SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN DIEGO, EAST COUNTY DIVISION

1. California Civil Code §47(b)(2), which allows civil prosecution of perjury
when combined with spoliation of documents, was written so that the
instant case could be prosecuted.  

However, it is deeply uncertain that the instant case will be allowed to go
forward because CCC 47(b)(2) is a law whose existence the courts have
systematically ignored.  Why?  Because the courts do not want the
judgments that resulted from perjury and spoliation to be overturned.  

This “public policy” preserves the pervasive presence of perjury in our
judicial system.  Half of all lawyers say that perjury is a problem for them:
the other half are apparently not bothered by it.  

In the one case where this law was followed, Terry Rusheen v. Barry H.
Cohen, et al, the California Court of Appeal made sure to tag the case for
non-publication.  

And yet, California courts are unwilling to say that this law should not be
followed, or that “public policy” trumps a legitimate law, because the courts
know that this legitimate law should trump public policy.   

As long as perjury in furtherance of destruction of evidence is sanctions by
our courts, we don’t have a true justice system.  We merely have a decision-
making system.  


2. It’s time for California Civil Code §47(b)(2), which became law in 1991, to
be directly addressed by a California court.  Over the past fifteen years CCC
§47 has been frequently cited in case law, and has been upheld without fail.  
The courts have obviously read CCC §47(b)(2); they couldn’t have missed it.  
Still, these courts claim that the litigation privilege is absolute.  CCC §47(b)
(2) says it is not absolute; there is an exception when evidence is destroyed
or altered and unlawful statements are made “in furtherance” of such an
act. CCC §47(b)(2) states:
) Case No.   37-2007-00058893-CU-MC-EC
) Judge:        Eddie Sturgeon             
) Dept:          14
) Hearing date:   
)
) COMPLAINT FOR
) NON-MONETARY RELIEF
)
) VIOLATION OF STATUTE:
) PERJURY AND SUBORNATION
) OF PERJURY WITHOUT IMMUNITY
) (CALIFORNIA CIVIL CODE
) §47 (b)(2) ; CONSPIRACY)
)
)
)
)
) COMPLAINT FILED:
) TRIAL DATE: NOT SET                         
MAURA LARKINS,                                
Plaintiff,                                                 
       
vs.                                            

LINDA WATSON                               
VIRGINIA BOYD                               
BEVERLY TUCKER                                
MICHAEL D. HERSH                                
CALIFORNIA TEACHERS
ASSOCIATION,         
a California labor organization,    
CHULA VISTA ELEMENTARY   
EDUCATION ASSOCIATION,
a California labor organization,            
   
and DOES 1 through 10, inclusive,      
   
Defendants.            
______________________________

3. Aside from one or two indirect mentions (Laborde v. Aronson (App. 4
Dist. 2001) 112 Cal.Rptr.2d 119,92 Cal.App.4th 459), and one unpublished
decision, (Terry Rusheen v. Barry H. Cohen, et al.), California courts have
behaved as if this law did not exist.

4. In Terry Rusheen v. Barry H. Cohen, et al., the judgment was set aside
and a trial granted because, due to falsification of documents, the original
case had been dismissed without trial (Los Angeles County Super. Ct. No.
EC022640) SECOND APPELLATE DISTRICT, DIVISION FOUR).

5. This is exactly what occurred in the instant case. In San Diego Superior
Court case number GIC 781970 was dismissed without trial, without any
decision on the merits, due to spoliation and falsification of documents
furthered by perjury.
“This subdivision does not make privileged any
communication made in furtherance of an act of
intentional destruction or
alteration of physical evidence
undertaken for the purpose of
depriving a party to litigation of
the use of that evidence,
whether or not
the content of the communication is the subject of a
subsequent publication or broadcast which is privileged
pursuant to this section. As used in this paragraph, "physical
evidence" means evidence specified in Section 250 of the
Evidence Code or evidence that is property of any type
specified in Section 2031 of the Code of Civil Procedure.”
(Italics added.)

6. Plaintiff MAURA LARKINS is now, and at all times mentioned in this
complaint was, a resident of San Diego County, California.  Plaintiff was
employed as a teacher in Chula Vista Elementary School District from
September 1974 until February 2003, and is now retired.

