March 29, 2004
To: Michael Hersh
From: Maura Larkins by FAX only to: 562 949 6518
RE: MEET AND CONFER LETTER REGARDING YOUR REFUSAL TO
ALLOW GINA BOYD TO ANSWER DEPOSITION QUESTIONS
Obviously, in her answer to my complaint Gina Boyd denied receiving
information about arrest records. It would be pretty stupid of me to merely
do as you and your close associate Kelly Angell demand: to simply ask Gina
to repeat that denial orally.
What I am planning to prove is that there is NO EXPLANATION for my being
removed from my classroom on February 12, April 20, and August 13,
2001, and for the lack of any district investigation, and for contract
violations to be supported by the union, other than the fact that Gina Boyd,
Tim O’Neill, Robin Donlan and Linda Watson illegally obtained information.
If your clients have another explanation, I want to hear it. I will ask the court
to compel you to answer questions about it. You know very well that such
questions are well within the scope of discovery in this case. You yourself
wrote to PERB about rumors of my alleged tendency to violence. Why don’t
you want me to hear these rumors? You yourself brought them up!
Please think about this and let me know if you agree to allow Gina to answer
these questions. The fact that these questions are also related to other
cases is irrelevant. In particular, no new evidence can be submitted to
PERB at this time, so your claim that I plan to do so is clearly disingenuous.
By the way, I loved it when you referred to my “prison” records. Do you
mind if I use that quote in the media? It will certainly add to the drama of the
story, won’t it?
I DO NOT interpret the court’s award of sanctions regarding my late
responses to discovery as meaning: The court finds the district and CTA to
have behaved in an honest and just manner, and demands that Plaintiff
give her complete cooperation to these models of integrity, while they
continue to hide the truth.
Rather, I interpret the ruling as a warning meaning: If you want to be in this
race, you’ve got to be able to run with the Big Dogs. I believe the court has
given all the protection from reasonable discovery it is going to give in this
case. I believe that the court wants this shameful matter, which would have
been resolved in the principal’s office if the principal had been competent,
or at the district level if either the school district or the union had been
honest and law-abiding, to be over.
|MEET AND CONFER LETTER REGARDING CTA
REFUSAL TO ALLOW GINA BOYD TO ANSWER
|Maura Larkins v. Chula Vista
Elementary School District
and Related Case Documents