Sarah Dunford 09-05-2014.fullprint

SARAH DUNFORD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 1
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN DIEGO
RIMMA BREEZE, an individual,
Plaintiff,
vs. Case No. 37-2013

00067261-CU-CO-CTL
THE EVANS SCHOOL, INC.;
MARGARET GALE BAER, an individual;
and DOES 1 through 25,
Defendants.
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MARGARET GALE BAER, an individual,
Cross-Complainant,
vs.
RIMMA BREEZE, an individual; COLIN

BREEZE, an individual; BREEZE
VENTURES MANAGEMENT, LLC, doing
business as BREEZE IT CONSULITNG;
and ROES 1 through 10,
Cross-Defendants.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
DEPOSITION OF
SARAH ANNE DUNFORD
September 5, 2014
10:20 a.m.
402 West Broadway
Suite 1600
San Diego, California
Frauke Kuo, CSR No. 6283
800.211.DEPO (3376)
EsquireSolutions.com
1 APPEARANCES OF COUNSEL
3 For the Plaintiff and Cross-Defendants:
4 PERETZ & ASSOCIATES

YOSEF PERETZ, ESQ.
5 Suite 200
22 Battery Street
6 San Francisco, California 94111
(415) 732-3777
7 yperetz@peretzlaw.com
8
For the Defendants and Cross-Complainant:
9
GORDON & REES LLP
10 IAN G. WILLIAMSON, ESQ.
Suite 2000
11 101 West Broadway
San Diego, California 92101
12 (619) 696-6700
igwilliamson@gordonrees.com
13
14 Also Present:
15 RIMMA BREEZE, Plaintiff/Cross-Defendant

COLIN BREEZE, Cross-Defendant
16
17
18
19
20
21
22
23
24
25
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1 INDEX OF EXAMINATION
2 WITNESS: SARAH ANNE DUNFORD
3 EXAMINATION PAGE
4 By Mr. Peretz 5
5 By Mr. Williamson --
7
INFORMATION REQUESTED
8
Page Line
9
(None)
10
11
12
WITNESS INSTRUCTED NOT TO ANSWER
13
Page Line
14
(None)
15
16
17
18
19
20
21
22
23
24
25
800.211.DEPO (3376)
1 INDEX TO EXHIBITS
2 Exhibit Description Page
3 Exhibit 34 Amended Deposition Re-Notice of 5

Sarah Dunford (7 pages)
4
Exhibit 35 Evans Bulletin - 9/10, TES4125-126 13
5 (2 pages)
6 Exhibit 36 Letter to Teachers, 8/27/13 13

TES4127 (1 page)
7
Exhibit 37 Focus on Learning, TES4111-4121 13
8 (11 pages)
9 Exhibit 38 Emails, TES4001-4110 (110 pages) 14
10 Exhibit 39 Emails, 6/19/13 (1 page) 136
11
EXHIBITS REVIEWED
12
Exhibit 30 Letter from Evans School to Parents 135
13 9/16/13, TES027 (1 page)
14 Exhibit 31 Letter from Evans School to Parents 135

9/16/13 (1 page)
15
Exhibit 32 Letter from Evans School to Rimma 136
16 7/14/13, TES041 (1 page)
17
18
19
20
21
22
23
24
25
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1 DEPOSITION OF SARAH ANNE DUNFORD

2 September 5, 2014
3
4 SARAH ANNE DUNFORD,
5 having been first duly sworn, testifies as follows:
6
7 EXAMINATION
8 BY MR. PERETZ:
9 Q. Good morning, Ms. Dunford.
10 A. Um-hum.
11 Q. I introduced myself earlier. My name is Yosef
12 Peretz. I'm a principal at Peretz & Associates, and I
13 represent Rimma and Colin Breeze in a lawsuit they filed
14 against The Evans School.
15 And you have heard of this lawsuit; correct?
16 A. I have.
17 Q. Okay. And you understand that you are not a
18 party to this lawsuit.
19 A. I understand that.
20 Q. You understand that the Breezes did not file
21 any claims or have any allegations against you
22 personally.
23 A. I do.
24 Q. Okay.
25 (Defendant Exhibit 34 was marked.)
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1 BY MR. PERETZ:
2 Q. You understand that the reason that you are
3 being deposed is because we served you the deposition
4 notice that I marked as Exhibit 34; correct?
5 A. Correct.
6 Q. And you have had a chance to review this
7 deposition notice?
8 A. I did.
9 Q. Okay. And now, before coming here today, did
10 you have the understanding that the school disclosed you
11 in this lawsuit as a potential witness?
12 A. Could you repeat that.
13 Q. Sure. Let me rephrase that.
14 Prior to today -- Strike that.
15 Did you know that -- that the school disclosed
16 you in this lawsuit as a potential witness?
17 A. Yes.
18 Q. Okay. When were you informed if you'll be a
19 potential witness?
20 A. I don't recall.
21 Q. Approximately how long ago?
22 A. I really can't remember.
23 Q. Was it over a month ago?
24 A. Probably.
25 Q. Okay. Was it over six months ago?
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2 Q. Is it something between one and six months?
3 A. On the original acknowledgement that I would be
4 involved in this, I don't recall the exact date.
5 Q. I understand that. Let me go through some
6 basic rules here.
7 Were you ever been deposed before (sic)?
8 A. No.
9 Q. Did you ever testify at trial?
10 A. No.
11 Q. And I'm sure that Mr. Williamson or another
12 attorney went through some of the basic rules of a
13 deposition, but I'll go through some of them. Although
14 this is somewhat an informal setting, there is no judge
15 here, there is no jury, we are not in a courtroom. You
16 understand that the force and effect of your testimony
17 is the same as if you were testifying at trial?
18 A. Absolutely.
19 Q. Do you understand that you are giving testimony
20 under penalty of perjury?
21 A. Absolutely.
22 Q. Understand that you have to tell me truth and
23 only the truth?
24 A. Absolutely.
25 Q. Okay. Good.
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1 On occasions we don't remember things as best

2 as we want to because you know memories fade over time.
3 And things that were minor in the past all of a sudden
4 become the center of attention. On those instances,
5 even if you don't recall the exact date or time or
6 something that I am asking you, I am still entitled to
7 your best recollection of the events.
8 So, for example, if we take my previous
9 question, "When were you first made aware that you are a
10 potential witness in this case," even though you may not
11 remember the exact date, I am still entitled to your
12 best recollection. And "best recollection" -- I am just
13 taking this question as an example -- could be something
14 to the effect "I believe it was three months ago,"
15 "I believe it was between three and six months ago,"
16 I believe it was immediately before Easter this year" --
17 A. Um-hum.
18 Q. -- or anything that best indicates your best
19 recollection.
20 A. Um-hum.
21 Q. Are you with me so far?
22 A. Absolutely.
23 Q. Okay. And in the same manner I may ask you to
24 measure things -- measure a number of people, measure a
25 number of years, anything else. And at times you may
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1 not be able to tell me the exact thing that I am asking

2 you to measure. For example, I am asking you how many
3 students did you have in your class in 2011 and you may
4 not remember the exact number on those instances, I am
5 still entitled to your best approximation of what I am
6 asking.
7 A. Okay.
8 Q. Taking this as an example of students in the
9 class, a good answer could be, you know, "I don't
10 remember the exact number, but usually I have between 10
11 and 15 kids every year." Fair enough?
12 A. Fair enough.
13 Q. Okay. Everything is going to be transcribed
14 here by the court reporter. It's a challenging task.
15 To ease the process on her and make sure that we have an
16 accurate transcript, I would like you to wait until I
17 finish my question -- fully finish my question before
18 you answer.
19 In social engagement it's very common to
20 interrupt each other, and there is nothing -- absolutely
21 nothing wrong with that. In a deposition I would like
22 you to wait because if you jump in, the court reporter
23 will have to take what I said first, what you said and
24 then what I said, and it creates a very complicated
25 transcript. Fair enough?
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1 A. Fair enough.
2 Q. Good. Try to make audible verbal responses.
3 If you nod with your head, that's fine, but she can't
4 take it down.
5 A. Um-hum.
6 Q. So just accompany that with a "yes" or "no"
7 or --
8 A. Yes.
9 Q. Fair enough?
10 A. Fair enough.
11 Q. Okay. Try to avoid using uh-huh or huh-uh as a
12 form of a response. Most of the time by the tone of
13 your voice I will understand what you meant but the
14 transcript is tone deaf. So if a question asked for a
15 yes or no, just answer yes or no.
16 A. Sure.
17 Q. Even if it's a little awkward. Fair enough?
18 A. Fair enough.
19 Q. Okay. After the deposition is completed you
20 will have a chance to review the transcript and make any
21 changes to the transcript. However, if you make any
22 changes, we may comment on the fact that you made a
23 change and that may affect your credibility. For
24 example, if I asked you a question today and you say,
25 you know, definitely the light was red when I crossed
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1 the intersection, when you go home if I said the light

2 was red, oh, my God, I am going to change my answer to
3 the light was green. Obviously after the fact we will
4 be able to comment on that and say Ms. Dunford changed
5 her testimony after the fact because she realized that
6 she gave information that will put her at fault or
7 liability. So this is of course a hypothetical question
8 just to explain the process.
9 A. (The witness nodded.)
10 Q. Do you understand that?
11 A. I do.
12 Q. Okay. At times I may, you know, stumble, not
13 form a good question, use a term or phrase that you
14 don't know, haven't heard, don't clearly understand. In
15 all those instances, please indicate to me -- verbalize
16 that you don't understand what I am saying, or you don't
17 understand a term that I'm using, or my question is
18 confusing or unclear. Fair enough?
19 A. Fair enough.
20 Q. If you won't do that, you know, my assumption
21 will be that my question was clear enough and that your
22 answer is responsive to my questions. Okay?
23 A. Okay.
24 Q. Okay. Can you please state your full name for
25 the record.
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1 A. Sarah Anne Dunford.

2 Q. Okay. And did you ever go by other names?
3 A. Previous to my marriage I was Sarah McLean.
4 Q. And when did you get married?
5 A. December 2000.
6 Q. Do you have children?
7 A. I have two children.
8 Q. And what are their ages?
9 A. Eight and four.
10 Q. And what city do you reside?
11 A. La Jolla.
12 Q. And what's the date of birth? I apologize.
13 A. 12/31/73.
14 Q. Okay. It's a good time of year. Everyone is
15 probably fed up with gifts and all that.
16 A. That's right.
17 Q. What can you do.
18 MR. PERETZ: Before we go to the substantive
19 portion of the deposition, I want to make some
20 announcements for the record, nothing that has to do
21 with you.
22 Today I was handed by Mr. Williamson two CDs
23 that apparently include additional production of
24 documents. One of the CDs -- CD or DVD; I don't know --
25 one of them was titled TES00038, and it included
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1 documents stamped 732 through 3278. The other CD

2 included documents Bates-stamped 4001 through 4133.
3 And I was also handed a document Bates-stamped
4 4125 that will be marked as exhibit next in line, which
5 should be Exhibit 35.
6 (Plaintiff Exhibit 35 was marked.)
7 MR. PERETZ: And my understanding from
8 Mr. Williamson is that this is the September 10, 2013,
9 bulletin of The Evans School.
10 I was also handed a document Bates-stamped
11 4127, which I am going to mark as Exhibit 36.
13 MR. PERETZ: I was also handed documents
14 Bates-stamped 4111 to 4121, which I am going to mark as
15 37.
17 MR. PERETZ: And I was also handed a hard copy
18 of documents Bates-stamped 4001 through 4110, which I
19 believe were also produced electronically today as
20 well.
21 MR. WILLIAMSON: All of those documents were
22 also produced -- .pdf's of all those documents were on
23 the discs we produced today.
24 MR. PERETZ: I wasn't sure about that, so I
25 didn't want to make the statement.
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1 MR. PERETZ: Let's mark TES4001 through

2 TES4110. And that's 38; correct?
3 THE REPORTER: Yes.
4 MR. WILLIAMSON: Yes.
5 MR. PERETZ: Okay.
7 BY MR. PERETZ:
8 Q. Ms. Dunford, the deposition notice that I
9 handed you, Exhibit 34, included a request for
10 production of documents that begins on the sixth page
11 and ends on the seventh page and has 11 categories. Did
12 you have a chance to review that document request
13 before?
14 A. Yes.
15 Q. Okay. And it's my understanding that you
16 brought with you today documents that are responsive to
17 all the categories in those requests. Correct?
18 A. Correct.
19 Q. And those documents are Exhibit -- Exhibit 36,
20 37, and 38; correct?
21 A. Correct.
22 Q. And that's all the documents that are
23 responsive to the document request that is part of
24 Exhibit 34, your deposition notice; correct?
25 A. Correct.
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1 Q. Okay.
2 MR. WILLIAMSON: Let me clarify that.
3 MR. PERETZ: Yes. I'm sorry. There was also
4 a CD that was handed to me yesterday with additional
5 documents. And those are also documents that are
6 responsive to the deposition notice served on Sarah
7 Dunford; is that correct?
8 MR. WILLIAMSON: Correct.
9 MR. PERETZ: Okay.
10 MR. WILLIAMSON: Also your question, I think --
11 We can go back to read it. I think the understanding is
12 clear that she has produced everything that is
13 responsive. It doesn't mean that everything she
14 produced responsive to this category.
15 MR. PERETZ: I understand.
16 MR. WILLIAMSON: The record is clear. If you
17 go look and say, well, there is nothing here about
18 her -- about the Breezes' children's tuitions, that's
19 because she has no documents and had nothing to do with
20 that.
21 MR. PERETZ: All right. I totally understand
22 that.
23 MR. WILLIAMSON: And some of these documents
24 are requested both of Ms. Dunford and Ms. Brumfield, who
25 is our next deposition, and I have produced all of them
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1 to you at this point, no matter which one of the

2 witnesses gave me the documents, because they relate to
3 both women and they both worked there.
4 MR. PERETZ: Okay. No problem, and I
5 appreciate that.
6 BY MR. PERETZ:
7 Q. Ms. Dunford, just so we have some clarity here,
8 why don't you go through the document request, the 11
9 categories, and tell me for which category you did not
10 find any responsive documents. It starts at page 6
11 with 1, 2, 3 and so forth.
12 A. Okay.
13 Q. I only want you to tell me which ones you did
14 not have any documents that are responsive. Are you
15 understanding me?
16 A. I am.
17 Q. Okay. Thank you.
18 MR. PERETZ: Let's go off the record for a
19 second.
20 (Off the record.)
21 MR. PERETZ: Let's go back on the record.
22 BY MR. PERETZ:
23 Q. Ms. Dunford, did you have a chance to review
24 the 11 categories of documents in your deposition
25 notice?
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1 A. I did.
2 Q. Okay. Which categories you did not bring any
3 responsive documents (sic)?
4 A. Three.
5 Q. Anything else?
6 A. I believe five.
7 Q. Okay. You believe, but you are not 100-percent
8 sure; correct?
9 A. Correct.
10 Q. That's fine.
11 A. And therefore 6 and 7.
12 Q. Okay.
13 A. I believe there were no third party who
14 provided the IT services that I communicated with, item
15 10.
16 Q. So you don't have responsive documents for this
17 category, obviously.
18 A. Not that I recall.
19 Q. No problem. Anything else?
20 A. No.
21 Q. Thank you.
22 In terms of your efforts to produce documents
23 in part -- as part of this litigation, what actions did
24 you undertake?
25 A. I went into all of my email accounts.
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1 Q. And when you say "all of my email accounts,"

2 which email accounts are you referring to?
3 A. I have my personal email, all my old
4 sarahdunford@theevansschool.com --
5 Q. Okay.
6 A. -- sarahdunford@evansschool.org, communication
7 @evansschool.org. I believe it's
8 wasc@theevansschool.com, admin@theevansschool.com,
9 development@theevansschool.com.
10 Q. You are one busy individual.
11 So out of The Evans School email accounts,
12 which one is active currently?
13 A. Sarahdunford@evansschool.org --
14 Q. That's the only active email address?
15 A. No. I am giving you a chance to write it down.
16 Q. Thank you. I apologize.
17 A. -- and communication@evansschool.org.
18 Q. Um-hum.
19 A. They are all active. They are all -- They are
20 active in that I have access to them.
21 Q. Okay. Fair enough.
22 Do you not use any of them?
23 A. I do use currently
24 communication@evansschool.org,
25 sarahdunford@evansschool.org.
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1 Q. That's the two that you actively use?

2 A. Correct.
3 Q. But you have access to all these six email
4 addresses?
5 A. Yes, because they were prior used email
6 addresses.
7 Q. Okay. And do they all roll out to one account;
8 meaning you have one platform in which all the emails
9 roll in?
10 A. At some point they have.
11 Q. Okay.
12 A. But currently, no, they do not all roll out
13 into that.
14 Q. Because they are not active?
15 A. Correct. Because I don't function with them.
16 Q. So you looked at all the email addresses that
17 you just mentioned.
19 Q. What else did you look into?
20 A. WASC documentation.
21 Q. That's on the WASC website; correct?
22 A. No.
23 Q. That's a folder?
24 A. Sarah Brumfield and I went through -- Sarah
25 Brumfield and I pulled out the documentation that was
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1 required, anything to do with WASC.

