Nature of Proceedings: Motion: Protective Order; Motion Compel Further Deposition Testimony

Background:

(1) Motion to Compel Further Deposition Testimony

In this action plaintiffs, including plaintiff Monica Ponce Jackson, assert damages against defendant Santa Barbara Graduate School, Inc., dba Pacifica Graduate Institute (Pacifica) based upon Pacifica’s graduate education not having American Psychological Association (APA) accreditation.

On September 25, 2015, defendants took the deposition of Jackson in Houston, Texas.

Prior to the deposition, Jackson had asserted damage claims including emotional distress damages. (Dandillaya decl., ¶ 17.)

At the deposition, Jackson testified that she had enrolled at Pacifica based upon its representation that Pacifica was in the process of obtaining, and would obtain, APA accreditation. (Jackson depo., pp. 42-43 [Jordan decl., exhibit 1].) Graduation from an APA accredited program was necessary for licensure in Texas as a psychologist. (Jack