| . |
| ... |
| UPDATE: |
[Why did Robin Donlan tell Gretchen
Donndelinger, “You don’t want to know”?
Because it would be a crime for
Donndelinger to obtain the illegally retrieved
information Robin was discussing?
Did Robin Donlan fear that she would be
accused of a crime if a full and fair
investigation were conducted on why the
district had placed Maura Larkins on
administrative leave in February of 2001?
Robin Donlan, who had seniority, claimed
that she wanted the position Heather Coman
was going to move into. When Heather left,
Donlan withdrew her claim on the position. It
would appear that her only reason for asking
for the position was to push Heather Coman
out of the school.]
Donndelinger, “You don’t want to know”?
Because it would be a crime for
Donndelinger to obtain the illegally retrieved
information Robin was discussing?
Did Robin Donlan fear that she would be
accused of a crime if a full and fair
investigation were conducted on why the
district had placed Maura Larkins on
administrative leave in February of 2001?
Robin Donlan, who had seniority, claimed
that she wanted the position Heather Coman
was going to move into. When Heather left,
Donlan withdrew her claim on the position. It
would appear that her only reason for asking
for the position was to push Heather Coman
out of the school.]
Robin Donlan
is reading
a quote from
the
deposition of
Gretchen
Donndelinger
> > >
is reading
a quote from
the
deposition of
Gretchen
Donndelinger
> > >
Robin Donlan
is reading
a quote from
the
deposition of
Gretchen
Donndelinger
> > >
is reading
a quote from
the
deposition of
Gretchen
Donndelinger
> > >
| In this transcript, Robin Donlan changed her testimony on camera when attorney Kelly Angell of Stutz, Artiano, Shinoff & Holtz admonished her. San Diego Superior Court case number GIC781970. Kelly Angell Minnehan was working under the supervision of Daniel Shinoff, who had, with Jeffery Morris, set out a strategy of covering-up illegal actions and the circumstances surrounded them. ROBIN DONLAN DEPOSITION November 4, 2004 Page 99 Q. Do you know that I was dismissed by the school district? MS. ANGELL: You mean other than conversations that are attorney- client privileged, attorney work product and information related to Ms. Donlan in the course of this litigation? MS. LARKINS: Yes. THE WITNESS: We were told during a meeting, so-- At this point, the deponent had answered a clear question, AFTER her lawyer's clarification that the question specifically ruled out information that was "attorney-client privileged, attorney work product and information related to Ms. Donlan in the course of this litigation." Ms. Donlan made it clear that there had been a meeting which was NOT "attorney-client privileged, attorney work product and information related to Ms. Donlan in the course of this litigation," in which she had learned that LARKINS had been dismissed from employment. As DONLAN answered this question affirmatively, the video camera recorded her tone of voice, eye movements, and body language, all of which support the court reporter's record of an affirmative response. This additional evidence indicates DONLAN'S clear understanding of the question, and her clear understanding of the clarification by her lawyer. DONLAN nodded her head affirmatively as she answered, "We were told during a meeting, so--." She looked at Kelly Angell as she spoke the words, and spoke in a confidential tone of voice, as if she had never before given this information to her lawyer, but was giving it to her now. ANGELL interrupted her client's testimony to give a clear order, a clear directive, a clear instruction, to Ms. Donlan: Angell: "Well, you don't discuss anything that was told to you by your counsel, things that you discussed with counsel. So the question is did you know, other than through your counsel or through this litigation, that she had been dismissed? The witness --and a reasonable person informed of ANGELL'S words and actions--could not help but understand that ANGELL was ordering her client to change her testimony. And Ms. Donlan did change her testimony: THE WITNESS: No. Why did ANGELL want this apparently innocuous information contradicted? The information is a matter of public record. Because ANGELL was desperate to avoid any testimony about discussions about the matter by teachers and Michael Carlson and Rick Werlin at that time, since those discussions involved covering up crimes by planning new crimes. This isn’t a private lawyer protecting a client. This is a public entity lawyer preventing a witness from telling the truth about harm done by the public entity. This is a representative of a public institution (Chula Vista Elementary School District) forcing a client to lie to cover up a committed by that institution. This is public, not private. This is subornation of perjury BY government, supported by tax dollars, and the public has a right to know about it. The lawyers provided to CVESD by the San Diego County Office of Education Joint Powers Authority must stop milking the public and committing misdemeanors and felonies that harm public education. Plaintiff's conduct as alleged in this cause of action constitutes an unlawful act in violation of Penal Code section 127, which states, “Every person who willfully procures another person to commit perjury is guilty of subornation of perjury, and is punishable in the same manner as he would be if personally guilty of the perjury so procured.” The following quotes from Robin Donlan’s deposition show exactly how she contradicted the sworn testimony of her principal. SASH knew very well that these people had violated Labor Code Section 432.7 (a misdemeanor) against Larkins (Exhibit 8), but instead of an apology to Larkins they continued to bill the district for their efforts to subvert the justice system. ROBIN COLLS DONLAN DEPOSITION November 4, 2004 P 123 18 MS. LARKINS: Okay. I would like to ask that this document be labeled -- okay -- as Exhibit 5. I want to make sure that you get one, Ms. Garvin, because this relates so specifically to your client. P 124 (Exhibit 5 marked for identification.) "Deposition of Gretchen Donndelinger." P 125 A. "Did Robin Colls ever share with you any kind of information concerning a police report allegedly, somehow, involving Maura Larkins?" P 126 Q. Was there ever something about a police report that you didn't want Gretchen Donndelinger to know? A. Not to my recollection, no. Q. Okay. So according to your recollection, Gretchen Donndelinger's testimony about you here is false? A. As far as I recall. Q. Was there ever something about a police report that you didn't want Gretchen Donndelinger to know? A. Not to my recollection, no. Q. Okay. So according to your recollection, Gretchen Donndelinger's testimony about you here is false? A. As far as I recall. Q. Okay. Did your brother ever talk to you during the year 2000 about my having been arrested? MR[S]. GARVIN: Vague and ambiguous. THE WITNESS: No. 21-22 Q. Okay. Would you please read the question on Line 2 of Page 81. P 127 line 9-16 Q. Okay. Now that you have read almost half a page of Gretchen Donndelinger's testimony about a conversation she claims to have had with you, are you getting any memories at all of this conversation? A. No, none whatsoever. Q. Okay. Do you have any explanation for why Gretchen Donndelinger would have said that you talked about a police report? Page 128 line 8 through page 129 line 5 Q. So could you read the question that was asked of Gretchen Donndelinger that is recorded here on Line 10 on Page 81. A. "Was this in a face-to-face conversation with Robin Colls?" Q. And what was Gretchen's answer? A. "Yes." Q. Okay. You don't remember any face-to-face conversation with Gretchen Donndelinger about a police report that allegedly somehow involved me? A. No, I don't. Q. Okay. Do you have any experience of Gretchen Donndelinger having hallucinations? A. No. Personally, no. Q. Okay. But you heard -- her testimony here is false; is that your testimony? A. I don't have any recollection of that event. Q. Could this conversation have had happened and you might have forgotten it? A. I doubt that. Q. So you're quite sure this conversation never took place? A. I don't recall it. P70 11 Q. When I was working at Castle Park and Gretchen Donndelinger was working at Castle Park, did you ever talk to her about a police report involving me or anyone connected with me? A. No. Q. Did you ever tell her that you knew something about me, but you -- she wouldn't want to know it? A. No. Q. Did you ever tell her that there was some sort of non-school relationship between my family and your family? A. Not to my recollection, no. p71 Q. Did you ever talk to Gretchen Donndelinger without an attorney present about me at any other time other than the times you were discussing the white board incident and the notebook incident? A. I don't recall any, no. 12 Q. Okay. If you had knowledge about a police report about a teacher at your school, is that something you'd be likely to remember? 15 A. Probably. Another individual who committed perjury under pressure from Kelly Angell MInnehan, Daniel Shinoff, Jeffery Morris and the CVESD board was Linda Watson (Exhibit 7), contradicting herself again and again, and changing her testimony when Larkins asked if Watson would mind if her phone records were subpoenaed. |
| P. 67 Intriguing objection by Kelly Angell regarding "mild anxiety" MAURA LARKINS: Would you say that this was kind of a mild anxiety in the back of your mind? MS. ANGELL: Objection. Calls for expert testimony. This person has not been established to be a psychiatrist, psychotherapist or anything like that, and it sounds to me like you're talking about medical diagnoses. |
Robin Colls Donlan deposition
November 4, 2004
November 4, 2004
Page 93
Called you up to report events at Castle Park since you left
Have you suggested to her actions that she might take
I suggested that she call Gina Boyd
You were handing out literature on campus to students
Had Gina Boyd’s name on it
Called you up to report events at Castle Park since you left
Have you suggested to her actions that she might take
I suggested that she call Gina Boyd
You were handing out literature on campus to students
Had Gina Boyd’s name on it
| Page 99 contd. 16:17 |
Tape two quote outtakes
Page 83
3:54 p.m.
Page 83
3:54 p.m.
P 83
3 Q. Did you enjoy a great deal of influence
4 over decisions being made by administrators at Castle
5 Park Elementary School during most of the time you were
6 there?
7 A. If you could clarify that, please.
8 Q. Did you enjoy -- let me say this. Did Gretchen
9 Donndelinger listen to what you said to her and do what
10 you suggested a significant amount of the time?
14 Q. Did you frequently go in to Gretchen
15 Donndelinger's office and talk to her?
16 A. Not to my recollection, no.
[Maura Larkins' note: To my recollection, yes. Also, Gretchen told me
she encouraged them to come to her and "vent."]
Off the record at 3:40 p.m.
3 Q. Did you enjoy a great deal of influence
4 over decisions being made by administrators at Castle
5 Park Elementary School during most of the time you were
6 there?
7 A. If you could clarify that, please.
8 Q. Did you enjoy -- let me say this. Did Gretchen
9 Donndelinger listen to what you said to her and do what
10 you suggested a significant amount of the time?
14 Q. Did you frequently go in to Gretchen
15 Donndelinger's office and talk to her?
16 A. Not to my recollection, no.
[Maura Larkins' note: To my recollection, yes. Also, Gretchen told me
she encouraged them to come to her and "vent."]
Off the record at 3:40 p.m.
P 79 Donlan must have found out immediately. They would have gone straight to her, especially since she started the whole thing, and also she was a member of the Castle Park Family. |
21 VIDEOGRAPHER: This concludes Tape 1 of the
Off the record at 3:40 p.m. (Recess taken.)
This is Tape 2 of the deposition Back on the record at 3:54 p.m.
P84
22 Q. Okay. Do you recall a year at Castle Park when
23 Gretchen Donndelinger was principal and you said that you
24 might want to switch to a regular fourth grade class
25 instead of your special education class?
p85
1 A. Yes.
2 Q. Do you remember why you -- strike that. Did you
3 tell Gretchen Donndelinger that you wanted to switch to a
4 regular fourth grade class?
5 A. I inquired about a fourth grade opening that was
6 becoming available.
7 Q. Okay. Do you remember how that opening became
8 available?
9 A. I don't recall specifically. I believe that Al
10 Smith was transferred to third grade.
[Robin was maneuvering to push Heather Coman out]
P 86
2 Q. Okay. Why did you decide not to switch to the
3 regular fourth grade class when you had discussed it with
4 the principal?
5 A. I did not make that decision. Dr. Donndelinger
6 made that decision.
7 Q. Were you unhappy when you were not allowed to
8 switch to a fourth grade regular class?
9 A. I was disappointed.
10 Q. Are you now teaching a regular fourth grade
11 class?
12 A. Yes.
13 Q. But you weren't happy when you were given this
14 regular fourth grade class?
21 Q. Do you recall one year when the teachers had a
22 food fight in the staff lounge at Castle Park?
23 A. I wasn't present for that.
24 Q. Okay. Did that food fight occur on the last day
25 of school?
p87
1 A. I don't recall.
2 Q. The following year did you come to the lounge
3 dressed in a rain coat in the expectation of having
4 another food fight?
5 A. I don't recall.
6 Q. Was Lowell Billings an interim principal at
7 Castle Park when you were there?
8 A. Yes.
9 Q. What did you think of his administrative skills?
10 A. I didn't think anything. He wasn't there very
11 often.
[I wonder what he thought of her teaching skills. Perhaps the transfer reveals his
judgment.]
15 Q. Did you think that Gretchen Donndelinger had
16 good administrative skills?
17 A. Certain of her administrative skills were good,
18 yes.
19 Q. What skills were those?
25 MS. LARKINS: Okay. I would like to ask some
P 88
8 Q. What were Gretchen Donndelinger's administrative
9 skills in your point of view?
This is the only administrative skill she talks about
10 A. She cared for the children; she liked being
11 around children. She -- I felt that she had the best
12 interests of the children in heart. I feel those are
13 skills that are important for an administrator.
14 Q. Was she your friend?
15 A. She was my work acquaintance.
16 Q. Did you have a positive relationship with her?
17 A. I believe so.
18 Q. Okay. Did your relationship with her get better
19 over time?
