On May 25, 2017 a
Motion,Ex Parte
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.
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Electronically FILED by Superior Court of California, County of Los Angeles on 06/20/2022 03:31 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, Department S28]
13 Plaintiff, MOTION IN LIMINE NO. 18:
14 v. DEFENDANT PASADENA UNIFIED
SCHOOL DISTRICT’S MOTION IN
15 PASADENA UNIFIED SCHOOL LIMINE #18 TO EXCLUDE ANY
DISTRICT, BRIAN MCDONALD, in His EVIDENCE OF INSTALLATION AND
16 Official Capacity as Superintendent of PLACEMENT OF FENCE OR GATE IN
Pasadena Unified School District, FOCUS THE AREA WHERE THE INCIDENT
17 POINT ACADEMY, MICHAEL BELL, in INVOLVING PLAINTIFF OCCURRED
His Official Capacity as Principal of Focus THE DAY AFTER THE INCIDENT
18 Point Academy, KELLY RANEY, in Her OCCURRED, MEMORANDUM OF
Official Capacity as Teacher at Focus Point POINTS AND AUTHORITIES AND
19 Academy, COUNTY OF LOS ANGELES, a DECLARATION OF NANCY
public entity, LOS ANGELES DOUMANIAN IN SUPPORT THEREOF
20 DEPARTMENT OF MENTAL HEALTH,
ROE 1, A MINOR, ROE PARENT 1-5; ROE DATE: JULY 8, 2022
21 2, A MINOR, AND ROE PARENT 6-10, TIME: 9:30 AM
ROE 3, A MINOR, AND ROE PARENT 11- DEPT: S28 (Long Beach)
22 15, AND DOES 1-100, INCLUSIVE,
23 Defendants.
24
25 PLEASE TAKE NOTICE that on JULY 8, 2022 at 9:30 AM, in Department S28 of this
26 courthouse located at 275 Magnolia Avenue, Long Beach, California, and pursuant to the Court’s
27 June 20, 2022 Orders on the filing and hearing of this motion in limine, Defendant PASADENA
28 UNIFIED SCHOOL DISTRICT and will and hereby does move this Court for an Order to
-1-
MOTION IN LIMINE NO. 18 TO EXCLUDE ANY EVIDENCE OF INSTALLATION OF GATE AND
FENCING AS SUBSEQUENT REMEDIAL MEASURES
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 06/20/2022 03:31 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, Department S28] 13 Plaintiff, MOTION IN LIMINE NO. 18: 14 v. DEFENDANT PASADENA UNIFIED SCHOOL DISTRICT’S MOTION IN 15 PASADENA UNIFIED SCHOOL LIMINE #18 TO EXCLUDE ANY DISTRICT, BRIAN MCDONALD, in His EVIDENCE OF INSTALLATION AND 16 Official Capacity as Superintendent of PLACEMENT OF FENCE OR GATE IN Pasadena Unified School District, FOCUS THE AREA WHERE THE INCIDENT 17 POINT ACADEMY, MICHAEL BELL, in INVOLVING PLAINTIFF OCCURRED His Official Capacity as Principal of Focus THE DAY AFTER THE INCIDENT 18 Point Academy, KELLY RANEY, in Her OCCURRED, MEMORANDUM OF Official Capacity as Teacher at Focus Point POINTS AND AUTHORITIES AND 19 Academy, COUNTY OF LOS ANGELES, a DECLARATION OF NANCY public entity, LOS ANGELES DOUMANIAN IN SUPPORT THEREOF 20 DEPARTMENT OF MENTAL HEALTH, ROE 1, A MINOR, ROE PARENT 1-5; ROE DATE: JULY 8, 2022 21 2, A MINOR, AND ROE PARENT 6-10, TIME: 9:30 AM ROE 3, A MINOR, AND ROE PARENT 11- DEPT: S28 (Long Beach) 22 15, AND DOES 1-100, INCLUSIVE, 23 Defendants. 24 25 PLEASE TAKE NOTICE that on JULY 8, 2022 at 9:30 AM, in Department S28 of this 26 courthouse located at 275 Magnolia Avenue, Long Beach, California, and pursuant to the Court’s 27 June 20, 2022 Orders on the filing and hearing of this motion in limine, Defendant PASADENA 28 UNIFIED SCHOOL DISTRICT and will and hereby does move this Court for an Order to -1- MOTION IN LIMINE NO. 18 TO EXCLUDE ANY EVIDENCE OF INSTALLATION OF GATE AND FENCING AS SUBSEQUENT REMEDIAL MEASURES