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qa¢2s/2018 16:51 GENERAL
® oe 795 $832 P,003/119
NANCY P. DOUMANIAN, ESQ,, SBN: 168925 FILED.
DOUMANIAN & ASSOCIATES Superior Court of California
County of Los Angeles
418 North Fair Oaks Avenue, Suite 202
Pasadena, California 91103
Telephone (626) 795-5802 SEP 26 2018
Facsimile (626) 795-5832 Sherri R. Carer, execu itiver/cterk of Court
Email: nancy@nancylaw.com
By. » Deputy
Attorneys for Defendants,
PASADENA UNIFIED SCHOOL DISTRICT, a public entity, COUNTY OF LOS
ANGELES, a public entity, BRIAN MCDONALD, MICHAEL BELL, and KELLY RANEY,
public employees
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
10
ll JANE DOE, a minor, by and through her CASE NO, BC662842
guardian ad litem, KATHRYN T, [Assigned to the Honorable Malcolm H.
12 MCGUIGAN, Mackey]
13 Plaintiff, OPPOSITION TO PLAINTIFF’S
MOTION FOR ORDER COMPELLING
14 Vv. DEFENDANTS TO PROVIDE FURTHER
RESPONSES TO PLAINTIFF JANE
15 PASADENA UNIFIED SCHOOL DOE’S REQUEST FOR PRODUCTION
DISTRICT, BRIAN MCDONALD, in His OF DOCUMENTS; MEMORANDUM OF
16 Official Capacity as Superintendent of POINTS AND AUTHORITIES;
Pasadena Unified School District, FOCUS REQUEST FOR SANCTIONS IN THE
7 POINT ACADEMY, MICHAEL BELL, in AMOUNT OF $700.00; DECLARATION
His Official Capacity as Principal of Focus OF JAVIER Z
18 Point Academy, KELLY , in Her
Official Capacity as Teacher at Focus Point DATE: OCTOBER 9, 2018
19 Academy, COUNTY OF LOS ANGELES, a TIME; 8:30 A.M.
public entity, LOS ANGELES DEPT: “55”
20 DEPARTMENT OF MENTAL HEALTH, RES ID: 180822342380
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 COME NOW Defendants PASADENA UNIFIED SCHOOL DISTRICT, a public entity,
2 26 COUNTY OF LOS ANGELES, a public entity, BRIAN MCDONALD, MICHAEL BELL, and
5a
27 KELLY RANEY, public employees and hereby submit the following Opposition to Plaintiff's
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OPPOSITION TO PLAINTIFF'S MOTION FOR ORDER COMPELLING DEFENDANTS TO PROVIDE.
FURTHER RESPONSES TO PLAINTIREFANEODOH SREQUEST FOR PRODUCTION OF DOCUMENTS
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a . ~ qa¢2s/2018 16:51 GENERAL ® oe 795 $832 P,003/119 NANCY P. DOUMANIAN, ESQ,, SBN: 168925 FILED. DOUMANIAN & ASSOCIATES Superior Court of California County of Los Angeles 418 North Fair Oaks Avenue, Suite 202 Pasadena, California 91103 Telephone (626) 795-5802 SEP 26 2018 Facsimile (626) 795-5832 Sherri R. Carer, execu itiver/cterk of Court Email: nancy@nancylaw.com By. » Deputy Attorneys for Defendants, PASADENA UNIFIED SCHOOL DISTRICT, a public entity, COUNTY OF LOS ANGELES, a public entity, BRIAN MCDONALD, MICHAEL BELL, and KELLY RANEY, public employees SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 10 ll JANE DOE, a minor, by and through her CASE NO, BC662842 guardian ad litem, KATHRYN T, [Assigned to the Honorable Malcolm H. 12 MCGUIGAN, Mackey] 13 Plaintiff, OPPOSITION TO PLAINTIFF’S MOTION FOR ORDER COMPELLING 14 Vv. DEFENDANTS TO PROVIDE FURTHER RESPONSES TO PLAINTIFF JANE 15 PASADENA UNIFIED SCHOOL DOE’S REQUEST FOR PRODUCTION DISTRICT, BRIAN MCDONALD, in His OF DOCUMENTS; MEMORANDUM OF 16 Official Capacity as Superintendent of POINTS AND AUTHORITIES; Pasadena Unified School District, FOCUS REQUEST FOR SANCTIONS IN THE 7 POINT ACADEMY, MICHAEL BELL, in AMOUNT OF $700.00; DECLARATION His Official Capacity as Principal of Focus OF JAVIER Z 18 Point Academy, KELLY , in Her Official Capacity as Teacher at Focus Point DATE: OCTOBER 9, 2018 19 Academy, COUNTY OF LOS ANGELES, a TIME; 8:30 A.M. public entity, LOS ANGELES DEPT: “55” 20 DEPARTMENT OF MENTAL HEALTH, RES ID: 180822342380 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 COME NOW Defendants PASADENA UNIFIED SCHOOL DISTRICT, a public entity, 2 26 COUNTY OF LOS ANGELES, a public entity, BRIAN MCDONALD, MICHAEL BELL, and 5a 27 KELLY RANEY, public employees and hereby submit the following Opposition to Plaintiff's - Dot 28 ~m oa -l- OPPOSITION TO PLAINTIFF'S MOTION FOR ORDER COMPELLING DEFENDANTS TO PROVIDE. FURTHER RESPONSES TO PLAINTIREFANEODOH SREQUEST FOR PRODUCTION OF DOCUMENTS