20 A. I wouldn't say it got better or worse.
21 Q. Okay. Did you ever have problems with her when
22 she refused to suspend a student of yours that you wanted
23 suspended?
p89
17 Q. Were you ever unhappy with Gretchen Donndelinger
18 when she refused to suspend one of your students whom you
19 wanted suspended?
21 THE WITNESS: I was -- I wouldn't say I was
22 unhappy. I wasn't pleased.
24 Q. Did you ever ask Gina Boyd to come and have a
25 meeting with you and Gretchen --
P 90
1 A. I don't recall.
2 Q. -- regarding suspending students?
3 A. I don't recall.
4 Q. Did you ever ask Gina Boyd to come to Castle
5 Park and have a meeting with Gretchen Donndelinger about
6 anything?
7 A. I don't recall specifics.
8 Q. Do you recall ever asking Gina Boyd to come and
9 have a meeting with you and the principal at Castle Park?
10 A. I don't recall any specific events.
11 Q. But you think it might have happened?
12 A. It might have happened, yes.
15 Was Gina Boyd very supportive of you when you
16 were at Castle Park?
17 A. Gina Boyd was supportive of everybody who was at
18 Castle Park in my belief.
[She’s in denial about the fact that I was there at Castle Park even though she
didn’t want me there.]
19 Q. Was her relationship with you closer than it was
20 with other teachers?
21 A. She had known me for longer. We had been
22 acquaintances, been friendly work partners for longer.
23 Q. Uh-huh. Okay. What were some of Gretchen
24 Donndelinger's problems as an administrator?
P 91
1 Q. In your opinion.
2 A. Her problems with being an administrator or with
3 administrative traits or -- I'm unclear as to what you're
4 asking me.
6 Did you ever discuss with other teachers
7 Gretchen Donndelinger's failings as an administrator?
8 A. I don't recall specifically.
22 Q. Okay. In your opinion is Ollie Matos the worst
23 administrator that Castle Park has had during the time
24 you worked there?
25 A. Possibly.
P 92
1 Q. Who do you think might come close to him as a
2 bad administrator?
3 A. Mr. Perez.
4 Q. Okay. Do you believe that Ollie Matos should be
5 fired?
6 A. No.
7 Q. Do you believe that Ollie Matos should be
8 removed from Castle Park?
9 A. I believe that he would most likely be a better
10 fit at a different school.
11 Q. Why is that?
12 A. Because I believe that his skills would be
13 better suited to a different type of staff than Castle
14 Park was.
15 Q. When you say type of staff that Castle Park is,
16 what do you mean by that?
17 A. Castle Park is an independent staff. The staff
18 pretty much as a whole is used to being involved in
19 decision making. I believe that Mr. Matos' experience is
20 not of that, but there are schools where the staff is not
21 involved as closely in decision making. It's my belief
22 that he might be better suited to a school like that.
23 Q. Okay. Are you acquainted with one of the PTA --
24 let me rephrase that. Are you acquainted with PTA
25 president Kim Simmons?
p93
1 A. Yes.
2 Q. How long have you known her?
3 A. Approximately two years.
4 Q. How did you first become acquainted?
5 A. I don't recall.
6 Q. Has she ever called you up to report events at
7 Castle Park since you left?
8 A. Yes.
9 Q. About how often?
10 A. Occasionally, not very often.
11 Q. Have you suggested to her actions that she might
12 take at Castle Park since you left?
13 A. Yes.
14 Q. What actions were those?
15 A. I suggested at one incident that she call Gina
16 Boyd.
17 Q. What incident was that?
18 A. It was the incident where you were handing out
19 literature on the campus to the students.
20 Q. Okay.
21 A. The literature had Gina Boyd's name on it.
22 Q. Uh-huh. How did you feel about that?
25 Q. How did you feel about me handing out
literature
P 94
1 that had Gina Boyd's name on it?
2 A. You're entitled to your opinion. But opinion is
3 opinion.
[Robin appears very angry in the video, with deeply downward
lines on mouth.]
4 Q. It didn't bother you at all?
5 A. I really didn't have any opinion about it at
6 all.
7 Q. Did you have any feelings about it?
8 A. (Witness shakes head.)
9 I didn't -- I failed to understand the purpose,
10 but your opinion is your opinion. You're entitled to it.
11 Q. Okay. And what other reports has Kim Simmons
12 made to you about Castle Park since you left?
13 A. She called to ask me if I knew two gentlemen
14 that had attended a PTA meeting, which I did not.
15 Q. Was she concerned about these two gentlemen?
16 A. You would have to ask her that.
17 Q. Did she tell you she was worried about these two
18 gentlemen?
19 A. No. She did not know who they were. She asked
20 me if I knew who they were and why they were there, and I
21 said no.
22 Q. Did you go to curriculum night at Castle Park
23 recently and hand out fliers?
24 A. For Jill Galvez, yes. She was running for the
25 school board seat that is currently occupied by Patrick
P 95
1 Judd.
2 Q. Why did you choose Castle Park as a place to
3 hand out your fliers that night?
4 A. I -- I saw no reason not to.
5 Q. Who was with you when you were handing out
the
6 fliers?
7 A. Certain parents, Gina Boyd, other people I don't
8 recall specifically, and Peg Myers.
9 Q. Okay. Peg Myers was also recently transferred
10 from Castle Park, wasn't she?
11 A. Yes, she was.
12 Q. Were you trying to prove to the principal that
13 you could be there and he couldn't get rid of you?
14 A. I was not trying to prove anything. I was
15 handing out fliers in support of Jill Galvez.
16 Q. Were any of the parents or teachers who were
17 with you holding up signs?
18 A. Yes.
19 Q. What did those signs say?
20 A. Different things. "Support the teachers."
21 Q. What did that mean, "support the teachers"?
22 A. Support the teachers who were transferred.
23 Q. So these parents and teachers were protesting
24 your transfer?
25 A. I believe the parents were. The teachers who
P 96
1 were out there were myself and Peg Myers, and we were
2 handing out fliers for Jill Galvez.
3 Q. Okay. Do you remember when the bilingual
4 program began at Castle Park Elementary School?
5 A. I don't remember a specific year, but yes.
6 Q. Okay. Were the teachers involved in deciding
7 whether or not there would be a bilingual program?
8 A. I can't recall how much involvement the teachers
9 had in making the decision to have one.
10 Q. How did you feel about the bilingual program?
11 MS. ANGELL: Vague and ambiguous as to time.
12 BY MS. LARKINS:
13 Q. At Castle Park when it was being discussed that
14 it was going to be -- it might be coming.
15 A. I didn't have a strong belief in bilingual
16 education.
17 Q. Do you think bilingual education is a bad idea?
18 A. I wouldn't go to say that it's a bad idea. I
19 just don't have a belief that it's beneficial.
20 Q. Okay. Did you express these opinions at staff
21 meetings?
22 A. Yes, I did.
23 Q. Did other people express similar opinions?
24 A. Similar and opposed, yeah.
25 Q. Okay. Were these -- did people get pretty angry
P 97
1 at these staff meetings?
2 A. Not to my recollection.
14 Q. Who was your closest friend at Castle Park?
15 A. Kim Brown.
16 Q. Okay. Did the staff at Castle Park ever get an
17 in-service about how to conduct staff meetings?
19 MS. LARKINS: At any time that you were there at
20 Castle Park.
21 THE WITNESS: An in-service?
23 Q. Uh-huh.
24 A. I don't recall a specific in-service on how to
25 conduct staff meetings. There may have been, but I don't
p 99
1 recall one.
2 Q. Okay. After the bilingual program was
3 instituted, was there hostility remaining among the staff
4 toward the bilingual program?
5 A. I don't believe so.
6 Q. Okay. But a bilingual teacher -- the first
7 bilingual teacher was dismissed by the school district,
8 Heather Smith?
9 A. I don't know if she was dismissed or not.
10 Q. Okay. Do you know that I was dismissed by the
11 school district?
Off the record at 3:40 p.m. (Recess taken.)
This is Tape 2 of the deposition Back on the record at 3:54 p.m.
P84
22 Q. Okay. Do you recall a year at Castle Park when
23 Gretchen Donndelinger was principal and you said that you
24 might want to switch to a regular fourth grade class
25 instead of your special education class?
p85
1 A. Yes.
2 Q. Do you remember why you -- strike that. Did you
3 tell Gretchen Donndelinger that you wanted to switch to a
4 regular fourth grade class?
5 A. I inquired about a fourth grade opening that was
6 becoming available.
7 Q. Okay. Do you remember how that opening became
8 available?
9 A. I don't recall specifically. I believe that Al
10 Smith was transferred to third grade.
[Robin was maneuvering to push Heather Coman out]
P 86
2 Q. Okay. Why did you decide not to switch to the
3 regular fourth grade class when you had discussed it with
4 the principal?
5 A. I did not make that decision. Dr. Donndelinger
6 made that decision.
7 Q. Were you unhappy when you were not allowed to
8 switch to a fourth grade regular class?
9 A. I was disappointed.
10 Q. Are you now teaching a regular fourth grade
11 class?
12 A. Yes.
13 Q. But you weren't happy when you were given this
14 regular fourth grade class?
21 Q. Do you recall one year when the teachers had a
22 food fight in the staff lounge at Castle Park?
23 A. I wasn't present for that.
24 Q. Okay. Did that food fight occur on the last day
25 of school?
p87
1 A. I don't recall.
2 Q. The following year did you come to the lounge
3 dressed in a rain coat in the expectation of having
4 another food fight?
5 A. I don't recall.
6 Q. Was Lowell Billings an interim principal at
7 Castle Park when you were there?
8 A. Yes.
9 Q. What did you think of his administrative skills?
10 A. I didn't think anything. He wasn't there very
11 often.
[I wonder what he thought of her teaching skills. Perhaps the transfer reveals his
judgment.]
15 Q. Did you think that Gretchen Donndelinger had
16 good administrative skills?
17 A. Certain of her administrative skills were good,
18 yes.
19 Q. What skills were those?
25 MS. LARKINS: Okay. I would like to ask some
P 88
8 Q. What were Gretchen Donndelinger's administrative
9 skills in your point of view?
This is the only administrative skill she talks about
10 A. She cared for the children; she liked being
11 around children. She -- I felt that she had the best
12 interests of the children in heart. I feel those are
13 skills that are important for an administrator.
14 Q. Was she your friend?
15 A. She was my work acquaintance.
16 Q. Did you have a positive relationship with her?
17 A. I believe so.
18 Q. Okay. Did your relationship with her get better
19 over time?
20 A. I wouldn't say it got better or worse.
21 Q. Okay. Did you ever have problems with her when
22 she refused to suspend a student of yours that you wanted
23 suspended?
p89
17 Q. Were you ever unhappy with Gretchen Donndelinger
18 when she refused to suspend one of your students whom you
19 wanted suspended?
21 THE WITNESS: I was -- I wouldn't say I was
22 unhappy. I wasn't pleased.
24 Q. Did you ever ask Gina Boyd to come and have a
25 meeting with you and Gretchen --
P 90
1 A. I don't recall.
2 Q. -- regarding suspending students?
3 A. I don't recall.
4 Q. Did you ever ask Gina Boyd to come to Castle
5 Park and have a meeting with Gretchen Donndelinger about
6 anything?
7 A. I don't recall specifics.
8 Q. Do you recall ever asking Gina Boyd to come and
9 have a meeting with you and the principal at Castle Park?
10 A. I don't recall any specific events.
11 Q. But you think it might have happened?
12 A. It might have happened, yes.
15 Was Gina Boyd very supportive of you when you
16 were at Castle Park?
17 A. Gina Boyd was supportive of everybody who was at
18 Castle Park in my belief.
[She’s in denial about the fact that I was there at Castle Park even though she
didn’t want me there.]
19 Q. Was her relationship with you closer than it was
20 with other teachers?
21 A. She had known me for longer. We had been
22 acquaintances, been friendly work partners for longer.
23 Q. Uh-huh. Okay. What were some of Gretchen
24 Donndelinger's problems as an administrator?
P 91
1 Q. In your opinion.
2 A. Her problems with being an administrator or with
3 administrative traits or -- I'm unclear as to what you're
4 asking me.
6 Did you ever discuss with other teachers
7 Gretchen Donndelinger's failings as an administrator?
8 A. I don't recall specifically.
22 Q. Okay. In your opinion is Ollie Matos the worst
23 administrator that Castle Park has had during the time
24 you worked there?
25 A. Possibly.
P 92
1 Q. Who do you think might come close to him as a
2 bad administrator?
3 A. Mr. Perez.
4 Q. Okay. Do you believe that Ollie Matos should be
5 fired?
6 A. No.
7 Q. Do you believe that Ollie Matos should be
8 removed from Castle Park?
9 A. I believe that he would most likely be a better
10 fit at a different school.
11 Q. Why is that?
12 A. Because I believe that his skills would be
13 better suited to a different type of staff than Castle
14 Park was.
15 Q. When you say type of staff that Castle Park is,
16 what do you mean by that?
17 A. Castle Park is an independent staff. The staff
18 pretty much as a whole is used to being involved in
19 decision making. I believe that Mr. Matos' experience is
20 not of that, but there are schools where the staff is not
21 involved as closely in decision making. It's my belief
22 that he might be better suited to a school like that.
