| Linda Watson Deposition April 30, 2004 Page 1 Page 2 |
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| Linda Watson deposition Gina Boyd depostion Peg Myers deposition Robin Donlan Deposition Richard Werlin deposition Maura Larkins deposition |
| Who says "I don't like your attitude"? [Maura Larkins' note re page 126: I do not use the phrase, "I don't like your attitude." I believe that everyone has a right to have whatever attitude they wish. I have neither the desire nor the authority to force someone to change his or her attitude. It appears that Linda Watson is projecting her own feelings onto me, and putting her own words in my mouth.] |
P 81
14 Q. Did Mr. Werlin urge you to come to the meeting?
18 A. Yes, I think he did. He wanted me to be there if
19 at all possible.
23 Q. Did you consider even for a moment the possibility
24 that you might go to that meeting?
25 A. I probably considered it. But when I found out
p82
1 that you had a lawyer and I didn't, I didn't think that was
2 wise so I didn't go.
3 Q. Okay. So you were afraid you might be sued; is
4 that true?
5 A. I don't know what I was thinking at that point.
6 That was just a meeting I didn't want to go to.
15 A. "Well, I expressed it to Dr. Donndelinger when I
16 got back, and that's when she called Rick Werlin, and I
17 believe that was the day Gina Boyd was out of town at a
18 conference, so she wasn't available to be there, and that's
19 when we all got together in Dr. Donndelinger's office, and
20 Rick Werlin -- I guess that was what led him to put her on
21 leave again. I don't know. That was the decision that was
22 made at the district level."
[She’s all over the map. She knows she got me fired, but keeps pretending she knows nothing. Here
the truth seems to be surfacing.]
83
14 you can read the answer that starts on Line 17.
20
“I was probably talking with the other people. We were probably trying to gather
up the people involved to have a meeting."
Q. Okay. So do you recall this, that you were trying to gather up people to have
a meeting?
p84
2 Q. On April 20th, did you -- 2001, did you try to
3 gather up people to have a meeting?
4 A. I didn't try to gather anyone up. I was very
5 upset, distraught at that point. I don't know who did or
6 what happened after that. I don't know how these people were
7 asked to come to the meeting.
11 MS. ANGELL: Page 49, Line 12
13 Q. "I guess that was what led him to put her on leave again." So on this
day, whatever day it is, you talked to Donndelinger, and she called Rick Werlin,
according to your testimony, you believed that -- you believe that Gina Boyd was
out of town on a conference, and you guessed that -- I guess your expressions
are what caused Mr. Werlin to put Maura Larkins on leave again?
p 85
12 Q. Do you believe that the report you made on April 20th, 2001, was
what caused Rick Werlin to place Maura Larkins on leave again?
15 A. No. That was not my intent. I at no time said
16 anything to that effect, and that was in my previous
17 deposition.
18 Q. Okay. You didn't answer my question. Do you
19 believe that your report on April 20th, 2001 was what caused
20 Mr. Werlin to place Maura Larkins on leave again?
21 A. No. There are other people in the office that
22 were at that meeting that were expressing concerns, Kathy Bingham, for
example, went through that statement.
p87
p91
15 Q. Okay. Did you call Rick Werlin at his home at any
16 time?
17 A. No.
18 Q. Would you object to your phone records being
19 produced for February 10th, 2001?
20 A. I have no objection to that.
21 Q. Okay. What was your phone company at that time?
22 A. I have to get that information for you, because --
23 I think it was Pac Bell, but my husband pays the bills and I
24 think -- you know, company's change.
25 Q. Uh-huh. Okay.
p92
1 A. I'll get you that information.
P 93
13 Q. So on Friday, April 20th, what was it that Maura
14 Larkins wanted to talk to you about?
p 94
5 THE WITNESS: I believe that you were not
6 satisfied with the answer that you got at our grade level
7 meeting on Thursday about not doing the teaming the following
8 week, and you were -- when you approached me, your words were
9 "I have an" -- and I know you were going to say "I have an
10 idea as to how we can still team," because you were not going
11 to let that subject die. You were going to continue. And
12 that's when I cut you off and I said "I don't want to talk
13 about it unless we, you know, have a representative present."
15 Q. Okay. I understand that at that moment you were
16 fully convinced that you knew what Maura Larkins was going to
17 say. Now that you think back on it, are you 100 percent sure
18 that you know what Maura Larkins was going to say?
19 A. I knew that you had had trouble accepting a
20 decision, and if you didn't like the decision it was -- you
21 just kept coming back trying to modify it until it would suit
22 your needs or be what you wanted. And I just feel that this
23 was another attempt to continue teaming for the next week.
24 Q. So your answer is yes, you are quite certain that
25 you know what Maura Larkins was going to say?
p95
1 A. No, I'm not certain what you were going to say
2 because you only said about three words out of your mouth.
3 But I'm saying I did not want to talk to you at that point in
4 that situation, and you came right at me. You came really
5 close to me. And after what had happened two days prior to
6 that, I didn't know what to expect, and I didn't really feel
7 like talking to you in that situation.
8 Q. Okay. In another situation, though, if someone
9 came up to you and said I have an idea, you probably would
10 have heard them out?
14 A. Sure. If -- you know, if the person was talking
15 rationally and I had a relationship with that person where I
16 could communicate with them in a reasonable manner, yes, I
17 would let them finish talking to me.
18 Q. Okay. Now, at this point do you recall that Maura
19 Larkins had been back at work for about a week?
20 A. Yes.
97
2 Q. On April 20th, 2001, do you recall that
3 Ms. Larkins had been back at work for about a week?
4 A. Yes.
8 Q. Did you feel that she had a right to come back?
9 A. All of that decision making was at the district
10 level. I really didn't know why you were on leave. I didn't
11 know any details. That was all very hush hush and private,
12 and that was to respect your privacy, and we didn't -- I
13 didn't inquire.
