Stutz Artiano Shinoff & Holtz
defamation lawsuit against
Maura Larkins
for statements on this website
Testimony on this page:
Deposition of Maura Larkins
by Stutz law firm
June 16, 2008

Pages 68-73
23 Q. Now, when did you start the San Diego
24 Education Report, was that before or after the
25 termination of the last lawsuit in early 2005?

1 A. After.
2 Q. What was the reason that you decided to
3 start the San Diego Education Report?
4 A. I think that the corruption of public entity
5 lawyers and public entities is a serious matter,
6 especially with schools. Schools can never succeed as
7 long as good employees are thrown out by poor or
8 mediocre employees for whom personal politics is their
9 only avenue to job success.
10 Q. All right. On what date did you -- first of
11 all, do you distinguish in any manner between
12 and the San Diego Education Report,
13 or are those one and the same?
14 A. One and the same.
15 Q. Now, it's a mouthful to say either San Diego
16 Education Report or
17 Can we just call it the "Web site"?
18 A. Sure.
19 Q. If I use the word "Web site," you are going
20 to understand that I am referring to,
21 which is the same as the San Diego Education Report?
22 A. You can even say "your Web site."
23 Q. I will call it "your Web site."
24 A. Good.
25 Q. Just want to make sure that we are on the

1 same page.
2 Now, who maintains the server for your
3 Web site?
4 A. Yahoo.
5 Q. You set up your Web site through Yahoo?
6 A. (Witness nods head).
7 Q. Is that a "yes"?
8 A. Yes.
9 Q. Do you pay a monthly maintenance fee or any
10 type of fee for your Web site?
11 A. Yes. About $13.
12 Q. Did you also have to reserve the domain name
13 through anyone other than Yahoo?
14 A. No. Yahoo did it for me.
15 Q. Was that a separate charge?
16 A. No. Actually, I think it was free.
17 Q. When did you first set up your Web site?
18 A. Well, it could hardly have been called a
19 Web site at the beginning. I believe it was October
20 of 2005 when I first began. I had no idea whatsoever
21 that I was doing.
22 I started out with one of their premade
23 pages and just put a couple of words in. For a long
24 time it was just a page that really didn't say
25 anything.

1 Q. When was the first time that you made
2 statements about Stutz, Artiano, Shinoff & Holtz on
3 your Web site?
4 A. It would have been -- I am going to guess a
5 few months after. I am not sure exactly when, but I
6 would think it would have been in 2006.
7 Q. In early 2006?
8 A. Yeah, I think.
9 Q. Do you keep records of what is on your
10 Web site? Do you, like print off the contents so that
11 you are able to keep track of the content that is on
12 there, from time to time?
13 A. Since I got sued I have been. What I do is
14 I keep it on a disk. I just make a separate disk,
15 like I just load the whole Web site onto a disk.
16 Q. How many such disks do you have?
17 A. Oh, gosh. I am going to guess 50.
18 Q. Do you intend to keep those disks and you
19 have any intention to destroy them, do you?
20 A. No, certainly not, as long as I am getting
21 sued.
22 Q. Okay. You understand it is important since
23 we are making allegations about things that are on the
24 Web site, it is important that somewhere there exists
25 a record, at least as complete as we can have it, of

1 what has been on your Web site?
2 A. Yeah.
3 Q. You have been keeping these disks that have
4 everything that is on your Web site since at least the
5 time that we filed the lawsuit that brings you here
6 today?
7 A. Yes, yeah.
8 Q. Prior to the lawsuit, did you keep any type
9 of record of what was on the Web site?
10 A. Much less frequently. But once I started --
11 you know, people started -- my Web site has been
12 hacked. One of the things I started to -- that was my
13 motivation when I first started saving my Web site,
14 was because I would open up my Web site and a page
15 would be gone.
16 The first time that happened was when I
17 filed the lawsuit against CTA for perjury. That
18 lawsuit just suddenly disappeared. I had the whole
19 lawsuit on one page and it just disappeared. That is
20 when I started really trying to keep my Web site, keep
21 copies up-to-date so I would not have to redo
22 everything.
23 Q. What happened to your lawsuit against the
24 CTA for perjury?
25 A. It got thrown out because it is okay to

1 commit perjury.
2 Q. Who said that?
3 A. Eddie Sturgeon, the judge -- the law, the
4 policy -- well, actually, it is not the law. It is
5 public policy, the courts.
6 Q. Is to allow perjury?
7 A. Not to allow civil torts regarding perjury.
8 Q. Okay. Understood. Now, at some point, did
9 you put on your Web site an order that was granted by
10 a federal judge against a law firm by the name of
11 Lozano Smith?
12 A. I don't know if I put the order. I wrote
13 about it.
14 Q. Did you, at some point prior to writing
15 about the order with respect to Lozano Smith, did you
16 read the order?
17 A. I have never read the entire order. I think
18 it's 80 pages or something.
19 Q. Did you have a copy of it, the order?
20 A. I never printed out the whole order.
21 Q. How did you find out about that order?
22 A. It was on the Internet. It was a news
23 story. It was quite a scandal, apparently. People
24 don't know how corrupt public entity lawyers are.
25 When I saw that I thought, "Wow, Stutz is not the only
1 one." I mean...
2 Q. Did you read a portion of the order, or did
3 you read a story about the order?
4 A. Well, I certainly did read stories about the
5 order. I glanced through the order, but I did not
6 read it all.
7 Q. Did you then do a search to see if there had
8 ever been any similar orders issued against the Stutz
9 firm by any judge ever, anywhere?
10 A. These orders are not just on the Internet.
11 You would have to go to the court -- well, like if it
12 is federal court you have to look on PACER. With
13 state court, you have to actually go down and find all
14 their cases, which you can't search by attorney. You
15 would have to know what their cases are and look
16 through there. No, no, I had no way to do that.
17 Q. You mentioned PACER, that's the federal
18 system?
19 A. Yes.
20 Q. And the order we're talking about with
21 Lozano Smith, that was an order in the federal court?
22 A. Um-hmm.
23 Q. "True"?
24 A. Yeah.
25 Q. On the PACER system -- PACER, by the way, is
SD Education Report
Education and the
Culture Wars Blog
San Diego
Education Report
Education Reform
Site Map
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
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
Larkins case
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

pages 68-73

Lozano Smith order/
Shinoff tactics
pages 73-80

pages 80-89
Summary Judgment