Page 87
Q. Why did you not object during that meeting?
A. Because he said that—that other people felt that they were in danger, because he sent you
home with pay and so there was no discipline—disciplinary action taken and so there was no
discipline—disciplinary action taken.
Q. Did he ask for a fitness for duty letter from a doctor?
THE WITNESS: I don’t remember.
Line 12
Q. [W]e did discuss that last time, and we had it pretty well established that he did.
Page 88
Q. The allegations were anonymous?
A. Yes.
Q. And did he say any specifics of what I was accused of having done?
A. No. I don’t think he told us what they said to him. He just expressed that they were fearful.
Page 89
Q. Do you approve of a teacher being taken out of her classroom on the basis of anonymous,
vague allegation?
Line 15
A. No.
[Maura Larkins note: [Gina Boyd told me on February 11, 2001 that Werlin had no choice but to place
me on leave. She did approve the action.]
Q. Why did you not immediately file a grievance when this happened?
A. There was no negative impact.
Page 90
[Maura Larkins note: Gretchen Donndelinger’s show no instances of Gina objecting, nor that meeting
was brief. Maura Larkins' testimony show that the meeting was considerably longer than
Donndelinger's notes indicate. Gretchen’s notes were several pages, and Gina’s notes were "lost" or
"accidentally destroyed".]
Q. It’s your testimony that you expressed at the meeting that you were concerned about
anonymous complaints?
Line 25
A. Yes, I did.
Page 91
Line 1
Q. But you took notes at that meeting, didn’t you?
A. I believe I did.
Q. And we don’t have the notes, do we? You haven’t produced the notes?
A. No.
What happened to those notes?
I don’t know.
At that meeting, you knew it was an important case, didn’t you?
Yes.
You didn’t take good care of those notes?
A. I don’t know where the notes are, Maura.
Q. Did you make a special effort to take care of those notes?
A. Apparently not.
Q.Did you think those notes were important?
A. The information contained would have been very brief, that you were placed on administrative
transfer due to two complaints from people and that—you know, there was very little content to
that meeting other than that you were placed on administrative leave and that there would be an
investigation.
Q. There was little content to that meeting? How long did the meeting last?
A. Not very long.
Page 92
[Maura Larkins note: Kelly Angell is not under oath when she makes these statements. Of course, that
fact might not make any difference. Angell and Hersh were bullying Maura Larkins, who was alone and
opposed by three people, including Jackie Robinson, Law Clerk]
Kelly Angell [Minnehan] ...Plaintiff’s behavior of making facial gestures, laughing, sighing is
directed at the witness as a method of intimidating and being aggressive and argumentative and
coercing the witness.
Page 93
MR. HERSH: No, I’m kidding.
MS. LARKINS: You’re a funny guy.
Okay, I gasped. I gasped and I had
In your notes it said they feared for their lives. So I know you did still have your notes. It was
about a month later in March when the question was whether it was one or two people who had
called.
DESTROYED NOTES CONTD.
Your objection was false, saying that I was laughing and intimidating. You’re the one that forced
me to explain what was really going on here.
page 94
9 minute break
10:51:18
Page 105
CTA is in control, and pretends actions are made only by local affiliate
Line 6 I asked to address the representative council in December of 2002
Line 23 Q. Who made the decision that I would not be allowed to appear?
A. Tim O’Neill and I.
Page 106
Q. So who exactly determined that I would not be allowed to appear?
Line 17
A. Tim and I.
Page 108
Line 16 …I am very happy that we have an audiotape being made at the same time, because I
believe that Ms. Angell is trying to create a deceptive written record.
Line 23 Were you worried that your reputation would be harmed if I addressed the Representative
Council?
A. No.
Page 109
11 Did you believe that it would be morally wrong if I were to address the Representative Council?
Gina Boyd’s code of ethics.
I’m trying to figure out what was your reason for denying my request.
Page 110
Line 6 I just want to know why Gina Boyd denied my request to address the Representative
Council.
MS ANGELL: Let the record reflect that plaintiff is gesticulating with her hands, emphasizing her
question and speech in a manner that appears to be argumentative.
MR. HERSH: And snickering.
MS. ANGELL: And covering her mouth when she laughs.
MS. LARKINS: Let the record show that Ms. Angell has an extremely sour expression on her face.
She looks like she’s been chewing on lemons, and she’s rocking in her chair.
MS. ANGELL: Let the record reflect that plaintiff is staring down defense counsel during that—
however long that intermittent time period was in a manner similar to what was done in court when
the court directed her, plaintiff that is, to refrain from that type of behavior.