It most certainly was not private. Linda and half the staff knew a lot more than I did about why I was
placed on administrative leave.
p98
4 Q. Could
5 we go to Exhibit 4 which is the deposition of Virginia Boyd,
6 Page 40.
p100
7 And then the questioner, which was me said, "In
8 the meeting -- what do you remember that Rick Werlin said in
9 the meeting?" And could you read Gina Boyd's answer there on
10 Line 12.
11 A. "Rick Werlin indicated that more than one person
12 had contacted me and indicated that they feared for their
13 personal safety."
p103
Linda Watson was the second caller, and equal with JoEllen in responsibility for my being taken out of
my classroom. But Jo Ellen was willing to take responsibility for her actions. Linda was suffering from
paranoia or some other problem that caused her to demand that her action be concealed by the union
and the district.
9 Q. Did you ever tell anybody that you thought Maura
10 Larkins was the type of person who became a mass murderer?
11 A. No, I never said anything like that.
12 Q. I have a two-page document which I ask to be
13 marked as Exhibit 24.
14 (Plaintiff's Exhibit No. 24 was marked for
15 identification.)
21 The part of this note that's -- I'd like to
22 bring special attention to is the note that occurs past
23 the -- below the diagonal line that I drew there. Could you
24 read the first sentence there below the diagonal line?
p104
11 A. "I talked to Maria on 2-25."
14 "Tuesday or Wednesday,
15 February 20th or 21st, Linda had been talking with Jo Ellen
16 and Denmon. Linda W. asked about me."
18 "Two maybe
19 three people on staff initiated the destruction of another
20 teacher's career." And then it shows Linda Watson -- Linda
21 W. saying something, and Linda W. -- could you read what is
22 written there that Linda W. says?
105
5 THE WITNESS: "Do you really think Maura is
6 dangerous. That's what they say about people who are mass
7 murderers."
9 Q. Okay. And since my handwriting gets pretty messy
10 here, I will do the reading from now on. Then I have Linda,
11 colon, "That's why we didn't want to team with her."
p106
4 Could you read that last four lines?
5 A. "We're scared of her. Her way of doing things is
6 so different from ours."
7 Q. Did you ever tell anyone that you believed Maura
8 Larkins' way of doing things was different from yours?
9 A. I don't remember saying that.
10 Q. Ever?
11 A. I don't remember saying that, no.
12 Q. Do you remember thinking that?
15 Q. Was that ever a thought that entered your mind,
16 that Maura Larkins did things differently from you?
17 A. No. I mean, everybody does things differently,
18 you know. Everybody does things in their own way. It
19 doesn't make sense.
20 Q. Was there anything about the way Maura Larkins did
21 things that bothered you?
24 Q. Ah, let's say before Maura Larkins sued
25 you.
p107
1 A. You have to be more specific. What time are you
2 talking about?
3 Q. Okay. When Maura Larkins came to Castle Park
4 school as the bilingual teacher, did -- was her class
5 included in the 3rd grade academic teaming?
6 A. In the beginning -- the first year? I don't
7 remember. I know you were either that first year or the
8 second year.
(It was actually the third year, as demonstrated by the summary evaluation.)
18 Q. Okay. Let's look at Exhibit 3. At the top it
19 says Chula Vista Elementary School District, Summary
20 Evaluation Report, and the name on it is Maura Larkins. The
21 job description title is 3rd grade bilingual teacher. And if
22 you look at the last of the three pages, you'll see that it
23 is dated April 28th, '00, which is 2000.
24 Okay. I would like to look at the first page, the
25 very last sentence on the page which is under "Instructional
p110
1 Techniques"? There's a box under "Instructional Techniques"
2 and a paragraph of writing. The very last sentence there,
3 could you please read that sentence.
15 Q. It says, "Maura took a leadership role with her
16 team this year to offer students an equitable and consistent
17 program."
18 Okay. So it appears that in the year -- school
19 year 1999 to 2000 there was some sort of change in the --
20 her -- Maura Larkins' team.
25 Q. Is 1999 to 2000 the school year in which you began
p111
1 to do academic teaming with Maura Larkins?
2 A. I don't remember. I don't remember the dates.
3 Q. Do you remember there ever having been a time
4 where you did not do teaming with Maura Larkins?
5 A. It's -- I remember there was one year that we
6 decided not to team with you on the elective subjects like
7 art, social studies, but we did continue to team with you on
8 P.E.
16 Q. Okay. Is it possible that the first two years
17 that the only teaming that was done was P.E.?
18 A. I don't remember.
15:28:22 Page 112
[Changes her testimony]
1 THE VIDEOGRAPHER: We're off the record. The time
2 is 3:29 p.m.
3 (Recess taken.)
4 THE VIDEOGRAPHER: We're back on the record. The
5 time is 3:39 p.m.
6 MS. ANGELL: Now that we're back on the record,
7 Ms. Watson indicated to me on the break that she needs to
8 make a correction to earlier testimony.
9 Go ahead.
10 THE WITNESS: In regards to phoning Rick Werlin
11 on -- I don't know if it was a weekend night or whatever,
12 I've thought about it, and I may have called him, but I do
13 not remember reaching him. And I don't even remember what
14 the purpose of the call was.
15 BY MS. LARKINS:
16 Q. Thank you. Do you think that might have been in
17 February 2001?
18 A. I don't remember.
19 Q. Okay. Was it about -- in reference to Maura
20 Larkins?
21 A. I don't remember. I don't remember what it was
22 about. And I was trying to figure out when it could have
23 been made, and I can't -- I can't put the dates together as
24 to when it would make sense.
25 Q. But you believe that you -- at most you only
P 113
1 called him one time ever?
2 A. Yes. I'm -- you know, I want to say I'm pretty
3 sure that if I did, and I'm not even sure I did, that it was
4 one time to his house on a weekend. But I did not reach him,
5 did not have a conversation with him at that time.
6 MS. ANGELL: Could I ask a question on that?
7 Do you remember whether or not you called or are
8 you just saying that you don't remember not calling?
9 THE WITNESS: I don't remember whether I called or
10 not. But I want to be careful how I answer that. I don't
11 remember whether I called him or not at home.
17 Q. Assuming that you did call Rick Werlin or attempt
18 to call him, it would have been a matter of significant
19 importance, would it not, about which you called him?
23 Q. Is Rick Werlin a personal friend of yours?
24 A. No.
25 Q. Is it possible that you called him up just to chat?
p114
1 A. No.
2 Q. So if you called Rick Werlin at home, it would
3 have been something related to Chula Vista School District?
4 A. Yes.
5 Q. If you called Rick Werlin at home, it would have
6 been related to some important matter?
