Page 102 about 16:24
I think it is preposterous, the
idea that someone couldn’t
tell whether something is right
or wrong because they didn’t
have theological expertise,
but you can instruct your
client not to answer.
Page 103 16:24:31
Page 104
Discussions of standing
objections
Page 105 16:25:35
Page 106
I think teachers who are
transferred should have
reasons given them
Should have paper trail
Line 23 If a teacher is
transferred from Castle Park
Elementary School without
being given a reason, what
do you think should be done?
Page 107
Do you have a personal
opinon
What you personally thought
should be done
Page 108
If a teacher is involuntarily
transferred
Page 109
Her braid is in the way, so
she moves it around behind
her and brings it in front to
the other side
Line 9 Do you think Ollie
Matos is apprehensive about
you returning to Castle Park
Elementary and doing
something unpredictable?
Page 111
HYPOCRISY
Do you think that having their
teacher disappear suddenly
during the middle of the year
Is harmful for children?
Page 114
I don’t choose to speculate
Did you tell any reporter
Did you discuss
I expressed my concerns that
I would be replaced
16:39:29
Page 115
A credential provides training
I’m trying to figure out what
you feared would result
Are you afraid that they
would not be properly
disciplined?
Discipline is not specific to
special ed.
Do special ed classrooms
have different discipline
problems from regular
classrooms?
Not that I’ve seen.
Page 116 16:1:21
But for the most part, they
should stay in their seats
Talk
Not during instructional time
or during their quiet work time
Page 117
A very straight line
MS. ANGELL: Vague and
ambiguous as to time. Are
you talking about a 13 or 14
year time span and
continuously requiring
students to walk in a straight
line for 14 years?
MS. LARKINS: That’s an
interesting question. Did you
ever require that students
walk in a straight line for 14
years?
No.
I didn’t think so.
Page 118
Page 119
When you passed out these
flyers, were you trying to
make it impossible for Ollie
Matos to lead the school?
No.
| Home Why This Website SDCOE CVESD Castle Park Elem Law Enforcement CTA CVE Stutz Artiano Shinoff Silence is Golden Schools and Violence Office Admin Hearings Larkins OAH Hearing |
Page 100
Kelley Dupuis
Not that I can recall
Robin prepared flier
Page 101 16:20:45
Line 2 Do all teachers belong to the
Castle Park family?
How do they exclude themselves
Some teachers choose not to participate
in things
What things
Line 10 Staff meetings
They’re still considered part of the Castle
Park family—community
Teachers who are in the Castle Park
Family
Kelley Dupuis
Not that I can recall
Robin prepared flier
Page 101 16:20:45
Line 2 Do all teachers belong to the
Castle Park family?
How do they exclude themselves
Some teachers choose not to participate
in things
What things
Line 10 Staff meetings
They’re still considered part of the Castle
Park family—community
Teachers who are in the Castle Park
Family
Robin Donlan deposition
Part 2 page 100
November 4, 2004
Part 2 page 100
November 4, 2004
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
Robin Donlan was supported by attorneys
Deborah Garvin,
Kelly Angell, and
Michael Hersh
Link to Part 1
Part 3
Deborah Garvin,
Kelly Angell, and
Michael Hersh
Link to Part 1
Part 3
16:13 Bilingual program
p101
1 A. I meant the teachers, students and parents.
2 Q. Okay. Do all teachers belong to the Castle
Park
3 family?
4 A. If they desire to, yes.
[Wrong! I desired to, but before I got there it was
decided I would not be allowed to join. Heather Coman,
Heather Smith also wanted to belong, so did Lucy
Fowers]
5 Q. How do they exclude themselves from the
Castle
6 Park family?
7 A. Some teachers choose not to participate in
8 things.
9 Q. What things are those?
10 A. Staff meetings, other in-services. There
are
11 some teachers who remain to themselves. They
are still
12 considered part of the family -- the Castle Park,
you
13 know, community, but sometimes they don't
participate in
14 items, no.
P 105
23 Q. Do you think it's wrong for a teacher who is
a
24 member of the Castle Park family to be
transferred out of
25 the school?
P 106
15 THE WITNESS: I think that teachers who are
16 transferred should have reasons given to them in
the form
17 of some sort of administrative paper trail before
they
18 are transferred. It should not be a surprise.
20 Q. And if there is no reason given orally or on
21 paper, what should be done in your opinion?
22 A. I'm unclear.
23 Q. If a teacher is transferred from Castle Park
24 Elementary School without being given a reason,
what do
25 you think should be done?
