On May 25, 2017 a
Trial Materials
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 07/21/2022 07:19 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Ballesteros,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
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF LOS ANGELES – CENTRAL DISTRICT
9
10
JANE DOE, a minor, by and through her CASE NO. BC662842
11 guardian ad litem, KATHRYN T. [Assigned to the Honorable Patrick Madden,
MCGUIGAN, Department S28]
12
Plaintiff, OPPOSITION TO PLAINTIFF MOTION
13 IN LIMINE #19 AND PLAINTIFF’S
v. TRIAL BRIEF ON EASTERBY v. CLARK
14 TO ALLOW PLAINTIFF’S EXPERT DR
PASADENA UNIFIED SCHOOL JACKS TO AMEND HIS OPINIONS
15 DISTRICT, BRIAN MCDONALD, in His REGARDING PLAINTIFF’S FUTURE
Official Capacity as Superintendent of CARE; MEMORANDUM OF POINTS
16 Pasadena Unified School District, FOCUS AND AUTHORITIES AND
POINT ACADEMY, MICHAEL BELL, in DECLARATION OF NANCY
17 His Official Capacity as Principal of Focus DOUMANIAN IN SUPPORT THEREOF
Point Academy, KELLY RANEY, in Her
18 Official Capacity as Teacher at Focus Point SUBMITTED: JULY 21, 2022
Academy, COUNTY OF LOS ANGELES, a DEPT: S28
19 public entity, LOS ANGELES
DEPARTMENT OF MENTAL HEALTH, TRIAL: AUGUST 1, 2022
20 ROE 1, A MINOR, ROE PARENT 1-5; ROE TIME: 9:30 am
2, A MINOR, AND ROE PARENT 6-10, DEPT: S28
21 ROE 3, A MINOR, AND ROE PARENT 11-
15, AND DOES 1-100, INCLUSIVE,
22
Defendants.
23
24
25 COMES NOW Defendant PASADENA UNIFIED SCHOOL DISTRICT and hereby
26 submits the following opposition to the plaintiff’s motion in limine #19 and the plaintiff’s trial
27
-1-
28
OPPOSITION TO PLAINTIFF MOTION IN LIMINE #19 AND PLAINTIFF’S TRIAL BRIEF ON EASTERBY v. CLARK TO ALLOW
PLAINTIFF’S EXPERT DR JACKS TO AMEND HIS OPINIONS REGARDING PLAINTIFF’S FUTURE CARE; MEMORANDUM OF
POINTS AND AUTHORITIES AND DECLARATION OF NANCY DOUMANIAN IN SUPPORT THEREOF
Document Filed Date
July 21, 2022
Case Filing Date
May 25, 2017
Category
Intentional Infliction of Emotional Distress (General Jurisdiction)
Status
Jury Verdict 08/23/2022
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 07/21/2022 07:19 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Ballesteros,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 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF LOS ANGELES – CENTRAL DISTRICT 9 10 JANE DOE, a minor, by and through her CASE NO. BC662842 11 guardian ad litem, KATHRYN T. [Assigned to the Honorable Patrick Madden, MCGUIGAN, Department S28] 12 Plaintiff, OPPOSITION TO PLAINTIFF MOTION 13 IN LIMINE #19 AND PLAINTIFF’S v. TRIAL BRIEF ON EASTERBY v. CLARK 14 TO ALLOW PLAINTIFF’S EXPERT DR PASADENA UNIFIED SCHOOL JACKS TO AMEND HIS OPINIONS 15 DISTRICT, BRIAN MCDONALD, in His REGARDING PLAINTIFF’S FUTURE Official Capacity as Superintendent of CARE; MEMORANDUM OF POINTS 16 Pasadena Unified School District, FOCUS AND AUTHORITIES AND POINT ACADEMY, MICHAEL BELL, in DECLARATION OF NANCY 17 His Official Capacity as Principal of Focus DOUMANIAN IN SUPPORT THEREOF Point Academy, KELLY RANEY, in Her 18 Official Capacity as Teacher at Focus Point SUBMITTED: JULY 21, 2022 Academy, COUNTY OF LOS ANGELES, a DEPT: S28 19 public entity, LOS ANGELES DEPARTMENT OF MENTAL HEALTH, TRIAL: AUGUST 1, 2022 20 ROE 1, A MINOR, ROE PARENT 1-5; ROE TIME: 9:30 am 2, A MINOR, AND ROE PARENT 6-10, DEPT: S28 21 ROE 3, A MINOR, AND ROE PARENT 11- 15, AND DOES 1-100, INCLUSIVE, 22 Defendants. 23 24 25 COMES NOW Defendant PASADENA UNIFIED SCHOOL DISTRICT and hereby 26 submits the following opposition to the plaintiff’s motion in limine #19 and the plaintiff’s trial 27 -1- 28 OPPOSITION TO PLAINTIFF MOTION IN LIMINE #19 AND PLAINTIFF’S TRIAL BRIEF ON EASTERBY v. CLARK TO ALLOW PLAINTIFF’S EXPERT DR JACKS TO AMEND HIS OPINIONS REGARDING PLAINTIFF’S FUTURE CARE; MEMORANDUM OF POINTS AND AUTHORITIES AND DECLARATION OF NANCY DOUMANIAN IN SUPPORT THEREOF