On May 25, 2017 a
Party Discovery
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 05/08/2019 03:29 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Lara,Deputy Clerk
1 NANCY P. DOUMANIAN, ESQ., SBN: 168925
DOUMANIAN & ASSOCIATES
2 418 North Fair Oaks Avenue, Suite 202
Pasadena, California 91103
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
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES
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, PASADENA UNIFIED SCHOOL
DISTRICT'S OPPOSITION TO
14 V. PLAINTIFF'S MOTION TO COMPEL
DEPOSITION OF DEFENDANT'S
15 PASADENA UNIFIED SCHOOL PERSON MOST QUALIFIED KELLY
DISTRICT, BRIAN MCDONALD, in His RANEY; MEMORANDUM OF POINTS
16 Official Capacity as Superintendent of AND AUTHORITIES; DECLARATION
Pasadena Unified School District, FOCUS OF JAVIER RAMIREZ IN SUPPORT
17 POINT ACADEMY, MICHAEL BELL, in THEREOF
His Official Capacity as Principal of Focus
18 Point Academy, KELLY RANEY, in Her DATE: MAY 21, 2019
Official Capacity as Teacher at Focus Point TIME: 8:30 A.M.
19 Academy, COUNTY OF LOS ANGELES, a DEPT: "55"
public entity, LOS ANGELES RES ID: 101483867751
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 Ill
26 Ill
27 Ill
28 Ill
- 1-
PASADENA UNIFIED SCHOOL DISTRICT'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL
DEPOSITION OF DEFENDANT'S PERSON MOST QUALIFIED KELLY RANEY
Document Filed Date
May 08, 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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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 05/08/2019 03:29 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Lara,Deputy Clerk 1 NANCY P. DOUMANIAN, ESQ., SBN: 168925 DOUMANIAN & ASSOCIATES 2 418 North Fair Oaks Avenue, Suite 202 Pasadena, California 91103 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 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 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, PASADENA UNIFIED SCHOOL DISTRICT'S OPPOSITION TO 14 V. PLAINTIFF'S MOTION TO COMPEL DEPOSITION OF DEFENDANT'S 15 PASADENA UNIFIED SCHOOL PERSON MOST QUALIFIED KELLY DISTRICT, BRIAN MCDONALD, in His RANEY; MEMORANDUM OF POINTS 16 Official Capacity as Superintendent of AND AUTHORITIES; DECLARATION Pasadena Unified School District, FOCUS OF JAVIER RAMIREZ IN SUPPORT 17 POINT ACADEMY, MICHAEL BELL, in THEREOF His Official Capacity as Principal of Focus 18 Point Academy, KELLY RANEY, in Her DATE: MAY 21, 2019 Official Capacity as Teacher at Focus Point TIME: 8:30 A.M. 19 Academy, COUNTY OF LOS ANGELES, a DEPT: "55" public entity, LOS ANGELES RES ID: 101483867751 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 Ill 26 Ill 27 Ill 28 Ill - 1- PASADENA UNIFIED SCHOOL DISTRICT'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL DEPOSITION OF DEFENDANT'S PERSON MOST QUALIFIED KELLY RANEY