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SARAH BRUMFIELD 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.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
MARGARET GALE BAER, an individual,

Cross-Complainant,
vs.

RIMMA BREEZE, an individual; COLIN


BREEZE, an individual; BREEZE
VENTURES MANGEMENT, LLC, doing
business as BREEZE IT CONSULITNG;
and ROES 1 through 10,

Cross-Defendants.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

DEPOSITION OF

SARAH HARRISON BRUMFIELD

September 5, 2014

2:20 p.m.
402 West Broadway
Suite 1600
San Diego, California

Frauke Kuo, CSR No. 6283

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RIMMA BREEZE vs. EVANS SCHOOL 2

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 HARRISON BRUMFIELD

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

2 Exhibit Description Page

3 Exhibit 40 Amended Deposition Re-Notice of 5


Sarah Harrison Brumfield (8 pages)
4
Exhibit 41 S. Brumfield LinkedIn Printout 14
5 (4 pages)

6 Exhibit 42 Emails between S. Harrison and 27


Evans Admin, 7/22/13 (2 pages)
7
Exhibit 43 Emails between A. Rome and 55
8 S. Harrison, 9/8/13, TES589
(1 page)
9
Exhibit 44 Emails (52 pages) 68
10

11 EXHIBITS REVIEWED

12 Exhibit 38 Emails, TES4001-4110 (110 pages) 33

13

14

15

16

17

18

19

20

21

22

23

24

25

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1 DEPOSITION OF SARAH HARRISON BRUMFIELD


2 September 5, 2014
3
4 SARAH HARRISON BRUMFIELD,
5 having been first duly sworn, testifies as follows:
6
7 EXAMINATION
8 BY MR. PERETZ:
9 Q. Good afternoon, Ms. Brumfield. My name is
10 Yosef Peretz. I am a principal of Peretz & Associates,
11 and my firm represents Rimma and Colin Breeze in a
12 lawsuit that involves The Evans School.
13 (Plaintiff Exhibit 40 was marked.)
14 BY MR. PERETZ:
15 Q. And I marked as Exhibit 40 a document that is
16 titled "Amended Deposition Re-Notice of Sarah Harrison
17 Brumfield." Have you seen this document before?
18 A. I have.
19 Q. Okay. Why don't you take a look at it, because
20 we sent several versions and I want to make sure that
21 you went to that version. It's a legal document, and
22 they all look the same.
23 A. You'd like me to read the whole thing right
24 now?
25 Q. Just look at it, unless you feel like you need

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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 MR. PERETZ: Okay.


2 BY MR. PERETZ:
3 Q. And can you please state and spell your name
4 for the record.
5 A. Sure. My first name is Sarah -- S-a-r-a-h,
6 middle name Harrison -- H-a-r-r-i-s-o-n, last name
7 Brumfield -- B-r-u-m-f-i-e-l-d.
8 Q. Okay. Thank you.
9 And you go by Ms. Brumfield, correct,
10 currently?
11 A. Correct.
12 Q. Okay. And Harrison was your maiden name;
13 correct?
14 A. Correct.
15 Q. Okay. And if you look at the document,
16 Exhibit 40, the portion beginning at page 6 that asks
17 you to bring documents today -- You don't have documents
18 with you at the moment; correct?
19 A. Correct.
20 Q. Okay. And is it fair to say that at some point
21 you went through certain files at the school and
22 collected any documents that were responsive to the
23 document request and gave them to your counsel?
24 A. Correct. I produced everything on each of the
25 requests.

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1 Q. And you gave them to your counsel; correct?


2 A. Yes.
3 MR. PERETZ: And Ian, all these documents were
4 produced to us?
5 MR. WILLIAMSON: Yes.
6 MR. PERETZ: Are there any documents that are
7 being withheld under privilege?
8 MR. WILLIAMSON: Yes. I believe the only
9 document that was withheld was the memo that she and
10 Ms. Dunford wrote to me --
11 MR. PERETZ: Okay. No problem.
12 MR. WILLIAMSON: -- about a year ago.
13 BY MR. PERETZ:
14 Q. And when you were going through the process of
15 identifying documents responsive to the document
16 request, where did you actually look?
17 A. I logged into several different email accounts
18 that I have either managed or owned over the course of
19 my time at Evans and searched either the name Rimma, the
20 name Rimma Breeze, the name admin@theevansschool, and
21 tried to find and print every document that made any
22 mention of those.
23 Q. And what email accounts did you look into?
24 A. There is one that's called evanswasc@email.com.
25 Q. Okay.

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1 A. There is one that's called


2 development@theevansschool.com. There is one that's
3 called sarahharrison@theevansschool.com. There is one
4 that's saraharrison@e.com, and there is one
5 s.harrison.2@gmail.com.
6 And I also had a problem where I had an update
7 to my computer and lost some, so I had to recover them
8 all from the Time Machine backup and the messy email
9 situation, so I did my honest due diligence of searching
10 everything.
11 Q. Okay. And any other email accounts or these
12 are the ones?
13 A. I haven't changed my name yet. I don't think
14 there are any of those, so I believe that's it.
15 Q. Other than those email accounts, did you look
16 in any other folders, whether physical folders or
17 computer folders?
18 A. Yes. You requested everything to do with the
19 Western Association of Schools and Colleges, so I have a
20 folder on my desktop that I just copied and produced the
21 whole entire folder.
22 Q. Okay. Those were emails.
23 A. I produced hard copies of the actual report of
24 the visiting committee's follow-up. I have a
25 development folder/binder that had sign-in sheets from

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1 every staff meeting that had a log of back


2 qualifications, and I produced folders that have each
3 chapter of our accreditation report with a signature
4 page at the front that every staff member was asked to
5 read each chapter and sign to prove that they had
6 reviewed it.
7 Q. And that's part of the WASC folder?
8 A. Yes. There's separate folders, but it's part
9 of the WASC information that they handed over.
10 Q. Okay. When did you start working for The Evans
11 School?
12 A. In August of 2011.
13 Q. Okay. Did you ever give your deposition
14 before?
15 A. I have not.
16 Q. Did you ever testify at trial?
17 A. No.
18 Q. Were you ever involved in a lawsuit?
19 A. I had a lemon-law case one time.
20 Q. Okay. Was it Small Claims or --
21 A. I have no idea.
22 Q. Okay. Any -- anything other than that?
23 A. No, sir.
24 Q. Okay. So let me go through some of the rules
25 on how we are going to conduct this deposition.

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1 Everything is taken down by the court reporter.


