| San Diego Education Report |
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Page 89 Q. Do you approve of a teacher being taken out of her
classroom on the basis of anonymous, vague allegation?
Line 15 A. No.
[Maura Larkins note: [Gina Boyd told me on February 11, 2001
that Werlin had no choice but to place me on leave. She did
approve the action.]
Q. Why did you not immediately file a grievance when this
happened?
A. There was no negative impact.
Page 90
[Maura Larkins note: Gretchen Donndelinger’s notes show no instances of Gina Boyd
objecting. The notes also show that the meeting was not brief. Maura Larkins'
testimony show that the meeting was considerably longer than Donndelinger's notes
indicate. Gretchen’s notes were several pages, and Gina’s notes were "lost" or
"accidentally destroyed".]
Q. It’s your testimony that you expressed at the meeting that you were concerned
about anonymous complaints?
Line 25
A. Yes, I did.
Page 91
Line 1
Q. But you took notes at that meeting, didn’t you?
A. I believe I did.
Q. And we don’t have the notes, do we? You haven’t produced the notes?
A. No.
What happened to those notes?
I don’t know.
At that meeting, you knew it was an important case, didn’t you?
Yes.
You didn’t take good care of those notes?
A. I don’t know where the notes are, Maura.
Q. Did you make a special effort to take care of those notes?
A. Apparently not.
Q.Did you think those notes were important?
A. The information contained would have been very brief, that you were placed on
administrative transfer due to two complaints from people and that—you
know, there was very little content to that meeting other than that you were placed
on administrative leave and that there would be an investigation.
Q. There was little content to that meeting? How long did the meeting last?
A. Not very long.
Page 92
[Maura Larkins note: Kelly Angell is not under oath when she made the following
statements. Of course, that fact might not make any difference. Angell and Hersh
were bullying Maura Larkins, who was alone and opposed by three people, including
Jackie Robinson, Law Clerk]
Kelly Angell [Minnehan] ...Plaintiff’s behavior of making facial gestures, laughing,
sighing is directed at the witness as a method of intimidating and being
aggressive and argumentative and coercing the witness.
Page 93
MR. HERSH: No, I’m kidding.
MS. LARKINS: You’re a funny guy.
Okay, I gasped. I gasped and I had
In your notes it said they feared for their lives. So I know you did still have your
notes. It was about a month later in March when the question was whether it was
one or two people who had called.
DESTROYED NOTES CONTD.
Your objection was false, saying that I was laughing and intimidating. You’re the
one that forced me to explain what was really going on here.
page 94
9 minute break
10:51:18
Page 105
CTA is in control, and pretends actions are made only by local affiliate
Line 6 I asked to address the representative council in December of 2002
Line 23 Q. Who made the decision that I would not be allowed to appear?
A. Tim O’Neill and I.
Page 106
Q. So who exactly determined that I would not be allowed to appear?
Line 17
A. Tim and I.
Page 108
Line 16 …I am very happy that we have an audiotape being made at the same time,
because I believe that Ms. Angell is trying to create a deceptive written record.
Line 23 Were you worried that your reputation would be harmed if I addressed
the Representative Council?
A. No.
Page 109
11 Did you believe that it would be morally wrong if I were to address the
Representative Council?
[Gina Boyd’s code of ethics.]
I’m trying to figure out what was your reason for denying my request.
Page 110
Line 6 I just want to know why Gina Boyd denied my request to address the
Representative Council.
MS ANGELL: Let the record reflect that plaintiff is gesticulating with her hands,
emphasizing her question and speech in a manner that appears to be
argumentative.
MR. HERSH: And snickering.
MS. ANGELL: And covering her mouth when she laughs.
MS. LARKINS: Let the record show that Ms. Angell has an extremely sour
expression on her face. She looks like she’s been chewing on lemons, and she’s
rocking in her chair.
MS. ANGELL: Let the record reflect that plaintiff is staring down defense counsel
during that—however long that intermittent time period was in a manner similar to
what was done in court when the court directed her, plaintiff that is, to refrain from
that type of behavior.
[Miss Angell is referring to a time when I was crying, and judge told me to look at
him to help me stop crying.]
MS. LARKINS: Ms. Angell, you could not possibly have known how long I was
looking at you unless you were looking at me for the same length of time.
