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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
						
                                

Preview

Electronically FILED by Superior Court of California, County of Los Angeles on 11/14/2019 03:07 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,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 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF LOS ANGELES 9 10 JANE DOE, a minor, by and through her CASE NO. BC662842 guardian ad litem, KATHRYN T. [Assigned to the Hon. Malcolm H. Mackey, 11 MCGUIGAN, Dept. 55] 12 Plaintiff, DECLARATION OF NANCY P. DOUMANIAN IN SUPPORT OF 13 v. DEFENDANT PASADENA UNIFIED SCHOOL DISTRICT’S AMENDED 14 PASADENA UNIFIED SCHOOL OPPOSITION TO PLAINTIFF’S DISTRICT, BRIAN MCDONALD, in His MOTION FOR TERMINATING, ISSUE 15 Official Capacity as Superintendent of AND/OR EVIDENCE SANCTIONS Pasadena Unified School District, FOCUS 16 POINT ACADEMY, MICHAEL BELL, in Filed concurrently with: His Official Capacity as Principal of Focus 17 Point Academy, KELLY RANEY, in Her 1. DEFENDANT PUSD’S Official Capacity as Teacher at Focus Point OPPOSITION TO PLAINTIFF’S 18 Academy, COUNTY OF LOS ANGELES, a MOTION FOR SANCTIONS; AND public entity, LOS ANGELES 2. DECLARATION OF JAVIER 19 DEPARTMENT OF MENTAL HEALTH, RAMIREZ WITH EXHIBITS ROE 1, A MINOR, ROE PARENT 1-5; ROE 20 2, A MINOR, AND ROE PARENT 6-10, ROE 3, A MINOR, AND ROE PARENT 11- DATE: NOVEMBER 26, 2019 21 15, AND DOES 1-100, INCLUSIVE, TIME: 8:30 A.M. DEPT: “55” 22 Defendants. 23 24 /// 25 /// 26 /// 27 /// 28 /// -1- PROOF OF SERVICE