7.  LINDA WATSON, hereinafter referred to as WATSON, is now, and at all
times mentioned in this complaint has been, a resident of San Diego County,
California and an employee of CHULA VISTA ELEMENTARY SCHOOL
DISTRICT.

8. Defendant VIRGINIA BOYD, hereinafter referred to as BOYD, is now and
at all times mentioned in this complaint was a resident of San Diego County,
California.  At the time of the events referred to in this complaint, BOYD
was employed as President of CHULA VISTA ELEMENTARY EDUCATION
ASSOCIATION.  Prior to her employment by CTA, she was employed as a
teacher at Castle Park Elementary School.  

9.  Defendant Michael D. Hersh, hereinafter referred to as HERSH, is now
and at all times mentioned in this complaint was a resident of Los Angeles
County, California, and was employed as an attorney for the California
Teachers Association, and represented Virginia Boyd, CHULA VISTA
ELEMENTARY EDUCATION ASSOCIATION, and CALIFORNIA TEACHERS
ASSOCIATION in San Diego Superior Court case number GIC 781970.

10.  Defendant Beverly Tucker, hereinafter referred to as TUCKER, is now
and at all times mentioned in this complaint was a resident of California, and
was employed as Head Counsel for the California Teachers Association, and
represented Virginia Boyd, CHULA VISTA ELEMENTARY EDUCATION
ASSOCIATION, and CALIFORNIA TEACHERS ASSOCIATION in San Diego
Superior Court case number GIC 781970.

11.  Chula Vista Elementary Education Association, hereinafter referred to
as “CHULA VISTA ELEMENTARY EDUCATION ASSOCIATION” or “CVE,”
is a labor organization authorized and existing under the laws of the State
of California in the county of San Diego.  It is a local chapter of
CALIFORNIA TEACHERS ASSOCIATION.

12. California Teachers Association, hereinafter referred to as CALIFORNIA
TEACHERS ASSOCIATION or “CTA” is a labor organization authorized and
existing under the laws of the State of California.

13.  The true names of defendants DOES 1 through 10, inclusive, are
unknown to plaintiff at this time.  Plaintiff sues those defendants by such
fictitious names pursuant to section 474 of the Code of Civil Procedure.  
Plaintiff is informed and believes, and based on that information and belief
alleges, that each of the defendants designated as a DOE is legally
responsible for the events and happenings referred to in this complaint, and
unlawfully caused the injuries and damages to plaintiff alleged in this
complaint.
SECOND CAUSE OF ACTION
VIOLATION OF PENAL CODE SECTION § 127


27. BOYD did not write a single word during an August 13, 2001 meeting at CVESD
regarding plaintiff, but sat silent and unmoving during the entire meeting.
Instead of taking notes, BOYD made a tape recording of the August 13, 2001
meeting.

28. After the meeting, BOYD prepared notes of the meeting, cherry-picking items
she wanted to include and items she wanted to leave out, thus altering a document
that was blank, and creating a bogus document.
29. BOYD, TUCKER, HERSH, CVE AND CTA destroyed the tape recording made by
BOYD at that meeting in order to deprive plaintiff of the use of that evidence.
30. TUCKER, HERSH, CVE AND CTA prepared a false declaration for BOYD to sign
(Exhibit 2) regarding the “notes” and the tape recording made at the August 13,
2001 meeting.

31. BOYD signed the false declaration in furtherance of the act of destruction of
evidence and the alteration of evidence, thus committing perjury on June 28, 2004.  
This perjury was suborned by TUCKER, HERSH, CVE AND CTA.

32. Defendants’ conduct as alleged in this cause of action constitutes an unlawful
act in violation of Penal Code section 127, which states, “Every person who willfully
procures another person to commit perjury is guilty of subornation of perjury, and
is punishable in the same manner as he would be if personally guilty of the perjury
so procured.”

33. As a proximate result of defendant’s conduct as described in this cause of
action, Plaintiff and students and teachers of California have suffered from a
damaged educational and legal system caused by the blatant violation of both civil
and criminal statutes by DEFENDANTS WATSON, TUCKER, HERSH, BOYD, CTA AND
CVE.

