Page 111
Line 7 Q. Okay. I understood that you felt that you were not obliged to let me
address the Representative Council. That’s what this states. What I want to know
is why didn’t you let me do it anyway?
A. Because the items that before—come before the council need to be
legitimately placed there, and this was not.
Q. So you have the—so according to the bylaws of CVE the
president can forbid anyone to come and complain about her?
Line 24 Q. Did you have the right to deny my request?
A. Yes.
Page 112
Line 1 Q. Did you do it to protect yourself?
A. No.
Line 3
Q. Do you have the right to deny a teacher the ability to make
a complaint against you?
Line 13. A. I don’t know.
Line 16 Q. Do you have the right to deny a teacher the ability to
make an oral complaint about you to the Representative Council?
A. I don’t know. I don’t think it’s in our bylaws anywhere, but—
Q. But you did deny me that right; is that correct?
A. I don’t think that you had the right according to the bylaws to
make that particular complaint.
Page 113
Line 11 A. Yes, I’ve read it.
Line 19 MS. LARKINS: Well, as it happens Exhibit 6 is an editorial published in the
Union Tribune titled “Silence is Not Golden in Chula Vista Elementary School
District.”
MR. HERSH: Dated September 2nd, 2004?
Page 114
Line 16 A. “This is the most egregious and disrespectful affront to district
personnel I have ever seen, and I have been involved with this district for over 25
years, said Boyd of the teachers’ organization, which has filed a grievance.”
115
Line 9
Q. Who did you speak to when you made this statement?
A. I think his name is Don. I’m not—
Q. Okay. This most egregious and disrespectful affront to district personnel
that you spoke of here, can you tell us what it was? What was the affront?
That they were administratively transferred without cause.
Was the contract violated in this case?
Yes.
The transfer article.
116
Line 4 I’m going to instruct the witness not to answer a question concerning a
matter that is in litigation
MS. LARKINS: This case has made strange bedfellows, has it not?
117
Line 18 Q. Okay. Were five teachers transferred out of Castle Park Elementary
School recently?
MS. ANGELL: Objection. The witness has previously been instructed by her
counsel not to respond to questions concerning a matter that’s pend—currently in
litigation, specifically the transfer of teachers at Castle Park Elementary School in
or about September of 2004?
119
Q. Did you read the part of the article where Felicia Starr and Kim Simmons made
statements to the Star-News?
A. Yes.
120
Line 9
Q. Okay. What is your relationship with Felicia Starr?
A. I know her as a parent of children who attend Castle Park School.
Q. How did you come to know her?
A. She’s also assisting with a campaign for one of the board of education
candidates.
Q. And you are also working on that campaign?
A. Yes.
Q. Okay. And how—what is your relationship with Kim Simmons?
A. I know that she’s a parent of children at Castle Park School.
Q. How did you come to know her?
A. Just by being at the school I’ve been introduced to her.
Q. How long have you known her?
121
A. I’ve known her by name probably since September.
Q. Just last month?
A. Yeah.
Line 9
Q. I’m sorry. How many times have you talked to Kim Simmons?
A. Maybe two or three.
Q. What is your--do you consider her a friend?
A. I have a congenial relationship with her.
Q. Okay. Did you caress her hand at the last Chula Vista Elementary School
District School District board meeting when she put her hand on your shoulder?
A. I don’t know.
Q. Okay. Did Felicia Starr sit with you at the last board meeting?
A. Yes.
122
Line 8 MR. HERSH: Just for the record, just as I did last time, I’ve already told you,
you know, we’re leaving after lunch because you’re not asking questions that are
within the scope of discovery. You’ve got another half hour.
Line 20 What is your current relationship with Robin Donlan?
A. She’s one of my unit members and she’s a friend.
Page 123
Line 18 MS. LARKINS: Yeah. Is this a fair article about Ollie Matos?
THE WITNESS: Yes.
[THE FOLLOWING IS A SIMPLE QUESTION ABOUT LOGICAL THINKING RELATED TO
THE VALIDITY OF A POLL]
Page 124
Line 2 Q. When—it has a poll here that says 17 teachers answered a poll, but it
doesn’t tell the total number of teachers. Do you think that the whole—that the
total number of teachers should have been told?