23 Q. Okay. Are you acquainted with one of the PTA --
24 let me rephrase that. Are you acquainted with PTA
25 president Kim Simmons?
p93
1 A. Yes.
2 Q. How long have you known her?
3 A. Approximately two years.
4 Q. How did you first become acquainted?
5 A. I don't recall.
6 Q. Has she ever called you up to report events at
7 Castle Park since you left?
8 A. Yes.
9 Q. About how often?
10 A. Occasionally, not very often.
11 Q. Have you suggested to her actions that she might
12 take at Castle Park since you left?
13 A. Yes.
14 Q. What actions were those?
15 A. I suggested at one incident that she call Gina
16 Boyd.
17 Q. What incident was that?
18 A. It was the incident where you were handing out
19 literature on the campus to the students.
20 Q. Okay.
21 A. The literature had Gina Boyd's name on it.
22 Q. Uh-huh. How did you feel about that?
25 Q. How did you feel about me handing out
literature
P 94
1 that had Gina Boyd's name on it?
2 A. You're entitled to your opinion. But opinion is
3 opinion.
[Robin appears very angry in the video, with deeply downward
lines on mouth.]
4 Q. It didn't bother you at all?
5 A. I really didn't have any opinion about it at
6 all.
7 Q. Did you have any feelings about it?
8 A. (Witness shakes head.)
9 I didn't -- I failed to understand the purpose,
10 but your opinion is your opinion. You're entitled to it.
11 Q. Okay. And what other reports has Kim Simmons
12 made to you about Castle Park since you left?
13 A. She called to ask me if I knew two gentlemen
14 that had attended a PTA meeting, which I did not.
15 Q. Was she concerned about these two gentlemen?
16 A. You would have to ask her that.
17 Q. Did she tell you she was worried about these two
18 gentlemen?
19 A. No. She did not know who they were. She asked
20 me if I knew who they were and why they were there, and I
21 said no.
22 Q. Did you go to curriculum night at Castle Park
23 recently and hand out fliers?
24 A. For Jill Galvez, yes. She was running for the
25 school board seat that is currently occupied by Patrick
P 95
1 Judd.
2 Q. Why did you choose Castle Park as a place to
3 hand out your fliers that night?
4 A. I -- I saw no reason not to.
5 Q. Who was with you when you were handing out
the
6 fliers?
7 A. Certain parents, Gina Boyd, other people I don't
8 recall specifically, and Peg Myers.
9 Q. Okay. Peg Myers was also recently transferred
10 from Castle Park, wasn't she?
11 A. Yes, she was.
12 Q. Were you trying to prove to the principal that
13 you could be there and he couldn't get rid of you?
14 A. I was not trying to prove anything. I was
15 handing out fliers in support of Jill Galvez.
16 Q. Were any of the parents or teachers who were
17 with you holding up signs?
18 A. Yes.
19 Q. What did those signs say?
20 A. Different things. "Support the teachers."
21 Q. What did that mean, "support the teachers"?
22 A. Support the teachers who were transferred.
23 Q. So these parents and teachers were protesting
24 your transfer?
25 A. I believe the parents were. The teachers who
P 96
1 were out there were myself and Peg Myers, and we were
2 handing out fliers for Jill Galvez.
3 Q. Okay. Do you remember when the bilingual
4 program began at Castle Park Elementary School?
5 A. I don't remember a specific year, but yes.
6 Q. Okay. Were the teachers involved in deciding
7 whether or not there would be a bilingual program?
8 A. I can't recall how much involvement the teachers
9 had in making the decision to have one.
10 Q. How did you feel about the bilingual program?
11 MS. ANGELL: Vague and ambiguous as to time.
12 BY MS. LARKINS:
13 Q. At Castle Park when it was being discussed that
14 it was going to be -- it might be coming.
15 A. I didn't have a strong belief in bilingual
16 education.
17 Q. Do you think bilingual education is a bad idea?
18 A. I wouldn't go to say that it's a bad idea. I
19 just don't have a belief that it's beneficial.
20 Q. Okay. Did you express these opinions at staff
21 meetings?
22 A. Yes, I did.
23 Q. Did other people express similar opinions?
24 A. Similar and opposed, yeah.
25 Q. Okay. Were these -- did people get pretty angry
P 97
1 at these staff meetings?
2 A. Not to my recollection.
14 Q. Who was your closest friend at Castle Park?
15 A. Kim Brown.
16 Q. Okay. Did the staff at Castle Park ever get an
17 in-service about how to conduct staff meetings?
19 MS. LARKINS: At any time that you were there at
20 Castle Park.
21 THE WITNESS: An in-service?
23 Q. Uh-huh.
24 A. I don't recall a specific in-service on how to
25 conduct staff meetings. There may have been, but I don't
p 99
1 recall one.
2 Q. Okay. After the bilingual program was
3 instituted, was there hostility remaining among the staff
4 toward the bilingual program?
5 A. I don't believe so.
6 Q. Okay. But a bilingual teacher -- the first
7 bilingual teacher was dismissed by the school district,
8 Heather Smith?
9 A. I don't know if she was dismissed or not.
10 Q. Okay. Do you know that I was dismissed by the
11 school district?
"not to my
recollection"
Cognitive
dissonance
recollection"
Cognitive
dissonance
| Robin Donlan was far more forthcoming when asked about the 2009 ComiCon convention for a video clip placed on the Internet by ComicCon. Robin, an officer of ComicCon, noted that some people complained if they weren't treated "like a special little snowflake." |
Teacher Robin Donlan and the "Castle Park Five" wreaked havoc at Castle Park Elementary in CVESD.
| See also Maura Larkins deposition |
| Depositions Robin Donlan Peg Myers Gina Boyd Maura Larkins |
Depostion of Principal of Castle Park
Elementary September 10, 2002
Page 80 line 19
Q. Did Robin Colls [AKA Robin
Donlan] ever share with you any kind
of
information concerning a police report
allegedly, somehow, involving Maura
Larkins?
A. Actually, that did come up at
some point when she [Robin
Colls/Donlan]was
talking, but she, herself, said, you
know, you don’t want to hear anything
about
that. And I’m not going to tell you. I
know that there is something, but I
have no clue what it is. She didn’t
want me to know.
[Robin is demonstrating awareness of
guilt.]
Q. So she said there’s something
in the police report?
A. It was a personal thing.
Q. Involving something that was a
non-school matter but that Robin Colls
was
aware of?
A. Uh-huh.
Q. Was that a yes?
A. Yes, I do recall hearing something
like that. I have no details whatsoever.
Q. Was this in a face-to-face
conversation with Robin Colls?
A. Yes.
Q. And what year was that?
A. That was the year, I think she told
me about that this year, the year—
Q. 2002?
A. Two—1999, 2000 school year. It
was the year before.
Q. That this occurred?
A. It occurred in the 1999, 2000
school year.
Q. But you found out about it in which
year.
A. There was an incident that this is
referring to in my belief. They had a
problem with a staff member the year
before and—that’s what I understood
this to
mean anyway.
Q. Exhibit 19? [Exhibit 19]
Page 82 lines 1-25:
A. Yes. It happened in 1999,
September. [actually, 2000,
September]
It was like the first week back from
vacation. That’s when that happened,
and, I believe, that’s when Robin told
me
that there was an incident, there was a
personal, a side incident, but she said
you don’t want to know about it
[because it would be a crime to obtain
this
information?]. And I said no, it’s
personal, doesn’t have anything to do
with
school, I don’t want to know.
Q. And she told you it involved
some sort of police report or law
enforcement
report?
A. I think so, yes.
Q. Did you ask her how she knew
that?
A. Uh-uh.
Q. No?
A. That was it. That’s all she said.
She said I have this thing going on
with her on the side. Outside of
school. You don’t want to know about
it.
Q. Was it an indication that she
had it going on, that it was something
personal?
A. It was a personal issue outside
of school going on with Maura and her
somehow, and I don’t know if it was
her or her family or—but that was it.
That’s all she said.
Q. Did Ms. Colls, rather, leave you
with the impression that it was going
on—that somehow, Ms. Colls was
actually involved in this personal
incident?
A. That she or her family, you
know, she knows about it or it was—
something else going on outside of
school,
Page 83, lines 1-8:
[A. contd.] Something to do with Robin
and or her family and Maura. I don’t
know even why I remember that.
Somehow somebody told me, and I
think it was Robin.
Q. It had something to do with
either Robin or a family member of
Robin’s?
A. Yeah. I think if it was actually
Robin I probably would have wanted
to know, just natural curiosity. I
don’t think it was against her. I think
it was a family member.
Elementary September 10, 2002
Page 80 line 19
Q. Did Robin Colls [AKA Robin
Donlan] ever share with you any kind
of
information concerning a police report
allegedly, somehow, involving Maura
Larkins?
A. Actually, that did come up at
some point when she [Robin
Colls/Donlan]was
talking, but she, herself, said, you
know, you don’t want to hear anything
about
that. And I’m not going to tell you. I
know that there is something, but I
have no clue what it is. She didn’t
want me to know.
[Robin is demonstrating awareness of
guilt.]
Q. So she said there’s something
in the police report?
A. It was a personal thing.
Q. Involving something that was a
non-school matter but that Robin Colls
was
aware of?
A. Uh-huh.
Q. Was that a yes?
A. Yes, I do recall hearing something
like that. I have no details whatsoever.
Q. Was this in a face-to-face
conversation with Robin Colls?
A. Yes.
Q. And what year was that?
A. That was the year, I think she told
me about that this year, the year—
Q. 2002?
A. Two—1999, 2000 school year. It
was the year before.
Q. That this occurred?
A. It occurred in the 1999, 2000
school year.
Q. But you found out about it in which
year.
A. There was an incident that this is
referring to in my belief. They had a
problem with a staff member the year
before and—that’s what I understood
this to
mean anyway.
Q. Exhibit 19? [Exhibit 19]
Page 82 lines 1-25:
A. Yes. It happened in 1999,
September. [actually, 2000,
September]
It was like the first week back from
vacation. That’s when that happened,
and, I believe, that’s when Robin told
me
that there was an incident, there was a
personal, a side incident, but she said
you don’t want to know about it
[because it would be a crime to obtain
this
information?]. And I said no, it’s
personal, doesn’t have anything to do
with
school, I don’t want to know.
Q. And she told you it involved
some sort of police report or law
enforcement
report?
A. I think so, yes.
Q. Did you ask her how she knew
that?
A. Uh-uh.
Q. No?
A. That was it. That’s all she said.
She said I have this thing going on
with her on the side. Outside of
school. You don’t want to know about
it.
Q. Was it an indication that she
had it going on, that it was something
personal?
A. It was a personal issue outside
of school going on with Maura and her
somehow, and I don’t know if it was
her or her family or—but that was it.
That’s all she said.
Q. Did Ms. Colls, rather, leave you
with the impression that it was going
on—that somehow, Ms. Colls was
actually involved in this personal
incident?
A. That she or her family, you
know, she knows about it or it was—
something else going on outside of
school,
Page 83, lines 1-8:
[A. contd.] Something to do with Robin
and or her family and Maura. I don’t
know even why I remember that.
Somehow somebody told me, and I
think it was Robin.
Q. It had something to do with
either Robin or a family member of
Robin’s?
A. Yeah. I think if it was actually
Robin I probably would have wanted
to know, just natural curiosity. I
don’t think it was against her. I think
it was a family member.
Very certain.
See the Sept. 2002 deposition of the
principal of Castle Park Elementary
(BELOW)
and the Rick Werlin deposition.
Michael Carlson's sister Robin
Colls/Donlan and other CVESD
employees contradicted themselves
again and again, or contradicted
known facts.
Their friends, and those who feared
them, also lied.
Gina Boyd, the president of Chula
Vista Educators came to depositions
of Castle Park teachers, to make sure
witnesses didn't tell the truth. It was
entirely inappropriate of her to
"represent" witnesses against Maura
Larkins, when she was also
"representing" Maura Larkins. When
this was pointed out to her, Boyd still
refused to leave.
But Gina was not present at the
deposition of the principal of Castle
Park Elementary. In that deposition,
the truth about the illegally obtained
and distributed police report came
out.
Below is the pertinent part of that
deposition, taken for the Office of
Administrative Hearings, but never
used by Maura Larkins' attorney.
See the Sept. 2002 deposition of the
principal of Castle Park Elementary
(BELOW)
and the Rick Werlin deposition.
Michael Carlson's sister Robin
Colls/Donlan and other CVESD
employees contradicted themselves
again and again, or contradicted
known facts.
Their friends, and those who feared
them, also lied.
Gina Boyd, the president of Chula
Vista Educators came to depositions
of Castle Park teachers, to make sure
witnesses didn't tell the truth. It was
entirely inappropriate of her to
"represent" witnesses against Maura
Larkins, when she was also
"representing" Maura Larkins. When
this was pointed out to her, Boyd still
refused to leave.
But Gina was not present at the
deposition of the principal of Castle
Park Elementary. In that deposition,
the truth about the illegally obtained
and distributed police report came
out.