7 A. Pardon me. Yes.
8 Q. Is it possible that you called him regarding Maura
9 Larkins?
10 A. It's possible.
[Their main witness perjured herself again and again, and had the union file a grievance to force the
district to cover up the truth about her early involvement in the case.]
11 Q. Okay. Thank you. Could I ask you to look at
12 Exhibit 20. It's these notes of Gretchen Donndelinger dated
13 4-20-01.
24 Could you read that second area of writing, those three lines.
25 A. "The truth will come out," that one?
p 115
1 Q. Uh-huh.
2 A. "The truth will come out in court. We'll all take
3 lie detector test. The truth will come out."
4 Q. Okay. Looking back on the previous page, do you
5 see that someone has written "Linda Watson" with a sort of
6 strange "L" that looks more like an "S," and then there is an
7 area of writing that continues through and including the
8 sentence you just read?
17 These notes seem to be indicating that this passage is
18 something that you said to Gretchen Donndelinger and she
19 wrote down. This does sound a lot like what you were quoting
20 regarding the incident that same morning, April 20th, 2001 at
21 Loma Verde.
p 116 15:45
3 Q. Do you believe that you said these words to
4 Gretchen Donndelinger on April 20th, 2001?
10 THE WITNESS: It's kind of hard to read.
16 A. I don't -- I can't read that. I don't know what
17 that means. 12 years?
18 Q. Perhaps known 12 years, known Maura since Rice?
19 A. Oh, okay. Then what does that say in parentheses?
20 Q. Gosh, something that -- loner maybe, loner there?
21 Would you have said something like that? I'm just guessing.
22 A. I don't know.
23 Q. Lover?
24 A. Lover there, didn't say that.
117
1 A. Is that supposed to be me?
7 THE WITNESS: I can't read half of the words on
8 this document.
10 Q. Yeah, it's pretty bad handwriting. I believe that
11 there is just one section that's quoting you, and it stops
12 right there after that line that you read.
13 A. Which one?
14 Q. The line "the truth will come out in court. We'll
15 all take lie detector test. The truth will come out"?
24 Q. Okay. Did you have a chance to read this -- the
25 bottom of the first page after the words "Linda Watson"?
p118 15:47
6 Q. Okay. Does this sound like what you reported to
7 Gretchen Donndelinger on April 20th, 2001?
8 A. Yes, it does.
9 Q. Okay. And now that you see that she apparently
10 reported that you said everybody -- "we'll all take lie
11 detector test," do you think maybe you did say that to her?
18 THE WITNESS: I may have said this to her. And
19 there again, you may have said that at the pool. I was
20 scared; I was upset. You were ranting and raving, and it was
21 hard to understand a lot of the things you were saying at the
22 pool.
24 Q. Okay. And is it possible that you were so
25 frightened at this time that you didn't remember everything
P 119
1 exactly correctly?
2 MS. ANGELL: Objection. Calls for speculation.
3 It's possible that there could be a banana boat parked out
4 front.
6 Q. Do you believe that your memory of what happened
7 on April 20th, 2001, in the locker room at Loma Verde is
8 perfect?
9 A. I went back to school -- immediately went back to
10 school, and I went to my desk and I wrote this up so that my
11 memory would be clear and I would have it documented with
12 dates. And except for that one statement that said I was
13 at -- in Loma Verde locker room, this is -- this is my
14 recollection this is what happened on April 20th, 2001.
24 Q. Okay. Okay. I'm getting the impression that you
25 are relying on your notes to know what happened during the
p 120
1 week of April 16th, 2001. Do you have -- are you relying on
2 those notes to help you remember what happened during the
3 week of April 16th, 2001?
4 A. I was so traumatized on that day, that whole week,
5 I will never forget what happened to me during that week,
6 what you put me through during that week. These notes may
7 refresh my memory a little bit, but I -- I remember this. I
8 was telling you this before I even looked at that.
9 Q. You were in a state of terror that week?
10 A. I wouldn't say I was in a state of terror that
11 week. I was very calm. I was collected. I never raised my
12 voice to you. I never acted in a irrational way. I went
13 through the whole week, and I was upset Wednesday after you
14 called me those names in front of all the children and were
15 shouting at me, which I never shouted back or called you any
16 names.
She had caused me to be placed on administrative leave by committing two crimes, and she wanted an
apology, and wouldn’t look at me when I came back. Her memory is extremely selective.
17 And then Thursday I was at school, and I -- I'd
18 had no -- no one had talked to me Thursday about what had
19 happened on Wednesday, and I was -- I even went to Maria
20 Beers and asked her if you had even known what had happened,
21 because no one had said anything about -- I expected you to
22 come and talk to me or to apologize or -- you never did. And
23 so as of Thursday, we had our meeting, and even then we were
24 meeting amicably. And it was Friday when all of this
25 happened, and the fist in the face and being out of control
P 121
1 was too much.
2 Q. You remember this fist in the face and Maura
3 Larkins being out of control occurred the day after you began
4 to believe that your life was in danger?
5 A. No. I didn't feel that my life was in danger at
6 that point, not until after the incident with the first up in
7 the air and you making irrational statements.
8 Q. What were the irrational statements?
9 A. The truth will come out in a court of law. Just
10 that kind of thing.
11 Q. The truth will come out in a court of law?
12 A. We hadn't even had a conversation. It was -- it
13 was -- you said three words to me. I said not to talk to me,
14 and you just started making no sense at all.
15 Q. Okay. Did -- did Maura Larkins say something --
16 to me that makes perfect sense, the truth will come out in a
17 court of law. That does not seem irrational at all.
23 Did Maura Larkins say anything more irrational
24 than the truth will come out in a court of law?
25 A. All I know is I was trying to get out of there as
p122
1 fast as I could. I started talking saying I thought I was
2 your friend. I said I didn't have anything to do with -- I
3 didn't know what -- I didn't know what you were upset about.
4 I didn't know why you were so -- I don't know what this truth
5 is you're talking about so it did not make sense to me. I
6 still don't know what you were saying the truth will come out
7 about. About what?
