| Timeline for events on this page Feb. 12, 2001 Teacher (Maura Larkins) placed on leave due to anonymous reports that she might kill two teachers March 27, 2001 (The "March 27 Incident") CVESD's Richard Werlin took Maura Larkins to a place where there were no witnesses, then later claimed that she started screaming, "I want to work! I want to work!," while at the same time repeatedly running away and coming back. Rick Werlin says she was running and jerking at the same time. In the interest of science, a prize is being offered to anyone who can run and jerk at the same time. Feb. 12, 2001 to present CVESD has never done an investigation of any of the deadly serious allegations in this case. April 3, 2001 The teacher sent this fax to CVESD. 8 days after the March 27 apparent psychotic break allegedly witnessed by Richard Werlin, CVESD did something it has never explained: April 4, 2001 CVESD asked the supposedly dangerous teacher to return to work without a fitness for duty examination. The teacher's health care provider wanted to know what was going on. She called Richard Werlin and he did not mention a word about the alleged March 27 incident. Daniel Shinoff prepared a document claiming that the March 27 incident was genuine for Werlin to sign, and filed the document in San Diego Superior Court on behalf of CVESD. |
| Stutz Artiano Shinoff & Holtz defamation lawsuit against Maura Larkins for statements on this website |
3 Q. So whose perjury did Mr. Shinoff suborn?
4 A. Basically, I believe that combined CTA and
5 the district and their lawyers, by bringing these
6 people in and making sure that they did not tell the
7 truth, or keeping them out -- one thing Stutz tried to
8 do was he tried to prevent depositions, which
9 certainly is an indicator that it knew that the truth
10 would not be good for its case.
11 Just the fact of bringing someone in knowing
12 that you are going to want them to commit perjury,
13 yeah, I would say that is suborning perjury. I would
14 say that Daniel Shinoff and Stutz suborned perjury.
15 Q. Yeah. My question was -- and I am doing my
16 best here to allow you to talk as much as you want
17 about whatever you want to talk about in response to
18 my questions.
19 But my question was, whose perjured
20 testimony did Mr. Shinoff suborn? Who is this witness
21 who Mr. Shinoff subordinated perjury from?
22 A. Well, it is hard to separate Mr. Shinoff
23 from Ms. Angell and Mr. Morris.
24 Q. Let's just talk about all the lawyers at the
25 Stutz firm together.
106
1 A. Thank you.
2 Q. Whose perjured testimony did --
3 A. Well, Robin Donlan, to start with.
4 Q. Who else?
5 A. Linda Watson.
6 Q. Who else?
7 A. I think I would say most or all of their
8 witnesses. I would have to look at the depositions
9 carefully to see if there was someone who actually
10 managed to escape committing perjury.
11 Q. How do you go about deciding who committed
12 perjury?
13 A. Well, for one thing, there is this story
14 about March 27th, 2001. Rick Werlin's story is --
15 well, one of his stories -- is that I completely went
16 insane outside of the Castle Park School. He said
17 that my eyes glazed over. I was shaking -- oh, I was
18 jerking and I was running -- I have tried to do that.
19 It is impossible. Try it sometime, to jerk and run at
20 the same time.
21 He said that I threw two pens at him -- oh,
22 and then I ran away and came back and I ran away and
23 came back, and all the time I was yelling, "I want to
24 work. I want to work." I was there. I was the only
25 other person there, and his story was completely false
107
1 and totally perjured.
2 Q. Do you believe that any lawyer from the
3 Stutz firm told Mr-- I'm sorry, what is his name?
4 A. Werlin.
5 Q. Werlin -- Mr. Werlin, to make up this story?
6 A. No. They were not involved at that time.
7 But they told him to keep telling it. They didn't
8 tell him to tell the original story, but they told him
9 to keep telling it.
10 Q. Was any lawyer from the Stutz firm there at
11 the time of the events, that Mr. Werlin described a
12 certain way with which you disagree?
13 A. I think I just answered that question.
14 Q. No, no. I mean physically, were they
15 physically there to see what happened?
16 A. I have already answered that question; asked
17 and answered.
18 Q. I don't think I asked that question,
19 specifically. So could you please answer it for me
20 again.
