Académique Documents
Professionnel Documents
Culture Documents
Plaintiff,
Defendants.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
MARGARET GALE BAER, an individual,
Cross-Complainant,
vs.
Cross-Defendants.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
DEPOSITION OF
September 5, 2014
2:20 p.m.
402 West Broadway
Suite 1600
San Diego, California
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RIMMA BREEZE vs. EVANS SCHOOL 2
1 APPEARANCES OF COUNSEL
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:
17
18
19
20
21
22
23
24
25
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1 INDEX OF EXAMINATION
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
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1 INDEX TO EXHIBITS
11 EXHIBITS REVIEWED
13
14
15
16
17
18
19
20
21
22
23
24
25
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1 to.
2 MR. WILLIAMSON: Is there some specific portion
3 that you would like her to focus on?
4 MR. PERETZ: Yes.
5 BY MR. PERETZ:
6 Q. You have seen this document before?
7 A. Correct. But you sent different versions. I
8 want to be accurate in saying that this is the same
9 version.
10 Q. Okay. Read it enough to make sure --
11 A. Well, can you tell me what part was revised
12 since the former version?
13 Q. I think the only thing was revised was the date
14 of your deposition, to be honest.
15 A. Okay.
16 Q. So the other language was not revised, but
17 still, it is not identical, so I don't want to lead you
18 to something inaccurate.
19 A. Okay.
20 Q. Are you done with reading?
21 MR. WILLIAMSON: I think this is the version
22 she has seen.
23 So with that representation, if you read the
24 one I sent you, this is the one.
25 THE WITNESS: Okay. Then yes.
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1 mean --
2 Q. Okay.
3 A. I mean, since Google Gmail came out, so I'm
4 very familiar with all of the Google platforms.
5 Q. You are very savvy?
6 A. More or less. I can get by with things
7 necessary to run our school at the level at which Evans
8 needs to function --
9 Q. Okay.
10 A. -- technologically.
11 Q. Okay. And when did you first hear that Rimma
12 will no longer be working at the school?
13 A. It was early to mid-August of last summer, so
14 2013. I'm a little bit fuzzy on my dates. I believe
15 2013.
16 Q. We are in 2014. So last year would have
17 been --
18 A. Yes, 2013.
19 Q. And how did you hear that for the first time?
20 A. I believe I was at school preparing for summer
21 camp and I needed access to my class website. And I
22 asked Gale if I could email Rimma to reset my password,
23 or something along those lines.
24 I'm not sure how it came about, but I recall
25 Gay and Gale being in the room and saying that Rimma was
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1 A. Yes.
2 Q. Okay. After she forwarded from your phone, did
3 you look somewhere else to see where this email is
4 going? I mean, I didn't catch this portion of the
5 discussion.
6 A. No. She just handed my phone back to me and
7 that was all.
8 Q. That was it?
9 A. Um-hum.
10 Q. Is that a "Yes"?
11 A. Yes.
12 Q. Okay. Okay.
13 But then you started hearing information about
14 some forwards that go -- go through Rimma's -- Rimma's
15 email, something to that effect; correct?
16 A. Correct.
17 Q. Did you firsthand review any of those forwards
18 or notice those forwards?
19 A. May I ask what the purpose of the LinkedIn
20 profile is?
21 Q. Just to establish what your work history is.
22 That's it.
23 A. Is my work history relevant?
24 Q. As a background, yes. Just as a general
25 background. As you can see, I didn't ask you how did
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1 BY MR. PERETZ:
2 Q. And you mentioned Dan Swanson. And that's his
3 name, by the way. You are referring to the IT person?
4 A. Correct.
5 Q. Okay. After Rimma left, did you work with him
6 on taking control over the Google Apps for Education or
7 other systems of the school?
8 A. I was not involved in their attempt with Google
9 to regain control of the Google Apps for Education under
10 the emails or under the URL, under theevansschool.com.