Union trib and Chula Vista Star News reporters would
be hard pressed to recognize the aggressive and angry
woman they talked to
p107
1 A. Without being given an administrative trail --
2 paper trail reason?
3 Q. Yes.
11 MS. LARKINS: Are you instructing your
client
12 not to answer the question?
13 THE WITNESS: Well, if she has a legal
opinion
14 and she's qualified as a lawyer about what needs
to
15 happen when people get transferred, she can by
all means
16 answer.
20 Q. Do you have just a personal opinion?
21 A. I gave you my personal opinion as to how I
felt
22 about transfers.
23 Q. But I asked you what you personally
thought
24 should be done if a transfer takes place without
any
25 administrative paper trail or any oral reasons.
P 108
13 Q. If a teacher is involuntarily transferred from
14 Castle Park Elementary School, do you think he
or she has
15 a right to come back to the school and pass out
16 literature about the transfer?
19 THE WITNESS: In the school, outside the
school,
20 inside the school grounds, outside the school
grounds?
21 Please clarify.
23 Q. Okay. If a teacher is involuntarily
transferred
24 out of Castle Park Elementary School without an
25 administrative paper trail, do you think that
teacher
P 109
1 should come back and hold rallies inside the
school?
3 THE WITNESS: If the -- I believe that after
4 school hours a school becomes a public park.
Public
5 parks are available for distribution -- for voicing
6 opinions, holding rallies, having soccer games,
letting
7 your children play.
15 Q. Okay. So we talked about -- do you think
that
16 it is right for a teacher who has been involuntarily
17 transferred from Castle Park Elementary School
without a
18 paper trail of the administrative reasons to come
and
19 pass out literature on the sidewalk out in front of
the
20 school?
p110
5 THE WITNESS: The sidewalk is a public
venue.
7 Q. So, for example, you felt that it was right for
8 me to pass out literature on the sidewalk in front of
9 Castle Park School regarding my involuntary
transfer?
10 A. I had no opinion on that.
17 Q. Do you think having a teacher removed
from the
18 school during the summer harms a child who was
planning
19 on having that teacher in the following school
year?
20 MS. ANGELL: Objection. Calls for a legal
21 conclusion. This person is not established as an
expert
22 in any type of genre. It sounds like you're asking
for a
23 psychological opinion.
P 111
4 Q. How many years have you taught children?
5 A. Sixteen.
12 Q. During your 16 years teaching children,
did you
13 develop any opinions about classroom situations
that
14 might help children?
15 A. Yes.
16 Q. Did you develop any opinions about
classroom
17 situations that might harm children?
18 A. Yes.
19 Q. Do you think that having their teacher
disappear
20 suddenly during the middle of the year is harmful
for
21 children?
22 MS. ANGELL: Objection. Calls for an expert
23 opinion. Again, this person is not established as
an
24 expert in psychological issues, and I believe you're
25 asking for a psychological analysis.
P 112 prevents her from answering
1 MS. LARKINS: Are you instructing her not to
2 answer the question?
3 MS. ANGELL: She can't answer the question.
4 Are you qualified as a -- do you have any
5 training -- are you licensed as a psychologist?
6 THE WITNESS: No.
7 MS. ANGELL: Are you license as a
psychiatrist?
8 THE WITNESS: No.
9 MS. ANGELL: Have you had training in
counseling
10 and guidance for school children?
11 THE WITNESS: No.
12 MS. ANGELL: Do you have any
qualifications that
13 make you an expert as to what is harmful to school
14 children?
15 THE WITNESS: No.
16 MS. LARKINS: Okay. That's fascinating to
me
17 that you have no qualifications for deciding what is
18 harmful for school children. Wow! Okay.
19 Q. When you passed out this flier, were you
trying
20 to impact the children of Castle Park Elementary
School?
21 A. No.
P 113
24 Q. Do you think your transfer was in the best
25 interests of the educational program of Castle
Park?
P 114
1 A. No.
2 Q. Why do you think you were transferred?
3 A. I was only given that reason. I don't choose
to
4 speculate on any other reasons.
5 Q. Do you think you were transferred because
you
6 were -- you talked a lot in staff meetings?
7 A. I don't choose to speculate on any other
8 reasons. I'm not privy to that information as to why I
9 was transferred other than the information I was
given,
10 which is that it was in the best interests of the
11 educational program.
12 Q. Did you tell any reporter that you were
13 transferred because you disagreed with Ollie
Matos?