12 THE WITNESS: I was lining my kids up counting the
13 kids to make sure they were all there ready to go back to
14 school. You came up to me and you -- you said that you
15 wanted to continue the rotation group for the next week,
16 which we had already said we weren't going to do because your
17 substitute needed more time to do the -- her special testing,
18 bilingual testing. And we didn't know you were coming back
19 and so she didn't know how much time she would need, so we
20 had agreed before you came back that she would take that next
21 week to finish the testing. And then you came back and said
22 that you could do the testing much faster, but we had already
23 planned to do our Mother's Day project that we needed to get
24 started on. And normally that's not a problem when we adjust
25 our schedule around, but you could not accept that and you
Would only talk to my assistant teacher
p123
1 were -- and that's when I said let's discuss it at the grade
2 level meeting which would be the next day, Thursday. Just
3 wait one day and we'll all discuss it together, because I'm
4 only one member of the team. I don't make all the decisions.
6 Q. So you did not want to discuss this at all?
7 A. We had already discussed it, Maura. That's --
8 that was the whole point is that we had discussed it, and we
9 had come to an agreement that we would not do the test -- or
10 not do the rotation group the following week.
11 Q. Who had discussed it?
12 A. As a team with your substitute we discussed it,
13 Rick Denmon, Al Smith. We had decided that we wouldn't do
14 the teaming because the substitute said she needed more time
15 to do the testing.
16 Q. But Maura Larkins was not involved in that
17 discussion?
P 124
4 Q. Was Maura Larkins involved in this discussion that
5 you've been talking about?
6 A. I believe that we had a discussion with you upon
7 your return, but I can't -- I can't remember a specific date
8 or time. It could have been in the hallway. It could have
9 been with Gretchen and Maria Beers. I don't remember.
10 Q. Is it possible that Maura Larkins had not been
11 included in the discussion?
12 Something tells me that says "I don't recall."
13 A. I would have assumed that you were part of the
14 decision making, you know, because as you returned back you
15 were there, we were there, you know, we all talked together.
16 But we had decided before you came back and, you know, we had
17 already made plans and we had a -- we were on a time -- you
18 know, were on a time line to get these Mother's Day projects
19 done, and so that's what we had decided to do.
20 Q. And basically you simply didn't want to talk to
21 Maura Larkins that week.
24 THE WITNESS: That's not true. I welcomed you
25 back on Monday morning, and I would have talked to you on
p125
1 Tuesday but you just walked by me and didn't say anything to
2 me. Didn't greet me. And I assumed you didn't want to talk
3 to me because you were so mad about what had transpired
4 before, so there was --
She imagined she’d been slighted, and went into a fury
6 Q. And what was that that transpired before?
7 A. Well, that you were out on leave for whatever
8 reason. I didn't know if you were blaming me or whatever. I
9 didn't know why you weren't talking to me.
10 Q. Let's go back to this Wednesday. So Maura Larkins
11 came up to you and wanted to talk about teaming, and you did
12 not want to talk about teaming. You said we'll talk about it
13 at a meeting?
14 MS. ANGELL: Asked and answered. I object. This
15 repeated line of questioning, the same thing over and over is
16 argumentative and it's harassing to this witness. You've
17 asked the question. Can we move on to something that you
18 haven't asked about?
19 MR. HERSH: And I'd like to add for the record
20 that I also believe that this is a misuse of the discovery
21 process, and I'm probably going to be filing a motion for
22 sanctions based on your wasting everyone's time without --
23 I'm talking to Ms. Larkins, without having dealt with the
24 issues that you've alleged in the complaint.
p126-127
6 Q. Thank you. On Wednesday, April 18th, 2001, did
7 Maura Larkins say to you if we're going to be a team, we need
8 to talk?
9 A. I remember you coming up to me and wanting to
10 discuss the teaming for the next week, and I said let's wait
11 until tomorrow when we can discuss it on Thursday as a team
12 member, and then you said you didn't like my attitude. So I
13 don't remember you saying that other statement, no.
Q. Is the line "I don't like your attitude," is that a line that you often use with
children?
A. No, I don't -- maybe there's -- you know, maybe once -- I mean, that is --
that's a possibility, but that's not a statement I use regularly.
19 Q. Is there anybody that you know that uses that line a lot?
25 A. No, I don't know of anyone that says that.
3 Q. Have you ever heard Maura Larkins use that line other than this alleged time?
5 A. I don't remember you using that phrase before.
6 Q. Okay. And do you remember -- this is a yes or no
7 question. Do you remember Maura Larkins saying if we're
8 going to be a team, we have to talk?
10 THE WITNESS: No, I don't remember.
13 Okay. Do you remember saying if you want to talk,
14 let's talk?
15 A. I remember saying let's talk about it at the grade
16 level meeting on the next day which was Thursday.
17 Q. Do you remember leading Maura Larkins away from
18 the children over to the sandbox where the playground
19 equipment was so you'd be far away from the children in order
20 to talk?
23 Q. On Wednesday, April 18th, 2001.
24 A. I know that I was at the back of the line when you
25 approached me. Whether I moved over, I don't remember. I
p128
1 didn't think it was appropriate to have that conversation in
2 front of the children, and I don't know where we had the
3 conversation other than in that vicinity where the children
4 were lined up.
5 Q. Did you say to Maura Larkins "I've had it with
6 you. I'm through with you" in a very angry and loud tone of
7 voice?
8 A. No, I never said that. I never said anything like
9 that.
10 Q. Did you say "I welcomed you back on Monday and you
11 wouldn't even give me the time of day"?
12 A. My exact words were, after you said "I don't like
13 your attitude," I said "well, speaking of attitude -- of a
14 bad attitude," I said, "I welcomed you back Monday and you
15 never even responded to me." That's what I said.
16 Q. But now -- but later did you think that perhaps
17 Maura Larkins hadn't heard your welcome on Monday, that you
18 might have been mistaken about that?
19 A. I have no idea whether you heard it or not.
25 A. I was looking right at your face, and that's why I
p129
1 saw you look away. You looked at me, you kind of glared, and
2 then you just looked over by the fence and walked on.
3 Q. The fence.
4 A. Because this happened right in front of -- as
5 you're walking toward Loma Verde pool --
6 Q. Yes. Yes. We're clear on that. That is your
7 current memory.
8 Okay. Did Maura Larkins at that time ask you a
9 question "are you lying or are you delusional?"
