092704 Nevitt statements
Main Timeline
Motivations CP teachers
Case Summary
2003 Stutz invoices
2002 SDCOE payments
to Daniel Shinoff
2003 part 2 Stutz invoices
Public Records Requests
SDCOE Crosier denial
Payments to Shinoff
Maura Larkins
v. CVESD
Stutz Artiano Shinoff & Holtz
defamation lawsuit against
Maura Larkins
for statements on this website
Testimony on this page:

Kostic and Larkins together examine mauralarkins.com

Diane Crosier hid 2005 tort claim
regarding perjury 129; see also 135

Rodger Hartnett
Deposition of Maura Larkins
by Ljubisa Kostic
June 16, 2008

Pages 124 to 138
4 Q. We have subornation of perjury. We have
5 hiding documents.

6 What else had Stutz done that is corrupt and
7 unethical?

8 A. Well, maybe we should look at my Web site.

9 Q. Okay. Let's take a very quick break and
10 then we'll come back and we'll get the computer going,
11 and we are going to take a look at your Web site.

12 A. Okay.

13 (Recess taken.)

14 BY MR. KOSTIC:

15 Q. Ms. Larkins, what we have done here now is I
16 put up a laptop and I am on the Internet with it, and
17 we are at www.mauralarkins.com.

18 A. Um-hmm.

19 Q. Are you able to see the screen okay?

20 A. Yes, I am.

21 Q. Let me know if at any time the glare gets in
22 your way. What I am going to do is from time to time
23 we are just going to print a copy of what is on our
24 screen. I will have you confirm that it's a true and
25 correct copy, and we'll attach that as our exhibits.

125

1 A. Okay.

2 Q. So we appear to be on what they usually call
3 a "landing page." It's the very front page of your
4 Web site.
5 Is that what we are looking at?

6 A. Yes.
7 Q. What I am going to do is I am going to hit
8 "print" and then I am going to go print off a copy and
9 we will mark it as our first exhibit. I will print
10 off a copy of it.
11 Ms. Larkins, what I did is I printed a copy
12 of what we are looking at. I can tell already that
13 there are a couple of places where the print kind of
14 overlaps.

15 A. Okay.

16 Q. So what I am going to do is I will just read
17 into the record those portions that you can't see.
18 So, for example, on Page 1 if you look at
19 where it says,

"The County Board of Education has an
20 improper relationship with," so then we can't see what
21 it says. But on the computer it says, "with legal
22 corporations which care nothing about our children,"
23 period.

24 "The San Diego County Board of Education
25 Joint Powers Authority,"
and then, once again, we can
page 126
1 see it on the exhibit,
"shields its panel of approved
2 defense attorneys from legal responsibility."
3 Did I read that correctly into the record
4 from the computer monitor?

5 A. I believe so.

6 Q. Now, on what is Page 3 of the printout,
7 there appears to be a similar problem. Okay. Right
8 after where it says,
"Easier to throw good money after
9 bad."

10 A. Um-hmm.

11 Q. Once again, I am going to read from the Web
12 site,
"CVESD board members and administrators were not
13 using their own money. They were using the taxpayer's
14 money. SDCOE-JPA and its member districts have left
15 no paper trail regarding their use of taxpayer dollars
16 to defend lawyers who break the law."
17 I think I have now read everything that is
18 not legible on my printout.
19 Did I read it correctly?

20 A. I believe so.

21 Q. I think those are the only things I wanted
22 to correct. Do you want to take the time to see if
23 what I printed appears to you to be -- other than is
24 corrected, what's --

25 A. No. I would rather just accept it.


127

1 Q. It does have, you know --

2 A. Yeah, yeah.

3 (Exhibit 1 was marked for identification.)

4 BY MR. KOSTIC:

5 Q. At the bottom of the page it has the Web
6 site. It has the date I printed it. I will represent
7 on the record that I printed it directly from my
8 computer to a printer.
9 What I am going to attach as Exhibit No. 1
10 is the printout of what you and I are looking at on
11 the landing page of your Web site.
12 Okay. Now, it looks to me like there are
13 some links and, from time to time, I am going to click
14 on them and ask you some questions. We are going to
15 start at the top. Okay, it says at the top here,
16 second paragraph,
"The San Diego County Board of
17 Education Joint Powers Authority shields panel of
18 approved defense attorneys from legal responsibility
19 when they violate the law on behalf of school
20 districts."

