED TO PLAINTIFF’S
19 Academy, COUNTY OF LOS ANGELES, a DAMAGES; MEMORANDUM OF
public entity, LOS ANGELES POINTS AND AUTHORITIES IN
20 DEPARTMENT OF MENTAL HEALTH, SUPPORT THEREOF
ROE 1, A MINOR, ROE PARENT 1-5; ROE
21 2, A MINOR, AND ROE PARENT 6-10, FILED CONCURRENTLY WITH:
ROE 3, A MINOR, AND ROE PARENT 11- 1. Declaration of Nancy P. Doumanian
22 15, AND DOES 1-100, INCLUSIVE, 2. Proposed Order
23 Defendants. DATE: JULY 29, 2022
TIME: 9:30 AM
24 DEPT: S28
25
26
27 PLEASE TAKE NOTICE that, on JULY 29, 2022, at 9:30 a.m., or as soon thereafter
28 as counsel may be heard in Department "S28" of Long Beach Courthouse, located at 275
-1-
EX PARTE APPLICATION FOR TERMINATING SANCTIONS
OR OTHER RELIEF
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 07/28/2022 09:44 AM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Salcido,Deputy Clerk 1 NANCY P. DOUMANIAN, ESQ., SBN: 168925 DOUMANIAN & ASSOCIATES 2 837 South Fair Oaks Avenue, Suite 200 Pasadena, California 91105 3 Telephone (626) 795-5802 Facsimile (626) 795-5832 4 Email: nancy@nancylaw.com 5 Attorneys for Defendant, PASADENA UNIFIED SCHOOL DISTRICT, a public entity, 6 PUBLIC ENTITY DEFENDANT, NO FILING FEE PER GOV’ T. CODE § 6103 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES – SOUTH DISTRICT 10 11 JANE DOE, a minor, by and through her CASE NO. BC662842 guardian ad litem, KATHRYN T. [Assigned to the Honorable Patrick Madden, 12 MCGUIGAN, Department S28] 13 Plaintiff, DEFENDANT’S EX PARTE APPLICATION FOR A COURT ORDER 14 v. ISSUING TERMINATING SANCTIONS IN THE FORM OF A DISMISSAL OF 15 PASADENA UNIFIED SCHOOL THE OPERATIVE COMPLAINT OR, IN DISTRICT, BRIAN MCDONALD, in His THE ALTERNATIVE, EVIDENTIARY, 16 Official Capacity as Superintendent of ISSUE OR OTHER SANCTIONS Pasadena Unified School District, FOCUS AGAINST PLAINTIFF AND HER 17 POINT ACADEMY, MICHAEL BELL, in ATTORNEYS OF RECORD, GIVEN His Official Capacity as Principal of Focus WILLFUL SUPPRESSION OF 18 Point Academy, KELLY RANEY, in Her MATERIAL EVIDENCE IN DISCOVERY Official Capacity as Teacher at Focus Point RELATED TO PLAINTIFF’S 19 Academy, COUNTY OF LOS ANGELES, a DAMAGES; MEMORANDUM OF public entity, LOS ANGELES POINTS AND AUTHORITIES IN 20 DEPARTMENT OF MENTAL HEALTH, SUPPORT THEREOF ROE 1, A MINOR, ROE PARENT 1-5; ROE 21 2, A MINOR, AND ROE PARENT 6-10, FILED CONCURRENTLY WITH: ROE 3, A MINOR, AND ROE PARENT 11- 1. Declaration of Nancy P. Doumanian 22 15, AND DOES 1-100, INCLUSIVE, 2. Proposed Order 23 Defendants. DATE: JULY 29, 2022 TIME: 9:30 AM 24 DEPT: S28 25 26 27 PLEASE TAKE NOTICE that, on JULY 29, 2022, at 9:30 a.m., or as soon thereafter 28 as counsel may be heard in Department "S28" of Long Beach Courthouse, located at 275 -1- EX PARTE APPLICATION FOR TERMINATING SANCTIONS OR OTHER RELIEF