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 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
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PROOF OF SERVICE
Document Filed Date
November 14, 2019
Case Filing Date
May 25, 2017
Category
Intentional Infliction of Emotional Distress (General Jurisdiction)
Status
Jury Verdict 08/23/2022
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