2 And you are giving your testimony under penalty of
3 perjury. You understand that; correct?
4 A. Yes.
5 Q. Okay. Because it's being taken down, I would
6 like to adhere to some rules.
7 First of all, try not to speak over me. If you
8 speak over me, it's going to be very challenging for the
9 court reporter to take it down because she has to take
10 down everything in the same order that it's being said.
11 Fair enough?
12 A. Yes.
13 Q. It's okay to nod your head, but follow that
14 with a verbal response when you answer a question,
15 because that -- the court reporter cannot take down
16 nonverbal responses. Fair enough?
17 A. Yes.
18 Q. Try to avoid uh-huh or huh-uh as a form of
19 response, because we won't be able to know after the
20 fact if that uh-huh or huh-uh meant yes or no or
21 something else. Okay?
22 A. Yes.
23 Q. It's very important that you give me your full
24 and complete testimony today, because -- Although you
25 will have the opportunity to change your testimony after

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1 the fact, after a transcript of the deposition has been


2 generated, if you make any of those changes, we may
3 comment on the fact that you made a change. Do you
4 understand that?
5 A. I do.
6 Q. Okay. I will try to make my questions as
7 clearly as possible. Sometimes I won't be able to do
8 that or I may use a term, a phrase, a word that you
9 don't understand, or you are not -- or you don't fully
10 understand, or I may use a term that may be interpreted
11 in different ways. By all means, if you think that my
12 question is not clear enough, or you are confused by it,
13 or it doesn't make sense to you, verbalize that to me.
14 Is that okay?
15 A. Yes.
16 Q. If you won't do that, though, I will assume
17 that you understood my question and my -- your answer
18 was responsive to my question. Okay?
19 A. All right.
20 Q. Ms. William's -- or Mr. Williamson may make
21 some objections for the record. If he makes objections,
22 for the most time you will still be required to answer
23 the question. It's going to be a little confusing
24 because I am going to say something, and he may say
25 "Objection," and you would think that then you don't

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1 have to answer the question --


2 A. Um-hum.
3 Q. -- but you still have to answer the question
4 unless he instructs you not to answer. Fair enough?
5 A. Yes.
6 Q. Okay. And you need to give us the full and
7 truthful answers, which I am sure you're going to give.
8 But on occasion, you know, we don't remember exactly
9 what happened in the past, for example.
10 And for example, I may ask you, you know, "What
11 was your first day at The Evans School?" And you may
12 not remember the exact day that you started at The Evans
13 School. On those occasions, I am still entitled to your
14 best recollection of the events. And if I'm taking the
15 example of your first day in The Evans School, a good
16 answer could be, you know, "I don't remember the exact
17 date, but I am sure or fairly positive that it was in
18 August of 2011" or "it was in summer 2011." Again,
19 anything that's best -- indicates your best recollection
20 of what I ask. Okay?
21 A. All right.
22 Q. The same thing; I may ask you to measure
23 things, measure the number of people, measure dates,
24 times, lengths of meetings and so forth and so on. You
25 may not remember exactly what I am asking you to measure

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1 on those instances, and that's the time to give me an


2 approximation of what I am asking. Fair enough?
3 A. Yes.
4 Q. Okay. I actually went ahead and printed out a
5 LinkedIn account or LinkedIn profile that I believe is
6 yours.
7 MR. PERETZ: And let's mark that as Exhibit 41.
8 (Plaintiff Exhibit 41 was marked.)
9 BY MR. PERETZ:
10 Q. When you are done reviewing it, let me know.
11 A. I am done.
12 Q. So is Exhibit 41 your LinkedIn account or your
13 LinkedIn profile?
14 A. Yes.
15 Q. Did you create this LinkedIn profile?
16 A. Yes.
17 Q. Okay. Is everything in your profile -- Ignore
18 the ads or the stuff on the right side there. Is
19 everything in your profile true and accurate?
20 A. To the best of my knowledge?
21 Q. Yes.
22 A. Yes.
23 Q. Okay. And all your work experience is exactly
24 correct?
25 A. Correct. I have not updated it in quite some

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1 time, but, yes, I -- yes, this is me.


2 Q. Okay. No problem.
3 And my understanding is that you are currently
4 a teacher at The Evans School. Correct?
5 A. Correct.
6 Q. And what class or subjects do you teach?
7 A. I teach first grade.
8 Q. And have you been teaching first grade ever
9 since you started at Evans?
10 A. Yes.
11 Q. Okay. Did you ever teach any of Rimma Breeze's
12 kids?
13 A. No.
14 Q. How did you first met Rimma (sic)?
15 A. I don't recall exactly. She was a parent at
16 the school. And it's a very small community, so you see
17 people about.
18 Q. And that's how you came to know who she is?
19 A. I don't recall a formal meeting ever, or
20 introduction.
21 Q. Okay. When did you first have your more
22 substantive discussion/talk/meeting with Rimma?
23 A. Probably April or so of 2012 when Rimma was
24 creating email addresses for the staff.
25 Q. And she created an email address for you?

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1 A. Correct. She asked my input and Sarah


2 Dunford's input on the format of emails, as I recall.
3 Q. Okay.
4 A. And prior to that I'm not -- I'm sure we had
5 spoken, but I don't -- It's hard to remember.
6 Q. Okay. And -- And did you think it was a good
7 idea to create those email addresses?
8 A. Absolutely.
9 Q. And what about using Google Apps for Education?
10 Rimma introduced that to the school; correct?
11 A. Right. And I believe I had told her that we
12 had used that at Columbia and I was very fond of the
13 program. I thought the file-sharing was a big plus and
14 that it would look professional for the school for us to
15 all have uniform email addresses.
16 Q. Okay. And because you were somewhat familiar
17 with that, you thought it was a good idea to use Google
18 Apps for Education for the school; correct?
19 A. I mean, I was never formally asked my opinion
20 on it, but, yes, I believe I said, "Oh, exciting."
21 Q. Okay. Now, you expressed your approval and
22 excitement to Rimma about, you know, getting school
23 email addresses and using Google Apps for Education;
24 correct?
25 A. Yes.

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1 Q. Was that a genuine response? Meaning, you did


2 feel excited, or was it something that you felt you had
3 to express some excitement just so that she didn't feel
4 bad?
5 A. No. It was a genuine response.
6 Q. Was there any time -- Strike that.
7 It appears to be that throughout the time that
8 Rimma worked at the school you had a positive working
9 relationship; correct?
10 A. Absolutely.
11 Q. And did you find her to be unprofessional at
12 any point?
13 A. No.
14 Q. Did you find her to be professional?
15 A. Yes.
16 Q. Was she responsive to issues in questions?
17 A. Yes.
18 Q. Okay. You had a positive working relationship
19 with her?
20 A. Yes.
21 Q. Okay. And on it it indicates occasions --
22 you did express the fact that you know you approved --
23 or you were happy about things that she did for you or
24 for the school; correct?
25 A. Yes.

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1 Q. Those were genuine responses, meaning you


2 didn't tell her, hey, that's a great idea or that's good
3 but you didn't mean that; correct?
4 A. No. I mean what I say.
5 Q. I am not trying to be disrespectful. I am just
6 trying to get your testimony.
7 A. Yes. They were genuine.
8 Q. You understand that sometimes we say
9 something -- If I feel bad and somebody asks me, you
10 know, "How are you feeling," I am not going to say,
11 "Oh, my God, I feel awful." I am going to say, "Well, I
12 am okay." Now we are in a deposition, and this is a
13 different story.
14 Your responses to Rimma were genuine; correct?
15 A. Yes.
16 Q. Okay. Did you ever get the impression that
17 Rimma was brought into the technology or IT systems
18 position at the school because someone was trying to do
19 her a favor?
20 A. I was not privy to anything of that nature.
21 Q. Okay. Did you ever hear any opinion of someone
22 that Rimma was brought on to do technology work at the
23 school because she was jealous of Alex Rome or because
24 she was jealous that other parents participated in the
25 school activities and she wasn't?