14 A. I don't specifically recall making that
15 statement.
16 Q. Did you discuss your transfer with a
reporter?
17 A. Yes, I did.
18 Q. What do you recall saying to the reporter?
19 A. I expressed my concerns that I would be
replaced
20 with a person who was not credentialed in special
ed and
21 that that would not be in the best interest of those
22 students.
23 Q. What do you feel that a uncredentialed
teacher
24 in special ed would do differently from you?
25 A. They don't have the training or the
background
P 115
1 on theory, behavior --
11 Q. But I'm trying to figure out what you feared
12 would result.
13 A. That the students would not receive the
best
14 quality education possible from an unqualified
teacher.
15 Q. Okay. Are you afraid that they would not
be
16 properly disciplined?
17 A. Discipline is not specific to special ed.
18 Q. Do special ed classrooms have different
19 discipline problems from regular classrooms?
20 A. Not that I've seen.
[she couldn’t get away with her extreme rigidity in a
regular classroom, there’d be no justification. Regular
kids can handle discussion, and need it. I think special
ed kids can handle it and need it, but many people
think special ed classes should have rigid discipline,
like Robin imposes]
P 116
3 Q. Do you feel that you are able to get your
4 students to behave better than other teachers are
able
5 to?
6 A. I believe that I'm able to get my students to
7 behave.
8 Q. And by "behave," what do you mean by that?
9 A. Remain on task, behave in a civilized
manner,
10 follow the rules of the school and of the
classroom.
11 Q. Okay. Does that involve walking around
the
12 room?
14 THE WITNESS: I don't understand what you
mean.
16 Q. Do you allow your students to walk around
the
17 room?
18 A. Occasionally, yes.
19 Q. But for the most part, they should stay in
their
20 seats?
21 A. Yes.
22 Q. Okay. Do you allow your students to talk?
23 A. Not during their instructional time or during
24 quiet work time, no.
P 117
7 Q. When you were at Castle Park, did you
require
8 your students to walk in a very straight line?
9 MS. ANGELL: Do you mean -- excuse me.
Vague
10 and ambiguous as to time. Are you talking about
a 13 or
11 14-year time span and continuously requiring
students to
12 walk in a straight line for 14 years?
13 MS. LARKINS: That's an interesting
question.
14 Q. Did you ever require that students walk in a
15 straight line for 14 years?
16 A. No.
17 Q. I didn't think so.
18 Did you change your discipline
requirements over
19 the years at Castle Park?
20 A. My discipline requirements were adjusted
to suit
21 the needs of the students that I had.
25 Q. So during all the years that you taught at
P 118
1 Castle Park, you required your students to walk in a
2 straight line?
3 A. My emphasis was more on a quiet line than a
4 straight line.
16 Q. When students are walking in a line, do you
17 think their teachers are remiss if they don't
require the
18 line to be straight?
19 A. No. I think the teachers just have a
different
20 expectation than I have.
21 Q. Okay. Do you think that some of the
teachers at
22 Castle Park during the time you were teaching
there were
23 not as good teachers as you?
24 A. I wouldn't have any opinion on that. I have
not
25 observed many teachers in their classroom
teaching.
P 119
1 Q. And that would stop you from having an
opinion
2 about them?
3 A. If I have no knowledge from which to base it
on.
4 Q. Good.
5 When you passed out these fliers, were you
6 trying to make it impossible for Ollie Matos to lead
the
7 school?
11 Q. When you passed out the fliers such as
Exhibit
12 4, were you trying to make it impossible for Ollie
Matos
13 to lead the school?
14 A. No.
15 Q. What were you trying to accomplish?
16 A. Inform the parents of the transfer and how
they
17 could stop it if they so chose.
19 MS. ANGELL: Do you need a break?
20 THE WITNESS: Yeah, if I could, please.
P 123
10 MS GARVIN: Are we going to take a break
and go
11 off the record?
12 MS. LARKINS: Okay. Shall we do that now?
13 THE WITNESS: I would like to do that.
15 VIDEOGRAPHER: Off the record at 4:49.
(Recess taken.)
Back on the record at 4:55.
18 MS. LARKINS: Okay. I would like to ask that
19 this document be labeled -- okay -- as Exhibit 5.
20 I want to make sure that you get one,
21 Ms. Garvin, because this relates so specifically to
your
22 client.
P 124
3 (Exhibit 5 marked for identification.)
17 A. "Deposition of Gretchen Donndelinger."
P 125
22 A. "Did Robert -- Robin Colls ever share with
you
23 any kind of information concerning a police report
24 allegedly, somehow, involving Maura Larkins?"
