I discussed this with my principal/supervisor on                                                ______________                __________  


Date                             Signature of grievant                                                                      ________________________


CVE/Grievance Level II
(For further
explanation of
hoax, see
Did
CVESD Violate
EERA?)
CVE Grievance Chair Jim
Groth failed to fulfil his
legal obligations.  If he
had honestly pursued the
grievance (below),
instead of  perpetrating a
hoax on Maura Larkins,
the truth would have been
revealed about  illegal
actions of Assistant
Superintendent
Richard
Werlin and teacher Robin
Donlan, and the entire
situation would have been
rectified without litigation.
GRIEVANCE REPORT FORM                                  LEVEL II
To be used only after informal conference has been held and grievance is not resolved, or in cases where the
grievance is initiated at Level II.
Type Only
Principal/Supervisor                                                                                    ____________________________     
Gretchen Donndelinger
The District violated Article 38.1 of the Agreement when it issued a
letter of reprimand to Maura Larkins without just cause on
April 4,
2001.

Proposed remedy to grievance:
The District shall:
1) Provide written, detailed rationale for why the employee was
placed on Administrative Leave on February 8, 2001.
2) Provide specific written details of the behaviors alleged to be
"irrational and unprofessional."
3) Modify the content of the 4/4/01 memorandum by eliminating
completely the second paragraph.
4) Any other remedies mutually agreed to by the parties.
Last Name                                 First Name                                       M.I.                     Date                               _____        
Groth          Jim                                     5/22/01
School/Department                                                                      Position                                           ___________  
CVE for Castle Park Elementary       CVE Grievance Chair
Jim Groth's hoax led Chula
Vista Educators and Chula
Vista Elementary School
District down a path that has
cost both himself and CVESD
board members Cheryl Cox,
Bertha Lopez, Pam Smith,
Larry Cunningham and Pat
Judd any claim they might
have had to being honest or
ethical public servants.
Donlan and other abusive
teachers were
transferred out of Castle
Park Elementary in
2004, after they had
done enormous harm to
the children of the school.
Jim Groth preferred to take a
path that included multiple
felony cover-ups rather than to
admit that a close personal
friend of CVE President Gina
Boyd, Robin Donlan, was guilty
of a couple of misdemeanors.
Teachers Robin Donlan
and Linda Watson
continued to cause trouble
at Castle Park Elementary
for three more years.
Asst. Superintendent
Richard Werlin was
covering up his own as
well as
Robin Donlan's
illegal actions.   Robin
Donlan should have been
transferred out of
Castle
Park Elementary in 2001.  
Werlin left the district in
2003.
On April 4, 2001, the day
after reciving Larkins' fax,
the district asked Maura
Larkins to return to work,
but began to
create a paper
trail with false accusations to
cover-up its illegal actions of
February 12, 2001.
This grievance was a hoax, created to fool Maura Larkins into thinking the union was
representing her.   Jim Groth was rewarded for his dishonesty by CTA, which has a
policy of supporting local leaders no matter what they do, and is now a member of
CTA's board of directors.
> > >
In order to keep Larkins
unaware of the role CVE was
playing in the Larkins case, CVE
president Jim Groth played a
clever trick on
CVE member
Maura Larkins.   Jim Groth, who
was then the grievance
chairman, and is now a director
of CTA,   with the help of
Executive Director Tim O'Neill
and then-President Gina Boyd,  
convinced Larkins that he was
representing her. He was
actually trying to prevent her
from figuring out that CVE and
certain teachers had committed
crimes against her.  CVE was
supporting the teachers who had
made the accusations, Linda
Watson and Jo Ellen Hamilton.  
The motive was the upcoming
election of Gina Boyd, and the
friendship of Gina Boyd with
Linda Watson and the originator
of the potential murderer
allegation, Robin Donlan.
At the same time, the union got
busy trying to create a fake
paper trail to cover up what
had happened. The grievance
below was created to fool
Maura Larkins into thinking
that the union was
representing her.   She was
told not to come to the
grievance meeting, because it
would be in her "best interest"
not to come.  There actually
was no grievance meeting.
This grievance is
Exhibit #3 in
May 2007 lawsuit
against
California
Teachers
Association
CVE grievance chair Jim Groth's grievance (below) was never filed, according
to the sworn testimony of CVE President Gina Boyd.

