Linda Watson Deposition April 30, 2004
|Who says Kelly Angell
Minnehan doesn't have
a sense of humor?
A helpful suggestion
BY KELLY ANGELL
If you have any
questions that you can
propound in the form of
maybe that would be a
more economical use of
time and get you the
answers that you're
looking for. That might
be more productive.
Ms. Angell, I remember I
gave you 20 special
interrogatories, and I got
20 objections back. So I
don't think I will be taking
5 Q. Was Gina Boyd at your deposition when it was taken
7 A. No. I don't think she was. I don't remember.
10 I don't recall. I thought I was all by myself at the Ed
Center when we had the deposition.
12 Oh, you know what, now I do remember. She was
17 Q. Okay. Did you ask Gina Boyd to attend the
19 A. I don't remember.
20 Q. Were you glad she was there?
21 A. Yes. I -- I like to be represented by the union.
22 Q. So she was there representing you?
23 A. I guess so, yes. Yes.
24 Q. How nice for you.
25 A. And she was protecting my rights as a union member.
5 Q. Did you discuss what you were going to say with Gina
Boyd before your deposition?
7 A. No. I don't remember talking to Gina Boyd about it. I
talked to my lawyers.
Q. Were you afraid that something that
could come out of that deposition might
cause you to lose your job or be
disciplined by the school district?
[Why would Linda Watson need representation
from the teachers union? She was being
represented by the school district lawyer,
Mark Bresee--and she wasn’t the one being
dismissed. Why wasn’t Chula Vista Educators
representing Maura Larkins, or at least maintaining
a neutral stance? Why did Gina Boyd feel she
needed to be there to protect Linda Watson?
24 Q. I am giving you a copy of the transcript
of the deposition which you gave for my dismissal
hearing. I ask that this exhibit be marked as Exhibit 2.
Q. Do you recall signing your deposition, a copy was given to you, and
you were allowed to look over it and check for errors?
A. I don't remember. I don't remember if I did or not.
MS. ANGELL: I would suggest that the witness needs the opportunity to
review the 80 pages, 81 pages of this transcript in order to be able to
answer questions about it.
[Linda and Kelly took 56 minutes to read the 22 pages I wanted to
discuss out of a total of 76 pages of Linda Watson’s own testimony in
this case. That’s two and a half minutes per page. She ended someone’
s career, and she’s not sure what she said? It wasn’t important enough
to remember? Or was she making up stories when she gave her
testimony, and forgot the details?]
The time now is 10:31 a.m. Recess taken.
Back on the record. The time now is 11:27 a.m.
2 Now -- now that you've had a chance to read it for the last
hour, are you pretty confident that that is your testimony?
14 THE WITNESS: Yes.
15 MS. ANGELL: Do you understand what question was just
asked of you?
17 THE WITNESS: Yes.
2 Q. Are you concerned that this document may have been
altered and that is actually not what you said?
4 A. I don't remember some of this. I don't know if it has or hasn't.
[Ms. Angell and Ms. Watson seem to want to escape from Ms. Watson's
6 Q. Okay. Let's try to find out what you do remember.
16 A. I remember you were hired as our bilingual teacher.
17 Q. Yes. Had -- how long had the school had a bilingual
3 A. What do you mean by a bilingual program?
4 Q. Okay. When a teacher who is called a bilingual
5 teacher, officially a bilingual teacher, is teaching a
6 classroom that's officially called a bilingual class, I'll go
7 ahead and call that a bilingual program even if it's just one
9 Do you remember a time when a bilingual program
10 began at Castle Park?
11 A. There was a bilingual program started for grades K
12 through 3, as I remember, when Oscar Perez was principal.
13 That's when he started it.
23 Q. Do you remember the planning discussions when the
24 staff was discussing whether or not to have a bilingual
25 program come to Castle Park school?
1 A. There was discussions about it during staff
3 Q. What do you remember about those discussions?
4 A. I remember there were pro and cons. There were
5 people that, you know, said we needed this program, there
6 were people that felt that we didn't need it, and obviously
7 we decided that we needed it because we had so many, you
8 know, bilingual children that needed that help.
9 Q. Okay. Were there some people that were quite
10 hostile to the idea of having a bilingual program?
11 A. I don't remember anybody being quite hostile. I
12 don't know what quite hostile means. What does that mean?
13 Q. Raising voices, repeating again and again
14 negative --
15 A. I don't remember that. I don't remember that.
16 Q. Okay. Do you remember any of the bilingual
17 teachers who came to Castle Park school besides Maura
19 A. I remember Maria Beers and Rick Ramirez and -- I
20 can't remember the other one's name. Let's see. Those are
21 the only ones I remember right now. I'll think about it.
13 Q. Now, do you remember someone named Michelle
15 A. I remember her, but I didn't work with her.
16 Q. But she was a bilingual teacher at Castle Park?
17 A. Okay. You know what, you know, I really don't
18 remember what she did. I didn't know if she was a teacher or
19 an aide. I don't remember. I did not work with her
Tellez was a bilingual teacher, just like Heather Smith
21 Q. Do you remember a kindergarten teacher named
22 Ms. Heather, someone who developed cancer?
23 A. Heather Smith? Yes, I remember her.
24 Q. Okay.
25 A. But I did not know she was bilingual.
1 Q. Do you remember what happened with her employment
3 A. No, I don't know what happened to her employment
5 Q. Did she just stop coming to school? Is that how
6 you recall?
