Batestampeddocsproduced

Stutz, Artiano Shinoff & Holtz and
Chula Vista Elementary School District

Bate-stamped documents,
missing many pages

Produced by Mark Bresee of Parham &
Rajcic in 2002 for Larkins' OAH hearing

A "Bate-stamped"
document is one that
has been stamped
< < <
with a page number by a lawyer
who is collecting evidence for a
case.

< < < This is the
exhibit number, NOT
the Bate stamp. See
the Bate stamp at
bottom of page.

The document below, written long after events
took place, reveals that Gretchen Donndelinger
had forgotten that she came into Maura Larkins'
classroom and warmly greeted Larkins during the
3/26/01 visit described. Maura Larkins had been
invited back to work the previous evening by
Richard Werlin, and had told Werlin that she would
help her substitute, but did not want to come back
until an investigation took place and allegations
against her were retracted.

No investigation took place. Much later,
Donndelinger tried to reconstruct a report out of
her very incomplete notes. It's not surprising that
she made mistakes.

Bate stamp        Date                                Subject
#

01-04              April 16-20, 2001       Linda Watson notes
05-06 missing                                 ?
07                  March 6, 2001            Letter to parents from Gretchen
08                  April 6, 2001              Letter to parents from Gretchen
09 missing                                      ?
10                  March 29, 2001          Letter to parents from Gretchen
11 missing                                     ?
12                  April 23, 2001            Letter to parents from Gretchen
13-20 missing                                 ?

It's hard to tell which pages are missing
when they are all mixed up like this.
(This was the district's intent.)

(Where is #55?)
Missing documents:
5-6, 9, 11, 13-20, 24,
27, 28, 39, 44,
48,51-53, 55,
63-65, 77-83
Letters from Robin
and Kim are missing.

Some documents were produced; at
least 33 documents are missing.

Why is Chula Vista Elementary School
District hiding these documents?

Bate-stamped
document # 56

The documents described below have been hidden by
Chula Vista Elementary School District and its attorney
Daniel Shinoff for four years, since originally requested in
2003. Stutz law firm failed to bring these documents to its
deposition on November 8, 2007.

OAH Exhibit 14 is a perfect example of this strategy. It consists of
Gretchen Donndelinger notes, some of which were prepared in
handwriting specifically for the hearing, long after the events took place.

The documents are listed in the order they appear in the exhibit.

Bate stamp     Date               rewrite/original          subject
#

84-87               "around 9/21/08"   rewrite                       Michelle
68,                      Jan 2001                                                    Jo Ellen joke
69-70                                                 original                       Robin's control issues, paranoia
71                                                       original                       Gretchen note to Maura
72-76                                                 rewrite                       notes
67                                                       rewrite                       Roger Cunningham, James Comer Program
66                                                       original
57-62               Feb. 12, 2001          original                        meeting notes Rick Werlin
56                     3/26/01                   rewrite                       Maura visit after call from Werlin asking her back
55 IS MISSING
54
49
50
45-46
41-43
36-38
39 IS MISSING
40
31-35
29-30
25-26
20-23

47 4/4/01 Letters from Robin, Kim, Lynn
Letters from Robin and Kim are missing

Missing documents:
5-6, 9, 11, 13-20, 24, 27, 28,
39, 44, 48,51-53, 55,
63-65, 77-83
Letters from Robin and Kim
are missing.