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v ORrGINAL
F l LE D
a COURT 0F CALIFORNIA
SLéPoESrijgrY 0F SAN BERNARDINO
DISTRICT
SAN BERNARDlNo
.— RYAN D. MILLER (SBN 256799)
’%~
BARBARA M. MOORE (SBN 140613) JAN 1 7 2023
CUMMINGS, MCCLOREY, DAVIS, ACHO & ASSOCIATES, P.C.
3801 University Avenue, Suite 560
Riverside, CA 92501
BY”- a" mm“ Dewy
(951) 276-4420
(951) 276-4405 fax
EXEMPT PER GOV. CODE § 6103
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,
DECLARATION OF GLENN SCOTT
LIPSON, PH.D. IN SUPPORT OF
V' DISTRICT’S MOTION FOR ORDER
ALLOWING DISCOVERY 0F
BARSTOW UNIFIED SCHOOL PLAINTIFF’S SEXUAL HISTORY
DISTRICT, a California local public entity _
and DOES 2 t0 100. [Flled concurrently with Notice 0f Motion
and Motion for Order for Discovery Re
Defendants.
dvvvvvvvvvvvvvvvvvvvvvvv
Plaintiff’s Sexual History, Supporting
NNNNNNNN—‘r—d—v—HHHp—‘p—‘H
Declarations of Barbara M. Moore and
[Proposed] Order]
QQUI-bWNHOQWNONM-PWNHO
Date: March 14, 2023
Time: 8:30 am
Dept: 823
Complaint Filed: June 2, 2021
Trial Date: None
28
Cummings, McClorey,
Davis. Acho
& Associates, P.C.
3801 University Avenue.
Suite 560
-1-
Riverside, CA 92501
Telephone (95 l
) 276—4420
Facsimile (95 1) 276-4405 DELCARATION OF GLENN SCOTT LIPSON
I, Dr. Glenn Lipson, declare:
1. I have personal knowledge of the matters contained herein, except for those
matters stated on information and belief, and if called as a witness to testify to these matters, I
could and would competently do so.
2. I received my Doctor of Clinical Psychology from the California School of
OOONQUIAUJN
Professional Psychology in 1986. I performed my post-doctorate studies at The Menninger
Postgraduate Diagnostic Training Program from 1986 t0 1987, and at Clinical Psychology
Fellowship, Karl Menninger School 0f Psychiatry and Behavioral Health Sciences‘ from 1987 t0
1989. I am California Licensed Psychologist, License No. PSY 1 1335, since 1989; and a Nevada
10 Licensed Psychologist, License N0. PY0375, since 1999. I have worked in private clinical and
11 forensic psychology since 1993. I have treated patients dealing with many different
12 psychological, mental, 0r emotional problems, including, but not limited t0, survivors 0f sexual
13 abuse and sexual trauma. Ihave been retained in sexual harassment, abuse, and assault cases by
14 both plaintiffs and defendants in employment, criminal, personal injury, and childhood sexual
15 cases just t0 name a few.
16 3. In my professional experience and opinion, the meaning assigned by a person to
17 sexual contact varies depending upon the persons experiences, religious beliefs and community.
18 Therefore, the degree of harm to a person is influenced by the meaning they assign to the event.
19 Moreover, the degree of trauma assigned to an event 0f sexual contact depends on the person’s
20 history, resiliency, and risk factors.
21 4. It is in part for these reasons that inquiry into a sexual abuse survivor’s sexual
22 history in both a sensitive and limited way is necessary to understand the nature of their
23 psychological injuries. This is especially applicable to situations involving claims of sexual
24 harassment, assault, and abuse because without the additional information gathered by asking
25 non-invasive questions about the examinee’s experience in sexual relationships, the proximate
26
27
28
1
The Karl Menninger School of Psychiatry and Behavioral Health Science was located in Topeka,
Kansas during Dr. Lipson’s postdoctoral training.
Cummings, McCIorey,
Davis, Acho
& Associates, P.C.
3801 University Avenue,
Suite 560
Riverside. CA 92501 -1 _
Telephone (95 l) 276-4420
Facsimile (951) 1764405 DECLARATION 0F GLENN LIPSON, PHD.