10 MS. ANGELL: Vague and ambiguous as to time.
11 BY MS. LARKINS:
12 Q. On Wednesday, April 18th, 2001.
13 A. And ask me the question again, please.
14 Q. On Wednesday, April 18th, 2001, did Maura Larkins
15 ask you "are you lying or are you delusional?"
16 A. You said to me "you're a liar. You're
17 delusional." You shouted it at me.
18 Q. Okay. So this wasn't asked calmly, "are you lying
19 or are you delusional?"
20 A. No, it was not asked calmly at all.
21 Q. Okay.
22 A. It was shouting at me.
23 Q. Did the suggestion that you might be lying upset
24 you quite a bit?
25 A. The whole situation was upsetting to me, to have
p130
1 anybody raise their voice and shout accusations at me.
2 Q. I'm sure it would.
3 Okay. I'm going to try to get you to answer this
4 question. It's a yes or no question. Did the suggestion on
5 Wednesday, April 18th, 2001, that you might be lying upset
6 you?
7 A. Sure it upset me, because I wasn't lying.
p131
9 Q. All right. Some word with the same root word as
10 the word lie was used by me on that day. We are in agreement
11 with that. And I want to know if that upset you?
12 A. Yes, it upset me.
18 Q. Did the use of the word delusional upset you?
19 A. Yes, it did.
20 Q. Why did that upset you?
21 A. Because you were calling me a liar, and I guess
22 delusional means I don't know what I'm talking about when I
23 told you that I said hello to you and you were calling me a
24 liar and said I didn't know what I was talking about. And
25 that was not true, because I did.
p132
1 Q. Uh-huh. And you had not earlier said that Maura
2 Larkins was the type of person who became a mass murderer?
6 Q. You must have been very angry. Were you very
7 angry?
12 Q. Right. Were you very angry on -- when Maura
13 Larkins used the word delusional on Wednesday, April 18th,
14 2001?
15 A. I wouldn't say that I was angry. I -- well, I was
16 frustrated, because I -- I felt that we had discussed the
17 teaming thing, that we had already agreed to the time frame,
18 and that you were coming back wanting to discuss more -- you
19 know, to have the date changed so that we could do teaming
20 again. So it was more of a frustration. Is that what you're
21 after? I don't understand.
22 Q. So you were more upset about teaming than about
23 the suggestion that you might be delusional?
24 A. No. I was upset with the names that you called
25 me. I was very upset.
p133
1 Q. Okay. But you're not certain -- but you admit
2 that it's possible that you had called up Rick Werlin in
3 February and made some statement that caused Maura Larkins to
4 be taken out of her classroom?
11 Q. Do you admit that it's a possibility that you
12 called Rick Werlin in February 2001 and told him that you
13 feared for your life, that Maura Larkins was unstable -- that
14 you feared for your life and that Maura Larkins was unstable
15 and that you feared she might kill you?
20 THE WITNESS: If I called him -- when you first
21 asked me the question, I just -- no, there was no reason to
22 call him. But I'm thinking about it, and if I did call him,
23 I -- I vaguely remember the phone ringing and not reaching
24 him. But that could have been a call to his office at the
25 district level. I don't remember whether it was his home or
p 134
1 if it was a weekend or when it was, because a lot was going
2 on and this has been so long ago.
8 Q. Okay. Do you recall there being a time in the
9 year 2002 or thereabouts when you had a lockdown at your
10 school and you got under your desk and you are very
11 frightened?
p135
1 THE WITNESS: We have had many lock -- well, many
2 lockdowns, we've had more than one lockdown. I don't
3 remember which specific one you're talking about and when it
4 occurred.
6 Q. Have you gotten under your desk more than one of
7 those lockdowns?
8 A. Yes, we have.
9 Q. Okay. Do you remember one of those lockdowns in
10 which you were thinking that it might be Maura Larkins coming
11 to get you?
12 A. I think that thought crossed my mind, but it was
13 just out of the fear that I've had since our incidents.
14 Q. Okay. Do you believe that that was a rational
15 fear?
16 A. I'd -- there again, if it's irrational or
17 rational, it's still a fear, and that's the way I feel, and I
18 have reason to feel that way.
19 Q. But you do believe that you can judge Maura
20 Larkins' behavior as to whether it's rational or not?
p136
1 THE VIDEOGRAPHER: Off the record. The time now is 4:15 p.m. (Recess taken.)THE
VIDEOGRAPHER: Back on the record. The time now is 4:23 p.m.
14 (Plaintiff's Exhibit No. 22 was marked for identification--reporter's
18 transcript for the office of administrative hearings hearing in January 2003.
p137
5 This is right after February 12th,
12 And then down on Line 14 Mr. Bresee, the district's lawyer,
13 asks a question of Mr. Werlin. He says, "And after this
14 meeting with Maura Larkins and others, subsequent to the
15 phone call that you received, did you follow up conducting
16 additional inquiry or investigation at Castle Park?"
19 Mr. Werlin answered, "We had
20 numerous conversations with the principal…We also had a
23 chance to speak with Ms. Hamilton again…
25 and several other teachers had come up and talked
p 138
1 with me while I was at the site about similar concerns."
24 Q. Okay. And then on Page 60, Line 3, could you read
25 that question, please.
p139-140
1 A. "Do you recall who some of those teachers were?"
2 Q. And what is the answer there?
3 A. "Linda Watson, Rick Denmon, librarian,
4 Ms. Scharmach."
5 Q. Do you recall talking to Mr. Werlin while Maura
6 Larkins was out on leave after February 12th, 2001, and
7 before Maura Larkins came back to work?
[Even Werlin contradicts her testimony.]
24 Q. Do you recall talking to Werlin -- Richard Werlin between February 12th, 2001, and the
time Maura Larkins came back to work?
2 A. I don't recall.
(Plaintiff's Exhibit No. 14 was marked for identification.)This was entered as evidence in this OAH
hearing as the equivalent of the sworn testimony of Alan Smith without his being present.
p141
18 Q. Okay. So we're at April 16th, 2001. And could
19 you now look at Page 19 where your testimony continues and
20 could you read that next paragraph?
21 A. "So I went back to school. When I got to school,
22 Al Smith was upset because he had had a confrontation with
23 Maura that morning on the way to the swimming pool."
16 Q. Okay. Now I would like you to look at Exhibit 14?
p 143
2 A. "On the way to swimming she told me, 'We need to
3 be positive.' All I said was that the children were not
4 listening to directions very well today."