A. I don’t have any opinion about that in either direction.
Q. It’s sort of a math question. I mean, wouldn’t—if 17 is half the number of
teachers, the poll isn’t worth much. If 17 is the total number of teachers, then the
poll is pretty—has a lot more value, and they don’t tell.
MS. ANGELL: Objection.
125
Q. Did you think that this article was unfair to the ELAC parents, accusing them of
trying to take over power at Castle Park?...
A. No.
Q. But no ELAC parents were interviewed or quoted in the article, were they?
A. I don’t know. I don’t know.
Q. But it would matter, wouldn’t it? If they weren’t, it would be unfair?
A. Apparently Kelley Dupuis thought it was fair, and really don’t have any opinion
about it.
Q. Okay. Did you think that my being taken out of my classroom on February 12th,
2001 was fair?
A. No, I don’t.
Q. Did you think my being taken out of my classroom on April 20, 2001 was fair?
A. Is that the pencil incident?
126-127
Line 7
Q. Do you believe that Richard Werlin lied when he described what you have
just referred to as I think the—what did you say? …The pencils incident?
A. The pencils incident.
Q. Okay. Do you believe that Mr. Werlin lied when he described the pencils
incident?
…THE WITNESS: No.
He said you were very angry and upset and that he was trying to calm you down
and that you threw a pencil at the ground near him.
And that then you walked away. I can remember what you said, but I believe that
that was Mr. Werlin’s depiction of the event.
Did he say he tried to welcome me back and then I exploded for no apparent
reason?
A. Yes, he did.
[she contradicts self—she also said I was upset because my job was in jeopardy]
Line 10 Okay. Thank you. Did CVE file a grievance about the pencils incident?
A. No.
Q. Did Mr. Werlin say that I behaved in an irrational and unprofessional manner
during the pencils incident?
A. Yes.
128
Exhibit 8 Werlin April 4, 2001 letter
130
Ms. Boyd, to your knowledge, was this grievance ever filed?
A. It doesn’t look to me like it was because it’s not signed or dated.
Q. Is it your understanding that CVE filed a grievance on my behalf?
A. About—about this incident?
Q. About anything. Did CVE ever file a grievance on my behalf?
MR. HERSH: If you remember.
THE WITNESS: I don’t remember.
132
Line 23 Were you concerned that I behaved like a person who might be seriously
mentally ill?
133
I thought that you were duly upset considering what you were going through.
Q. So you think it’s normal behavior for someone to run away and come back and
run away and come back?
A. I don’t know whether that’s what you did. That was his description.
Q. So you don’t necessarily believe that that was true, his—his allegation was
true?
A. I think his perceptions might not be the same as others.
Q. Perceptions are one thing but the truth is something else. Do you think that I
ran away and came back and ran away and came back?
A. I don’t know.
MIDDLE PACKET
151
Line 12 Q. Can you tell us, Ms. Boyd, what difference you notice between the
purported grievance that we looked at earlier and the purported grievance that
we’re looking at now?
Page 178
Why is there no signature on this grievance?
This is a copy. The one given to Werlin was signed by Jim Groth.
(Gina was lying, but she wasn’t under oath when she wrote this.)
179
Line 1
Somewhere around May 30th, 2001, you believed—did you believe that Jim Groth
had signed a grievance on my behalf and filed it with the district?
A. Yes.
Q. Okay. Do you have any reason to think that a grievance meeting was held
regarding this grievance?
A. I don’t know whether there—whether one was.
Q. It’s—it’s a mystery. Okay.
181
Line 4 MS. LARKINS: As I’ve said before, all my evidence
…comes from events at Chula Vista Elementary School District and the
preposterous behavior of Gina Boyd and others including the lawyers involved in
this case which points to an effort to cover up the truth. And that’s why I need to
ask questions about why people were investigating themselves …
25 MS. LARKINS: Haven’t they already been asked and answered?
Page 183
The last time you were here you stayed for an hour and a half, not a few hours.
This deposition was originally scheduled in 2002.
Page 184
Ms. Boyd, why didn’t you come forward voluntarily in 2002 to testify when I—to
help me with my administrative hearing and my lawsuit?
MS. ANGELL: Objection. Seeks to invade attorney-client privilege. Seeks to
invade attorney work product. Calls for speculation. Calls for facts not in
evidence.