7 MS. ANGELL: Objection. Relevance.
8 MS. LARKINS: I believe that this is relevant
9 because there's been a very high percentage of bilingual
10 teachers fired from Castle Park school, and I'm trying to
11 find out about the circumstances by which -- you have a few
12 people, like maybe seven people, and how two of them have
13 been dismissed by the school board.
[False accusations were made up to get rid of teachers, and to fire
14 MS. ANGELL: Mrs. Larkins, what does that have to
15 do with any cause of action alleged in the case at bar?
16 MS. LARKINS: I believe that there have been many
17 false stories made up about my dismissal from Chula Vista,
18 and I'm trying to get at the atmosphere at the school, the
19 attitudes at the school, and the truth about my dismissal.
14 We're going to go right to September 2000. Do you recall that
16 Larkins was teaching half days at the beginning of the 2000,
17 2001 school year?
18 A. No, I don't remember.
19 Q. Do you recall coming up to Maura Larkins at the
20 beginning of the year -- I'm kind of trying to help you jog your
21 memory -- and saying that you were worried that she might be
22 sick and asking her why she had been taking half days off?
23 A. Maybe.
I don't remember that.
4 Q. But you're not denying that it could have happened?
6 A. I don't remember.
16 Q. Okay. Do you remember in approximately -- in
17 February 2001, not approximately, in February 2001 that
18 Larkins was put on leave?
19 A. I don't remember when you were put on leave.
[Maura Larkins' note :It was the next work day after she called Rick
Werlin. She’s is still pretending it was only Jo Ellen Hamilton who called
Werlin on Saturday evening, Feb. 10, 2009. She changed her
testimony later when I ask if she would mind if I subpoenaed her phone
20 Q. Okay. But you do remember that I was put on
22 A. All I know is you weren't there. I don't know why
23 you weren't there.
24 Q. Okay. I think we really do need to refer to this
25 prior testimony.
4 Could you look around Page 29.
10 Q. Line 11, could you read your answer there, those
11 four lines into the record.
14 A. Well, before that, I knew something had happened
15 between Maura Larkins and Jo Ellen Hamilton, but I didn't
16 know, and I still don't know really what happened.
17 Q. Okay. And the questioner asked you, "And how did
18 you know that something had happened?" Could you read your
19 answer to that question?
20 A. On Line 17?
21 Q. Yes.
22 A. And "how did I know? You know, I don't even know
23 how to answer that. You know, I guess the words -- you know,
24 I don't even know how to answer that. She was -- I can't
25 even think -- with people talking about it at school, but she
1 was -- we must have talked about it. Jo Ellen must have -- I
2 mean -- I don't know."
13 And the questioner said, "But sitting here today,
14 you knew at the time, that you knew something had happened?"
15 And you said, "I knew something had happened, and
16 Maura Larkins wasn't at the school. She was put on leave"?
17 A. Well, at that time maybe that's what we were told.
18 I don't remember.
11:56 a.m.--12:03 p.m. (Recess taken.)
(Plaintiff's Exhibit No. 9 was marked for identification.)
16 Q. Looking at this first page here, at first glance
17 does this appear to be your handwriting?
18 A. Yes.
19 Q. Okay. Could you read the first paragraph that
20 starts with Mon., the abbreviation for Monday, Mon. 4/16?
21 A. Monday, 4/16, I was in Loma Verde locker room
22 following my students' swimming lesson. Maura was coming in
23 as I was leaving. I looked up at her and said, "Welcome
24 back, Maura." Maura glared at me and looked the other way.
25 I took that response as not wanting to talk to me so I didn't
1 say anything else.
2 Q. Can you now remember this incident independently
3 of these notes?
4 A. Yes, I can remember this.
5 Q. Okay. Can you tell me something about what was --
6 why would you take notes about -- about this incident?
7 A. Because there were -- okay. I was -- I was told
8 by Dr. Donndelinger that you were coming back to school and
9 that we should be friendly and, you know, cooperate, get
10 along and so forth, and so I made it a point to welcome you
11 back. And I remember saying this right in front as you're
12 walking into Loma Verde pool where there's dirt right by the
13 chain link fence. That's where our class -- our two classes
14 passed. You were coming and we were leaving, and I said,
15 "Welcome back, Maura" right to your face, and you just gave
16 me this -- this look that was not very friendly and just --
17 and then just looked the other way. You didn't say anything.
[Page 34-35: Linda is confused about where this alleged
incident took place.]
21 Q. Would you please read again the first
sentence of this.
23 A. I was in Loma Verde locker room
following my students' swimming lesson.
25 Q. Thank you. So according to these notes
you were in the locker room. Is it possible that your
memory of the fence is somewhat confused?
note re page 19: I'll
bet that if Michelle
Tellez had been
Watson would have
known that she was
a teacher, not an
LINDA MAE WATSON
Pages 1 through 161, inclusive
Claudia A. Witt, CSR
1 Deposition preamble, two pages 5
2 Condensed transcript of the deposition of Ms. Watson dated 9-11-02 before the
Governing Board of the Chula Vista Elementary School District, 21 pages 8
3 Summary Evaluation Report concerning Ms. Larkins dated 4-28-00, three pages 107
4 Condensed transcript of the deposition of Virginia Boyd dated 3-22-04, 17 pages 53
6 Handwritten note by Ms. Hamilton dated 2-6, one page 53
9 Handwritten notes, four pages 33
10-A Pages 51 to 54 from a condensed reporter's 54
transcript dated 1-6-03, one page
10-B Pages 79 to 82 from a condensed reporter's 54
transcript dated 1-6-03, one page
14 Typewritten document entitled "Maura 140
Documentation," one page
20 Handwritten notes, two pages 88
22 Pages 59 to 62 from a condensed reporter's 136
transcript dated 1-6-03, one page
23 Typewritten notes, one page 144
24 Handwritten notes, two pages 103
The time now is 10:11 a.m.
