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 06/08/2022 09:41 AM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Salcido,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 EX PARTE
14 v. APPLICATION FOR LEAVE OF COURT
TO FILE FIVE (5) ADDITIONAL
15 PASADENA UNIFIED SCHOOL MOTIONS IN LIMINE; MEMORANDUM
DISTRICT, BRIAN MCDONALD, in His OF POINTS AND AUTHORITIES AND
16 Official Capacity as Superintendent of DECLARATION OF NANCY
Pasadena Unified School District, FOCUS DOUMANIAN IN SUPPORT THEREOF
17 POINT ACADEMY, MICHAEL BELL, in
His Official Capacity as Principal of Focus
18 Point Academy, KELLY RANEY, in Her DATE: JUNE 10, 2022
Official Capacity as Teacher at Focus Point TIME: 9:30 AM
19 Academy, COUNTY OF LOS ANGELES, a DEPT: S28 (Long Beach)
public entity, LOS ANGELES
20 DEPARTMENT OF MENTAL HEALTH,
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 this ex parte application on JUNE 10, 2022 at 9:30 am in Department “S28” of this
27 Court, for leave of Court to file the following additional motions in limine: (1) motion in limine
28 to exclude reference to gate installation and place at the scene of the incident, after the plaintiff’s
-1-
EX PARTE APPLICATION FOR LEAVE OF COURT TO FILE ADDITIONAL MOTIONS IN LIMINE
Document Filed Date
June 08, 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 06/08/2022 09:41 AM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Salcido,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 EX PARTE 14 v. APPLICATION FOR LEAVE OF COURT TO FILE FIVE (5) ADDITIONAL 15 PASADENA UNIFIED SCHOOL MOTIONS IN LIMINE; MEMORANDUM DISTRICT, BRIAN MCDONALD, in His OF POINTS AND AUTHORITIES AND 16 Official Capacity as Superintendent of DECLARATION OF NANCY Pasadena Unified School District, FOCUS DOUMANIAN IN SUPPORT THEREOF 17 POINT ACADEMY, MICHAEL BELL, in His Official Capacity as Principal of Focus 18 Point Academy, KELLY RANEY, in Her DATE: JUNE 10, 2022 Official Capacity as Teacher at Focus Point TIME: 9:30 AM 19 Academy, COUNTY OF LOS ANGELES, a DEPT: S28 (Long Beach) public entity, LOS ANGELES 20 DEPARTMENT OF MENTAL HEALTH, 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 this ex parte application on JUNE 10, 2022 at 9:30 am in Department “S28” of this 27 Court, for leave of Court to file the following additional motions in limine: (1) motion in limine 28 to exclude reference to gate installation and place at the scene of the incident, after the plaintiff’s -1- EX PARTE APPLICATION FOR LEAVE OF COURT TO FILE ADDITIONAL MOTIONS IN LIMINE