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 04/27/2022 11:05 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariano,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 Hon. Malcolm H. Mackey,
12 MCGUIGAN, Dept. 55]
13 Plaintiff, DEFENDANT’S OPPOSITION TO
PLAINTIFF’S MOTION IN LIMINE NO.
14 v. 6 TO EXCLUDE ALL DEPOSITION
TESTIMONY OF THE MINOR
15 PASADENA UNIFIED SCHOOL PLAINTIFF INVOLVING CONFUSION,
DISTRICT, BRIAN MCDONALD, in His MANIPULATION OR
16 Official Capacity as Superintendent of MISREPRESENTATION OF ANY
Pasadena Unified School District, FOCUS ASPECT OF THE DISCOVERY AND
17 POINT ACADEMY, MICHAEL BELL, in LITIGATION PROCESS
His Official Capacity as Principal of Focus
18 Point Academy, KELLY RANEY, in Her DATE: APRIL 29. 2022
Official Capacity as Teacher at Focus Point TIME: 8:30 AM
19 Academy, COUNTY OF LOS ANGELES, a DEPT: 55
public entity, LOS ANGELES
20 DEPARTMENT OF MENTAL HEALTH, FSC: APRIL 29, 2022
ROE 1, A MINOR, ROE PARENT 1-5; ROE TRIAL: MAY 9, 2022
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 to Plaintiff JANE DOE’s motion in limine to exclude all deposition
27
28
-1-
DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 6 TO EXCLUDE ALL
DEPOSITION TESTIMONY OF THE MINOR PLAINTIFF INVOLVING CONFUSION, MANIPULATION OR
MISREPRESENTATION OF ANY ASPECT OF THE DISCOVERY AND LITIGATION PROCESS
Document Filed Date
April 27, 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 04/27/2022 11:05 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariano,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 Hon. Malcolm H. Mackey, 12 MCGUIGAN, Dept. 55] 13 Plaintiff, DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 14 v. 6 TO EXCLUDE ALL DEPOSITION TESTIMONY OF THE MINOR 15 PASADENA UNIFIED SCHOOL PLAINTIFF INVOLVING CONFUSION, DISTRICT, BRIAN MCDONALD, in His MANIPULATION OR 16 Official Capacity as Superintendent of MISREPRESENTATION OF ANY Pasadena Unified School District, FOCUS ASPECT OF THE DISCOVERY AND 17 POINT ACADEMY, MICHAEL BELL, in LITIGATION PROCESS His Official Capacity as Principal of Focus 18 Point Academy, KELLY RANEY, in Her DATE: APRIL 29. 2022 Official Capacity as Teacher at Focus Point TIME: 8:30 AM 19 Academy, COUNTY OF LOS ANGELES, a DEPT: 55 public entity, LOS ANGELES 20 DEPARTMENT OF MENTAL HEALTH, FSC: APRIL 29, 2022 ROE 1, A MINOR, ROE PARENT 1-5; ROE TRIAL: MAY 9, 2022 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 to Plaintiff JANE DOE’s motion in limine to exclude all deposition 27 28 -1- DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 6 TO EXCLUDE ALL DEPOSITION TESTIMONY OF THE MINOR PLAINTIFF INVOLVING CONFUSION, MANIPULATION OR MISREPRESENTATION OF ANY ASPECT OF THE DISCOVERY AND LITIGATION PROCESS