March 27, 2008
Richard Romero
Attorney of record
SASH v. Maura Larkins
By fax to 619 232 3264
Dear Mr. Romero:
Thank you for the note indicating that you will NOT respond to
my phone calls.
Does your refusal to respond also extend to the
faxed meet-and-confer letter (attached) that I
sent yesterday?
Respectfully,
Maura Larkins
Richard Romero
Attorney of record
SASH v. Maura Larkins
By fax to 619 232 3264
Dear Mr. Romero:
Thank you for the note indicating that you will NOT respond to
my phone calls.
Does your refusal to respond also extend to the
faxed meet-and-confer letter (attached) that I
sent yesterday?
Respectfully,
Maura Larkins
March 28, 2008
Ray Artiano, Esq.
Designated representative
of Stutz, Artiano Shinoff & Holtz for deposition
Daniel Shinoff, Esq., noticed deponent,
counsel for Ray Artiano for deposition
By fax
Re: Meet and Confer re Stutz, Artiano, Shinoff &
Holtz v. Maura Larkins regarding production of
documents and appearances at deposition
Dear Ray Artiano and Daniel Shinoff:
I am writing to ask if you have found the documents that you failed
to produce as required on November 8, 2007. I trust that you’ve
had an opportunity to look for them during the past four and a half
months. Please produce them immediately if you have found them.
Once again, the requested documents consist of the documents that
Daniel Shinoff collected from employees of Chula Vista Elementary
School District in or about the fall of 2001. Mr. Shinoff caused the
documents to be Bate-stamped in his office. His office gave copies
of some or all of these documents to attorney Mark Bresee of
Parham and Rajcic in 2002. Mr. Bresee produced some, but not all,
of these documents for my OAH hearing. As I stated in your Notices
of Deposition: "The Bate stamps begin with the number 1, not 01 or
001, and continue through 87."
In July 2004 I made a heroic effort to help your office determine
exactly which documents were requested. I faxed a letter to Kelly
Angell on July 22, 2004, and attached the documents that Mark
Bresee had produced, so that SASH could easily and precisely
identify the missing documents. My efforts were ignored by SASH.
Your law firm has had years to produce these documents.
Two days ago I re-faxed to you the July 22, 2004 letter and
documents so that you will be able to clearly and precisely identify
the set of documents which you are required by law to produce.
I have received no reponse regarding the meet-and-confer letter
that I sent you two days ago. All I received was a short fax
acknowledging receipt of the Bate-stamped documents, and saying
that SASH would not respond to the meet-and-confer phone calls I
made.
When the two of you walked out of Ray Artiano’s deposition on
November 8, 2008, the same day that Daniel Shinoff refused to
appear for his own deposition, you took with you the set of
documents you had offered in lieu of the requested documents. Of
course, I will need a copy of that set just to avoid any further
confusion.
I would like to have a discovery referee in this case. Are you willing
to agree to ask the court to appoint a discovery referee?
Finally, I would like to ask if one or both of you is now willing to
appear for your deposition. Please call me if you are willing to
discuss the above matters, or if you wish to discuss any other
matter.
Respectfully,
Maura Larkins
Ray Artiano, Esq.
Designated representative
of Stutz, Artiano Shinoff & Holtz for deposition
Daniel Shinoff, Esq., noticed deponent,
counsel for Ray Artiano for deposition
By fax
Re: Meet and Confer re Stutz, Artiano, Shinoff &
Holtz v. Maura Larkins regarding production of
documents and appearances at deposition
Dear Ray Artiano and Daniel Shinoff:
I am writing to ask if you have found the documents that you failed
to produce as required on November 8, 2007. I trust that you’ve
had an opportunity to look for them during the past four and a half
months. Please produce them immediately if you have found them.
Once again, the requested documents consist of the documents that
Daniel Shinoff collected from employees of Chula Vista Elementary
School District in or about the fall of 2001. Mr. Shinoff caused the
documents to be Bate-stamped in his office. His office gave copies
of some or all of these documents to attorney Mark Bresee of
Parham and Rajcic in 2002. Mr. Bresee produced some, but not all,
of these documents for my OAH hearing. As I stated in your Notices
of Deposition: "The Bate stamps begin with the number 1, not 01 or
001, and continue through 87."
In July 2004 I made a heroic effort to help your office determine
exactly which documents were requested. I faxed a letter to Kelly
Angell on July 22, 2004, and attached the documents that Mark
Bresee had produced, so that SASH could easily and precisely
identify the missing documents. My efforts were ignored by SASH.
Your law firm has had years to produce these documents.
Two days ago I re-faxed to you the July 22, 2004 letter and
documents so that you will be able to clearly and precisely identify
the set of documents which you are required by law to produce.
I have received no reponse regarding the meet-and-confer letter
that I sent you two days ago. All I received was a short fax
acknowledging receipt of the Bate-stamped documents, and saying
that SASH would not respond to the meet-and-confer phone calls I
made.
