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 01/29/2019 09:59 AM Sherri R. Carter, Executive Officer/Clerk of Court, by P. Offord,Deputy Clerk
1 NANCY P. DOUMANIAN, ESQ., SBN: 168925
JAVIER RAMIREZ, ESQ., SBN: 249516
2 DOUMANIAN & ASSOCIATES
418 North Fair Oaks Avenue, Suite 202
3 Pasadena, California 91103
Telephone (626) 795-5802
4 Facsimile (626) 795-5832
Email: nancy@nancylaw.com
5
Attorneys for Defendant,
6 PASADENA UNIFIED SCHOOL DISTRICT, a public entity,
r"l
<::> 7
~
~
~ 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
~
Q
9 FOR THE COUNTY OF LOS ANGELES
0
u
~ 10
>
0 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 REPLY TO PLAINTIFF'S
~ 14 v. OPPOSITION TO EX PARTE
z
.... APPLICATION FOR AN ORDER TO
15 PASADENA UNIFIED SCHOOL COMPEL DEPOSITION OF PLAINTIFF
....
~
~ DISTRICT, BRIAN MCDONALD, in His AND PRODUCTION OF DOCUMENTS
0 16 Official Capacity as Superintendent of AT DEPOSITION, OR IN THE
z Pasadena Unified School District, FOCUS ALTERNATIVE, SHORTENING TIME
~ 17 POINT ACADEMY, MICHAEL BELL, in ON A MOTION TO COMPEL
z His Official Capacity as Principal of Focus
<
Q 18 Point Academy, KELLY RANEY, in Her
z~ Official Capacity as Teacher at Focus Point
~ 19 Academy, COUNTY OF LOS ANGELES, a DATE: JANUARY 30, 2019
~ public entity, LOS ANGELES TIME: 8:30 A.M.
Q
20 DEPARTMENT OF MENTAL HEALTH, DEPT: "55"
~
ROE 1, A MINOR, ROE PARENT 1-5; ROE
....
~
~ 21 2, A MINOR, AND ROE PARENT 6-10,
z~ ROE 3, A MINOR, AND ROE PARENT 11-
22 15, AND DOES 1-100, INCLUSIVE,
...
u
~ Defendants.
~ 23
;;J
~
24
25
26
27
28
- 1-
PASADENA UNIFIED SCHOOL DISTRICT'S REPLY TO PLAINTIFF'S OPPOSITION TO EX PARTE
APPLICATION
Document Filed Date
January 29, 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 01/29/2019 09:59 AM Sherri R. Carter, Executive Officer/Clerk of Court, by P. Offord,Deputy Clerk 1 NANCY P. DOUMANIAN, ESQ., SBN: 168925 JAVIER RAMIREZ, ESQ., SBN: 249516 2 DOUMANIAN & ASSOCIATES 418 North Fair Oaks Avenue, Suite 202 3 Pasadena, California 91103 Telephone (626) 795-5802 4 Facsimile (626) 795-5832 Email: nancy@nancylaw.com 5 Attorneys for Defendant, 6 PASADENA UNIFIED SCHOOL DISTRICT, a public entity, r"l <::> 7 ~ ~ ~ 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA ~ Q 9 FOR THE COUNTY OF LOS ANGELES 0 u ~ 10 > 0 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 REPLY TO PLAINTIFF'S ~ 14 v. OPPOSITION TO EX PARTE z .... APPLICATION FOR AN ORDER TO 15 PASADENA UNIFIED SCHOOL COMPEL DEPOSITION OF PLAINTIFF .... ~ ~ DISTRICT, BRIAN MCDONALD, in His AND PRODUCTION OF DOCUMENTS 0 16 Official Capacity as Superintendent of AT DEPOSITION, OR IN THE z Pasadena Unified School District, FOCUS ALTERNATIVE, SHORTENING TIME ~ 17 POINT ACADEMY, MICHAEL BELL, in ON A MOTION TO COMPEL z His Official Capacity as Principal of Focus < Q 18 Point Academy, KELLY RANEY, in Her z~ Official Capacity as Teacher at Focus Point ~ 19 Academy, COUNTY OF LOS ANGELES, a DATE: JANUARY 30, 2019 ~ public entity, LOS ANGELES TIME: 8:30 A.M. Q 20 DEPARTMENT OF MENTAL HEALTH, DEPT: "55" ~ ROE 1, A MINOR, ROE PARENT 1-5; ROE .... ~ ~ 21 2, A MINOR, AND ROE PARENT 6-10, z~ ROE 3, A MINOR, AND ROE PARENT 11- 22 15, AND DOES 1-100, INCLUSIVE, ... u ~ Defendants. ~ 23 ;;J ~ 24 25 26 27 28 - 1- PASADENA UNIFIED SCHOOL DISTRICT'S REPLY TO PLAINTIFF'S OPPOSITION TO EX PARTE APPLICATION