21 What information do you have that the
22 San Diego Board of Education JPA does that?

23 A. Well, for one example of the proof is I
24 filed a tort claim about perjury by -- well, first of
25 all, I just sent letters to the JPA and Diane Crosier
page 128
1 about the perjury and the whole case that was covering
2 up criminal actions. There was no response and then I
3 filed a tort claim
and it was -- you know what, can I
4 go to a Web page that talks about this?

5 Q. Okay.

6 A. Let's see if I can remember which one it is.
7 It is the one about Diane Crosier. Let me do a
8 search -- oh, you know what, sometimes I am not good
9 at navigating my own site. Let me just tell you what
10 I remember.
11 Then -- it was not that long ago; it was
12 just a few months ago -- I called up Diane Crosier.
13 She answered the phone and I said that I was looking
14 for a tort -- the tort claim that I filed in 2005, and
15 she said she could not see it. She looked it up on
16 her computer and she said she didn't see it. That was
17 the one about perjury.

18 Q. Okay.

19 A. She said, "Maybe it got put in with the 2004
20 tort claim." She said, "Was it a continuing action?"
21 I said, "No. It was completely separate."
22 So there is one way in which she was
23 covering up -- was the perjury. First of all, she
24 ignored the letters about the perjury. Then when she
25 got a tort claim about it, she hid it. It doesn't
SCHULER COURT REPORTING - 858.518.1619
129
1 even show up on the computer.
2 Q. So you think she is hiding it because it did
3 not show up on her computer?
4 A. Yeah, or -- yeah, she is in charge, and it
5 might be nice to ask her again where it is now.
6 Q. This is your tort claim?
7 A. Yeah.
8 Q. Was there any response to your tort claim?
9 A. I believe there was.
10 Q. So for a time it was not hidden?
11 A. Well, I am not sure it ever appeared on the
12 computer.
13 Q. From whom do you think Diane Crosier was
14 hiding your tort claim, to which you received a
15 response?
16 A. Anybody who might want to know how that tort
17 claim was handled.
18 Q. From whom did you receive a response?
19 A. San Diego County Office of Education.
20 Q. Do you know if the response was also
21 carefully hidden?
22 A. Well, I assume it is wherever the tort claim
23 is. It is with the tort claim.
24 Q. But you have both the tort claim and the
25 response in your possession.

130
1 A. Yes.
2 Q. Have you published those on your Web site to
3 expose Diane Crosier?
4 A. Yeah. I think I published the tort claim.
5 Aren't you shocked that a public entity
6 would try to hide a complaint about lawyers suborning
7 perjury?
8 Q. Well, I am not here to answer your
9 questions. If you want to notice of my deposition,
10 you know, feel free. I don't think you will be able
11 to, but...
12 A. It was rhetorical. Mr. Kostic, I am not
13 going to notice your deposition.
14 Q. I appreciate that. Let's take a look here.
15 It says that, "The San Diego County Office of
16 Education JPA does not even have a written contract
17 with its favorite lawyer, Daniel Shinoff."
18 How did you find out that there is no
19 written contract between the SDCOE-JPA and
20 Mr. Shinoff?
21 A. Some of my information came from board
22 meetings at Grossmont Union High School District when
23 they were fighting over lawyers. A lot of information
24 came out then, when former superintendent Terry Ryan
25 was trying to defend Shinoff and keep Shinoff, and he