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1 A. No. My understanding was that a notice had


2 gone home, as in every previous year, asking parents how
3 they would like to get involved, or volunteer, and that
4 there was this parent who had these resources that we
5 weren't aware of and offered to help us with our
6 website, and I thought that sounded great.
7 Q. Okay. Well, did someone else tell you
8 differently; that, in fact, the reason was different?
9 A. No.
10 Q. Okay. Now, you were tasked at some point to
11 change the WASC committee.
12 A. Yes.
13 Q. And that was fall of 2011?
14 A. Yes.
15 Q. Around that time?
16 A. Correct.
17 Q. Do you know why you were tasked with that task?
18 A. No.
19 Q. Okay. Just --
20 A. I believe I went to the first training because
21 there were two full-time teachers in first grade. And
22 the first training was off campus on a day that was open
23 house, so Sarah Dunford was needed to stay in the
24 first-grade classroom. And I don't know Gale's
25 reasoning behind asking me to go. Maybe she knew I was

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1 fresh out of graduate school and would be able to write


2 an academic paper. I would like to think there was some
3 merit-based selection, but it could have just been I was
4 extra and so she sent me.
5 So I went to the first training with another
6 person at Evans; Howard Young. And when I returned I
7 went upstairs to call and said, "Who would you like me
8 to hand all this information over to?"
9 Q. And she directed you and Sarah Dunford to do
10 the project?
11 A. Yes.
12 Q. I see.
13 A. So I was never formally appointed. You are the
14 chair. We don't ever function with titles like that.
15 Q. Okay. And -- but you were tasked with handling
16 that?
17 A. Yes.
18 Q. Whether formally or not formally, it's
19 irrelevant.
20 A. Yes.
21 Q. Okay. Now, you -- it seems like you embraced
22 the fact that Rimma was brought aboard and improved the
23 technology platform at the school; correct?
24 A. Yes. I was excited for it.
25 Q. And when Rimma joined -- When did Rimma join in

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1 a more official -- more official role?


2 A. Since I was new, I didn't really know what the
3 norm was. But as I recall, it was toward the end of the
4 2012 or -- 2011/2012 school year; so meaning late spring
5 of 2012 is when Rimma would give a little presentation
6 to the teachers on how to check your email, what this
7 means, and asking us to sort of be involved.
8 Q. And you went to that presentation; correct?
9 A. Yes.
10 Q. And you thought she did a good job at the
11 presentation; correct?
12 A. Correct.
13 Q. And you commended her on that; correct?
14 A. Yes.
15 Q. And that commendation was genuine; correct?
16 A. Yes.
17 Q. And Rimma became more and more involved in the
18 technology aspect of the school from that point on;
19 correct? I -- Again, your experience.
20 A. Yes.
21 Q. And at that time you were in the midst of
22 preparing for the WASC application; correct?
23 A. Correct.
24 Q. And did you find it helpful in that regard, for
25 the WASC application, to have someone on board that

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1 improved the technology platform at the school?


2 MR. WILLIAMSON: Vague and ambiguous.
3 THE WITNESS: That's hard to answer yes or no
4 exactly. I think that people like communication. So to
5 some it was a benefit; to others it was a downfall that
6 they had to learn something new. We have teachers who
7 have been there 30 years and have never had to do things
8 like that and didn't want to do things like that.
9 Our school has been accredited by WASC for
10 many, many years and never had the communication. So I
11 have served on the committees and I know that the
12 technology is not a necessity for accreditation. So I
13 do not think it was necessary for it, and it could have
14 been viewed was a pro or a con.
15 MR. PERETZ: I see.
16 BY MR. PERETZ:
17 Q. From your perspective, was it a pro or a con?
18 A. From my perspective a pro, because I come from
19 a younger generation and was fresh out of graduate
20 school.
21 Q. Okay. And would you agree with me that the
22 trend in education, based on, you know, coming out of
23 school and engaging in those different kinds of
24 economies, is that the trend is to use more and more
25 technology in the classroom and in school?

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1 A. In some schools, yes, and in other schools they


2 have seen the decline since using the technology and
3 have withdrawn major technology rollouts and have gone
4 back to traditional learning environments.
5 Q. I see. After Rimma left, did you -- did -- did
6 you -- did The Evans School experience the same type of
7 going back to traditional school methods?
8 A. Can you elaborate, please.
9 Q. Yes. Rimma introduced several technology
10 platforms; correct?
11 A. Such as --
12 Q. Such as usage of Google Apps for Education;
13 correct?
14 A. Yes.
15 Q. And email addresses that were assigned through
16 a URL or website of the school; correct? That's
17 another --
18 A. Yes.
19 Q. Okay. And also the use of iPads at the school
20 by classes and teachers; correct?
21 MR. WILLIAMSON: Vague and ambiguous.
22 THE WITNESS: I don't think Rimma introduced
23 that. I think the school was doing it and Rimma offered
24 to help.
25 MR. PERETZ: Um-hum.

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1 THE WITNESS: Gay Dixon has pioneered a lot of


2 that leadership. The sixth-grade teacher Seeley and the
3 second-grade teacher Hannah are all involved in the
4 iPads. I mean, Rimma was in a position where she
5 offered to help and therefore facilitated a lot of it.
6 BY MR. PERETZ:
7 Q. I'd like you to speak to your previous
8 statement about Google Apps for Education.
9 A. And the email addresses with our school's URL,
10 I created all of that again from a separate Google Apps
11 for Education account.
12 And I have no technical training of any sort,
13 so, yes, it was wonderful that Rimma got that started
14 and initiated it. And we were all very appreciative;
15 however, when we stopped using the @theevansschool.com
16 email addresses, I was able to set up everything that we
17 had previously by myself with @evansschool.org. So now
18 we have email addresses and the whole Google Apps for
19 Education platform, which I was able to administer.
20 Q. Okay.
21 A. So I do not think it was pivotal.
22 Q. I understand. But by the time that you set it
23 up, you had already been working with it for over a
24 year; correct?
25 A. I have worked with it for my whole life. I

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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 not going to be functioning in that role anymore, was


2 not going to be involved, and we did not have access
3 currently to any of the accounts which Rimma had
4 previously done for us and that she was not turning the
5 passwords over, or something along those lines, because
6 I recall that throughout my time Rimma would share the
7 password with me for the admin account and would sort of
8 say "Go in. Explore. I'm not going to be here forever.
9 See what you can learn to do."
10 She was very encouraging in a mentorship type
11 of role. "Great job creating that site. You are
12 learning it." She'd be supportive. She'd change the
13 passwords from time to time, which she said she was
14 going to do. I would email her. Sometimes she would
15 email back with the new passwords, other times she'd not
16 give them or would say she had to change them later or
17 couldn't remember them or something of that nature.
18 So I looked into my email at -- I think the
19 last email password she had shared with me. And I
20 showed it to Gay, and Gay hit "Forward" from my phone
21 and typed in her email address and sent it to herself.
22 And I think that's what kicked off some of the
23 back-and-forth of trying to log in and trying to know
24 what was happening, because, as I found out later, Rimma
25 had been forwarding the emails on. So I think she saw

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1 that forward of the password is my understanding, but I


2 have bits and pieces.
3 Q. Okay. And that was probably what? The
4 beginning of August?
5 A. To mid. Maybe, you know, the 9th, 10th,
6 something like that.
7 Q. Okay. Let me --
8 MR. PERETZ: Just to help you with the
9 timeline, let's mark this as Exhibit 20 -- 42.
10 (Plaintiff Exhibit 42 was marked.)
11 BY MR. PERETZ:
12 Q. Please review Exhibit 42.
13 A. (The witness complied.)
14 Q. And when you are done, let me know.
15 A. Okay.
16 Q. It's a Google thread, so the earlier email is
17 the top email.
18 A. I recall.
19 Q. You did have this exchange with Rimma; correct?
20 A. Correct.
21 Q. That's the email thread from July 2013;
22 correct?
23 A. Correct.
24 Q. Just again, I want to establish the timeline.
25 You emailed Rimma on July 22nd and asked her

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1 for some assistance with the Evans email; correct?