Below is the pertinent part of that
deposition, taken for the Office of
Administrative Hearings, but never
used by Maura Larkins' attorney.
Deposition of the principal of
Castle Park Elementary
for the Office of Administrative
Hearings
Castle Park Elementary
for the Office of Administrative
Hearings
CVESD attorney Mark Bresee listened to
this and other depositions, and then
continued to work to hide crimes. CVESD
and other districts rely on such attorneys.
See Robin Donlan's response when
confronted with Gretchen Donndelinger's
testimony--bottom of this page.
this and other depositions, and then
continued to work to hide crimes. CVESD
and other districts rely on such attorneys.
See Robin Donlan's response when
confronted with Gretchen Donndelinger's
testimony--bottom of this page.
How certain is it that Michael
Carlson and his sister Robin
Donlan committed perjury in
CVESD case?
Carlson and his sister Robin
Donlan committed perjury in
CVESD case?
Why This Website
Stutz Artiano
Shinoff & Holtz v.
Maura Larkins
defamation
SDCOE
CVESD
Castle Park
Elementary School
Law Enforcement
CTA
CVE
Stutz Artiano
Shinoff & Holtz
Silence is Golden
Schools and Violence
Office Admin
Hearings
Larkins OAH Hearing
Stutz Artiano
Shinoff & Holtz v.
Maura Larkins
defamation
SDCOE
CVESD
Castle Park
Elementary School
Law Enforcement
CTA
CVE
Stutz Artiano
Shinoff & Holtz
Silence is Golden
Schools and Violence
Office Admin
Hearings
Larkins OAH Hearing
| San Diego Education Report |
| SDER |
San Diego
Education Report
Education Report
| SDER |
| SDER |
| SDER |
| San Diego Education Report |
| SDER |
San Diego
Education Report
Education Report
| SDER |
| SDER |
| SDER |
[Note: No attorney-client privilege
exists if attorney counsels client to
criminal activity.]
exists if attorney counsels client to
criminal activity.]
| Robin Donlan |
EXHIBITS: PAGE
1 One-page handwritten notes 28
2 Copy of a Star News article
August 20, 2004, two pages 36
3 One-page memo, February 25, 2002 42
4 Two-page bilingual flier 73
5 Condensed transcript, deposition of
Gretchen Donndelinger, September 10, 2002 124
1 One-page handwritten notes 28
2 Copy of a Star News article
August 20, 2004, two pages 36
3 One-page memo, February 25, 2002 42
4 Two-page bilingual flier 73
5 Condensed transcript, deposition of
Gretchen Donndelinger, September 10, 2002 124
A master of evasion? Did she
have a reason to hide the truth?
have a reason to hide the truth?
CVESD Teacher Robin Donlan was supported during the following
deposition by attorneys Deborah Garvin (lawyer for her brother), Kelly
Angell (Minnehan) of Stutz Artiano Shinoff & Holtz, and Michael Hersh.
deposition by attorneys Deborah Garvin (lawyer for her brother), Kelly
Angell (Minnehan) of Stutz Artiano Shinoff & Holtz, and Michael Hersh.
P 44
1 Q. Okay. Okay. And did you have any idea what it
2 was about?
3 A. No.
4 Q. And when you got there, he said that he had
5 received a letter?
6 A. Yes.
7 Q. And what did he say about the letter? Did he --
8 I'm sorry. Let me ask this. This is a better question.
9 Did he show you the letter?
10 A. No.
14 Q. Did he tell you anything about the letter?
15 A. He said that it made reference to a brother that
16 I had in law enforcement, and he asked me if I had a
17 brother who was in law enforcement, and I said yes.
18 Q. Okay. Did he tell you anything else about the
19 letter?
20 A. He shared some of the items in the letter and
21 asked if I knew anything about them.
22 Q. What were some of the items -- what was one of
23 the items that he shared?
24 A. That my brother had sent people to your house.
25 Q. And do you remember anything else he said about
P 45
1 the letter?
2 A. That he had gotten it in -- as a fax from you, I
3 believe. But it was something that he received from you
4 and wanted to find out if I actually had a brother who
5 was in law enforcement, which I confirmed.
6 Q. Okay. How did you feel as he --
7 A. Confused.
8 Q. Okay. Did you become upset?
11 Q. Did you become upset when Mr. Werlin was talking
12 to you about this letter?
13 A. Not that I recall.
14 Q. Do you recall anything you said to Mr. Werlin?
15 A. Specific words, no.
16 Q. Do you recall any general -- do you recall your
17 general response to Mr. Werlin?
18 A. That I had no idea what the letter was talking
19 about.
25 Q. During this meeting concerning -- during this
p46
1 meeting that Mr. Werlin called you to attend regarding a
2 letter from me, did you tell Mr. Werlin that you were
3 upset about not having been included in a meeting at
4 Castle Park?
5 A. I don't recall specifically saying that.
6 Q. Do you recall ever having been upset about not
7 having been included in a meeting about me at Castle
8 Park?
9 A. Upset? No.
10 Q. Do you recall ever having been concerned about
11 not having been included in a meeting about me at Castle
12 Park?
13 A. Yes.
14 Q. Can you tell me about that concern?
15 A. I was concerned because I wished to relate the
16 incidents that had happened.
17 Q. Okay. You used the plural, incidents. Can you
18 tell me -- you told me -- we started talking about one of
19 them. Can you tell me another?
20 A. Yes. I was falsely accused of moving a notebook
21 and making comments to you which I did not make.
[SHE WAS TRYING TO HAVE OTHER PEOPLE BE THE PUBLIC ACCUSERS.]
p47
11 Can you tell me this incident, explain what
12 happened?
13 A. I was called in to a meeting in
14 Dr. Donndelinger's office with myself, other teachers and
15 yourself. I was accused of moving a notebook from the
16 table to another table and telling you that you could not
17 sit with us. I explained during the meeting that I did
18 not say these things; I did not move the notebook; no one
19 who was at the table had any recollection of the words
20 being said or my moving the notebook.
21 The resolution of the meeting was that I
22 apologized if you had mistakenly got the impression that
23 we did not want you to sit there or I did not want you to
24 sit at the table with us. And I had understood at that
25 point that it was resolved.
[She wasn’t apprehensive then????]
48
1 Q. Okay. Okay. Now, and you -- okay. Now, I'm
2 going back to something that you said just before we
3 discussed this second incident. You said that you had
4 wanted to be included at a meeting so you could discuss
5 this incident?
6 A. (Witness nods head.)
7 Q. Okay. Can you tell me another incident?
8 A. That would be the incident by the white board in
9 the morning where I felt -- I feel that I was unjustly
10 and unprovokedly verbally attacked by you.
11 Q. Is that that -- are you now talking about the
12 first incident we discussed today earlier? Because we
13 discussed this -- this sounds exactly like the incident
14 we were discussing a while ago.
15 A. That would be the incident, yes.
p49
4 MS. LARKINS: Yes. Let's call that the white
5 board and Kingdoms incident. That's a good idea to add
6 that word "Kingdoms." That helps make it clear. Okay.
7 Q. And is there another incident?
8 A. No.
9 Q. Okay. Was there any other interaction you ever
10 had with me that was negative?
17 Q. Were there any incidents other than the white
18 board/Kingdoms incident and the notebook incident during
19 the time you and I taught at Castle Park that you
20 consider to have been negative between you and me?
21 A. Not to my recollection.
[This doesn’t make sense. She may have wanted to stop situation--which
she had criminally started--from blowing up.]
22 Q. Okay. So when you wanted to be included in a
23 meeting at Castle Park about me, you wanted to discuss
24 the white board incident and the notebook incident?
25 A. Yes.
[SHE HAD ALREADY REPORTED THE WHITE BOARD INCIDENT, AND HAD
FALSELY APOLOGIZED FOR THE NOTEBOOK INCIDENT, SHE WAS ANGRY
ABOUT IT, AND WAS DETERMINED TO RETALIATE. She wanted me to
never say anything, to not be around. She wanted total control.These two
tiny incidents don’t explain her extreme upset. She was upset that the
whole thing was blowing up, Werlin and Kelly Angell had blown it up.]
P 50
1 Q. Okay. Let's go back to that white board
2 incident.
4 Let me try to remember where we left of. We
5 left off where you were standing or sitting next to the
6 white board, and you said there were other people there
7 in the room?
8 A. Uh-huh.
9 Q. Do you remember who those other people were?
10 A. I remember a couple of them, yes.
11 Q. Who were they?
12 A. Victoria Singleton, Kim Brown. I believe Linda
13 Kandel was there. There were others, but I don't recall
14 specifically.
[She and Kim also reported Victoria.]
15 Q. Okay. Then did you say anything?
18 Q. Okay. Then what happened?
19 A. From what point?
20 Q. Well, how did -- I believe you referred to --
21 you said that there was a confrontation with me. Could
22 you tell me how that began?
23 A. The confrontation portion or -- there were two
24 portions to that incident.
25 Q. How about you tell me the first one.
P 51
1 A. There was a change in the -- a change, and then
2 a change back in the Kingdoms schedule for that day. It
3 was noted on the board that the Kingdoms would be a video
4 that we were all to watch for that afternoon. You became
5 very upset at this and seemed to be more upset than the
6 situation required. Another teacher made a comment to
7 you that it was only -- was a video; it was very simple
8 to turn on the TV. You remarked to that teacher that you
9 thought her -- her comment was not very polite. You left
10 the room. You returned a few moments later and started
11 verbally attacking me about that you hoped that me and
12 Joe Ellen were happy and that we were out -- I don't
13 recall the specific words, but it was very aggressive,
14 very aggressive posture, very aggressive stance, very
15 accusatory that somehow I had done something to change
16 the Kingdoms on purpose to frustrate your lesson plan for
17 the day.
18 My response, while being shocked, was that I had
19 nothing to do with Kingdoms; that I was on the budget
20 committee, and I asked you to stop yelling at me.
21 Q. Okay. I'm interested in the first part of your
22 response. Was Victoria Singleton the other teacher?
23 A. Yes.
24 Q. And was she rude to me?
[She admits I was attacked at that time. She always runs and reports
everything. See Gretchen Donndelinger testimony and my testimony at OAH
hearing. Robin spoke very loudly and domineeringly.]
25 A. She was rude to many people, but, yeah, she was
P 52
1 a little out of line, yes.
2 Q. Okay. And did you ever tell anyone that you
3 thought she was rude to me?
4 A. I may have told Dr. Donndelinger when I spoke to
5 her about the incident, yes.
6 Q. Uh-huh. At that time did you say that I was
7 rude to -- that I -- did you tell Dr. Donndelinger that I
8 had said that Victoria was rude?
9 A. Yes. You said to Victoria that she was rude or
10 impolite or -- I don't remember the exact words. You
11 addressed her by name; you said that you thought that she
12 was rude, impolite, and you left the room.
13 Q. Okay. Now, this incident caused you to fear me?
14 A. No. The second incident caused me to fear you,
15 yes. The verbal attack after you had returned to the
16 room.
20 THE WITNESS: The second part of that incident.
[She’s deluded--or lying. In fact, I never spoke to her again. It was JoEllen who
confronted me a little bit later. JoEllen approached me to justify herself and I
walked away. I think Robin went in and talked to principal right then, at recess.
Or maybe she waited until lunch, after talking to JoEllen. Gretchen wrote me a
note and spoke to me at lunch.]
23 THE WITNESS: When Mrs. Larkins verbally
24 attacked me unprovoked.
25 MS. ANGELL: When she returned to the room on
p53
1 the same day?
2 THE WITNESS: Yes.
5 Q. Then what happened?
6 A. Then what happened from what point?
7 Q. After I allegedly verbally attacked you.
8 A. You left the room. I went and expressed my
9 concerns to Dr. Donndelinger.
10 Q. Okay. Did you -- okay. That's fine. Okay.
11 And this incident made you afraid of me. What
12 did you fear that I would --
21 Q. Okay. After this incident, what were you afraid
22 of that I might do to you?
p54
1 THE WITNESS: That another unprovoked response
2 or unprovoked attack would occur.
4 Q. A verbal attack?
5 A. Verbal mostly, yes. Any type of attack. I
6 don't know.
7 Q. Did you fear that I might attack you physically?
8 A. Not at that time, no.
9 Q. Okay. After I allegedly yelled at you in the
10 white board/Kingdoms incident, you were not afraid that I
11 would attack you physically?
14 Q. Is that correct?
15 A. I was afraid that your behavior was
16 unpredictable and not rational. I don't know
17 specifically whether it would just pertain to verbal or
18 physical as well.
19 Q. Okay. I'm really trying to get your state of
20 mind at that time. Okay.
21 Now, a minute ago you said you were not afraid
22 of me physically at that time after that incident, and
23 now you're saying maybe you were?
24 A. I don't specifically recall making any
25 statements that I was afraid of you physically, but I'm
p55
1 not sure. I mean unpredictable behavior is unpredictable
2 behavior.
3 Q. Okay. What -- okay. Anyway, at some point in
4 time you began to fear that I might physically attack
5 you?
6 A. Not specifically, but unpredictable behavior is
7 unpredictable behavior.
