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  • JANE DOE VS PASADENA UNIFIED SCHOOL DISTRICT ET AL Intentional Infliction of Emotional Distress (General Jurisdiction) document preview
  • JANE DOE VS PASADENA UNIFIED SCHOOL DISTRICT ET AL Intentional Infliction of Emotional Distress (General Jurisdiction) document preview
						
                                

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Electronically FILED by Superior Court of California, County of Los Angeles on 05/18/2022 03:49 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 FOR THE COUNTY OF LOS ANGELES 10 11 JANE DOE, a minor, by and through her CASE NO. BC662842 guardian ad litem, KATHRYN T. 12 MCGUIGAN, MOTION IN LIMINE NO. 12: 13 Plaintiff, DEFENDANT PASADENA UNIFIED SCHOOL DISTRICT’S MOTION IN 14 v. LIMINE #12 TO EXCLUDE IMPROPER TESTIMONY BY PLAINTIFF EXPERT 15 PASADENA UNIFIED SCHOOL CRAIG CUNNINGHAM, OR IN THE DISTRICT, BRIAN MCDONALD, in His ALTERNATIVE, REQUEST FOR 402 16 Official Capacity as Superintendent of HEARING PRIOR TO TRIAL Pasadena Unified School District, FOCUS TESTIMONY BY PLAINTIFF’S EXPERT 17 POINT ACADEMY, MICHAEL BELL, in His Official Capacity as Principal of Focus 18 Point Academy, KELLY RANEY, in Her TRIAL: MAY 19, 2022 Official Capacity as Teacher at Focus Point TIME: 1:30 PM 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 will and 26 hereby does move this Court for an Order to preclude testimony at trial by plaintiff’s retained 27 expert CRAIG CUNNINGHAM (former PE Teacher) 28 -1- MOTION IN LIMINE NO. 12 TO EXCLUDE CRAIG CUNNINGHAM