It may or may not have been filed.  In fact, the district responded to it.  

One thing is clear.  The entire grievance process was a charade created to fool Maura Larkins, with the
purpose of hiding CVESD's and CVE's involvement in crimes initiated by teachers.
Chula Vista Elementary School
District, particularly Richard
Werlin, worked closed with
Jim Groth, Tim O'Neill and
Gina Boyd, wasting close to
half a million in  taxpayer
dollars to cover up  
misdemeanors which would
never have resulted in
penalties for anybody.
Jim Groth worked
with Asst. Supt.
Richard Werlin to
perpetrate a hoax and
cover up crimes
On April 3, 2001 Maura
Larkins figured out that the
district had
committed a
crime against her (violation
of Labor Code section
432.7). She sent a letter
with a copy of a
restraining
order against Kathleen Elton
to the district and to CVE.
The district and CVE realized
that the woman whose
allegations they had relied
on when they had taken
action against Maura
Larkins seven weeks earlier
was actually an unreliable
individual.   But the district
did not apologize.  It tried to
create a paper trail that
would cover-up what had
happened, and justify the
action by fabricating new
allegations.
On February 12, 2001,
CVESD teacher Maura
Larkins was told not to
report to work because two
teachers reported she might
kill them.
The teachers union
pretended to help Larkins,
although it turned out that
the leaders of the union had
been helping the teachers
who had made the
allegations.
Jim Groth
preferred to take a
path that included
felony cover-ups
Asst.
Superintendent
Richard Werlin
was covering up
Chula Vista
Elementary School
District
Below: Hoax Grievance by Jim Groth and CTA

and hoax follow-up letters by CVE Presidents Jim Groth  and Gina Boyd and
Executive Director Tim O'Neill of
Chula Vista Educators
Richard Werlin,
Superintendent
Libia Gil, and CTA
executive director
Tim O'Neill all
wrote letters to
help pull off the
hoax.
To go back to
page 12
Jim Groth knew
the truth when
he published the
following in
March 2008:

"CTA works hard to
ensure your rights are
protected.

"A member's rights
come through the
contract bargaining by
SDEA and through laws
and education code.

"If a right is violated,
CTA provides
members resources to
defend their rights. "

found at
http://www.sdea.net/column_ct
a/column_cta.html

In fact, Jim Groth made
sure that Maura Larkins
rights were violated,
that the law was
disobeyed, and that
absolutely no resources
were provided to
defend Maura Larkins.  
The same was true in
the case of Danielle
Cozaihr.


Mr. Groth further writes:
"Members also receive
... protection of due
process rights, and free
legal consultations."

Jim Groth knows that
this is not true in many
cases.  It all depends on
what CTA officials feel to
be in their own interest.

Mr. Groth also warns:

"Non-members will not
be given access to CTA
legal resources."

At least they don't pay
thousands and
thousands of dollars
which will then be used
to pay for lawyers who
work to deny their rights!
California Teachers
Association head
counsel Beverly
Tucker became
involved in the
cover-up on April 30,
2001.
Chula Vista
Educators violated
its own bylaws to
keep the truth
covered up.  
The CVE board of directors'
lawyer, Michael Hersh, who
is a subordinate of head
counsel Beverly Tucker,
worked with CVE President
Gina Boyd and executive
director Tim O'Neill to

prevent Maura Larkins from
making a complaint to the
CVE board of directors or
representative council.
This behavior by CTA's top
officials was repeated at
Teachers Association of
Long Beach (TALB), where
CTA lawyers worked to
protect the affiliate's
president, who was misusing
funds.
CTA's top brass has
been involved in
multiple cover-ups
SD Education Rpt Blog
Next, Rick Werlin sent a response.
So, was the
grievance filed or
not?  Did Gina
Boyd's lawyers, who
included CTA head
counsel Beverly
Tucker and Michael
Hersh, give her bad
instructions during
her deposition?  Did
they suborn her
perjury?  Here is
Gina Boyd's sworn
testimony on the
matter:
Richard Werlin was assigned
by Superintendent Libia Gil
to investigate himself.

