Document for JUANITA DENISE SCHMITTLE VS BALDWIN PARK UNIFIED SCHOOL DIST

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 08/01/2019 10:21 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. So,Deputy Clerk




             1     LAW OFFICES OF JOE HARITON, A PROFESSIONAL CORPORATION
                   JOE HARITON, SBN 133994
             2         E-MAIL: JOE@HARITONLAW.COM
             3     Physical Address: 10215 Santa Monica Boulevard, Suite C, Century City, CA 90067
                   Mailing Address: 10573 W. Pico Blvd., #201, Los Angeles, CA 90064
             4     Telephone: 310.218.0535
                   Facsimile: 310.218.0536
             5
             6     Attorneys for Plaintiff, JUANITA DENISE SCHMITTLE

             7                                 SUPERIOR COURT IN THE STATE OF CALIFORNIA
             8
                            FOR THE COUNTY OF LOS ANGELES – SPRING STREET COURTHOUSE
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           10          JUANITA DENISE SCHMITTLE                                            CASE NO. BC 595422
                                                                                           [Assigned for all purposes to the Hon. Judge
           11                                             Plaintiff,                       Teresa A. Beaudet, Dept. 50]
           12
                                  vs.                                                      DECLARATION OF JOE HARITON IN
           13                                                                              SUPPORT OF PLAINTIFF’S MOTION IN
                       BALDWIN PARK UNIFIED SCHOOL                                         LIMINE NO. 2 - TO EXCLUDE ANY AND
           14          DISTRICT; and DOES 1 through 10,                                    ALL EVIDENCE RELATED TO ANY
           15          inclusive,                                                          MENTAL HEALTH EVALUATION OF
                                                                                           PLAINTIFF IN A CASE WHICH IS NOT
           16                                             Defendants.                      THE INSTANT CASE
           17
                                                                                           Complaint Filed:                   September 22, 2015
           18                                                                              Trial Date:                        September 4, 2019
           19
           20                  TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
           21                  Plaintiff, JUANITA DENISE SCHMITTLE, hereby submits this Declaration of Joe
           22      Hariton in support of Plaintiff’s Motion in Limine No. 2 (“MIL #2) – To Exclude any and all
           23      Evidence Related to any Mental Health Evaluation of Plaintiff in a Case which is not the Instant
           24      Case.
           25
           26                                                        DECLARATION OF JOE HARITON
           27            1. I, JOE HARITON, declare I am an attorney at law duly licensed to practice before all of
           28

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                         PLAINTIFF’S COUNSEL’S DECLARATION IN SUPPORT OF PLAINTIFF’S MIL #2