|Transcripts in GIC 781970
Notes for ex parte 2-1-05
I would like to know who exactly Ms.
Angell is representing at this time.
Neither CVESD or any of its
employees are going to be involved
from here on in. I’ve made it clear
that the only DOES I intend to name
in this case are Stutz, Artiano Shinoff
& Holtx, because I believe Mr. Shinoff
or Ms. Angell instructed Richard
Werlin to obstruct justice. He wouldn’
t have thought up such a thing on
This meeting should not be billed to
CVESD or it’s insurance carrier. JPA
might pay for it, but I trust the JPA
has reserved the right not to pay if
the lawyers it indemnified are guilty
of criminal acts.
It’s taken me years to realize exactly
what the relationship is between this
law firm and the public entities who
supply it with taxpayer dollars.
The reason I delayed serving this on
Stutz Artiano is that I wanted to give
them a chance to do the right thing,
and to settle this case, but Mr.
Artiano, the agent for service, is
illegally evading service.
When I received notice less than 24
hours ago of this hearing, and
papers at _____, I tried to Ray
Artiano, the agent for service for the
corporation. When I asked his
secretary if my process server would
be able to serve him at his office,
she (Ann) said “This is a law office.
We don’t evade service.” She said I
could come during office hours and
either she would accept service for
him or he might want to come out
and accept service himself.
Then she had to eat her words.
I received a fax saying he insisted on
being served personally.
I called and asked if he was in, and I
was told he’d be there until five.
Then a while later I got a call from
Ann saying he had just left.
C. Obstruction of justice causes of
action were filed less than one year
ago, and have by no means reached
a three year limit.
I remember that Kelly Angell said,
during the February 1, 2005 hearing,
that the taxpayers would have to pay
to defend Mr. Shinoff and STUTZ. I
interpreted this as meaning that the
taxpayers had indemnified Mr. Shinoff
and STUTZ. I remember turning to
look at Ms. Angell when she said
these words because I was startled
that she had made such a
statement. I believe she specifically
mentioned Chula Vista Elementary
School District as the source of the
taxpayer dollars that would be used
to defend Mr. Shinoff and STUTZ.
My memories can easily be compared
with the transcript of that hearing,
which has been prepared, but which I
do not yet have.
1935 Autocross Court
El Cajon, CA 92019
619 444 0065
Plaintiff in pro per
SUPERIOR COURT OF THE
STATE OF CALIFORNIA
COUNTY OF SAN DIEGO
LARKINS, ) Case
No. GIC 825879
William R. Nevitt
vs. ) Dept.:
date: March 11, 2005 2:30 pm.
DOES 52 through 100,
DECLARATION OF PLAINTIFF
OF REPLY TO
) OPPOSITION TO MOTION SEEKING
AMENDMENT OF COMPLAINT
TO ADD TRUE NAMES
FILED: February 18, 2004
DATE: not set
I, the undersigned, declare:
1. I am the plaintiff in pro per
2. I have prepared this
supplementary declaration to make
sure the court has all the necessary
information to make a decision
regarding this Motion.
3. At the time I filed Complaint
GIC 825879, I did not have the
slightest suspicion that Daniel Shinoff
had instructed Richard Werlin to
obstruct justice in February and
March of 2002.
4. After I prepared my January 7,
2004 Motion to name Richard Werlin
as a DOE, I realized that although
Richard Werlin had committed
obstruction of justice, he was not the
one who was orchestrating assaults
on the integrity of government in
multiple school districts; that job was
being done by Daniel Shinoff and his
law firm. At about that time I decided
not to file a Reply the Non-party
Opposition to my Motion. I decided
instead to name Shinoff and STUTZ
5. I have never possessed or
seen the transcript of the ex parte
hearing in this case on February 1,
6. Kelly Angell, however, did
acquire a transcript of that hearing.
7. It’s a wonder Kelly Angell did
not include that transcript as an
exhibit to support her denial that
during that ex parte hearing in this
case, on February 1, 2005, she
confirmed Shinoff was indemnified for
his work on this case.
8. I remember that Kelly Angell
said, during the February 1, 2005
hearing, that the taxpayers would
have to pay to defend Mr. Shinoff
and STUTZ. I interpreted this as
meaning that the taxpayers had
indemnified Mr. Shinoff and STUTZ. I
remember turning to look at Ms.
Angell when she said these words
because I was startled that she had
made such a statement. I believe
she specifically mentioned Chula
Vista Elementary School District as
the source of the taxpayer dollars
that would be used to defend Mr.
Shinoff and STUTZ. My memories
can easily be compared with the
transcript of that hearing, which has
been prepared, but which I do not yet
9. I can think of only one reason
why a client would indemnify a lawyer,
thus relieving the lawyer of his legal
obligation to the client to follow the
law when acting on behalf of or
advising the client. That reason
would be that the client wanted the
lawyer to give advice and take action
that might cause the lawyer to be
charged with wrongdoing.
I declare under penalty of perjury
under the laws of the State of
California that the foregoing is true
DATED: March 2, 2005
Maura Larkins, plaintiff in pro per