2 Q. And where did you pull it out from?
3 A. From a folder or a binder.
4 Q. Okay. So you have a binder that includes all
5 the WASC communication or material?
6 A. I believe that has been provided. I don't have
7 an individual one.
8 Q. It's the school one?
9 A. It's Sarah and mine combined.
10 Q. Okay. Just to make it clear -- Again, there is
11 nothing wrong. I just want to get some clarity here.
12 A. Um-hum.
13 Q. Sarah Brumfield and you have a physical file
14 for all WASC-related documents; correct?
15 A. Correct.
16 Q. And you looked through that folder, file, and
17 provided to the attorney documents that are responsive.
18 A. Sarah Brumfield informed me that she had done
19 that. She physically did that. I did not.
20 Q. She did that. She told you that she did that;
21 correct?
22 A. Correct.
23 Q. What actions did you undertake to provide
24 documents for this deposition other than what you
25 discussed?
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1 A. That's the only documentation that relates, I

2 believe.
3 Q. Okay. My understanding is that you also went
4 to the WASC website.
5 A. I did not go to the WASC website.
6 MR. WILLIAMSON: Sarah Brumfield.
7 MR. PERETZ: Okay.
8 BY MR. PERETZ:
9 Q. So Exhibit 37 appears to be a document that was
10 pulled out from the WASC website. You did not do that.
11 That was Sarah Brumfeld?
12 A. Brumfield.
14 Now, Exhibit 36 is a document that you
15 authored; correct?
16 A. I believe I did, yes.
17 Q. And where did you find this document?
18 MR. WILLIAMSON: Assumes facts.
19 BY MR. PERETZ:
20 Q. You can answer that. On occasions your
21 attorney will make objections.
22 A. I did not provide this. I believe Ms. Gale
23 found it on her computer.
24 Q. Okay. But you were actually the one that typed
25 the document?
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1 A. I did, and I did find it last night in this

2 form.
3 Q. In your email?
4 A. No. On my hard drive.
6 And now another question I have: Exhibit 38,
7 is this the product of looking through your email
8 accounts and printing out stuff that is relevant?
9 A. Correct.
10 Q. Okay. Can you -- It seems like at some point
11 these documents were placed in a three-ring binder.
12 A. They were.
13 Q. Correct?
14 A. Correct.
15 Q. Okay. When was that?
16 A. About three days ago.
17 Q. Okay. So when did you actually go through all
18 the emails and pull the documents?
19 A. I have been doing it over time. I started
20 approximately four weeks ago to start looking.
21 Q. Okay. And then whenever you saw something
22 responsive, you printed it out?
23 A. I flagged lots of emails that I initially saw
24 but then somehow lost those flags.
25 Q. Oh, that's fun.
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1 A. Yeah. So then I went into each -- I went

2 through my mail app to initially find the emails but was
3 not finding everything I thought was there. So I went
4 into Google -- specifically signed into each Google
5 account and went in that way, instead of using the mail
6 platform or the mail app.
7 Q. Was the process then that you printed out the
8 documents --
9 A. Correct.
10 Q. -- so you don't flag them and lose that again?
11 What was the reason for that?
12 A. Well, I initially flagged them so I didn't lose
13 them --
14 Q. Okay. I see.
15 A. -- when I was gathering evidence.
16 Q. Okay. So ultimately --
17 A. I had moved house. My printer wasn't working.
18 I was doing it when I had time to do it.
19 Q. Okay. So at some point -- Many of the
20 documents have a date stamp of September 1st, '14.
21 A. Correct.
22 Q. So is that the date that you printed the
23 majority of them?
24 A. No.
25 Q. All right.
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1 A. I did not print those on September 1st. I

2 started forwarding them --
3 Q. I see.
4 A. -- and flagged them that way with the date
5 stamp. So a lot of them -- I was forwarding them from
6 my Google account to my mail account so that I have one
7 clear list so it would be easier to print, but
8 ultimately that's not how I gathered these documents to
9 print them.
10 Q. Okay. So at some point you printed all the
11 documents, and then you placed them in a three-ring
12 binder; correct?
13 A. Correct.
14 Q. And then you gave them to the attorney?
15 A. Correct.
16 MR. PERETZ: And Mr. Williamson, are there any
17 documents that were withheld based on any privilege?
18 MR. WILLIAMSON: One. Actually -- I am
19 sorry -- two.
20 MR. PERETZ: Two documents.
21 MR. WILLIAMSON: There was a note from the
22 witness to me, and there was a set of -- a memo from the
23 witness to -- from Ms. Brumfield and Ms. Dunford that
24 was prepared at my request.
25 MR. PERETZ: Okay. So these two documents that
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1 were there are the only ones that were withheld under
2 the privilege?
3 MR. WILLIAMSON: Yes. And I don't believe that
4 there was anything in the disc/binder that was redacted.
5 MR. PERETZ: Yeah, I don't believe so. If it's
6 redacted, it can still appear.
7 MR. WILLIAMSON: Okay.
8 BY MR. PERETZ:
9 Q. Ms. Dunford, indeed you prepared this memo for
10 Mr. Williamson?
11 A. Correct.
12 Q. When was that? And don't tell me anything that
13 was in the memo, but what was the date that you prepared
14 the memo?
15 A. Sunday or Monday of this week. Sunday and
16 Monday three or four days ago.
17 MR. WILLIAMSON: That would be the note. I
18 believe the memo is probably --
19 THE WITNESS: You are referring to the memo?
21 THE WITNESS: August of last year, I think. I
22 can't remember exactly.
23 BY MR. PERETZ:
24 Q. So the note that you prepared for
25 Mr. Williamson was prepared a few days ago.
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1 A. The handwritten notes that I placed with the

2 documents, yes.
3 Q. I see. Okay.
4 And then you prepared a typed memo with
5 Ms. Brumfield approximately a year ago?
6 A. Correct.
7 Q. Okay. And you provided that to Mr. Williamson,
8 correct, that memo?
9 A. Correct.
10 Q. Okay. And that was a memo prepared at his
11 request; correct?
12 A. Correct.
13 Q. Okay. Just making sure.
14 And you know Alex and Albert Rome?
15 A. Yes.
16 Q. And I believe Albert Rome also goes by Chip;
17 correct?
18 A. Correct.
19 Q. Okay. How long have you known them?
20 A. I have known them since their children started
21 at Evans in kindergarten, so approximately six years,
22 five years.
23 Q. Five or six years ago?
24 A. Correct.
25 Q. Okay. And did any of their kids ever went
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1 through your class or was in your class (sic)?

2 A. Yes.
3 Q. And when was the first time that that happened?
4 A. When -- Fall of 2010.
5 Q. And you are teaching what grades?
6 A. Can I correct?
7 Q. Sure.
8 A. January 2011.
9 Q. And can you just remind me of which classroom
10 do you teach?
11 MR. WILLIAMSON: At that point?
12 THE WITNESS: At that point?
13 MR. PERETZ: Correct.
14 THE WITNESS: That was fourth grade.
15 MR. PERETZ: Oh, okay.
16 BY MR. PERETZ:
17 Q. And I'm just curious. Why was it in the middle
18 of the school year?
19 A. I was on maternity leave.
20 Q. And you came back January 11?
21 A. Correct.
22 Q. And that was first grade then?
23 A. Yes.
24 Q. And how long have you been teaching at
25 The Evans School?
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1 A. 12 years.
2 Q. So ever since 2002, approximately?
3 A. 2002, correct.
4 Q. Okay. Do you have teaching credentials?
5 A. I do.
6 Q. When did you obtain those?
7 MR. WILLIAMSON: First obtained in any
8 jurisdiction?
9 MR. PERETZ: Any jurisdiction including the UK.
10 They do have teachers there.
11 THE WITNESS: And very good credentials.
12 MR. PERETZ: I'm sure.
13 THE WITNESS: That would be 2007.
14 MR. PERETZ: Okay.
15 BY MR. PERETZ:
16 Q. And that was in the UK or was it here?
17 A. I need to correct.
18 Q. Sure.
19 A. 1997.
20 Q. Sorry. That's okay.
21 And just so we have a timeline: When did you
22 move to the States? I assume that you did.
23 A. I did. August 2000.
24 Q. Okay. So you obtained -- you first obtained
25 your teaching credential in England in 1997?
800.211.DEPO (3376)
YVer1f
1 A. Correct.
2 Q. Okay. And did you attend college or university
3 in England?
4 A. I did.
5 Q. When was that?
6 A. From '93 to '97.
7 Q. In what year?
8 A. In London.
9 Q. I'm sorry.
10 A. Oh, beg your pardon.
11 Q. Okay. What area of study?
12 A. Education and English language and linguistics.
13 Q. And did you obtain a degree?
14 A. Yes.
15 Q. What degree?
16 A. Bachelor's.
17 Q. And what was the name of the institution?
18 A. It was -- At the time it was called -- well,
19 Surrey University -- University of Surrey.
20 Q. Did it change name ever since?
21 A. I believe it may have.
22 Q. And do you know the new name by any chance?
23 A. No.
24 Q. And then when did you obtain your teaching
25 credentials in the UK?
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YVer1f
1 A. I did not clear California credential.

2 Q. Okay. So you don't have California teaching
3 credential?
4 A. Correct.
5 Q. Okay. Did you attend any school or schooling
6 in the United States?
7 A. I did.
8 Q. What was that?
9 A. To begin my California credential, to clear my
10 California credential.
11 Q. And when was that?
12 A. 2001 through '02.
13 Q. But you didn't complete the process?
14 A. Correct.
15 Q. Okay. Any other schools in the States?
16 A. In which I have worked?
17 Q. No. I'm sorry. I apologize.
18 Did you attend any other school or university
19 or college in the States?
20 A. No.
21 Q. Okay. And where did you study toward your
22 California teaching credential, in what institution?
23 A. UCSD.
24 Q. And do you currently have any professional
25 licenses in the States?
800.211.DEPO (3376)
YVer1f
1 A. No.
2 Q. Do you have any certifications in the States?
3 A. No.
4 Q. So you have professional licenses or
5 certificates in the UK?
6 A. Yeah.
7 Q. What do you have?
8 A. Qualified teacher status.
9 Q. And that's from 1997?
10 A. Yes.
11 Q. Okay. Anything else?
12 A. No.
13 Q. And I don't think we have established that, but
14 you were born and raised in the UK; correct?
15 A. Correct.
16 Q. Okay. So the first time that you had any of
17 the Rome children in your class was the beginning of
18 your school year 2011; is that correct?
19 A. Yes.
20 Q. And prior to that, were you in any type of
21 communications with the Romes?
22 A. Only in passing, as I would be with any other
23 parent in the school.
24 Q. It's a small school, so people say "Hi" to each
25 other.
800.211.DEPO (3376)
YVer1f
1 A. Exactly.
2 Q. So it was just --
3 A. Informal.
4 Q. -- informal? Okay.
5 At some point did you develop a friendship with
6 the Romes?
7 A. I would not say a friendship. I would say a
8 connection.
9 Q. And what do you mean by "a connection"?
10 A. We had a British connection. Alex,
11 Mrs. Rome -- Alex Rome and I obviously, being both
12 British, we collaborated on a tea for the school to
13 celebrate the royal wedding.
14 Q. Fair enough.
15 A. I mean --
16 Q. For non-English people: Which wedding are you
17 referring to?
18 A. The wedding of Prince William and Kate
19 Middleton.
20 Q. Okay. And remind me: What year was that? I
21 apologize. That was 2012?
22 A. Prior, I believe.
23 Q. Okay. Was it prior? They are married so long?
24 A. I don't recall. I don't know.
25 Q. Was it before her son joined your class, so you
800.211.DEPO (3376)
YVer1f
1 can have that as a time mark?

3 Q. That's okay. We will not belabor that. Tell
4 that to anyone back home.
5 So that was essentially the first event that
6 you were in more communication?
7 A. Correct.
8 Q. Okay. And where did this tea party take place?
9 A. At The Evans School.
10 Q. And who participated in that?
11 A. The whole school.
12 Q. So it was a school event?
13 A. Correct.
14 Q. Okay. But you and her organized that event?
15 A. She organized the tea party itself. I took the
16 role of educating the children about the British royal
17 family in assemblies and helped on the day of the tea
18 to -- hands-on. "What do you need me to do?"
19 Q. Okay. And why don't you go through how your
20 relationship with Ms. Rome developed after that tea
21 party.
22 MR. WILLIAMSON: Lacks foundation, assumes
23 facts.
24 You can answer. Go ahead.
25 THE WITNESS: It didn't really. That weekend,
800.211.DEPO (3376)
YVer1f
1 I believe, I went to her house, along with some other

2 mothers, to watch a video recording of the royal wedding
3 due to it being on in the middle of the night. That --
4 But beyond that, I have had no socialization out of
5 school with the Romes at all.
6 BY MR. PERETZ:
7 Q. Did you have any socialization with them
8 outside of the school ever since that tea party?
9 A. I -- I had lunch with Alex at her request.
10 Q. When was that?
11 A. Just to be clear: Late spring of 2013.
12 Q. Late spring? April? May?
13 A. May.
14 Q. Okay. Any other events in which you socialized
15 with Alex Rome?
16 MR. WILLIAMSON: Outside of school?
17 MR. PERETZ: Inside or outside the school.
18 THE WITNESS: I believe she attended a birthday
19 party of a co-parent that I was at -- of another parent.
21 THE WITNESS: I was at a parent's birthday
22 party, and she was also a guest.
23 BY MR. PERETZ:
24 Q. And when was that?
800.211.DEPO (3376)
YVer1f
1 Q. Was it during the last two years?

2 A. I believe not.
3 Q. So it was 2011/2012?
4 A. I believe so. I don't know.
5 Q. That's okay. That's your best estimation?
6 A. Correct.
7 Q. Okay. Don't feel bad if I ask you dates and
8 you don't know.
9 A. Yeah. I had a lot going on in my life, and it
10 was very fuzzy -- a very fuzzy time.
11 Q. So I struck that chord. I apologize.
12 Okay. Any other social events that you and
13 Alex Rome attended?
14 A. I believe there was one -- and this was many
15 years ago -- one tea party at the Shakespeare Tea Room
16 with other mothers, but she invited me too, along with
17 other mothers.
18 Q. And that was more than three or four years ago?
19 A. Yes.
20 Q. Okay. After May of 2013, did you ever
21 socialize with Alex Rome?
22 A. No.
23 Q. And I assume you never socialized with Albert
24 Rome.
25 A. Correct.
800.211.DEPO (3376)
YVer1f
1 Q. And when was the last you were in communication

2 with Alex Rome up until the present?
3 A. Can you clarify "communication."
4 Q. Yes. "Communication" means anything that
5 includes phone, email, text, in person.
6 A. Yesterday.
7 MR. WILLIAMSON: I was going to say: Can we
8 clarify whether you are talking about one-on-one or --
9 I mean, if she sent something on behalf of the school to
10 all parents, you know, that's -- that's a much broader
11 universe.
12 MR. PERETZ: I see. Sounds good.
13 MR. WILLIAMSON: And there is an enormous
14 quantity of information which I don't think has anything
15 to do here.
16 MR. PERETZ: I would agree. That's good. Now
17 we have a clarification here.
18 BY MR. PERETZ:
19 Q. What was the nature of the communication
20 yesterday? I am going to take it --
21 A. I waved at her.
22 Q. You saw her at school and you --
23 A. I saw her at school.
24 Q. Let's not include in "communications" just
25 waving. It was vague and --
800.211.DEPO (3376)
YVer1f
1 A. "Hi."
2 Q. Or "Good morning." Anything more than that?
3 And not school emails that go school-wide and she is one
4 of those recipients.
5 A. Okay.
6 Q. What was your last communication of that nature
7 with Ms. Rome?
8 A. She emailed me regarding an issue with her son.
9 Q. When was that?
10 A. I believe last weekend or the weekend before.
11 Q. And that was only about her son?
12 A. Correct.
13 Q. Was there anything else there other than
14 discussion about the issue with her son?
15 A. No.
16 Q. Okay. When was the previous communication
17 between you and Alex Rome?
18 MR. WILLIAMSON: Previous?
19 MR. PERETZ: Previous to this one that you just
20 described.
21 MR. WILLIAMSON: Are you looking for things
22 that are specifically between a teacher and a parent
23 about a student?
24 MR. PERETZ: Well, we can -- we'll see how
25 frequent it is, and then we may deal with that a little
800.211.DEPO (3376)
YVer1f
1 more.
2 THE WITNESS: I keep my relationship at school
3 very personal. And when I'm at school I'm a teacher and
4 I focus on being a teacher, so any communication I have
5 with a parent is usually regarding the student or an
6 issue.
7 MR. PERETZ: Okay.
8 BY MR. PEREZ:
9 Q. It seems that in May of 2013 there was some
10 communication that didn't involve just your teaching;
11 correct?
12 A. Correct.
13 Q. Okay. And it started with Ms. Rome asking you
14 for lunch? Is that how it started?
15 A. Yes.
16 Q. Okay. And why don't you tell me. How did
17 she approached you (sic)? How -- What did she do to
18 approach you?
19 A. She came up to me at school and said that she
20 was at her wit's end and very distraught about the
21 situation with the Breezes and that she couldn't take it
22 anymore and wanted some advice on how -- She just
23 wanted, I guess, to express her frustration and concern
24 for Rimma and how to best figure out a harmonious
25 relationship at school and out of school.
800.211.DEPO (3376)
YVer1f
1 Q. And is that a discussion you had when she asked

2 you to go to lunch or are you more bringing that into
3 what happened during lunch?
4 A. Both.
5 Q. Okay.
6 A. She said, "Can we meet for lunch?"
7 Q. Okay. I want to go kind of blow by blow, step
8 by step --
9 A. Sure.
10 Q. -- just because I don't want to confuse the
11 event. Let's focus on the first time she approached
12 you. Fair enough?
13 A. Correct.
14 Q. Okay. Was that the first time she ever
15 approached you with an issue involving Rimma Breeze?
16 A. No.
17 Q. When was the first time that Ms. Rome
18 approached you with an issue about Rimma Breeze?
20 Q. Was it a year or two years prior to that?
21 A. Probably when I was teaching -- when both boys
22 were in my care in first grade.
23 Q. Meaning the Breezes' boy and the Romes' boy?
24 A. Correct.
25 Q. And when was that? 2010 or 2011?
800.211.DEPO (3376)
YVer1f
1 A. January 2011.
2 Q. In January of 2011 Ms. Rome approached you
3 about Rimma; correct?
4 A. Not about Rimma.
5 Q. What was -- What did she approach you about?
6 A. It was about how it was difficult that the
7 boys -- She was being accused of not including Rimma or
8 Augie or Colin in any play dates or parties or social
9 events and the like.
10 Q. Did she come to you and she told you she was
11 being accused about this and that and the other, or how
12 did you find out about that?
13 A. I don't recall the exact conversation.
14 Q. Okay. Did she mention to you who accused her
15 of that?
16 A. No.
17 Q. Okay. Did you ever have any discussion with
18 Rimma Breeze about the situation -- her situation with
19 the Romes?
21 Q. Okay. So Ms. Breeze never approached you to
22 discuss anything about Alex -- correct, as you sit
23 here -- about Alex Rome?
24 A. As I recall, no.
25 Q. I am correct? Let me rephrase that. When I
800.211.DEPO (3376)
YVer1f
1 use double-negatives, sometimes it's confusing.