2 A. Correct.
3 Q. Okay. And at that time when you made that
4 request, July 22nd, did anyone mention to you that Rimma
5 will not be working with the school, or she gave up her
6 position, or she doesn't have access or anything of that
7 nature?
8 A. No, or else I would not have sent it.
9 Q. Okay. Prior to that email, meaning prior to
10 July 22nd, did Ms. Gale ever tell you that there is an
11 intention or thought to remove Rimma from her position?
12 A. No.
13 Q. Did anyone else other than Ms. Gale, before
14 July 22nd, informed you or advised you that there is an
15 intention to remove Rimma from her position (sic)?
16 A. No.
17 Q. And then Rimma responded to you that day and
18 provided you with the information that you wanted;
19 correct?
20 A. Correct.
21 Q. Okay. And that was the end of it; correct?
22 A. Correct.
23 Q. Okay. And now, you talked about some email
24 that was forwarded from your phone or sent from your
25 phone to Gay Dixon. Do you remember that?

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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 you perform and, you know, all that.


2 A. Um-hum.
3 Q. Just as a general background. Off the record.
4 (Off the record.)
5 MR. PERETZ: Okay. Great. Let's go back on.
6 And Madam Reporter, why don't you read the
7 question that's pending.
8 (The record was read.)
9 THE WITNESS: I believe I was forwarded a few
10 of them from either Gay Dixon or Dan -- Swanson, I
11 believe is his last name -- when they discovered that
12 the emails had been forwarded, because they asked me,
13 "Is this one that you sent," or something along those
14 lines. So I believe I reviewed -- I opened them in an
15 email and read them in the text version --
16 MR. PERETZ: Okay.
17 THE WITNESS: -- but not thoroughly. I have
18 access to the admin account where they were all logged,
19 but quite honestly, I am focused on being a homeroom
20 teacher and have not spent a lot of time reviewing
21 this --
22 MR. PERETZ: Email.
23 THE WITNESS: -- each email --
24 MR. PERETZ: Okay.
25 THE WITNESS: -- yeah.

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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 the email forwarding, and he discovered that there had


2 been a third-party something installed that was, I
3 think, controlling the forwarding. So he struggled with
4 that for a few days to try and make the email stop
5 forwarding.
6 Q. But you weren't involved. He just informed you
7 of that?
8 A. Yeah. It would be, "Send me one" just to see
9 if it showed up in the other one, or, "Sarah, respond,
10 please, to let me know if this comes through," that sort
11 of thing, where we were just testing the system.
12 Q. Okay. You understand that there is a lawsuit
13 pending about this whole situation; correct?
14 A. That's why we're here; correct?
15 Q. Well, yeah, but --
16 A. I do, yes.
17 Q. Okay. When was the first time that you learned
18 of that lawsuit?
19 A. I don't recall. It would be in the fall of
20 2013, but I got married in the fall of 2013, and I
21 started the school year, and it's a little bit fuzzy.
22 Q. Okay. I see.
23 So you weren't --
24 A. My mind was elsewhere.
25 Q. You weren't focused on that?

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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 Q. Okay. But nobody told you that?


2 A. I don't recall.
3 Q. Okay. Did you have any experience with Rimma
4 that you found her to be threatening?
5 A. No.
6 Q. Did you have any experience with Rimma that you
7 felt that she was a threat to you, to your safety or
8 your life?
9 A. Personally my safety? No. I had concerns that
10 there was one person who had the sole access to our
11 administrative accounts. I did not voice those
12 concerns. Gale is extremely trusting and open and only
13 sees the good in people, so I knew that a voiced concern
14 would not likely come to any change. But I think just
15 from a professional standpoint, no one person,
16 especially that's a parent and not an employee or not,
17 you know, an administrator of the school should have
18 access. So my concerns only were that.
19 Q. But you understand also that there's some
20 security issues, and if too many people share passwords,
21 that may cause another type of --
22 A. I do understand that, but I thought that Gale
23 and maybe one other person with some technical savvy
24 should have been granted Super Admin access, which would
25 have allowed them to also go in and change passwords and

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1 create things and administer the Google Apps for


2 Education.
3 Q. Okay. Do you know if -- Did you get the
4 impression when you were working with Rimma that she
5 doesn't want to share passwords?
6 A. No. There were several instances where she did
7 share the passwords with me. So I think my concern came
8 when I would try and use the password she had shared and
9 it would be changed, or I would request it again and she
10 would say "I'll just handle it" or -- or not know the
11 password right off and kind of scoot around giving it to
12 me. That would be it, but I don't recall specific
13 instances.
14 Q. That that happened?
15 A. Correct. But as I stated earlier, there were
16 many times where she'd send me the password and say,
17 "Here. Log in. Explore. Check it out. Great job" and
18 was very supportive and encouraging of me learning it
19 and even stated "I won't be here forever, so it's great
20 that you are learning this," you know, in a mentorship
21 type of way. I thought we had a nice relationship.
22 Q. And your concern with one person has to do more
23 with good practices, what if that person is not
24 available, rather than concern that that person will
25 turn malicious and cause some damage. Is that a fair

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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 Q. How did you learn of that?


2 MR. WILLIAMSON: She just said she doesn't
3 recall.
4 THE WITNESS: I just said that I do not recall.
5 BY MR. PERETZ:
6 Q. Did you learn that from one of them or did you
7 learn that from rumors coming around at the school?
8 A. I don't recall.
9 Q. Okay. Can you better ascertain when you
10 learned that? Was it the beginning of 2013, the
11 beginning of -- or the mid 2013?
12 A. I'm sorry. I don't recall.
13 Q. Okay. And what did you learn about the tension
14 between the two of them?
15 A. Just that the families didn't get along, and
16 that is the extent of what I knew.
17 Q. Okay.
18 A. I did not know why. I did not teach their
19 children. To my understanding, the boys were hardly in
20 a class together, because Rimma's son was always working
21 with the grade above or one-on-one instruction with
22 teachers.
23 They received a lot of accommodations for how
24 advanced Augie was in certain classes, and I always
25 thought that it was very nice of Gale and the school to

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1 have a class for one or two children.