8 Q. Okay. Okay. So may I -- okay. Were you afraid
9 because you felt uncertain about my behavior?
10 A. Could you clarify that, please.
11 Q. Were you -- okay. Is it fair to say that you
12 were worried that I might verbally attack you? After
13 that incident you were afraid that I might verbally
14 attack you?
15 A. That more unpredictable behavior would follow,
16 might follow. No specifics on what type of behavior that
17 might be.
18 Q. But I want to know what you feared.
24 Q. You're saying that you don't know what you
25 feared. I'm asking you to try to remember what it was
p56
1 that you feared.
4 THE WITNESS: I did answer that.
6 Q. I really need to hear the answers again, because
7 I really do not know what the answer is.
8 A. I feared that more un -- that unpredictable
9 behavior -- unprovoked unpredictable behavior would occur
10 again. There were no specifics of what type of behavior
11 I feared.
12 MS. ANGELL: Do you mean you didn't tell anybody
13 specifically what behavior, or you weren't sure --
14 THE WITNESS: I was just not sure. I did not
15 know what I might expect.
17 Q. Okay. Did you think I might bring a gun to
18 school and shoot you?
19 A. No.
20 Q. Did you think I might punch you in the nose?
21 A. I don't know. Unpredictable behavior is
22 unpredictable behavior. I have no specific things that I
23 was afraid of.
24 Q. Would it be fair to say you just had a
25 generalized anxiety directed towards me?
P 57
6 Q. After this incident -- this white board/Kingdoms
7 incident, did you feel anxious around me?
8 A. Yes.
She felt vindictive
9 Q. When you felt anxious around me, was there a
10 specific action on my part that you feared?
11 A. No. Other than unpredictable behavior, but
12 nothing specific, no.
13 Q. Okay. Were you afraid that I might report your
14 aggressive behavior toward me?
15 A. No.
22 Q. Okay. I'd like to -- do you recall which one of
23 these two incidents happened first, the notebook incident
24 or the white board/Kingdoms incident?
25 A. The notebook incident.
p58
1 Q. Okay. And did you feel falsely accused after
2 the notebook incident?
3 A. I've already stated that, yes.
4 Q. Okay. At that time after the notebook incident,
5 were you afraid that I might start yelling at you?
6 A. No.
10 Q. Okay. Were you afraid that I might truthfully
11 accuse you?
12 A. No.
13 Q. Okay. Going back to that notebook incident, do
14 you remember sitting at a table before an in-service?
16 Q. During that meeting where I allegedly falsely
17 accused you -- regarding which I allegedly falsely
18 accused you?
19 A. Do I recall sitting at a table before that
20 meeting? Yes.
24 Q. Okay. And was I sitting at that table?
25 A. No.
P 59
1 Q. Had I made any attempt to sit at that table?
2 A. I don't know that you made an attempt to sit at
3 the table. You came to the table looking for your
4 notebook.
5 Q. Did you tell me to go over -- go over there and
6 point to the kindergarten table?
7 A. I don't recall what I said specifically, but I
8 don't recall telling you to go over somewhere. I may
9 have referred that your notebook might be over there, but
10 I don't recall telling you to go sit somewhere else, no.
11 Q. Was Rick Denmen sitting next to you at the time?
12 A. I don't know where Rick Denmen was sitting. He
13 was at the table, but I don't recall who was sitting next
14 to me.
15 Q. At the meeting that -- and the meeting -- at the
16 meeting about this incident did you say, "Rick Denmen
17 always gets me in trouble"?
18 A. Probably.
19 MS. ANGELL: I'm going to instruct the witness
20 to answer what you know or what you don't know as opposed
21 to guessing.
22 THE WITNESS: I don't recall specifically making
23 that statement, but I have made that statement, yes.
P 60
2 Q. Can you tell me about another time when you made
3 that statement?
4 A. After more than one staff meeting.
5 Q. Is Rick Denmen your friend?
6 A. Yes.
7 Q. Okay. Do you discuss school issues together?
8 Or when you were working at Castle Park, did you discuss
9 school issues together?
10 A. Occasionally.
11 Q. Did he talk to you about me?
12 A. Not to my recollection.
20 Q. The anxiety that you felt regarding me, did that
21 become more severe over time?
22 A. No.
23 Q. Okay. Did you think I was crazy?
P 61
3 Q. When you say you believed that I was
4 unpredictable, how did you come to that conclusion?
5 A. That was based on your behavior towards me
6 during the white board incident.
[after she had brought arrest records to school—she feared I would find out—
also, she was very aggressive, booming voice telling everyone within 20 yards
what was going to happen, Gina refused to ameliorate the harassment of me.]
7 Q. Okay. During the white board incident were you
8 afraid that I might report that you were aggressive
9 toward me?
10 A. No.
Robin depo reTim allen and fear unpredictable
11 Q. Okay. Did you ever tell Tim Allen that you
12 thought I might bring a gun to school?
13 A. No, not to my recollection.
17 Q. Did you tell Tim Allen what you were afraid I
18 was going to do?
19 A. I don't recall specifically what I told Tim
20 Allen except for that I was apprehensive about you.
21 Q. Okay. And at this time you told Tim Allen this,
22 I was not employed at Castle Park, was I?
23 A. No.
24 Q. Were you afraid I might come to Castle Park?
P 62
2 A. I had no feelings whatsoever about you coming to
3 Castle Park or not.
4 Q. What were you apprehensive of when you told
5 Tim --
6 A. The unpredictable behavior on your part towards
7 me.
8 Q. I hadn't -- I hadn't appeared at Castle Park for
9 many, many months at the time you reported this to
10 Mr. Allen, right?
11 A. (Witness nods head.)
17 MS. ANGELL: I'm going to instruct the witness
18 that questions that seek to invade an attorney-client
19 privilege, which would mean meetings where counsel was
20 present, are not to be answered.
21 THE WITNESS: Okay.
23 Q. Why did you discuss me with Tim Allen?
P 63
[Maura Larkins' note: was Donlan afraid her reputation would be harmed by
true allegations in my lawsuit, and wanted to smear me?]
2 Q. Why did you talk to Tim Allen about me when Tim
3 Allen was principal of Castle Park Elementary?
4 A. It was concerning a meeting with the attorney
5 and I choose not to answer.
8 MS. ANGELL: Do you need to talk to me for a
9 second?
10 THE WITNESS: No. You instructed me not to
11 answer questions that had to do with meetings where
12 counsel was present.
13 MS. ANGELL: Let's go off for a second. I'll
14 see if I can get it cleared up.
18 VIDEOGRAPHER: Off the record.
19 (Recess taken.)
24 Q. When you told Tim Allen that you were
25 apprehensive about me, was there an attorney present?
p64
1 A. No.
2 Q. Okay. Why did you tell Tim Allen that you were
3 apprehensive about me?
4 A. He asked me.
5 Q. Okay. Do you recall exactly how he asked it?
6 A. No.
7 Q. Had he heard from someone else that you were
8 apprehensive about me?
14 THE WITNESS: I don't know.
16 Q. How did he begin the conversation?
21 THE WITNESS: I don't recall precisely how the
22 conversation began.
24 Q. Is he the one who brought up my name during that
25 conversation?
p65
1 A. I believe so.
2 Q. Is it possible that you were the one that
3 brought up my name?
5 THE WITNESS: I don't know.
7 Q. Okay. Are you certain that he was the one who
8 brought up my name during that conversation?
9 A. No, I'm not certain that he is the one.
Note this passage from page 109:
9 Q. Do you think Ollie Matos is apprehensive about
10 your returning to Castle Park Elementary and doing
11 something unpredictable?
25 Q. Okay. When Tim Allen was principal at Castle
p66
1 Park, about how often did you become apprehensive about
2 me?
3 A. I don't recall making note of occurrences of
4 apprehension.
5 Q. Would you say it was a rare event?
6 A. No. I don't believe there were events.
7 Q. The event I'm referring to is your feeling
8 apprehensive about me. Was that a rare event?
9 A. No.
10 Q. Was it a common event?
11 A. Yes.
12 Q. Okay. Did you feel constantly apprehensive
13 about me?
14 A. I don't recall specifically.
15 Q. Okay. What were you afraid of that I would do?
16 A. Exhibit more unpredictable behavior.
17 Q. Where were you afraid that I would exhibit this
18 behavior?
19 A. I had no specific location that I was concerned
20 about.
21 Q. Did you think I would exhibit this behavior in a
22 location where you were located?
23 A. Yes.
24 Q. Okay. Did you think I would seek you out?
25 A. I did not speculate on that, no.
p 67
1 Q. Did you think I might accidentally come across
2 you?
3 A. I did not speculate on that.
4 Q. Did you think that somehow you and I would be
5 together and I would behave unpredictably?
6 A. I didn't specifically speculate on that.
7 I guess I'm not understanding the question being
8 asked.
9 Q. Okay. Let me try. Were you afraid that somehow
10 you and I would end up at the same location and I would
11 behave unpredictably?
12 A. Yes.
17 Q. Would you say that this was kind of a mild
18 anxiety in the back of your mind?
19 MS. ANGELL: Objection. Calls for expert
20 testimony. This person has not been established to be a
21 psychiatrist, psychotherapist or anything like that, and
22 it sounds to me like you're talking about medical
23 diagnoses.
Lots of don’t recalls
24 Q. Did you find out at some time that I had filed a
25 lawsuit?
p68
1 Q. Let's see. Let's not use the word "anxiety."
2 Let's say did you feel stressed about the possibility
3 that I might somehow appear and act unpredictable?
4 A. At times, yes.
5 Q. Okay. How often did these times occur?
6 A. I've not really speculated on that.
7 Q. Uh-huh. And this anxiety stemmed simply from
8 this white board/Kingdoms incident; is that correct?
9 A. Yes.
10 Q. And you were afraid that I might do something
11 worse than yell at you?
12 A. I didn't say that.
13 Q. Were you afraid that I might do something worse
14 than yell at you?
15 A. I was afraid that you would exhibit more
16 unpredictable behavior.
17 Q. Okay. In other words, you thought I might --
18 you were afraid -- were you afraid that I would exhibit
19 behavior which you had never experienced me exhibiting
20 before?
24 MS. ANGELL: Do you understand the question?
25 THE WITNESS: No.
p 69
7 Q. When you were feeling apprehensive about me when
8 Tim Allen was principal, did you think I might exhibit
9 behavior which I had never before exhibited?
10 A. I don't know what behavior you had exhibited
11 before, so I have no -- I need you to clarify that. Do
12 you mean exhibited to me?
13 Q. Yes. I mean to you.
14 A. Yes. That would go along with unpredictable
15 behavior.
16 Q. Okay. I'm going to leave that for a while.
17 Did you ask Tim Allen to get a restraining order
18 against me?
19 A. No.
20 Q. Did you ask Tim Allen to make sure that I didn't
21 come on the school grounds?
22 A. Not to my recollection.
23 Q. Did you tell Tim Allen about the white board
24 incident?
25 A. I don't recall.
p70
1 Q. Did you give any reason to Tim Allen for your
2 apprehension about me?
3 A. I don't recall specific reasons.
4 Q. If you had given him a reason for your
5 apprehension about me, it would have been the white board
6 incident, correct?
11 Q. When I was working at Castle Park and Gretchen
12 Donndelinger was working at Castle Park, did you ever
13 talk to her about a police report involving me or anyone
14 connected with me?
15 A. No.
16 Q. Did you ever tell her that you knew something
17 about me, but you -- she wouldn't want to know it?
18 A. No.
19 Q. Did you ever tell her that there was some sort
20 of non-school relationship between my family and your
21 family?
22 A. Not to my recollection, no.
p71
7 Q. Did you ever talk to Gretchen Donndelinger
8 without an attorney present about me at any other time
9 other than the times you were discussing the white board
10 incident and the notebook incident?
11 A. I don't recall any, no.
12 Q. Okay. If you had knowledge about a police
13 report about a teacher at your school, is that something
14 you'd be likely to remember?
15 A. Probably.
16 Q. Okay. Did you ever speak to Chris Moran, a
17 Union-Tribune reporter?
18 A. I don't know. I may have.
19 Q. Okay. Did you speak to any Union-Tribune
20 reporter regarding your transfer out of Castle Park
21 Elementary?
22 A. Yes.
p72
19 Q. Did you talk to a Union-Tribune reporter about
20 your transfer from Castle Park Elementary?
23 Q. Since last August.
24 A. I don't recall the exact date, but yes.
25 Q. Okay. Did you talk to more than one
73
1 Union-Tribune reporter?
2 A. No.
3 Q. Okay. Did you call the reporter or did the
4 reporter call you?
5 A. I did not call the reporter; the reporter did
6 not call me.
7 Q. Did you talk to the reporter in person?
8 A. Yes.
9 Q. Okay. Where were you when you talked to the
10 reporter?
11 A. I was at Castle Park Elementary School.
12 Q. Okay. At what time of day was it?
13 A. I don't recall specifically. It was in the
14 evening.
15 Q. Okay. And was this at a rally to protest your
16 transfer?
17 A. It was at a rally to inform the parents about
18 the transfer.
21 (Exhibit 4 marked for identification.)