P 126
9 Q. Was there ever something about a police
report
10 that you didn't want Gretchen Donndelinger to
know?
11 A. Not to my recollection, no.
12 Q. Okay. So according to your recollection,
13 Gretchen Donndelinger's testimony about you
here is
14 false?
15 A. As far as I recall.
9 Q. Was there ever something about a police
report
10 that you didn't want Gretchen Donndelinger to
know?
11 A. Not to my recollection, no.
12 Q. Okay. So according to your recollection,
13 Gretchen Donndelinger's testimony about you
here is
14 false?
15 A. As far as I recall.
16 Q. Okay. Did your brother ever talk to you
during
17 the year 2000 about my having been arrested?
18 MR. GARVIN: Vague and ambiguous.
19 THE WITNESS: No.
perjury
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.
1 A. I meant the teachers, students and parents.
2 Q. Okay. Do all teachers belong to the Castle
Park
3 family?
4 A. If they desire to, yes.
[Wrong! I desired to, but before I got there it was
decided I would not be allowed to join. Heather Coman,
Heather Smith also wanted to belong, so did Lucy
Fowers]
5 Q. How do they exclude themselves from the
Castle
6 Park family?
7 A. Some teachers choose not to participate in
8 things.
9 Q. What things are those?
10 A. Staff meetings, other in-services. There
are
11 some teachers who remain to themselves. They
are still
12 considered part of the family -- the Castle Park,
you
13 know, community, but sometimes they don't
participate in
14 items, no.
P 105
23 Q. Do you think it's wrong for a teacher who is
a
24 member of the Castle Park family to be
transferred out of
25 the school?
P 106
15 THE WITNESS: I think that teachers who are
16 transferred should have reasons given to them in
the form
17 of some sort of administrative paper trail before
they
18 are transferred. It should not be a surprise.
20 Q. And if there is no reason given orally or on
21 paper, what should be done in your opinion?
22 A. I'm unclear.
23 Q. If a teacher is transferred from Castle Park
24 Elementary School without being given a reason,
what do
25 you think should be done?
Union trib and Chula Vista Star News reporters would
be hard pressed to recognize the aggressive and angry
woman they talked to
p107
1 A. Without being given an administrative trail --
2 paper trail reason?
3 Q. Yes.
11 MS. LARKINS: Are you instructing your
client
12 not to answer the question?
13 THE WITNESS: Well, if she has a legal
opinion
14 and she's qualified as a lawyer about what needs
to
15 happen when people get transferred, she can by
all means
16 answer.
20 Q. Do you have just a personal opinion?
21 A. I gave you my personal opinion as to how I
felt
22 about transfers.
23 Q. But I asked you what you personally
thought
24 should be done if a transfer takes place without
any
25 administrative paper trail or any oral reasons.
P 108
13 Q. If a teacher is involuntarily transferred from
14 Castle Park Elementary School, do you think he
or she has
15 a right to come back to the school and pass out
16 literature about the transfer?
19 THE WITNESS: In the school, outside the
school,
20 inside the school grounds, outside the school
grounds?
21 Please clarify.
23 Q. Okay. If a teacher is involuntarily
transferred
24 out of Castle Park Elementary School without an
25 administrative paper trail, do you think that
teacher
P 109
1 should come back and hold rallies inside the
school?
3 THE WITNESS: If the -- I believe that after
4 school hours a school becomes a public park.
Public
5 parks are available for distribution -- for voicing
6 opinions, holding rallies, having soccer games,
letting
7 your children play.
15 Q. Okay. So we talked about -- do you think
that
16 it is right for a teacher who has been involuntarily
17 transferred from Castle Park Elementary School
without a
18 paper trail of the administrative reasons to come
and
19 pass out literature on the sidewalk out in front of
the
20 school?
p110
5 THE WITNESS: The sidewalk is a public
venue.
7 Q. So, for example, you felt that it was right for
8 me to pass out literature on the sidewalk in front of
9 Castle Park School regarding my involuntary
transfer?
10 A. I had no opinion on that.
17 Q. Do you think having a teacher removed
from the
18 school during the summer harms a child who was
planning
19 on having that teacher in the following school
year?
20 MS. ANGELL: Objection. Calls for a legal
21 conclusion. This person is not established as an
expert
22 in any type of genre. It sounds like you're asking
for a
23 psychological opinion.