21 A. I already told you that there was no one
22 there but me and Rick Werlin.
23 Q. Okay. All right. What I was trying to --
24 A. And I also told you that Stutz was not
25 involved at that time.
108
1 Q. I guess what I'm confused about is I was
2 asking you how you decide who has committed perjury
3 and who has not. I thought it was in connection with
4 the subornation of perjury by the Stutz firm.
5 So I am trying to decide if there was a
6 witness in any litigation where the Stutz firm was
7 representing the district, how you decide that the
8 Stutz firm told the witness what to say, knew what the
9 witness would say, or for that matter, knew what the
10 truth was, having not been there at the time of the
11 events.
12 A. Okay.
13 Q. Do you want me to break those down for you?
14 A. I have the first one, "Told him what to
15 say." What was the second?
16 Q. Knew what the witness would say?
17 A. Knew what they would say.
18 Q. In response to specific questions?
19 A. These are good questions, very important
20 questions. Let's really give an answer to these.
21 One of the most beautiful passages in any
22 deposition was this one with Robin Donlan where I
23 asked her if she knew that I had been removed from my
24 job and she said, "Yes, there was a meeting."
25 Kelly Angell interrupted her and said, "But wait a
page 109
1 minute, was this something you knew without being told
2 by a lawyer." Well, of course. Because it was way
3 before the lawyers were involved. She got her to
4 change her testimony right there. The whole
5 subornation was then on camera.
6 Q. And you have that?
7 A. Yes.
8 Q. You have it videotaped?
9 A. Yes. Let me finish answering. This was an
10 important question with three parts.
11 Q. I just want to make sure you have completed
12 part one, though. You gave an example with
13 Kelly Angell.
14 A. No, I have not completed part one.
15 Q. Okay. Go ahead.
16 A. This is how Stutz knew that Rick Werlin's
17 story was a lie.
18 Q. Before or after his deposition?
19 A. Before.
20 Q. Go ahead. I'm sorry.
21 A. At the time that this March 27th event
22 happened where I -- according to Richard Werlin, went
23 into this extreme psychotic state with apparently some
24 severe neurological problems too, I had just been
25 asked by him to come back to work. This happened on a
page 110
1 Tuesday, and I had been asked by him on Sunday to come
2 back to my classroom and work Monday morning.
3 I told him that I was afraid that there
4 would be new allegations, that these horrible
5 allegations against me of this Columbine-like event
6 that I was about to perpetrate, no one had -- first of
7 all, they were still anonymous, and no one had
8 retracted them. No one had made any apologies to me.
9 I thought, well, what's -- you know, they are just
10 going to make more allegations.
11 So I said, "No, I don't feel that I can come
12 back to work, although I would be happy to come in and
13 help the substitute." Apparently, the substitutes
14 were doing really bad. Those children were really
15 harmed, really harmed.
16 So, anyway, so I came back to help the
17 substitute. Here I am, this person --
18 Q. This is in 2001?
19 A. Yes. March 27th. Come back to help the
20 substitute. Also, the parents were upset about what
21 had happened to me. On this Tuesday morning,
22 March 27th, there was a parent meeting about me. You
23 would think that -- no one had told -- no one had told
24 me anything. This had been going on since
25 February 12th, and Richard Werlin had been -- he had
111
1 not been investigating. It turns out there was never
2 an investigation. The final report was the initial
3 allegations. There was never an investigation.
4 So, anyway, I go to the school district -- I
5 mean, to the principal's office for this meeting, and
6 the principal says she doesn't want me there at the
7 meeting.
8 The parents later told me that she had --
9 when they all went into her office and I was left
10 outside, that she called up Rick Werlin then and asked
11 him to come over. So he came over.
12 What really happened is this. I was in the
13 office and he said, "Maura, could you come out here."
14 Right in front of the office he said, "I just wanted
15 to welcome you back. It is good to see you back."
16 Then he started walking outside toward the front of
17 the school, and I followed him.
