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
Electronically FILED by Superior Court of California, County of Los Angeles on 06/21/2022 04:00 PM 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 – 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, S28, Long Beach Courthouse]
13 Plaintiff, OPPOSITION TO PLAINTIFF MOTION
IN LIMINE #11:
14 v.
DEFENDANT’S OPPOSITION TO
15 PASADENA UNIFIED SCHOOL PLAINTIFF’S MOTION IN LIMINE #11
DISTRICT, BRIAN MCDONALD, in His TO PRECLUDE USE OF MINOR
16 Official Capacity as Superintendent of PLAINTIFF’S JUVENIE COURT FILE,
Pasadena Unified School District, FOCUS MEMORANDUM OF POINTS AND
17 POINT ACADEMY, MICHAEL BELL, in AUTHORITIES AND DECLARATION
His Official Capacity as Principal of Focus OF NANCY DOUMANIAN IN SUPPORT
18 Point Academy, KELLY RANEY, in Her THEREOF
Official Capacity as Teacher at Focus Point
19 Academy, COUNTY OF LOS ANGELES, a DATE: JULY 8, 2022
public entity, LOS ANGELES TIME: 9:30 AM
20 DEPARTMENT OF MENTAL HEALTH, DEPT: S28
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
26 submits the following opposition to the plaintiff’s Motion in Limine #11 to preclude use of the
27 minor plaintiff’s juvenile court records.
28
-1-
DEFENDANT’S OPPOSITION TO PLAINITFF MIL #11 TO PRECLUDE USE OF
JUVENILE COURT RECORDS
Document Filed Date
June 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 06/21/2022 04:00 PM 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 – 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, S28, Long Beach Courthouse] 13 Plaintiff, OPPOSITION TO PLAINTIFF MOTION IN LIMINE #11: 14 v. DEFENDANT’S OPPOSITION TO 15 PASADENA UNIFIED SCHOOL PLAINTIFF’S MOTION IN LIMINE #11 DISTRICT, BRIAN MCDONALD, in His TO PRECLUDE USE OF MINOR 16 Official Capacity as Superintendent of PLAINTIFF’S JUVENIE COURT FILE, Pasadena Unified School District, FOCUS MEMORANDUM OF POINTS AND 17 POINT ACADEMY, MICHAEL BELL, in AUTHORITIES AND DECLARATION His Official Capacity as Principal of Focus OF NANCY DOUMANIAN IN SUPPORT 18 Point Academy, KELLY RANEY, in Her THEREOF Official Capacity as Teacher at Focus Point 19 Academy, COUNTY OF LOS ANGELES, a DATE: JULY 8, 2022 public entity, LOS ANGELES TIME: 9:30 AM 20 DEPARTMENT OF MENTAL HEALTH, DEPT: S28 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 26 submits the following opposition to the plaintiff’s Motion in Limine #11 to preclude use of the 27 minor plaintiff’s juvenile court records. 28 -1- DEFENDANT’S OPPOSITION TO PLAINITFF MIL #11 TO PRECLUDE USE OF JUVENILE COURT RECORDS