Motion,Ex Parte: JANE DOE VS PASADENA UNIFIED SCHOOL DISTRICT ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 04/22/2022 07:51 PM Sherri R. Carter, Executive Officer/Clerk of Court, by V. Sino-Cruz,Deputy Clerk




                          1 PANISH SHEA & BOYLE LLP
                            BRIAN J. PANISH, State Bar No. 116060
                          2   panish@psblaw.com
                            DAVID RUDORFER, State Bar No. 254666
                          3   rudorfer@psblaw.com
                            11111 Santa Monica Boulevard, Suite 700
                          4 Los Angeles, California 90025
                            Telephone: 310.477.1700
                          5 Facsimile: 310.477.1699

                          6 SHERI E. MANUWAL, State Bar No. 106305
                            ROBERT I. MANUWAL, State Bar No. 102781
                          7 MANUWAL & MANUWAL
                            100 N. Westlake Boulevard, Suite 203
                          8 Westlake Village, CA 91362
                            Telephone: 818.715.6040
                          9 Facsimile: 818.715.6030
                        10 Attorneys for Plaintiff

                        11                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA

                        12                                     COUNTY OF LOS ANGELES, CENTRAL DISTRICT

                        13

                        14 "JANE DOE", a person with a disability by                                         Case No. BC662842
                           and through her Guardian ad Litem
                        15 KATHRYN T. MCGUIGAN,                                                              [Assigned to Hon. Judge Malcolm Mackey,
                                                                                                             Dept. 55]
                        16                            Plaintiff,
                                                                                                             PLAINTIFF’S MOTION IN LIMINE NO.
                        17                 v.                                                                11 TO PRECLUDE THE USE OF THE
                                                                                                             MINOR PLAINTIFF’S JUVENILE
                        18 PASADENA UNIFIED SCHOOL DISTRICT,                                                 COURT FILE WHICH WAS NEVER
                           a public entity; FOCUS POINT ACADEMY,                                             PRODUCED DURING DISCOVERY;
                        19 a public entity; BRIAN MCDONALD, an                                               MEMORANDUM OF POINTS AND
                           individual; MICHAEL BELL, an individual;                                          AUTHORITIES AND DECLARATION OF
                        20 KELLY RANEY, an individual; COUNTY                                                DAVID RUDORFER
                           OF LOS ANGELES, a public entity, LOS
                        21 ANGELES DEPARTMENT OF MENTAL                                                      [Complaint filed: 05/25/2017]
                           HEALTH, a public entity; and DOES 1                                               [Trial Date:      10/18/2021]
                        22 through 50, Inclusive,

                        23                            Defendants.

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                                PLAINTIFF’S MOTION IN LIMINE NO. 11 TO PRECLUDE THE USE OF THE MINOR PLAINTIFF’S JUVENILE
                                               COURT FILE WHICH WAS NEVER PRODUCED DURING DISCOVERY