District witnesses wildly
unreliable; Watson has
no memory of details of
how she ended another
Denmon and Coffey
|[Maura Larkins' note re page 51:
Kathy Bingham had suggested, weeks
before, that if Maura Larkins had
lounge duty then the food might be
poisoned. On this particular day Maura
Larkins brought food, and told Kathy
Bingham she would be all right so she
wouldn't worry about food poisoning.]
|[Maura Larkins' note re
: In fact, Linda Watson
went off in a spectacular
fashion, and did it in a
She led me over away
from the children before
she burst out with a loud,
|I was trying to think of anything I could say to get out of there...
"Maura, I had nothing to do with the Jo Ellen thing. I thought we were friends"... "Are you
going to sue me?" [Maura] said, "Justice will be served." And by that, I was out of there,
and that's -- I was very upset.
[Maura Larkins' note: Why on earth would Linda Watson think that I might sue her? What
would I sue her for? I did not know what she had done, but she knew what she had done. The
question of whether I might sue her demonstrates a keen awareness of guilt. ]
"I said, 'Are you going to sue me?'"
Page 112 testimony
contradicts page 25
7 Ms. Watson
indicated to me on the
break that she needs to
8 make a correction to
9 Go ahead.
WITNESS: In regards
to phoning Rick Werlin
11 on -- I don't know if
it was a weekend night
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
14 the purpose of the
15 BY MS. LARKINS:
16 Q. Thank
you. Do you think that
might have been in
17 February 2001?
18 A. I don't
19 Q. Okay.
Was it about -- in
reference to Maura
21 A. I don't
Werlin said she was too
distraught to come to the
Q. Did you call Rick Werlin at his home at any
* * *
Attorney Kelly Angell Minnehan: "Ms. Watson
indicated to me on the break that she needs to
make a correction to earlier testimony."
Linda Watson: "In regards to phoning Rick
Werlin on -- I don't know if it was a weekend
night or whatever, I've thought about it, and I
may have called him, but I do not remember reaching
him. And I don't even remember what the purpose of the
Q. But you believe that you -- at most you only called him one time ever?
A. Yes. I'm -- you know, I want to say I'm pretty sure that if I did, and I'm not even
sure I did, that it was one time to his house on a weekend.
For Robin Donlan and Linda Watson:
By: KELLY R. ANGELL, ESQ.
STUTZ, ARTIANO, SHINOFF & HOLTZ
For Chula Vista Educators,
California Teachers Association,
Virginia Boyd and Timothy O'Neil:
By: MICHAEL D. HERSH, ESQ.
CALIFORNIA TEACHERS ASSOCIATION
11745 East Telegraph Road
Post Office Box City 2153
Santa Fe Springs, California 90670
For Maura Larkins:
Maura Larkins in pro per
[At first Linda Watson was angry because she
thought Maura Larkins was avoiding her, then
she was angry because Maura Larkins tried to
talk to her. Watson was in no way disposed to
allow Larkins to be part of a normal working
3 A. Okay. I don't understand why I put that first
4 sentence, because on Monday I clearly remember that this
5 incident happened as we were coming and going. I was --
when I wrote this, I was very upset because of the incident that
7 happened on Friday. And I came back to my -- to the school
8 shaking. You can see by my writing. I was crying. I was
9 very upset. And I put down -- I tried to document everything
10 that had happened during that week. And that's why I may
11 have -- you know, this all related to the Loma Verde pool
12 incident, and I put things in order so that I would remember
13 them and try to understand what had happened.
14 Q. Okay. But at this point in time you are sure that
15 this is incorrect where it says "I was in Loma Verde locker
17 A. Yes, that is incorrect. I remember it was right
18 in front of the fence as we were passing with our classrooms.
19 Q. Okay. Okay. Now, I want to stick with this
20 Monday, April 16th.
21 MS. ANGELL: What year are you talking about?
22 MS. LARKINS: It's 2001.
23 Q. Now, you say that you wanted to welcome Maura
24 Larkins back because the principal had told you to. But
25 personally how did you feel about Maura Larkins coming back?
1 A. I had -- I had no problem you coming back. I
2 mean, you had been gone a lot. We were happy that you would
3 come back and be with our team again.
[“Maura was coming in as I was leaving” is another indication it
happened indoors, not outside by a fence. Linda is caught in her
confusion here. I don't know why she can't admit she remembered it
correctly when she wrote about it in April 2001, but remembered it
incorrectly when she was deposed late in 2002.]
18 Q. In this encounter here when you said Maura was
19 coming -- well, here you say "Maura was coming in as I was
20 leaving," and I think what you want to say is that Maura was
21 coming to the pool and you were finished and you were leaving
22 the pool. I think we can work with this, this difference.