[when I was crying, and judge told me to look at him to help me stop crying]
MS. LARKINS: Ms. Angell, you could not possibly have known how long I was looking at you unless
you were looking at me for the same length of time.
Page 111
Line 7 Q. Okay. I understood that you felt that you were not obliged to let me address the
Representative Council. That’s what this states. What I want to know is why didn’t you let me do it
anyway?
A. Because the items that before—come before the council need to be legitimately placed
there, and this was not.
Q. So you have the—so according to the bylaws of CVE the president can forbid anyone to
come and complain about her?
Line 24 Q. Did you have the right to deny my request?
A. Yes.
Page 112
Line 1 Q. Did you do it to protect yourself?
A. No.
Line 3
Q. Do you have the right to deny a teacher the ability to make a complaint against you?
Line 13. A. I don’t know.
Line 16 Q. Do you have the right to deny a teacher the ability to make an oral complaint about you
to the Representative Council?
A. I don’t know. I don’t think it’s in our bylaws anywhere, but—
Q. But you did deny me that right; is that correct?
A. I don’t think that you had the right according to the bylaws to make that particular complaint.
Page 113
Line 11 A. Yes, I’ve read it.
Line 19 MS. LARKINS: Well, as it happens Exhibit 6 is an editorial published in the Union Tribune
titled “Silence is Not Golden in Chula Vista Elementary School District.”
MR. HERSH: Dated September 2nd, 2004?
Page 114
Line 16 A. “This is the most egregious and disrespectful affront to district personnel I have ever
seen, and I have been involved with this district for over 25 years, said Boyd of the teachers’
organization, which has filed a grievance.”
115
Line 9
Q. Who did you speak to when you made this statement?
A. I think his name is Don. I’m not—
Q. Okay. This most egregious and disrespectful affront to district personnel that you spoke of
here, can you tell us what it was? What was the affront?
That they were administratively transferred without cause.
Was the contract violated in this case?
Yes.
The transfer article.
116
Line 4 I’m going to instruct the witness not to answer a question concerning a matter that is in
litigation
MS. LARKINS: This case has made strange bedfellows, has it not?
117
Line 18 Q. Okay. Were five teachers transferred out of Castle Park Elementary School recently?
MS. ANGELL: Objection. The witness has previously been instructed by her counsel not to
respond to questions concerning a matter that’s pend—currently in litigation, specifically the
transfer of teachers at Castle Park Elementary School in or about September of 2004?
119
Q. Did you read the part of the article where Felicia Starr and Kim Simmons made statements to the
Star-News?
A. Yes.
120
Line 9
Q. Okay. What is your relationship with Felicia Starr?
A. I know her as a parent of children who attend Castle Park School.
Q. How did you come to know her?
A. She’s also assisting with a campaign for one of the board of education candidates.
Q. And you are also working on that campaign?
A. Yes.
Q. Okay. And how—what is your relationship with Kim Simmons?
A. I know that she’s a parent of children at Castle Park School.
Q. How did you come to know her?
A. Just by being at the school I’ve been introduced to her.
Q. How long have you known her?
121
A. I’ve known her by name probably since September.
Q. Just last month?
A. Yeah.
Line 9
Q. I’m sorry. How many times have you talked to Kim Simmons?
A. Maybe two or three.
Q. What is your--do you consider her a friend?
A. I have a congenial relationship with her.
Q. Okay. Did you caress her hand at the last Chula Vista Elementary School District School
District board meeting when she put her hand on your shoulder?
A. I don’t know.
Q. Okay. Did Felicia Starr sit with you at the last board meeting?
A. Yes.
122
Line 8 MR. HERSH: Just for the record, just as I did last time, I’ve already told you, you know, we’re
leaving after lunch because you’re not asking questions that are within the scope of discovery.
You’ve got another half hour.
Line 20 What is your current relationship with Robin Donlan?
A. She’s one of my unit members and she’s a friend.
Page 123
Line 18 MS. LARKINS: Yeah. Is this a fair article about Ollie Matos?
THE WITNESS: Yes.
[THE FOLLOWING IS A SIMPLE QUESTION ABOUT LOGICAL THINKING RELATED TO THE VALIDITY OF A
POLL]
Page 124
Line 2 Q. When—it has a poll here that says 17 teachers answered a poll, but it doesn’t tell the total
number of teachers. Do you think that the whole—that the total number of teachers should have
been told?
