On November 03, 2021 a
Request,Application
was filed
involving a dispute between
Doe, John Vnr,
and
Brown, Eric Lynn,
Does 1-100,
Victor Valley Union High School District,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
V \v
Ra mond F. Dolen SBN 130534
D LEN TUCKER TIERNEY & ABRAHAM SUPERIORIZOIUIET%F%ALIFORNIA
17 1 0 Plum Lanes SUite A COUNTY 0F SAN BERNARDINO
SAN BERNAnDINo DISTRICT
Redlands, CA 92374
Ph: 951-683-6014 .
APR O 6 2022
/Wg.‘
Fax; 951-683-03 14
rdolen@redlands-law.com
Our File No: 12-303b
BY
KOOOQQUI-RUJN
Attorne s for Defendant,
VICTOfi VALLEY UNION HIGH SCHOOL DISTRICT
ijc” DEPUTY
”“7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
10
11 JOHN VBK DOE, an individual; CASE NO: CIVSB 2200478
Assigned Judge Wilfred J. Schneider
12 :
Plaintiff, Department : S-32
Complaint Filed January 7, 2022
13 :
VS.
14 [Fee Exempt per Gov. Code §6103]
VICTOR VALLEY UNION HIGH
15 SCHOOL DISTRICT, a business entity of DEFENDANT’S REQUEST FOR
form unknown; ERIC LYNN BROWN, an JUDICIAL NOTICE IN SUPPORT OF
16 individual, and DOES 1 through 100, DEFENDANT’S DEMURRER TO
THE COMPLAINT OF PLAINTIFF
17 Defendants.
[Filed Concurrently with Defendant’s Demurrer to
18 Complaint of Plaintiff and Declaration of Raymond
F. Dolen]
19
Date: May 24, 2022
20 Time: 9:00 a.m.
Department: S-32
21
22 TO: SAN BERNARDINO COUNTY SUPERIOR COURT and to Plaintiff John
23 VBK Doe and to his attorneys of record:
24 PLEASE TAKE NOTICE that defendant VICTOR VALLEY UNION HIGH
25 SCHOOL DISTRICT requests that the court take judicial notice of the following
26 documents pursuant to California Evidence Code §§45 1, 452 and 453:
27 1. The complaint filed in the Superior Court for the State of California, in and for
28 the County of San Bernardino, Case No. VCVVS 027960 Which complaint was
-1-
DEFENDANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEFENDANT’S DEMURRER TO THE COMPLAINT OF PLAINTIFF
V \r
filed September 6, 2002; and
2. The request for dismissal filed in Case No. VCVVS 027960 on April 26, 2003.
this court to take judicial notice 0f records 0f
Evidence Code §452(d) authorizes
The complaint and dismissal referenced in Case No. VCVVS
any court of this state.
constitute such documents. Thus, the court may properly take judicial notice
027960
\OWQONM-PWN
thereof.
A copy of the complaint is attached hereto has Exhibit “1”. A copy 0f the
“2”.
dismissal is attached hereto as Exhibit
Dated: April (,2022 DOLEN TUCKER TIERNEY & ABRAHAM
10
11
12
WP.
Atto
DOLEN
e s for Defendant,
VICTO VALLEY UNION HIGH SCHOOL
13 DISTRICT
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-2-
DEFENDANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
DEFENDANT’S DEMURRER TO THE COMPLAINT OF PLAINTIFF
Document Filed Date
April 06, 2022
Case Filing Date
November 03, 2021
Category
Other PI/PD/WD Unlimited
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Preview
V \v Ra mond F. Dolen SBN 130534 D LEN TUCKER TIERNEY & ABRAHAM SUPERIORIZOIUIET%F%ALIFORNIA 17 1 0 Plum Lanes SUite A COUNTY 0F SAN BERNARDINO SAN BERNAnDINo DISTRICT Redlands, CA 92374 Ph: 951-683-6014 . APR O 6 2022 /Wg.‘ Fax; 951-683-03 14 rdolen@redlands-law.com Our File No: 12-303b BY KOOOQQUI-RUJN Attorne s for Defendant, VICTOfi VALLEY UNION HIGH SCHOOL DISTRICT ijc” DEPUTY ”“7 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 10 11 JOHN VBK DOE, an individual; CASE NO: CIVSB 2200478 Assigned Judge Wilfred J. Schneider 12 : Plaintiff, Department : S-32 Complaint Filed January 7, 2022 13 : VS. 14 [Fee Exempt per Gov. Code §6103] VICTOR VALLEY UNION HIGH 15 SCHOOL DISTRICT, a business entity of DEFENDANT’S REQUEST FOR form unknown; ERIC LYNN BROWN, an JUDICIAL NOTICE IN SUPPORT OF 16 individual, and DOES 1 through 100, DEFENDANT’S DEMURRER TO THE COMPLAINT OF PLAINTIFF 17 Defendants. [Filed Concurrently with Defendant’s Demurrer to 18 Complaint of Plaintiff and Declaration of Raymond F. Dolen] 19 Date: May 24, 2022 20 Time: 9:00 a.m. Department: S-32 21 22 TO: SAN BERNARDINO COUNTY SUPERIOR COURT and to Plaintiff John 23 VBK Doe and to his attorneys of record: 24 PLEASE TAKE NOTICE that defendant VICTOR VALLEY UNION HIGH 25 SCHOOL DISTRICT requests that the court take judicial notice of the following 26 documents pursuant to California Evidence Code §§45 1, 452 and 453: 27 1. The complaint filed in the Superior Court for the State of California, in and for 28 the County of San Bernardino, Case No. VCVVS 027960 Which complaint was -1- DEFENDANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANT’S DEMURRER TO THE COMPLAINT OF PLAINTIFF V \r filed September 6, 2002; and 2. The request for dismissal filed in Case No. VCVVS 027960 on April 26, 2003. this court to take judicial notice 0f records 0f Evidence Code §452(d) authorizes The complaint and dismissal referenced in Case No. VCVVS any court of this state. constitute such documents. Thus, the court may properly take judicial notice 027960 \OWQONM-PWN thereof. A copy of the complaint is attached hereto has Exhibit “1”. A copy 0f the “2”. dismissal is attached hereto as Exhibit Dated: April (,2022 DOLEN TUCKER TIERNEY & ABRAHAM 10 11 12 WP. Atto DOLEN e s for Defendant, VICTO VALLEY UNION HIGH SCHOOL 13 DISTRICT 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- DEFENDANT’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANT’S DEMURRER TO THE COMPLAINT OF PLAINTIFF