23 Do you remember the first moment you laid eyes on
24 Maura Larkins at that -- in this encounter?
25 A. Yes.
1 Q. Okay. What was she doing?
18 Q. Okay. When you first looked at her at this
19 incident which we've been talking about --
[Amazingly detailed story, considering that Linda's own written notes
and my clear memory contradict it.]
14 So April 16th, 2001 is the date for all my
15 questions until I tell you that we're changing dates.
20 Q. Okay. What did you see when you first saw Maura
21 Larkins in this encounter?
22 A. Okay. On Monday you were bringing your children
23 to the pool as we were leaving because we had our
24 first. We were passing right by the side of Loma Verde
25 where the chain link fence was where the dirt meets the
1 pavement, and that was the first time I saw you that day on
2 your return. And you looked up and I looked up and our eyes
3 met, and I said, "Welcome back, Maura." That is all I said.
4 And you just ignored -- you just kind of glared at me and
5 then you looked the other way. You didn't say anything, and
6 I continued to walk with my children back to Castle Park.
7 That's all that happened on Monday.
8 Q. Okay. Thank you. So this was pretty much an
9 instantaneous event or did you -- were you looking at Maura
10 Larkins for 10 seconds? 20 seconds?
11 A. No. It was just being friendly and welcoming you
13 Q. This was a very short encounter. Are you saying
14 this was a very short encounter?
15 A. Yes. It was short because I only said, "Welcome
16 back, Maura," and you said nothing.
17 Q. Okay. And -- okay. So this probably lasted
18 three, four, five seconds?
19 A. Yes.
20 Q. Okay. Okay. How did you feel after that?
21 A. I didn't feel good because I thought you were
22 ignoring me and you were not being friendly.
[Wait a minute. She said I was irrational--now I'm not friendly? Which
13 Q. Were you worried that Maura Larkins might be
14 thinking you were responsible for her being put on leave?
15 A. Maybe. I didn't know what you were thinking.
16 Maybe -- maybe you were. I don't know. I didn't know what
17 you were feeling because you weren't expressing anything.
18 You weren't talking.
25 Q. Okay. I'd like to refer to Exhibit 2, Page 31.
1 A. Exhibit 2, Page 31?
[Her testimony is all over the map.]
2 Q. Uh-huh. Page 31, Line 5. According to this
3 transcript the questioner asked you, "On that Monday at the
4 pool when you got no response from Maura Larkins, did you
5 consider that to be rude?"
14 Q. Would you please read your answer which begins on
15 Line 8.
16 A. I considered it to be rude, but in hindsight, you
17 know, she may not have even heard me." She may not have
18 even -- "she may not have even heard me say it. You know,
19 I'm walking with kids, she's going this way, and I'm going
20 this way.
13 I want to talk about Tuesday, April 17th, 2001.
14 You have a notation here in the middle of this page, Tuesday
16 A. Yes.
17 Q. Could you read what you wrote for that date.
22 THE WITNESS: Tuesday, April 17th, 2001. "It
23 seemed obvious that Maura was avoiding me. So I didn't have
24 any reason to talk to her so we didn't say anything to each
[At first Linda Watson was angry because she thought Maura Larkins was avoiding her, then she was
angry because Maura Larkins tried to talk to her. Watson was in no way disposed to allow Larkins to
be part of a normal working situation.]
2 Q. Okay. So you had come to the conclusion that
3 Maura was avoiding you. Is that true?
4 A. Yes.
5 Q. And do you still believe that to be true?
6 A. I don't understand.
7 Q. Okay. Do you believe you were correct when you
8 made this -- when you came to this conclusion?
9 A. Yes.
10 Q. Okay. And was your reason because you felt that
11 she had -- Maura Larkins had snubbed you the day before?
22 THE WITNESS: I don't remember. I mean, I just
23 stated that we did not have a conversation on Tuesday when
24 we -- when our classes passed, neither one of us said
25 anything. I don't remember what I was thinking or what
1 conclusion or anything I came to.
3 Q. Okay. So you don't remember what your reasons
4 were for concluding that Maura was avoiding you?
8 Q. You don't remember why you came to this
9 conclusion. Is that correct?
10 MS. ANGELL: Objection. Asked and answered.
11 THE WITNESS: Do I have to answer it? I don't --
12 I mean, that's what went through my mind. I thought that --
13 that you were mad, upset. I don't know -- I didn't know
14 what your feelings were. I still don't know what your
15 feelings were.
16 All I know is that you did not respond to me, and
17 you never talked to me when we walked by. You didn't greet
18 me on Tuesday when we passed. You didn't say hello to me,
19 and I didn't say anything to you. It was very odd.
21 Q. Do you recall passing Maura Larkins on Tuesday?
22 A. Yes, I do.
23 Q. Where did this take place?
24 A. At the same place. It was right as you were
25 coming in, we were going out, exactly the same as Monday.
2 A. But on Tuesday neither one of us said anything to
3 one another.
4 Q. Okay. So are you telling me that it was the two
5 days of -- when you believe that Maura Larkins did not say
6 hello to you -- by the way, my testimony will be that I said
7 "Hi, Linda" on Monday, and I do not recall seeing you on
23 Q. Okay. So you have given two reasons why you came
24 to this conclusion that Maura was avoiding you, because you
25 didn't believe Maura had spoken to you when you encountered
1 her on Monday and because you believe that you encountered
2 her on Tuesday and she didn't speak to you.