2 Ms. Breeze never approached you to discuss
3 anything about either Albert or Alex Rome? I am
4 correct?
5 MR. WILLIAMSON: That you recall.
6 THE WITNESS: I really don't recall.
7 MR. PERETZ: Okay.
8 BY MR. PERETZ:
9 Q. As you sit here today, do you have any
10 recollection of Rimma approaching you to discuss her
11 relationship with the Romes?
12 MR. WILLIAMSON: Asked and answered. She has
13 told you three times she doesn't recall.
14 BY MR. PERETZ:
15 Q. You can answer.
16 MR. WILLIAMSON: Tell him again.
17 THE WITNESS: I don't recall.
19 BY MR. PERETZ:
20 Q. You don't recall. Do you mean -- I'm sorry.
21 Maybe I'm splitting hairs.
22 When you say "I don't recall," do you mean you
23 don't recall one way or the other or you are definitive
24 in that Rimma never approached you?
25 A. I don't recall one way or the other.
800.211.DEPO (3376)
YVer1f
1 Q. Okay. Great.
2 So Ms. Rome approached you at some -- at the
3 beginning sometime when you first took your position as
4 the first-grade teacher in January 2011; is that
5 correct?
6 A. Not soon after.
7 Q. About how long after?
8 A. I don't know.
9 Q. Okay. It was during that school year, though;
10 correct?
11 A. Correct.
12 Q. And other than what you had stated before, what
13 else did she tell you?
14 A. That was all.
15 Q. Okay. And what was your response to that?
17 Q. Did you do anything about her statement other
18 than just respond to her? Did you get anyone involved?
19 Did you report that to Ms. Baer, Ms. Augustine, Rimma
20 Breeze? Anyone else?
21 A. I don't believe I did, because --
22 Q. Okay.
23 A. -- I knew they were already aware of the
24 situation.
25 Q. How did you know that?
800.211.DEPO (3376)
YVer1f
1 A. Because I had heard them -- They had talked to

2 me about this, and everybody was aware of the tension
3 between the Romes and the Breezes.
5 A. General knowledge.
6 Q. Okay. No problem.
7 And then when was the next time that Ms. Rome
8 approached you about issues with the Breezes?
9 A. Probably that time, May 2013.
10 Q. Okay. And when she asked you for lunch or
11 invited you to go to lunch, what did she tell you? And
12 try to focus on that discussion.
13 A. Sure. She said, "I need some advice. I'm at
14 my wit's end. Can we meet because -- and talk sense?"
15 You know, "You are a voice of reason. Can you meet with
16 me discretely."
17 Q. Okay. And did she approach you at school when
18 she talked to you or did she call you after school?
19 A. I believe she caught me, you know, outside on
20 campus and just mentioned it to me.
21 Q. Okay. And you obviously agreed; correct?
22 A. I did.
23 Q. Okay. Did you report to anyone about this
24 conversation at that point?
25 A. I did.
800.211.DEPO (3376)
YVer1f
1 Q. To whom?
2 A. Ms. Gale.
3 Q. Okay. And what was her reaction? Meaning
4 Ms. Gale's reaction.
5 A. I asked her if she'd like me to proceed with
6 the conversation; I would do whatever she advised me
7 she'd like me to do. And she felt that she'd like
8 anything done to resolve the conversation -- to resolve
9 the issue, that a conversation would be perfectly
10 suitable and appropriate.
11 Q. Okay. So she basically gave you the green
12 light to meet for lunch with Ms. Rome; correct?
13 A. Correct.
14 Q. Okay. And where did you meet for lunch?
15 A. Where?
16 Q. Yes, where.
17 A. I don't recall the name of the restaurant. It
18 is a Greek restaurant near UTC --
19 Q. Okay.
20 A. -- next to -- opposite UTC. There is a Greek
21 restaurant next to the fancy market. I don't recall the
22 name of it.
23 Q. No problem. It's not that critical.
24 A. Um-hum.
25 Q. And what were you told during that
800.211.DEPO (3376)
1 conversation? Meaning the lunch meeting.

2 A. I was told that Alex felt that her character --
3 her own character was being defamed because she was
4 being accused of things that were unfounded by the
5 Breezes.
6 Q. And what did she say about the -- Did she give
7 you a list of the accusations or did she mention any of
8 the accusations?
9 A. She mentioned them. We talked about it.
10 Q. Please, what did she mention?
11 A. She basically was being accused of being
12 exclusive to the Breezes. Let me clarify. The Breezes
13 were being excluded specifically by her --
14 Q. Okay.
15 A. -- at any social event that was taking place,
16 and she was being accused that she was not inviting or
17 including them. However, in our previous conversation
18 in the classroom and at that lunch meeting she
19 absolutely was adamant that that had not occurred, and
20 she gave some pointers in terms of examples of when
21 she had specifically included Augie in social events.
22 Q. At that time when you went to the lunch
23 meeting, did you have the boys in your class or was
24 it --
25 A. Let me think.
800.211.DEPO (3376)
YVer1f
1 Q. May of 2013. That's what you mentioned.

2 A. They were -- Can I -- Can I specify
3 specifically -- I can specify specifically that I was
4 teaching some third-grade classes at the time. I
5 believe Augie was in third grade, but I was not the
6 home-room teacher, so I was not responsible for his
7 overall welfare. And, in fact, he was not in any of my
8 classes because Ms. Gale had made accommodations for his
9 academics individually, so I had very little contact
10 with Augie.
11 Q. Was Ms. Rome's child in the third-grade class?
12 A. One was --
13 Q. Okay.
14 A. -- at the time.
15 Q. Okay. So you were teaching both of them?
16 A. I had contact with both of them, yes.
17 Q. I just wanted to get the context a little bit.
18 No problem.
19 What other examples of false accusations did
20 Ms. Rome give you in May of 2013 at the lunch?
21 A. That was basically it.
22 Q. Basically the accusation is that she, Ms. Rome,
23 is accused that she is excluding the Romes (sic) from
24 some social events; correct?
25 A. Yes.
800.211.DEPO (3376)
YVer1f
1 Q. So my question --
2 (Off the record.)
3 MR. PERETZ: Yes, I will fix my question. I
4 apologize. I didn't mean to confuse you.
5 BY MR. PERETZ:
6 Q. The basic tenet of Ms. Rome's allegation or
7 statements to you during the lunch meeting was that she
8 is being accused -- "she" meaning Ms. Rome -- is accused
9 from excluding the Breezes from social events; correct
10 (sic)?
11 A. Correct.
12 Q. And then you were in the midst of describing
13 something else, and why don't you go there. What other
14 examples, defamation or accusations, did Ms. Rome tell
15 you during this lunch meeting other than general -- what
16 seems to be a somewhat general accusation?
17 MR. WILLIMSON: If any.
18 MR. PERETZ: If any. Yes, of course.
19 THE WITNESS: That was basically the crux; that
20 she was frustrated because she thought they were totally
21 unfounded.
22 BY MR. PERETZ:
23 Q. Now, did she mention who accused her?
24 A. Yes.
25 Q. How do you know that?
800.211.DEPO (3376)
YVer1f
1 A. Ms. Gale had met with both parties, and I was

2 privy to that information.
3 Q. That was earlier than May of 2013, though; no?
4 A. I believe Ms. Gale met with Alex prior to that
5 meeting.
6 Q. I see.
7 A. Separately from any meeting that occurred with
8 the Breezes.
9 MR. WILLIAMSON: Just so we are clear: There
10 was -- There were several meetings --
11 MR. PERETZ: I understand.
12 MR. WILLIAMSON: -- involving Ms. Baer.
14 MR. WILLIAMSON: So when you say that was
15 prior, I suspect you have in mind the meeting that
16 involved Ms. Forssman and Ms. Hixon, and that was
17 probably not the same meeting that Ms. Dunford was --
18 MR. PERETZ: That's where I'm getting. I'm
19 going to get to all the timelines and all the meetings,
20 unfortunately.
21 THE WITNESS: Correct.
22 BY MR. PERETZ:
23 Q. So there was a meeting September of 2012 that
24 involved Ms. Forssman and Ms. Baer and the Breezes and
25 Ms. Rome. You didn't have anything to do with that
800.211.DEPO (3376)
YVer1f
1 meeting; correct?
2 A. I had nothing to do with that meeting.
3 Q. I am just trying to establish the timeline.
4 I'm not trying to pester you. Is that okay?
5 A. That's fine.
6 Q. And then when Ms. Rome approached you, did she
7 report to you that she met with Ms. Gale separately?
8 A. Yes.
9 Q. And so was this the reason she was at her wit's
10 end; meaning the meeting with Ms. Gale?
11 A. I believe so.
12 Q. Okay. And do you recall how long before you
13 met Ms. Rome for lunch did she meet with Ms. Gale?
14 A. My best guess would be a couple of weeks.
15 Q. Your best estimate? We don't like guessing.
16 A. Estimate. Sorry.
17 Q. So -- No problem.
18 So you took from what she said that somehow
19 Ms. Baer informed Ms. Rome of accusations that she is
20 excluding the Breezes from social events; correct?
21 A. At that point Ms. Gale was feeling that -- At
22 that point Ms. Gale did not have all the facts regarding
23 communications that had gone on --
24 Q. How do you know --
25 A. -- and therefore Ms. Gale was feeling that Alex
800.211.DEPO (3376)
YVer1f
1 was the one causing trouble.

2 Q. I see. Okay.
3 That was your impression?
4 A. Yes.
5 Q. And that's your impression based on your lunch
6 meeting with Ms. Rome; correct?
7 A. I believe things had taken place between
8 Ms. Gale and Alex.
9 Q. And that's before Alex approached you; correct?
10 A. Correct.
11 Q. How did you know about that meeting?
12 A. I knew the meeting had taken place. I did not
13 know what had been discussed within the meeting, but I
14 had seen Alex leave the meeting looking very flustered.
15 Q. I see.
16 And when Alex left the meeting looking
17 flustered, did you exchange any words with her?
18 A. No.
19 Q. You just happened to see her?
20 A. Correct.
21 Q. Okay. And then she approached you a couple
22 weeks later; correct?
23 A. Correct.
24 Q. That's the setup for the lunch?
25 A. That's how I recall it.
800.211.DEPO (3376)
YVer1f
1 Q. Again, I am trying to find out information.

3 Q. Now, other than the accusation and that she is
4 falsely accused -- Strike that.
5 Other than the statement that Ms. Rome made
6 that she is being falsely accused of excluding the
7 Breezes, did she make any allegations to you in the May
8 lunch meeting about the Breezes?
9 A. No.
10 Q. Okay.
12 Q. Did she mention, for example, that Rimma and
13 the Breezes are sending nasty emails to various people?
14 A. There was one mention of one email, but I don't
15 recall the detail.
16 Q. Okay. All you remember is that there was one
17 email?
18 A. I believe -- Could you repeat the question?
19 Q. Sure.
20 Was -- My question was whether Ms. Rome told
21 you that Rimma or the Breezes sent out negative emails
22 about them, something to that effect.
23 A. No.
24 Q. Okay. So what email -- what came up in the
25 context of this one email?
800.211.DEPO (3376)
YVer1f
1 A. In your question it reminded me that there has

2 been an email, I believe, from another parent just
3 discussing some situation that -- some communication, I
4 think, that they didn't want -- they were tired of
5 having the Breezes' child in the class.
6 Q. Okay. But that has nothing to do with
7 Ms. Rome.
8 A. Correct. Exactly. That's why I --
9 Q. Okay.
10 A. That's on a tangent. Sorry.
11 Q. No problem. That was --
12 A. Just going through my memory.
13 Q. I get that, but that has nothing to do with
14 Ms. Rome or --
15 A. Correct.
16 Q. -- or the relationship between Ms. Rome and
17 Ms. Breeze; correct?
18 A. Correct.
19 Q. Okay. And that was an issue with -- that
20 apparently a child had with Ms. Breeze's child in the
21 classroom.
22 A. Correct.
23 Q. Okay. And at this -- Do you have any other
24 recollection -- Do you recall anything else that came up
25 during that meeting -- that lunch meeting?
800.211.DEPO (3376)
YVer1f
1 A. General chitchat. We talked about how Alex had

2 kept all of her email documentation to prove that she
3 had, in fact, included the Breezes in every social setup
4 that she had been involved in.
5 Q. Okay. Did she bring those documents to that
6 lunch or she just mentioned it?
7 A. She did not. She mentioned it.
8 Q. Okay. Anything else that was mentioned there?
10 Q. Did she mention to you that she wants you to
11 speak with Gale there or someone else on her behalf, or
12 what did she ask from you?
13 A. She was just asking, "Sarah, what do I do
14 here?"
15 Q. I see.
16 A. I suggested that she -- She told me that she
17 had every single email communication and that she -- and
18 I suggested -- because I felt that Ms. Gale was not
19 getting both sides of the story, I suggested to Alex
20 that she provide those emails in a binder --
21 Q. Okay.
22 A. -- to give to Ms. Gale.
23 Q. Okay. And then later on Ms. Rome gave you that
24 binder; correct?
25 A. Correct. The next day.
800.211.DEPO (3376)
YVer1f
1 Q. The next day. Okay. The next day she gave you
2 the binder.
3 And what did you do with the binder?
4 A. I kept it in my classroom -- in a cupboard in
5 my classroom.
6 Q. And then where is this binder, if you know?
7 A. Currently? It is in the possession -- I don't
8 know where it is. I provided it to Ms. Gale but not
9 directly.
10 Q. How did you provide it to Ms. Gale?
11 A. She was going to North Carolina that evening,
12 and I emailed her and told her that -- that I had a
13 binder that Alex had given to me containing email
14 evidence and that I knew that -- that she was trying to
15 stay neutral and thought, if she wanted the binder, I --
16 I didn't want to say "Here's a binder." I told her
17 where it was located if she wanted to take it with her
18 to review.
19 Q. And you told her where it is; correct?
20 A. I did.
21 Q. And then it disappeared, meaning she took it?
22 A. She took it.
23 Q. Okay. How do you know she took it?
24 A. She told me.
25 Q. Okay. Later on she told you she took it?
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YVer1f
1 A. Correct.
2 Q. And what else did she tell you after that?
3 A. Who?
4 Q. Ms. Baer. Sorry about that.
5 MR. WILLIAMSON: About the binder or the
6 contents of the binder?
7 MR. PERETZ: Correct.
8 MR. WILLIAMSON: Anything?
9 THE WITNESS: We didn't really discuss the
10 contents of the binder.
11 BY MR. PERETZ:
12 Q. Did Ms. Baer ever have any follow-up discussion
13 about the binder or the relationship between the Romes
14 and the Breezes after she picked up the binder?
15 A. With me?
16 Q. Correct.
17 A. No.
18 Q. Were you informed anything from other
19 individuals about the situation between the Romes and
20 the Breezes after -- after this lunch meeting and
21 getting the binder?
22 A. About what?
23 Q. Let me rephrase it. Okay?
24 A. Please.
25 Q. Sure. You know what, let me take a step back.
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YVer1f
1 So after that Ms. Baer told you "I took the

2 binder"; correct?
3 A. I don't recall if she used those words and she
4 specifically told me, but I recall somehow I knew she
5 had taken the binder because it was missing from my
6 closet.
7 Q. Okay. There was some indication that Ms. Baer
8 took the binder; correct?
9 A. Correct.
10 Q. Okay. You don't remember the exact words?
11 A. (The witness shook her head.)
12 Q. And my question is: Did you ever hear about
13 the -- that binder again?
14 A. No.
15 Q. Have you seen it again?
16 A. No.
17 Q. Do you know if Ms. Baer kept it or destroyed
18 it, or what did she do with it?
19 A. I believe it was in her possession. I have not
20 even seen it.
21 Q. You just make the assumption that it's in her
22 possession?
23 A. She mentioned that she had it somewhere.
24 Q. I see.
25 When -- As late as when did she mention she had
800.211.DEPO (3376)
YVer1f
1 it somewhere?
2 A. Couple months ago.
3 Q. Oh, okay. Fair enough.
4 What was the context that she mentioned that?
5 A. When -- I guess when we knew that this -- the
6 lawsuit was taking place and we were discussing where we
7 were having to start thinking about gathering evidence.
8 Q. So when -- During that time Ms. Baer told you,
9 "We are going to have this binder somewhere"?
10 A. I don't recall exactly the conversation.
11 Q. Okay. But it's something to that effect?
12 A. Yes.
13 Q. Well --
14 A. Yes.
15 Q. Sorry. Again, I'm not trying to pester you.
16 A. Um-hum.
17 Q. Okay. Let me ask you something else.
18 Did you look at the binder when -- What was in
19 the binder when Ms. Rome gave it to you?
20 A. I did.
21 Q. And what do you recall was in that binder?
22 A. There were lots of emails, as Alex had
23 indicated, showing the Romes in the "Sent" line to lots
24 of social events, birthday parties, playdates. That's
25 what I recall seeing.
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YVer1f
1 Q. Other than emails, do you recall anything else

2 that was in the binder?
3 A. That's all that was in the binder.
4 Q. Were the emails just printouts of emails or
5 were any comments made on the emails?
6 A. I believe it was just the emails.
7 Q. Okay. And you say "lots of emails." I mean,
8 "lots" --
9 A. Like --
10 Q. Lots? A stack?
11 A. Maybe 40.
13 Was there any notes that accompanied the emails
14 or --
15 A. No.
16 Q. Okay. So the only thing that was in the binder
17 are printouts of emails; correct?
18 A. Correct.
19 Q. Okay. Did you go through the emails with
20 Ms. Rome at that time?
21 A. No.
22 Q. Did you go through the emails later?
23 A. No.
24 Q. And you said that Ms. Baer didn't have
25 Ms. Rome's side of the story. You said that a couple of
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YVer1f
1 times.
2 A. Yes.
3 Q. Okay. How do you know that Ms. Baer didn't
4 have Ms. Rome's side of the story? I mean, it seems
5 like it's an assumption that you are making. And I'm
6 not saying necessarily that it's untrue. I am just
7 trying to find out how did you come to that opinion.
8 A. Because I was privy to some conversations and
9 knowledge that Gay Dixon was having a lot of ear time
10 with Rimma regarding her issues regarding the Breezes,
11 and any Evans issues. And I felt that Gay was at that
12 point very supportive of Rimma, and therefore I felt
13 that Gale was hearing everything from Gay regarding
14 Rimma but Alex was really not having an opportunity to
15 give her side.
16 Q. I see.
17 And how did you hear that Gay and Rimma were
18 talking about it? Was it Gay that mentioned it to you?
19 A. Yes.
20 Q. Rimma never mentioned that to you?
21 A. No, because Rimma was not on campus from
22 February of that year.
23 Q. February of 2013?
24 A. Correct.
25 Q. Why wasn't she on campus?
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1 A. Because she was sick.