CVESD board members Cheryl
Cox, Pamela Smith, Bertha Lopez,
Patrick Judd and Larry
Cunningham found this behavior
to be appropriate.

How else could they cover up
crimes by CVESD?


It is odd that CVESD submitted the
above UNSIGNED GRIEVANCE to
the Office of Administrative
Hearings as its Exhibit 26.

CVESD must have copied the
grievance provided by Maura
Larkins, instead of a grievance
that had actually been filed,  which
would, of course, have been
signed by Jim Groth.  

Was a grievance signed by Jim
Groth on behalf of Maura Larkins
actually received by the district?  

The answer is hard to determine
when both CVESD and CTA were
suborning perjury of their
witnesses.

Did CVESD (with Lowell Billings
as superintendent and Rick Werlin
as Billings' faithful liaison with
Mark Bresee of Parham & Rajcic)
submit a hoax grievance and hoax
responses to that grievance?  

Or did CTA employee Gina Boyd
commit perjury when she said the
grievance was never filed?  

The following two pages are Exhibit 14 in Gina Boyd's 2004 deposition.
Here is a clear transcription of the grievance:
CVE Executive Director Tim O'Neill ignored Maura Larkins' calls and faxes, until he
finally decided he had better pretend to support Larkins.  In July 2001, Tim O'Neill
sent the following disingenuous letter to Libia Gil.  It's shocking to realize that even
though he could clearly express the wrongfulness of the situation, he continued to help
Libia Gil cover up crimes.
CVESD Superintendent Libia Gil covered up multiple
violations of the law by assigning Richard Werlin to
investigate himself.
 

And CTA supported her.  Why?  It turned out CTA was involved
in the wrongdoing from the beginning.
Libia Gil covered up crimes by assigning
Richard Werlin to investigate himself.
Gina Boyd
contradicted these
written statements
when she was under
oath.
Hoax?  Yes.
It turned out that Mr. O'Neill wrote this letter in an effort to
convince Maura Larkins that she was being represented
by CTA.  But according to sworn testimony by CVE
president Gina Boyd, the CTA grievance was never filed.
Hoax?  Yes.  It turned out that Tim O'Neill and
CTA were helping the district cover up
wrongdoing against Maura Larkins.
It turned out that the grievance Libby Gil is
talking about in this letter had
never been
filed
, according to sworn testimony by CVE
president Gina Boyd.  Neither CTA nor
CVESD ever produced a signed copy of the
grievance in question.
Hoax?  Yes.
It turned out that Jim Groth never filed
this grievance, or at least never
wanted a positive response.
Hoax?  Yes.
This is just a clearer
copy of the above
grievance.
Hoax?  Yes.
Gina Boyd
contradicted these
written statements
when she was under
oath.
Hoax?  Yes.
When she was under
oath Gina Boyd stated
that this grievance was
never filed.
Hoax?  Yes--at
least by Gina Boyd.
When she was
under oath Gina
Boyd stated that this
grievance was never
filed.
Hoax?  Yes.
Site Map
If you guessed that every single document on this page
was a hoax, you are correct.  Neither CTA nor CVESD ever
produced a signed copy of the grievance in question.

But is it possible the grievance really was filed?
Yes, but that leaves us to conclude that Gina Boyd
committed perjury.

Which is it?  Why would anyone commit a felony to cover up
a silly hoax?