18 He stopped outside almost to the sidewalk,
19 not quite, and said nothing. He just stood there. I
20 said, "Do you want me to leave?" And he said, "Oh,
21 Maura" -- I know that wasn't much of an answer.
22 So I said, again, "Do you want me to leave?"
23 He goes, "Oh, Maura." I thought that it was pretty
24 obvious that he wanted me to leave but he didn't want
25 to say so.
4 A. Basically, I believe that combined CTA and
5 the district and their lawyers, by bringing these
6 people in and making sure that they did not tell the
7 truth, or keeping them out -- one thing Stutz tried to
8 do was he tried to prevent depositions, which
9 certainly is an indicator that it knew that the truth
10 would not be good for its case.
11 Just the fact of bringing someone in knowing
12 that you are going to want them to commit perjury,
13 yeah, I would say that is suborning perjury. I would
14 say that Daniel Shinoff and Stutz suborned perjury.
15 Q. Yeah. My question was -- and I am doing my
16 best here to allow you to talk as much as you want
17 about whatever you want to talk about in response to
18 my questions.
19 But my question was, whose perjured
20 testimony did Mr. Shinoff suborn? Who is this witness
21 who Mr. Shinoff subordinated perjury from?
22 A. Well, it is hard to separate Mr. Shinoff
23 from Ms. Angell and Mr. Morris.
24 Q. Let's just talk about all the lawyers at the
25 Stutz firm together.
106
1 A. Thank you.
2 Q. Whose perjured testimony did --
3 A. Well, Robin Donlan, to start with.
4 Q. Who else?
5 A. Linda Watson.
6 Q. Who else?
7 A. I think I would say most or all of their
8 witnesses. I would have to look at the depositions
9 carefully to see if there was someone who actually
10 managed to escape committing perjury.
11 Q. How do you go about deciding who committed
12 perjury?
13 A. Well, for one thing, there is this story
14 about March 27th, 2001. Rick Werlin's story is --
15 well, one of his stories -- is that I completely went
16 insane outside of the Castle Park School. He said
17 that my eyes glazed over. I was shaking -- oh, I was
18 jerking and I was running -- I have tried to do that.
19 It is impossible. Try it sometime, to jerk and run at
20 the same time.
21 He said that I threw two pens at him -- oh,
22 and then I ran away and came back and I ran away and
23 came back, and all the time I was yelling, "I want to
24 work. I want to work." I was there. I was the only
25 other person there, and his story was completely false
107
1 and totally perjured.
2 Q. Do you believe that any lawyer from the
3 Stutz firm told Mr-- I'm sorry, what is his name?
4 A. Werlin.
5 Q. Werlin -- Mr. Werlin, to make up this story?
6 A. No. They were not involved at that time.
7 But they told him to keep telling it. They didn't
8 tell him to tell the original story, but they told him
9 to keep telling it.
10 Q. Was any lawyer from the Stutz firm there at
11 the time of the events, that Mr. Werlin described a
12 certain way with which you disagree?
13 A. I think I just answered that question.
14 Q. No, no. I mean physically, were they
15 physically there to see what happened?
16 A. I have already answered that question; asked
17 and answered.
18 Q. I don't think I asked that question,
19 specifically. So could you please answer it for me
20 again.
21 A. I already told you that there was no one
22 there but me and Rick Werlin.
23 Q. Okay. All right. What I was trying to --
24 A. And I also told you that Stutz was not
25 involved at that time.
108
1 Q. I guess what I'm confused about is I was
2 asking you how you decide who has committed perjury
3 and who has not. I thought it was in connection with
4 the subornation of perjury by the Stutz firm.
5 So I am trying to decide if there was a
6 witness in any litigation where the Stutz firm was
7 representing the district, how you decide that the
8 Stutz firm told the witness what to say, knew what the
9 witness would say, or for that matter, knew what the
10 truth was, having not been there at the time of the
11 events.
12 A. Okay.
13 Q. Do you want me to break those down for you?
14 A. I have the first one, "Told him what to
15 say." What was the second?
16 Q. Knew what the witness would say?
17 A. Knew what they would say.
18 Q. In response to specific questions?
19 A. These are good questions, very important
20 questions. Let's really give an answer to these.