5 Q. Now that you have read this, does it in any way
6 jog your memory about talking to Al Smith on April 16th, 2001?
7 A. I -- I remember that Al was upset with you on the
8 first day that you two went swimming, because you were the
9 team that went first -- or it would be second. I don't --
10 you know, I don't remember what the exact details were.
[There are a number of indications that Plaintiff had a working environment in which her accusers
were detached from a normal manner of thinking.]
146
[Looking at Gina’s note.]
THE VIDEOGRAPHER: Going off the record. This concludes Tape 2 of the deposition of Linda Mae
Watson. We're off the record. The time is 4:40 p.m. (Recess taken.)THE VIDEOGRAPHER: This is
Tape 3 of thedeposition of Linda Mae Watson. We're back on the record. The time now is 4:44 p.m.
p150
5 MS. LARKINS: Perhaps Ms. Angell would like to say
6 something about it on the record.
7 MS. ANGELL: Well, before we conclude this
8 deposition, I have a couple of questions for Ms. Watson about
9 the issues that you discussed today.
22 Q. Do you recall ever asking anyone whether or not
23 Maura Larkins had a gun?
24 A. No, I don't remember asking -- well, can you be
25 more specific?
p 151
1 Q. Yeah. I'll rephrase. At any time prior to the
2 instigation of this litigation -- that means this lawsuit in
3 Superior Court which according to your deposition notice was
4 filed on January 24th, 2002 -- were you ever told that Maura
5 Larkins had a gun?
6 A. No.
7 Q. Did you ever tell anyone else prior to January 24,
8 2002, that Maura Larkins had a gun?
9 A. No. The only -- the only time I was concerned
10 about a gun was after I received this current lawsuit which
11 she alleged that -- with allegations in it about some kind of
12 an arrest. That's when I was concerned.
13 Q. And please be mindful that I'm not asking you
14 about anything that you may have discussed with attorneys who
15 represent you.
[The following is contradicted by Gretchen’s notes:]
16 A. That's right. I had not talked about a gun. I
17 didn't even consider a gun until this current lawsuit which
18 stated in it that there was an arrest record. And I knew
19 nothing about it. I knew nothing about an arrest record. I
20 still don't know anything about an arrest record.
21 Q. Okay. The next question is, in your discussions
22 about the April 20th, 2001 Friday incident at the Loma Verde
23 pool, there was a question about how Maura Larkins physically
24 threatened you, some discussion about that. And I wondered
25 whether or not Maura Larkins physically approached you?
p152
1 A. Yes, I feel that she physically approached me.
["I feel that she physically approached me"? What does that mean? She thinks her
psychological reaction is as important as the actual truth?]
p153
Perjury?
16 Q. Have you ever been provided information from
17 anyone not including your lawyers which was told to you came
18 from any criminal records information concerning Maura
19 Larkins?
20 A. No, none whatsoever.
6 Q. Thank you. On Wednesday, April 18th, 2001, did
7 Maura Larkins say to you if we're going to be a team, we need
8 to talk?
9 A. I remember you coming up to me and wanting to
10 discuss the teaming for the next week, and I said let's wait
11 until tomorrow when we can discuss it on Thursday as a team
12 member, and then you said you didn't like my attitude. So I
13 don't remember you saying that other statement, no.
Q. Is the line "I don't like your attitude," is that a line that you often use with
children?
A. No, I don't -- maybe there's -- you know, maybe once -- I mean, that is --
that's a possibility, but that's not a statement I use regularly.
19 Q. Is there anybody that you know that uses that line a lot?
25 A. No, I don't know of anyone that says that.
3 Q. Have you ever heard Maura Larkins use that line other than this alleged time?
5 A. I don't remember you using that phrase before.
6 Q. Okay. And do you remember -- this is a yes or no
7 question. Do you remember Maura Larkins saying if we're
8 going to be a team, we have to talk?
10 THE WITNESS: No, I don't remember.
13 Okay. Do you remember saying if you want to talk,
14 let's talk?
15 A. I remember saying let's talk about it at the grade
16 level meeting on the next day which was Thursday.
17 Q. Do you remember leading Maura Larkins away from
18 the children over to the sandbox where the playground
19 equipment was so you'd be far away from the children in order
20 to talk?
23 Q. On Wednesday, April 18th, 2001.
24 A. I know that I was at the back of the line when you
25 approached me. Whether I moved over, I don't remember. I
p128
1 didn't think it was appropriate to have that conversation in
2 front of the children, and I don't know where we had the
3 conversation other than in that vicinity where the children
4 were lined up.
5 Q. Did you say to Maura Larkins "I've had it with
6 you. I'm through with you" in a very angry and loud tone of
7 voice?
8 A. No, I never said that. I never said anything like
9 that.
10 Q. Did you say "I welcomed you back on Monday and you
11 wouldn't even give me the time of day"?
12 A. My exact words were, after you said "I don't like
13 your attitude," I said "well, speaking of attitude -- of a
14 bad attitude," I said, "I welcomed you back Monday and you
15 never even responded to me." That's what I said.
16 Q. But now -- but later did you think that perhaps
17 Maura Larkins hadn't heard your welcome on Monday, that you
18 might have been mistaken about that?
19 A. I have no idea whether you heard it or not.
25 A. I was looking right at your face, and that's why I
p129
1 saw you look away. You looked at me, you kind of glared, and
2 then you just looked over by the fence and walked on.
3 Q. The fence.
4 A. Because this happened right in front of -- as
5 you're walking toward Loma Verde pool --
6 Q. Yes. Yes. We're clear on that. That is your
7 current memory.
8 Okay. Did Maura Larkins at that time ask you a
9 question "are you lying or are you delusional?"
10 MS. ANGELL: Vague and ambiguous as to time.
11 BY MS. LARKINS:
12 Q. On Wednesday, April 18th, 2001.
13 A. And ask me the question again, please.
14 Q. On Wednesday, April 18th, 2001, did Maura Larkins
15 ask you "are you lying or are you delusional?"
16 A. You said to me "you're a liar. You're
17 delusional." You shouted it at me.