A. I don’t have any opinion about that in either direction.
Q. It’s sort of a math question. I mean, wouldn’t—if 17 is half the number of teachers, the poll
isn’t worth much. If 17 is the total number of teachers, then the poll is pretty—has a lot more value,
and they don’t tell.
MS. ANGELL: Objection.
125
Q. Did you think that this article was unfair to the ELAC parents, accusing them of trying to take
over power at Castle Park?...
A. No.
Q. But no ELAC parents were interviewed or quoted in the article, were they?
A. I don’t know. I don’t know.
Q. But it would matter, wouldn’t it? If they weren’t, it would be unfair?
A. Apparently Kelley Dupuis thought it was fair, and really don’t have any opinion about it.
Q. Okay. Did you think that my being taken out of my classroom on February 12th, 2001 was fair?
A. No, I don’t.
Q. Did you think my being taken out of my classroom on April 20, 2001 was fair?
A. Is that the pencil incident?
126
Line 7
Q. Do you believe that Richard Werlin lied when he described what you have just referred to as
I think the—what did you say? …The pencils incident?
A. The pencils incident.
Q. Okay. Do you believe that Mr. Werlin lied when he described the pencils incident?
…THE WITNESS: No.
He said you were very angry and upset and that he was trying to calm you down and that you threw
a
127
Pencil at the ground near him.
And that then you walked away. I can remember what you said, but I believe that that was Mr.
Werlin’s depiction of the event.
Did he say he tried to welcome me back and then I exploded for no apparent reason?
A. Yes, he did.
[she contradicts self—she also said I was upset because my job was in jeopardy]
Line 10 Okay. Thank you. Did CVE file a grievance about the pencils incident?
A. No.
Q. Did Mr. Werlin say that I behaved in an irrational and unprofessional manner during the
pencils incident?
A. Yes.
128
Exhibit 8 Werlin April 4, 2001 letter
130
Ms. Boyd, to your knowledge, was this grievance ever filed?
A. It doesn’t look to me like it was because it’s not signed or dated.
Q. Is it your understanding that CVE filed a grievance on my behalf?
A. About—about this incident?
Q. About anything. Did CVE ever file a grievance on my behalf?
MR. HERSH: If you remember.
THE WITNESS: I don’t remember.
132
Line 23 Were you concerned that I behaved like a person who might be seriously mentally ill?
133
I thought that you were duly upset considering what you were going through.
Q. So you think it’s normal behavior for someone to run away and come back and run away and
come back?
A. I don’t know whether that’s what you did. That was his description.
Q. So you don’t necessarily believe that that was true, his—his allegation was true?
A. I think his perceptions might not be the same as others.
Q. Perceptions are one thing but the truth is something else. Do you think that I ran away and
came back and ran away and came back?
A. I don’t know.
MIDDLE PACKET
151
Line 12 Q. Can you tell us, Ms. Boyd, what difference you notice between the purported grievance
that we looked at earlier and the purported grievance that we’re looking at now?
Page 178
Why is there no signature on this grievance?
This is a copy. The one given to Werlin was signed by Jim Groth.
(Gina was lying, but she wasn’t under oath when she wrote this.)
179
Line 1
Somewhere around May 30th, 2001, you believed—did you believe that Jim Groth had signed a
grievance on my behalf and filed it with the district?
A. Yes.
Q. Okay. Do you have any reason to think that a grievance meeting was held regarding this
grievance?
A. I don’t know whether there—whether one was.
Q. It’s—it’s a mystery. Okay.
181
Line 4 MS. LARKINS: As I’ve said before, all my evidence
…comes from events at Chula Vista Elementary School District and the preposterous behavior of
Gina Boyd and others including the lawyers involved in this case which points to an effort to cover
up the truth. And that’s why I need to ask questions about why people were investigating
themselves …
25 MS. LARKINS: Haven’t they already been asked and answered?
Page 183
The last time you were here you stayed for an hour and a half, not a few hours. This deposition was
originally scheduled in 2002.
Page 184
Ms. Boyd, why didn’t you come forward voluntarily in 2002 to testify when I—to help me with my
administrative hearing and my lawsuit?
MS. ANGELL: Objection. Seeks to invade attorney-client privilege. Seeks to invade attorney work
product. Calls for speculation. Calls for facts not in evidence.
But I’m wondering why you didn’t voluntarily come forward and testify on my behalf?
Page 185
Did you say that she would not testify in a deposition by me regarding anything to do with CVE or
her representation of me?
214
13 Do you believe this grievance should have been arbitrated?
No.