P 111
4 Q. How many years have you taught children?
5 A. Sixteen.
12 Q. During your 16 years teaching children,
did you
13 develop any opinions about classroom situations
that
14 might help children?
15 A. Yes.
16 Q. Did you develop any opinions about
classroom
17 situations that might harm children?
18 A. Yes.
19 Q. Do you think that having their teacher
disappear
20 suddenly during the middle of the year is harmful
for
21 children?
22 MS. ANGELL: Objection. Calls for an expert
23 opinion. Again, this person is not established as
an
24 expert in psychological issues, and I believe you're
25 asking for a psychological analysis.
P 112 prevents her from answering
1 MS. LARKINS: Are you instructing her not to
2 answer the question?
3 MS. ANGELL: She can't answer the question.
4 Are you qualified as a -- do you have any
5 training -- are you licensed as a psychologist?
6 THE WITNESS: No.
7 MS. ANGELL: Are you license as a
psychiatrist?
8 THE WITNESS: No.
9 MS. ANGELL: Have you had training in
counseling
10 and guidance for school children?
11 THE WITNESS: No.
12 MS. ANGELL: Do you have any
qualifications that
13 make you an expert as to what is harmful to school
14 children?
15 THE WITNESS: No.
16 MS. LARKINS: Okay. That's fascinating to
me
17 that you have no qualifications for deciding what is
18 harmful for school children. Wow! Okay.
19 Q. When you passed out this flier, were you
trying
20 to impact the children of Castle Park Elementary
School?
21 A. No.
P 113
24 Q. Do you think your transfer was in the best
25 interests of the educational program of Castle
Park?
P 114
1 A. No.
2 Q. Why do you think you were transferred?
3 A. I was only given that reason. I don't choose
to
4 speculate on any other reasons.
5 Q. Do you think you were transferred because
you
6 were -- you talked a lot in staff meetings?
7 A. I don't choose to speculate on any other
8 reasons. I'm not privy to that information as to why I
9 was transferred other than the information I was
given,
10 which is that it was in the best interests of the
11 educational program.
12 Q. Did you tell any reporter that you were
13 transferred because you disagreed with Ollie
Matos?
14 A. I don't specifically recall making that
15 statement.
16 Q. Did you discuss your transfer with a
reporter?
17 A. Yes, I did.
18 Q. What do you recall saying to the reporter?
19 A. I expressed my concerns that I would be
replaced
20 with a person who was not credentialed in special
ed and
21 that that would not be in the best interest of those
22 students.
23 Q. What do you feel that a uncredentialed
teacher
24 in special ed would do differently from you?
25 A. They don't have the training or the
background
P 115
1 on theory, behavior --
11 Q. But I'm trying to figure out what you feared
12 would result.
13 A. That the students would not receive the
best
14 quality education possible from an unqualified
teacher.
15 Q. Okay. Are you afraid that they would not
be
16 properly disciplined?
17 A. Discipline is not specific to special ed.
18 Q. Do special ed classrooms have different
19 discipline problems from regular classrooms?
20 A. Not that I've seen.
[she couldn’t get away with her extreme rigidity in a
regular classroom, there’d be no justification. Regular
kids can handle discussion, and need it. I think special
ed kids can handle it and need it, but many people
think special ed classes should have rigid discipline,
like Robin imposes]
P 116
3 Q. Do you feel that you are able to get your
4 students to behave better than other teachers are
able
5 to?
6 A. I believe that I'm able to get my students to
7 behave.
8 Q. And by "behave," what do you mean by that?
9 A. Remain on task, behave in a civilized
manner,
10 follow the rules of the school and of the
classroom.
11 Q. Okay. Does that involve walking around
the
12 room?
14 THE WITNESS: I don't understand what you
mean.
16 Q. Do you allow your students to walk around
the
17 room?
18 A. Occasionally, yes.
19 Q. But for the most part, they should stay in
their
20 seats?
21 A. Yes.
22 Q. Okay. Do you allow your students to talk?
23 A. Not during their instructional time or during
24 quiet work time, no.
P 117
7 Q. When you were at Castle Park, did you
require
8 your students to walk in a very straight line?
9 MS. ANGELL: Do you mean -- excuse me.
Vague
10 and ambiguous as to time. Are you talking about
a 13 or
11 14-year time span and continuously requiring
students to
12 walk in a straight line for 14 years?
13 MS. LARKINS: That's an interesting
question.
14 Q. Did you ever require that students walk in a
15 straight line for 14 years?
16 A. No.
17 Q. I didn't think so.
18 Did you change your discipline
requirements over
19 the years at Castle Park?