2 Q. Until May? She was sick for three months?
3 A. We did not see her. I personally believed -- I
4 did not see her in that period of time.
5 Q. From February 13th until the end of the school
6 year?
7 A. Pretty much.
8 Q. Okay. So that's six months or so?
9 A. No. Four.
10 Q. I'm sorry. Four months. You are correct.
11 About four months.
13 Q. Is that correct?
14 A. Yes.
15 Q. I'm sorry. You just nodded.
16 A. Yes.
17 Q. That's the reason.
18 A. It's my first nod.
19 Q. It's not the first one; just the first one that
20 didn't accompany a verbal response.
21 MR. WILLIAMSON: Counsel, whenever it's
22 convenient, can we take two or three minutes?
23 MR. PERETZ: Let's take 10 minutes.
24 MR. WILLIAMSON: I would like to keep it short.
25 MR. PERETZ: I will stay here.
800.211.DEPO (3376)
1 (Recess.)
2 BY MR. PERETZ:
3 Q. Ms. Dunford, you want to supplement any of your
4 prior responses?
5 A. Yes.
6 Q. Please do.
7 A. You asked me if Alex had discussed anything
8 else regarding Rimma --
9 Q. Yes.
10 A. -- I believe. I wanted to make the point that
11 Alex -- during the whole conversation her need for doing
12 that was that she generally, truly -- in my opinion --
13 was concerned for Rimma's well-being?
14 Q. Why was that? Why was she concerned for
15 Rimma's well-being.
16 A. Because she felt that she was being
17 unreasonable or unreasonable in her accusation and
18 thought that that's not how they were actually
19 occurring.
20 Q. I get that.
21 When you combined that with the statement that
22 she was concerned for Rimma's well-being, I am getting
23 to a conclusion that there was some underlying
24 assessment by Ms. Rome that Ms. Breeze was detached from
25 reality in some fashion. Are you with me?
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YVer1f
1 A. I was just reporting that that was a comment by

2 Alex. This was not my opinion.
3 Q. I understand that, but did you take it this
4 way; that essentially Ms. Rome is making statements of
5 concern because she thinks that Ms. Breeze has some
6 unrealistic perception of reality?
7 A. I did not take it that way. I took it that no
8 one had seen Rimma around school for several months and
9 that the things that Alex was being accused of were
10 unfounded and that the whole situation was not being
11 shown in a fair light and that Alex -- that Rimma was
12 saying things that were not true about Alex.
13 Q. Yes, but you understood that to be Alex's
14 position; correct?
15 A. Correct.
16 Q. You never confronted Ms. Breeze with any of
17 those accusations; correct?
18 A. I didn't see Ms. Breeze.
19 Q. But you could have contacted her; correct?
20 A. No.
21 Q. No? Because you didn't have her phone number
22 or email?
23 A. No, because that was not my role.
24 Q. Okay. And then -- But you did come to some
25 conclusion that no one is hearing Ms. Rome's position;
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YVer1f
1 correct?
2 A. Repeat that, please.
3 Q. You did -- You were of the opinion that Ms. --
4 Ms. Rome's position wasn't heard? That she is not
5 heard; correct?
6 A. Correct.
7 Q. But you don't know if Ms. Breeze was heard as
8 well; correct?
9 A. I know that Ms. Breeze was heard via Gay Dixon
10 to Ms. Gale in that situation.
11 Q. Okay. I see. Okay.
12 Now, what was your take about the statement
13 that Ms. Rome is concerned about Rimma's well-being?
14 A. I knew that Rimma had been ill, as she had
15 emailed certain people and told them that she was off
16 campus for that reason, and that we hadn't seen her.
17 I didn't know specifically.
18 Also Colin had indicated one night -- I don't
19 recall exactly when -- There had been a problem with
20 technology up at Evans. And we had a dinner event, and
21 Sarah Brumfield and I were there due to our WASC role.
22 And Rimma was supposed to be there, or could have been
23 there, I believe, but was not to be there.
24 Colin came up, and Sarah Brumfield said --
25 knowing that we knew that she had been ill, "How is
800.211.DEPO (3376)
1 Rimma doing?" And Colin just looked at us and shook his

2 head and said something to the effect of "Well, you
3 don't want to know," or "She is really ill," or
4 something to make us be worried about her.
5 Q. When was that? When was this --
6 A. I believe it was post WASC. Maybe February or
7 March time.
8 Q. Oh, so in February Colin said -- you saw Colin,
9 and he mentioned -- indicated, not mentioned --
10 A. Let me retract that. That might not have been
11 February. That might have been -- I'm confused with
12 regards -- regarding the events and when that happened.
13 It could have been an end-of-year event. I don't recall
14 the exact event.
15 Q. Were you informed that at some point Rimma
16 broke her leg or foot?
17 A. Yes, I was.
18 Q. And that was May -- May 13 of 2013?
19 A. (The witness shook her head.)
20 Q. I --
21 A. Okay.
22 MR. WILLIAMS: Take it as an assumption.
23 MR. PERETZ: Yeah.
24 BY MR. PERETZ:
25 Q. Take that as an assumption. You don't remember
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YVer1f
1 that date; correct?

2 A. I don't remember the date.
3 Q. Okay. But that sounds like about right?
4 A. Correct.
5 Q. Okay. Before that, when was the last you heard
6 that Rimma is ill, or sick, or there is something wrong
7 with her?
8 A. After the WASC committee meeting, towards the
9 end of February. So at the end of February.
10 Q. So there was a three-month gap of Rimma -- You
11 didn't hear that Rimma was sick during approximately
12 three months; correct?
13 A. I did hear that Rimma was sick for three
14 months, within that time that she wasn't on campus.
15 Q. Okay. I may be confused now.
16 So when was the end of WASC?
17 A. End of February.
18 Q. Okay. End of February. You hear from Colin --
19 or there is an indication from Colin that Rimma is not
20 doing well; correct?
21 A. I may be confused regarding whether that was
22 the end -- I just know it was a dinner meeting. Sarah
23 Brumfield might be able to clarify that --
24 Q. Okay.
25 A. -- that event.
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YVer1f
1 Q. Okay. In between the end of February until

2 May -- mid-May of 2013, what did you hear that indicated
3 to you that Rimma was ill or sick during that period of
4 time?
5 A. I heard from most people who knew that she was
6 sick for some reason, that she had a bug. There is an
7 email that Rimma sent to another teacher saying that she
8 had had -- had been under the weather and had something
9 horrible and not being able to doing something regarding
10 tech.
11 Q. People get sick. You understand that?
12 A. (The witness shrugged her shoulders.)
13 Q. You have --
14 A. You are asking me?
15 Q. Okay. No. I mean -- Okay.
16 Was it your understanding that this bug or
17 illness took more than the typical two or three or four
18 days to recover?
19 A. Was I under that impression?
20 Q. Yes.
21 A. I knew none of the details specifically
22 regarding any illness or illnesses that Rimma had, but I
23 did know that I had not seen her on campus nor had she
24 been in the usual communication.
25 Q. Did Ms. Rome indicate to you that she believed
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YVer1f
1 that Rimma suffered from some mental episode or mental

2 illness or something like that?
3 A. No. She was just concerned about her general
4 well-being.
5 Q. Why would she be concerned about her general
6 well-being when she is claiming to you that she is being
7 falsely accused by Rimma? Is there something --
8 MR. WILLIAMSON: Calls for --
9 MR. PERETZ: Let me finish.
10 MR. WILLIAMSON: Sorry.
11 BY MR. PERETZ:
12 Q. There is a gap there that I am trying to
13 understand how you took it. And let me explain to you,
14 and then I will ask for a response.
15 On the one hand Ms. Rome initiated that lunch
16 by saying "I am being falsely accused by Rimma Breeze";
17 correct?
18 A. No.
19 Q. Okay. What is incorrect about the statement?
20 A. The lunch was more as to how do we resolve
21 this.
22 Q. Okay. But she did tell you when she approached
23 you that she is being defamed and falsely accused by
24 Ms. Breeze; correct?
25 A. Correct.
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YVer1f
1 Q. Okay. So you get that, that presumably Rimma

2 is defaming Ms. Rome; correct? Presumably. You don't
3 know if it's true or not, but that's the --
4 A. Correct.
5 Q. -- the assumption.
6 On the other hand Ms. Rome is telling you that
7 she is concerned with Rimma's well-being; correct?
8 A. Correct.
9 Q. Okay. And typically, if someone defames you or
10 causes you -- or inflicts pain or damage to you, you
11 don't necessarily -- you are not necessarily concerned
12 of their well-being. Are you following my thread of
13 thought so far?
14 MR. WILLIAMSON: I am not sure if she --
15 BY MR. PERETZ:
16 Q. Do you follow me so far?
17 A. I follow you.
18 Q. So Ms. Rome tells you on the one hand "Rimma is
19 defaming me" and on the other hand she says to you, "I
20 am concerned about Rimma's well-being." How did you
21 interpret these two somewhat conflicting statements?
23 facts.
24 BY MR. PERETZ:
25 Q. Please go ahead.
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1 MR. WILLIAMSON: It's a mischaracterization,

2 but answer the question to the extent you understand it.
3 THE WITNESS: That was Rimma's -- I beg your
4 pardon?
5 That was Alex's opinion, and I didn't take
6 anything from it.
7 BY MR. PERETZ:
8 Q. Well --
9 A. I just felt that I was concerned that Ms. Gale,
10 who was trying to have harmony in her school and amongst
11 her parents, was not hearing both sides of the story.
12 That was my concern at the time, and then I wanted Alex
13 to have a fair hearing.
14 Q. Okay. Well, why do you think that Alex didn't
15 have a fair hearing?
16 MR. WILLIAMSON: Asked and answered.
17 THE WITNESS: I can answer?
18 MR. WILLIAMSON: Tell him again.
19 THE WITNESS: Because Gay Dixon was in
20 communication and emotionally supporting Rimma regarding
21 Rimma's feelings about how people -- she felt people
22 were treating her at school. And Gay Dixon was
23 counseling her regarding that. So that was my
24 understanding. And therefore Gale was hearing a lot
25 from Gay regarding Rimma but nothing really from Alex.
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YVer1f
1 BY MR. PERETZ:
2 Q. Did Alex's role go beyond Rimma's well-being?
3 Did she elaborate on that? Did you ask her questions
4 about it?
5 A. No.
6 Q. Was there any communication or indication
7 what is meant by "What is wrong with Rimma" or her
8 well-being?
9 A. No.
10 Q. And you formed no opinions about what was the
11 cause of that?
12 A. My concern was having the school and Ms. Gale
13 harmonious. Everything -- We just wanted harmony at our
14 school.
15 Q. I understand that. Harmony is very important
16 at The Evans School. I get that. My question is
17 different.
18 My question is: You know, our minds wander,
19 whether we want to or not. We can't control what we
20 think of. When Ms. Rome told you "I am concerned about
21 Rimma's well-being," what was your take on that? What
22 was your thought on that?
23 A. I agreed that I was concerned about Rimma's
24 well-being, because I hadn't seen her for four months.
25 Q. Okay. And then what was -- What did you think
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YVer1f
1 about Rimma's well-being at that point? Did you think

2 to yourself -- Again, I'm saying "to yourself." Again,
3 do you think -- were you thinking that Rimma suffers
4 from some mental breakdown, or some mental illness, or
5 some emotional problems? Did you have any type of those
6 feelings?
8 facts, not reasonably calculated to lead to the
9 discovery of admissible evidence.
10 Answer the question if you recall having
11 formulated, you know, your personal opinion at that
12 time. It also calls for expert opinion.
13 THE WITNESS: I don't recall what my thoughts
14 were.
15 BY MR. PERETZ:
16 Q. You don't recall? You just don't recall?
17 A. I was concerned more about Alex at that point.
18 For me it was -- At that point I wanted harmony for the
19 school. That was my number-one objective.
20 Q. Okay. Thank you. I appreciate that.
21 And after that -- You know, after you met with
22 Alex in person and she forwarded you the emails --
23 A. She handed them to me the next day.
24 Q. I understand that. I didn't say --
25 I understand that. I didn't say what it was.
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YVer1f
1 I understand that.
2 After that did you have any discussions with
3 Ms. Rome about her situation with Ms. Breeze up until
4 the present?
5 A. No.
6 Q. Okay. When she handed you the binder, did she
7 mention anything additional -- anything in addition?
8 A. No.
9 Q. Okay. That's all?
10 A. Correct.
11 Q. She just gave you the binder --
12 A. That's it.
13 Q. -- and that's it? There was no discussion
14 there?
15 A. No.
16 Q. Again, I am trying to preserve our record. Try
17 not to talk over me.
18 Go to Exhibit 38.
19 A. (The witness complied.)
20 Q. And Exhibit 38, the first page, Bates-stamped
21 4001, is an email you sent to Gale Baer; correct?
22 A. Correct.
23 Q. And that is an email that followed this lunch
24 meeting; correct?
25 A. Correct.
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YVer1f
1 Q. Okay. And I'd like to -- I think we have

2 covered most of it, but I want to ask you some follow-up
3 questions.
4 First of all, what you attempted to put in this
5 email is the events that you experienced during the
6 lunch with Alex; correct?
7 A. Correct.
8 Q. Okay. And you attempted to record them
9 accurately; correct?
10 A. Yes.
11 Q. Okay. Is there any inaccuracies in this email
12 that you are aware of?
13 A. I need to review the email.
14 Q. By all means, do so. Anytime I am going to
15 hand you a document -- This is not a guessing game.
16 Please review them. And if you need to speak to
17 Counsel, please do that.
18 A. Please repeat your question.
19 Q. Sure.
20 My question was whether -- Now that you read
21 it, in retrospect -- and now you are under oath, so it
22 is a heightened requirement -- do you recognize any
23 inaccuracies in this email, meaning anything that's
24 inaccurate?
25 A. There is nothing inaccurate.
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YVer1f
1 Q. Okay. It seems like --

2 A. Can I expand?
3 Q. It seems like you want to expand. Please. I
4 want to give you the opportunity.
5 A. I think I recall -- I recall not having an
6 opportunity, after I had met with Alex, to speak with
7 Gale that specific day. And therefore, within, I
8 think -- What's this? The third paragraph. "After the
9 performance, Alex was up in the classroom" -- I had not
10 yet informed Ms. Gale that Alex was able to provide a
11 folder of emails. I just wanted to clarify that.
12 Q. Okay. No problem. This is not, like,
13 inaccuracies. It's just giving me more context.
14 A. Right.
15 Q. And I gather, you know, Ms. Gale is very busy.
16 Is that true?
17 A. Yes.
18 Q. Okay. So there wasn't anything like you tried
19 to avoid her or she was trying to avoid you?
20 A. Oh, no, no, no.
21 Q. And she was apparently going to North Carolina.
22 A. Correct.
23 Q. That probably put another demand on her time.
24 A. Correct.
25 Q. So you just thought it would be a good idea
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YVer1f
1 just to email her because you didn't have a chance to

2 speak with her in person?
3 A. I didn't want her to go to North Carolina not
4 having had any communication and feedback regarding the
5 lunch meeting.
6 Q. Okay. Good.
7 Now, I want to go through some of the comments
8 you made in your email, if that's okay with you.
9 A. Yes.
10 Q. The second paragraph mentions that you head off
11 to camp. Was that a camp with one of the classes?
12 A. She goes to Camp Rockmont for a few days prior
13 to the children arriving.
14 Q. Okay. I see.
15 A. And I believe that the camp is in
16 North Carolina.
17 Q. Okay. Good. That's -- Well, okay.
18 Now in the third paragraph you talk about
19 "After the performance." That's your class performance?
20 A. It must have been some school event.
21 Q. Some class --
22 A. Assembly, et cetera.
23 Q. Okay. And then you have reference to Alex.
24 And that's a reference to Alex Rome; correct?
25 A. Correct.
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YVer1f
1 Q. Now, she said that -- She said to you, and I

2 gather that this is accurate, that she was up all night
3 as she couldn't sleep; correct? That's what she told
4 you?
5 A. Correct.
6 Q. And did she tell you why she was up all night?
7 A. She was gathering -- She was so distraught
8 about the whole situation and that she had put the time
9 to good use and decided to use that time to gather the
10 emails that I had suggested she produce.
11 Q. Okay. And sometimes people say "I was up all
12 night" as a figure of speech, meaning it's not like
13 literally they were up all night but they --
14 A. I don't know.
15 Q. You don't know one way or the other; correct?
16 A. Correct.
17 Q. But she also told you that she couldn't sleep;
18 correct?
19 MR. WILLIAMSON: Asked and answered. The
20 document speaks for itself.
21 MR. PERETZ: I try to lay a foundation here.
22 BY MR. PERETZ:
23 Q. Ms. Rome told you that she couldn't sleep;
24 correct?
25 A. I believe so.
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YVer1f
1 Q. Okay. Did she mention in that context that she

2 couldn't sleep because she was emotional or agitated or
3 because the lunch with you kept her in a way that she
4 couldn't sleep?
5 A. I don't think it was because of our lunch. I
6 think it was just the issue at hand.
7 Q. Okay. So the issue kept her not sleeping?
8 A. She had been concerned about this, yes.
9 Q. Okay. Now, you say -- in the next sentence you
10 say it is -- I'm sorry -- "In it is her explanation of
11 what has happened and copies of emails." Do you see
12 that?
13 A. Correct.
14 Q. Now, you mentioned that there was only -- the
15 binder only included emails; correct?
16 A. That's what I recall.
17 Q. Okay. But didn't -- It seems like there may
18 have been something there that she explained what the
19 emails are.
20 A. I believe that there may -- Now that you have
21 triggered my memory, I believe there may have been one
22 kind of cover sheet that just said "Here are the" -- you
23 know, "Here are the emails." And I recall it saying
24 "I really" -- something positive towards Rimma with
25 something like "I really want this to be resolved."
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YVer1f
2 And what has happened, meaning the --
3 essentially the situation with -- the reference here was
4 the situation with the Breezes; correct?
5 A. Correct.
6 Q. Okay. I just want to make that clear.
7 And now, in the fourth paragraph -- I'm sorry;
8 the paragraph that begins with "I am probably crossing
9 the line" -- you mentioned that -- Obviously, you don't
10 have job duties to solve disputes between parents;
11 correct?
12 A. Unofficially. Officially I don't have that.
13 Q. Okay. So that's why you mentioned that you are
14 crossing the line. It's not like you did something
15 illegal; correct?
16 A. Oh, correct.
17 Q. That's all I am trying to clarify.
18 And now you also are saying "I am going to
19 stick my neck" --
20 A. Correct.
21 Q. That's a figure of speech.
22 A. Correct.
23 Q. And then you say "for Rimma's sake."
24 A. Um-hum.
25 Q. Correct?
800.211.DEPO (3376)
1 A. Yes.
2 MR. WILLIAMSON: Yes?
3 THE WITNESS: Yes.
4 BY MR. PERETZ:
5 Q. Why did you say you are sticking your neck out
6 for Rimma's sake and that -- Well, the reason I am
7 asking the question is because it seems like you said
8 that repeatedly today. And I don't want to repeat that
9 again, but I have to -- you wanted Ms. Baer to hear
10 Alex's side of the story; correct?
11 A. I did.
12 Q. Okay. So why are you doing that for Rimma's
13 sake?
14 A. Because -- It was for everybody's sake,
15 because -- because Alex had evidence that she did, in
16 fact, have -- had invited the Breezes. The contents of
17 the emails supported what Alex was -- as a way of
18 backing up her own story -- saying that I have not done
19 anything wrong here.
20 Q. Okay. But again -- I'm sorry. You probably
21 didn't think much about your choice of words back then,
22 and I am going to nitpick on that, but that's my job.
23 You didn't say "for everyone's sake." You said
24 "for Rimma's sake"; correct? That's the language you
25 used; correct?
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YVer1f
1 A. She already knew that I was concerned about