14 Q. Okay. I think we have enough on that. Let's see.
15 You know what, I'm kind of getting interested in -- we seem
16 to have such a problem with memory here that I think maybe we
17 should just go a little further into the nitty-gritty of this
18 case. Here it is.
19 Okay. Have you ever at any time been concerned
20 that Maura Larkins might have a gun?
[No answer because lawyer made lengthy objections.]
Before you ever met Ms. Angell or Mr. Bresee or Mr.
Shinoff or any other attorney that you might have
discussed any of these matters with, were you ever
afraid that Maura Larkins might have a gun?
11 A. No, never.
12 Q. Did you at any time before you met these attorneys
13 fear that Maura Larkins might kill you?
14 A. I was afraid of Maura Larkins because of some of
15 the statements she had made and the incident with my son that
16 made me fearful, not necessarily you're going to kill me. I
17 didn't know what was going to happen, but it made me feel
18 very uncomfortable.
Page 49 Gun
14 Q. And this happened the day after your son convinced
15 you that only Kathy Bingham would be saved and everyone
16 else -- would be dead?
21 Q. Okay. Did you fear that Maura Larkins might kill
22 or harm everyone but Kathy Bingham?
23 A. I didn't know what you meant. I just knew that it
24 wasn't appropriate and it was fearful, and it was not
25 appropriate behavior, and we -- I don't know what you were
1 thinking, but it wasn't making me feel very calm. I felt
2 upset about it.
3 Q. Okay. So you were already upset and fearing
4 possible physical harm from Maura Larkins before this
5 incident that you report?
16 Q. Was Thursday the day when your son convinced you
17 that Maura Larkins was going to kill or somehow physically
18 harm everybody but Kathy Bingham?
21 THE WITNESS: Yeah. My son -- my son stated that
22 he thought you were threatening me and that I was, you know,
23 in danger. And you also on Wednesday had yelled at me at the
24 pool and called me a liar and delusional, and never once did
25 I raise my voice to you. And so all these incidents just
1 snowballed, and I don't know why you were acting that way
2 towards me.
[She was afraid that I might know that she had committed crimes against me. She was in a panic about
being exposed for her own wrongful actions. She had already got the union to file a grievance to keep her
February 10, 2009 allegations anonymous, which the district clearly granted.]
4 Q. Do you think that these incidents could have been
5 perceived by you because you were already in a great state of
6 fear and tension?
7 A. No.
8 Q. You're quite sure that you got everything right
9 except for that little problem about whether you were in the
10 locker room or by the fence?
11 A. That's right.
12 Q. Okay. So you told these things to Mr. Werlin on
13 Friday about a fist being very near your face?
14 A. I said I didn't know if Mr. Werlin was there on
16 Q. Okay. But you did say this to Gretchen?
17 A. Yes.
18 Q. Okay. You made this report on Friday to Gretchen.
19 MS. ANGELL: Friday, April 20, 2001, correct?
20 THE WITNESS: Yes.
22 Q. Okay. I'd like you to look at Exhibit 2, Page 47.
1 Q. Actually, can I -- let's go up to 46
2 up there, Line 22. Could you just read that one paragraph
3 there which extends down onto Page 47.
4 A. "As I was walking out, trying to get around her, I
5 said, 'Maura, I had nothing to do with the Jo Ellen thing. I
6 thought we were friends.' I was trying to think of anything
7 I could say to get out of there. She had her fist up in the
8 air like this, like the Statue of Liberty. She said,
9 'Justice will be served. Justice will come out,'"
15 I said, 'Are you going to sue me?'
[Why on earth would Linda Watson think that I might sue her? What would I sue her for? I did not
know what she had done, but she knew what she had done. This question demonstrates a keen
awareness of guilt. ]
16 'Justice will be served.' And by that, I was out of there,
17 and that's -- I was very upset. That was a big part of
18 it" -- "that was a big part of it that I didn't say."
19 Q. Okay. Are you confident that you have Maura
20 Larkins' exact words here or was it -- would you like to
21 maybe say that it was words to that effect?
1 A. You said the truth will come out in a court of
2 law. That's what you said. Justice will be served.
3 Q. Okay. Thank you. The truth will come out in a
4 court of law?
5 A. Yes.
6 Q. Okay.
7 A. That's not in there, but that's -- I remember you
8 saying that.
9 Q. Okay. All right. Now, here you say justice will
10 be served. Justice will come out. And then you ask, "Are
11 you going to sue me?" Why did you think Maura Larkins would
12 sue you?
13 A. Because of what you were saying. You were saying
14 that the truth will come out in a court of law and justice
15 will be served and all of those things, and that's what
16 brought to my mind that you were thinking about suing
18 Q. Somebody. Why did you think it might be you?
19 A. I don't know. I was just -- I was so frightened,
20 I was just trying to get out of there. I -- that was just
21 the first thing that came to my mind.
22 Q. Were you frightened of being sued?
23 A. I -- at that point I didn't even -- didn't even
24 think that you would be suing anybody.
25 Q. Were you afraid of the truth coming out?
1 A. I don't even know what truth you're talking about,
2 because --
3 Q. Well, whatever truth you said -- I think you just
4 quoted me as saying something like the truth will come out in
5 a court of law. I think you said I said that?
