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. 16 TO PRECLUDE REFERENCE TO
PLAINTIFF’S COUNSEL MEETING
15 PASADENA UNIFIED SCHOOL WITH OR COMMUNICATING WITH
DISTRICT, BRIAN MCDONALD, in His THE MINORS WHO SEXUALLY
16 Official Capacity as Superintendent of ASSAULTED PLAINTIFF
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 any reference to
27
28
-1-
DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 16 TO PRECLUDE REFERENCE
TO PLAINTIFF’S COUNSEL MEETING WITH OR COMMUNICATING WITH THE MINORS WHO
SEXUALLY ASSAULTED PLAINTIFF
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
For full print and download access, please subscribe at https://www.trellis.law/.
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. 16 TO PRECLUDE REFERENCE TO PLAINTIFF’S COUNSEL MEETING 15 PASADENA UNIFIED SCHOOL WITH OR COMMUNICATING WITH DISTRICT, BRIAN MCDONALD, in His THE MINORS WHO SEXUALLY 16 Official Capacity as Superintendent of ASSAULTED PLAINTIFF 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 any reference to 27 28 -1- DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION IN LIMINE NO. 16 TO PRECLUDE REFERENCE TO PLAINTIFF’S COUNSEL MEETING WITH OR COMMUNICATING WITH THE MINORS WHO SEXUALLY ASSAULTED PLAINTIFF