Jane Doe 1 vs Rafael Ramirez et al

SUPERIOR COURT, STATE OF CALIFORNIA COUNTY OF SANTA CLARA Department 1 Honorable Eunice Lee, Presiding TBD, Courtroom Clerk 191 North First Street, San Jose, CA 95113

DATE: September 1, 2026 TIME: 9:00 A.M. and 9:01 A.M. To contest the ruling, call the Court at (408) 808-6856 before 4:00 P.M. Make sure to also let the other side know before 4:00 P.M. that you plan to contest the ruling, in accordance with California Rule of Court, Rule 3.1308(a)(1) and Local Rule 8D.

**Please specify the issue to be contested when calling the Court and counsel**

LAW AND MOTION TENTATIVE RULINGS 9:00 A.M. LINE 1 23CV411676 Brian Claire vs Motion to Set Aside Default/Judgment Manuel Groto et al Scroll down to Line 1 for Tentative Ruling.

LINE 2 24CV430173 Lee (aka Lit) Leong Motion to Quash vs Ashley A. Lopez OFF CALENDAR. On March 26, 2026 the parties notified the court of a settlement agreement. LINE 3 24CV438701 James Bodwin vs Motion for Sanctions Persimmons, Inc. Scroll down to Line 3 for Tentative Ruling.

LINE 4 25CV456187 Curtis Edwad Motion to Compel Responses to Form Interrogatories, Special McGovert vs Q2 Interrogatories, Request for Production of Document, and Sanctions Fiber Communic- Scroll down to Line 4 for Tentative Ruling. ations Inc. et al LINE 5 25CV462288 Kourosh Zahedi et Motion Judgment on the Pleadings al vs Volkswagen Scroll down to Line 5 for Tentative Ruling. Group of America, Inc. et al LINE 6 25CV473786 Jane Doe 1 vs Motion for Change of Venue Rafael Ramirez et al Scroll down to Line 6 for Tentative Ruling.

LINE 7 25CV474250 Adelita Mendez Motion to Disqualify Plaintiff’s Law Firm Gonzalez vs Costco Scroll down to Line 7 for Tentative Ruling. Wholesale Corpor- ation et al LINE 8 25CV477635 Mid-Century Motion to Compel Responses to Request for Production of Insurance Company Documents, and Sanctions vs Justin Collins Scroll down to Line 8 for Tentative Ruling.

LINE 9 25CV480281 Salvador Ortiz vs Motion for Attorneys’ Fees and Costs General Motors Scroll down to Line 9 for Tentative Ruling. LLC

Calendar Line # 6 Case Name Jane Doe 1 vs Rafael Ramirez et al Case No. 25CV473786 Motion for Change of Venue

I. BACKGROUND This case stems from allegations of sexual assault. Plaintiff Jane Doe filed a Complaint on August 27, 2025 against Defendants Pacific Collegiate School (“PCS”), Santa Cruz County Office of Education (“SCCOE”), Rafael Ramirez, Maria Reitano, Trung Lai, and DOES 1 through 10 (collectively “Defendants”). Plaintiff filed a First Amended Complaint on January 15, 2026 alleging five causes of actions, including: (1) sexual abuse of a minor; (2) negligence of SCCOE, PCS employee in hiring, supervision and/or retention of Defendant Lai under Government Code section 815.2; (3) negligence of SCCOE, PCS employee in, supervision of Jane Doe 1 under Government Code section 815.2; (4) negligence of SCCOE, PCS employee in hiring, supervision and/or retention of Defendant Lai; and (5) negligence of SCCOE, PCS employee in, supervision of Jane Doe 1.

On March 24, 2026, the Court heard Defendant Lai’s motion to stay civil proceedings for a period of six months pending Defendant Lai’s criminal case in Santa Cruz County, docket 24CR02808.

Before the Court, is Plaintiff’s motion to change venue. The motion is unopposed. Per Code of Civil Procedure section 1005(b) opposition papers were due on August 19, 2026. A failure to oppose a motion may be deemed a consent to the granting of the motion. (California Rule of Court Rule 8.54(c); Sexton v. Superior Court (1997) 58 Cal.App.4th 1403, 1410). Failure to oppose a motion leads to the presumption that the defendant has no meritorious arguments. (Laguna Auto Body v. Farmers Ins. Exchange (1991) 231 Cal.App.3d 481, 489). Defendants stipulate to Plaintiff’s motion to transfer venue to Santa Cruz County.

II. LEGAL STANDARD Code of Civil Procedure section 395, subdivision (a) provides, in pertinent part:

Except as otherwise provided by law and subject to the power of the court to transfer actions or proceedings as provided in this title, the superior court in the county where the defendants or some of them reside at the commencement of the action is the proper court for the trial of the action.

If the action is for injury to person or personal property or for death from wrongful act or negligence, the superior court in either the county where the injury occurs or the injury causing death occurs or the county where the defendants, or some of them reside at the commencement of the action, is a proper court for the trial of the action.

(Code of Civ. Proc., 395(a)). The burden is on the moving party to establish that the venue selected by Plaintiff is improper. And the moving party has the burden of “negating the propriety of venue as laid on all possible grounds.” (Karson Industries, Inc. v. Superior Court (1969) 273 Cal.App.2d 7, 8-9).

III. ANALYSIS Here, the Plaintiff’s motion to change venue is unopposed and made pursuant to a stipulation by all parties. (Exhibit A, attached to Motion, p. 1). Plaintiff moves to transfer venue from Santa Clara County to Santa Cruz County. It is unopposed that parties reside or conduct business in Santa Cruz County. (Motion, p. 2). Plaintiff claims that the sexual assault occurred in Santa Cruz County. (Id., at p. 3). The Court notes that parties represented that a criminal case was filed and pending in Santa Cruz County, docket number 24CR02808. It is undisputed that this civil case

and criminal matter in Santa Cruz County arise from the same operative factual allegations. Parties stipulate that a transfer to Santa Cruz County will have no adverse inference or legal consequences. (Exhibit A, at p. 4).

The Court finds that Santa Cruz County is the proper venue for this action. The parties stipulate that all parties either reside or conduct business in Santa Cruz County. Moreover, the underlying factual allegations occurred in Santa Cruz County. Criminal charges arising from the same operative facts were filed in Santa Cruz in docket 24CR02808.

IV. CONCLUSION Based on the foregoing, the stipulated motion to change venue in this action to Santa Cruz County is GRANTED. The Court will prepare the formal order.

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