2 Q. Okay. Good. And at some point did you --
3 after Rimma left did you start any dialogue with Alex
4 Rome about Rimma?
5 A. There might have been -- There was a -- I don't
6 recall exactly. I believe she would say things here or
7 there, or Alex was concerned about what was happening or
8 going on. And she had a history that went far beyond
9 what I knew of their relationship.
10 Q. But she approached you and told you some of the
11 history; correct?
12 A. She did not tell me the history, but she
13 knew -- I guess expressed in some way that she did not
14 get along with her, did not like her, and that she
15 should not be in positions of power, I guess, at school.
16 Q. Okay.
17 A. But I don't -- I don't -- not in that sort of
18 way. I don't know. She just did not like the family, I
19 guess is what it boils down to. And Alex is a rational
20 person, and so I just assumed that she had substance
21 behind that, but I did not get into it.
22 Q. So she was sharing that with you, but you
23 didn't respond in saying yes, I see where you are coming
24 from and things like that?
25 A. Not that I recall.

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1 Q. Okay. What do you mean by Alex is a rational


2 person?
3 A. Is a rational --
4 Q. Yes.
5 A. I mean that if she felt strongly that she did
6 not get along with someone, that something had probably
7 happened in the past to make her feel that way and
8 warrant it or justify it in her perspective.
9 Q. Okay. And how about -- Did you have any
10 discussions with her about the lawsuit?
11 A. Not that I recall.
12 Q. Okay. Did she tell you her opinions about the
13 lawsuit, like who is right or who is wrong?
14 A. I did not need to ask. I knew what her
15 opinions were.
16 Q. She was vocal about it?
17 A. Well, I knew how she felt about Rimma, so --
18 And she loves and supports the school.
19 Q. What did she tell you about that?
20 A. She did not tell me anything. That was just my
21 assumption.
22 Q. Okay. And did you try to contact Rimma after
23 she left the school?
24 A. Not that I recall.
25 Q. Okay. And did you try to find out where her

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1 kids are going after she left the school?


2 A. I think there was a general "I wonder," but I
3 did not proactively do anything to search it out. I saw
4 her crossing -- I drive up Mt. Soledad, and I saw her
5 crossing with her children to All Hallows. So it took a
6 couple weeks, and I knew where she was attending.
7 Q. Okay. So you saw her take her kids over there?
8 A. Yes. The schools are right across the street
9 from there.
10 Q. And that's how you found out?
11 A. I believe so.
12 Q. Did you share that information with Alex Rome?
13 A. No.
14 Q. Did you tell Alex Rome at some point that you
15 know where Rimma is sending her kids?
16 A. Possibly, but I don't recall.
17 Q. Okay. So you may have done it, but you don't
18 remember doing that?
19 A. Did I share it with her?
20 Q. Yes.
21 A. I don't think so.
22 Q. Okay. Why wouldn't you do that?
23 A. Why wouldn't I?
24 Q. Yes.
25 A. Because I'm trying to stay out of it so I -- to

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1 a reasonable degree of not -- I also thought Alex


2 probably knew. Alex has friends at All Hallows.
3 Q. How do you know that she has friends at that
4 school?
5 A. Because she has friends all over the community,
6 and she is -- she has said that she has friends at
7 All Hallows in other instances.
8 Q. Okay. Did you ever had a discussion with Alex
9 about how Rimma was able to get her kids at All Hallows
10 (sic)?
11 A. Somehow she was able to get them there?
12 Q. Yes.
13 A. I believe Alex told me in an email that -- that
14 families had recommended them.
15 Q. Families had recommended them?
16 A. I assume you are referring to an email.
17 Q. I am asking you either email or discussion. I
18 don't know what the extent of your discussions on the
19 subject was.
20 A. Not any in person, so I don't recall.
21 Q. So she just informed you that -- at some point
22 that some families recommended Rimma to -- Rimma to the
23 school or something like that.
24 A. I recall hearing that, but I can't say
25 precisely when or where or what context.

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1 Q. Did she say which family or --


2 A. No.
3 Q. Okay. Did you have a discussion over that?
4 A. No.
5 Q. Okay. Why would she tell you that? I mean,
6 why was it a topic of an interest between the two of
7 you?
8 MR. WILLIAMSON: Calls for speculation as to
9 the mental state of another person.
10 You can answer if you know.
11 THE WITNESS: I don't know. It was over a year
12 ago.
13 BY MR. PERETZ:
14 Q. Well, that doesn't mean anything. It was over
15 a year ago, I understand, but were you -- but was
16 that -- but was, you know, Rimma's faith after the
17 school -- you know, after they left the school -- after
18 they left the school, was it an issue that was discussed
19 between you and Alex?
20 A. Rimma's faith?
21 Q. What schools her kids are attending, where she
22 did go, or --
23 MR. WILLIAMSON: I'm sorry, Counsel. I want to
24 make sure we've got the right word. It sounds like
25 maybe you meant fate. I heard "faith," but --

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1 MR. PERETZ: Let me rephrase the question.


2 THE WITNESS: Sorry.
3 BY MR. PERETZ:
4 Q. After Rimma and her family was no longer at
5 The Evans School, did you have any discussion with Alex
6 about, hum, I wonder where they are going; I wonder what
7 school they are attending; I wonder what you are doing
8 or thinking or anything of that nature?
9 A. I believe I already answered this to the best
10 of my knowledge. I don't recall specifically, but I do
11 recall hearing that there had been a couple of families
12 that had recommended the Breezes to All Hallows. So in
13 what context or what surrounded that, I don't recall.
14 Q. Okay. And you said that you were trying to
15 stay out of it, correct, from the tension between Rimma
16 and Alex; correct?
17 A. I think very few people will enjoy being
18 wrapped up in this sort of thing, so yes.
19 Q. And I would agree with you, but how come you
20 were informed about that the families recommended Rimma?
21 And it seems like more involvement than just, hey, she
22 is not here anymore. I would rather not talk to her
23 about it.
24 A. Well --
25 MR. WILLIAMSON: Calls for speculation as to

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1 the intent of third parties. You can answer the


2 question if you can.
3 THE WITNESS: Like it or not, I am involved.
4 And as to why other people spoke to me about it, I
5 cannot speculate.
6 MR. PERETZ: That's fair enough.
7 BY MR. PERETZ:
8 Q. Is it fair to say that the person that got you
9 involved was Alex Rome?
10 A. No.
11 Q. So who got you involved in this lawsuit?
12 A. In this lawsuit? Rimma.
13 Q. How did Rimma get you involved in this lawsuit?
14 A. I wouldn't be here if it weren't for Rimma.
15 Q. Well, but we didn't identify you as a witness.
16 A. Okay. So Gale.
17 Q. Okay.
18 A. I am just saying "the situation."
19 Q. Okay. I see.
20 Did Rimma ever talk to you about her tension
21 with Alex Rome?
22 A. Oh, that's tough for me to comment on. As I
23 stated earlier, I believe there was a general
24 understanding that they did not like one another. I
25 believe I heard it from both sides, because I remember

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1 thinking I like both ladies and finding it interesting


2 that they didn't get along, because I thought they were
3 both nice and got along with both of them just fine.
4 Q. Okay. Did Rimma ever share with you what were
5 her issues with Alex Rome, if any?
6 A. I can't recall exactly. I mean, I think maybe
7 Rimma at one point said that she knew Chip Rome before
8 Alex knew him or -- I don't know. There is fuzzy -- We
9 were colloquial. We were casual. We were in the
10 kitchen and the copy room together. So stuff was said
11 in passing, and I don't want to speak to the validity of
12 it because I am not sure.
13 Q. Okay. Did Alex Rome ever commented to you that
14 she is concerned to Rimma's well-being (sic)?
15 A. Not that I recall.
16 Q. Did she express to you any concern -- Did Alex
17 Rome ever express to you any concern about Rimma's
18 health or mental being after Rimma was no longer at the
19 school?
20 A. Not that I recall.
21 Q. Did -- During the month of February, March,
22 April, May of 2013, so the winter or spring of last
23 year --
24 A. Um-hum.
25 Q. -- did you see -- did you happen to notice if

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1 Rimma was at the school doing her work?