Page 215
Memorandum of understanding
217
19 I have none of those records.
So you think you possibly could have responded to this letter and then lost your copy?
I presented all of my copies of all documentation to CTA legal.
218
I don’t recall.
220
("I don't recall is repeated, but together I've counted them as one "don’t recall.")
lines 1-4
221
That machine is in my office.
So you are the only one that has access to it?
222-223
Yes.
Did you talk to your friend Robin about my case in March of 2001. No, I don’t believe so. No.
[She remembers that!!!]
[Robin not fear for life]
Page 226
Line 15 Q. Do you keep any record of calls you make?
A. Yes.
But you’ve lost all your records regarding…
get back to them. It’s my phone log.
227
When you received faxes from me where did you put them?
A. Probably in a file.
228
8. A. No, I don’t remember this.
13. Okay. I’m just going to look through here and see if I can find something that’s so visually
compelling that you’d really remember it.
I know I tried to make things visually compelling so you would look at them.
MR. HERSH: I didn’t know there was a rational reason for your interest in faxes.
MS. LARKINS
MR. HERSH I didn’t assume irrationality. I just assumed a lack of rationality.
229 Ring a bell?
No.
232
14 Q. Does this seem familiar to you?
15 A. No.
18 Ms. Boyd, can you explain how there can be so many letters written to you and so few
responses from you?
A. No.
22. Okay. Do you remember seeing this one?
A. No.
234
236
2 Does this letter strike you as familiar?
No.
4. Did you become angry at me during 2001?
15. What if they were working hard to uncover a crime you had committed?
Q. I believe we had Jim Groth representing you.
A. No.
237
Have you ever had someone from outside of CVE represent a CVE member?
No.
As my lawyer, you must reveal that
238
to me. Then you should call CTA and tell them you do not wish…
Such as your ties with my accusers, and ties with the board of directors which you apparently hope
to exploit on Monday.”
239
4-25-01 As your lawyer, I’m telling you it is very important for you to come to this meeting today d
240
When you received this did you call CTA and tell them that you did not wish to represent me and
that I need a representative from outside the district?
No.
Why not?
Because I didn’t believe that was true.
241
Do you remember this?
Not specifically.
(This doesn’t count as a not remember, because I asked her the same question on next page)
242
It attracted your attention, didn’t it?
Just now?
Just now.
Yes.
But you don’t recall having received it when—at the time?
Q. Why did you not object during that meeting?
A. Because he said that—that other people felt that they were in danger, because he sent you
home with pay and so there was no discipline—disciplinary action taken and so there was no
discipline—disciplinary action taken.
Q. Did he ask for a fitness for duty letter from a doctor?
THE WITNESS: I don’t remember.
Line 12
Q. [W]e did discuss that last time, and we had it pretty well established that he did.
Page 88
Q. The allegations were anonymous?
A. Yes.
Q. And did he say any specifics of what I was accused of having done?
A. No. I don’t think he told us what they said to him. He just expressed that they were fearful.
Page 89
Q. Do you approve of a teacher being taken out of her classroom on the basis of anonymous,
vague allegation?
Line 15
A. No.
[Maura Larkins note: [Gina Boyd told me on February 11, 2001 that Werlin had no choice but to place
me on leave. She did approve the action.]
Q. Why did you not immediately file a grievance when this happened?
A. There was no negative impact.
Page 90
[Maura Larkins note: Gretchen Donndelinger’s show no instances of Gina objecting, nor that meeting
was brief. Maura Larkins' testimony show that the meeting was considerably longer than
Donndelinger's notes indicate. Gretchen’s notes were several pages, and Gina’s notes were "lost" or
"accidentally destroyed".]
Q. It’s your testimony that you expressed at the meeting that you were concerned about
anonymous complaints?
Line 25
A. Yes, I did.
Page 91
Line 1
Q. But you took notes at that meeting, didn’t you?
A. I believe I did.
Q. And we don’t have the notes, do we? You haven’t produced the notes?
A. No.
What happened to those notes?
I don’t know.
At that meeting, you knew it was an important case, didn’t you?
Yes.
You didn’t take good care of those notes?
A. I don’t know where the notes are, Maura.
Q. Did you make a special effort to take care of those notes?
A. Apparently not.
Q.Did you think those notes were important?
A. The information contained would have been very brief, that you were placed on administrative
transfer due to two complaints from people and that—you know, there was very little content to
that meeting other than that you were placed on administrative leave and that there would be an
investigation.
