On June 02, 2021 a
Request,Application
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
F I L E
supemon count 0F CALIFORMA
D
coum 0F SAN eenmmomo
_ RYAN D. MILLER (SBN 256799) SAN BERNARDINO CIVIL ownsuou
BARBARA M. MOORE (SBN 1406 1 3)
CUMMINGS, MCCLOREY, DAVIS, ACHO & ASSOCIATES, P.C. AUG 3 1 2023
3801 University Avenue, Suite 560
Riverside, CA 92501
(951) 276-4420
(951) 276-4405 fax
L so}
M
smug; DEPerY
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.: CIVSBZl 15713
Judge: Hon. Donald Alvarez
Plaintiff,
DEFENDANT BARSTOW UNIFIED
v '
SCHOOL DISTRICT’S REQUEST FOR
JUDICIAL NOTICE
BARSTOW UNIFIED SCHOOL
DISTRICT, a California local public entity VVVVVVVVVVVVVVVVV
DATE: September 11, 2023
and DOES 2 t0 100.
TIME: 8:30 a.m.
DEPT.: 823
Defendants.
NamAWN—OOOOQONMAWN—‘o
NNNNNNNN—‘h—‘H——v—n_~—H
Complaint Filed: 6/2/2021
Trial Date: 3/25/2024
TO THE CLERK OF THE COURT, PLAINTIFF JANE BNS DOE AND TO HER
ATTORNEY OF RECORD:
PLEASE TAKE NOTICE that Defendant Barstow Unified School District (hereinafter
the “District” or “Defendant”) hereby requests that the Court take judicial notice of the following
matters or materials set forth below, pursuant to Evidence Code §§ 451 & 452 in support of
Defendant’s Motion for Judgment on the Pleadings.
Evidence Code § 452 states: “Judicial notice may be taken of the following matters to the
28 .”
extent that they are not embraced within Section 45 1 “Records of [ ] any court within the state.”
Cummings, McClorey,
Davis, Acho
& Associates, EC.
380] University Avenue,
Sun: 560
-1-
Rivenlk. (”A 92501
Telephone (95 ) 276-4420
I
Facslmllc (95]) 276-4405
DEFENDANT BARSTOW UNIFIED SCHOOL DISTRICT’S REQUEST FOR JUDICIAL NOTICE
\a \v
l Evidence Code 451(d)(1).
2 Defendant respectfully requests the Court take judicial notice of the following documents
3 filed within this state.
4 Judicial notice is hereby requested of the following documents:
5 1. Order after Hearing in Contra Costa County Superior Coun case no. C22-026l3,
6 filed June l3, 2023, a true and correct copy of which is attached hereto as Exhibit
7 A.
8 2. Respondent’s Brief from case no. C095446 from the Third Appellate District in
9 the State of California, a true and correct copy of which is attached hereto as
10 Exhibit B.
1 l 3 Appellant’s Opening Brief from case no. C097661 from the Third Appellate
12 District in the State of California, a true and correct copy of which is attached
13 hereto as Exhibit C.
14 Dated: September 1, 2023 CUMMINGS, MCCLOREY, DAVIS, ACHO & ASSOCIATES, P.C.
15
16
By:
17
Ryan D. Miller,
Barbara Moore
18
Attorneys for Defendant
19 Barstow Unified School District
20
21
22
23
24
25
26
27
28
Cummings. McClorey.
Dnvis. Acho
a Associates. ?.C.
3801 University Awnuc. - —
Sun: 560
2
Rlvemk. (‘A 9250i
Tel hone 95| 276-4420
Fagmnegosngvoms DEFENDANT BARSTOW UNIFIED SCHOOL DISTRICT’S REQUEST FOR JUDICIAL NOTICE
Document Filed Date
August 31, 2023
Case Filing Date
June 02, 2021
Category
Other PI/PD/WD Unlimited
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Preview
V ORrGINAL F I L E supemon count 0F CALIFORMA D coum 0F SAN eenmmomo _ RYAN D. MILLER (SBN 256799) SAN BERNARDINO CIVIL ownsuou BARBARA M. MOORE (SBN 1406 1 3) CUMMINGS, MCCLOREY, DAVIS, ACHO & ASSOCIATES, P.C. AUG 3 1 2023 3801 University Avenue, Suite 560 Riverside, CA 92501 (951) 276-4420 (951) 276-4405 fax L so} M smug; DEPerY 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.: CIVSBZl 15713 Judge: Hon. Donald Alvarez Plaintiff, DEFENDANT BARSTOW UNIFIED v ' SCHOOL DISTRICT’S REQUEST FOR JUDICIAL NOTICE BARSTOW UNIFIED SCHOOL DISTRICT, a California local public entity VVVVVVVVVVVVVVVVV DATE: September 11, 2023 and DOES 2 t0 100. TIME: 8:30 a.m. DEPT.: 823 Defendants. NamAWN—OOOOQONMAWN—‘o NNNNNNNN—‘h—‘H——v—n_~—H Complaint Filed: 6/2/2021 Trial Date: 3/25/2024 TO THE CLERK OF THE COURT, PLAINTIFF JANE BNS DOE AND TO HER ATTORNEY OF RECORD: PLEASE TAKE NOTICE that Defendant Barstow Unified School District (hereinafter the “District” or “Defendant”) hereby requests that the Court take judicial notice of the following matters or materials set forth below, pursuant to Evidence Code §§ 451 & 452 in support of Defendant’s Motion for Judgment on the Pleadings. Evidence Code § 452 states: “Judicial notice may be taken of the following matters to the 28 .” extent that they are not embraced within Section 45 1 “Records of [ ] any court within the state.” Cummings, McClorey, Davis, Acho & Associates, EC. 380] University Avenue, Sun: 560 -1- Rivenlk. (”A 92501 Telephone (95 ) 276-4420 I Facslmllc (95]) 276-4405 DEFENDANT BARSTOW UNIFIED SCHOOL DISTRICT’S REQUEST FOR JUDICIAL NOTICE \a \v l Evidence Code 451(d)(1). 2 Defendant respectfully requests the Court take judicial notice of the following documents 3 filed within this state. 4 Judicial notice is hereby requested of the following documents: 5 1. Order after Hearing in Contra Costa County Superior Coun case no. C22-026l3, 6 filed June l3, 2023, a true and correct copy of which is attached hereto as Exhibit 7 A. 8 2. Respondent’s Brief from case no. C095446 from the Third Appellate District in 9 the State of California, a true and correct copy of which is attached hereto as 10 Exhibit B. 1 l 3 Appellant’s Opening Brief from case no. C097661 from the Third Appellate 12 District in the State of California, a true and correct copy of which is attached 13 hereto as Exhibit C. 14 Dated: September 1, 2023 CUMMINGS, MCCLOREY, DAVIS, ACHO & ASSOCIATES, P.C. 15 16 By: 17 Ryan D. Miller, Barbara Moore 18 Attorneys for Defendant 19 Barstow Unified School District 20 21 22 23 24 25 26 27 28 Cummings. McClorey. Dnvis. Acho a Associates. ?.C. 3801 University Awnuc. - — Sun: 560 2 Rlvemk. (‘A 9250i Tel hone 95| 276-4420 Fagmnegosngvoms DEFENDANT BARSTOW UNIFIED SCHOOL DISTRICT’S REQUEST FOR JUDICIAL NOTICE