2 A. No, she was not. She had been there very
3 routinely and I believe in February was no longer on
4 campus.
5 Q. At all?
6 A. Here and there, but not to the extent which she
7 had been.
8 Q. Um-hum.
9 A. And I recall hearing she had broken her foot or
10 that she had been ill before that. I remember some
11 instance -- and I don't recall if it was a Christmas
12 party, end-of-the-year party, or what; so again, my
13 timeline is not precise here -- overhearing Colin Breeze
14 and Gay Dixon just talking about Rimma. And Gay was
15 saying, "I hope she is feeling better" or something.
16 And I was a little bit nosy and said, "Oh, is
17 she ill?" And then realized it was none of my business
18 and an inappropriate question, and they both clearly did
19 not want to comment on it, so I did not know any of the
20 extent.
21 Q. And that was -- you think it was over the
22 end -- the Christmas of 2012 or around that time?
23 A. All the way up to the end of the year --
24 Q. Okay.
25 A. -- of, you know, June 2013, because it was a

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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 A. Yes. She was still responding to emails and


2 helpful on tasks. I think she probably even provided me
3 the admin password from time to time in that period.
4 Q. I see. I see.
5 And you never asked her if she was sick or ill
6 or something like that?
7 A. I think we might have spoken about her foot,
8 because I remember her saying "Oh, I'm stuck up here" or
9 that kind of thing, so I think -- in my view she had
10 broken her foot --
11 Q. Well, she did break her foot.
12 A. -- and was out of commission for a while.
13 Q. Rimma had broken her foot May 13 of 2013.
14 A. May 13?
15 Q. Yes, May 13.
16 A. Okay.
17 Q. Prior to May 13 of 2013 do you recall any
18 discussion that Rimma told you "I'm sick," or "ill," or
19 something to that effect?
20 A. I don't recall.
21 Q. Okay. And I would like you to --
22 MR. PERETZ: Where are the exhibits, the prior
23 exhibits, Madam Reporter?
24 THE REPORTER: Right here.
25 MR. PERETZ: Okay.

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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 and providing to explain and to show that -- we are


2 showing a diverse group of the school's stakeholders.
3 Q. And I understand that. I mean, I think because
4 it's a small school, you -- the attempt was to formalize
5 what has been somewhat informal up until that point.
6 Correct?
7 A. And in hindsight, this was probably taken --
8 taking too much liberty on the parts of Sarah Dunford
9 and myself. Gale reviewed this, obviously, but Gale
10 would never have assigned these titles.
11 Q. How do you know that?
12 A. I assume it because nobody has formal titles.
13 I think that Gale likes to function in an environment
14 that's not so much --
15 Q. Well, do you think that any of the titles that
16 you provided was inaccurate or deceptive?
17 A. I think that that all accurately describes the
18 roles in which these people -- and the realms in which
19 these people function. The term -- now, in hindsight --
20 "Director" seems, I guess, to imply a paid position. I
21 don't know. Maybe it seems more corporate than a school
22 typically is, but we were showing that a leadership --
23 if a visiting committee comes and wants to sit down with
24 people, that they know what types of -- or what area of
25 the school each person can speak to.

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1 Q. Okay. And I want to show you another email.


2 A. If I may make one more statement on this
3 regarding the titles.
4 Q. Please.
5 A. Just to say that this was never published
6 anywhere. This is not part of our school website. No
7 parents saw this unless they are also on staff and read
8 our WASC report. This was internal use solely for the
9 purpose of the WASC visiting committee.
10 Q. Okay. I get that, because the school is
11 somewhat informal because it's a small school.
12 A. Uh-huh.
13 Q. But you agree with me that, you know, filing
14 and -- or making a submission to WASC is serious. It's
15 not something that should be taken lightly; correct?
16 A. But nobody on the visiting committee would
17 contest or think that this was done falsely.
18 Q. And that's what I am getting to in my next
19 question.
20 At least from your part -- I am not -- I don't
21 speak for someone else -- there wasn't an attempt made
22 to deceive the visiting committee; correct?
23 A. Absolutely not.
24 Q. And there wasn't an attempt made to present the
25 school in a way that it's not; correct?

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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 (Plaintiff Exhibit 43 was marked.)


2 BY MR. PERETZ:
3 Q. Do you recognize Exhibit 43?
4 A. I do now in reviewing it, but I had not
5 reviewed it before.
6 Q. Okay. No problem. Take your time and review
7 it.
8 A. (The witness complied.)
9 Q. And before today, when was the last you
10 reviewed this email, if ever?
11 A. I don't recall. I believe this was in a folder
12 on my Mac, which as I stated earlier I had a massive
13 loss of emails and have been retrieving them from a
14 storage device. And so I believe this was archived in
15 that, which I turned over to the lawyers.
16 Q. Okay. And when was that? When did you
17 retrieve this document? When was that?
18 A. Maybe two weeks ago. Whenever I gave it to
19 them. I don't recall exactly, but I had not read
20 through everything that I turned over.
21 Q. Okay. Do you recall focusing on this email
22 when you retrieved the documents or you just handed it
23 over?
24 A. I just handed it over.
25 Q. And that's an email exchange you had with Alex

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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 looked for (sic) -- you looked at the website and


2 realized that it was down?
3 A. Or that -- It must have said something like
4 we are undergoing some kind of rebuild or revamp of our
5 website --
6 Q. And was there --
7 A. -- and that they -- And I must be saying that
8 Rimma was working on their website.
9 Q. Okay.
10 MR. WILLIAMSON: Are you sure that what you say
11 is what you actually know and recall? Don't speculate.
12 If you don't remember, you don't remember.
13 THE WITNESS: Then, no, I don't recall.
14 MR. WILLIAMSON: If you remember you can tell
15 him, but don't speculate.
16 THE WITNESS: I don't remember the details of
17 if it was told that she was working on their website or
18 had been given access to their website.
19 BY MR. PERETZ:
20 Q. And then the website was down?
21 A. The All Hallows?
22 Q. Yes.
23 A. I can't tell based on this email, and I don't
24 recall.
25 Q. Now, you make a comment under that, "Guess no

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1 one passed along your warning," two exclamation marks.


2 Do you see that?
3 A. I do.
4 Q. What is the reference that you are making here?
5 A. I don't recall.
6 Q. You don't recall? That's a reference about the
7 Breezes; correct?
8 A. I assume, based on what follows, but in terms
9 of what warning or if the website was down or if the
10 website just said we are being rebuilt, I -- It was a
11 year ago.
12 Q. Okay. I understand. Actually, a year ago
13 almost to the day, so indeed it is a year ago.
14 Did you look at All Hallows Academy's website
15 to see if the kids of the Breezes were registered at
16 that school?
17 A. I would have no way to know if they were
18 registered there. So I doubt that was what I was doing,
19 but -- It looks like I visited their website, but as for
20 what, I can't say.
21 Q. Okay. And then the comment "Guess no one
22 passed along your warning" is meaning nobody passed Alex
23 Rome's warning about the Breezes; correct?
24 MR. WILLIAMSON: She said she doesn't recall.
25 THE WITNESS: I'm not sure.

