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 09:35 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. 8 TO PRECLUDE DEFENDANT FROM
INTRODUCING ANY WITNESSES,
15 PASADENA UNIFIED SCHOOL EVIDENCE, OR CONTENTIONS NOT
DISTRICT, BRIAN MCDONALD, in His DISCLOSED IN RESPONSES TO
16 Official Capacity as Superintendent of DISCOVERY
Pasadena Unified School District, FOCUS
17 POINT ACADEMY, MICHAEL BELL, in DATE: APRIL 29. 2022
His Official Capacity as Principal of Focus TIME: 8: 30 AM
18 Point Academy, KELLY RANEY, in Her DEPT: 55
Official Capacity as Teacher at Focus Point
19 Academy, COUNTY OF LOS ANGELES, a FSC: APRIL 29, 2022
public entity, LOS ANGELES TRIAL: MAY 9, 2022
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 to Plaintiff JANE DOE’s motion in limine to preclude defendant from
27 introducing any witnesses, evidence, or contentions not disclosed in responses to discovery.
28
-1-
DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 8 TO PRECLUDE DEFENDANT
FROM INTRODUCING ANY WITNESSES, EVIDENCE, OR CONTENTIONS NOT DISCLOSED IN
RESPONSES TO DISCOVERY
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 04/27/2022 09:35 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. 8 TO PRECLUDE DEFENDANT FROM INTRODUCING ANY WITNESSES, 15 PASADENA UNIFIED SCHOOL EVIDENCE, OR CONTENTIONS NOT DISTRICT, BRIAN MCDONALD, in His DISCLOSED IN RESPONSES TO 16 Official Capacity as Superintendent of DISCOVERY Pasadena Unified School District, FOCUS 17 POINT ACADEMY, MICHAEL BELL, in DATE: APRIL 29. 2022 His Official Capacity as Principal of Focus TIME: 8: 30 AM 18 Point Academy, KELLY RANEY, in Her DEPT: 55 Official Capacity as Teacher at Focus Point 19 Academy, COUNTY OF LOS ANGELES, a FSC: APRIL 29, 2022 public entity, LOS ANGELES TRIAL: MAY 9, 2022 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 to Plaintiff JANE DOE’s motion in limine to preclude defendant from 27 introducing any witnesses, evidence, or contentions not disclosed in responses to discovery. 28 -1- DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 8 TO PRECLUDE DEFENDANT FROM INTRODUCING ANY WITNESSES, EVIDENCE, OR CONTENTIONS NOT DISCLOSED IN RESPONSES TO DISCOVERY