THIRD CAUSE OF ACTION

35. BOYD, TUCKER, CVE AND CTA created a hoax grievance (Exhibit 3) in 2001 to
fool plaintiff into thinking they were representing her, when actually they were
representing WATSON, and doing everything they could to hide WATSON’s crimes.
This grievance constituted "physical evidence" as specified in Section 250 of the
Evidence Code or evidence that is property of any type specified in Section 2031 of
the Code of Civil Procedure.”

36. In or about October of 2004, this grievance was destroyed by BOYD, TUCKER,
CVE AND CTA in order to deprive plaintiff of the use of that evidence.

37.  In or about October of 2004, HERSH, TUCKER, WATSON, CVE AND CTA
committed perjury during testimony under oath San Diego Superior Court case
number GIC 781970 in furtherance of this destruction of evidence and in order to
deprive plaintiff of the use of this evidence.  

38. Defendants’ conduct as alleged in this cause of action constitutes an unlawful
act in violation of Penal Code section 127, which states, “Every person who willfully
procures another person to commit perjury is guilty of subornation of perjury, and
is punishable in the same manner as he would be if personally guilty of the perjury
so procured.”

39. As a proximate result of defendant’s conduct as described in this cause of
action, Plaintiff and students and teachers of California have suffered from a
damaged educational and legal system caused by the blatant violation of both civil
and criminal statutes by DEFENDANTS WATSON, TUCKER, HERSH, BOYD, CTA AND
CVE.










FOURTH CAUSE OF ACTION
CONSPIRACY TO DESTROY EVIDENCE AS TO DEFENDANTS WATSON, TUCKER,
HERSH, BOYD, CTA AND CVE


41.  On or about September 23, 2004, BEVERLY TUCKER, MICHAEL D. HERSH,
VIRGINIA BOYD, CALIFORNIA TEACHERS ASSOCIATION,  CHULA VISTA
ELEMENTARY EDUCATION ASSOCIATION and each of them, knowingly and willfully
conspired and agreed among themselves that they would destroy the notes taken
by BOYD during a meeting at CVESD on February 12, 2001. These notes constituted
"physical evidence" as specified in Section 250 of the Evidence Code or evidence
that is property of any type specified in Section 2031 of the Code of Civil
Procedure.”

42. BEVERLY TUCKER, MICHAEL D. HERSH, VIRGINIA BOYD, CALIFORNIA
TEACHERS ASSOCIATION,  CHULA VISTA ELEMENTARY EDUCATION ASSOCIATION,
each acting individually and giving encouragement, collaboration, and assistance to
the other, conspired to destroy the notes taken by BOYD during a meeting at
CVESD on February 12, 2001.

43. Defendants BEVERLY TUCKER, MICHAEL D. HERSH, VIRGINIA BOYD,
CALIFORNIA TEACHERS ASSOCIATION, CHULA VISTA ELEMENTARY EDUCATION
ASSOCIATION, and each of them, did the acts and things herein alleged pursuant
to, and in furtherance of, the conspiracy and above-alleged agreement.

44.  The February 12, 2001 notes were destroyed by BOYD or HERSH on or about
May 14, 2004 in furtherance of the conspiracy and in order to deprive plaintiff of the
use of the evidence.

45. As a proximate result of defendant’s conduct as described in this cause of
action, Plaintiff and students and teachers of California have suffered from a
damaged educational and legal system caused by the blatant violation of both civil
and criminal statutes by DEFENDANTS TUCKER, HERSH, BOYD, CTA AND CVE.

FIFTH CAUSE OF ACTION
CONSPIRACY TO DESTROY EVIDENCE AS TO
DEFENDANTS TUCKER, HERSH, BOYD, CTA AND CVE

41.  On or about September 23, 2004, BEVERLY TUCKER, MICHAEL D. HERSH,
VIRGINIA BOYD, CALIFORNIA TEACHERS ASSOCIATION,  CHULA VISTA
ELEMENTARY EDUCATION ASSOCIATION and each of them, knowingly and willfully
conspired and agreed among themselves that they would destroy the tape
recording  made by BOYD during a meeting at CVESD on August 13, 2001, and alter
a document to create fake “notes” of that meeting. This tape recording and notes
constituted "physical evidence" as specified in Section 250 of the Evidence Code or
evidence that is property of any type specified in Section 2031 of the Code of Civil
Procedure.”