Q. There was little content to that meeting? How long did the meeting last?
A. Not very long.
Page 92
[Maura Larkins note: Kelly Angell is not under oath when she makes these statements. Of course, that
fact might not make any difference. Angell and Hersh were bullying Maura Larkins, who was alone and
opposed by three people, including Jackie Robinson, Law Clerk]
Kelly Angell [Minnehan] ...Plaintiff’s behavior of making facial gestures, laughing, sighing is
directed at the witness as a method of intimidating and being aggressive and argumentative and
coercing the witness.
Page 93
MR. HERSH: No, I’m kidding.
MS. LARKINS: You’re a funny guy.
Okay, I gasped. I gasped and I had
In your notes it said they feared for their lives. So I know you did still have your notes. It was
about a month later in March when the question was whether it was one or two people who had
called.
DESTROYED NOTES CONTD.
Your objection was false, saying that I was laughing and intimidating. You’re the one that forced
me to explain what was really going on here.
page 94
9 minute break
10:51:18
Page 105
CTA is in control, and pretends actions are made only by local affiliate
Line 6 I asked to address the representative council in December of 2002
Line 23 Q. Who made the decision that I would not be allowed to appear?
A. Tim O’Neill and I.
Page 106
Q. So who exactly determined that I would not be allowed to appear?
Line 17
A. Tim and I.
Page 108
Line 16 …I am very happy that we have an audiotape being made at the same time, because I
believe that Ms. Angell is trying to create a deceptive written record.
Line 23 Were you worried that your reputation would be harmed if I addressed the Representative
Council?
A. No.
Page 109
11 Did you believe that it would be morally wrong if I were to address the Representative Council?
Gina Boyd’s code of ethics.
I’m trying to figure out what was your reason for denying my request.
Page 110
Line 6 I just want to know why Gina Boyd denied my request to address the Representative
Council.
MS ANGELL: Let the record reflect that plaintiff is gesticulating with her hands, emphasizing her
question and speech in a manner that appears to be argumentative.
MR. HERSH: And snickering.
MS. ANGELL: And covering her mouth when she laughs.
MS. LARKINS: Let the record show that Ms. Angell has an extremely sour expression on her face.
She looks like she’s been chewing on lemons, and she’s rocking in her chair.
MS. ANGELL: Let the record reflect that plaintiff is staring down defense counsel during that—
however long that intermittent time period was in a manner similar to what was done in court when
the court directed her, plaintiff that is, to refrain from that type of behavior.
[when I was crying, and judge told me to look at him to help me stop crying]
MS. LARKINS: Ms. Angell, you could not possibly have known how long I was looking at you unless
you were looking at me for the same length of time.
Page 111
Line 7 Q. Okay. I understood that you felt that you were not obliged to let me address the
Representative Council. That’s what this states. What I want to know is why didn’t you let me do it
anyway?
A. Because the items that before—come before the council need to be legitimately placed
there, and this was not.
Q. So you have the—so according to the bylaws of CVE the president can forbid anyone to
come and complain about her?
Line 24 Q. Did you have the right to deny my request?
A. Yes.
Page 112
Line 1 Q. Did you do it to protect yourself?
A. No.
Line 3
Q. Do you have the right to deny a teacher the ability to make a complaint against you?
Line 13. A. I don’t know.
Line 16 Q. Do you have the right to deny a teacher the ability to make an oral complaint about you
to the Representative Council?
A. I don’t know. I don’t think it’s in our bylaws anywhere, but—
Q. But you did deny me that right; is that correct?
A. I don’t think that you had the right according to the bylaws to make that particular complaint.
Page 113
Line 11 A. Yes, I’ve read it.
Line 19 MS. LARKINS: Well, as it happens Exhibit 6 is an editorial published in the Union Tribune
titled “Silence is Not Golden in Chula Vista Elementary School District.”
MR. HERSH: Dated September 2nd, 2004?
Page 114
Line 16 A. “This is the most egregious and disrespectful affront to district personnel I have ever
seen, and I have been involved with this district for over 25 years, said Boyd of the teachers’
organization, which has filed a grievance.”
115
Line 9
Q. Who did you speak to when you made this statement?
A. I think his name is Don. I’m not—
Q. Okay. This most egregious and disrespectful affront to district personnel that you spoke of
here, can you tell us what it was? What was the affront?
That they were administratively transferred without cause.
Was the contract violated in this case?
Yes.
The transfer article.
116
Line 4 I’m going to instruct the witness not to answer a question concerning a matter that is in
litigation
MS. LARKINS: This case has made strange bedfellows, has it not?
