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 06/09/2022 12:51 PM 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 RESPONSE AND
14 v. OPPOSITION TO PLAINTIFF’S
SUPPLEMENTAL BRIEF ON
15 PASADENA UNIFIED SCHOOL DEFENDANT’S MOTION IN LIMINE #6
DISTRICT, BRIAN MCDONALD, in His TO EXCLUDE SUBSEQUENT
16 Official Capacity as Superintendent of REMEDIAL MEASURES AS TO
Pasadena Unified School District, FOCUS EMPLOYEE LANCE GREEN;
17 POINT ACADEMY, MICHAEL BELL, in MEMORANDUM OF POINT AND
His Official Capacity as Principal of Focus AUTHORITIES IN SUPPORT THEREOF
18 Point Academy, KELLY RANEY, in Her
Official Capacity as Teacher at Focus Point SUBMITTED: JUNE 9, 2022
19 Academy, COUNTY OF LOS ANGELES, a
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 OPPOSITION/REPLY to plaintiff’s Supplemental Brief on defendant’s Motion in
27 Limine #6 to exclude subsequent remedial measures.
28
-1-
DEFENDANT’S RESPONSE AND OPPOSITION TO PLAINTIFF’S SUPPLEMENTAL BRIEF ON
DEFENDANT’S MOTION IN LIMINE #6 TO EXCLUDE SUBSEQUENT REMEDIAL MEASURES AS TO
EMPLOYEE LANCE GREEN
Document Filed Date
June 09, 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 06/09/2022 12:51 PM 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 RESPONSE AND 14 v. OPPOSITION TO PLAINTIFF’S SUPPLEMENTAL BRIEF ON 15 PASADENA UNIFIED SCHOOL DEFENDANT’S MOTION IN LIMINE #6 DISTRICT, BRIAN MCDONALD, in His TO EXCLUDE SUBSEQUENT 16 Official Capacity as Superintendent of REMEDIAL MEASURES AS TO Pasadena Unified School District, FOCUS EMPLOYEE LANCE GREEN; 17 POINT ACADEMY, MICHAEL BELL, in MEMORANDUM OF POINT AND His Official Capacity as Principal of Focus AUTHORITIES IN SUPPORT THEREOF 18 Point Academy, KELLY RANEY, in Her Official Capacity as Teacher at Focus Point SUBMITTED: JUNE 9, 2022 19 Academy, COUNTY OF LOS ANGELES, a 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 OPPOSITION/REPLY to plaintiff’s Supplemental Brief on defendant’s Motion in 27 Limine #6 to exclude subsequent remedial measures. 28 -1- DEFENDANT’S RESPONSE AND OPPOSITION TO PLAINTIFF’S SUPPLEMENTAL BRIEF ON DEFENDANT’S MOTION IN LIMINE #6 TO EXCLUDE SUBSEQUENT REMEDIAL MEASURES AS TO EMPLOYEE LANCE GREEN