2 Alex, and I didn't want her to feel that I was taking
3 sides -- only Alex's side.
4 Q. Okay. Okay.
5 A. So --
6 Q. Go ahead. Finish that thought.
7 A. Okay. So I wanted Ms. Gale to feel that I was
8 being fair and not taking sides myself. Yes, I had met
9 with Alex, but it was with the objective of helping to
10 resolve this whole situation.
11 Q. Okay. You follow that statement by saying
12 "I generally believe that Alex is showing genuine
13 concerns for Rimma's welfare; correct?
14 A. Correct.
15 Q. Okay. So now it appears to be that you also
16 believe that there is a concern here for Rimma's
17 welfare; correct?
18 A. Because I had -- Yeah, correct, because I had
19 not seen her for four months.
20 Q. Okay. Did you have -- Was any of those concern
21 about Rimma's mental welfare or did you have anything
22 more specific than Rimma's welfare in mind (sic)?
23 A. No.
24 Q. Okay. Like the following sentence says that
25 you felt that you didn't do a good job in explaining to
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YVer1f
1 her what was discussed yesterday. So it seems like you

2 had some sort of additional discussion with Ms. Baer;
3 correct?
4 A. It was a quick debrief. I met with Alex. This
5 is what we talked about, but I believe at the time that
6 I had not told her specifically about the folder.
7 Q. Okay.
8 A. I believe.
9 Q. What did you tell her in this short debriefing?
10 A. Just that I truly felt that Alex had been
11 including the Breezes in social situations and that Alex
12 had evidence to prove that, you know, if she wanted to
13 see that. But I did not know -- when I initially
14 briefly spoke with Gale in passing, I did not know that
15 Alex was going to be able to produce that folder the
16 next day.
17 Q. I see.
18 Now, why do you follow that with "Yes, Alex is
19 vocal and she is an organizer." Why did you -- Why did
20 you use these descriptors of Alex in that context?
21 A. Because that's who she is.
22 Q. What do you mean by she is vocal? She has a
23 loud voice or she just voices her opinion?
24 A. She just says it how it is in her opinion, you
25 know.
800.211.DEPO (3376)
YVer1f
1 Q. Would you describe her as a straight shooter?

2 A. Compared to -- It's part of her nature, being
3 British, to be more of a straight shooter, I think.
4 Q. Yeah. That's what I am saying.
5 A. I think that's part of who she is, compared to
6 my perception of Californians in terms of beating around
7 the bush.
8 Q. Okay.
9 A. "Straight shooter" as in more straight-shooting
10 than a Californian but not as in offensive.
11 Q. But you do understand -- again, I am coming
12 from a different culture -- that sometimes what works
13 well in a different culture doesn't work well in another
14 culture; correct?
15 MR. WILLIAMSON: Vague and ambiguous,
16 overbroad, lacks foundation, assumes facts.
17 MR. PERETZ: Let me take it back. It's not so
18 outrageously controversial, but let's -- let's -- let's
19 bring some context here.
20 BY MR. PERETZ:
21 Q. You mentioned that Alex was vocal because you
22 were afraid that Alex, being a straight shooter, may be
23 perceived at times as offensive; correct?
24 A. Some people have been offended, yes, by the way
25 in which Alex communicates.
800.211.DEPO (3376)
YVer1f
1 Q. Okay. And then the comments here as to "some

2 people," this is not necessarily Rimma Breeze only;
3 correct?
4 A. Correct, but there are very few. This is not a
5 generalization of how people take Alex Rome.
6 Q. Okay. What's the reference here to the
7 organizer?
8 A. Well, the tea party. You know, she is a doer.
9 She wants to do things to help the school, to provide
10 social events on a social level for the children.
11 Q. I see.
12 But it seems like here you are trying to defend
13 that quality in a way. So what are you trying to
14 defend?
15 A. I was -- At this point I knew that Ms. Gale was
16 more in favor of Rimma, and I was trying to show that I
17 know Alex is not perfect. No one is perfect. So in
18 this email not saying, hey, Rimma is X, Y and Z, or
19 whatever, in terms of I want to see both sides. And
20 that's what I said, you know, when I said, "I like both
21 ladies very much, and I am definitely not taking sides,"
22 which is why I said that.
23 Q. Okay. I get that. Thank you.
24 And the file referenced here is the same thing,
25 the binder that you kept in your cupboard or closet?
800.211.DEPO (3376)
YVer1f
1 A. Correct.
2 Q. Okay. And let's -- Now, you mentioned that
3 Rimma was out. You haven't seen Rimma between March and
4 May?
5 A. Not that I recall. And if I did --
6 Q. Again, I'm not -- I'm not -- you don't need to
7 defend your position. I am just trying to follow up
8 with another position.
9 A. Um-hum.
10 Q. Do you know who dropped off Rimma's kids during
11 that period of time?
12 A. No.
13 Q. Okay. Do you see -- Do you happen to see --
14 Are you outside during drop-off?
15 A. No.
16 Q. So you are not -- you wouldn't see if she was
17 there or not; correct?
18 A. Correct.
19 Q. Okay. I just wanted to clarify that.
20 Let's go to what we call the -- If you look at
21 the bottom of the documents there are Bates stamps.
22 There's numbers at the top right -- I am sorry -- bottom
23 right. That helps everyone to make sure that we are all
24 on the same page, literally.
800.211.DEPO (3376)
YVer1f
1 Q. So I am going to refer to those numbers to make

2 sure we are on the same page. Is that okay?
3 A. Yes.
4 Q. Okay. I mean, I have some random questions
5 about the documents that you gave me --
6 A. Okay.
7 Q. -- and I am going to ask them.
8 So if you look at 410 -- 4010 -- Okay?
9 A. Yeah.
10 Q. And by all means, if you need to read the email
11 or the entire exchange, do that. I am not trying to not
12 give you the opportunity to do that.
13 If you look at the top there is an email from
14 Martha Baer to Evans Admin.
15 A. Um-hum.
16 Q. Yes?
17 A. Yes.
18 Q. Okay. Now, in May of 2013 you didn't have the
19 admin accounts; correct?
20 A. No.
21 Q. The way you --
22 MR. WILLIAMSON: "No," it's not correct, or --
23 MR. PERETZ: Yeah.
24 MR. WILLIAMSON: -- or "No," you didn't have
25 the admin account?
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YVer1f
1 MR. PERETZ: Thank you.

2 MR. WILLIAMSON: The question-and-answer
3 colloquy doesn't give us a clear answer.
4 THE WITNESS: I don't 100-percent recall, but
5 at some point I believe Sarah and I did have passwords
6 for that account. But we did not ever use it, I
7 believe.
8 MR. PERETZ: Okay.
9 BY MR. PERETZ:
10 Q. And so the reason you have a copy of this email
11 is because you did this search of documents now and
12 looked at this email account as well; correct?
13 A. Correct.
14 Q. Okay. Now, because that's not an email that
15 you were copied to --
16 A. Correct.
17 Q. -- so I was wondering.
18 A. Yeah.
19 Q. Okay. Nevertheless, you saw this email;
20 correct?
21 A. Correct.
22 Q. And it says here, "As for the Blast" -- Do you
23 see that?
24 A. Yes, I do.
25 Q. And I assume that this is not a reference to a
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YVer1f
1 bomb blast.
2 A. Oh, no.
3 Q. Taking you back to the UK for a second.
4 A. Um-hum.
5 Q. So what is the Blast, with a capital B? It's
6 not just a small blast.
7 A. Blast was an email communication to parents
8 that we were sending out, or the school was sending out,
9 as a way of e-communication with the parents.
10 Q. And the person who sent out the Blast letter
11 was usually Rimma when she was there; correct?
12 A. Correct.
13 Q. And that's the email Blast that we refer to;
14 correct?
15 A. Correct.
16 Q. And that's Blakeley Blast?
17 A. Blakeley's Blast.
18 Q. And Blakeley is the school dog; correct?
19 A. Correct.
20 Q. And that Blast was typically sent from an
21 admin -- an address of blakeley@theevansschool.com;
22 correct? If you remember.
24 Q. But Rimma was the one who was sending those
25 Blasts?
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1 A. At that time.
2 Q. When she was there; correct?
3 A. Correct.
4 Q. Who took over that responsibility after
5 Rimma --
6 A. Sarah Brumfield and I.
7 Q. So you do the Blast?
8 A. I do.
9 Q. And what email do you use to do the Blast now?
10 A. We use Mail Chimp at
11 communication@evansschool.org.
12 MR. WILLIAMSON: Communication
13 @evansschool.org.
14 THE WITNESS: But I would have to check. It's
15 auto log-in, so I never have to type it in.
17 BY MR. PERETZ:
18 Q. Was the reason establishing
19 communication@evansschool.com to use that address for
20 the Blast?
21 A. Repeat the question, please.
22 Q. What was the purpose of establishing the
23 communication@evansschool.com?
24 MR. WILLIAMSON: Evansschool.org.
25 MR. PERETZ: .org. I'm sorry. I think it's --
800.211.DEPO (3376)
YVer1f
1 THE WITNESS: Repeat it again to clarify.

2 MR. PERETZ: Sure.
3 BY MR. PERETZ:
4 Q. The communication email address --
5 A. @evansschool.org.
6 Q. Correct.
7 -- what was the reason to establish that email
8 address? Because it's separated of other emails (sic).
9 Why did you need that email? Why was it created?
10 MR. WILLIAMSON: If you know why it was created
11 THE WITNESS: I do.
12 Sarah Brumfield and I created it to send out
13 whole-school emails and have a centralized way of
14 communication with teachers, parents, faculty, and
15 staff.
17 BY MR. PERETZ:
18 Q. Now, if we look at the bottom of the email,
19 there is an email from Margaret Baer to The Evans
20 School. And there is a reference there to a person
21 named Alex Lukia -- L-u-k-i-a. Do you see that?
22 A. I do.
23 MR. WILLIAMSON: What page?
24 MR. PERETZ: Same page. 4010.
25 BY MR. PERETZ:
800.211.DEPO (3376)
1 Q. Do you see the name?

2 A. I do.
3 Q. Did you ever contact the person?
4 A. No.
5 Q. Do you know who he is?
6 A. No.
7 Q. Okay. Let's move to page 4018.
9 Q. And if you look at the bottom, you make a
10 comment, "Bizarre." Do you see that?
11 A. Yes.
12 Q. Can you tell me why you mentioned "Bizarre"?
13 What was the reason for that?
14 A. Because I did not receive the attachment that
15 Rimma said she had sent. It was bizarre that I had not
16 received it.
17 Q. Okay. And that's what you thought? You didn't
18 think that Rimma is bizarre. You just thought it was
19 odd?
20 A. Yeah, that the communication had not come
21 through.
22 Q. Okay. I just wanted to clarify that.
23 Let's move to the next page, 4019.
25 Q. Do you see that?
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YVer1f
1 A. I do.
2 Q. It's a communication about usage of photos for
3 school purposes -- kids' photos and other photos for
4 school purposes. Why don't you read that, if you need
5 to, just to refresh your recollection.
6 A. The whole page?
7 Q. Yes, the whole page. To yourself, not out
8 loud. Just read it to yourself.
9 A. I read it.
10 Q. Okay. Does it refresh your recollection about
11 policy regarding dealing with how to handle photos of
12 children?
13 MR. WILLIAMSON: Lacks foundation.
14 THE WITNESS: I don't recall ever reading this
15 email.
17 BY MR. PERETZ:
18 Q. Well, the email was sent to you at some point;
19 correct?
20 A. Correct. At this time --
21 Q. You just don't recall at this time?
22 A. I know that I did not read it. At this time, I
23 thought she was very ill, and I had a lot going on.
24 Q. Okay.
25 A. So this is right before my father passed, so
800.211.DEPO (3376)
1 I -- there are certain emails I read and certain I

2 didn't. I don't recall reading this one.
3 Q. And I sincerely apologize. Of course I didn't
4 want to trigger --
5 A. Um-hum.
6 Q. Okay. So who -- Do you know if at some
7 point -- Are you okay to continue?
8 A. Yes.
9 Q. Okay. Do you know if at some point Rimma sent
10 out a policy dealing with photos or usage of photos?
11 A. Do I know when Rimma sent that?
12 Q. Or what was distributed to the parents.
13 A. A policy has been distributed to the parents
14 regarding photo sharing, I believe.
15 Q. And when was that, if you recall?
17 Q. Was it around the end of -- the end -- the fall
18 of 2012?
19 A. I was out of commission. I flew to England.
20 Q. Okay.
21 A. I was out of the country for three months --
22 Q. Okay. I see.
23 A. -- between -- I don't remember the exact dates,
24 but --
25 Q. Okay. No problem. That's helpful.
800.211.DEPO (3376)
YVer1f
1 Let's go to 4030.
3 Q. And now, throughout these documents there's
4 some -- I mean the entire Exhibit, Exhibit 38, there's
5 some asterisks made and circling and underlining. These
6 are your comments?
7 A. That was just me identifying which emails were
8 coming from which direction.
9 Q. Okay. So you were the one who made the
10 comments?
11 A. I did.
12 Q. Okay. No problem. I just wanted to make sure.
13 A. Okay.
14 Q. And this is an email about some presentation
15 that Rimma did.
16 A. Would you please repeat the --
17 Q. I am sorry. 4030. Why don't you go through
18 that.
20 Q. Okay.
21 A. Yes.
22 Q. Okay. Now that you have read the email, do you
23 have any recollection of the presentation that Rimma did
24 that is being discussed here?
25 A. I am looking for the day.
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1 Q. It's May of 2012.

2 A. Slightly.
3 Q. Okay. Do you have -- Sarah Harrison describes
4 that everyone is so impressed and excited. Do you see
5 that?
6 A. I do.
7 Q. Thinking back, did you share those sentiments
8 with her? I mean, were you excited and impressed by the
9 presentation as you recall?
10 MR. WILLIAMSON: If you recall.
11 BY MR. PERETZ:
12 Q. If you recall, of course.
13 MR. WILLIAMSON: If you don't recall the
14 presentation -- So if you can recall whether you were
15 impressed by a presentation you don't recall, go ahead
16 and answer.
17 THE WITNESS: I was pleased at the time that we
18 were making some improvements to some --
19 I'm not going to talk if he is not paying
20 attention.
21 BY MR. PERETZ:
22 Q. I am listening to you. I am sorry. I am
23 listening to you. Even if I don't look into your eyes,
24 I am listening.
25 A. I personally was pleased that -- that we were
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YVer1f
1 making some progress --

2 Q. Okay.
3 A. -- that we were involving ourselves in
4 technology as a school and incorporating technology, but
5 one of the reasons that we were quite enthusiastic to
6 Rimma was because we -- part of the reason that Gale
7 brought Rimma on was that she felt it was a way to make
8 things more harmonious and give Rimma a purpose for
9 being more involved in the school because she felt that
10 Rimma was envious of Alex's role volunteering in the
11 school, and participation, and we were trying to be
12 encouraging to Rimma to help that along.
13 So if it seems overenthusiastic, yes, we were
14 pleased, but we were bolstering it somewhat to make
15 Rimma feel better.
16 Q. And where did you get the sentiment that
17 Ms. Baer is trying to be more inclusive to Rimma because
18 of her --
19 A. Just from -- I'm privy to many conversations
20 regarding the situation, and Gale's way of dealing with
21 issues such as this is to make everyone try and get
22 along.
23 Q. Okay. So you were privy to conversations with
24 Ms. Baer regarding the situation?
25 A. I guess so.
800.211.DEPO (3376)
YVer1f
1 Q. Um --
2 A. Yes.
3 Q. Okay. Sorry about the stare.
4 If you look earlier on page 4022, it seems that
5 this is the email you sent about this presentation.
6 A. Correct.
7 Q. Um-hum? That's a "Yes"?
8 A. Um-hum. Yes.
9 Q. Okay. Let's move to 4037, please.
10 A. Do you want me to be looking at both?
11 Q. No.
12 A. Why did you just ask me to look at 4022?
13 Q. So you can confirm that that's the email you
14 sent to Rimma. That's about it. We talked about it.
15 A. Okay.
16 Q. We are going to move on.
17 MR. WILLIAMSON: I lost track. 37?
18 MR. PERETZ: Yes.
19 MR. WILLIAMSON: Thank you.
20 BY MR. PERETZ:
21 Q. And this is an email that -- This is an email
22 exchange with Colin Breeze's email and the Google Apps
23 for Education Team; correct? Do you see that?
24 A. I do.
25 Q. You didn't get a copy of this in realtime
800.211.DEPO (3376)
1 around the time that it was sent; correct?

2 A. Correct.
3 Q. And you weren't aware that Mr. Breeze is
4 contacting people and asking for the next step.
5 A. Could you repeat that, please.
6 Q. "In realtime," meaning in January of 2012, you
7 weren't aware of Mr. Breeze's attempt to communicate
8 with Google Apps for Education; correct?
9 A. I knew that he was doing something, but I was
10 not clear exactly as to his role.
11 Q. Okay. Let's move to 4041.
13 Q. 4041 is another email from Alex Rome to you;
14 correct?
15 A. Correct.
16 Q. And that's an email that followed the handing
17 of the binder and the lunch meeting; correct?
18 A. Correct.
19 Q. Okay. And that's approximately two weeks after
20 that?
21 A. Correct.
22 Q. Okay.
23 A. Just to give you a time frame.
24 So Alex did have some sort of follow-up on the
25 situation with the Breezes, and that was in the form of
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YVer1f
1 that email; correct?