117
Line 18 Q. Okay. Were five teachers transferred out of Castle Park Elementary School recently?
MS. ANGELL: Objection. The witness has previously been instructed by her counsel not to
respond to questions concerning a matter that’s pend—currently in litigation, specifically the
transfer of teachers at Castle Park Elementary School in or about September of 2004?
119
Q. Did you read the part of the article where Felicia Starr and Kim Simmons made statements to the
Star-News?
A. Yes.
120
Line 9
Q. Okay. What is your relationship with Felicia Starr?
A. I know her as a parent of children who attend Castle Park School.
Q. How did you come to know her?
A. She’s also assisting with a campaign for one of the board of education candidates.
Q. And you are also working on that campaign?
A. Yes.
Q. Okay. And how—what is your relationship with Kim Simmons?
A. I know that she’s a parent of children at Castle Park School.
Q. How did you come to know her?
A. Just by being at the school I’ve been introduced to her.
Q. How long have you known her?
121
A. I’ve known her by name probably since September.
Q. Just last month?
A. Yeah.
Line 9
Q. I’m sorry. How many times have you talked to Kim Simmons?
A. Maybe two or three.
Q. What is your--do you consider her a friend?
A. I have a congenial relationship with her.
Q. Okay. Did you caress her hand at the last Chula Vista Elementary School District School
District board meeting when she put her hand on your shoulder?
A. I don’t know.
Q. Okay. Did Felicia Starr sit with you at the last board meeting?
A. Yes.
122
Line 8 MR. HERSH: Just for the record, just as I did last time, I’ve already told you, you know, we’re
leaving after lunch because you’re not asking questions that are within the scope of discovery.
You’ve got another half hour.
Line 20 What is your current relationship with Robin Donlan?
A. She’s one of my unit members and she’s a friend.
Page 123
Line 18 MS. LARKINS: Yeah. Is this a fair article about Ollie Matos?
THE WITNESS: Yes.
[THE FOLLOWING IS A SIMPLE QUESTION ABOUT LOGICAL THINKING RELATED TO THE VALIDITY OF A
POLL]
Page 124
Line 2 Q. When—it has a poll here that says 17 teachers answered a poll, but it doesn’t tell the total
number of teachers. Do you think that the whole—that the total number of teachers should have
been told?
A. I don’t have any opinion about that in either direction.
Q. It’s sort of a math question. I mean, wouldn’t—if 17 is half the number of teachers, the poll
isn’t worth much. If 17 is the total number of teachers, then the poll is pretty—has a lot more value,
and they don’t tell.
MS. ANGELL: Objection.
125
Q. Did you think that this article was unfair to the ELAC parents, accusing them of trying to take
over power at Castle Park?...
A. No.
Q. But no ELAC parents were interviewed or quoted in the article, were they?
A. I don’t know. I don’t know.
Q. But it would matter, wouldn’t it? If they weren’t, it would be unfair?
A. Apparently Kelley Dupuis thought it was fair, and really don’t have any opinion about it.
Q. Okay. Did you think that my being taken out of my classroom on February 12th, 2001 was fair?
A. No, I don’t.
Q. Did you think my being taken out of my classroom on April 20, 2001 was fair?
A. Is that the pencil incident?
126
Line 7
Q. Do you believe that Richard Werlin lied when he described what you have just referred to as
I think the—what did you say? …The pencils incident?
A. The pencils incident.
Q. Okay. Do you believe that Mr. Werlin lied when he described the pencils incident?
…THE WITNESS: No.
He said you were very angry and upset and that he was trying to calm you down and that you threw
a
127
Pencil at the ground near him.
And that then you walked away. I can remember what you said, but I believe that that was Mr.
Werlin’s depiction of the event.
Did he say he tried to welcome me back and then I exploded for no apparent reason?
A. Yes, he did.
[she contradicts self—she also said I was upset because my job was in jeopardy]
Line 10 Okay. Thank you. Did CVE file a grievance about the pencils incident?
A. No.
Q. Did Mr. Werlin say that I behaved in an irrational and unprofessional manner during the
pencils incident?
A. Yes.
128
Exhibit 8 Werlin April 4, 2001 letter
130
Ms. Boyd, to your knowledge, was this grievance ever filed?
A. It doesn’t look to me like it was because it’s not signed or dated.
Q. Is it your understanding that CVE filed a grievance on my behalf?
A. About—about this incident?
Q. About anything. Did CVE ever file a grievance on my behalf?
MR. HERSH: If you remember.