42. BEVERLY TUCKER, MICHAEL D. HERSH, VIRGINIA BOYD, CALIFORNIA
TEACHERS ASSOCIATION,  CHULA VISTA ELEMENTARY EDUCATION ASSOCIATION,
each acting individually and giving encouragement, collaboration, and assistance to
the other, conspired to alter a document and to destroy the tape recording made by
BOYD during a meeting at CVESD on August, 2001.

43. Defendants BEVERLY TUCKER, MICHAEL D. HERSH, VIRGINIA BOYD,
CALIFORNIA TEACHERS ASSOCIATION, CHULA VISTA ELEMENTARY EDUCATION
ASSOCIATION, and each of them, did the acts and things herein alleged pursuant
to, and in furtherance of, the conspiracy and above-alleged agreement.

44.  The August 13, 2001 tape recording was destroyed by BOYD or HERSH on or
about June 28, 2004 in furtherance of the conspiracy and in order to deprive
plaintiff of the use of the evidence.

45. As a proximate result of defendant’s conduct as described in this cause of
action, Plaintiff and students and teachers of California have suffered from a
damaged educational and legal system caused by the blatant violation of both civil
and criminal statutes by DEFENDANTS TUCKER, HERSH, BOYD, CTA AND CVE.

SIXTH CAUSE OF ACTION
CONSPIRACY TO DESTROY EVIDENCE AS TO DEFENDANTS TUCKER, HERSH, BOYD,
CTA AND CVE

40. Plaintiff realleges and incorporates Paragraphs 1 through 13, inclusive, of the
General Allegations, as though fully set forth herein.

41.  On or about October of 2004, BEVERLY TUCKER, MICHAEL D. HERSH, VIRGINIA
BOYD, CALIFORNIA TEACHERS ASSOCIATION,  CHULA VISTA ELEMENTARY
EDUCATION ASSOCIATION and each of them, knowingly and willfully conspired and
agreed among themselves that they would destroy the 2001 hoax grievance
(Exhibit 3) to fool plaintiff into thinking they were representing her, when actually
they were representing WATSON, and doing everything they could to hide WATSON’
s crimes. This grievance constituted "physical evidence" as specified in Section 250
of the Evidence Code or evidence that is property of any type specified in Section
2031 of the Code of Civil Procedure.”

42. BEVERLY TUCKER, MICHAEL D. HERSH, VIRGINIA BOYD, CALIFORNIA
TEACHERS ASSOCIATION,  CHULA VISTA ELEMENTARY EDUCATION ASSOCIATION,
each acting individually and giving encouragement, collaboration, and assistance to
the other, conspired to destroy the 2001 hoax grievance (Exhibit 3) to fool plaintiff
into thinking they were representing her, when actually they were representing
WATSON, and doing everything they could to hide WATSON’s crimes.

43. Defendants BEVERLY TUCKER, MICHAEL D. HERSH, VIRGINIA BOYD,
CALIFORNIA TEACHERS ASSOCIATION, CHULA VISTA ELEMENTARY EDUCATION
ASSOCIATION, and each of them, did the acts and things herein alleged pursuant
to, and in furtherance of, the conspiracy and above-alleged agreement.

44.  The 2001 hoax grievance was destroyed by BOYD or HERSH on or about
October of 2004 in furtherance of the conspiracy and in order to deprive plaintiff of
the use of the evidence.

45. As a proximate result of defendant’s conduct as described in this cause of
action, Plaintiff and students and teachers of California have suffered from a
damaged educational and legal system caused by the blatant violation of both civil
and criminal statutes by DEFENDANTS TUCKER, HERSH, BOYD, CTA AND CVE.