131
1 did succeed in keeping Shinoff. He just did not
2 succeed in keeping himself.
3 He said that -- now, this was just
4 Grossmont -- well, wait a minute. You know, it was
5 done at a school board meeting.
6 So it is available on DVD, the whole
7 meeting. I made a transcript of large parts of it.
8 He said that he had -- that they just had a
9 gentlemen's agreement with Stutz, Artiano, with
10 Dan Shinoff at Stutz.
11 He was talking a lot about the
12 superintendents who are involved in San Diego County
13 Office of Education JPA, and he was always also
14 talking about Grossmont Union. I think he must have
15 said something about SDCOE, for me to have written
16 that. I will have to go back and look at the my
17 little transcript of the board meeting.
18 Q. If it turns out that at the board meeting
19 that you are talking about -- that was a
20 Grossmont Union High School District meeting?
21 A. Yeah, um-hmm.
22 Q. If it turns out that the information was --
23 whether or not there was a written agreement between
24 Mr. Shinoff and/or his firm on the one hand and
25 Grossmont Union High School District on the other;

page 132
1 meaning, that there was nothing discussed about an
2 agreement between SDCOE-JPA and Mr. Shinoff, will you
3 then retract the statement from your Web site?
4 A. Yes, gladly.
5 Q. Will you post something that says that you
6 had inaccurate information on your Web site and you
7 have now changed it to --
8 A. Yeah. If you have looked over my Web site,
9 you will see that I have that in a few places, where I
10 have a correction box.
11 Q. Now, skipping down to the paragraph that
12 says, "If she really cared about taxpayers, she
13 wouldn't have a secret agreement with the Stutz Law
14 Firm," that is referring to Diane Crosier has a secret
15 agreement with the Stutz firm?
16 A. Um-hmm.
17 Q. What is the nature of the secret agreement
18 between Diane Crosier and the Stutz firm?
19 A. Well, I was referring to the gentlemen's
20 agreement that was not written down.
21 Q. Oh, you mean the agreement between the law
22 firm and the San Diego County Office of Education JPA?
23 A. Yes.
24 Q. How do you know it's a secret agreement?
25 A. Well, it is certainly a secret from the

133
1 public if it is not even written down. It is just a
2 gentlemen's agreement done verbally between a few
3 insiders.
4 Q. What is your understanding about the nature
5 of that gentlemen's agreement? What does it pertain
6 to, the agreement?
7 A. The hourly rates and -- well, just that he
8 will be chosen. You may have heard recently that
9 Rodger Hartnett filed a lawsuit against San Diego
10 County Office of Education. Apparently, San Diego
11 County Office of Education has a $3 million budget for
12 legal fees, and it was supposed to be shared between
13 Stutz and another law firm -- might have been Best,
14 Best & Krieger. I am not really sure about that,
15 though. But it turned out that Stutz had the lion's
16 share of it and that this was against the original
17 agreement.
18 So that is the sort of thing that I am
19 talking about when I say, you know, these
20 off-the-record agreements that result in this -- Stutz
21 being given legal work that is not according to the
22 plan that was laid out on paper.
23 Q. Who do you understand to have laid out this
24 plan on paper about who should get what legal work?
25 A. I don't know. Maybe I should subpoena
page 134

1 Rodger Hartnett.

2 Q. Is Mr. Hartnett a good guy? He is one of
3 the good guys?

4 A. I believe that there is good and evil in
5 everybody. What do you think? Do you think
6 Mr. Hartnett is one of the good guys?

7 Q. I have never met the man in my life. This
8 is why we need to stick to you answering my questions.
9 Remember how in the beginning I told you
10 that just because I am asking you something, doesn't
11 mean I do or don't know it?

12 A. What is the meaning of that, "Is
13 Mr. Hartnett a good guy?" Are you getting snide
14 again?

15 Q. Diane Crosier is someone who you think is
16 doing wrong with the San Diego County Office of
17 Education, true?

18 A. Yes.

19 Q. Is Mr. Hartnett part of that wrong?

20 A. Not now. He has been fired.

21 Q. Before he was fired, was he was part of the
22 wrong that Diane Crosier --

23 A. Yes.

24 Q. That is what I meant. Okay. So
25 Mr. Hartnett is complicit with Diane Crosier in her
page 135
1 secret agreement with Daniel Shinoff?

2 A. Oh, I have no idea about that. All I know
3 is he is the one that rejected my first tort claim.
4 If you have seen on my site, they have a policy of
5 rejecting all tort claims.
6 Of course anybody who rejects all tort
7 claims, they know they are doing wrong. They know
8 that not every single tort claim is -- lacks merit.

9 Q. Now, you said that the gentlemen's agreement
10 or the secret agreement is Mr. Shinoff's hourly rate,
11 plus the fact that he would be chosen?