P 74
6 Q. Did you prepare this document?
7 A. Yes, I did.
8 Q. Do you feel that it is wrong for someone to be
9 transferred without being told why?
10 A. Without being told why and -- if I -- I need
11 more clarification.
14 Q. Okay. Did you write this document in order to
15 protest your transfer out of Castle Park Elementary
16 School?
17 A. I wrote this document to make parents aware of a
18 meeting that was being held to inform the public, the
19 parents of Castle Park Elementary School about our
20 transfer and what they could to do to prevent it if they
21 so chose.
22 Q. Did you want the parents to prevent your
23 transfer?
24 A. Yes.
25 Q. Okay. Did you think your transfer was wrong?
P 75
1 MS. ANGELL: Objection. Vague and ambiguous;
2 calls for a legal conclusion.
4 Q. Did you think that you're transfer was morally
5 wrong?
6 MR. HERSH: Calls for a theological expert
7 response.
9 Q. How did you feel about your transfer?
10 A. I felt it was sudden and without appropriate
11 reason.
12 Q. Okay. Have you ever become aware at any time
13 before today that I was taken out of my classroom and
14 placed on administrative leave without being told why?
15 A. No.
16 Q. Were you ever aware until today -- before today
17 that I was taken out of my classroom at Castle Park and
18 placed on administrative leave?
p76
6 THE WITNESS: We knew -- I was aware you were on
7 leave. I did not know the specifics pertaining to that
8 leave, no.
P 77
11 Q. Okay. I am hoping that you'll be able to think
12 back and try to remember the very first time. And I
13 would imagine it would be a memorable moment, because
14 it's pretty unusual for a teacher to be placed on
15 administrative leave.
4 MS. LARKINS: Okay. This litigation,
5 Ms. Angell, was filed -- well, actually it was filed in
6 January of 2002, but it wasn't served until about March
7 12, 2002. And I don't think that Ms. Donlan became aware
8 of this litigation until March 12, 2002.
9 Now, I was placed on administrative leave the
10 first time on February 12, 2001, so we are talking about
11 a period of over a year before there was any litigation,
12 any attorneys, any attorney-client privilege. And of
13 course Ms. Donlan wants to tell us the truth here.
14 Q. So I need to ask you during the period of time
15 between February 12, 2001 and the time in 2002 when you
16 discovered that I had filed a lawsuit, did you ever find
17 out that I had been placed on administrative leave?
24 Q. Did you find out at some time that I had filed a
25 lawsuit?
P 79
2 THE WITNESS: Yes.
4 Q. Okay. How soon after teachers were served at
5 Castle Park Elementary did you find out that they had
6 been served?
7 A. I don't recall.
8 Q. Okay. Do you think it was pretty soon after?
9 A. I don't recall.
15 Q. When you were at Castle Park, was there a
16 table -- a certain table in the teachers' lounge that you
17 liked to sit at?
18 A. Yes.
19 Q. Okay. Were there other teachers who frequently
20 sat there with you?
21 A. Yes.
22 Q. Could you tell me who those teachers were?
23 A. It varied from day to day.
24 Q. Who were the most like -- who sat there with you
25 more often -- most often?
P 80
1 A. My assistant Kim Brown. Occasionally Victoria
2 Singleton would sit there. Occasionally Mimi January,
3 Linda Kandel, sometime -- generally Virginia Copeland.
4 Occasionally Terry Coffey.
11 Q. How do you feel about principal Ollie Matos?
19 THE WITNESS: I'm curious as to why my feelings
20 about Mr. Matos are relevant.
21 MS. ANGELL: Well, you don't get to ask those
22 kinds of questions, but -- because I think her --
25 MS. ANGELL: I'm just raising the relevance
P 81
1 objection again because we moved away from the transfer
2 issue I think for a little bit, and I think you are
3 moving back toward there, so it would be another one of
4 those relevance objections.
5 MS. LARKINS: I believe that Robin Donlan's
6 attitudes toward Ollie Matos are typical of her attitudes
7 toward quite a few people, and I believe she has sought
8 to damage him in a similar way that she sought to damage
9 me.
10 MS. ANGELL: Move to strike. No question
11 pending.
12 MS. LARKINS: I was talking to you.
13 MS. ANGELL: I don't understand what you're
14 saying. It sounds like you're testifying.
15 MS. LARKINS: No. You wanted to know how this
16 was relevant, and I'm just telling you that.
24 MS. LARKINS: I believe that conspiracy to
25 commit slander was one of the causes of action.
P 82
1 MS. ANGELL: That's alleged against Ms. Donlan
2 and Mr. Carlson.
3 MS. LARKINS: Exactly. I believe that
4 Ms. Donlan has a pattern of behavior of conspiracy to
5 commit slander and slander. That's why I think this
6 question is relevant.
7 MS. ANGELL: Okay. Go ahead.
10 Q. How do you feel about Ollie Matos?
13 A. I do not care for him.
14 Q. Could you tell me why not?
15 A. I do not feel that he is an effective
16 administrator.
17 Q. Why not?
18 A. Because he has proven on more than one occasion
19 to not be completely truthful, and I believe truthfulness
20 is very important -- an important administrative quality.
21 Q. Do you believe truthfulness is important for
22 teachers?
23 A. I believe truthfulness is important for
24 everyone.
First mention of "whiteboard incident"
Robin’s claimed fear of me due to two incidents
P 25
12 Q. Did you tell Tim Allen that you were
afraid of
13 me?
14 A. I don't recall specifically.
15 Q. Have you ever been afraid of me?
16 A. Yes.
P 26
9 Q. When were you first afraid of me?
10 A. I first became concerned after an
incident in
11 the staff lounge where you confronted me
in front of many
12 people there unprovoked.
13 Q. Okay. By unprovoked, do you
mean that you had
14 not said anything?
15 A. Not at that moment, no.
16 Q. About how long before this alleged
confrontation
17 had you said something?
18 A. Probably 10, 15 minutes. Maybe
longer. I don't
19 recall exactly the time.
20 Q. How long did this confrontation
last?
21 A. Probably about five minutes.
22 Q. Okay. And do you remember what
you were doing
23 before this confrontation began?
24 A. I was standing in the lounge talking
to people.
25 Q. Do you remember where you were
standing?
P 27
1 A. I was standing behind one of the
tables near the
2 white board.
3 Q. Uh-huh. And you're sure you
weren't sitting?
4 A. I'm not sure I wasn't sitting.
20 Q. Do you remember when this
happened?
21 A. It was in the morning.
22 Q. Okay. Do you remember what
year?
23 A. Not specifically.
24 Q. Can you relate it to some other
events?
25 A. It was when Dr. Donndelinger was
principal.
P 28
1 Q. Okay. And was there any personnel
action taken
2 against me shortly after this?
8 A. I don't recall when you stopped
working at
9 Castle Park Elementary School.
10 Q. Okay. Okay. Let's go back to this
incident.
11 Okay. Dr. Donndelinger was principal,
and you were
12 standing or sitting next to the white board
and it was in
13 the morning. I'm going to see if I can help
out here.
14 Do you think this might have been around
-- on or about
15 January 17th or so, maybe January 16th
of 2001?
16 A. I wouldn't know. I don't have any
recollection
17 of the date.
19 MS. ANGELL: Do you need some
water or anything?
20 (Brief interruption.)
24 (Exhibit 1 marked for identification.)
P 29
2 Q. Would you please read the first two
lines on
3 this document.
4 A. "January 16th; controversy on
Kingdom day; on
5 schedule, not in bulletin. January 17th;
Kingdoms,
6 Robin, Kim informing everyone."
P 31
15 Q. Does this document appear to you
to describe the
16 confrontation that you have -- between
yourself and me
17 which you have been talking about?
18 A. Describe? No.
19 Q. Does it appear to refer to that
confrontation?
20 A. Refer, yes.
21 Q. Okay. So in this line that says,
"Kingdoms,
22 Robin/Kim informing everyone," you have
a suspicion that
23 that Robin refers to you?
24 A. I do.
25 Q. And who do you think Kim refers
to?
P 32
1 A. Kim Brown.
2 Q. And who is she?
3 A. She is a special day class assistant.
4 Q. Okay. Is she a friends of yours?
5 A. Yes.
6 Q. Okay. Do you have a close working
relationship?
7 A. Not currently.
8 Q. Well, when you were working
together, did you
9 have a close working relationship?
10 A. Yes.
Robin’s claimed fear of me due to two incidents
P 25
12 Q. Did you tell Tim Allen that you were
afraid of
13 me?
14 A. I don't recall specifically.
15 Q. Have you ever been afraid of me?
16 A. Yes.
P 26
9 Q. When were you first afraid of me?
10 A. I first became concerned after an
incident in
11 the staff lounge where you confronted me
in front of many
12 people there unprovoked.
13 Q. Okay. By unprovoked, do you
mean that you had
14 not said anything?
15 A. Not at that moment, no.
16 Q. About how long before this alleged
confrontation
17 had you said something?
18 A. Probably 10, 15 minutes. Maybe
longer. I don't
19 recall exactly the time.
20 Q. How long did this confrontation
last?
21 A. Probably about five minutes.
22 Q. Okay. And do you remember what
you were doing
23 before this confrontation began?
24 A. I was standing in the lounge talking
to people.
25 Q. Do you remember where you were
standing?
P 27
1 A. I was standing behind one of the
tables near the
2 white board.
3 Q. Uh-huh. And you're sure you
weren't sitting?
4 A. I'm not sure I wasn't sitting.
20 Q. Do you remember when this
happened?
21 A. It was in the morning.
22 Q. Okay. Do you remember what
year?
23 A. Not specifically.
24 Q. Can you relate it to some other
events?
25 A. It was when Dr. Donndelinger was
principal.
P 28
1 Q. Okay. And was there any personnel
action taken
2 against me shortly after this?
8 A. I don't recall when you stopped
working at
9 Castle Park Elementary School.
10 Q. Okay. Okay. Let's go back to this
incident.
11 Okay. Dr. Donndelinger was principal,
and you were
12 standing or sitting next to the white board
and it was in
13 the morning. I'm going to see if I can help
out here.
14 Do you think this might have been around
-- on or about
15 January 17th or so, maybe January 16th
of 2001?
16 A. I wouldn't know. I don't have any
recollection
17 of the date.
19 MS. ANGELL: Do you need some
water or anything?
20 (Brief interruption.)
24 (Exhibit 1 marked for identification.)
P 29
2 Q. Would you please read the first two
lines on
3 this document.
4 A. "January 16th; controversy on
Kingdom day; on
5 schedule, not in bulletin. January 17th;
Kingdoms,
6 Robin, Kim informing everyone."
P 31
15 Q. Does this document appear to you
to describe the
16 confrontation that you have -- between
yourself and me
17 which you have been talking about?
18 A. Describe? No.
19 Q. Does it appear to refer to that
confrontation?
20 A. Refer, yes.
21 Q. Okay. So in this line that says,
"Kingdoms,
22 Robin/Kim informing everyone," you have
a suspicion that
23 that Robin refers to you?
24 A. I do.
25 Q. And who do you think Kim refers
to?
P 32
1 A. Kim Brown.
2 Q. And who is she?
3 A. She is a special day class assistant.
4 Q. Okay. Is she a friends of yours?
5 A. Yes.
6 Q. Okay. Do you have a close working
relationship?
7 A. Not currently.
8 Q. Well, when you were working
together, did you
9 have a close working relationship?
10 A. Yes.
p. 82
Donlan on truthfulness
Donlan on truthfulness
[Robin Donlan, who had seniority, claimed that
she wanted the position Heather Coman was
going to move into.
When Heather left, Donlan withdrew her claim on
the position.
It would appear that her only reason for asking for
the position was to push Heather Coman out of
the school.]
she wanted the position Heather Coman was
going to move into.
When Heather left, Donlan withdrew her claim on
the position.
It would appear that her only reason for asking for
the position was to push Heather Coman out of
the school.]
[The following news story came out two years after Robin Donlan
revealed her relationship with PTA president Kim Simmons in this
deposition.]
Former president of PTA is arrested
November 17, 2006
SAN DIEGO UNION TRIBUNE
CHULA VISTA – A former PTA president at Castle Park Elementary School has been
arrested on suspicion of embezzling thousands of dollars from the school, a police
spokesman said.
Kimberlee Simmons, 43, of Chula Vista was arrested by Chula Vista police Nov. 3, said
police spokesman Bernard Gonzales.
Gonzales said Simmons is suspected of stealing $10,000 to $20,000 from the school.
Simmons visited police headquarters for questioning and by the end of the interview
police decided they had enough information to arrest her, Gonzales said.
Simmons was booked into Las Colinas Detention Facility but released the same day, a
jail spokesman said.
Police have submitted the results of their investigation to the district attorney's office.
A deputy district attorney said yesterday that no charg-es have been filed against
Simmons while his office considers the case.
– Chris Moran
revealed her relationship with PTA president Kim Simmons in this
deposition.]
Former president of PTA is arrested
November 17, 2006
SAN DIEGO UNION TRIBUNE
CHULA VISTA – A former PTA president at Castle Park Elementary School has been
arrested on suspicion of embezzling thousands of dollars from the school, a police
spokesman said.