But I’m wondering why you didn’t voluntarily come forward and testify on my
behalf?
Page 185
Did you say that she would not testify in a deposition by me regarding anything to
do with CVE or her representation of me?
214
13 Do you believe this grievance should have been arbitrated?
No.
Page 215
Memorandum of understanding
217
19 I have none of those records.
So you think you possibly could have responded to this letter and then lost your
copy?
I presented all of my copies of all documentation to CTA legal.
218
I don’t recall.
220
("I don't recall is repeated, but together I've counted them as one "don’t recall.")
lines 1-4
221
That machine is in my office.
So you are the only one that has access to it?
222-223
Yes.
Did you talk to your friend Robin about my case in March of 2001. No, I don’t
believe so. No.
[She remembers that!!!]
[Robin not fear for life]
Page 226
Line 15 Q. Do you keep any record of calls you make?
A. Yes.
But you’ve lost all your records regarding…
get back to them. It’s my phone log.
227
When you received faxes from me where did you put them?
A. Probably in a file.
228
8. A. No, I don’t remember this.
13. Okay. I’m just going to look through here and see if I can find something that’s
so visually compelling that you’d really remember it.
I know I tried to make things visually compelling so you would look at them.
MR. HERSH: I didn’t know there was a rational reason for your interest in faxes.
MS. LARKINS
MR. HERSH I didn’t assume irrationality. I just assumed a lack of rationality.
229 Ring a bell?
No.
232
14 Q. Does this seem familiar to you?
15 A. No.
18 Ms. Boyd, can you explain how there can be so many letters
written to you and so few responses from you?
A. No.
22. Okay. Do you remember seeing this one?
A. No.
234
236
2 Does this letter strike you as familiar?
No.
4. Did you become angry at me during 2001?
15. What if they were working hard to uncover a crime you had committed?
Q. I believe we had Jim Groth representing you.
A. No.
237
Have you ever had someone from outside of CVE represent a CVE member?
No.
As my lawyer, you must reveal that
238
to me. Then you should call CTA and tell them you do not wish…
Such as your ties with my accusers, and ties with the board of directors which you
apparently hope to exploit on Monday.”
239
4-25-01 As your lawyer, I’m telling you it is very important for you to come to this
meeting today d
240
When you received this did you call CTA and tell them that you did not wish to
represent me and that I need a representative from outside the district?
No.
Why not?
Because I didn’t believe that was true.
241
Do you remember this?
Not specifically.
(This doesn’t count as a not remember, because I asked her the same question on
next page)
242
It attracted your attention, didn’t it?
Just now?
Just now.
Yes.
But you don’t recall having received it when—at the time?
| Lawsuit Against CTA Head Counsel Beverly Tucker |
| CTA Lawyers Ann Smith Fern Steiner Bernhard Rohrbacher |
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| Chula Vista Educators (CVE) |
Home
Why This Website
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Silence is Golden
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Why This Website
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CVE
Stutz Artiano Shinoff
Silence is Golden
Schools and Violence
Office Admin Hearings
Larkins OAH Hearing
Deposition of Gina Boyd
President of Chula Vista Educators and former teacher at Castle Park Elementary
School; Testimony below given in November 2004 while being deposed by Maura
Larkins (who was also a teacher at Castle Park Elementary). One wonders: is this
union leader completely incompetent--or is she committing perjury?
President of Chula Vista Educators and former teacher at Castle Park Elementary
School; Testimony below given in November 2004 while being deposed by Maura
Larkins (who was also a teacher at Castle Park Elementary). One wonders: is this
union leader completely incompetent--or is she committing perjury?
Gina Boyd,
Winner of
the Alberto
Gonzalez
CRS award for Oct. 11,
2004 testimony:
Winner of
the Alberto
Gonzalez
CRS award for Oct. 11,
2004 testimony:
June 16, 2008
Maura Larkins
Deposition
Maura Larkins
Deposition
during Gina Boyd's 6 hour
deposition she said
"I don't know" 25 times;
"I don't remember (or
recall, etc.) 35 times;
total cognitive lapses: 60
deposition she said
"I don't know" 25 times;
"I don't remember (or
recall, etc.) 35 times;
total cognitive lapses: 60
Nov. 8, 2007
Atty. Ray Artiano
Deposition
Atty. Ray Artiano
Deposition
From the deposition:
[Page 79 10:17:36] Q: Were you curious as to what my
behavior might have been that caused them to fear for their
lives?