6 A. Yes.
7 Q. Were you afraid of that happening?
8 A. No, I'm not.
She didn’t remember I said deposition, she thought I said lie detector test
15 Q. Okay. So did you -- do you think that Maura
16 Larkins may have used the word deposition?
19 A. No.
20 Q. You're sure Maura Larkins didn't use the word
22 A. (Witness shakes head.)
6 Q. Now, here you talk about "she had her fist up in
7 the air, like this, like the Statue of Liberty," but this
8 doesn't say anything about it being near your face. Do you
9 think that could be something that your memory has created
10 since then?
12 THE WITNESS: No.
14 Q. So we were both going in the same direction?
15 A. I was trying to get out of there as fast as I
16 could. Exactly, you were trying to keep -- you were still
17 talking to me and ranting and raving with your fist in the
18 air as I was getting out of there as fast as I could. So you
19 were backing towards the door as I was trying to get around
20 you to go out the door.
21 Q. So you were forcing me backward?
22 A. I wasn't forcing you backwards. I was trying to
23 get out of there. That's what was happening.
24 Q. Okay. So was Maura Larkins' fist up in the air
25 for two or three minutes?
1 A. At least a minute.
2 Q. A minute. She must work out.
6 Q. Okay. What did Maura Larkins say when you asked
7 if she was going to sue you?
20 Q. Uh-huh. Okay. It sounds like quite a -- quite an
Q. Did Maura Larkins say anything about a lie detector? ...At this encounter
that we've been talking about here on April 20th, 2001.
A. I don't remember you saying anything about a lie detector.
Q. I don't either. Were you worried that you might have to take a lie detector
THE WITNESS: No. It never occurred to me. I don't know what I would be
lying about. I don't even understand what -- why I would be having a
problem. Taking a test for what.
[Her own notes contradict her. ]
|Gretchen Donndelinger's notes:
"Linda asked if she was a danger, if she
(Maura) had a gun..."
19 Q. Thank you. Did you think that Maura Larkins'
20 killing you was a possibility?
21 A. Yes, because at the time there were many violent
22 things going on in the world like school shootings and things
23 like that.
20 Q. Okay. Did you ever ask Gretchen
Donndelinger if Maura Larkins had a gun?
22 A. No. Oh -- I don't remember. I don't -- I don't
23 remember. I may have been concerned about that. I may
24 asked her that.
25 Q. What would cause you to worry about that?
1 A. Because of the statement that you had made to
2 Kathy Bingham in the hallway.
3 Q. Yes, tell us about that statement.
4 A. You apparently were walking down the hallway and
5 met Kathy Bingham, and your statement was "Kathy, you'll
6 all right" and just walked on and didn't say anything more
7 and Kathy didn't say anything more to you.
8 And then that was so odd and Kathy was wondering
9 about that, and in a conversation we had she relayed that to
10 me and I relayed that to my son who at the time was in high
11 school, La Jolla High School. And he just looked at me and
12 said, "Mom, she just threatened you." And I said, "What do
13 you mean?" And he said, "She was telling Kathy that she
14 would be all right but that the rest of you were all going to
15 die or have something happen to you." And I just -- I was
16 just stunned. I hadn't even thought of that. That didn't --
17 had not even come into my mind until my son said that, and it
18 just -- it just made me feel sick to my stomach.
19 And you have to remember, this was after the
20 Santana shootings, the one in Colorado and -- Columbine, and
21 he had been counseled at school on lots of violence
22 awareness, and it was a very timely situation, and it did
23 make me very fearful.
24 Q. Okay. So you had hearsay that Maura Larkins had said you're
going to be all right, and then you thought that Maura Larkins might
harm you with a gun?
6 Q. Do you -- at this point in time do you feel that
7 your reaction was a reasonable one?
8 A. I felt like my reaction was a reasonable one
9 because you were acting so irrationally, and we couldn't
10 communicate with you, and I didn't know what you were going
11 to do next or what you were capable of. But I didn't dwell
12 on a gun. I don't even -- you know, I may have just asked
13 that, but that wasn't something I was -- you know, I don't
14 know. It was -- it was very odd. It was odd behavior.
15 Q. Okay. Okay. You just said that Maura Larkins was
acting irrationally. Can you tell us more about that.
V. We're going off the record.
The time now is 12:35 p.m. (Recess taken.) Back on the record. The time now 12:41 p.m.
16 Q. Okay. Do you recall that Maura Larkins never
17 worked at Castle Park school again after April 20th?
20 THE WITNESS: I don't believe you did come back
21 after that.
23 Q. And do you understand that the reason was because
24 you and someone else made a complaint about Maura Larkins?
25 A. I didn't know why you were put out on leave.
She was in the meeting to make sure I was forever removed from school
7 Q. Okay. Let's look at your own notes here. You might believe your own handwriting. On
the -- this page that is Bates stamped with a 03 here?
11 MS. LARKINS: Of Exhibit 9. Thank you.
17 A. At 10:45 Gretchen told me that we would meet as a team with Rick
Werlin at 2:30.
19 Q. Okay. So does that help refresh your memory at all?
21 A. I guess so. Yeah, I guess we met. I don't --
22 Q. But you don't have any present -- at present you
23 don't have a clear --
24 A. I want to make sure I'm remembering exactly what
25 happened, and I -- I assume that we met, but I don't – I
1 know there was a meeting. I know that Gina was -- Gina was
2 out of town for one of the meetings, so I just can't remember
3 who was there at that meeting.
