Deposition of Maura Larkins
by Ljubisa Kostic
June 16, 2008

Pages 91-94
Daniel Shinoff, giving advice to the board, Mark Bresee
Stutz Artiano Shinoff & Holtz
defamation lawsuit against
Maura Larkins
for statements on this website
9 Q. How do you know that the district was
10 following Daniel Shinoff's directions with respect to
11 the hearing at the Office of Administrative Hearings,
12 in which another law firm was representing the
13 district?

14 A. Because he was the main guiding force in the
15 district's legal decision. Parham & Rajcic was sort
16 of like second tier. They just take care of the
17 Office of Administrative Hearings. As soon as I filed
18 a tort claim, Daniel Shinoff became the person who was
19 calling the shots.

20 Q. Right. I guess what I am trying to get to
21 is not your conclusions, but
what information do you
22 have that allows you to conclude that Daniel Shinoff
23 was telling the
Rajcic firm what to do in that Office
24 of Administrative Hearings?

25 A. No, I don't think he was telling the Rajcic

page 92

1 firm. I think he was telling the school board.

2 Q. How do you know that?

3 A. Because they don't seem to have much ability
4 to think for themselves. They just blindly follow
5 their attorneys, no matter how much trouble it gets
6 them into. If they had wanted to dismiss me before
7 Shinoff got involved, they could have. But they
8 didn't do it until he was in charge.

9 Q. Okay. When did Mr. Shinoff become in
10 charge?

11 A. October 4th, 2001.

12 Q. How do you know that?

13 A. He told me that.

14 Q. When did Mr. Shinoff tell you that?

15 A. When I met with him and Kelly Angell at
16 Starbucks.

17 Q. How did you come to meet with Mr. Shinoff
18 and Kelly Angell at Starbucks?

19 A. It was Mr. Shinoff's idea.

20 Q. Mr. Shinoff told you that starting on
21 October 4th, 2001, he was in charge of all decisions
22 having to do with you and your hearing at the Office
23 of Administrative Hearings?

24 A. He said he became involved on that date.

25 Q. Oh, he became involved, okay. Did he tell

93
1 you what specifically his duties were at the time that
2 he became involved?

3 A. Is that a serious question?

4 Q. Yes. You are saying he directed everybody.
5 I want to know how you know that. You say you met
6 with Mr. Shinoff. You say he told you he became
7 involved on a certain date. I want to know if he told
8 you in more detail about what his involvement was. "I
9 became in charge. I was telling people what to do."
10 Anything like that?

11 A. You mean like if he said, "Well, it is my
12 job to respond to any letters you write"?

13 Q. Or anything that he said to you. I don't
14 know if he said anything.

15 A. He was mysteriously silent at that meeting.
16 He did not go into detail.

17 Q. When was the process through the Office of
18 Administrative Hearings first initiated against you?

19 A. What do you mean by that?

20 Q. Well, in order to terminate you, the
21 district had to allow you to have a hearing through
22 the Office of Administrative Hearings, true?

23 A. Right. They voted on May 7th, 2002.

24 Q. That would be the school board?

25 A. Um-hmm.


94

1 Q. Voted on whether or not they wanted to
2 initiate proceedings to terminate you?

3 A. Right.

4 Q. Did Mr. Shinoff tell you whether he advised
5 the board as to whether it should initiate termination
6 proceedings against you through the Office of
7 Administrative Hearings?

8 A. He is not that dumb.

9 Q. I just need straight answers. Did
10 Mr. Shinoff say that to you?

11 A. Of course not.

12 Q. Did anyone tell you that Mr. Shinoff was the
13 one who advised the board as to how they should vote
14 on May 7th, 2002?

15 A. No.
16 Q. Do you have any information from any source
17 whatsoever that would lead you to believe that
18 Mr. Shinoff advised the board on how they should vote
19 on May 7th, 2002?

20 A. Well, as a matter of fact, I had a phone
21 conversation with school board member
Cheryl Cox. In
22 it, she made it clear to me that she does whatever her
23 lawyers tell her to do and that she would never
24 question whether or not the lawyers were giving legal
25 instructions.



95

1 Q. Did Ms. Cox tell you that Mr. Shinoff
2 advised her in any fashion regarding whether or not
3 proceedings should be initiated against you to
4 terminate your employment?

5 A. No. She did not use his name. She used the
6 term "our lawyers."

7 Q. She did not tell you which lawyers?

8 A. I just said she didn't use names.
I need to ask
Shinoff this
question. > > >
I need to ask this
question in a
deposition of Mr.
Shinoff. > > >
Question:  Was
Mark Bresee of
Parham & Rajcic
to
blame, rather than
Daniel Shinoff of
Stutz law firm?
I need this
information.  I need
to depose  Mr.
Shinoff to get it.
I need to ask
Shinoff this
question. > > >
Maura Larkins
deposition

page 89-91 Judge Ahler OAH

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

pages 95-105
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
Summary Judgment
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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

pages 68-73

Lozano Smith order/
Shinoff tactics
pages 73-80

pages 80-89
Return to "Why this
website"
Deposition of Ray Artiano