Kimberlee Simmons, 43, of Chula Vista was arrested by Chula Vista police Nov. 3, said
police spokesman Bernard Gonzales.
Gonzales said Simmons is suspected of stealing $10,000 to $20,000 from the school.
Simmons visited police headquarters for questioning and by the end of the interview
police decided they had enough information to arrest her, Gonzales said.
Simmons was booked into Las Colinas Detention Facility but released the same day, a
jail spokesman said.
Police have submitted the results of their investigation to the district attorney's office.
A deputy district attorney said yesterday that no charg-es have been filed against
Simmons while his office considers the case.
– Chris Moran
FOOD FIGHT IN STAFF LOUNGE
I wasn’t present for that.
Page 87
The following year did you come to the lounge dressed in a
raincoat in the expectation of having another food fight?
I don’t recall.
WHEN THE PRINCIPAL REFUSED TO SUSPEND A STUDENT
THAT ROBIN COLLS (DONLAN) WANTED SUSPENDED
Page 88
Gretchen Donndelinger
Did you ever have problems with her when she refused to suspend
a student you wanted suspended?
Page 89
Were you ever unhappy with Gretchen Donndelinger when she
refused to suspend one of your students whom you wanted
suspended?
I was—I wouldn’t say unhappy. I wasn’t pleased.
[Maura Larkins' note: Ms. Donlan, was, in fact, speechless with
rage, running into the staff lounge and leaning back against a wall
for support because she was so distraught. Two teachers went to
her to hear Donlan's complaints about Gretchen Donndelinger.]
I wasn’t pleased.
Did you ever ask Gina Boyd to come to Castle Park have a meeting
Page 90
I don’t recall
It might have happened
Line 17 Gina Boyd was supportive of everybody who was at Castle
Park in my belief.
[Maura Larkins' note: I guess I wasn’t anybody!]
Page 91
Did you discuss Gretchen Donndelinger’s failings?
Ollie Matos
Page 92
Mr. Perez
Do you believe Ollie Matos should be fired?
Removed from Castle Park
Most likely be a better fit at a different school
His skills better suited to a different type of staff than Castle Park
Castle Park is an independent staff, the staff as a whole is pretty
much involved in decision making
He might be better suited
[ROBIN DONLAN'S MISSING REPORT TO
GRETCHEN DONNDELINGER]
Page 84
Did you ever give a written statement about me
to Gretchen Donndelinger?
[exhibit 14]
Line 9 I have a pretty good memory for certain
things
Line 13 Do you frequently give written
statements about other teachers to principals?
No.
So it would stand out in your mind?
I don’t know
Line 19 Did you ever tell anyone that you were a victim of me?
[notes of March 2001 CVE meeting]
GRETCHEN DONNDELINGER]
Page 84
Did you ever give a written statement about me
to Gretchen Donndelinger?
[exhibit 14]
Line 9 I have a pretty good memory for certain
things
Line 13 Do you frequently give written
statements about other teachers to principals?
No.
So it would stand out in your mind?
I don’t know
Line 19 Did you ever tell anyone that you were a victim of me?
[notes of March 2001 CVE meeting]
| Tape 2 |
One way to get rid of a teacher who's not
adequately supportive of your politics:
PRETEND THAT YOU WANT TO SWITCH FROM
SPECIAL ED TO A REGULAR FOURTH GRADE
CLASS
Page 85
I enquired about a fourth grade opening that was becoming
available.
Do you remember how that opening became available
I believe Al Smith was transferred to third grade
Do you remember a year when a new portable was brought to
Castle Park School
Page 86
Why did you decide not to switch?
I did not make that decision. Dr. Donndelinger made
that decision.
Were you unhappy
I was disappointed
Are you now teaching a regular fourth grade class?
adequately supportive of your politics:
PRETEND THAT YOU WANT TO SWITCH FROM
SPECIAL ED TO A REGULAR FOURTH GRADE
CLASS
Page 85
I enquired about a fourth grade opening that was becoming
available.
Do you remember how that opening became available
I believe Al Smith was transferred to third grade
Do you remember a year when a new portable was brought to
Castle Park School
Page 86
Why did you decide not to switch?
I did not make that decision. Dr. Donndelinger made
that decision.
Were you unhappy
I was disappointed
Are you now teaching a regular fourth grade class?
Page 94
"I really didn't have any opinion about it at all"
[Robin appears very angry, deeply downward lines on mouth,
when discussing my handing out fliers.]
Did you... hand out fliers?
...yes...
Page 95
Certain parents, Gina Boyd, Peg Myers
Were you trying to prove to the principal that you could be
there and he couldn’t get rid of you?
Holding up signs
‘Support the teachers”
What did that mean?
Support the teachers who were transferred
Page 96 16:13
Bilingual
Did people get pretty angry
Page 97 16:14:25
Line 1 At these staff meetings?
Line 2 Not to my recollection.
Rule established
Staff meetings
Page 98
[No one claims to remember James Barron Stark inservice.]
I don’t recall.
Page 99
Hostility remaining
Heather Smith
Robin Donlan deposition
page 92 line 25
Are you acquainted with PTA president Kim Simmons?
p93
1 A. Yes.
2 Q. How long have you known her?
3 A. Approximately two years.
4 Q. How did you first become acquainted?
5 A. I don't recall.
6 Q. Has she ever called you up to report events at
7 Castle Park since you left?
8 A. Yes.
9 Q. About how often?
10 A. Occasionally, not very often.
11 Q. Have you suggested to her actions that she might
12 take at Castle Park since you left?
13 A. Yes.
14 Q. What actions were those?
15 A. I suggested at one incident that she call Gina
16 Boyd.
17 Q. What incident was that?
18 A. It was the incident where you were handing out
19 literature on the campus to the students.
20 Q. Okay.
21 A. The literature had Gina Boyd's name on it.
22 Q. Uh-huh. How did you feel about that?
25 Q. How did you feel about me handing out literature
P 94
1 that had Gina Boyd's name on it?
2 A. You're entitled to your opinion. But opinion is
3 opinion.
[Robin appears very angry in the video, with deeply downward
lines on mouth.]
4 Q. It didn't bother you at all?
5 A. I really didn't have any opinion about it at
6 all.
7 Q. Did you have any feelings about it?
8 A. (Witness shakes head.)
9 I didn't -- I failed to understand the purpose,
10 but your opinion is your opinion. You're entitled to it.
11 Q. Okay. And what other reports has Kim Simmons
12 made to you about Castle Park since you left?
13 A. She called to ask me if I knew two gentlemen
14 that had attended a PTA meeting, which I did not.
15 Q. Was she concerned about these two gentlemen?
16 A. You would have to ask her that.
17 Q. Did she tell you she was worried about these two
18 gentlemen?
19 A. No. She did not know who they were. She asked
20 me if I knew who they were and why they were there, and I
21 said no.
22 Q. Did you go to curriculum night at Castle Park
23 recently and hand out fliers?
24 A. For Jill Galvez, yes. She was running for the
25 school board seat that is currently occupied by Patrick
P 95
1 Judd.
2 Q. Why did you choose Castle Park as a place to
3 hand out your fliers that night?
4 A. I -- I saw no reason not to.
5 Q. Who was with you when you were handing out the
6 fliers?
7 A. Certain parents, Gina Boyd, other people I don't
8 recall specifically, and Peg Myers.
9 Q. Okay. Peg Myers was also recently transferred
10 from Castle Park, wasn't she?
11 A. Yes, she was.
12 Q. Were you trying to prove to the principal that
13 you could be there and he couldn't get rid of you?
page 92 line 25
Are you acquainted with PTA president Kim Simmons?
p93
1 A. Yes.
2 Q. How long have you known her?
3 A. Approximately two years.
4 Q. How did you first become acquainted?
5 A. I don't recall.
6 Q. Has she ever called you up to report events at
7 Castle Park since you left?
8 A. Yes.
9 Q. About how often?
10 A. Occasionally, not very often.
11 Q. Have you suggested to her actions that she might
12 take at Castle Park since you left?
13 A. Yes.
14 Q. What actions were those?
15 A. I suggested at one incident that she call Gina
16 Boyd.
17 Q. What incident was that?
18 A. It was the incident where you were handing out
19 literature on the campus to the students.
20 Q. Okay.
21 A. The literature had Gina Boyd's name on it.
22 Q. Uh-huh. How did you feel about that?
25 Q. How did you feel about me handing out literature
P 94
1 that had Gina Boyd's name on it?
2 A. You're entitled to your opinion. But opinion is
3 opinion.
[Robin appears very angry in the video, with deeply downward
lines on mouth.]
4 Q. It didn't bother you at all?
5 A. I really didn't have any opinion about it at
6 all.
7 Q. Did you have any feelings about it?
8 A. (Witness shakes head.)
9 I didn't -- I failed to understand the purpose,
10 but your opinion is your opinion. You're entitled to it.
11 Q. Okay. And what other reports has Kim Simmons
12 made to you about Castle Park since you left?
13 A. She called to ask me if I knew two gentlemen
14 that had attended a PTA meeting, which I did not.
15 Q. Was she concerned about these two gentlemen?
16 A. You would have to ask her that.
17 Q. Did she tell you she was worried about these two
18 gentlemen?
19 A. No. She did not know who they were. She asked
20 me if I knew who they were and why they were there, and I
21 said no.
22 Q. Did you go to curriculum night at Castle Park
23 recently and hand out fliers?
24 A. For Jill Galvez, yes. She was running for the
25 school board seat that is currently occupied by Patrick
P 95
1 Judd.
2 Q. Why did you choose Castle Park as a place to
3 hand out your fliers that night?
4 A. I -- I saw no reason not to.
5 Q. Who was with you when you were handing out the
6 fliers?
7 A. Certain parents, Gina Boyd, other people I don't
8 recall specifically, and Peg Myers.
9 Q. Okay. Peg Myers was also recently transferred
10 from Castle Park, wasn't she?
11 A. Yes, she was.
12 Q. Were you trying to prove to the principal that
13 you could be there and he couldn't get rid of you?
[It was difficult getting answers to my questions, but things
eventually got quite interesting.]
...[page] 30...
16 Q. Does this appear to you to be Page 5 of a series
17 of documents?
18 A. I have no idea.
19 Q. What do you think the 5 means?
20 A. I don't know.
P 36
1 Do you understand what "program" means?
2 THE WITNESS: No.
P34
16 Q. Were programs such as Kingdoms started at Castle
17 Park without the approval of the staff?... When Dr. Donndelinger was
principal.
P 35
[NO ANSWER]
12 [ Donlan] Does it make me angry if a principal starts a
13 program without the approval of the staff?
15 [Donlan] Angry? No.
16 Q. Does it make you angry if a principal stops a
17 program without the approval of the staff at a school at
18 which you are working?
19 A. Angry? No.
20 Q. How does it make you feel when a principal stops
21 a program at a school at which you are working without
22 the approval of the staff?
23 MS. ANGELL: Objection. It's vague and
24 ambiguous as to "program." I don't understand what
25 you're talking about.
p 36
1 [Ms. Angell, the witness' own attorney, questions the
witness!] Do you understand what "program" means?
2 THE WITNESS: No.
[Robin’s leaving Castle Park]
P 36
10 Q. Did there come a time
11 when you stopped working at Castle Park Elementary
12 School?
13 A. Yes.
14 Q. When was that time?
15 A. August --
16 MS. ANGELL: And I'm going to object here on
17 privacy and on relevance. And if you'd like to make an
18 offer of proof as to why this is relevant to the
19 litigation, I'm all ears.
20 MS. LARKINS: Or otherwise you're going to
21 instruct her not to answer the question? Okay.
22 I would like to say something about privacy.
23 I'd like to ask that this document be entered as Exhibit
24 2.
25 (Exhibit 2 marked for identification.)
P 37
18 My entire case rests on events which happened at
19 Chula Vista Elementary School District after the acts
20 were committed that I have alleged in my complaint. I
21 had no idea that the acts were being committed at the
22 time they were committed. It wasn't until long after
23 that I became aware. Everything in my case rests on the
24 bizarre behavior of Chula Vista Elementary School
25 District employees after I alleged that some of these
P 38
1 employees violated Section 432.7 of the Labor Code.
2 You have just made a claim of privacy regarding
3 Robin Donlan's leaving Castle Park, and yet Robin Donlan
4 herself caused her name to be repeated again and again in
5 the Star News and the Union-Tribune. She has totally
6 lost any right to privacy by the fact that she herself
7 has discussed widely, including going back to Castle Park
8 on curriculum night and talking to teachers and talking
9 to parents and making as public as possible her -- the
10 circumstances under which she left Castle Park.
16 MS. LARKINS: Well, one of my allegations is
17 that Ms. Donlan and other teachers who were involved in
18 egregious clique behavior behaved very abusively to
19 principals and teachers, and that that is why Castel Park
20 could not function with Robin Donlan on staff and --
P 39
12 MS. LARKINS: My proof of the conspiracy and
13 Labor Code violations is -- rests on the behavior of
14 Robin Donlan and others at Chula Vista Elementary School
15 District.
16 MS. ANGELL: So what does that have to do with
17 Ms. Donlan's employment status now?
18 MS. LARKINS: This is powerful -- a powerful
19 indication that Robin Donlan is very confrontational.