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v ORrGINAL F l LE D a COURT 0F CALIFORNIA SLéPoESrijgrY 0F SAN BERNARDINO DISTRICT SAN BERNARDlNo .— RYAN D. MILLER (SBN 256799) ’%~ BARBARA M. MOORE (SBN 140613) JAN 1 7 2023 CUMMINGS, MCCLOREY, DAVIS, ACHO & ASSOCIATES, P.C. 3801 University Avenue, Suite 560 Riverside, CA 92501 BY”- a" mm“ Dewy (951) 276-4420 (951) 276-4405 fax EXEMPT PER GOV. CODE § 6103 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, DECLARATION OF GLENN SCOTT LIPSON, PH.D. IN SUPPORT OF V' DISTRICT’S MOTION FOR ORDER ALLOWING DISCOVERY 0F BARSTOW UNIFIED SCHOOL PLAINTIFF’S SEXUAL HISTORY DISTRICT, a California local public entity _ and DOES 2 t0 100. [Flled concurrently with Notice 0f Motion and Motion for Order for Discovery Re Defendants. dvvvvvvvvvvvvvvvvvvvvvvv Plaintiff’s Sexual History, Supporting NNNNNNNN—‘r—d—v—HHHp—‘p—‘H Declarations of Barbara M. Moore and [Proposed] Order] QQUI-bWNHOQWNONM-PWNHO Date: March 14, 2023 Time: 8:30 am Dept: 823 Complaint Filed: June 2, 2021 Trial Date: None 28 Cummings, McClorey, Davis. Acho & Associates, P.C. 3801 University Avenue. Suite 560 -1- Riverside, CA 92501 Telephone (95 l ) 276—4420 Facsimile (95 1) 276-4405 DELCARATION OF GLENN SCOTT LIPSON I, Dr. Glenn Lipson, declare: 1. I have personal knowledge of the matters contained herein, except for those matters stated on information and belief, and if called as a witness to testify to these matters, I could and would competently do so. 2. I received my Doctor of Clinical Psychology from the California School of OOONQUIAUJN Professional Psychology in 1986. I performed my post-doctorate studies at The Menninger Postgraduate Diagnostic Training Program from 1986 t0 1987, and at Clinical Psychology Fellowship, Karl Menninger School 0f Psychiatry and Behavioral Health Sciences‘ from 1987 t0 1989. I am California Licensed Psychologist, License No. PSY 1 1335, since 1989; and a Nevada 10 Licensed Psychologist, License N0. PY0375, since 1999. I have worked in private clinical and 11 forensic psychology since 1993. I have treated patients dealing with many different 12 psychological, mental, 0r emotional problems, including, but not limited t0, survivors 0f sexual 13 abuse and sexual trauma. Ihave been retained in sexual harassment, abuse, and assault cases by 14 both plaintiffs and defendants in employment, criminal, personal injury, and childhood sexual 15 cases just t0 name a few. 16 3. In my professional experience and opinion, the meaning assigned by a person to 17 sexual contact varies depending upon the persons experiences, religious beliefs and community. 18 Therefore, the degree of harm to a person is influenced by the meaning they assign to the event. 19 Moreover, the degree of trauma assigned to an event 0f sexual contact depends on the person’s 20 history, resiliency, and risk factors. 21 4. It is in part for these reasons that inquiry into a sexual abuse survivor’s sexual 22 history in both a sensitive and limited way is necessary to understand the nature of their 23 psychological injuries. This is especially applicable to situations involving claims of sexual 24 harassment, assault, and abuse because without the additional information gathered by asking 25 non-invasive questions about the examinee’s experience in sexual relationships, the proximate 26 27 28 1 The Karl Menninger School of Psychiatry and Behavioral Health Science was located in Topeka, Kansas during Dr. Lipson’s postdoctoral training. Cummings, McCIorey, Davis, Acho & Associates, P.C. 3801 University Avenue, Suite 560 Riverside. CA 92501 -1 _ Telephone (95 l) 276-4420 Facsimile (951) 1764405 DECLARATION 0F GLENN LIPSON, PHD.