MAURA LARKINS
Defendant pro se
STUTZ ARTIANO SHINOFF
& HOLTZ, APC,
Plaintiff,
v.
MAURA LARKINS,
and DOES 1 through 100, inclusive,
Defendants.
______________________________
Defendant Maura Larkins offers the following list of needed discovery:
A. Persons whose depositions are needed and documents to be produced:
1. Daniel Shinoff, SASH attorney in GIC 781970, refused to attend deposition, and
also refused to produce documents. I need to know if the documents I requested
have been destroyed. I need two sets of Bate-Stamped documents numbered 1-84
(One set starts with 01, the other starts with 1);
2. Robert Gallagher, former SASH attorney who left firm right after I sent evidence of
obstruction of justice;
3. Santa Barbara Sheriff’s Department, including records of CLETS searches
mentioned in Sheriff’s letter to me;
B. Also needed are depositions from the following individuals who avoided
depositions in GIC 781970:
4. Richard Werlin, former Assistant Superintendent, Chula Vista Elementary School
District;
5. Michael Carlson, Deputy, Santa Barbara Sheriff’s Department;
6. Stephenie Parker-Petitt, teacher;
7. Jim Groth, CTA director;
8. Monica Sorenson, Vice-President Chula Vista Educators;
C. Depositions which might be needed:
Tim O’Neill, former executive director Chula Vista Educators
Joyce Abrams, Chula Vista Educators director
Lowell Billings, Superintendent, Chula Vista Elementary School District
Jeffery Morris, SASH attorney
Kelly Angell Minnehan, former SASH attorney
Peggie Myers, Chula Vista Educators President.
Dated: Jan. 9, 2008
Maura Larkins, defendant in pro per
Why discovery is needed in Stutz v. Larkins
|
) Case number: 07cv02202-WQH (WMc)
)
) Judge: Hon. William Q. Hayes
) (Hon. William McCurine, Jr.)
) Date: Jan. 9, 2008
) Time: 3:00 p.m.
)
)
) EARLY CASE EVALUATION
) DISCOVERY NEEDED
)
)
)
)
) COMPLAINT FILED: 10/05/07
) TRIAL DATE: None set
UNITED STATES DISTRICT COURT Southern District of California
|
Why I need discovery
I have an advantage over the jurors that will be deciding Stutz v. Larkins. Regarding almost every piece of evidence or testimony in the case, I know if it is genuine or fabricated because I received (or failed to receive) the documents, and I heard the evidence. I know that Stutz, Artiano, Shinoff & Holtz committed and covered-up crimes.
But the jurors don't have direct knowledge. They need proof.
This is the evidence I need:
|
SAN DIEGO EDUCATION
REPORT
mauralarkins.com
by Maura Larkins
TO: All PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on THURSDAY November 8, 2007, at 1620 5th Ave Blvd
Ste 770, San Diego, CA 92101, telephone (619) 232-1164, Defendant Maura Larkins
will take the depositions of:
(1) STUTZ, ARTIANO SHINOFF & HOLTZ, APC (“SASH”), 2488 Historic Decatur
Rd # 200, San Diego, CA, telephone (619) 232-3122 at 10:00 a.m., and
(2) Daniel R. Shinoff, 2488 Historic Decatur Rd # 200, San Diego, CA, telephone
(619) 232-3122 at 1:00 p.m..
The depositions will be upon oral examination before a Certified Shorthand Reporter,
and will continue from day to day, Saturdays, Sundays, and holidays excepted, until
completed.
The depositions will also be recorded by videotape as authorized by CCP section
20225(d) and (l). Defendant reserves the right to use any videotaped portion of the
deposition testimony at a hearing or trial in this matter. The deposition may also be
recorded through such means as to provide the instant display of the testimony as
also authorized by CCP section 2025 (d).
Defendant requests that the following documents be produced by SASH at its
deposition at 10:00 a.m. on November 8, 2007:
1) The documents Bate-stamped with the numbers 5, 6, 9, 11, 13 through
19 inclusive, 24, 27, 28, 39, 44, 48, 51, 52, 53, 55, 63, 64, 65, 77 through 83
inclusive, which were collected and Bate-stamped by Daniel Shinoff and/or
other agents of SASH in or about the fall of 2001, regarding a tort claim filed
by Maura Larkins against Chula Vista Elementary School District on October 4,
2001. The Bate-stamps begin with the number “1” (not “01” or “001”) and
continue through 87. Please be particularly careful to bring the documents
Bate-stamped “39” and “55.”
2) Documents containing information regarding the dollar amounts all payments
received by SASH from Chula Vista Elementary School District (“CVESD”) and/or San
Diego County Office of Education and/or San Diego County Office of Education-Joint
Powers Authority and/or any insurance company or insurance broker for legal
representation of CVESD and/or its employees and/or officers from July 1, 2000
through July 1, 2005.
3) All documents supporting SASH’s claim that Maura Larkins’ website has caused
financial losses to SASH.
4) All documents related to any investigation by SASH to determine if Maura
Larkins’ complaints, either in writing to SASH, or on her website, might be true.
5) Documents indicating SASH’s policies with regard to complaints about unethical
or illegal behavior on the part of its attorneys.
Defendant Maura Larkins requests that Daniel Shinoff produce the following
documents at his deposition at 1 p.m. on Thursday November 8, 2007:
The documents Bate-stamped with the numbers 5, 6, 9, 11, 13 through 19
inclusive, 24, 27, 28, 39, 44, 48, 51, 52, 53, 55, 63, 64, 65, 77 through 83
inclusive, which were collected and Bate-stamped by Daniel Shinoff and/or
other agents of SASH in or about the fall of 2001, regarding a tort claim filed
by Maura Larkins against Chula Vista Elementary School District on October 4,
2001.
The Bate-stamps begin with the number “1” (not “01” or “001”) and continue through
87. Please be particularly careful to bring the documents Bate-stamped “39” and “55.”
DATED: October 24, 2007
_____________________________________
Maura Larkins, defendant in pro per
Defendant in pro per
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO
STUTZ ARTIANO SHINOFF
& HOLTZ, APC,
Plaintiff,
vs.
MAURA LARKINS,
and DOES 1 through 100, inclusive,
Defendants.
_________________________________
) Date
)
)
)
)
)
) NOTICE OF DEPOSITIONS
) AND REQUEST FOR
) PRODUCTION OF DOCUMENTS
)
)
)
) TRIAL DATE: NOT SET
) CASE FILED: OCTOBER 5, 2007
)
)