11 I had the log-in to the Mail Chimp account that I don't
12 recall if Rimma had emailed me one time or I had it
13 saved somewhere. So I was able to log into the Mail
14 Chimp account and change the password.
15 So that was the one thing that we had control
16 over which previously Rimma had maintained. But other
17 than that, I was not involved in any of the
18 back-and-forth, to my recollection.
19 Q. Were you involved with Dan Swanson, after Rimma
20 left, on any other tasks or issues?
21 A. I mean, I see him around and we touch base on
22 email-account things. He -- He would test, sending an
23 email to my account to see if it showed up in the admin
24 account to see if it was still forwarding.
25 As I recall, there was some trouble turning off
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1 A. No.
2 Q. Okay. And bear with me. I am going to ask you
3 the questions. And if you don't remember, obviously you
4 don't remember.
5 Do you remember how you learned about it?
6 A. I do not.
7 Q. Do you remember if you saw any of the papers
8 that were part of the lawsuit?
9 A. No.
10 Q. Up until today, did you see any papers of the
11 lawsuit?
12 A. I received Exhibit 40.
13 Q. Okay. Other than that, obviously.
14 A. No.
15 Q. Okay.
16 A. I don't even know who started -- who initiated
17 it.
18 Q. Okay. You do understand that you -- that Rimma
19 didn't make any claims against you personally.
20 A. I do.
21 Q. And you understand that the school has
22 identified you as a witness.
23 A. I do now.
24 Q. Okay. You didn't know that?
25 A. I guess I assumed.
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1 statement?
2 A. "That one person" meaning Rimma?
3 Q. Yes.
4 A. Correct.
5 Q. Yeah.
6 A. Correct.
7 Q. Okay. Did anyone express to you that they have
8 a concern to their safety because of Rimma (sic)?
9 A. No.
10 Q. Did you hear Ms. Gale say that, that she has
11 concerns about her safety or life because of Rimma?
12 A. No.
13 Q. Okay. And did you ever had any discussions
14 with Alex Rome in which she told you that she is
15 concerned to her safety in light -- because of Rimma
16 (sic)?
17 A. No.
18 Q. Okay. And did Ms. Rome ever advise you that
19 she had some issues with Rimma in the past?
20 A. Not that I recall.
21 Q. Okay.
22 A. I knew that there was a general discord between
23 them after I had been at Evans a while. I do not recall
24 how I learned of that, but I just recall knowing that
25 they did not get along.
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1 time where the staff was upstairs but Rimma was not
2 there.
3 Q. I don't understand. The comment that you heard
4 from Colin, when did this take place?
5 A. That was what I am saying. I don't recall.
6 Q. I see.
7 A. It was either -- You know, we have certain
8 staff gatherings. At Christmastime we go up to the
9 area --
10 Q. I see.
11 A. -- or the end of the year we go up to the area.
12 Q. Okay. So in one of those gatherings he was
13 there and Rimma was not there?
14 A. Correct.
15 Q. And was it your impression that you -- that
16 Rimma was ill, more than the typical cold or flu or
17 something like that?
18 A. Yes, because we had not seen her for a while.
19 Q. For how long hadn't you seen her?
20 A. I don't recall, but I just remember thinking
21 that I shouldn't have asked that question because it
22 seemed private, so I withdrew.
23 Q. Okay. So during those notes, February to May
24 of 2013, did Rimma help you or assisted you with various
25 issues at the school (sic)?
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1 BY MR. PERETZ:
2 Q. I would like you to look at the Exhibit -- If
3 you look at the bottom number, 4075, Exhibit 38.
4 A. Yes.
5 Q. And that is -- this email includes 12 pages.
6 Why don't you skim through it. I am not going to ask
7 you about each and every thread.
8 A. (The witness complied.)
9 Q. So for this review that email starts -- It's a
10 12-page email from 4075 --
11 A. Yes.
12 Q. -- through 40- --
13 A. I have an 11 of 12 and no 12 of 12, so I assume
14 12 of 12 is blank.