PRAYER FOR RELIEF
WHEREFORE, plaintiff requests judgment from defendants in the above causes of
action as follows:
1.        That the court order defendants to publicly apologize, both orally and in
writing, to plaintiff, the students and teachers of Chula Vista Elementary School
District, and Judge Nevitt and the San Diego Superior Court for perpetrating a fraud
on the court, and for violating civil and criminal statutes of California, and to
promise to discontinue such violations of statute.
2.        Cost of suit;
3.        Such further relief as the court deems proper.


May 14, 2007                _____________________________________
MAURA LARKINS


VERIFICATION

I, MAURA LARKINS, am the plaintiff in the above-entitled action.  I have read the
foregoing complaint for violations of California Statutes regarding perjury,
spoliation, and conspiracy, and know its contents.  The same is true of my own
knowledge, except as to those matters which are alleged on information and belief,
and as to those matters, I believe it to be true.  

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.

May 14, 2007                _____________________________________
MAURA LARKINS
Link: Exhibit 1
Boyd's declaration regarding destroyed notes
from Feb. 12, 2001 meeting at CVESD
Link: Exhibit 3:
Jim Groth's
Hoax Grievance
What should Linda
Watson have done to
repair the harm done by
her crimes?

She had two choices:
either
retract the
allegations she made (on
February 10, 2001) when
she called Richard
Werlin at his home, or
come forward and make
the allegations openly,
so that Maura Larkins
could respond to them.
Link: Exhibit 2

Boyd's declaration
regarding her tape
recording on August 13,
2001 (which vanished) and
the notes she later created
(which were phony)

(I'll scan this document and
link to it as soon as I can!)
General Allegations
FIRST CAUSE OF ACTION


15.  On May 14, 2004, defendants  intentionally prepared a false declaration  
(Exhibit 1) to be signed under penalty of perjury by CVE President VIRGINIA BOYD.

16.  Virginia Boyd knowingly signed the false document under penalty of perjury
and HERSH, TUCKER, WATSON, CVE AND CTA suborned the perjur.  BOYD, HERSH,
TUCKER, WATSON,CVE AND CTA filed the document in San Diego Superior Court
case number GIC 781970.

17. Defendants’ conduct as alleged in this cause of action constitutes an unlawful
act in violation of Penal Code section 127, which states, “Every person who willfully
procures another person to commit perjury is guilty of subornation of perjury, and
is punishable in the same manner as he would be if personally guilty of the perjury
so procured.”

18. The perjured declaration signed by BOYD on May 14, 2004 stated that BOYD’s
notes of a February 12, 2001 meeting CVESD meeting regarding plaintiff were
accidentally lost or destroyed (Exhibit 1).  

In fact, the notes were intentionally destroyed by BOYD, TUCKER, WATSON,
HERSH, CTA AND CVE, either directly or by conspiracy to destroy the notes, on or
about May 14, 2004.  These notes constituted "physical evidence" as specified in
Section 250 of the Evidence Code or evidence that is property of any type specified
in Section 2031 of the Code of Civil Procedure.”

19. In or about October of 2004, WATSON, BOYD, TUCKER, HERSH, CTA AND CVE,
through subornation or false testimony under oath, committed perjury again in
furtherance of this act of destruction of documents and in order to deprive plaintiff
of the use of this evidence.

20.  The double felony of spoliation and perjury was committed by WATSON, BOYD,
HERSH, TUCKER, WATSON, CVE AND CTA to hide crimes by WATSON and Robin Colls
Donlan.  In 2000, WATSON had received information from an arrest record illegally
obtained by Robin Donlan, and in 2001 WATSON took part in a conspiracy to violate
Labor Code 432.7 against plaintiff.  

WATSON demanded that her illegal actions against a fellow member of CVE and CTA
be concealed by CVE and CTA.  BOYD and CVE thereafter filed a grievance on
WATSON’s behalf to keep her actions secret, and to deprive plaintiff of the use of
that evidence.

21. Defendants BOYD, TUCKER, WATSON, CVE AND CTA conspired to file a
grievance on WATSON’s behalf, and the grievance was filed by CVE, in order to
conceal WATSON’s actions.