21 One of the most beautiful passages in any
22 deposition was this one with Robin Donlan where I
23 asked her if she knew that I had been removed from my
24 job and she said, "Yes, there was a meeting."
25 Kelly Angell interrupted her and said, "But wait a
page 109
1 minute, was this something you knew without being told
2 by a lawyer." Well, of course. Because it was way
3 before the lawyers were involved. She got her to
4 change her testimony right there. The whole
5 subornation was then on camera.
6 Q. And you have that?
7 A. Yes.
8 Q. You have it videotaped?
9 A. Yes. Let me finish answering. This was an
10 important question with three parts.
11 Q. I just want to make sure you have completed
12 part one, though. You gave an example with
13 Kelly Angell.
14 A. No, I have not completed part one.
15 Q. Okay. Go ahead.
16 A. This is how Stutz knew that Rick Werlin's
17 story was a lie.
18 Q. Before or after his deposition?
19 A. Before.
20 Q. Go ahead. I'm sorry.
21 A. At the time that this March 27th event
22 happened where I -- according to Richard Werlin, went
23 into this extreme psychotic state with apparently some
24 severe neurological problems too, I had just been
25 asked by him to come back to work. This happened on a
page 110
1 Tuesday, and I had been asked by him on Sunday to come
2 back to my classroom and work Monday morning.
3 I told him that I was afraid that there
4 would be new allegations, that these horrible
5 allegations against me of this Columbine-like event
6 that I was about to perpetrate, no one had -- first of
7 all, they were still anonymous, and no one had
8 retracted them. No one had made any apologies to me.
9 I thought, well, what's -- you know, they are just
10 going to make more allegations.
11 So I said, "No, I don't feel that I can come
12 back to work, although I would be happy to come in and
13 help the substitute." Apparently, the substitutes
14 were doing really bad. Those children were really
15 harmed, really harmed.
16 So, anyway, so I came back to help the
17 substitute. Here I am, this person --
18 Q. This is in 2001?
19 A. Yes. March 27th. Come back to help the
20 substitute. Also, the parents were upset about what
21 had happened to me. On this Tuesday morning,
22 March 27th, there was a parent meeting about me. You
23 would think that -- no one had told -- no one had told
24 me anything. This had been going on since
25 February 12th, and Richard Werlin had been -- he had
111
1 not been investigating. It turns out there was never
2 an investigation. The final report was the initial
3 allegations. There was never an investigation.
4 So, anyway, I go to the school district -- I
5 mean, to the principal's office for this meeting, and
6 the principal says she doesn't want me there at the
7 meeting.
8 The parents later told me that she had --
9 when they all went into her office and I was left
10 outside, that she called up Rick Werlin then and asked
11 him to come over. So he came over.
12 What really happened is this. I was in the
13 office and he said, "Maura, could you come out here."
14 Right in front of the office he said, "I just wanted
15 to welcome you back. It is good to see you back."
16 Then he started walking outside toward the front of
17 the school, and I followed him.
18 He stopped outside almost to the sidewalk,
19 not quite, and said nothing. He just stood there. I
20 said, "Do you want me to leave?" And he said, "Oh,
21 Maura" -- I know that wasn't much of an answer.
22 So I said, again, "Do you want me to leave?"
23 He goes, "Oh, Maura." I thought that it was pretty
24 obvious that he wanted me to leave but he didn't want
25 to say so.
| > > > Rick Werlin didn't commit perjury in this case until after Stutz law firm got involved. Stutz told him what to say and knew what he would say. |
| The March 27, 2008 incident > > > Richard Werlin perjury |
| Testimony on this page: The March 27, 2001 incident Daniel Shinoff suborns Richard Werlin's perjury Stutz lawyer Kelly Angell suborns Robin Donlan's perjury |
| Deposition of Maura Larkins by Ljubisa Kostic June 16, 2008 Pages 105 to 111 |
| Stutz subornation of perjury by Richard Werlin and Robin Donlan |
| Kelly Angell suborns Robin Donlan perjury on camera. |
investigating
page 111 line 2
page 111 line 2
| Public Records Requests |
| Payments to Shinoff |
| Maura Larkins v. CVESD |
| BLOGS |
| 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 |
| 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 |