On June 02, 2021 a
Motion-Secondary
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
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MORGAN A. STEWART (State Bar N0. 209852)
mstewart@manlystewart.com
SAUL E. WOLF (State Bar No. 244833)
swolf@manlystewart.com
JENNY R. LOURO (State Bar No. 306535) "
jlouro@manlystewart.com
F m O
MANLY STEWART FINALDI
19100 Von Karman Avenue, Suite 800 cemfiéifiégwa
Irvine, California92612 i
2023
Telephone: (949) 252-9990 MAR 0 1
Facsimile: (949) 252-9991
‘1
,
Attorneys for Plaintiff JANE BNS DOE
’
‘
Dew“ _
'
9v r
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF SAN BERNARDINO
A8
11
LAWYERS
800 JANE BNS DOE, an individual; CASE NO.: CIVSB21 15713
12 Judge: Honorable Donald Alvarez XVd
252—9991
DI
Suite
Dept: $23
Plaintiff,
12 13
FINAL
Ave.,
926 (949)
PLAINTIFF’S OPPOSITIONTO
14 V. DEFENDANT BARSTOW UNIFIED
& CA
(f)
SCHOOL DISTRICT’S MOTION FOR
Karman
15 BARSTOW UNIFIED SCHOOL ORDER ALLOWING DISCOVERY OF
PLAINTIFF’S SEXUAL HISTORY
Irvine,
252-990 DISTRICT, a California local public entity
STEWART
Von
16 and DOES 2 to 100.
Defendants.
00
(949)
Date: March 14, 2023
191’ 17
Time: 8:30 a.m.
MANLY
Dept.:S23
18
19
Complaint Filed: June 2, 2021
20 Trial Date: September 11, 2023
21
TO THE COURT, THE PARTIES, AND THEIR ATTORNEY OF RECORD:
22
PLEASE TAKE NOTICE that Plaintiff Jane BNS Doe (“Plaintiff”) hereby submits her
23
Opposition to Defendant Barstow Unified School District’s (“BUSD”) Motion
for Order
24
Allowing Discovery of Plaintiff’s Sexual History on the basis that BUSD has n0 grounds on
25
which to obtain an order compelling Plaintiff to submit t0 discovery inquiring into her sexual
26
history with third parties. BUSD fails, in good faith, to even attempt to limit the scope of the
27
discovery requested. Rather, BUSD seeks to conduct a fishing expedition into Plaintiff‘s entire
28
l
PLAINTIFF’S OPPOSITION
x, \r
sexual history. This conduct flies in the fact of
Code of Civil Procedure section 2017.220, as well
be denied, in its
as related case law. Such conduct cannot be condoned and the Motion should
entirety.
the attached Memorandum of Points and
This Opposition is based on this Notice,
records and files in this action herein, and
Authorities, the Declaration of Jenny R. Louro, the
upon such further evidence and argument as may be presented, prior to or during the hearing on
the Motion.
MANLY STEWART & FINALDI
LAWYERS
800
10
11
12
Dated: March 1, 2023
By: W fl Law
JEWY MLOURO, ESQ.
Attorneys for Plaintiff
252-9991
Su1te
13
FINALDI.
92612
Ave.,
(949)
14
CA (f)
&
Karman
15
Irvmc,
252-990
STEWART 0n
16
19100V (949)
17
MANLY,
18
19
20
21
22
23
24
25
26
27
28
2
PLAINTIFF’S OPPOSITION
Document Filed Date
March 02, 2023
Case Filing Date
June 02, 2021
Category
Other PI/PD/WD Unlimited
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\r MORGAN A. STEWART (State Bar N0. 209852) mstewart@manlystewart.com SAUL E. WOLF (State Bar No. 244833) swolf@manlystewart.com JENNY R. LOURO (State Bar No. 306535) " jlouro@manlystewart.com F m O MANLY STEWART FINALDI 19100 Von Karman Avenue, Suite 800 cemfiéifiégwa Irvine, California92612 i 2023 Telephone: (949) 252-9990 MAR 0 1 Facsimile: (949) 252-9991 ‘1 , Attorneys for Plaintiff JANE BNS DOE ’ ‘ Dew“ _ ' 9v r SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF SAN BERNARDINO A8 11 LAWYERS 800 JANE BNS DOE, an individual; CASE NO.: CIVSB21 15713 12 Judge: Honorable Donald Alvarez XVd 252—9991 DI Suite Dept: $23 Plaintiff, 12 13 FINAL Ave., 926 (949) PLAINTIFF’S OPPOSITIONTO 14 V. DEFENDANT BARSTOW UNIFIED & CA (f) SCHOOL DISTRICT’S MOTION FOR Karman 15 BARSTOW UNIFIED SCHOOL ORDER ALLOWING DISCOVERY OF PLAINTIFF’S SEXUAL HISTORY Irvine, 252-990 DISTRICT, a California local public entity STEWART Von 16 and DOES 2 to 100. Defendants. 00 (949) Date: March 14, 2023 191’ 17 Time: 8:30 a.m. MANLY Dept.:S23 18 19 Complaint Filed: June 2, 2021 20 Trial Date: September 11, 2023 21 TO THE COURT, THE PARTIES, AND THEIR ATTORNEY OF RECORD: 22 PLEASE TAKE NOTICE that Plaintiff Jane BNS Doe (“Plaintiff”) hereby submits her 23 Opposition to Defendant Barstow Unified School District’s (“BUSD”) Motion for Order 24 Allowing Discovery of Plaintiff’s Sexual History on the basis that BUSD has n0 grounds on 25 which to obtain an order compelling Plaintiff to submit t0 discovery inquiring into her sexual 26 history with third parties. BUSD fails, in good faith, to even attempt to limit the scope of the 27 discovery requested. Rather, BUSD seeks to conduct a fishing expedition into Plaintiff‘s entire 28 l PLAINTIFF’S OPPOSITION x, \r sexual history. This conduct flies in the fact of Code of Civil Procedure section 2017.220, as well be denied, in its as related case law. Such conduct cannot be condoned and the Motion should entirety. the attached Memorandum of Points and This Opposition is based on this Notice, records and files in this action herein, and Authorities, the Declaration of Jenny R. Louro, the upon such further evidence and argument as may be presented, prior to or during the hearing on the Motion. MANLY STEWART & FINALDI LAWYERS 800 10 11 12 Dated: March 1, 2023 By: W fl Law JEWY MLOURO, ESQ. Attorneys for Plaintiff 252-9991 Su1te 13 FINALDI. 92612 Ave., (949) 14 CA (f) & Karman 15 Irvmc, 252-990 STEWART 0n 16 19100V (949) 17 MANLY, 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFF’S OPPOSITION