THE WITNESS: I don’t remember.
132
Line 23 Were you concerned that I behaved like a person who might be seriously mentally ill?
133
I thought that you were duly upset considering what you were going through.
Q. So you think it’s normal behavior for someone to run away and come back and run away and
come back?
A. I don’t know whether that’s what you did. That was his description.
Q. So you don’t necessarily believe that that was true, his—his allegation was true?
A. I think his perceptions might not be the same as others.
Q. Perceptions are one thing but the truth is something else. Do you think that I ran away and
came back and ran away and came back?
A. I don’t know.
MIDDLE PACKET
151
Line 12 Q. Can you tell us, Ms. Boyd, what difference you notice between the purported grievance
that we looked at earlier and the purported grievance that we’re looking at now?
Page 178
Why is there no signature on this grievance?
This is a copy. The one given to Werlin was signed by Jim Groth.
(Gina was lying, but she wasn’t under oath when she wrote this.)
179
Line 1
Somewhere around May 30th, 2001, you believed—did you believe that Jim Groth had signed a
grievance on my behalf and filed it with the district?
A. Yes.
Q. Okay. Do you have any reason to think that a grievance meeting was held regarding this
grievance?
A. I don’t know whether there—whether one was.
Q. It’s—it’s a mystery. Okay.
181
Line 4 MS. LARKINS: As I’ve said before, all my evidence
…comes from events at Chula Vista Elementary School District and the preposterous behavior of
Gina Boyd and others including the lawyers involved in this case which points to an effort to cover
up the truth. And that’s why I need to ask questions about why people were investigating
themselves …
25 MS. LARKINS: Haven’t they already been asked and answered?
Page 183
The last time you were here you stayed for an hour and a half, not a few hours. This deposition was
originally scheduled in 2002.
Page 184
Ms. Boyd, why didn’t you come forward voluntarily in 2002 to testify when I—to help me with my
administrative hearing and my lawsuit?
MS. ANGELL: Objection. Seeks to invade attorney-client privilege. Seeks to invade attorney work
product. Calls for speculation. Calls for facts not in evidence.
But I’m wondering why you didn’t voluntarily come forward and testify on my behalf?
Page 185
Did you say that she would not testify in a deposition by me regarding anything to do with CVE or
her representation of me?
214
13 Do you believe this grievance should have been arbitrated?
No.
Page 215
Memorandum of understanding
217
19 I have none of those records.
So you think you possibly could have responded to this letter and then lost your copy?
I presented all of my copies of all documentation to CTA legal.
218
I don’t recall.
220
("I don't recall is repeated, but together I've counted them as one "don’t recall.")
lines 1-4
221
That machine is in my office.
So you are the only one that has access to it?
222-223
Yes.
Did you talk to your friend Robin about my case in March of 2001. No, I don’t believe so. No.
[She remembers that!!!]
[Robin not fear for life]
Page 226
Line 15 Q. Do you keep any record of calls you make?
A. Yes.
But you’ve lost all your records regarding…
get back to them. It’s my phone log.
227
When you received faxes from me where did you put them?
A. Probably in a file.
228
8. A. No, I don’t remember this.
13. Okay. I’m just going to look through here and see if I can find something that’s so visually
compelling that you’d really remember it.
I know I tried to make things visually compelling so you would look at them.
MR. HERSH: I didn’t know there was a rational reason for your interest in faxes.
MS. LARKINS
MR. HERSH I didn’t assume irrationality. I just assumed a lack of rationality.
229 Ring a bell?
No.
232
14 Q. Does this seem familiar to you?
15 A. No.
18 Ms. Boyd, can you explain how there can be so many letters written to you and so few
responses from you?
A. No.
22. Okay. Do you remember seeing this one?
A. No.
234
236
2 Does this letter strike you as familiar?
No.
4. Did you become angry at me during 2001?
15. What if they were working hard to uncover a crime you had committed?
Q. I believe we had Jim Groth representing you.
A. No.
237
Have you ever had someone from outside of CVE represent a CVE member?
No.
As my lawyer, you must reveal that
238
to me. Then you should call CTA and tell them you do not wish…
Such as your ties with my accusers, and ties with the board of directors which you apparently hope
to exploit on Monday.”
239
4-25-01 As your lawyer, I’m telling you it is very important for you to come to this meeting today d
240
When you received this did you call CTA and tell them that you did not wish to represent me and
that I need a representative from outside the district?
No.
Why not?