The grievance demanded that Assistant Superintendent Richard Werlin of Chula
Vista Elementary School District deny that he made a statement on February 12,
2001 to the effect that two teachers called him at home on the previous Saturday
night.   

Werlin agreed to change his story and to say that only one teacher called him.   
Werlin kept to the agreement, and committed perjury in 2002 and 2003 regarding
this matter.  

BOYD, after destroying her notes, or giving them to HERSH to destroy, apparently
forgot about the agreement to conceal this detail, and three years after making the
agreement, BOYD stated under oath that Richard Werlin announced on Feb. 12,
2001 that two people had called him at home regarding plaintiff.

22. LINDA WATSON committed perjury when she denied under oath that she had
called Werlin, but changed her story when asked if she minded if her Saturday
February 10, 2001 phone records were checked to see if she called Richard Werlin
at his home around 8:30 in the evening.

23.  Evidence of the truth about WATSON’s actions was contained in BOYD’s notes
of a meeting at Chula Vista Elementary School District on February 12, 2001.  All
defendants conspired to destroy these notes.

24. At the root of all these misdemeanors and felonies were the original
misdemeanors of Robin Colls Donlan and her brother Michael Carlson in or about
September of 2000, in which they conspired to obtain and disseminate, in violation
of multiple California Codes, the record of an arrest that led to neither charges nor a
conviction.  BOYD, then-president of Chula Vista Educators (CVE), was a long-time
friend of Robin Donlan, and for that reason decided to commit multiple felonies to
cover up Donlan’s and WATSON’s misdemeanors.

25.  As a proximate result of defendant’s conduct as described in this cause of
action, Plaintiff and students and teachers of California have suffered from a
damaged educational and legal system caused by the blatant violation of both civil
and criminal statutes by DEFENDANTS WATSON, TUCKER, HERSH, BOYD, CTA AND
CVE.
This case involves
2 separate acts of destruction
of evidence
by CTA Head Counsel
Beverly Tucker and her underlings.

It also involves
2 separate acts
of creating hoax documents.
Lawsuit
Maura Larkins v.
California Teachers Association (CTA) and
Beverly Tucker  (CTA Head Counsel)
Is this case a tempest in a teapot?  Not according to the
California Teachers Association.  CTA's lawyers admit
that these charges are very serious.  Beverly Tucker
and Michael Hersh deny that these charges are true, of
course, but they note that if these charges were FALSE,
they would be "defamatory" and "outrageous."  So why
doesn't CTA sue Maura Larkins for defamation?  CTA is
tacitly admitting that the charges are true.  No one has
the right to libel or slander anyone by disseminating
false allegations.
Exhibit 2

Gina Boyd's
declaration
regarding her
tape recording on
August 13, 2001
(which vanished).


Also, the phony
notes she later
created.
Exhibit 3:

Jim Groth's
Hoax Grievance




(Groth was
grievance chair,
then president of
Chula Vista
Educators)
Fraud #1
Fraud #3
Fraud #2
As long as perjury in furtherance of destruction of
evidence is tolerated by our courts, we don’t have a
true justice system.  
We merely have a decision-making system.
Exhibit 1

Gina Boyd's
declaration
regarding
destroyed notes
from Feb. 12, 2001
meeting at CVESD



(Boyd was
president of Chula
Vista Educators)
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CTA MAILS
ITS RESPONSE
I filed this
complaint on May
14, 2007, and
worked hard to get
an amendment
finished in order  to
add
defendants
such
as Stutz,
Artiano, Shinoff &
Holtz.  
I failed to get my
amended complaint
ready by July 13,
2007, so I'll need to
file a whole new
complaint.  I'll refile
these causes of
action in the new
case.  

The bizarre
behavior of CTA
continues.  I never
served this
complaint on CTA
because I wanted
to wait and serve
the amended
complaint.  
Nevertheless,
without having been
served, CTA called
up the court and got
a September 28,
2007 hearing date
for its motion to
strike the
complaint, and
mailed a bunch of
pleadings to me.   

The funny thing is
that in the past, one
of CTA's favorite
excuses for not
responding to a
lawsuit  was to
claim that it hadn't
been properly
served.  

Now it responds to
lawsuits that it
wasn't even served
with!