KosticErrata

Letter from Maura
Larkins

December 2, 2008

Ljubisa Kostic, Esquire
Stutz Artiano Shinoff & Holtz

Dear Mr. Kostic:

I was fascinated by the
shocking statements you
including in your Motion for
Protective Order. My
feelings regarding your
bizarre misrepresentations
are ambivalent. On the one
hand, you have provided
more evidence of SASH’s
habit of attempting to
perpetrate frauds on the
court, which should work in
my favor. On the other, you
are blatantly trying to
subvert the integrity of San
Diego Superior Court, which
is harmful to everyone in
San Diego.

There are three glaring
examples of your efforts to
deceive the court on the
first page of your Points and
Authorities. The true facts
are these:

1) No one ever claimed that
I made any death threat, or
any type of threat at all.

2) I was dismissed for
staying home for my own
safety.

Stutz attorney Ljubisa Kostic's
Notice of Errata

Tuesday, December 02, 2008
My friendly chat with Ljubisa Kostic about CVESD deposition subpoenas

I called up Stutz law firm attorney Ljubisa Kostic today to meet and confer
regarding my depositions of CVESD officials.

I asked him if he was instructed by his client, CVESD, to make these false
statements in his pleading.

Mr. Kostic said he has never spoken to anyone at CVESD. He says there is
another person at the firm who does that. Hmmm. Would that be Daniel
Shinoff, by any chance? Anyway, this seems to let CVESD off the hook for
trying to perpetrate a fraud on the court. Well, maybe not. CVESD knows
from long experience that this is the way Stutz operates. By rehiring Stutz,
they basically said, "We want you to do for us now the things that you did
for us before."

Mr. Kostic says he is the lead attorney in the case, not Ray Artiano, and
that's why Ray Artiano didn't look at the "Notice of Deposition" documents
I served a week and a half ago. Isn't that what the extra attorneys
assigned to a case are for? For looking at documents that have been
served on them by name when the lead attorney is out of town? What's up
with that, Mr. Artiano? And I'm quite confident that assistant
superintendent Tom Cruz called Daniel Shinoff the morning after Mr. Cruz
and his associates were served with deposition subpoenas. So why did
Shinoff keep the fact secret from the "lead attorney" in the case? Or is
Ljubisa simply misrepresenting the truth yet again?

(contd. from above)

No, that is not the sole
reason I was fired, nor is it
the real reason I was fired.
It is merely the
justification approved by
the board on May 7, 2002.

I told Mr. Kostic that the
official accusation against
me was that I had stayed
home. I was waiting for
the district to investigate
wrongdoing against me by
a small group of Castle
Park Elementary teachers.
The district never even
began an investigation; it
had been perfectly happy
that I was staying home
without being paid. This
was definitely not the
reason I was dismissed.

The district dismissed me
shortly after I filed a
lawsuit on March 12,
2002. The true (and
illegal) reason for the
dismissal was printed out
in black and white in the
final dismissal decision
issued on February 11,
2003: my offense was
filing grievances and a
lawsuit.

Why was CVESD so afraid
of my lawsuit that it would
decide to violate Labor
Code 1102.5 and Labor
Code 432.7 by dismissing
me? Because they wanted
to cover-up their previous
(criminal) violations of
Labor Code section 432.7
against me. In other
words, they violated
section 432.7 in order to
cover up previous
violations of 432.7.

Now CVESD is working
with Stutz Artiano Shinoff
& Holtz in an effort to shut
down my website. Stutz
has no case, so it must rely
on perpetrating a fraud on
the court.

More links below

December 4, 2008

Here is an unusual document: a "Notice of Errata" filed by Stutz attorney Ljubisa Kostic.
I received it after I complained about false statements in Mr. Kostic's Motion to Quash
Subpoenas. Nothing like this has ever happened before during my 7-year experience with
the stubborn and belligerant Stutz law firm. I suspect that Chula Vista Elementary School
District sent Mr. Kostic the message that although they were pleased with the falsehoods
Daniel Shinoff got away with four years ago, they feared that new, outlandish fabrications
would do more harm than good.

Predictably, Kostic's Notice of Errata has false statements. Kostic's Notice says, "Ms.
Larkins indicated that she believes she was terminated solely due to job abandonment..."

(contd. below left)

But please do file an amended ex parte application with the correct information
regarding the three deceptions enumerated above.

Respectfully,
Maura Larkins

P.S. Also, you might want to correct your statement about my dismissal coming
before my lawsuit. I was dismissed AFTER I filed suit; it was obviously
retaliation for filing the lawsuit, coming less than two months after I served
CVESD with the complaint.

3) There was never any
question of my losing my
teaching credential. I still
have it.

(contd. at right)

(contd. from left) I will overlook for now your effort to convince the court of the
non-existence of the many documents and detailed descriptions regarding SASH
wrongdoing on my website by claiming that my statements about SASH are all
general statements, and “not specific.”

Stutz v. Larkins
defamation suit
regarding website