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 06/20/2022 12:26 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Ballesteros,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]
13 Plaintiff, DEFENDANT PASADENA UNIFIED
SCHOOL DISTRICT’S SUPPLEMENTAL
14 v. MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT OF
15 PASADENA UNIFIED SCHOOL DEFENDANT’S MOTION IN LIMINE #8
DISTRICT, BRIAN MCDONALD, in His TO EXCLUDE THIRD PARTY
16 Official Capacity as Superintendent of STATEMENTS CONTAINED (1) IN NINE
Pasadena Unified School District, FOCUS INCIDENT REPORTS ABOUT THE
17 POINT ACADEMY, MICHAEL BELL, in SUBJECT INCIDENT AS HEARAY
His Official Capacity as Principal of Focus WITH NO APPLICABLE EXCEPTION;
18 Point Academy, KELLY RANEY, in Her (2) LA SHERIFFS REPORT AND
Official Capacity as Teacher at Focus Point SUPPLEMENTAL REPORT; (3)
19 Academy, COUNTY OF LOS ANGELES, a FORENSIC SART NURSE’S REPORT
public entity, LOS ANGELES FOR CRIMINAL PROSECUTION; AND
20 DEPARTMENT OF MENTAL HEALTH, (4) SCHOOL RECORDS REFERRING
ROE 1, A MINOR, ROE PARENT 1-5; ROE TO THE INCIDENT INVOLVING
21 2, A MINOR, AND ROE PARENT 6-10, PLAINTIFF; (5) AND ADDRESSING THE
ROE 3, A MINOR, AND ROE PARENT 11- RECENT 5/22/22 BOWSER V. FORD
22 15, AND DOES 1-100, INCLUSIVE, DECISION SUPPORTING EXCLUSION;
MEMORANDUM OF POINTS AND
23 Defendants. AUTHORITIES IN SUPPORT THEREOF
24
DATE: JUNE 20, 2022
25 TIME: 9:30 AM
DEPT: S28 (Long Beach)
26
27
28
-1-
EX PARTE APPLICATION FOR LEAVE OF COURT TO FILE ADDITIONAL MOTIONS IN LIMINE
Document Filed Date
June 20, 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 06/20/2022 12:26 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Ballesteros,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] 13 Plaintiff, DEFENDANT PASADENA UNIFIED SCHOOL DISTRICT’S SUPPLEMENTAL 14 v. MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF 15 PASADENA UNIFIED SCHOOL DEFENDANT’S MOTION IN LIMINE #8 DISTRICT, BRIAN MCDONALD, in His TO EXCLUDE THIRD PARTY 16 Official Capacity as Superintendent of STATEMENTS CONTAINED (1) IN NINE Pasadena Unified School District, FOCUS INCIDENT REPORTS ABOUT THE 17 POINT ACADEMY, MICHAEL BELL, in SUBJECT INCIDENT AS HEARAY His Official Capacity as Principal of Focus WITH NO APPLICABLE EXCEPTION; 18 Point Academy, KELLY RANEY, in Her (2) LA SHERIFFS REPORT AND Official Capacity as Teacher at Focus Point SUPPLEMENTAL REPORT; (3) 19 Academy, COUNTY OF LOS ANGELES, a FORENSIC SART NURSE’S REPORT public entity, LOS ANGELES FOR CRIMINAL PROSECUTION; AND 20 DEPARTMENT OF MENTAL HEALTH, (4) SCHOOL RECORDS REFERRING ROE 1, A MINOR, ROE PARENT 1-5; ROE TO THE INCIDENT INVOLVING 21 2, A MINOR, AND ROE PARENT 6-10, PLAINTIFF; (5) AND ADDRESSING THE ROE 3, A MINOR, AND ROE PARENT 11- RECENT 5/22/22 BOWSER V. FORD 22 15, AND DOES 1-100, INCLUSIVE, DECISION SUPPORTING EXCLUSION; MEMORANDUM OF POINTS AND 23 Defendants. AUTHORITIES IN SUPPORT THEREOF 24 DATE: JUNE 20, 2022 25 TIME: 9:30 AM DEPT: S28 (Long Beach) 26 27 28 -1- EX PARTE APPLICATION FOR LEAVE OF COURT TO FILE ADDITIONAL MOTIONS IN LIMINE