A: Gina Boyd: [long pause] I guess...I don't know...
[10:18:20] Q. You weren't drivingly curious as to why
teachers were concerned that another teacher might kill
them?
[Stutz law firm Atty. Kelly Angell:]
Objection. Asked and answered.
[Angell was not Boyd's attorney, she was the school district's
attorney, but she prevented Boyd from answering
this question. The school district didn't like this question
because the district was not curious, either; the district did not
investigate the report of two teachers that Maura Larkins might kill
them, nor did it investigate this report that came three weeks
earlier.]
[Maura Larkins] 10:19...Were you curious about it--the
results of his investigation?
[Gina Boyd] I don't know whether he ever completed it,
frankly.
Q. Did you ask him?
A. No.
10:19:28 Q. Were you concerned about the safety of teachers
at Castle Park?
A. I'm concerned about the safety of all my teachers...
[Page 79 10:17:36] Q: Were you curious as to what my
behavior might have been that caused them to fear for their
lives?
A: Gina Boyd: [long pause] I guess...I don't know...
[10:18:20] Q. You weren't drivingly curious as to why
teachers were concerned that another teacher might kill
them?
[Stutz law firm Atty. Kelly Angell:]
Objection. Asked and answered.
[Angell was not Boyd's attorney, she was the school district's
attorney, but she prevented Boyd from answering
this question. The school district didn't like this question
because the district was not curious, either; the district did not
investigate the report of two teachers that Maura Larkins might kill
them, nor did it investigate this report that came three weeks
earlier.]
[Maura Larkins] 10:19...Were you curious about it--the
results of his investigation?
[Gina Boyd] I don't know whether he ever completed it,
frankly.
Q. Did you ask him?
A. No.
10:19:28 Q. Were you concerned about the safety of teachers
at Castle Park?
A. I'm concerned about the safety of all my teachers...
10:20:06
Did any teacher ever tell you that he or she feared that I might
kill him or her?
No.
[Page 81, line 19]
...Did you believe that I had behaved in a manner that threatened
the lives of others?
No.
Did you think these two people had lied?
No.
[Page 84, line 12, 10:23]
If there is any explanation for your behavior other than the
explanation I have given in my complaint, I want to know about it.
I don't want to be surprised in court.
Did any teacher ever tell you that he or she feared that I might
kill him or her?
No.
[Page 81, line 19]
...Did you believe that I had behaved in a manner that threatened
the lives of others?
No.
Did you think these two people had lied?
No.
[Page 84, line 12, 10:23]
If there is any explanation for your behavior other than the
explanation I have given in my complaint, I want to know about it.
I don't want to be surprised in court.
lasted 6 hours
Deposition lasted 2
hours, then Mr.
Artiano walked out
hours, then Mr.
Artiano walked out
Gina Boyd forbids member to make ethics
complaint--about Gina Boyd
complaint--about Gina Boyd
2004
Robin Donlan
Deposition
Robin Donlan
Deposition
2004
Linda Watson
Deposition
Linda Watson
Deposition
Related depositions:
next page is under construction
Page 87
Q. Why did you not object during that meeting?
A. Because he said that—that other people felt that they
were in danger, because he sent you home with pay and so
there was no discipline—disciplinary action taken.
Q. Did he ask for a fitness for duty letter from a doctor?
THE WITNESS: I don’t remember.
Line 12 Q. [W]e did discuss that last time, and we had it pretty
well established that he did.
Page 88 Q. The allegations were anonymous?
A. Yes.
Q. And did he say any specifics of what I was accused of
having done?
A. No. I don’t think he told us what they said to him. He just
expressed that they were fearful.
Q. Why did you not object during that meeting?
A. Because he said that—that other people felt that they
were in danger, because he sent you home with pay and so
there was no discipline—disciplinary action taken.
Q. Did he ask for a fitness for duty letter from a doctor?
THE WITNESS: I don’t remember.
Line 12 Q. [W]e did discuss that last time, and we had it pretty
well established that he did.
Page 88 Q. The allegations were anonymous?