12 A. Yes.

13 Q. Explain to me what you mean by "that he
14 would be chosen."

15 A. Well, for example, that he would -- Stutz,
16 his law firm, would be chosen over the other law firm,
17 which I think was Best, Best & Krieger.

18 Q. Do you know who at San Diego County Office
19 of Education JPA gets to decide which law firm gets
20 which case?

21 A. I am under the impression that it is
22 Diane Crosier.

23 Q. Do you know if Ms. Crosier has that
24 authority as part of her duties for SDCOE-JPA; in
25 other words, that it is part of her job to make that
                                                                                 page 136
1 decision?

2 A. Well, you're differentiating authority and
3 power and reality. I don't know as far as whatever is
4 written down is supposedly who is supposed to do it.
5 I have no idea what that says. I do believe that she
6 has the power to do it.

7 Q. Does she have the right to do it?

8 A. As long as she obeys the law.

9 Q. What kinds of laws does she need to obey in
10 choosing who to give legal work to?

11 A. Not to give it to people who violate the
12 law.

13 Q. All right. Do you know if Diane Crosier
14 believes that Daniel Shinoff and our firm violates the
15 law?

16 A. If she read her mail, she does.

17 Q. So Diane Crosier's mail makes it obvious
18 that the Stutz firm and Daniel Shinoff violate the
19 law?

20 A. I sent her documentation. I sent her enough
21 documentation. If she read it, she would know.

22 Q. Is that the same documentation that you are
23 going to use in this case in order to prove that the
24 things on your Web site are true?

25 A. It is a small part of it.



137
1 Q. Now it says,
"While the SDCOE board looks
2 the other way, Diane Crosier and her cronies at public
3 entities and law firms put into practice the motto,"
4 quote, "Win if you can win fairly. But if you can't
5 win fairly, cheat. And be sure to do it all with
6 taxpayer dollars."
7 How did you find out that this is
8 Diane Crosier's and her cronies' motto?

9 A. I witnessed it firsthand.

10 Q. Did they chant the motto?

11 A. No. They put it into practice. I never
12 said that they chanted it or wrote it down or said it.
13 I said they put it into practice.

14 Q. Okay. So first they try to win fairly. But
15 if they can't win fairly, they cheat.

16 A. Yes.

17 Q. All the while they make sure it is all with
18 taxpayer dollars.

19 A. Yes.

20 Q. Who should pay to defend lawsuits against
21 public entities?

22 A. The taxpayers.

23 Q. For example, when you say --

24 A. Wait a minute. I really need to say more.

25 Q. Okay.


page 138
1 A. The taxpayers, unless the public entities
2 have committed crimes or other violations of law.

3 Q. Then who should pay?

4 A. The people who committed the crimes or
5 violations of law.
SDCOE-JPA shields panel of
defense attorneys
page 127

Diane Crosier
hid my 2005
tort claim regarding perjury;
(Discussed on page 129 of
deposition)
"The San Diego County
Board of Education Joint
Powers Authority" webpage
Deposition of
Maura Larkins



Lozano Smith order/  
Shinoff tactics
pages 73 to 80


Judge Ahler OAH
page 89-91

Is Shinoff or Mark
Bresee to blame?
pages 91-94

pages 95-105

pages 105-111

pages 112-123

pages 124-138

pages 138 -






Errata and signature
page
Summary Judgment
Who chooses the lawyers?
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092704 Nevitt statements
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2002 SDCOE payments
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2003 part 2 Stutz invoices
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Payments to Shinoff
Maura Larkins
v. CVESD
Judge Ahler OAH
page 89-91

Is Shinoff or Mark
Bresee to blame?
pages 91-94

pages 95-105

pages 105-111

pages 112-123

pages 124-138

pages 138-157

pages 157-175

pages 175-203

pages 203-222


Errata and signature
page
Larkins case
summary
Case Timeline
Deposition of
Maura Larkins

Richard Werlin
changed the record
pages 1-15

pages 15-25

pages 25-35

pages 35-48

pages 48-60

Pages 60--68

Lozano Smith
pages 73-80

pages 68-89