When the two of you walked out of Ray Artiano’s deposition on
November 8, 2008, the same day that Daniel Shinoff refused to
appear for his own deposition, you took with you the set of
documents you had offered in lieu of the requested documents. Of
course, I will need a copy of that set just to avoid any further
confusion.
I would like to have a discovery referee in this case. Are you willing
to agree to ask the court to appoint a discovery referee?
Finally, I would like to ask if one or both of you is now willing to
appear for your deposition. Please call me if you are willing to
discuss the above matters, or if you wish to discuss any other
matter.
Respectfully,
Maura Larkins
March 26, 2008
Ray Artiano
Daniel Shinoff
Stutz, Artiano Shinoff & Holtz By fax
Re: Meet and Confer re production of documents
and appearances at deposition
Dear Ray Artiano and Daniel Shinoff:
I am writing to ask if you have found the documents that you failed
to produce as required on November 8, 2007. I trust that you’ve
had an opportunity to look for them during the past four and a half
months. Please produce them immediately if you have found them.
Once again, the requested documents consist of the documents
that Daniel Shinoff collected from employees of Chula Vista
Elementary School District in or about the fall of 2001. Mr. Shinoff
caused the documents to be Bate-stamped in his office. His office
gave copies of some or all of these documents to attorney Mark
Bresee of Parham and Rajcic in 2002. Mr. Bresee produced some,
but not all, of these documents for my OAH hearing. As I stated in
your Notices of Deposition: "The Bate stamps begin with the
number 1, not 01 or 001, and continue through 87."
In July 2004 I made a heroic effort to help your office determine
exactly which documents were requested. I faxed a letter to Kelly
Angell on July 22, 2004, and attached the documents that Mark
Bresee had produced, so that SASH could easily and precisely
identify the missing documents. My efforts were ignored by SASH.
Your law firm has had years to produce these documents. I am
attaching the July 22, 2004 letter and documents so that you will
be able to clearly and precisely identify the set of documents which
you are required by law to produce.
When the two of you walked out of Ray Artiano’s deposition on
November 8, 2008, the same day that Daniel Shinoff refused to
appear for his own deposition, you took with you the set of
documents you had offered in lieu of the requested documents. Of
course, I will need a copy of that set just to avoid any further
confusion. We don’t want to go through all of this again, with you
producing this other set of documents repeatedly in lieu of the set
formally requested, now that it has been made clear that they are
not part of the Bate-stamped set I requested.
I would like to have a discovery referee in this case. Are you
willing to agree to ask the court to appoint a discovery referee?
Finally, I would like to ask if one or both of you is now willing to
appear for your deposition. Please call me if you are willing to
discuss the above matters, or if you wish to discuss any other
matter. Also, you can fax me at that same number.
Respectfully,
Maura Larkins
Ray Artiano
Daniel Shinoff
Stutz, Artiano Shinoff & Holtz By fax
Re: Meet and Confer re production of documents
and appearances at deposition
Dear Ray Artiano and Daniel Shinoff:
I am writing to ask if you have found the documents that you failed
to produce as required on November 8, 2007. I trust that you’ve
had an opportunity to look for them during the past four and a half
months. Please produce them immediately if you have found them.
Once again, the requested documents consist of the documents
that Daniel Shinoff collected from employees of Chula Vista
Elementary School District in or about the fall of 2001. Mr. Shinoff
caused the documents to be Bate-stamped in his office. His office
gave copies of some or all of these documents to attorney Mark
Bresee of Parham and Rajcic in 2002. Mr. Bresee produced some,
but not all, of these documents for my OAH hearing. As I stated in
your Notices of Deposition: "The Bate stamps begin with the
number 1, not 01 or 001, and continue through 87."
In July 2004 I made a heroic effort to help your office determine
exactly which documents were requested. I faxed a letter to Kelly
Angell on July 22, 2004, and attached the documents that Mark
Bresee had produced, so that SASH could easily and precisely
identify the missing documents. My efforts were ignored by SASH.
Your law firm has had years to produce these documents. I am
attaching the July 22, 2004 letter and documents so that you will
be able to clearly and precisely identify the set of documents which
you are required by law to produce.
When the two of you walked out of Ray Artiano’s deposition on
November 8, 2008, the same day that Daniel Shinoff refused to
appear for his own deposition, you took with you the set of
documents you had offered in lieu of the requested documents. Of
course, I will need a copy of that set just to avoid any further
confusion. We don’t want to go through all of this again, with you
producing this other set of documents repeatedly in lieu of the set
formally requested, now that it has been made clear that they are
not part of the Bate-stamped set I requested.
I would like to have a discovery referee in this case. Are you
willing to agree to ask the court to appoint a discovery referee?
Finally, I would like to ask if one or both of you is now willing to
appear for your deposition. Please call me if you are willing to
discuss the above matters, or if you wish to discuss any other
matter. Also, you can fax me at that same number.
Respectfully,
Maura Larkins
| Stutz, Artiano, Shinoff & Holtz' response to meet and confer request |
MAURA LARKINS
Defendant pro se
STUTZ ARTIANO SHINOFF
& HOLTZ, APC,
Plaintiff,
v.