15 Q. Yeah, I assume so. It's not here, so I assume
16 so.
17 A. All right.
18 Q. You went through that email. The top email is
19 the email that you sent; correct?
20 A. Correct. Looks like it.
21 Q. And it seems like a long thread of emails, but
22 when -- around the Leadership Team, the description of
23 the Leadership Team, which is one of the issues of the
24 way it's supposed to be described for WASC purposes;
25 correct?
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1 A. Correct.
2 Q. Now, who came with the titles to all the
3 individuals that are mentioned in this Leadership Team
4 table (sic)?
5 A. Sarah Dunford and I assigned not, per se,
6 titles but more of the descriptions so that a visiting
7 committee could understand the roles in which we
8 functioned. The criteria for the formation of the
9 Leadership Team was to provide a comprehensive group
10 that represented several various stakeholders of the
11 school so that you have parents, alumni, staff somewhat
12 united representing the school.
13 And our school is unique in that it's a sole
14 proprietorship. Nobody has formal titles. I did not
15 know if I was a co-teacher or an assistant for a while.
16 I still don't really know if I'm a head teacher or -- We
17 just don't function that way. We have the owner of our
18 school and we have staff and faculty.
19 And I do many roles within the school that I do
20 not have a title for, so I think that this was our way
21 of explaining roles so that a visiting committee, who
22 comes from larger schools with way more defined
23 organization, could understand the types of roles we
24 have. I mean, obviously "Evans parents" is not a role.
25 It's not a title. This is something that we are doing
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1 A. Absolutely not.
2 Q. Okay. And those titles were reviewed,
3 essentially, by each and every staff member; correct?
4 A. Yes.
5 Q. And no one ever gave you comments and said,
6 "Well, I don't think you should describe," you know,
7 "Gay Dixon as Science and Technology Advisor";
8 correct?
9 A. Correct.
10 Q. Nobody mentioned that; correct?
11 A. Correct.
12 Q. Did Gay Dixon mention something to the effect
13 that "I don't think this is an accurate description of
14 my position with the school"?
15 A. No.
16 Q. Okay. Do you think that describing Gay Dixon
17 as "Science and Technology Advisor" was inaccurate?
18 A. No.
19 Q. Do you think it was a title that appropriately
20 accounts for what she was doing for the school at that
21 time in terms of science and technology?
22 A. In my limited experience with organizational
23 structure and titles, yes.
24 Q. Okay. And let's take Kristy Soo. Do you think
25 that the title that you gave as "Director of Admissions"
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1 was inaccurate?
2 A. No. I have seen her business card, I believe.
3 Q. Okay. She has business cards that say
4 "Director of Admissions"?
5 A. It says -- To the best of my recollection.
6 Q. Okay. And -- Well, from your perspective back
7 in February of 2013, did she not function as director of
8 admissions?
9 A. To the best of my recollection, she did.
10 Q. Okay. And you didn't know then what was the
11 pay arrangement with Kristy Soo; correct?
12 A. I don't know the pay arrangement of anybody.
13 Q. Okay. So it's not like you gave those titles
14 based on whether people were paid, what they were paid,
15 if they were paid, and in what form they were paid;
16 correct?
17 A. Absolutely not.
18 Q. Okay.
19 A. We assigned these descriptions based on what we
20 observed people doing, what people told us that they
21 were helping with or involved in --
22 Q. I see.
23 A. -- to the best of our ability.
24 Q. Okay. No problem.
25 MR. PERETZ: Now, let's mark Exhibit 43.
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1 Rome; correct?
2 A. Yes.
3 Q. Is that a "Yes"?
4 A. Yes.
5 Q. Okay. And you had this email exchange with
6 Alex Rome on September 8 of 2013; correct?
7 A. September 8th -- Yes, based on what the email
8 says.
