On June 02, 2021 a
Order of Examination
was filed
involving a dispute between
Doe, Jane Bns,
and
Barstow Unified School District,
Doe 1,
Does 2 To 100,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
V ORrGINAL
SUPER E LI 1':
_‘
RYAN D. MILLER (SBN 256799) ‘
Sffiudgggggfig Di IFO
‘
BARBARA M. MOORE (SBN 1406 1 3) BERNARD N’A
NS g‘fiwmww
CUMMINGS, MCCLOREY, DAVIS, ACHO & ASSOCIATES, P.C. DIVISION
JUL 6 2023
3801 University Avenue, Suite 560
Riverside, CA 92501
(951) 276—4420
(951) 276-4405 fax
EXEMPT PER GOV. CODE m§ ‘63
Attorneys for Defendant
Barstow Unified School District
FAX
SUPERIOR COURT OF THE STATE OF CALIFORNIA
BY FOR THE COUNTY OF SAN BERNARDINO
JANE BNS DOE, AN INDIVIDUAL, ) Case No.: CIVSBleS713
) Judge: Hon. Donald Alvarez
)
Plaintiff,
) JOINT STIPULATION FOR MENTAL
v.
EXAMINATION OF PLAINTIFF JANE
3
BNS DOE ANDTPROFOSEB] ORDER
)
BARSTOW UNIFIED SCHOOL )
DISTRICT, a California local public entity
g
and DOES 2 t0 100.
)
)
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Defendants. )
) Complaint Filed: 6/2/2021
Trial Date: 9/11/2023
g
NQUILWNHOOOOflamng—‘O
STIPULATION
IT IS HEREBY STIPULATED by and between Plaintiff, JANE BNS DOE (“Plaintiff’),
and Defendant BARSTOW UNIFIED SCHOOL DISTRICT (“District”) through their respective
counsel as follows:
1. Plaintiff JANE BNS DOE will appear and submit to an Independent Mental
Examination (“IME”) pursuant to Code 0f Civil Procedure section 2032.010 et seq. at the
request 0f District on July 28, 2023 at 10:00 a.m. District has retained Kristina Malek, Ph.D.
(“Examiner”) to conduct the IME. The following terms and conditions apply to the IME.
28 2. The IME will include psychological assessments that shall be administered by the
Cummings, McClorey,
Davis, Acho
& Associates, P.C.
3801 University Avenue,
Suite 560 -1-
Riverside, CA 9250]
Telephone (95|)276-4420
Facsimile (9S l) 270-4405
JOINT STIPULATION FOR MENTAL EXAMINATION OF PLAINTIFF JANE BNS DOE
Examiner or her staff. The Examiner may administer any or all 0f the following assessments:
o ACE Questionnaire
o SIMS. If SIMS is elevated, I would administer the SlRS—Z
o PCL-5 with LEC-S and Criterion A. If elevated, Iwould follow up With the CAPS—S
OOONONKJI-bWNt—
0 DAPS
o Personality Assessment Inventory (PAI)
O SPECTRA: Indices of Psychopathology
3. The IME shall not exceed six (6) hours in total, and Plaintiff shall be afforded up
to a thirty (3 0) minute lunch break.
4. Pursuant to Code of Civil Procedure, Section 2017.220, the Examiner shall not
ask Plaintiff any questions about her sexual conduct with anyone other than the alleged
perpetrator, John Chiarella.
5. Neither party, nor their counsel, shall Video the examination. The entirety 0f the
IME may, however, be audio recorded by any party. There will be n0 interruptions with the
examination to address any technical difficulties with audio recordation of the examination, nor
Will the breaks be used t0 address any technical issues.
6. During the IME, no one else shall be present in the room other than the Examiner
NNNNNNNNP—‘flb—‘flb—tr—Ip—AHHH
flam-RUJNHOQOONQM-bWNF-‘O
and Plaintiff. The Examiner will give Plaintiff instructions on how to take the assessments and
will answer questions by Plaintiff about the assessments.
7. District’s counsel shall provide the Examiner with a copy of this Stipulation and
advise her that she must comply with the terms set forth herein. By proceeding with the IME, the
Examiner will be deemed to have consented to the terms 0f this Stipulation.
8. The examination shall not be construed as a waiver 0f Plaintiff” s right to privacy
in the information divulged at the examination.
9. The District shall pay for the cost 0f the Examiner’s service to conduct the
examination. The District shall pay for Plaintiff” s reasonable travel costs consisting ofher airfare
to/from Washington t0 California and if needed, an Uber or similar transportation to/from the
28 airport in California t0 the location of the examination or to/from the location where Plaintiff
Cummings. McClorey,
plans to lodge in the Vicinity of the location of the examination. Upon receipt from Plaintiff of
Davis, Acho
& Associates, P.C.