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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 Q. Sure. Again, I mean, it seems like, you know,


2 we have your statement without context because we
3 weren't privy to your discussions previous to that. The
4 statement that you make is "Guess no one passed along
5 your warning." Do you see that?
6 A. I do.
7 Q. First of all, "your warning" -- As you sit here
8 today, your recollection is that that was a warning that
9 Alex Rome had about the Breeze family; correct?
10 A. To the best of my gathering of this email, yes.
11 Q. Okay. And do you have more specifics on that
12 warning? Was it "Watch out for this family," or was it
13 more specifically "Watch out for Rimma Breeze. She is a
14 computer hacker," or "Watch out for the Breezes. They
15 are bad people"? What do you recall about the warning
16 that Alex gave you?
17 A. I don't recall.
18 MR. WILLIAMSON: Lacks foundation, assumes
19 facts.
20 MR. PERETZ: Okay.
21 BY MR. PERETZ:
22 Q. Now, you mentioned nobody passed on your
23 warning. And now I assume from that that that warning
24 was given to you -- was told to you by Alex before you
25 sent the email. Correct?

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1 A. I probably heard that Alex had friends that


2 went there. And Alex has had friends that have gone to
3 All Hallows and have known about the discord between the
4 Breezes and the Romes for years, aside from anything to
5 do with Evans or our technology, so I cannot say to what
6 extent this is referring --
7 Q. Well, you can say because Alex Rome told you
8 that she has friends at All Hallows and she is going to
9 tell them about the Breeze family; correct?
10 A. I don't recall.
11 Q. You don't recall her saying that to you?
12 A. No.
13 Q. Okay. Well, you are talking about passing
14 along a warning. Did Alex told you at some point prior
15 to September 8 that she is going to pass a warning to
16 parents she knows at All Hallows (sic)?
17 A. I don't recall.
18 Q. Okay. You just don't remember? You have
19 completely no recollection whatsoever about that?
20 MR. WILLIAMSON: She said that several times.
21 THE WITNESS: And as I said, this was
22 September 8 of 2013. I was starting school. I was
23 getting married in a month. I had a lot going on.
24 BY MR. PERETZ:
25 Q. Well, if you had a lot going on, why did you

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1 find the time to go to All Hallows' website? If you are


2 so busy, why do you go to the website and then pass it
3 along to Alex Rome?
4 A. I can't say.
5 MR. WILLIAMSON: Now, I will let you ask the
6 questions, but watch your tone.
7 MR. PERETZ: Sure.
8 MR. WILLIAMSON: I understand everybody is
9 getting excited. That's fine, but watch your tone.
10 Don't badger my witness.
11 MR. PERETZ: Sure. No problem.
12 BY MR. PERETZ:
13 Q. At that point you had strong negative feelings
14 toward the Breeze family; correct?
15 A. I don't think that's displayed in this email at
16 all.
17 Q. It is not displayed in this email?
18 A. Not that I can see.
19 Q. Is it fair to assume that by September 8th you
20 learned that Rimma Breeze's kids are going to All
21 Hallows?
22 A. Yes.
23 Q. Okay. And you took an issue with that because
24 you mentioned that to Ms. Breeze's, you know, worst
25 enemy; let's put it this way.

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1 A. It makes no difference to me where the Breezes'


2 children go to school.
3 Q. Why do you put it in writing to someone who was
4 definitely in a contentious situation with Rimma Breeze?
5 A. I can't say. I don't know.
6 Q. Did you -- Did you try or did you make any
7 attempt to essentially -- Strike that.
8 Were you made aware of any attempt that Alex
9 Rome made to prevent the kids of the Breeze family from
10 attending schools after they left The Evans School?
11 A. Aside from what is written in this email? No.
12 Q. Okay. Did you yourself then undertook any
13 action to prevent the Breezes' kids from attending other
14 schools (sic)?
15 A. Absolutely not.
16 Q. Okay. You never did that?
17 A. Absolutely not.
18 Q. Okay. And Alex Rome didn't tell you that she
19 is trying to do that?
20 A. I just said I don't recall besides what is
21 stated in this email.
22 Q. And as you sit here today under oath and
23 penalty of perjury, you have no recollection who Alex
24 Rome was supposed to give a warning about the Breezes;
25 correct?

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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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1 A. Well, my response, as stated in the email, is


2 "Great. Notice our website is down now." So no, that
3 was the extent of it.
4 MR. PERETZ: Move to strike.
5 BY MR. PERETZ:
6 Q. Following this email, did you have any
7 discussion with Alex Rome about what she did -- about
8 what she did behind the scene to try to prevent from --
9 the Breeze family to attend All Hallows school?
10 A. No.
11 MR. WILLIAMSON: Lacks foundation, assumes
12 facts, asked and answered.
13 THE WITNESS: Not that I recall.
14 MR. PERETZ: Okay.
15 BY MR. PERETZ:
16 Q. All you have is this email from Alex Rome. You
17 never had any follow-up with her; correct?
18 A. Not that I recall.
19 Q. Okay. And then why did you make the comment,
20 "Notice our website is down now... Ugh"? What was this
21 comment about?
22 A. Based on my spotty recollection of a year ago,
23 I was assuming our website was not functioning at that
24 time and that that was frustrating.
25 Q. I see.

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1 A. I had also covered that Rimma had been copying


2 some of my emails, so I think I am well-founded to feel
3 a little bit frustrated with the situation.
4 Q. I see.
5 And you thought that Rimma caused the website
6 to be down?
7 A. I did not say that in this email, nor is there
8 any speculation.
9 Q. Okay. Well, I am asking you a question.
10 A. I don't know.
11 Q. Why did you make that comment? Did you think
12 that Rimma took the website down?
13 MR. WILLIAMSON: Which question do you want her
14 to answer? One of those she has already answered. It's
15 a compound question, so break it down. You can't ask
16 both questions.
17 MR. PERETZ: Sure.
18 MR. WILLIAMSON: One of them is asked and
19 answered already.
20 BY MR. PERETZ:
21 Q. On September 8, 2013, at 1:45 p.m., did you
22 think that Rimma Breeze took The Evans School's website
23 down?
24 A. I did not recall that ever even happening until
25 I saw this email, so I don't know.

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1 Q. You just don't remember?


2 A. I don't.
3 Q. Okay. Did anyone tell you that Rimma took the
4 website down?
5 A. I don't recall that either.
6 Q. And you don't know if it was malicious or not
7 malicious?
8 A. I don't.
9 Q. All you have is this very short email to Alex
10 Rome; correct?
11 A. Yes.
12 Q. Okay. And Alex Rome responds and says
13 something about "Need to explain to the parents why the
14 website is down."
15 Do you recall any talks at The Evans School,
16 the small community, about explaining to parents why the
17 website was down?
18 A. All I recall is Gale being very adamant that
19 she did not want any of our legal situation discussed
20 and to get new emails up and running as soon as
21 possible, and that was kind of it. So I believe on
22 September 10th, I think, is when I made new emails for
23 the staff and we had a new form of communication between
24 parents and teachers.
25 Q. Okay. Now, she ends the email by saying "Now

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1 rumors are going around that Evans is broke."