20 She has an enormous amount of hostility. She is
21 perfectly happy to destroy the reputations of
other
22 people. And this here is proof -- well, it's proof
of a
23 pattern of behavior of Robin Donlan of basically
24 character assassination and efforts to destroy
the
25 careers of others.
P 40
1 MS. ANGELL: So you want to ask Mrs. Donlan
2 about information contained in this news article
3 concerning Mr. Matos?
9 Q. I brought this out to indicate
10 that she does not seem to be that interested in
privacy.
20 MS. ANGELL: Well, I've asked for an offer of
21 proof as to why Ms. Donlan's current employment status is
22 relevant to the litigation which has allegations of
23 events in 2000 and 2001, and so far I haven't heard.
24 MS. LARKINS: Okay. Well, if you think it
25 appropriate, you can instruct your client not to answer a
P 41
1 question.
11 Q. Ms. Donlan, were you recently transferred
out of
12 Castle Park Elementary School?
13 THE WITNESS: Do I answer that?
14 MS. ANGELL: You want to talk to me for a
15 minute?
16 THE WITNESS: Sure.
21 VIDEOGRAPHER: Off the record at 2:13.
(18 minute Recess taken.)
P 42
7 Q. Did you ever tell Richard Werlin that your
8 brother was in law enforcement?
9 A. Yes.
10 Q. What was the situation when you told him that?
11 A. I was in a meeting with Mr. Werlin and Mrs. Boyd
12 regarding a letter they had received from you that made a
13 reference to a brother of mine in law enforcement, and he
14 asked me if I had a brother who was in law enforcement
15 and I said yes.
16 Q. Uh-huh. Can you -- did he ask you -- what else
17 did he ask you at that meeting?
18 A. He asked me if I had any knowledge of the letter
19 or the events described in the letter.
20 Q. Do you recall how you felt at that meeting?
21 A. Confused.
P 43
3 Did Rick Werlin tell you that he had
4 received a letter from me?
5 A. Yes.
10 Q. At this meeting between you and Mr. Werlin and
11 Gina Boyd, did Mr. Werlin say that he had received a
12 letter from me about you?
13 A. About me? No.
14 Q. What did he say the letter was about? Did he
15 say he had received a letter from me?
16 A. Yes.
23 Q. How was the meeting arranged?
24 A. He called and asked me to come to the district
25 office to meet with him and with Gina Boyd.
[MR. WERLIN NEVER DISCUSSED THE MATTER WITH MAURA
LARKINS! KELLY ANGELL MINNEHAN TALKED TO ROBIN'S BROTHER
MICHAEL CARLSON AND RECOMMENDED THAT HE GO TO DEBORAH
GARVIN AT THE FIRM STARTED BY SIDNEY STUTZ (BEFORE HE
FOUNDED STUTZ, ARTIANO SHINOFF & HOLTZ). SURVEILLANCE WAS
INITIATED IN 2003 WHEN I SUED MICHAEL CARLSON.]
eventually got quite interesting.]
...[page] 30...
16 Q. Does this appear to you to be Page 5 of a series
17 of documents?
18 A. I have no idea.
19 Q. What do you think the 5 means?
20 A. I don't know.
P 36
1 Do you understand what "program" means?
2 THE WITNESS: No.
P34
16 Q. Were programs such as Kingdoms started at Castle
17 Park without the approval of the staff?... When Dr. Donndelinger was
principal.
P 35
[NO ANSWER]
12 [ Donlan] Does it make me angry if a principal starts a
13 program without the approval of the staff?
15 [Donlan] Angry? No.
16 Q. Does it make you angry if a principal stops a
17 program without the approval of the staff at a school at
18 which you are working?
19 A. Angry? No.
20 Q. How does it make you feel when a principal stops
21 a program at a school at which you are working without
22 the approval of the staff?
23 MS. ANGELL: Objection. It's vague and
24 ambiguous as to "program." I don't understand what
25 you're talking about.
p 36
1 [Ms. Angell, the witness' own attorney, questions the
witness!] Do you understand what "program" means?
2 THE WITNESS: No.
[Robin’s leaving Castle Park]
P 36
10 Q. Did there come a time
11 when you stopped working at Castle Park Elementary
12 School?
13 A. Yes.
14 Q. When was that time?
15 A. August --
16 MS. ANGELL: And I'm going to object here on
17 privacy and on relevance. And if you'd like to make an
18 offer of proof as to why this is relevant to the
19 litigation, I'm all ears.
20 MS. LARKINS: Or otherwise you're going to
21 instruct her not to answer the question? Okay.
22 I would like to say something about privacy.
23 I'd like to ask that this document be entered as Exhibit
24 2.
25 (Exhibit 2 marked for identification.)
P 37
18 My entire case rests on events which happened at
19 Chula Vista Elementary School District after the acts
20 were committed that I have alleged in my complaint. I
21 had no idea that the acts were being committed at the
22 time they were committed. It wasn't until long after
23 that I became aware. Everything in my case rests on the
24 bizarre behavior of Chula Vista Elementary School
25 District employees after I alleged that some of these
P 38
1 employees violated Section 432.7 of the Labor Code.
2 You have just made a claim of privacy regarding
3 Robin Donlan's leaving Castle Park, and yet Robin Donlan
4 herself caused her name to be repeated again and again in
5 the Star News and the Union-Tribune. She has totally
6 lost any right to privacy by the fact that she herself
7 has discussed widely, including going back to Castle Park
8 on curriculum night and talking to teachers and talking
9 to parents and making as public as possible her -- the
10 circumstances under which she left Castle Park.
16 MS. LARKINS: Well, one of my allegations is
17 that Ms. Donlan and other teachers who were involved in
18 egregious clique behavior behaved very abusively to
19 principals and teachers, and that that is why Castel Park
20 could not function with Robin Donlan on staff and --
P 39
12 MS. LARKINS: My proof of the conspiracy and
13 Labor Code violations is -- rests on the behavior of
14 Robin Donlan and others at Chula Vista Elementary School
15 District.
16 MS. ANGELL: So what does that have to do with
17 Ms. Donlan's employment status now?
18 MS. LARKINS: This is powerful -- a powerful
19 indication that Robin Donlan is very confrontational.
20 She has an enormous amount of hostility. She is
21 perfectly happy to destroy the reputations of
other
22 people. And this here is proof -- well, it's proof
of a
23 pattern of behavior of Robin Donlan of basically
24 character assassination and efforts to destroy
the
25 careers of others.
P 40
1 MS. ANGELL: So you want to ask Mrs. Donlan
2 about information contained in this news article
3 concerning Mr. Matos?
9 Q. I brought this out to indicate
10 that she does not seem to be that interested in
privacy.
20 MS. ANGELL: Well, I've asked for an offer of
21 proof as to why Ms. Donlan's current employment status is
22 relevant to the litigation which has allegations of
23 events in 2000 and 2001, and so far I haven't heard.
24 MS. LARKINS: Okay. Well, if you think it
25 appropriate, you can instruct your client not to answer a
P 41
1 question.
11 Q. Ms. Donlan, were you recently transferred
out of
12 Castle Park Elementary School?
13 THE WITNESS: Do I answer that?
14 MS. ANGELL: You want to talk to me for a
15 minute?
16 THE WITNESS: Sure.
21 VIDEOGRAPHER: Off the record at 2:13.
(18 minute Recess taken.)
P 42
7 Q. Did you ever tell Richard Werlin that your
8 brother was in law enforcement?
9 A. Yes.
10 Q. What was the situation when you told him that?
11 A. I was in a meeting with Mr. Werlin and Mrs. Boyd
12 regarding a letter they had received from you that made a
13 reference to a brother of mine in law enforcement, and he
14 asked me if I had a brother who was in law enforcement
15 and I said yes.
16 Q. Uh-huh. Can you -- did he ask you -- what else
17 did he ask you at that meeting?
18 A. He asked me if I had any knowledge of the letter
19 or the events described in the letter.
20 Q. Do you recall how you felt at that meeting?
21 A. Confused.
P 43
3 Did Rick Werlin tell you that he had
4 received a letter from me?
5 A. Yes.
10 Q. At this meeting between you and Mr. Werlin and
11 Gina Boyd, did Mr. Werlin say that he had received a
12 letter from me about you?
13 A. About me? No.
14 Q. What did he say the letter was about? Did he
15 say he had received a letter from me?
16 A. Yes.
23 Q. How was the meeting arranged?
24 A. He called and asked me to come to the district
25 office to meet with him and with Gina Boyd.
[MR. WERLIN NEVER DISCUSSED THE MATTER WITH MAURA
LARKINS! KELLY ANGELL MINNEHAN TALKED TO ROBIN'S BROTHER
MICHAEL CARLSON AND RECOMMENDED THAT HE GO TO DEBORAH
GARVIN AT THE FIRM STARTED BY SIDNEY STUTZ (BEFORE HE
FOUNDED STUTZ, ARTIANO SHINOFF & HOLTZ). SURVEILLANCE WAS
INITIATED IN 2003 WHEN I SUED MICHAEL CARLSON.]
[Many Castle Park Elementary teachers were livid
when the idea of a bilingual program was introduced
during the 1993-4 school year.
1. Staff discussions were so out of control that James
Barron Stark was hired to teach the teachers how to
conduct a staff meeting without yelling.
Unfortunately, the angry teachers just became
passive aggressive instead of openly
aggressive. They took out their
anger on bilingual teachers and
bilingual kids.
2. During the following six years, these angry
teachers instigated the dismissals of
two bilingual teachers in a school with
only four bilingual positions.
3. Angry teachers also refused to team with bilingual
teachers. Luci Fowers was the sole English-only
teacher who was willing to team.
when the idea of a bilingual program was introduced
during the 1993-4 school year.
1. Staff discussions were so out of control that James
Barron Stark was hired to teach the teachers how to
conduct a staff meeting without yelling.
Unfortunately, the angry teachers just became
passive aggressive instead of openly
aggressive. They took out their
anger on bilingual teachers and
bilingual kids.
2. During the following six years, these angry
teachers instigated the dismissals of
two bilingual teachers in a school with
only four bilingual positions.
3. Angry teachers also refused to team with bilingual
teachers. Luci Fowers was the sole English-only
teacher who was willing to team.
Then-CVESD-Superintendent, Lowell Billings filled in
as one of the eleven principals who worked at the
school during the past eleven years. Billings was so
weak (or so uninterested) that he went along with
whatever these teachers wanted. Despite this,
Billings accepted an award from the California
Association of Bilingual Educators in 2007. Perhaps
the award is best explained by the fact that Bertha
Lopez, a board member of CABE, is also a board
member of CVESD. CVESD board members
apparently appreciate the way Lowell Billings has kept
quiet about their wrongdoing.
UPDATE: Bertha Lopez was indicted in
Jan. 2013 after becoming a trustee
Sweetwater Union High School District.
In 2005 the district realized that the
ruling teachers were out of control,
and transferred some of them out of
the school. Robin Donlan and the
other transferred teachers were
outraged that they were given a small
taste of the medicine they had been
gleefully delivering in heavy doses to
others for years. Playing the part of
victims, they became known as the
"Castle Park Five."]
as one of the eleven principals who worked at the
school during the past eleven years. Billings was so
weak (or so uninterested) that he went along with
whatever these teachers wanted. Despite this,
Billings accepted an award from the California
Association of Bilingual Educators in 2007. Perhaps
the award is best explained by the fact that Bertha
Lopez, a board member of CABE, is also a board
member of CVESD. CVESD board members
apparently appreciate the way Lowell Billings has kept
quiet about their wrongdoing.
UPDATE: Bertha Lopez was indicted in
Jan. 2013 after becoming a trustee
Sweetwater Union High School District.
In 2005 the district realized that the
ruling teachers were out of control,
and transferred some of them out of
the school. Robin Donlan and the
other transferred teachers were
outraged that they were given a small
taste of the medicine they had been
gleefully delivering in heavy doses to
others for years. Playing the part of
victims, they became known as the
"Castle Park Five."]
SDER blog posts re Castle Park
Five
Five
Castle Park Five
teachers depositions
and stories
Robin Donlan deposition
Robin Donlan $7 m fraud
Peg Myers (CVE
President) deposition
Peg Myers and the SDUT
teachers depositions
and stories
Robin Donlan deposition
Robin Donlan $7 m fraud
Peg Myers (CVE
President) deposition
Peg Myers and the SDUT
Other former Castle
Park Elementary
teachers
Gina Boyd (CVE President)
Maura Larkins (target of
Robin Donlan, Peg Myers
and Gina Boyd.
Park Elementary
teachers
Gina Boyd (CVE President)
Maura Larkins (target of
Robin Donlan, Peg Myers
and Gina Boyd.
CVESD Rptr blog posts re 2008
case
case
Blog posts
Web pages
| See "page 99" below, at bottom of this web page. |
| See "page 99" at bottom of this web page. |
| Depositions Robin Donlan Peg Myers Gina Boyd (See also: more perjury by Gina Boyd) Linda Watson Maura Larkins |