3 facts. The document speaks for itself.
4 BY MR. PERETZ:
5 Q. Is that correct? You can answer.
6 MR. WILLIAMSON: Is it accurately
7 characterizing it or not?
8 THE WITNESS: Repeat it, please.
9 MR. PERETZ: Yes.
10 BY MR. PERETZ:
11 Q. This is an email that Alex sent a couple weeks
12 after she approached you and you had lunch together;
13 correct?
14 A. Correct.
15 Q. Okay. And in this email she mentioned that she
16 followed up with the Breezes about coming to a party.
17 Do you see that?
18 A. I do.
19 Q. Okay. Other than this sentence in the email,
20 did you have a follow-up discussion with Alex about it?
21 A. No.
22 Q. Did you respond to this email?
24 Q. Okay. Do you know about what parties she is
25 talking about?
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YVer1f
1 A. I do.
2 Q. What party was that?
3 A. It was the end-of-year class party for the
4 students and families.
5 Q. And did you attend that party?
6 A. I don't -- Oh, I did.
7 Q. Okay. Do you know if anyone of the Breezes
8 were there?
9 A. I believe they were.
10 Q. Okay. And did you notice any tension between
11 Alex or -- and any of the Breezes during that party?
12 A. No.
13 Q. Now, if you look at this document, you put two
14 asterisks next to the paragraph there.
15 A. Um-hum.
16 Q. Is that a "Yes"?
17 A. Yes.
18 Q. And there is an asterisk next to the paragraph
19 that says "Would still like to have you down to beach
20 club." Do you see that?
21 A. Yes.
22 Q. Why did you put an asterisk next to that
23 sentence?
24 A. I think it was an error, and I was going
25 through it really quickly and did it.
800.211.DEPO (3376)
YVer1f
1 Q. Okay. And you meant to put the asterisk next

2 to Alex's name?
3 A. Next to Alex.
4 Q. Is that correct?
5 A. Correct.
6 Q. Okay. Now, there is an invitation there to go
7 to the beach club.
8 A. Yes.
9 Q. Did you take her up on the invitation?
10 A. No, I did not.
11 Q. Did you ever attend the beach club?
12 A. I have attended the beach club but not
13 specifically individually with the Romes.
14 Q. Okay. I see.
15 And the following page 42 is your response to
16 this email; correct?
17 A. Apparently I did reply to it.
18 Q. And there is a handwritten comment next to it.
19 And that handwritten comment is, "Response to previous
20 email from Alex Rome." That's your handwriting;
21 correct?
22 A. Correct.
23 Q. And this is not a contemporaneous note,
24 meaning you didn't do it back when the email was sent
25 but you did it now when you went through the emails;
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YVer1f
1 correct?
2 A. Correct.
3 Q. Okay. And now, there is a reference here to a
4 gift for Chip. That's a gift for her husband; correct?
5 A. Yes.
6 Q. When did this issue come up? It seems like
7 this is a follow-up from a different conversation, and
8 it's not in her initial email.
9 A. It was a one-to-one conversation -- personal
10 conversation.
11 Q. Okay. I don't understand what you mean by
12 "one-to-one conversation."
13 A. Well, between Alex and I. She had mentioned
14 that she was -- She mentioned purchasing a gift for
15 Chip, and this was me asking her did you decide what you
16 were going to buy Chip for his birthday.
17 Q. Yeah, I understand that.
18 When did Alex mention that to you? Do you
19 remember?
20 A. No.
21 Q. Okay. Was it during the lunch that you had
22 together?
23 A. No, I don't think so. Maybe it was. I don't
24 recall.
25 Q. Was it in between the lunch and -- We are
800.211.DEPO (3376)
YVer1f
1 talking about two weeks after that lunch.

2 A. I really don't recall specifically when we had
3 the conversation about Chip's birthday gift.
4 Q. Okay. At the bottom there, there is a
5 reference to Mandy. "Wasn't it great to see Mandy this
6 am!"
7 A. Um-hum. Yes.
8 Q. What is that reference to?
9 A. Mandy Forssman had come into Evans to say
10 hello.
11 Q. Why did you mention that to Alex Rome?
12 A. Because she knows Alex Rome.
13 Q. Oh. Was Alex Rome, during that time -- Was
14 Alex at the school that morning and you saw her with
15 Mandy or something?
16 A. I guess so, as I was going to class and -- I
17 don't know. I don't recall specifically.
18 Q. Okay. Go to 4045.
19 A. Yes.
20 Q. You made the handwritten comment about what is
21 the use for the email address
22 development@theevansschool.com; correct?
23 A. Correct.
24 Q. Okay. And that was an email address that you
25 established for communication with WASC; correct?
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YVer1f
1 A. Correct.
2 Q. When were you tasked with handling the WASC
3 application? Do you recall that?
4 A. I do. It was in the summer -- It was a
5 conversation that Ms. Gale and I had, I believe, at the
6 beginning or towards the end of the school year in 2011.
7 Q. And what were you told back then?
8 A. That I would be one of the chair of -- or one
9 of the chairs of the WASC committee.
10 Q. Okay. Anything other than that?
11 A. No.
12 Q. Okay. And it took you about a year and a half
13 to prepare all the documentation?
14 A. Oh, yes.
15 Q. It's a big task; correct?
16 A. It is.
17 Q. Was technology -- Was technology a part of this
18 application process?
19 A. Could you clarify?
20 Q. Sure. Was advancement in technology in IT
21 systems part of -- of the information that was provided
22 to the WASC committee or body?
23 A. By Evans School?
24 Q. Yes.
25 A. It was.
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YVer1f
1 Q. And when you handled this whole WASC

2 application process -- Strike that.
3 Was part of Rimma's engagement at the school to
4 kind of like streamline the effort in -- in improving
5 the IT systems because the school applied to WASC for
6 accreditation?
7 MR. WILLIAMSON: Can I ask you to clarify.
8 MR. PERETZ: No.
9 THE WITNESS: What do you mean by "engagement
10 of the school?" Because I'm not sure of the time frame
11 you are talking about.
12 MR. PERETZ: The time frame is early 2012.
13 THE WITNESS: Repeat the question, please.
14 MR. PERETZ: Yes.
15 BY MR. PERETZ:
16 Q. You were the one who was coordinating the
17 submission to WASC; correct?
18 A. Correct.
19 Q. And this is a huge undertaking; correct?
20 A. Correct.
21 Q. It's not a form that you fill out and file and
22 submit; correct?
23 A. It depends how you want to present your school.
24 You could do it to that level. We put a lot of time and
25 effort into this.
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YVer1f
1 Q. Fair enough.
2 The Evans School -- The Evans School put a lot
3 of effort and time in 2012 and '13 towards this
4 application; correct?
5 A. I would reword that in that Sarah Brumfield and
6 I put a lot of time and effort into WASC and we
7 required -- we asked the faculty to contribute as
8 minimum as possible but for us to do it -- our job. We
9 wanted them to be involved to the point which was
10 necessary.
11 Q. Okay. Was Rimma involved in that process?
12 A. Clarify, please.
13 Q. Did Rimma handle any tasks or any issues that
14 pertained to that application?
15 A. Some.
16 Q. Okay. What issues or tasks did she handle?
17 A. She -- The main one was towards the end of the
18 accreditation process when we were writing the action
19 plan, which is a plan that says how we would like to
20 move forward in the next few years.
21 I -- Rimma had kept offering. "Let me know
22 what we can do" or "I can do to help," blah-blah-blah.
23 And at that point, at the end when we were accrediting,
24 or at the end of the process, writing this action plan,
25 we asked her specifically, "What would you like to have
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YVer1f
1 on the action plan regarding information technology?"

2 Q. Okay. And she gave you that information?
3 A. She did.
4 Q. And that action plan, is that the booklet that
5 was ultimately submitted?
6 A. It is within it.
7 Q. It's within that booklet?
8 A. But I could have -- I could have written down
9 the more sort of generic goals for our school regarding
10 technology, but Rimma was available and she wanted to
11 help, and we asked her "What direction do you think you
12 would like to go?"
13 Q. No problem. Look at 4047.
15 Q. I am going to jump around now, so bear with me.
16 A. Um-hum.
17 Q. This is an email from Rimma to you. Do you see
18 that?
19 A. Yes.
20 Q. It's a pretty -- She was handling IT. So
21 you -- So you used her for assistance in passwords and
22 things like that; correct?
23 A. Correct.
24 Q. Now, she mentioned here -- Rimma mentioned in
25 the email, "I change the passwords from time to time so
800.211.DEPO (3376)
YVer1f
1 it's totally not your fault." Do you see that?

2 A. Correct.
3 Q. Was it your understanding that Rimma's
4 practice was that she changed passwords from time to
5 time for security purposes?
7 facts.
8 You can answer if you have an understanding.
9 THE WITNESS: I don't have an understanding
10 about that.
12 BY MR. PERETZ:
13 Q. You don't have an understanding about that?
14 Okay.
15 And look at 4054.
16 A. (The witness complied.) Yeah.
17 Q. 54 is an agenda for a staff meeting; correct?
18 A. Correct.
19 Q. And then you made a comment next to the agenda
20 for the staff meeting on December 13; is that correct?
21 A. Correct.
22 Q. That's a comment that you made now; correct?
23 A. Correct.
24 Q. This was a very short time slot, 20 minutes --
25 about 20 minutes within the -- within the meeting;
800.211.DEPO (3376)
YVer1f
1 correct?
2 A. Correct.
3 Q. Okay. And the reference is Rimma's
4 presentation.
5 A. Correct.
6 Q. Okay. So it took 20 minutes out of the
7 four-hour meeting; correct?
8 A. Approximately, yes.
9 Q. Okay. Why did you -- Why did you thought --
10 Why did you make the point that Rimma's presentation
11 was, you know, short or it was a short time slot? Why
12 was it important for you to put it down?
13 A. Because I wanted to clarify to Ian when I was
14 handing the documents over that the book review looks
15 like not very much within the four-hour meeting, but in
16 fact those meeting -- those book reviews took -- every
17 staff member did a book review, and it took a very long
18 time.
19 Q. Okay. I see.
20 Let's look to 7073.
21 MR. WILLIAMSON: 4073?
22 MR. PERETZ: I'm sorry. 4073?
23 MR. WILLIAMSON: Counsel, she needs a break.
24 MR. PERETZ: I am trying to rush it because we
25 have three people.
800.211.DEPO (3376)
YVer1f
1 THE WITNESS: Yes.

2 MR. PERETZ: Let's take a 10-minute break,
3 actually.
4 (Recess.)
5 MR. PERETZ: Back on the record. And I'm
6 sorry. We're trying to finish three depositions today,
7 so I'm cutting down on my niceties and all that stuff.
8 BY MR. PERETZ:
9 Q. 4067.
10 A. Yes.
11 Q. Okay. 4067, again, is an email exchange. Do
12 you see that?
13 A. Yes I do.
14 Q. There is a handwritten comment there that says,
15 "This was scheduled for her so she could leave the
16 meeting once she has presented."
17 That's talking about Rimma's presentation at
18 the staff meeting; correct?
19 A. Correct.
20 Q. And that's to show that Rimma's participation
21 wasn't struggling with timing but just the first
22 segment?
23 A. Correct.
24 Q. And just to show that she wasn't that involved
25 in the school activities; correct?
800.211.DEPO (3376)
YVer1f
1 A. Correct.
2 Q. Would that be the intention behind that?
3 A. Correct.
4 Q. Why was it important for you to show that Rimma
5 was not so involved?
6 A. I was just stating why it was there at the
7 first of the meeting, because she had -- because I know
8 that she is claiming that she spent x-amount of hours
9 involved in the WASC program or whatever, and she was
10 only there for a short period in that whole meeting.
11 Q. I mean, you are a teacher at the school;
12 correct?
13 A. I teach at the school.
14 Q. You are also a teacher. Is there a difference?
15 A. I do other roles as well, but yes.
16 Q. Okay. I apologize. I am not dismissing the
17 other roles.
18 And you are definitely taking the school's side
19 in this litigation; correct?
20 A. Correct.
21 Q. Okay. I just want to make sure that that's the
22 case.
23 A. Um-hum.
24 Q. And did you see any of the legal documents in
25 this case?
800.211.DEPO (3376)
1 A. The only legal document I have seen is my own

2 deposition.
3 Q. Your own deposition notice?
4 A. Notice, I beg your pardon, yes.
5 Q. Okay. That's the only legal document you have
6 seen?
7 A. And I saw -- When I was looking for the email,
8 gathering --
9 Q. The email from Google?
10 A. Correct.
11 Q. Okay.
12 A. Yes and no. There was something else.
13 Q. Okay. There was something else?
14 A. I believe.
15 Q. What was the something else, based on memory,
16 without looking at documents?
17 A. I remember this.
18 Q. "This" meaning --
20 THE WITNESS: My deposition and -- I don't
21 recall. Something that looks like this when I was
22 gathering material.
23 BY MR. PERETZ:
24 Q. I hate to break it to you, but they all look
25 like that.
800.211.DEPO (3376)
YVer1f
1 A. Yeah. Something that looked official.

2 Q. Okay. What was the -- Sorry about that.
3 Do you remember what was the content of that?
4 A. I believe I received it from the -- It was
5 just, I think, the initial lawsuit notice, as it were,
6 that I found in the admin@theevansschool during the
7 month of August that had been sent to Rimma. It was
8 regarding Rimma. It was not regarding me.
9 Q. So what was it about Rimma? Notice of --
10 A. No. It was something like this that was -- I
11 don't know the specifics. I could pull it up for you,
12 but I --
13 MR. WILLIAMSON: Some of the emails that were
14 forwarded to Ms. Breeze from Evans -- from
15 admin@theevansschool.com came from me or Mr. Scully and
16 had attachments, which would have included pleadings,
17 and she may have seen those when she was reviewing that
18 file, that folder. They weren't sent to admin. They
19 were sent to or from my clients' other email accounts,
20 but they were forwarded to Ms. Breeze's personal email.
21 THE WITNESS: It wasn't -- It wasn't
22 Ms. Breeze's.
23 MR. WILLIAMSON: It was just in the admin
24 account?
25 THE WITNESS: It was in the admin account.
800.211.DEPO (3376)

2 BY MR. PERETZ:
3 Q. You have access to the admin account?
4 A. Correct.
5 Q. You didn't see it so far?
6 A. So far, no.
7 Q. Okay.
8 MR. WILLIAMSON: All right.
9 MR. PERETZ: Okay. Well, we'll see about that
10 later, I guess. That's fine. Now maybe is a good time
11 for us to do housekeeping.
12 BY MR. PERETZ:
13 Q. Every email -- You gathered all the emails that
14 are part of Exhibit 38; correct?
15 A. Correct.
16 Q. And all the emails that include you as either a
17 recipient or sender, you either received them or sent
18 them; correct?
19 A. Correct.
20 MR. WILLIAMSON: It's true -- She admitted she
21 received the one about the -- There were some that she
22 said she received but didn't read, but she doesn't deny
23 that they have been received.
24 MR. PERETZ: I didn't want to quibble with
25 that.
800.211.DEPO (3376)
YVer1f
1 MR. WILLIAMSON: No. I am sorry. I was

2 thinking out loud.
3 BY MR. PERETZ:
4 Q. Let's look at 4068 now.
5 A. Thank you. Yes.
6 Q. Now, this is an email you sent to whom? To
7 Gay Dixon; correct?
8 A. Correct.
9 Q. And this is about teachers' email addresses?
10 A. Correct.
11 Q. And why do you make the comment that "they are
12 WASC happy," or something to that effect?
13 A. Because it was a bonus for us to include
14 anything that was technology-based, I suppose.
15 Q. And what was the technology-based issue here?
16 That the teachers were provided with, like, school
17 address emails?
18 A. I don't recall why we were supplying Rimma with
19 these current email addresses. I don't recall the
20 purpose behind it.
21 Q. Okay. And you don't recall how it helped with
22 the -- or how it made the WASC people happy; correct?
23 MR. WILLIAMSON: Misstates the document.
24 THE WITNESS: It's just a throw-away comment
25 that, hey, it's something else we can add to our WASC
800.211.DEPO (3376)
YVer1f
1 documentation.
2 MR. PERETZ: Okay.
3 BY MR. PERETZ:
4 Q. So whatever Rimma did here, which you don't
5 specifically remember, helped with the WASC
6 documentation; is that correct?
7 A. Correct.
8 Q. Okay. And you handled the WASC filing;
9 correct?
10 A. Alongside Sarah Brumfield.
11 Q. Alongside with Sarah Brumfield.
12 A. Yes.
13 Q. Would you agree with me that without Google
14 Apps documentation you couldn't have gone through that
15 process in the time frame that you did?
16 A. I don't know what you are referring to.
17 Q. Okay.
18 A. Would you repeat.
19 Q. Sure.
20 The school at some point moved to a Google Apps
21 for Education platform, or Rimma did.
22 A. I believe so.
23 Q. And that allows the school to share documents
24 and conduct surveys; correct?
25 A. Correct.
800.211.DEPO (3376)
1 Q. Okay. And that was an issue that was important

2 for the accreditation process with WASC; correct?
3 A. It was not essential.
4 Q. I didn't say it was essential. I said it was
5 important.
6 A. It was not important.
7 Q. It was not important?
8 A. Correct.
9 Q. Okay. So it was unimportant?
10 A. It was not essential.
11 Q. Well, what's the difference between "essential"
12 and "important" and "not important"?
13 A. Because we have gone through several WASC
14 accreditations prior to this without being on Google
15 Apps for Education.
16 Q. When was the last accreditation that the school
17 went through?
18 A. I am not sure. I believe -- I can figure it
19 out.
20 Q. They come up every six years.
21 A. Not necessarily.
22 Q. Not necessarily. So when was the last that the
23 school went through that?
24 A. Every school goes through a mid-year review, so
25 I believe -- Starting in -- I should know -- 2010, I
800.211.DEPO (3376)
YVer1f
1 believe.
2 Q. Okay. Was it as elaborate and extensive as the
3 one in 2012?
4 A. No, because it was a mid-year term and someone
5 else was writing it.
6 Q. Okay. You have been at the school for 12 years
7 now?
8 A. Correct.
9 Q. Okay. Do you remember or do you recall any
10 accreditation process that was as elaborate as the one
11 in 2012, '13?
12 A. Could you clarify "elaborate."
13 Q. "Elaborate" meaning the same level of time and
14 effort was put into the submission.
15 A. Yes, I can.
16 Q. Which one?
17 A. They're for 2007.
18 Q. 2007?
19 A. Correct.
20 Q. Were you handling that process?
21 A. I was not.
22 Q. Who was handling that process?
23 MR. WILLIAMSON: Who chaired it? Is that the
24 question?
25 THE WITNESS: There were three chairs, I
800.211.DEPO (3376)
YVer1f
1 believe. Jeannie Fleming, Howard Young, and I believe

2 Jenny Shreeve.
3 MR. PERETZ: Okay.
4 BY MR. PERETZ:
5 Q. Who was coordinating the technology aspect of
6 that accreditation, if you remember?
7 MR. WILLIAMSON: Lacks foundation.
8 THE WITNESS: Technology? Can I answer?
10 THE WITNESS: "Technology" as in communication
11 between teachers or technology advancements within the
12 school?
13 MR. PERETZ: Both.
14 THE WITNESS: The technology communication was
15 handled by Jeannie Fleming -- oh, and also Amy Garrett.
17 BY MR. PERETZ:
18 Q. And at the time the techno- -- any technology
19 that --
20 A. I don't recall who was dealing with any
21 technology curriculum.
22 Q. Was there anyone who was dealing with that at
23 that time?
24 A. I wouldn't be able to specify who. I don't
25 know specifically who.
800.211.DEPO (3376)
1 Q. Well, was there anyone, if you recall?