18 Q. Okay. So this wasn't asked calmly, "are you lying
19 or are you delusional?"
20 A. No, it was not asked calmly at all.
21 Q. Okay.
22 A. It was shouting at me.
23 Q. Did the suggestion that you might be lying upset
24 you quite a bit?
25 A. The whole situation was upsetting to me, to have
p130
1 anybody raise their voice and shout accusations at me.
2 Q. I'm sure it would.
3 Okay. I'm going to try to get you to answer this
4 question. It's a yes or no question. Did the suggestion on
5 Wednesday, April 18th, 2001, that you might be lying upset
6 you?
7 A. Sure it upset me, because I wasn't lying.
p131
9 Q. All right. Some word with the same root word as
10 the word lie was used by me on that day. We are in agreement
11 with that. And I want to know if that upset you?
12 A. Yes, it upset me.
18 Q. Did the use of the word delusional upset you?
19 A. Yes, it did.
20 Q. Why did that upset you?
21 A. Because you were calling me a liar, and I guess
22 delusional means I don't know what I'm talking about when I
23 told you that I said hello to you and you were calling me a
24 liar and said I didn't know what I was talking about. And
25 that was not true, because I did.
p132
1 Q. Uh-huh. And you had not earlier said that Maura
2 Larkins was the type of person who became a mass murderer?
6 Q. You must have been very angry. Were you very
7 angry?
12 Q. Right. Were you very angry on -- when Maura
13 Larkins used the word delusional on Wednesday, April 18th,
14 2001?
15 A. I wouldn't say that I was angry. I -- well, I was
16 frustrated, because I -- I felt that we had discussed the
17 teaming thing, that we had already agreed to the time frame,
18 and that you were coming back wanting to discuss more -- you
19 know, to have the date changed so that we could do teaming
20 again. So it was more of a frustration. Is that what you're
21 after? I don't understand.
22 Q. So you were more upset about teaming than about
23 the suggestion that you might be delusional?
24 A. No. I was upset with the names that you called
25 me. I was very upset.
p133
1 Q. Okay. But you're not certain -- but you admit
2 that it's possible that you had called up Rick Werlin in
3 February and made some statement that caused Maura Larkins to
4 be taken out of her classroom?
11 Q. Do you admit that it's a possibility that you
12 called Rick Werlin in February 2001 and told him that you
13 feared for your life, that Maura Larkins was unstable -- that
14 you feared for your life and that Maura Larkins was unstable
15 and that you feared she might kill you?
20 THE WITNESS: If I called him -- when you first
21 asked me the question, I just -- no, there was no reason to
22 call him. But I'm thinking about it, and if I did call him,
23 I -- I vaguely remember the phone ringing and not reaching
24 him. But that could have been a call to his office at the
25 district level. I don't remember whether it was his home or
p 134
1 if it was a weekend or when it was, because a lot was going
2 on and this has been so long ago.
8 Q. Okay. Do you recall there being a time in the
9 year 2002 or thereabouts when you had a lockdown at your
10 school and you got under your desk and you are very
11 frightened?
p135
1 THE WITNESS: We have had many lock -- well, many
2 lockdowns, we've had more than one lockdown. I don't
3 remember which specific one you're talking about and when it
4 occurred.
6 Q. Have you gotten under your desk more than one of
7 those lockdowns?
8 A. Yes, we have.
9 Q. Okay. Do you remember one of those lockdowns in
10 which you were thinking that it might be Maura Larkins coming
11 to get you?
12 A. I think that thought crossed my mind, but it was
13 just out of the fear that I've had since our incidents.
14 Q. Okay. Do you believe that that was a rational
15 fear?
16 A. I'd -- there again, if it's irrational or
17 rational, it's still a fear, and that's the way I feel, and I
18 have reason to feel that way.
19 Q. But you do believe that you can judge Maura
20 Larkins' behavior as to whether it's rational or not?
p136
1 THE VIDEOGRAPHER: Off the record. The time now is 4:15 p.m. (Recess taken.)THE
VIDEOGRAPHER: Back on the record. The time now is 4:23 p.m.
14 (Plaintiff's Exhibit No. 22 was marked for identification--reporter's
18 transcript for the office of administrative hearings hearing in January 2003.
p137
5 This is right after February 12th,
12 And then down on Line 14 Mr. Bresee, the district's lawyer,
13 asks a question of Mr. Werlin. He says, "And after this
14 meeting with Maura Larkins and others, subsequent to the
15 phone call that you received, did you follow up conducting
16 additional inquiry or investigation at Castle Park?"
19 Mr. Werlin answered, "We had
20 numerous conversations with the principal…We also had a
23 chance to speak with Ms. Hamilton again…
25 and several other teachers had come up and talked
p 138
1 with me while I was at the site about similar concerns."
24 Q. Okay. And then on Page 60, Line 3, could you read
25 that question, please.
p139-140
1 A. "Do you recall who some of those teachers were?"
2 Q. And what is the answer there?
3 A. "Linda Watson, Rick Denmon, librarian,
4 Ms. Scharmach."
5 Q. Do you recall talking to Mr. Werlin while Maura
6 Larkins was out on leave after February 12th, 2001, and
7 before Maura Larkins came back to work?
[Even Werlin contradicts her testimony.]
24 Q. Do you recall talking to Werlin -- Richard Werlin between February 12th, 2001, and the
time Maura Larkins came back to work?
2 A. I don't recall.
(Plaintiff's Exhibit No. 14 was marked for identification.)This was entered as evidence in this OAH
hearing as the equivalent of the sworn testimony of Alan Smith without his being present.
p141
18 Q. Okay. So we're at April 16th, 2001. And could
19 you now look at Page 19 where your testimony continues and
20 could you read that next paragraph?
21 A. "So I went back to school. When I got to school,
22 Al Smith was upset because he had had a confrontation with
23 Maura that morning on the way to the swimming pool."
16 Q. Okay. Now I would like you to look at Exhibit 14?
p 143
2 A. "On the way to swimming she told me, 'We need to
3 be positive.' All I said was that the children were not
4 listening to directions very well today."
5 Q. Now that you have read this, does it in any way
6 jog your memory about talking to Al Smith on April 16th, 2001?