2 Did you ever hear any of those rumors that
3 The Evans School is broke?
4 A. I heard it based on this email that Rimma told
5 her she was the technology head at Evans but Evans
6 didn't have money to pay her because we were having
7 difficulty.
8 Q. That's the only source of that rumor? That's
9 the only thing you heard; correct?
10 A. That I recall.
11 Q. Okay. Nothing outside of this email? You
12 never heard anyone else coming in saying "Is the school
13 broke," or asking whether the school was broke or had no
14 money or anything like that?
15 A. I don't remember.
16 Q. You don't remember because it was a year ago.
17 Correct?
18 A. Yes.
19 Q. Okay. Let's take a short break, and I think
20 we'll be done very soon.
21 MR. WILLIAMSON: Okay.
22 (Recess.)
23 (Plaintiff Exhibit 44 was marked.)
24 BY MR. PERETZ:
25 Q. Let's do this most efficiently. I handed you

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1 Exhibit 44, Ms. --


2 A. Brumfield
3 Q. I'm sorry. I'm just -- the Sarahs are getting
4 mixed up in my mind.
5 A. Brumfield.
6 Q. These appear to be emails that you exchanged
7 with Rimma Breeze. I am not going to ask you any
8 substantive questions on the emails. All I want to do
9 is have you authenticate them, tell me you wrote them.
10 And you don't need to read them as thoroughly as you
11 think you would need to. I just want to make sure you
12 wrote them.
13 A. I sent a lot of emails.
14 Q. All I want to do is to essentially
15 authenticate, meaning confirm that you had those email
16 exchanges with Rimma. I am not asking you about the
17 email.
18 A. It appears the words that I have read in the
19 emails seem to be exchanges we've had.
20 Q. Okay.
21 A. But without going through the full entire
22 thing, you know -- I'm sorry. This is my first time.
23 I don't know how you want me to respond to that.
24 Q. Okay. I think it's enough for us.
25 A. Like if you pull something out later that you

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1 say this -- you know, this one minor thing or something


2 that is not accurate, or I didn't write it, I don't want
3 that to be held against me is my concern.
4 Q. I understand that. So why don't you go through
5 all of them and be comfortable enough to make sure that
6 these emails -- that you exchanged these emails. That's
7 all I want from that.
8 A. Okay.
9 MR. PERETZ: Off the record.
10 (Off the record.)
11 MR. PERETZ: Okay. Let's go back.
12 BY MR. PERETZ:
13 Q. Ms. Brumfield, did you review Exhibit 44?
14 A. I did.
15 Q. Did you exchange all the emails that are part
16 of this exhibit?
17 A. Yes.
18 Q. Okay. Did you ever hear any rumors or
19 statements that the Breezes caused vandalism at the
20 school?
21 A. No.
22 Q. Did you personally experience any act of
23 vandalism that the Breezes engaged in?
24 A. Can you explain "vandalism."
25 Q. Vandalism, act of menace; something that they

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1 broke, something that they destroyed, things of that


2 nature.
3 Q. Not that I recall.
4 Q. Okay. And I'm almost done. Actually, I have
5 one question about one of the emails. If you go -- And
6 I'm -- you are going to get to read the email so you are
7 completely comfortable with it. It's an email from
8 September 14th, 2012. They are organized
9 chronologically, so once you get to that day, let me
10 know.
11 MR. WILLIAMSON: Is that the exchange "When we
12 meet next week"?
13 MR. PERETZ: Yes.
14 BY MR. PERETZ:
15 Q. Why don't you read this email. And then when
16 you know what it is, we can talk about that. I have one
17 question about it.
18 A. Okay.
19 Q. You sent this email to Rimma -- the top
20 email -- September 14, 2012, at 1:22 p.m. Do you have
21 that date in mind?
22 A. Yes.
23 Q. Okay. At the bottom of the email you mentioned
24 a friend from Google that serves on the policy team. Do
25 you see that?

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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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1 and between counsel:)


2 MR. WILLIAMSON: We are going to stipulate to
3 relieve the court reporter of her custodial duties under
4 the Code. The transcript will be prepared in the normal
5 course and sent to Gordon Rees for the witness.
6 We will make the transcript available to the
7 witness for review and signature. We will get the
8 review and signature within two weeks of our receipt of
9 the transcript, and immediately after signature we will
10 provide notice to counsel of the fact of signature and
11 any changes to the transcript.
12 We will maintain custody of the original, make
13 it available upon reasonable request, and lodge it with
14 the court at the time of trial without the need for
15 further request.
16 If the original is not signed, lost, damaged,
17 destroyed, or not made available, a certified copy can
18 be used for any and all purposes, including trial, as if
19 it were a signed, unchanged original transcript.
20 MR. PERETZ: So stipulated.
21 (The deposition concluded at 4:15 p.m.)
22 * * *
23
24
25

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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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1 DEPOSITION ERRATA SHEET


2
3 Our Assignment No. 185549B
4 Case Caption: BREEZ 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 HARRISON BRUMFIELD
23
24
25

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1 DEPOSITION ERRATA SHEET


2 Page No. _____ Line No._____ Change to:_________________
3 ________________________________________________________
4 Reason for change:______________________________________
5 Page No. _____ Line No._____ Change to:_________________
6 ________________________________________________________
7 Reason for change:______________________________________
8 Page No. _____ Line No._____ Change to:_________________
9 ________________________________________________________
10 Reason for change:______________________________________
11 Page No. _____ Line No._____ Change to:_________________
12 ________________________________________________________
13 Reason for change:______________________________________
14 Page No. _____ Line No._____ Change to:_________________
15 ________________________________________________________
16 Reason for change:______________________________________
17 Page No. _____ Line No._____ Change to:_________________
18 ________________________________________________________
19 Reason for change:______________________________________
20 Page No. _____ Line No._____ Change to:_________________
21 ________________________________________________________
22 Reason for change:______________________________________
23
24 SIGNATURE:______________________________________________
25 SARAH HARRISON BRUMFIELD

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1 DEPOSITION ERRATA SHEET


2 Page No. _____ Line No._____ Change to:_________________
3 ________________________________________________________
4 Reason for change:______________________________________
5 Page No. _____ Line No._____ Change to:_________________
6 ________________________________________________________
7 Reason for change:______________________________________
8 Page No. _____ Line No._____ Change to:_________________
9 ________________________________________________________
10 Reason for change:______________________________________
11 Page No. _____ Line No._____ Change to:_________________
12 ________________________________________________________
13 Reason for change:______________________________________
14 Page No. _____ Line No._____ Change to:_________________
15 ________________________________________________________
16 Reason for change:______________________________________
17 Page No. _____ Line No._____ Change to:_________________
18 ________________________________________________________
19 Reason for change:______________________________________
20 Page No. _____ Line No._____ Change to:_________________
21 ________________________________________________________
22 Reason for change:______________________________________
23
24 SIGNATURE:______________________________________________
25 SARAH HARRISON BRUMFIELD

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