Because I didn’t believe that was true.
241
Do you remember this?
Not specifically.
(This doesn’t count as a not remember, because I asked her the same question on next page)
242
It attracted your attention, didn’t it?
Just now?
Just now.
Yes.
But you don’t recall having received it when—at the time?
| Lawsuit Against CTA Head Counsel Beverly Tucker |
| CTA Lawyers Ann Smith Fern Steiner Bernhard Rohrbacher |
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| Chula Vista Educators (CVE) |
| Home Why This Website SDCOE CVESD Castle Park Elem Law Enforcement CTA CVE Stutz Artiano Shinoff Silence is Golden Schools and Violence Office Admin Hearings Larkins OAH Hearing |
| Gina Boyd President of Chula Vista Educators, Longtime teacher at Castle Park Elementary School 2004 Deposition Testimony |
| Gina Boyd, Winner of the Alberto Gonzalez CRS award for her testimony on |
| June 16, 2008 Maura Larkins Deposition |
| Deposition lasted 6 hours |
| Oct. 11, 2004. Gina Boyd Deposition: "I don't know" 25 times "I don't remember 35 times (or recall, etc.)" |
| Nov. 8, 2007 Atty. Ray Artiano Deposition |
Is this union leader completely
incompetent--or is she
committing perjury?
Quotes from Deposition:
[Page 79
10:17:36
Maura Larkins:]
Were you curious as to what my
behavior might have been that caused them
to fear for their lives?
[Gina Boyd:
long pause]
I guess...I don't know...
[Maura Larkins
10:18:20]
You weren't drivingly curious as to
why teachers were concerned that
another teacher might kill them?
[Stutz law firm Atty. Kelly Angell:]
Objection. Asked and answered.
[Angell was not Boyd's attorney, she was the school
district's attorney, but she prevented Boyd
from answering this question. The
school district didn't like this question because the
district was not curious, either; the district did not
investigate the report of two teachers that Maura
Larkins might kill them, nor did it investigate this
report that came three weeks earlier.]
[Maura Larkins]
10:19
...Were you curious about it--the results of his
investigation?
[Gina Boyd]
I don't know whether he ever completed it, frankly.
Q. Did you ask him?
A. No.
10:19:28
Q. Were you concerned about the safety of teachers
at Castle Park?
A. I'm concerned about the safety of all my teachers...
incompetent--or is she
committing perjury?
Quotes from Deposition:
[Page 79
10:17:36
Maura Larkins:]
Were you curious as to what my
behavior might have been that caused them
to fear for their lives?
[Gina Boyd:
long pause]
I guess...I don't know...
[Maura Larkins
10:18:20]
You weren't drivingly curious as to
why teachers were concerned that
another teacher might kill them?
[Stutz law firm Atty. Kelly Angell:]
Objection. Asked and answered.
[Angell was not Boyd's attorney, she was the school
district's attorney, but she prevented Boyd
from answering this question. The
school district didn't like this question because the
district was not curious, either; the district did not
investigate the report of two teachers that Maura
Larkins might kill them, nor did it investigate this
report that came three weeks earlier.]
[Maura Larkins]
10:19
...Were you curious about it--the results of his
investigation?
[Gina Boyd]
I don't know whether he ever completed it, frankly.
Q. Did you ask him?
A. No.
10:19:28
Q. Were you concerned about the safety of teachers
at Castle Park?
A. I'm concerned about the safety of all my teachers...
10:20:06
Did any teacher ever tell you that he or she feared that I might kill him or her?
No.
[Page 81, line 19]
...Did you believe that I had behaved in a manner that threatened the lives of others?
No.
Did you think these two people had lied?
No.
[Page 84, line 12, 10:23]
If there is any explanation for your behavior other than the explanation I have given in my
complaint, I want to know about it. I don't want to be surprised in court.]
Did any teacher ever tell you that he or she feared that I might kill him or her?
No.
[Page 81, line 19]
...Did you believe that I had behaved in a manner that threatened the lives of others?
No.
Did you think these two people had lied?
No.
[Page 84, line 12, 10:23]
If there is any explanation for your behavior other than the explanation I have given in my
complaint, I want to know about it. I don't want to be surprised in court.]
| lasted 6 hours |
| Deposition lasted 2 hours, then Mr. Artiano walked out |
| Gina Boyd forbids member to make ethics complaint--about Gina Boyd |
| 2004 Robin Donlan Deposition |
| 2004 Linda Watson Deposition |
| Related depositions: |
| photo taken during this answer > > > |
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