A. Yes.
Q. And did he say any specifics of what I was accused of
having done?
A. No. I don’t think he told us what they said to him. He just
expressed that they were fearful.
"No negative impact"
when a teacher is sent home in the
middle of the year without an
explanation?
How about the impact on her
students, Ms. Boyd? They were
given a substitute who had not
even started her student teaching.
Hypocrisy alert: Gina
Boyd and Peg Myers led a huge
protest three and a half years later
when several of Maura Larkins'
accusers were transferred to
other schools before the new
school year started. Boyd
complained to the media and filed
a complaint with PERB, claiming
that the district had violated the
contract by not explaining in detail
why the teachers were
transferred. It was inadequate, the
union claimed, for the
superintendent to have simply told
teachers they were being
transferred to enhance the
educational program.
when a teacher is sent home in the
middle of the year without an
explanation?
How about the impact on her
students, Ms. Boyd? They were
given a substitute who had not
even started her student teaching.
Hypocrisy alert: Gina
Boyd and Peg Myers led a huge
protest three and a half years later
when several of Maura Larkins'
accusers were transferred to
other schools before the new
school year started. Boyd
complained to the media and filed
a complaint with PERB, claiming
that the district had violated the
contract by not explaining in detail
why the teachers were
transferred. It was inadequate, the
union claimed, for the
superintendent to have simply told
teachers they were being
transferred to enhance the
educational program.
> > >
| San Diego Education Report |
| SDER |
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Education Report
Education Report
| SDER |
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| SDER |
| News, information and ideas about our education system by Maura Larkins |
Clueless students call white-robed
priest a Klansman while he tries to get
frozen yogurt
Greg Piper
April 6, 2016
...A Dominican friar on a prayer walk around Indiana
University-Bloomington Monday night was mistaken for
an armed member of the Ku Klux Klan, sparking a social-
media freakout and leading students to confront the
poor guy while he was trying to order frozen yogurt...
A resident adviser emailed his residents to warn about
the reports of the KKK on campus, saying campus
police couldn’t do anything about it because of the
Klansman’s “first ammendment [sic] rights,” and advising
them to just stay inside for the night or contact him if
they feel “unsafe.”
The Tab said:
While the KKK has been active in the area in the past,
it later became apparent this klansman armed with
a whip was actually just a monk of the Dominican
order in traditional white robes. The “whip” he
was holding may have been his rosary beads.
After a picture of the supposed violent racist at Red
Mango got sent around, RA Ethan Gill posted a
clarification to Facebook (not public) halfheartedly
apologizing for his own naivete and negligence but
calling the viral reports “a hilarious miscommunication.”
Yeah, rising up with digital pitchforks against a guy
praying for your clueless souls is a riot...
priest a Klansman while he tries to get
frozen yogurt
Greg Piper
April 6, 2016
...A Dominican friar on a prayer walk around Indiana
University-Bloomington Monday night was mistaken for
an armed member of the Ku Klux Klan, sparking a social-
media freakout and leading students to confront the
poor guy while he was trying to order frozen yogurt...
A resident adviser emailed his residents to warn about
the reports of the KKK on campus, saying campus
police couldn’t do anything about it because of the
Klansman’s “first ammendment [sic] rights,” and advising
them to just stay inside for the night or contact him if
they feel “unsafe.”
The Tab said:
While the KKK has been active in the area in the past,
it later became apparent this klansman armed with
a whip was actually just a monk of the Dominican
order in traditional white robes. The “whip” he
was holding may have been his rosary beads.
After a picture of the supposed violent racist at Red
Mango got sent around, RA Ethan Gill posted a
clarification to Facebook (not public) halfheartedly
apologizing for his own naivete and negligence but
calling the viral reports “a hilarious miscommunication.”
Yeah, rising up with digital pitchforks against a guy
praying for your clueless souls is a riot...
In Chula Vista Elementary School District, it's part
of the political game for adult teachers to engage
in hysterical antics.
of the political game for adult teachers to engage
in hysterical antics.
This behavior is somewhat more understandable in
younger people. In the following case, the students
made a mistake out of ignorance. In CVESD, hysteria
was used as a political tool.
younger people. In the following case, the students
made a mistake out of ignorance. In CVESD, hysteria
was used as a political tool.