9 Q. Okay. Okay.
10 Do you believe those dates not to be accurate?
11 A. Seems accurate.
12 Q. Okay. Let's start from the bottom.
13 First of all, at 7:31 a.m., so 7:31 in the
14 morning you sent her a link to the All Hallows Academy
15 website; correct?
16 A. Yes.
17 Q. Okay. And first of all, what made you go and
18 check out the All Hallows Academy website?
19 A. I had assumed either they were attending or
20 that Rimma was doing something with their website,
21 because I believe, now that I see this, that I -- that
22 something on their website had said the site is down for
23 rebuild, or something along that nature. That would be
24 my assumption based on what I wrote below.
25 Q. So when you looked at the website, did you
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1 BY MR. PEREZ:
2 Q. As you sit here today, you are not sure about
3 what warning it is; correct?
4 A. I don't want to testify under oath something I
5 am not sure about.
6 Q. Well, you can give me your best recollection.
7 If you are not sure about it you don't have to say, you
8 know, this is exactly what happened, but you can say
9 something to the effect I believe it was something to
10 the effect of this and this and that. But you cannot
11 use "I don't remember" to deflect some testimony that
12 you are not comfortable with.
13 A. I understand that.
14 Based on Alex's response --
15 Q. Yes.
16 A. -- my best guess that it was something about --
17 to be wary of the Breezes or of giving her access to the
18 website.
19 Q. Okay. And what warning do you refer to,
20 meaning what warning Alex Rome was supposed to give
21 someone at All Hallows that she shared with you?
22 A. I think I just answered that.
23 Q. Right.
24 A. You might need to restate that. I'm not sure
25 what you are asking.
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1 A. No.
2 MR. WILLIAMSON: Lacks foundation, assumes
3 facts, misstates testimony.
4 BY MR. PERETZ:
5 Q. You mentioned that you had some general
6 knowledge that Alex Rome had some friends or parents at
7 the All Hallows school.
8 A. Correct.
9 Q. Who are they?
10 A. I have no idea.
11 Q. You have no idea?
12 A. I have only been in the La Jolla community
13 since the fall of 2011. It's a very different
14 demographic than the majority of the communities, and I
15 am not involved in the parents' relations.
16 Q. Apparently you are involved, but you just don't
17 remember that.
18 A. No, not to that. I do not know who Alex's
19 friend are at All Hallows.
20 Q. Okay. Now, she responds to you and writes,
21 "Oh, they did. They had a meeting with the head and she
22 was shocked." Do you see that?
23 A. I do.
24 Q. Okay. Did you have any follow-up conversation
25 with Alex Rome, what she meant by that?
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 68
800.211.DEPO (3376)
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 69
800.211.DEPO (3376)
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 70
800.211.DEPO (3376)
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 71
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 72
1 A. Yes.
2 Q. And it seems like you had contacted him, but
3 you didn't -- you didn't hear until the time of that
4 email. Do you recall if you talked to him after
5 that?
6 A. Rimma wanted to know -- I mentioned that my
7 friend worked for Google, and she thought he could be a
8 great contact to help us with our Google Apps for
9 Education. And my friend works on the YouTube policy
10 team so had no connection.
11 Q. So that friend got back to you and said I don't
12 work on that.
13 A. Yeah. He had no --
14 Q. No involvement on Google Apps for Education?
15 A. Correct.
16 Q. Did you disclose to him the situation with
17 Rimma or the Breeze family at any point?
18 A. Not that I recall. This was all way before
19 this.
20 Q. Yeah. Okay. I have no further questions.
21 Thank you. Thank you so much.
22 MR. WILLIAMSON: We can use the same
23 stipulations.
24 MR. PERETZ: Yes, same stipulations.
25 (The following stipulation was entered into by
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 73
800.211.DEPO (3376)
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 74
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
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 75
800.211.DEPO (3376)
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 76
800.211.DEPO (3376)
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SARAH BRUMFIELD September 05, 2014
RIMMA BREEZE vs. EVANS SCHOOL 77
800.211.DEPO (3376)
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