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  • JANE DOE VS PASADENA UNIFIED SCHOOL DISTRICT ET AL Intentional Infliction of Emotional Distress (General Jurisdiction) document preview
  • JANE DOE VS PASADENA UNIFIED SCHOOL DISTRICT ET AL Intentional Infliction of Emotional Distress (General Jurisdiction) document preview
						
                                

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Electronically FILED by Superior Court of California, County of Los Angeles on 12/29/2022 02:20 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Gray,Deputy Clerk 1 NANCY P. DOUMANIAN, ESQ., State Bar No.: 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 – CENTRAL 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 for Trial] 13 Plaintiff, DECLARATION OF NANCY DOUMANIAN IN SUPPORT OF 14 v. DEFENDANT PASADENA UNIFIED SCHOOL DISTRICT’S MOTION FOR 15 PASADENA UNIFIED SCHOOL NEW TRIAL AND COMPENDIUM OF DISTRICT, BRIAN MCDONALD, in His EXHIBITS [VOLUME 1 OF 9, EXHIBITS 16 Official Capacity as Superintendent of A THROUGH F] Pasadena Unified School District, FOCUS 17 POINT ACADEMY, MICHAEL BELL, in FILED CONCURRENTLY WITH: His Official Capacity as Principal of Focus 18 Point Academy, KELLY RANEY, in Her 1. MEMORANDUM OF POINTS Official Capacity as Teacher at Focus Point AND AUTHORITIES IN 19 Academy, COUNTY OF LOS ANGELES, a SUPPORT OF DEFENDANT’S public entity, LOS ANGELES MOTION FOR NEW TRIAL 20 DEPARTMENT OF MENTAL HEALTH, ROE 1, A MINOR, ROE PARENT 1-5; ROE 21 2, A MINOR, AND ROE PARENT 6-10, DATE: FEBRUARY 7, 2023 ROE 3, A MINOR, AND ROE PARENT 11- TIME: 8:30 AM 22 15, AND DOES 1-100, INCLUSIVE, DEPT: S28 (Long Beach) 23 Defendants. RESERVATION ID: DATE SET BY THE COURT 24 25 26 27 COMES NOW Defendant PASADENA UNIFIED SCHOOL DISTRICT and hereby 28 -1- DECLARATION OF NANCY DOUMANIAN IN SUPPORT OF DEFENDANT PASADENA UNIFIED SCHOOL DISTRICT’S MOTION FOR NEW TRIAL AND COMPENDIUM OF EXHIBITS [VOLUME 1 OF 9, EXHIBITS A THROUGH F]