2 A. Yes.
3 Q. Okay.
4 A. I think there were -- Over the period of years
5 there have been several people.
6 Q. Okay. Well, I am talking about the 2007 --
7 A. You are asking me specifically for one person's
8 name at that point. I cannot provide it. I do not
9 know.
10 Q. Okay. Let's go to 4073.
11 A. (The witness complied.) Yes.
12 Q. Okay. And this is an email exchange about some
13 class, I believe. Do you see that?
14 A. I do.
15 Q. Okay. And you made the comment, "Why would she
16 think we do or would participate in this?"
17 A. Correct.
18 Q. Okay. Why did you make that comment? What was
19 that --
20 A. Because it was so beyond what -- When I had a
21 quick glance, if I recall, at the email -- at the
22 website, I felt that children already have an intense
23 curriculum program at school and should not be -- My
24 opinion is that the children need to go home and play
25 and be outside and socializing not doing extra academic
800.211.DEPO (3376)
YVer1f
1 curricula.
2 Q. Okay. Let's move to 4074, the next page.
3 A. Yes.
4 Q. Okay. Why don't you read this email.
6 Q. And when you are done, let me know.
7 A. Yes.
8 Q. It seems that back in September of 2011
9 Ms. Gale asked for your assistance -- assistance or
10 opinion in regard to the tension between the Romes and
11 the Breezes. Do you recall that?
12 A. I do.
13 Q. Do you recall if there was any follow-up email
14 or conversation other than this email?
15 A. Well, there was conversation.
16 Q. What came up during that conversation?
17 A. That -- We suggested that someone neutral
18 should be brought in to help mediate the situation.
19 Q. Okay. Anything else that you remember?
20 A. No.
21 Q. You weren't part of that mediation; correct?
22 A. Correct.
23 Q. Did you talk to Alex Rome about this mediation?
24 A. No, I did not.
25 Q. Okay. Were you -- Were your discussions only
800.211.DEPO (3376)
YVer1f
1 with Ms. Gale about this or --

2 A. Correct.
3 Q. Okay. There is a comment here. "Apparently,
4 Chip Rome is really fed up." Do you see that?
5 A. Yes, I do.
6 Q. Do you recall if Ms. Gale elaborated by that
7 when she said that (sic)?
8 A. I think he was ready to pull his children out
9 of the school.
10 Q. Okay. Anything else other than that? Do you
11 recall why he was pulling his kids out of the school?
12 A. Because of the tension between the Breezes
13 and --
14 Q. That's an assumption you are making or this is
15 what --
16 A. Yeah. That's what I -- It was an assumption,
17 and I knew it.
18 Q. Okay. Let's go to the next page, 4075.
20 Q. And that's an email that Sarah Harrison then
21 sent to the Leadership Team of the school; correct?
22 A. It was called the Leadership Team for WASC
23 purposes.
24 Q. Well, are you qualifying that; meaning it
25 wasn't the Leadership Team of the school?
800.211.DEPO (3376)
YVer1f
1 A. Correct.
2 Q. Why not?
3 A. Because there's really only two people who
4 are part of the leadership of the school, and that's
5 Ms. Gale and Mrs. Augustine.
6 Q. Why did you put a table that was submitted
7 to WASC that included the Leadership Team with nine
8 different people and not just Ms. Baer and
9 Ms. Augustine (sic)?
10 A. Because we wanted them to understand -- Evans
11 is a school that has a lot of unofficial roles, and we
12 wanted it to seem -- or be more formal so they would
13 have a greater understanding of what people did without
14 specific titles. We did not have titles at The Evans
15 School officially.
16 Q. In your mind, was Rimma Breeze part of the
17 Leadership Team at the school at that time?
18 A. No.
19 Q. She was not?
20 A. No.
21 Q. And neither were Kristy Soo or Gale Dixon;
22 correct?
23 A. Correct.
24 Q. Now, who gave the title of Technology Advisor
25 to Gay Dixon? Whose idea was that?
800.211.DEPO (3376)
1 A. I don't recall. It would have been Sarah or

2 myself.
3 Q. And do you believe that the title fairly
4 characterized Ms. Dixon's involvement, whether formally
5 or informally, with the school?
6 A. A lot of people wear a lot of hats at Evans
7 School. That's one of her roles.
8 Q. So that hat is accurate? The description of
9 that hat -- this hat is accurate; correct?
10 A. Correct.
11 Q. Okay. And who gave Rimma Breeze the
12 description of "Director of Technology"?
13 A. I believe Sarah and I did.
14 Q. Okay. And do you feel that it was a fairly
15 accurate title for what Rimma did at the school at that
16 time?
17 A. I wouldn't say "Director." She was suggesting
18 ways in which we could improve our technology, but -- So
19 she was giving us direction, but she did not have the
20 official title of "Director of Technology."
21 Q. Well, why did you include it this way in the
22 WASC application?
23 A. To make it clearer for -- that we did have one
24 person who was fulfilling that role.
25 Q. So was it an accurate description or not an
800.211.DEPO (3376)
YVer1f
1 accurate description of Rimma's role?

2 A. I would preferred it to have been "Technology
3 Volunteer."
4 Q. Well, so why did you put "Director of
5 Technology"?
6 A. Because we were just trying to formalize the
7 roles of the people involved at school.
8 Q. Okay. So what -- If this role is inaccurate,
9 why did you not put a more accurate role?
10 A. In the same way Hannah Obradovich's says
11 "Director of Summer Programs." She is not really a
12 director of summer programs.
13 Q. I see.
14 So these titles are just --
15 A. Throw-away.
16 Q. Not fake titles --
17 A. No.
18 Q. -- so you get accredited?
19 A. No.
20 Q. Okay.
21 A. No. This is not a requirement for
22 accreditation through WASC. This was Sarah and I being
23 organized and as informative as possible so that when
24 people came to the school they would know who had the
25 role of what.
800.211.DEPO (3376)
YVer1f
1 Q. Ms. Dunford, when you submitted or prepared the

2 submissions to WASC, did you have any intention to
3 deceive or defraud WASC about certain aspects of the
4 school?
5 A. Absolutely not.
6 MR. WILLIAMSON: Badgering.
7 MR. PERETZ: Okay.
8 BY MR. PERETZ:
9 Q. Did you prepare this table with the attempt to
10 deceive WASC about the roles of the individuals at the
11 school?
12 A. Absolutely not.
13 MR. WILLIAMSON: Badgering.
15 BY MR. PERETZ:
16 Q. Is it fair to say that this table -- the
17 Leadership Team table accurately reflects the roles of
18 the individuals at the school in February of 2013?
19 A. They're roles that were informal, and we were
20 just trying to formalize them for the purpose of WASC;
21 to inform them as to what people did.
22 Q. I understand that.
23 Are these formal roles descriptors accurate or
24 they are deceptive (sic)?
25 A. Accurate, if I had to choose between one of the
800.211.DEPO (3376)
YVer1f
1 two.
3 Did Rimma Breeze force you to use the term
4 "Director of Technology" as a descriptor for her
5 position?
6 A. She did not force me, but I know she was using
7 it outside of Evans School.
8 Q. Okay. Did she request or make the demand that
9 she be referred to as the director of technology?
10 A. She did not.
11 Q. Okay. So this is something that you
12 voluntarily decided to use in terms of the description
13 of Rimma's role at the school; correct?
14 A. Repeat that, please. I was thinking about
15 something.
16 Q. Well, yeah.
17 The "Director of Technology" description was a
18 title that you voluntarily decided to use when you
19 decided to describe Rimma's role at the school for the
20 purpose of the WASC application; am I correct?
21 A. Sarah Brumfield and I gave her that throw-away
22 title for the purpose of this chart only.
23 Q. What did you mean by "throw-away"? It means
24 nothing?
25 A. No. That's not a formal title.
800.211.DEPO (3376)
YVer1f
1 Q. I see.
2 So it's an informal title or --
3 A. It was a description.
4 Q. It's a wink-wink-nod-nod title? I don't
5 understand what's the difference between a throw-away
6 title or a title that you use for some official filing.
8 facts, mischaracterizes the document, asked and
9 answered. I'm not sure what else you want her to say,
10 Counsel.
11 MR. PERETZ: I want to understand what she
12 means by "a throw-away title."
13 THE WITNESS: That there wasn't a whole lot of
14 thought put into it. It was just: What are the roles
15 of these people? Oh, let's add that to it and call it
16 that.
18 THE WITNESS: Could have been "Technology."
19 Could have just been "Technology." It didn't have to be
20 "Director of Technology."
22 BY MR. PERETZ:
23 Q. If you follow that page to -- with Bates stamp
24 4066 through bates stamp 4085, 10 pages, what -- this
25 table appears again and again in various communications
800.211.DEPO (3376)
YVer1f
1 between school staff.

2 A. It's a thread.
3 Q. It's forwarded several times.
4 MR. WILLIAMSON: It's forwarded?
5 THE WITNESS: It's a thread. It's just
6 forwarded in the same original form. It's replies and
7 it happens to still contain that table.
8 BY MR. PERETZ:
9 Q. That thread circulated that table several
10 times. Would you agree with me?
11 A. Well --
12 MR. WILLIAMSON: The document speaks for
13 itself.
14 BY MR. PERETZ:
15 Q. That table appears one, two, three, four, five,
16 six, seven times in that thread, eight times in that
17 thread; is that correct?
18 MR. WILLIAMSON: Are you testing her ability to
19 count?
20 MR. PERETZ: Yes.
21 THE WITNESS: I could have submitted the final
22 thread that would have shown it once.
23 MR. PERETZ: I understand that.
24 BY MR. PERETZ:
25 Q. That table appears eight times in that thread;
800.211.DEPO (3376)
YVer1f
1 correct?
2 MR. WILLIAMSON: The document speaks for
3 itself.
4 MR. PERETZ: I understand. I am trying to move
5 on. If you keep on saying that objection, we can't move
6 on.
7 THE WITNESS: There are eight copies within
8 this stack of emails.
9 MR. PERETZ: Okay.
10 BY MR. PERETZ:
11 Q. When that -- Did anyone made an objection to
12 the descriptor of Rimma's position as the Director of
13 Technology that you can recall (sic)?
14 A. Not that I can recall.
15 Q. Thank you. Let's move to 4090.
17 MR. PERETZ: Yes. 4091 -- 90. I am sorry.
18 (The witness complied.)
20 BY MR. PERETZ:
21 Q. That's an email from July 22nd, 2013. Do you
22 see that?
23 A. I do.
24 Q. Did you have a copy of that email in realtime?
25 A. No.
800.211.DEPO (3376)
YVer1f
1 Q. So you just see it now?

2 A. Correct.
3 Q. I mean you saw the email for the first time
4 when you went to the admin email address?
5 A. Correct.
6 Q. Were you ever made aware that Sarah Harrison,
7 on July 22nd, made some request to Rimma Breeze?
8 A. No.
9 Q. Okay. What was your understanding in July 22nd
10 of 2013 about Rimma's role at the school?
11 A. I was in England at the time. I had left three
12 or four weeks previously and --
13 Q. When did you leave? Like end of June?
14 A. End of June, yeah.
15 Q. Okay. When you were in England, did you have
16 any communications with anyone at the school?
17 A. No.
18 Q. Not at all?
19 A. I can't say not at all, but it would have been
20 minimal. "I am here. Here are some pictures of my
21 mom's dog." Regarding school issues, no.
22 Q. Okay. So you weren't aware of what was going
23 on --
24 A. No.
25 Q. -- in terms of what Rimma was going through;
800.211.DEPO (3376)
YVer1f
1 correct?
2 A. No, I was not. Correct.
3 Q. And when did you come back?
4 A. I don't recall. It was the beginning of August
5 or so.
6 Q. Okay. And you prepared Exhibit 36; correct?
7 A. I did.
8 Q. Okay. Who asked you to prepare it, if anyone?
9 A. Nobody asked me to prepare it. We discussed
10 it, that it should happen.
11 Q. Who discussed it?
12 A. I don't recall specifically. Probably
13 Ms. Gale, myself; maybe Gay was in on the conversation,
14 maybe Sarah Brumfield.
15 Q. Okay. And what was the discussion about? What
16 came up during the discussion? By all means, look at
17 the document.
18 A. Okay.
19 Q. I mean, this is not a test of your memory.
20 A. Okay.
21 Q. What came out in the discussion that led you to
22 write Exhibit 36?
23 A. We were concerned that we did not have control
24 of the technology aspects regarding communication, and
25 we did not want any come-back from any parents that
800.211.DEPO (3376)
YVer1f
1 things were too -- if things were to go wrong, in simple

2 terms. And just wanted to advise our parents that we
3 knew that this had happened and that we wanted to be, as
4 you would, cautious.
5 Q. Okay. Now this Exhibit 36 is addressed to the
6 teacher, but you prepared the same --
7 A. For the parents.
8 Q. -- the same document to the parents. I believe
9 that's Exhibit 29.
10 MR. PERETZ: Do you have the exhibits?
12 BY MR. PERETZ:
13 Q. I will show it to you, and I will just confirm
14 that.
16 Q. Correct?
17 A. Correct. Slightly different, but yes.
18 Q. I mean, the language is obviously slightly
19 different, but you were the one who prepared most of
20 them; correct?
21 A. I believe so, yes.
22 Q. After your discussion with Gale Baer; correct?
23 A. Correct.
24 Q. Okay. And you mentioned here in Exhibit 36
25 that there is a mention about a security breach.
800.211.DEPO (3376)
YVer1f
1 A. Correct.
2 Q. Okay. What was the security breach that you
3 were referring to?
4 A. That was a general term that we felt that we --
5 I don't know at that point whether we were suspicious
6 or had been confirmed that emails had been read by
7 Rimma.
8 Q. Okay. So that was what you were referring to?
9 A. Correct.
10 Q. And during that time, meaning the second half
11 of August after you came back --
12 Let us put it this way: After you came back
13 from England, whenever it was, were parents asking or
14 inquiring about the situation with Rimma and those
15 security breaches?
16 A. Some parents did ask, but I don't recall at
17 what point specifically.
18 Q. How many parents do you recall asked for that?
19 A. Maybe one or two.
20 Q. Okay.
21 A. Because once this was announced, Ms. Gale
22 obviously asked for nobody to be communicating or
23 talking about it, and we did not. We followed through
24 on that.
25 Q. Okay. And whose idea was it to recommend to
800.211.DEPO (3376)
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1 the parents and teachers to change passwords of their

2 emails or computer devices?
4 Q. Was it your idea?
5 A. I don't know if it was my specific idea, but it
6 was a good idea, I thought.
7 Q. Okay. Do you recall if that was recommended at
8 any time prior to that for parents or teachers of The
9 Evans School?
10 MR. WILLIAMSON: You can answer.
11 THE WITNESS: I don't recall.
12 BY MR. PERETZ:
13 Q. Meaning you don't recall that recommendation
14 being made?
15 A. I don't recall us ever asking parents
16 specifically to change their email passwords.
17 Q. Okay. And Exhibit 35 is a bulletin. Why don't
18 you look at that.
20 Q. And there is another reference to -- There is a
21 reference to a lawsuit.
22 A. Correct.
23 Q. If you look at the second page.
24 A. Um-hum.
25 Q. Who prepared that blurb, the one about the
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1 school being in the middle of a lawsuit?

2 A. Ms. Gale.
3 Q. Did you have any discussions with her about
4 that?
5 A. No.
6 Q. Were you aware that the school was in the
7 middle of a lawsuit when this communication came out?
8 That's September 10 of 2013.
9 A. I guess I was made aware, yes.
10 Q. How were you made aware of that?
11 A. Sarah Brumfield, I believe.
12 Q. What did she tell you?
13 A. That she was concerned that we were not able to
14 get into the web -- the communication emails, et cetera,
15 and the admin stuff -- and that she wasn't sure what was
16 going on but that it was an issue that we had.
17 Q. Okay. Did you -- I'd like to show you
18 Exhibit -- Exhibit 30.
19 MR. PERETZ: Do you have the exhibits from
20 yesterday?
21 MR. WILLIAMSON: Yes. I will use 31. It's
22 bigger.
23 MR. PERETZ: Okay. That's fine.
24 BY MR. PERETZ:
25 Q. Look at Exhibit 31.
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2 Q. Do you recognize this document?
3 A. It looks like every other document that
4 Ms. Gale sends out. I mean, I think I read it, yes.
5 Q. Okay. Did you -- Do you recall any discussion
6 with Ms. Gale's -- with Ms. Gale about this specific
7 letter that was sent out?
8 A. I think I remember saying that she is totally
9 telling her that I thought it was well written and a
10 very honorable way to handle it.
11 Q. Okay. Good. Look at Exhibit 32 now.
12 MR. PERETZ: If you don't have it, I can show
13 her.
15 (The witness complied.)
16 BY MR. PERETZ:
17 Q. Did you ever look at Exhibit 30 -- I am sorry.
18 Did you ever see Exhibit 32?
19 A. I have never seen it.
20 Q. That is the first time you see it?
21 A. Correct.
22 Q. Okay.
23 MR. PERETZ: Let's mark exhibit next in line,
24 which will be Exhibit 39.
800.211.DEPO (3376)
1 MR. PERETZ: Okay.