4 Q. Okay.
5 A. Because I was very upset at that point also.
6 Q. Is there -- okay. Well, that's -- yeah. That's
7 good. You remember that Gina was out of town. So it sounds
8 like you are starting to remember this -- this meeting.
9 MS. ANGELL: Excuse me. That misstates the
10 testimony. What she said is she remembered that Gina Boyd
11 was out of town for some meeting. She didn't remember which
12 meeting it was.
13 THE WITNESS: That's right. That's why I don't
14 remember who was at what --
18 Q. No. All I said was Gina Boyd was out of town.
19 And this meeting took place at Castle Park school, right?
20 A. There was a meeting on Friday afternoon at Castle
21 Park Elementary School, but I don't remember who was at that
23 Q. But you do remember Gina Boyd wasn't there.
24 A. No, I don't remember if Gina Boyd was at -- if she
25 was out of town for the Wednesday meeting or for the Friday
5 Q. Okay. Did you have a meeting with -- on Wednesday?
6 A. Yes.
7 Q. Who was at the meeting?
11 THE WITNESS: I remember coming back from the
12 pool, and the first person I remember right now that I talked
13 to was Maria Beers and going to Gretchen Donndelinger and
14 meeting with them in regard to what happened at Loma Verde
15 pool that day.
17 Q. Okay. So you remember meeting with Maria Beers
18 and Gretchen Donndelinger.
19 A. Yes. And I believe Gina Boyd was called that day,
20 but I can't remember if she was there or not. I believe she
21 was there.
3 Q. When you walked back to school from the pool on
4 Wednesday, April 18th, 2001, were there -- was Richard Denmon
5 with you?
6 A. Yes.
7 Q. Were -- do you remember your -- your encounter
8 with Maura Larkins on that day?
9 A. Yes.
12 Q. Okay. When you were talking to Maura Larkins,
13 were you crying?
14 A. No, not at the pool. It wasn't until I got back
15 to school that I was crying.
[Why waste the tears when there's no audience? At the pool she was
spitting fire, she was so angry.]
19 Q. Okay. And did you discuss with Richard Denmon
20 what had transpired between you and Maura Larkins?
21 A. Mr. Denmon knew that -- that there were words
22 exchanged. He knew that something was going on that --
23 Q. I'm not asking you what Mr. Denmon knew. I'm
24 asking you if you talked to him.
25 A. I probably talked to him, but I don't remember what I said. DR
Do you recall that the summer following this week that you -- we have
been discussing, this week from April 16th to the 20th, 2001, you were
called by Rick Werlin and asked to come to the district and tell Maura
Larkins face to face what your allegation against her had been?
3 THE WITNESS: Yes. But it was as a forum. It
4 wasn't to state allegations. It was to -- I thought it was
5 just to talk to you. I don't know what it was really for.
Q. Okay. Did you think that it was appropriate that Maura Larkins
never heard the allegations you had made about her?
Q. Did you ever tell Maura Larkins what your allegations against her
during the week of April 16th to 20th, 2001 were?
THE WITNESS: I don't know what allegations, what you're talking about.
23 Q. You made a complaint about Maura Larkins on
24 April 20th, 2001, to Gretchen Donndelinger and Rick Werlin?
25 A. I just stated what had happened. I stated exactly
1 what had happened between you and I at that time.
18 Q. What did you tell Rick Werlin on April 20th, 2001
19 about Maura Larkins?
20 A. That's all written down here. Did you want to --
21 want me to read this out loud?
22 Q. If you wish.
23 A. Okay. Friday --
24 Q. Are you sure that you -- that's exactly what you
25 told him?
1 A. I told him exactly what had happened at the pool.
2 I was very upset.
3 Q. You don't remember right now? I'd really prefer
4 that you -- you know, if you remember, that you don't read.
5 A. Sure. Absolutely.
6 Q. Okay.
7 A. I will tell you what happened.
8 Q. Okay.
9 A. Now, you want me just to -- for on Friday what had
11 Q. Yeah. What did you tell Rick Werlin and Gretchen
12 Donndelinger on Friday about Maura Larkins?
18 Q. Okay. Just a minute. Have you come to have a
19 clearer memory of that meeting than you had when we first
20 started talking about it?
21 A. I remember what I said at the meeting. I'm not
22 sure who was there.
23 Q. Do you remember that Rick Werlin was there?
24 A. I'm not sure. I'm just not sure. He might have
25 been there, but he may not have been there.
1 Q. When you made -- when you -- okay. Can you just
2 tell me in a nutshell what was your basic complaint about
3 Maura Larkins on that date, April 20th, 2001?
4 A. Because -- well, I went through the whole week, what had happened, all the events that
led up to Friday and the fact that I felt that you threatened me at Loma Verde pool in the
pool house inside the dressing room area.
8 Q. On what date?
9 A. On Friday, April 20th --
16 Q. Threatened physically?
17 A. Yes.
18 Q. Okay. In what way?
19 A. That you came up to me when I was getting my
20 children ready to go back to school, and you started talking
21 to me. And I said -- I said, "Maura, I don't want to talk to
22 you unless Gretchen or Rick Werlin or Maria Beers or Gina
23 Boyd were present, and you did not accept that, and "leave me
24 alone." You continued to talk to me in a very loud manner,
25 and I repeated it a second time. I said, "I don't want to
1 talk to you unless those people were present."
