|The tort claim that's
missing from the
January 4, 2008
I called up Diane Crosier today and asked her what insurance company
handled my April 21, 2005 tort claim against SDCOE and CVESD. She looked
on her computer and found tort claims for 2001, 2002, and May 2004, but
nothing for 2005.
She asked if the claim was about continuing incidents.
I said, no, they were about specific, single events on November 4 and 10,
She said it might be in the May 2004 file, but the file is in storage.
Here is the claim that either no one ever entered properly into the SDCOE-JPA
computer, or someone removed from the computer.
It regards SDCOE-JPA lawyers who suborned perjury.
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In fact, it is the
lawyer who must
witnesses have no
crimes of their
April 21, 2005
State of California
Victim Compensation and Government Claims Board
P.O. Box 3035
Sacramento, CA 95812-3035
San Diego County Office of Education
6401 Linda Vista Road
San Diego, CA 92111-7399
Lowell Billings, Superintendent
Chula Vista Elementary School District
84 East “J” Street
Chula Vista, CA 91910
Re: Maura Larkins
Date of injuries: November 4, 2004 and November 10, 2004
NOTICE OF CLAIM REQUIRED BY GOVERNMENT CODE SECTION 910
To whom it may concern:
1. Name of claimant: Maura Larkins
2. All correspondence, information and notices should be sent to Maura
Larkins at the above address.
3. The SAN DIEGO COUNTY SCHOOLS RISK MANAGEMENT JOINT
POWERS AUTHORITY, hereinafter designated as the “JPA,” and its officers,
employees and/or agents, and the SAN DIEGO OFFICE OF EDUCATION,
hereinafter referred to as the “SDCOE,” and its officers, employees and/or
agents, and Chula Vista Elementary School District, hereinafter referred to as
“CVESD,” and its officers, employees and/or agents, and attorney Daniel Shinoff
and his associates Jeffery Morris and Kelly Angell, on or about November 4, 2004
and November 10, 2004, caused injury to claimant by suborning perjury of
witnesses during testimony in depositions for San Diego Superior Court case
number GIC 781970. Kelly Angell committed the actions described below, under
the direction of her superiors and employers Jeffery Morris and Daniel Shinoff,
SDCOE, JPA, CVESD, and their officers, employees and/or agents.
(a) Kelly Angell suborned perjury by telling, ordering, and pressuring
deponents to testify falsely and to deceive by withholding information
during testimony in depositions for San Diego Superior Court case
number GIC 781970. One such incident occurred on November 4, 2005
during the deposition of Robin Donlan. Another such incident happened
on November 10, 2005, during the deposition of Michelle Scharmach.
(b) Kelly Angell informed deponents that any conversation any
witness in this case had with any other witness in this case is covered by
attorney clients privilege, even if no lawyer was present during that
conversation, if a lawyer had told one of the individuals to have that
conversation with the other individual.
(c) Kelly Angell told deponents that attorney-client
privilege covered all information which had ever been
discussed by lawyers in this case with their clients.
(d) Kelly Angell indicated to deponents that they were forbidden by
law to reveal information in depositions if that information were covered
by attorney-client privilege.
(e) Kelly Angell caused deponents to believe that their careers might
be in danger if they answered certain questions. Counsel is required to
tell Chula Vista Elementary School District that it would be illegal to
retaliate for any testimony given by defendants in depositions, and Chula
Vista Elementary School District is forbidden by law to retaliate for such
testimony. Counsel was clearly trying to intimidate and manipulate
witnesses, on behalf of herself, the JPA, and CVESD, to commit perjury.
4. The names of the public employees and/or agents and/or officers who are
responsible for the incident(s) are Diane Crosier, Patrick Judd, Pamela Smith,
Larry Cunningham, Bertha Lopez, Cheryl Cox, Daniel Shinoff, Jeffery Morris and
5. Claimant alleges that the SDCOE and the JPA and CVESD, and their
officers, agents and/or individuals employed by them, are liable for claimant’s
damages resulting from the actions described above.
6. The losses sustained by claimant consist of loss of reputation, loss of
financial compensation, emotional damages, and damage to her occupation and
financial condition, and pain and suffering.
7. The injuries in this claim will be according to proof at the time of trial, but
will exceed Twenty-Five Thousand ($25,000) Dollars. Plaintiff also, or as an
alternative, asks for non-financial relief in the form of an injunction against
subornation of perjury by defendants, and citizen oversight of the manner in which
JPA lawyers conduct lawsuits.
8. Witnesses to the incidents include Maura Larkins, Kelly Angell, Daniel
Shinoff, Robin Donlan, Michelle Scharmach, Karen Snyder, and Teresa Coffey.
Other witnesses may be called when claimant discovers their identities.
Dated: April 21, 2005
Education Reform Report