Answer:  They wouldn't.  
These people were
covering up a lot more
than one silly hoax.
Can you spot the hoax documents below?  You may be surprised.  
The answer can be found at the bottom of this page.
Chula Vista Elementary School District was represented by attorney Mark Bresee at the time
these documents were created.
(For further explanation of hoax, see
Did
CVESD Violate EERA?)
CVE President Gina Boyd wrote to Maura Larkins that the
grievance was filed on May 22, 2001.

[Regarding the odd black areas on each side of the fax: who knows why  Chula Vista
Educators kept these interesting features on its faxes for an extended period of time.]
Jim Groth and
Tim O'Neill,
Masters of
Irony?  

[Note: When the shoe was
on the other foot, and Jim
Groth's teacher allies were
transferred out of the very
same school that Maura
Larkins worked at,
suddenly Jim Groth and
Tim O'Neill changed their
tune.  Now they thought it
was wrong not to tell a
teacher why she was being
transferred, even though
this time the
superintendent worked far
harder to obey the
contract, actually meeting
with the transferred
teachers.  O'Neill had told
Maura Larkins that a
superintendent conference
was not required until after
her transfer had been
completed.]




Article from
San Diego
Union Tribune:

Contract broken in transfer
of 5 teachers
Superintendent needed to
give reason, ruling finds

By Chris Moran
February 11, 2006

CHULA VISTA – Chula
Vista's elementary schools
superintendent violated
union contract rules by not
explaining to five Castle
Park Elementary School
teachers why he transferred
them to other schools in
2004, an arbitrator has ruled.

Only one of the five, first-
grade teacher Nikki Perez,
has returned to the school.
Jim Groth, president of the
teachers union, said the
other four teachers declined
to return because of the
disruption of switching
schools mid-year.

Tom Cruz, Chula Vista
Elementary School District's
assistant superintendent for
human resources, agreed
that a mid-year transfer
would be disruptive but said
the district had to follow the
letter of the arbitrator's ruling.
The ruling on Dec. 21 states
that the teachers are entitled
to reinstatement to their old
jobs “commencing with the
next semester.” In Chula
Vista, that meant Jan. 30.

The arbitrator upheld the
authority of Chula Vista
Superintendent Lowell
Billings to move teachers
from school to school. But
the district's contract with
Chula Vista Educators
requires Billings to have a
“conference” with each
teacher.

Billings met with each of the
five teachers, but did not
explain his decisions other
than to say, “It is in the best
interests of the educational
program,” the ruling states.

The arbitrator ruled that the
contract does not allow the
superintendent to repeat
this “as a mantra” in
meeting with the teachers.

“This was not a
'conference,' as that word
is defined, but a unilateral
ukase,” the arbitrator
wrote.

“To this day, the
five
teachers don't know why
they were administratively
transferred,” Groth said.

The case isn't over. The
union also seeks payment
to Perez and former Castle
Park teachers Stephenie
Petitt, Victoria Singleton,
Robin Donlan and Peggie
Myers for expenses related
to their transfers. These
include time spent packing
and unpacking and the
purchase of teaching
materials needed, as some
of them changed grades.

The five teachers had been
active at Castle Park on the
school site council, which
governs the school, and the
budget committee, which
makes recommendations
on how to spend money.

Then-Principal Ollie Matos
testified that several of the
teachers refused to
cooperate with changes he
wanted to make to improve
the school, the arbitrator's
ruling states. Billings made
the transfers.

Matos has since left Castle
Park to become director of
educational services at
Lemon Grove School
District. Castle Park has had
nine principals and interim
principals in just over a
decade.
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Larkins OAH Hearing
Did CTA director Jim Groth file the grievance below when he was grievance chair for Chula
Vista Educators, or did he orchestrate an elaborate hoax?  Chula Vista Educators President
Gina Boyd testified during her deposition that the grievance was never filed.
Jim Groth's Grievance Hoax
(Mr. Groth had crucial help from
CVESD Superintendent Libia Gil)