7 A. I -- I remember that Al was upset with you on the
8 first day that you two went swimming, because you were the
9 team that went first -- or it would be second. I don't --
10 you know, I don't remember what the exact details were.
[There are a number of indications that Plaintiff had a working environment in which her accusers
were detached from a normal manner of thinking.]
146
[Looking at Gina’s note.]
THE VIDEOGRAPHER: Going off the record. This concludes Tape 2 of the deposition of Linda Mae
Watson. We're off the record. The time is 4:40 p.m. (Recess taken.)THE VIDEOGRAPHER: This is
Tape 3 of thedeposition of Linda Mae Watson. We're back on the record. The time now is 4:44 p.m.
p150
5 MS. LARKINS: Perhaps Ms. Angell would like to say
6 something about it on the record.
7 MS. ANGELL: Well, before we conclude this
8 deposition, I have a couple of questions for Ms. Watson about
9 the issues that you discussed today.
22 Q. Do you recall ever asking anyone whether or not
23 Maura Larkins had a gun?
24 A. No, I don't remember asking -- well, can you be
25 more specific?
p 151
1 Q. Yeah. I'll rephrase. At any time prior to the
2 instigation of this litigation -- that means this lawsuit in
3 Superior Court which according to your deposition notice was
4 filed on January 24th, 2002 -- were you ever told that Maura
5 Larkins had a gun?
6 A. No.
7 Q. Did you ever tell anyone else prior to January 24,
8 2002, that Maura Larkins had a gun?
9 A. No. The only -- the only time I was concerned
10 about a gun was after I received this current lawsuit which
11 she alleged that -- with allegations in it about some kind of
12 an arrest. That's when I was concerned.
13 Q. And please be mindful that I'm not asking you
14 about anything that you may have discussed with attorneys who
15 represent you.
[The following is contradicted by Gretchen’s notes:]
16 A. That's right. I had not talked about a gun. I
17 didn't even consider a gun until this current lawsuit which
18 stated in it that there was an arrest record. And I knew
19 nothing about it. I knew nothing about an arrest record. I
20 still don't know anything about an arrest record.
21 Q. Okay. The next question is, in your discussions
22 about the April 20th, 2001 Friday incident at the Loma Verde
23 pool, there was a question about how Maura Larkins physically
24 threatened you, some discussion about that. And I wondered
25 whether or not Maura Larkins physically approached you?
p152
1 A. Yes, I feel that she physically approached me.
["I feel that she physically approached me"? What does that mean? She thinks her
psychological reaction is as important as the actual truth?]
p153
Perjury?
16 Q. Have you ever been provided information from
17 anyone not including your lawyers which was told to you came
18 from any criminal records information concerning Maura
19 Larkins?
20 A. No, none whatsoever.
We're off the record. The time now is 1:19 p.m (Lunch recess taken.)
This is Tape 2 of the deposition of Linda Mae Watson. We're back on
the record. The time now is 2:32 p.m.
7 Q. I would like to go to the summer of 2001 when Rick
8 Werlin called you and asked if you would come to the district
9 to meet with Maura Larkins. Did you -- what did you tell him
10 when he asked you to come?
11 A. When he asked me to come, it was -- I thought it
12 was just an informal forum. We were just going to talk face
13 to face with you and talk about issues or whatever, and
14 that's all I remember it being. And I declined to go because
15 I -- I did not feel that I was represented by an attorney at
16 that time, and I knew that you did have an attorney. That
17 was one of the questions I asked him, does Maura Larkins have
18 an attorney, and he said yes. And I said well, I don't have
19 an attorney, so I declined to go.
20 Q. Did you tell Mr. Werlin that you were emotionally
21 distraught?
22 A. When?
23 Q. At the time that you declined to go to the
24 summer meeting.
25 A. I don't remember being emotionally distraught.
P 79
4 Q. Did you tell him you were emotionally distraught?
5 A. I don't remember.
6 Q. Did you tell him that you were healing?
7 A. I don't remember what I said to him other than
8 what I just told you.
9 Q. Okay. I would like to go to Exhibits 10-A and
10 10-B. Actually, I'd like to go to 10-B. On Page 81
p 80
4 What I meant to say is that it's the reporter's
5 transcript of the hearing on the day of January 6th, 2003.
6 Thank you for setting that straight.
7 Okay. Could we look at Page 81.
10 MS. LARKINS: Okay. Tell you what, I will
11 withdraw this Exhibit 10-B, but I will let you keep it. And
12 I just thought it might be interesting to you to see what
13 Mr. Werlin said about teachers not wanting to come to this
14 meeting.
This is Tape 2 of the deposition of Linda Mae Watson. We're back on
the record. The time now is 2:32 p.m.
7 Q. I would like to go to the summer of 2001 when Rick
8 Werlin called you and asked if you would come to the district
9 to meet with Maura Larkins. Did you -- what did you tell him
10 when he asked you to come?
11 A. When he asked me to come, it was -- I thought it
12 was just an informal forum. We were just going to talk face
13 to face with you and talk about issues or whatever, and
14 that's all I remember it being. And I declined to go because
15 I -- I did not feel that I was represented by an attorney at
16 that time, and I knew that you did have an attorney. That
17 was one of the questions I asked him, does Maura Larkins have
18 an attorney, and he said yes. And I said well, I don't have
19 an attorney, so I declined to go.
20 Q. Did you tell Mr. Werlin that you were emotionally
21 distraught?
22 A. When?
23 Q. At the time that you declined to go to the
24 summer meeting.
25 A. I don't remember being emotionally distraught.
P 79
4 Q. Did you tell him you were emotionally distraught?
5 A. I don't remember.
6 Q. Did you tell him that you were healing?
7 A. I don't remember what I said to him other than
8 what I just told you.
9 Q. Okay. I would like to go to Exhibits 10-A and
10 10-B. Actually, I'd like to go to 10-B. On Page 81
p 80
4 What I meant to say is that it's the reporter's
5 transcript of the hearing on the day of January 6th, 2003.
6 Thank you for setting that straight.
7 Okay. Could we look at Page 81.
10 MS. LARKINS: Okay. Tell you what, I will
11 withdraw this Exhibit 10-B, but I will let you keep it. And
12 I just thought it might be interesting to you to see what
13 Mr. Werlin said about teachers not wanting to come to this
14 meeting.