MAURA LARKINS,
and DOES 1 through 100, inclusive,
Defendants.
______________________________
Defendant Maura Larkins offers the following list of needed discovery:
A. Persons whose depositions are needed and documents to be produced:
1. Daniel Shinoff, SASH attorney in GIC 781970, refused to attend deposition, and
also refused to produce documents. I need to know if the documents I requested
have been destroyed. I need two sets of Bate-Stamped documents numbered 1-84
(One set starts with 01, the other starts with 1);
2. Robert Gallagher, former SASH attorney who left firm right after I sent evidence of
obstruction of justice;
3. Santa Barbara Sheriff’s Department, including records of CLETS searches
mentioned in Sheriff’s letter to me;
B. Also needed are depositions from the following individuals who avoided
depositions in GIC 781970:
4. Richard Werlin, former Assistant Superintendent, Chula Vista Elementary School
District;
5. Michael Carlson, Deputy, Santa Barbara Sheriff’s Department;
6. Stephenie Parker-Petitt, teacher;
7. Jim Groth, CTA director;
8. Monica Sorenson, Vice-President Chula Vista Educators;
C. Depositions which might be needed:
Tim O’Neill, former executive director Chula Vista Educators
Joyce Abrams, Chula Vista Educators director
Lowell Billings, Superintendent, Chula Vista Elementary School District
Jeffery Morris, SASH attorney
Kelly Angell Minnehan, former SASH attorney
Peggie Myers, Chula Vista Educators President.
Dated: Jan. 9, 2008
Maura Larkins, defendant in pro per
Defendant pro se
STUTZ ARTIANO SHINOFF
& HOLTZ, APC,
Plaintiff,
v.
MAURA LARKINS,
and DOES 1 through 100, inclusive,
Defendants.
______________________________
Defendant Maura Larkins offers the following list of needed discovery:
A. Persons whose depositions are needed and documents to be produced:
1. Daniel Shinoff, SASH attorney in GIC 781970, refused to attend deposition, and
also refused to produce documents. I need to know if the documents I requested
have been destroyed. I need two sets of Bate-Stamped documents numbered 1-84
(One set starts with 01, the other starts with 1);
2. Robert Gallagher, former SASH attorney who left firm right after I sent evidence of
obstruction of justice;
3. Santa Barbara Sheriff’s Department, including records of CLETS searches
mentioned in Sheriff’s letter to me;
B. Also needed are depositions from the following individuals who avoided
depositions in GIC 781970:
4. Richard Werlin, former Assistant Superintendent, Chula Vista Elementary School
District;
5. Michael Carlson, Deputy, Santa Barbara Sheriff’s Department;
6. Stephenie Parker-Petitt, teacher;
7. Jim Groth, CTA director;
8. Monica Sorenson, Vice-President Chula Vista Educators;
C. Depositions which might be needed:
Tim O’Neill, former executive director Chula Vista Educators
Joyce Abrams, Chula Vista Educators director
Lowell Billings, Superintendent, Chula Vista Elementary School District
Jeffery Morris, SASH attorney
Kelly Angell Minnehan, former SASH attorney
Peggie Myers, Chula Vista Educators President.
Dated: Jan. 9, 2008
Maura Larkins, defendant in pro per
| Why discovery is needed in Stutz v. Larkins |
) Case number: 07cv02202-WQH (WMc)
)
) Judge: Hon. William Q. Hayes
) (Hon. William McCurine, Jr.)
) Date: Jan. 9, 2008
) Time: 3:00 p.m.
)
)
) EARLY CASE EVALUATION
) DISCOVERY NEEDED
)
)
)
)
) COMPLAINT FILED: 10/05/07
) TRIAL DATE: None set
)
) Judge: Hon. William Q. Hayes
) (Hon. William McCurine, Jr.)
) Date: Jan. 9, 2008
) Time: 3:00 p.m.
)
)
) EARLY CASE EVALUATION
) DISCOVERY NEEDED
)
)
)
)
) COMPLAINT FILED: 10/05/07
) TRIAL DATE: None set
| UNITED STATES DISTRICT COURT Southern District of California |
| Why I need discovery I have an advantage over the jurors that will be deciding Stutz v. Larkins. Regarding almost every piece of evidence or testimony in the case, I know if it is genuine or fabricated because I received (or failed to receive) the documents, and I heard the evidence. I know that Stutz, Artiano, Shinoff & Holtz committed and covered-up crimes. But the jurors don't have direct knowledge. They need proof. This is the evidence I need: |
| Depositions Deposition of Ray Artiano p 1-30 Deposition of Ray Artiano p 30-40 Deposition of Ray Artiano p 40-58 Deposition of Maura Larkins Notice of Dan Shinoff Deposition |
| Subpoenas Sheriff of Santa Barbara Diane Crosier |
| Defamation Law |
| Home Why This Website SDCOE CVESD Castle Park Elem Law Enforcement CTA CVE Stutz Artiano Shinoff & Holtz Silence is Golden Schools and Violence Office Admin Hearings Larkins OAH Hearing |