2 And you just started raising your voice, ranting
3 and raving about the truth will come out in court, and you
4 had your fist up in the air like this right by my face. And
5 you -- I remember because it reminded me of the Statue of
6 Liberty. And you were ranting and raving the truth will come
7 out, and I put my hands up like this because I was afraid
8 that you were going to come at me. You had me backed into a
9 corner. And I was very fearful for my children that were
10 around, and I just started saying anything I could think of
11 to diffuse you and to walk around you and get out of there.
12 And I got back to school as fast as I could and I said that's
|April 16, 2001
My conversation with Linda Watson
I returned to work after two months, and on my first
day back I took my class to the pool for lessons.
Linda’s class was in the session just before mine.
When the pool staff said my class could go in to
the locker room I went in to see if the other class
was mostly out. The kids were all gone. Linda
was at the far end of the room, looking in stalls to
see if kids left belongings behind. Linda wore a
pink top and pink pants. She seemed to be
procrastinating, moving slowly toward me as she
looked in the stalls.
This was our first meeting since Linda told Maria
that I was the kind of person who became a mass
murderer. Knowing she had a very negative
opinion of me which she had shared with others to
my detriment, I was not comfortable.
Linda couldn't bring herself to look at me. She
seemed to mumble something to herself. She
dropped out each word as if it were a rotten
grape. I could barely hear her, but she must have
said, "Welcome back, Maura." Her mouth was
twitching, first a curled lip, then a grimace, then a
frown as she came toward me. I said, "Hi, Linda."
She still didn't look at me. Then I looked away and
rolled my eyes. She must have looked at me then;
that's the only point where our stories converge.
|page 58--Rick Werlin's
idea of a team is everyone
except the person being
discussed. He wanted to
make sure the truth didn't
False: The Statue of Liberty
is not threatening. I may
have made an offhand
"power to the people"
gesture to demonstrate that I
believed in justice, but Linda
is lying when she says I put
my hand near her face.
That's not what happened,
and that's not how I approach
problems. I'm a person who
talks about issues and, at
that time, I had confidence in
the justice system, and I
believed that the truth would
prevail. I was trying to solve
the problem, to prevent the
things that ended up
False: There were no
False: She wasn't backed
into a corner. She was in the
middle of the room.
What she was thinking was,
"Is Maura Larkins going to
|Q. Did you think that it was appropriate that Maura Larkins
never heard the allegations you had made about her? Did
you ever tell Maura Larkins what your allegations against
her during the week of April 16th to 20th, 2001 were?
A. I don't know what allegations, what you're talking about.
Where is #39? It has
never been produced.
Stutz Artiano Shinoff
and Holtz has never
document #39. Stutz
says that they asked a
paralegal to look for the
missing documents, but
she couldn't find them.
Daniel Shinoff, the
person who first
disinclined to look for
them himself, perhaps
because he knows
where they are.
|Bate-stamped document #39
Attorney Mark Bresee didn't produce it,
and attorney Daniel Shinoff didn't
[In fact, this incident happened in the locker room. Maura
Larkins had more reason to be upset, since she had been
placed on administrative leave due to unknown accusations
from two anonymous teachers who called Richard Werlin on
Saturday night February 10, 2001, and didn't know who
might falsely accuse her in the future. It turned out to be
LInda Watson, who kept her first accusation secret with help
from the teachers union, and made a second accusation to
prevent Maura Larkins from finding out the truth.]
Maura Larkins insisted that her lawyer,
Elizabeth Schulman, ask Richard
Werlin if Linda Watson talked to him on
Feb. 11, 2001.
Why was it important that the district hide the fact that Linda Watson was one of the two
teachers who called Richard Werlin on Feb. 10, 2001 to say they feared for their lives?
Because the district found those teachers to be unreliable, and asked Maura Larkins to return
to work without ever investigating those allegations.
But when Maura Larkins tried to find out the truth--which would have exposed criminal actions
by LInda Watson and the district--the district wanted to get rid of her. The district then relied
on a new (fabricated) allegation by LInda Watson and the bizarre report of Alan Smith.
One of them, Linda Watson, WITHOUT EVER RETRACTING HER FALSE
ALLEGATIONS AGAINST A FELLOW TEACHER, got the teachers union to
file a grievance to force the district to keep her identity secret. The
district changed its story to say that only one teacher called.
These phone calls did NOT result in an investigation by the school
district, but they did result in my losing my job. Linda Watson and
others continued to harass me so severely that I finally refused to go
back to work until there was an investigation. The district continued to
refuse to investigate; I was fired for "insubordination."
School attorneys Mark Bresee and Daniel Shinoff were advising the
district at the time regarding the actions the district should take.
Years later, I finally got the chance to ask Linda Watson about what
Richard Werlin's second anonymous Saturday-
night caller identifies herself--or does she?
Richard Werlin, former Assistant Superintendent for Human
Resources at Chula Vista Elementary School District, said that two
teachers called him on a Saturday night (Feb. 10, 2001). Mr. Werlin
claimed that the teachers said they feared for their lives, and that
they thought another teacher (me!) might kill them. Werlin did not say
who the teachers were, or what reasons they gave for believing that
death might be imminent.
|San Diego Education
Thank you. Do you think that might have been in February 2001?
A. I don't remember.
Q. Okay. Was it about -- in reference to Maura Larkins?
A. I don't remember. I don't remember what it was about. And I
was trying to figure out when it could have been made, and I
can't -- I can't put the dates together as to when it would make