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Demurrer and Motion to Strike to the Complaint by Defendants University of Southern California and Alfred E. Mann Institute For Biomedical Engineering

Factual and Procedural Background

This is a sexual battery case.

On May 23, 2018, plaintiff Jane Doe (“Plaintiff”)(self-represented) was walking on the campus of Santa Clara University when she was subject to a nonconsensual and forcible penetration of a foreign object into her private parts. (Complaint at ¶¶ 14, 23, 37.) The specimen was evaluated by experts and identified as a device with semiconductor components in an expert report received on September 5, 2018. (Id. at ¶¶ 14, 39.)

On December 12, 2018, Plaintiff discovered another suspect specimen that had penetrated her intimate parts against consent. (Complaint at ¶¶ 15, 40.) The foreign object was evaluated by experts and identified as a device with semiconductor components later learned to be of the type developed by defendants University of Southern California (“USC”), A