380] University Avenue,
Suitc 560 -2-
Riverside, CA 92501
Telephone (95 ) 276-4420
I
Facsimile (951) 270-1405
JOINT STIPULATION FOR MENTAL EXAMINATION OF PLAINTIFF JANE BNS DOE
Document Filed Date
July 06, 2023
Case Filing Date
June 02, 2021
Category
Other PI/PD/WD Unlimited
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V ORrGINAL SUPER E LI 1': _‘ RYAN D. MILLER (SBN 256799) ‘ Sffiudgggggfig Di IFO ‘ BARBARA M. MOORE (SBN 1406 1 3) BERNARD N’A NS g‘fiwmww CUMMINGS, MCCLOREY, DAVIS, ACHO & ASSOCIATES, P.C. DIVISION JUL 6 2023 3801 University Avenue, Suite 560 Riverside, CA 92501 (951) 276—4420 (951) 276-4405 fax EXEMPT PER GOV. CODE m§ ‘63 Attorneys for Defendant Barstow Unified School District FAX SUPERIOR COURT OF THE STATE OF CALIFORNIA BY FOR THE COUNTY OF SAN BERNARDINO JANE BNS DOE, AN INDIVIDUAL, ) Case No.: CIVSBleS713 ) Judge: Hon. Donald Alvarez ) Plaintiff, ) JOINT STIPULATION FOR MENTAL v. EXAMINATION OF PLAINTIFF JANE 3 BNS DOE ANDTPROFOSEB] ORDER ) BARSTOW UNIFIED SCHOOL ) DISTRICT, a California local public entity g and DOES 2 t0 100. ) ) NNNNNNNNt—‘Hr—IHH—tt—tp—AHH Defendants. ) ) Complaint Filed: 6/2/2021 Trial Date: 9/11/2023 g NQUILWNHOOOOflamng—‘O STIPULATION IT IS HEREBY STIPULATED by and between Plaintiff, JANE BNS DOE (“Plaintiff’), and Defendant BARSTOW UNIFIED SCHOOL DISTRICT (“District”) through their respective counsel as follows: 1. Plaintiff JANE BNS DOE will appear and submit to an Independent Mental Examination (“IME”) pursuant to Code 0f Civil Procedure section 2032.010 et seq. at the request 0f District on July 28, 2023 at 10:00 a.m. District has retained Kristina Malek, Ph.D. (“Examiner”) to conduct the IME. The following terms and conditions apply to the IME. 28 2. The IME will include psychological assessments that shall be administered by the Cummings, McClorey, Davis, Acho & Associates, P.C. 3801 University Avenue, Suite 560 -1- Riverside, CA 9250] Telephone (95|)276-4420 Facsimile (9S l) 270-4405 JOINT STIPULATION FOR MENTAL EXAMINATION OF PLAINTIFF JANE BNS DOE Examiner or her staff. The Examiner may administer any or all 0f the following assessments: o ACE Questionnaire o SIMS. If SIMS is elevated, I would administer the SlRS—Z o PCL-5 with LEC-S and Criterion A. If elevated, Iwould follow up With the CAPS—S OOONONKJI-bWNt— 0 DAPS o Personality Assessment Inventory (PAI) O SPECTRA: Indices of Psychopathology 3. The IME shall not exceed six (6) hours in total, and Plaintiff shall be afforded up to a thirty (3 0) minute lunch break. 4. Pursuant to Code of Civil Procedure, Section 2017.220, the Examiner shall not ask Plaintiff any questions about her sexual conduct with anyone other than the alleged perpetrator, John Chiarella. 5. Neither party, nor their counsel, shall Video the examination. The entirety 0f the IME may, however, be audio recorded by any party. There will be n0 interruptions with the examination to address any technical difficulties with audio recordation of the examination, nor Will the breaks be used t0 address any technical issues. 6. During the IME, no one else shall be present in the room other than the Examiner NNNNNNNNP—‘flb—‘flb—tr—Ip—AHHH flam-RUJNHOQOONQM-bWNF-‘O and Plaintiff. The Examiner will give Plaintiff instructions on how to take the assessments and will answer questions by Plaintiff about the assessments. 7. District’s counsel shall provide the Examiner with a copy of this Stipulation and advise her that she must comply with the terms set forth herein. By proceeding with the IME, the Examiner will be deemed to have consented to the terms 0f this Stipulation. 8. The examination shall not be construed as a waiver 0f Plaintiff” s right to privacy in the information divulged at the examination. 9. The District shall pay for the cost 0f the Examiner’s service to conduct the examination. The District shall pay for Plaintiff” s reasonable travel costs consisting ofher airfare to/from Washington t0 California and if needed, an Uber or similar transportation to/from the 28 airport in California t0 the location of the examination or to/from the location where Plaintiff Cummings. McClorey, plans to lodge in the Vicinity of the location of the examination. Upon receipt from Plaintiff of Davis, Acho & Associates, P.C. 380] University Avenue, Suitc 560 -2- Riverside, CA 92501 Telephone (95 ) 276-4420 I Facsimile (951) 270-1405 JOINT STIPULATION FOR MENTAL EXAMINATION OF PLAINTIFF JANE BNS DOE