Tarikh Demekpe v. California State University Dominguez Hills et al

Filing 21

NOTICE OF MOTION AND First MOTION for Summary Judgment as to Genuine Issue of Material Fact filed by defendant Board of Trustees of The California State University. Motion set for hearing on 11/21/2011 at 10:00 AM before Judge Dean D. Pregerson. (At tachments: # 1 Statement of Uncontroverted Facts, # 2 Proposed Order Proposed Order Granting Summary Judgment, # 3 Proposed Judgment, # 4 Declaration Declaration of Ginger Wilson, # 5 Declaration Declaration of Anupama Joshi, # 6 Declarat ion Declaration of Dr. Clarence "Gus" Martin, # 7 Declaration Declaration of Dr. S. Noel Sturm, # 8 Declaration Declaration of Dr. William R. Whetstone, # 9 Declaration Declaration of Dr. Miguel Dominguez, # 10 Declaration Declaration of Susan Westover, # 11 Exhibit Exhibits in Support of MSJ, Volume I, # 12 Exhibit Exhibits in Support of MSJ, Volume II, # 13 Exhibit Exhibits in Support of MSJ, Volume III)(Westover, Susan)

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CALIFORNIA STATE UNIVERSITY
OFFICE OF GENERAL COUNSEL
Christine Helwick (SBN 057274)
Susan Westover (SBN 151211)
401 Golden Shore, 4th Floor
Long Beach, CA 90802-4210
Tel.: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendant Board of Trustees
of the California State University

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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TARIKH DEMEKPE,
Plaintiff,

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vs.
BOARD OF TRUSTEES OF THE
CALIFORNIA STATE
UNIVERSITY,
Defendant.

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Case No. CV11-1177 DDP (MLG)
Date:
Time:
Courtroom:
Judge:

DECLARATION OF DR. MIGUEL
DOMINGUEZ IN SUPPORT OF
DEFENDANT CSU'S MOTION FOR
SUMMARY JUDGMENT
Date of Filing:
Trial Date:

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November 21, 2011
10:00 a.m.
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Hon. Dean D. Pregerson

February 23, 2011
Not Set

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I, Dr. Miguel Dominguez, declare as follows:
1.

I am a Professor in the Modern Languages Department at California State

University, Dominguez Hills.
2.

I served as Chair of the Student Grade Appeals Board after Dr. Whetstone

stepped down from that role during the 2010/2011 academic year.
3.

In January of 2011, Dr. Gus Martin brought to my attention that Tarikh

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Demepke raised a procedural concern over the handling of his grade appeal in HUS 460.

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Dr. Martin explained that Mr. Demekpe was threatening to file a lawsuit, so he had

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offered to have the newly constituted Student Grade Appeals Board re-review the prior
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MSJ: DEC. OF DR. M. DOMINGUEZ

Case No. CV11-1177 DDP (MLG)

Board's
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Appeals

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and agreed

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Iagreement in an

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5.

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concurred with

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Iresponsive

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9 ! the prior Board} s
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7.

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Demekpc had

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the two students on

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Itheir input.

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sent

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I be dropped.

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Exhibit No. 50.

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R.

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vote, the Bmu'd

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deny the grade

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9.

On

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I declare

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this declaration

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, I prepared the

Dcmekpe

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existed

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MSJ:

under the
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PROOF OF SERVICE
Demekpe v. Board of Trustees of the California State University
U.S. District Court Case No.: CV11-1177 DDP (MLG)
OGC No.: 11-0186
I, Jason T. Taylor, declare as follows:
I am employed in the County of Los Angeles, State of California. I am at least 18 years
old, and not a party to this action. I am an employee of California State University,
Office of General Counsel, whose business address is 401 Golden Shore, 4th Floor,
Long Beach, CA 90802-4210.

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On October 17, 2011, I served the document described as DECLARATION OF DR.
MIGUEL DOMINGUEZ IN SUPPORT OF DEFENDANT CSU’S MOTION FOR
SUMMARY JUDGMENT on the interested parties in this action as follows:
Tarikh Demekpe
688 Caliburn Drive, #24
Los Angeles, CA 90001

Plaintiff In Pro Per
[e-mail]
Tel: [phone]

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BY MAIL—COLLECTION BOX: I placed each document in a sealed envelope
with postage fully prepaid, in the California State University Office of General
Counsel’s mail collection box in Long Beach, California, so that following
ordinary business practices, the envelope would be collected and mailed on this
date. I am readily familiar with this office's business practice for collection and
processing of mail. In the ordinary course of business, each document would be
deposited with the United States Postal Service on that same day.
BY E-MAIL: I served each document on the parties by emailing each document
in PDF format to each email address listed above. Each e-mail was successfully
sent via CSU’s email server.
Signed on October 17, 2011, at Long Beach, California. I declare under penalty of
perjury under the laws of the State of California that this declaration is true and correct.

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Jason T. Taylor
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MSJ: DEC. OF DR. M. DOMINGUEZ

Case No.: CV11-1177 DDP (MLG)