20 A. My discipline requirements were adjusted
to suit
21 the needs of the students that I had.
25 Q. So during all the years that you taught at
P 118
1 Castle Park, you required your students to walk in a
2 straight line?
3 A. My emphasis was more on a quiet line than a
4 straight line.
16 Q. When students are walking in a line, do you
17 think their teachers are remiss if they don't
require the
18 line to be straight?
19 A. No. I think the teachers just have a
different
20 expectation than I have.
21 Q. Okay. Do you think that some of the
teachers at
22 Castle Park during the time you were teaching
there were
23 not as good teachers as you?
24 A. I wouldn't have any opinion on that. I have
not
25 observed many teachers in their classroom
teaching.
P 119
1 Q. And that would stop you from having an
opinion
2 about them?
3 A. If I have no knowledge from which to base it
on.
4 Q. Good.
5 When you passed out these fliers, were you
6 trying to make it impossible for Ollie Matos to lead
the
7 school?
11 Q. When you passed out the fliers such as
Exhibit
12 4, were you trying to make it impossible for Ollie
Matos
13 to lead the school?
14 A. No.
15 Q. What were you trying to accomplish?
16 A. Inform the parents of the transfer and how
they
17 could stop it if they so chose.
19 MS. ANGELL: Do you need a break?
20 THE WITNESS: Yeah, if I could, please.
P 123
10 MS GARVIN: Are we going to take a break
and go
11 off the record?
12 MS. LARKINS: Okay. Shall we do that now?
13 THE WITNESS: I would like to do that.
15 VIDEOGRAPHER: Off the record at 4:49.
(Recess taken.)
Back on the record at 4:55.
18 MS. LARKINS: Okay. I would like to ask that
19 this document be labeled -- okay -- as Exhibit 5.
20 I want to make sure that you get one,
21 Ms. Garvin, because this relates so specifically to
your
22 client.
P 124
3 (Exhibit 5 marked for identification.)
17 A. "Deposition of Gretchen Donndelinger."
P 125
22 A. "Did Robert -- Robin Colls ever share with
you
23 any kind of information concerning a police report
24 allegedly, somehow, involving Maura Larkins?"
P 126
9 Q. Was there ever something about a police
report
10 that you didn't want Gretchen Donndelinger to
know?
11 A. Not to my recollection, no.
12 Q. Okay. So according to your recollection,
13 Gretchen Donndelinger's testimony about you
here is
14 false?
15 A. As far as I recall.
9 Q. Was there ever something about a police
report
10 that you didn't want Gretchen Donndelinger to
know?
11 A. Not to my recollection, no.
12 Q. Okay. So according to your recollection,
13 Gretchen Donndelinger's testimony about you
here is
14 false?
15 A. As far as I recall.
16 Q. Okay. Did your brother ever talk to you
during
17 the year 2000 about my having been arrested?
18 MR. GARVIN: Vague and ambiguous.
19 THE WITNESS: No.
perjury
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.
| Robin Donlan Deposition November 2004 P 127 line 9-16 Q. 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. |
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.
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.
| Gretchen Donndelinger Deposition September 2002 This deposition of the principal of Castle Park Elementary was taken for the Office of Administrative Hearings (OAH) hearing, but never used by Maura Larkins' attorney Elizabeth Schulman. |
| 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. |
Kelly Angell broadens question
should have administrative
paper trail
if no reason given on paper
Kelly and Hersh stop answer,
pass out literature after being
transferred
P 100
10 Q. Okay. Going back to Exhibit No. 4, which is
the flier that you prepared --
13 Q. Did you do this translation into Spanish
yourself or did someone do that for you?
15 A. Someone did that for me.
16 Q. Who was that?
17 A. Stephanie Pettit.
20 MS. LARKINS: … How about we
staple this to Exhibit 4. This is the translation of [Exhibit
4].
22 Q. Okay. On the tenth line of the English
version
23 which you wrote, did you refer to the Castle Park
family?
24 A. Yes.
25 Q. What did you mean by that?
100
3 Q. Okay. Have you ever talked to Star News
4 reporter Kelley Dupuis?
5 A. Yes.
6 Q. Did you ever discuss me with him?
7 A. Not that I can recall.
3 Q. Okay. Have you ever talked to Star News
4 reporter Kelley Dupuis?
5 A. Yes.
6 Q. Did you ever discuss me with him?
7 A. Not that I can recall.
| Education Report |
| San Diego |
Q. ...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.
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.