2 BY MR. PERETZ:
3 Q. Why don't you review Exhibit 39.
5 Q. And let me know when you are done. Ignore the
6 heading, obviously.
7 A. Um-hum. Yes.
8 Q. Do you recall getting the email from Rimma on
9 June 19th, 2013?
10 A. I do.
11 Q. And you responded to that email; correct?
12 A. Correct.
13 Q. And essentially in her email she is mentioning
14 that -- to you she is mentioning that she noticed that
15 somebody attempted to change the administrative password
16 with Google Apps for Education. Do you see that?
17 A. I do.
18 Q. And she asked you, essentially, if you know
19 anything about it.
20 A. Um-hum. Yes.
21 Q. And your response is that you -- that you did
22 that?
23 A. I did.
24 Q. And why did you assent to change the
25 Administration Google App for Education that the
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1 administration --
2 A. Because we had sent out, like, a survey to the
3 teachers. It was in the Google Doc platform, and we --
4 I was trying to share it with Ms. Gale, but she had
5 forgotten her password. So to share it she had to sign
6 it, and I was trying to retrieve her password.
7 Q. What was the notice about?
8 A. Wrap-up of the school year, regarding what
9 worked well this year, how many paychecks do you want
10 next year; you know, just general kind of --
11 Q. A service to the teacher?
12 A. Teachers.
13 Q. I mean to the teachers.
14 A. I believe it was that, yes.
15 Q. Okay. And why didn't you ask Rimma for the
16 password before you attempted to change them (sic)?
17 A. Because I was sitting there with Gale right
18 there and I thought I could do it. I was sitting there
19 with Gale right there and was trying to allow her to
20 view the document that she was not -- I thought; whether
21 you do or don't, I don't know, but I was trying to have
22 her sign in to her Google account, and she couldn't
23 recall her password. And she was trying several
24 attempts, and then I tried to help her reset it so she
25 could get in and view the document.
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1 Q. Before that, did you ever attempt to reset

2 passwords to any of the Google Apps for Education
3 accounts, either yours or someone else's?
4 A. Not that I recall. I know how to do it now,
5 but I don't think I knew exactly how to do it then.
6 Q. Okay. And after that, do you remember if you
7 ever tried to do it again while Rimma was there?
8 A. I did not.
9 Q. Okay.
10 A. I believe Rimma communicated with Gale
11 regarding it, but I don't know what the outcome was.
12 Q. I am sorry. I think I didn't catch the date.
13 Were you in England at the end of July?
14 A. Yes, I probably was.
15 Q. The last week of July?
16 A. Yes.
17 Q. Okay. And you were disengaged from any school
18 activities?
19 A. Correct.
20 Q. And do you recall any acts of vandalism that
21 happened in the school during the last five years?
22 A. I do.
23 Q. Which ones do you recall?
24 A. The one -- There was one when Sarah Brumfield
25 and I were in North Carolina with Ms. Gale. If you are
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1 going to ask me for the date, I would have to think

2 about it, but it was the vandalism on the exterior of
3 the building.
4 Q. What year was it?
5 A. Well, it was during the WASC process. If you
6 left me a minute, I might be able to figure out when it
7 was.
8 Q. Sure. Take your time.
9 A. In the fall, I think. I believe it to have
10 been in the fall of 2012.
11 Q. And --
12 A. I might be wrong about that, but that's my best
13 recall -- my best recollection.
14 Q. That's perfectly fine. I am just trying to
15 estimate.
16 How did you learn about that?
17 A. I took the phone call. I believe it was --
18 Marianne Augustine was still here in La Jolla at the
19 school, and she called because Sarah, Gale, and I were
20 the only three in North Carolina. She called -- We were
21 driving in the car, and she called to say that there had
22 been vandalism during the night.
23 Q. And when that happened, and after that, did
24 Gale Baer ever tell you that she feared for her safety
25 or her life because of this account of vandalism?
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1 A. Yes, she did fear for her safety.

2 Q. How do you know that?
3 A. Because we had discussion about it.
4 Q. Well, that's a good answer. I'm sorry. Okay.
5 The discussion took place when you were still
6 in North Carolina?
7 A. No, because she left right away.
8 Q. Oh, I see.
9 A. She flew -- Sarah and I stayed for another
10 24 hours to work on WASC, but she flew right back to
11 handle the situation.
12 Q. And when you came back, you had a discussion
13 with Ms. Baer about it; correct?
14 A. Correct.
15 Q. And she said something to the effect "I am
16 fearing for my safety" or "the school safety"?
17 A. She was just nervous about living there by
18 herself, as anyone would be, with -- with having had
19 someone come onto the school and do that to her property
20 and her -- you know, her school when she is living on
21 campus. Of course, anybody would be fearful.
22 Q. That makes sense.
23 Do you know if a police report was filed?
24 A. I don't know.
25 Q. You don't know one way or the other?
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1 A. No, I don't know one way or the other.

2 Q. Okay. Did Ms. Baer ever tell you who did that
3 or who she suspects?
4 A. No.
5 Q. Okay. And my understanding is that after that
6 event some security came onto the school and cameras
7 were installed in the school.
8 A. Correct.
9 Q. After that incident of vandalism, do you recall
10 any other incident of vandalism that happened at the
11 school?
12 A. No.
13 Q. Again, I don't want to go back. During the
14 last five years.
15 A. No.
16 Q. Okay. Do you recall if during the last couple
17 years a couple parents complained that their tires were
18 slashed in the parking lot?
19 A. Now that you said that, I think it was during a
20 time when I was -- I've had a lot going on in my life,
21 you know, some -- yes. Now that you have said it, I
22 guess there was something about someone's tires, but it
23 was not a big deal. Like it wasn't a big issue. It
24 wasn't a big conversation.
25 Q. Okay. And when did this happen?
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1 A. More recently than that, but I don't know at

2 what point.
3 Q. Were you in England during that time?
4 A. During which time?
5 Q. When the tires of someone were slashed.
6 A. Well, no, I believe not, because I believe it
7 was during school time.
8 Q. Okay. So you were around?
9 A. I guess I was, yes. I suppose I was.
10 Q. What do you recall about that? What do you
11 recall of that?
12 A. It may have been a day when I wasn't -- I don't
13 work full time. So it may have happened -- Usually
14 things happen, they are discussed, and we move on. I
15 don't recall a big conversation -- me being involved
16 specifically in a big conversation about that.
17 Q. Did Ms. Baer ever communicated to you that she
18 feared for her safety or her life because of that event
19 (sic)?
20 A. I believe we changed the security pass on the
21 front gate. But feared for her life? She has been
22 concerned.
23 Q. Okay. Did she communicated to you who she
24 thinks caused that (sic)?
25 A. No.
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1 Q. Do you recall any other case of vandalism

2 during the last five years?
3 A. No.
4 Q. Okay. Did Ms. Baer ever communicated to you
5 that she was fearful of Rimma -- Rimma Breeze (sic)?
6 A. She has said that she feels she would not --
7 after the way that she reacted in the meeting -- during
8 the meeting that took place in, I believe, July when I
9 was in England that I have since learned about -- that
10 she was concerned then.
11 Q. Well, you weren't here at the time of the
12 meeting.
13 A. Correct.
14 Q. You were in England.
15 A. Correct.
16 Q. And you weren't in touch with Gale Baer during
17 that time; correct?
18 A. Correct.
19 Q. So when did you hear that comment?
20 A. Several times over the last year. I don't know
21 specifically.
22 Q. Okay. And what was the extent of the comment
23 that after that meeting --
24 A. No. When Ms. Gale was discussing that
25 meeting --
800.211.DEPO (3376)
1 Q. Okay.
2 A. -- she said she was fearful because she was
3 there alone and because of Rimma's behavior that she was
4 fearful.
5 Q. Okay.
6 A. In that meeting.
7 Q. And what did she -- Sorry.
8 What did she say about Rimma's behavior that
9 caused her to be fearful? Did she say anything?
10 A. Well, yes. She said she was distraught, she
11 was screaming, yelling; that she was very uncontrolled
12 and just seemed very -- sort of not in a good place.
13 Q. Okay.
14 A. That's the way Ms. Gale describes things.
15 Q. Yeah, I get that.
16 And that's the way she described that to you;
17 correct?
18 A. Yes.
19 Q. Okay. And do you know what came up -- Did she
20 say what came up during that meeting?
21 A. She told me some of the conversation, a little
22 bit.
23 Q. What did she tell you?
24 A. She told me that she met with Rimma to discuss
25 her role -- or her presumed role as aiding the IT at
800.211.DEPO (3376)
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1 The Evans School and that she felt that -- I don't know
2 exactly how that whole meeting came about. I don't
3 know -- Oh, I do. I beg your pardon.
4 I think it was to do with -- something to do
5 with the summer camp and Rimma's role in that. And that
6 was why the meeting had ultimately taken place, but I
7 believe it had gone on to different subjects while that
8 meeting took place regarding that Rimma -- that Gale did
9 not think that she could carry Rimma. And she was
10 expecting the tuition payment, and that's how -- I don't
11 know the exact details, but in general terms that was
12 it.
13 Q. How many discussions have you had with Ms. Baer
14 about this meeting and how Rimma reacted?
15 A. Not many.
16 Q. Two or three of them?
17 A. Two or three.
18 Q. And they were all during the last year or so?
19 A. Yes.
20 Q. Okay. And was her description consistent in
21 terms of that Rimma was screaming and yelling during
22 that meeting?
23 A. Yeah.
24 Q. Okay.
25 A. Although that didn't come up in every
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1 conversation.
2 Q. I get that.
3 A. Rimma's behavior was not always the crux of the
4 conversation regarding that meeting.
5 Q. Okay. So what other aspects of the meeting did
6 she describe?
7 A. It was just financial arrangements.
8 Q. Okay.
9 A. Not details but that that was what the meeting
10 ended up escalating into.
11 Q. And you never had discussions with Rimma about
12 it; correct?
13 A. Correct.
14 Q. After Rimma -- After you returned from England,
15 did you ever have any discussion with Rimma?
16 A. No.
17 Q. Okay. And as part of your -- You are an
18 employee of the school; correct?
19 A. Correct.
20 Q. A part-time employee? I think you mentioned --
21 A. Currently.
22 Q. Currently you work part time?
23 A. Um-hum. Almost full time.
24 Q. Okay.
25 A. I'm on school premises part time, but the hours
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1 I work are full time.

2 Q. Well, all teachers work way above the class
3 time.
4 A. Um-hum.
5 Q. But what's the official hour capacity at the
6 school? I mean, is it 10 hours a week, 20 hours a week,
7 30 hours?
8 A. We don't really go by hours, but I work
9 three-and-a-half days.
10 Q. Okay. So that's how it works?
11 Three-and-a-half days?
12 A. For me, yes.
13 Q. Okay. And do you get a break on tuition as
14 part of your compensation package?
15 MR. WILLIAMSON: That violates her privacy.
16 She has a right of financial privacy. It's hers to
17 decide whether to disclose or not. I am advising the
18 witness that she doesn't have to.
19 BY MR. PERETZ:
20 Q. Specifically I did not ask, you know, what
21 tuition discounts you get or what is the amount or
22 anything like that, or how much you make. And I do
23 think that it's discoverable, with all due respect.
24 The only question I'm asking now is: Is part
25 of your tuition discount or waiver?
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1 MR. WILLIAMSON: You can answer the question.

2 It's up to you.
3 THE WITNESS: Repeat the question.
4 MR. PERETZ: Yes.
5 BY MR. PERETZ:
6 Q. My question is whether part of your
7 compensation for working at the school includes tuition
8 waiver or discount.
9 A. You know, I -- I don't discuss financials with
10 my family and friends. I mean, I don't --
11 THE WITNESS: Do I have to answer that?
12 MR. WILLIAMSON: I'm not going to tell you you
13 have to answer the question. I think it invades your
14 privacy.
15 MR. PERETZ: Well, you are basically telling
16 her to not answer that. I don't believe it's true,
17 but --
18 THE WITNESS: You don't believe that what?
19 Sorry.
20 MR. WILLIAMSON: We are disagreeing on the law.
21 MR. PERETZ: We're disagreeing on the law.
22 THE WITNESS: Okay. Sorry.
23 BY MR. PERETZ:
24 Q. This is legal banter, nothing that has to do
25 with you. Would you answer or not to answer the
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1 question (sic)?
2 A. I prefer not to answer the question.
3 Q. So you are not answering that question?
4 A. Correct.
6 MR. PERETZ: I want to take a literally
7 five-minute break to see if I have anything else. And
8 if not, we are done. Okay?
9 MR. WILLIAMSON: Okay. So let's go off the
10 record for five minutes.
11 (Recess.)
12 MR. PERETZ: I have no further questions.
13 Thank you so much. He is just going to have to put it
14 on the record and you can go. Thank you so much.
15 MR. WILLIAMSON: Same stipulation we have used
16 before.
17 MR. PERETZ: Can we just insert it?
19 MR. PERETZ: Just insert the same stipulation
20 as before.
21 (The following stipulation was entered into by
22 and between counsel:)
23 "MR. WILLIAMSON: We are going to stipulate to
24 relieve the court reporter of her custodial duties under
25 the Code. The transcript will be prepared in the normal
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YVer1f
1 course and sent to Gordon Rees for the witness.

2 We will make the transcript available to the
3 witness for review and signature. We will get the
4 review and signature within two weeks of our receipt of
5 the transcript, and immediately after signature we will
6 provide notice to counsel of the fact of signature and
7 any changes to the transcript.
8 We will maintain custody of the original, make
9 it available upon reasonable request, and lodge it with
10 the court at the time of trial without the need for
11 further request.
12 If the original is not signed, lost, damaged,
13 destroyed, or not made available, a certified copy can
14 be used for any and all purposes, including trial, as if
15 it were a signed, unchanged original transcript."
16 MR. PERETZ: So stipulated.
17 (The deposition concluded at 1:40 p.m.)
18 * * *
19
20
21
22
23
24
25
800.211.DEPO (3376)
1
2 REPORTER'S CERTIFICATION
3
4 I, FRAUKE KUO, a Certified Shorthand Reporter in
5 and for the State of California, do hereby certify:
6
7 That the foregoing witness was by me duly sworn;
8 that the deposition was then taken before me at the time
9 and place herein set forth; that the testimony and
10 proceedings were reported stenographically by me and
11 later transcribed into typewriting under my direction;
12 that the foregoing is a true record of the testimony and
13 proceedings taken at that time.
14
15 IN WITNESS WHEREOF, I have subscribed my name this
16 10th day of September 2014.
17
18
19
20 ______________________________
21 FRAUKE KUO, CSR No. 6283
22
23
24
25
800.211.DEPO (3376)
1 DEPOSITION ERRATA SHEET

2
3 Our Assignment No. 185549A
4 Case Caption: BREEZE v. THE EVANS SCHOOL
5
6 DECLARATION UNDER PENALTY OF PERJURY
7
8 I declare under penalty of perjury that I have
9 read the entire transcript of my deposition taken in the
10 above-captioned matter, or the same has been read to me,
11 and the same is true and accurate, save and except for
12 changes and/or corrections, if any, as indicated by me
13 on the DEPOSITION ERRATA SHEET hereof, with the
14 understanding that I offer these changes as if still
15 under oath.
16
17 Signed on the ______ day of _________________
18 2014.
19
20
21 _________________________________________
22 SARAH ANNE DUNFORD
23
24
25
800.211.DEPO (3376)

2 Page No. _____ Line No._____ Change to:_________________
3 ________________________________________________________
4 Reason for change:______________________________________
6 ________________________________________________________
9 ________________________________________________________
12 ________________________________________________________
15 ________________________________________________________
18 ________________________________________________________
21 ________________________________________________________
23
24 SIGNATURE:______________________________________________
800.211.DEPO (3376)

3 ________________________________________________________
6 ________________________________________________________
9 ________________________________________________________
12 ________________________________________________________
15 ________________________________________________________
18 ________________________________________________________
21 ________________________________________________________
23
24 SIGNATURE:______________________________________________
800.211.DEPO (3376)

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SARAH DUNFORD September 05, 2014

RIMMA BREEZE vs. EVANS SCHOOL 1

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SAN DIEGO

RIMMA BREEZE, an individual,

vs. Case No. 37-2013

RIMMA BREEZE, an individual; COLIN

SARAH ANNE DUNFORD

Frauke Kuo, CSR No. 6283

3 For the Plaintiff and Cross-Defendants:

4 PERETZ & ASSOCIATES

15 RIMMA BREEZE, Plaintiff/Cross-Defendant

2 WITNESS: SARAH ANNE DUNFORD

2 Exhibit Description Page

3 Exhibit 34 Amended Deposition Re-Notice of 5

6 Exhibit 36 Letter to Teachers, 8/27/13 13

9 Exhibit 38 Emails, TES4001-4110 (110 pages) 14

10 Exhibit 39 Emails, 6/19/13 (1 page) 136

14 Exhibit 31 Letter from Evans School to Parents 135

1 DEPOSITION OF SARAH ANNE DUNFORD

1 On occasions we don't remember things as best

1 not be able to tell me the exact thing that I am asking

1 the intersection, when you go home if I said the light

1 A. Sarah Anne Dunford.

1 documents stamped 732 through 3278. The other CD

1 MR. PERETZ: Let's mark TES4001 through

1 to you at this point, no matter which one of the

1 Q. And when you say "all of my email accounts,"

1 Q. That's the two that you actively use?

1 required, anything to do with WASC.

1 A. That's the only documentation that relates, I

1 A. I did, and I did find it last night in this

1 A. Yeah. So then I went into each -- I went

1 A. I did not print those on September 1st. I

1 A. The handwritten notes that I placed with the

1 through your class or was in your class (sic)?

1 A. I did not clear California credential.

1 can have that as a time mark?

1 I believe, I went to her house, along with some other

1 Q. Was it during the last two years?

1 Q. And when was the last you were in communication

1 Q. And is that a discussion you had when she asked

1 use double-negatives, sometimes it's confusing.

1 A. Because I had heard them -- They had talked to

1 conversation? Meaning the lunch meeting.

1 Q. May of 2013. That's what you mentioned.

1 A. Ms. Gale had met with both parties, and I was

1 was the one causing trouble.

1 Q. Again, I am trying to find out information.

1 A. In your question it reminded me that there has

1 A. General chitchat. We talked about how Alex had

1 So after that Ms. Baer told you "I took the

1 Q. Other than emails, do you recall anything else

1 A. Because she was sick.

1 A. I was just reporting that that was a comment by

1 Rimma doing?" And Colin just looked at us and shook his

1 that date; correct?

1 Q. Okay. In between the end of February until

1 that Rimma suffered from some mental episode or mental

1 Q. Okay. So you get that, that presumably Rimma

1 MR. WILLIAMSON: It's a mischaracterization,

1 about Rimma's well-being at that point? Did you think

1 Q. Okay. And I'd like to -- I think we have