Ex-San Ysidro district superintendent Manuel Paul admits squeezing contractor for donations

If we look at the extremely high percentage of women and people of color among the officials indicted by the District Attorney's Public Integrity Unit over the years, we are forced to conclude one of two things:

1) either women and people of color are more corrupt than white males; or

2) the people who are targeted for prosecution do not enjoy the same protections and immunities that white male public officials in San Diego tend to enjoy.

I'm not saying that the DA is racist.  I don't think that's it.  I think the explanation for the gender and color imbalance is simply that the public officials with the most power tend NOT to be women or people of color.  The truly powerful public officials are mostly white males, and the DA wouldn't dare go after them.

And the big money isn't in parking lots in San Ysidro.  It isn't even in $20 million solar panel deals.

A few years ago the FBI was investigating kickbacks to public entities in San Diego from insurance companies. Nothing ever came of that. My guess is that they couldn't find an ideal defendant to indict: someone without connections in the high ranks of the San Diego political establishment.

Here is a link to my page about the County of Santa Clara vs. Driver Alliant Insurance Services, Inc., et al lawsuit.  These are the types of transactions that involve significant amounts of money.  The really big deals are not as much fun for the political establishment to talk about as a small cash envelope in a parking lot--so you don't read about them much in the paper. The big players almost always avoid criminal court. Note the lack of prosecutions in the 2009 Financial Crisis that was caused by the greed of the wealthy and powerful.

The big guys generally don't see the inside of a criminal court, and their civil cases get settled, not tried, where the public might get wind of what actually happened. (Of course, the Manuel Paul case wasn't tried in court, either. Why no trials? Who knows what information might come out in a trial that might expose a big fish?)

Here's a sample of a school district deal worth $1 billion: Superintendent John Deasy of Los Angeles Unified school district (LAUSD) probably isn't worried. I suspect that you need a lot better political connections to become superintendent of LAUSD than you do to get the top spot in San Ysidro School District.

Given that we live in a system in which huge corporation and billionaires believe they can buy elections, it's sort of embarrassing that the FBI is chasing down such small-time players.

Clearly, Bonnie Dumanis and the FBI aren't going to be able to stop campaign finance corruption.

But wouldn't it be nice if the public--and Bonnie Dumanis--started looking a little closer at some of the well-heeled districts on the north side of town?

In CVESD we also had a superintendent using his power to affect the school board election.



See all posts on white chalk crime.

Ex-San Ysidro district superintendent Manuel Paul admits squeezing contractor for donations
Channel 10 News
Aug 20, 2014

SAN DIEGO - A former San Ysidro School District superintendent pleaded guilty in federal court Wednesday to extracting political contributions from a prospective contractor by threatening to withhold work on future building contracts.

Manuel Paul, 63, faces up to a year in federal prison and a $100,000 fine when he is sentenced Nov. 18.

According to his plea agreement, Paul admitted he asked a contractor to contribute $3,600 to three political candidates for the 2010 School Board election...

Read more.

LAUSD insurer sues to avoid paying $30 million Miramonte settlement

LAUSD insurer sues to avoid paying $30 million Miramonte settlement
Former teacher Mark Berndt at his 2012 arraignment on charges that he abused students at Miramonte Elementary School.
Los Angeles Times
By Howard Blume
May 31, 2013

An insurance company has sued the Los Angeles Unified School District seeking to avoid paying settlement costs related to alleged child abuse at Miramonte Elementary School.

The action, if successful, could leave the nation's second-largest school system on the hook for an estimated $30 million that it agreed to pay to 58 alleged victims of former teacher Mark Berndt. At least as many claims remained unresolved, with attorneys seeking higher compensation than the settlement provides.

The suit was filed Wednesday in Los Angeles Superior Court by New Jersey-based Everest National Insurance Co.

L.A. Unified also has sought compensation for more than $5 million spent to replace the entire Miramonte staff for half a year after Berndt's arrest in January 2012.

Everest "disputes that there is any coverage under the Everest policies" for the claims by L.A. Unified. "A judicial declaration is necessary and appropriate," according to the suit.

Six other insurers also are named as defendants. All have provided policies to L.A. Unified, the suit claims.

The type of coverage was general liability, and the companies should be responsible for Miramonte costs beyond a "self-insurance" amount, in the district's view. The district's share of the liability should be $3 million or $5 million, said Sean Andrade, an outside counsel representing L.A. Unified.

The likely outcome of the litigation would be a determination of who owes what, said Andrade, adding that all insurers have so far refused to pay Miramonte-related claims.

Everest sued "before the district could sue them for breach of contract or bad faith," Andrade said.

"It's troubling that these insurance companies which were compensated to provide this coverage are now trying to escape responsibility," said district spokesman Sean Rossall. "We’re going to do everything possible to ensure that the carriers honor our policies. We’ve been working diligently to resolve these cases in the best interests of the students while also honoring the district's obligation to preserve resources for all students.”

Berndt, 62, awaits trial on allegations that he spoon-fed his semen to blindfolded students in his classroom as part of a tasting game. He has pleaded not guilty. He remains in custody in lieu of $23 million bail.


Southern California School District Settles Lewd ‘Tasting Games’ Claims
By Christina Hoag and Gillian Flaccus
March 14, 2013
Insurance Journal

The Los Angeles school district will pay millions of dollars to settle claims and lawsuits filed by students and families from an elementary school where a third-grade teacher was accused of spoon-feeding children semen in what he called “tasting games,” lawyers in the cases said Tuesday.

District officials did not reveal the total amount of the settlement, but attorney Raymond Boucher, who represents several Miramonte Elementary School students, said each claimant will receive $470,000.

District General Counsel David Holmquist said the settlement covers 58 of the 191 claims and lawsuits filed by students and parents against the district after the January 2012 arrest of former third-grade teacher Mark Berndt on 23 charges of lewd behavior spanning five years at Miramonte.

A few of the cases involved another Miramonte teacher, Martin Springer, who was charged with lewd acts on a child in a case involving a second-grader that authorities said was fondled in class in 2009.

The accusation surfaced after Berndt’s arrest, Holmquist said.

The 58 people involved in the settlement are all students, he said.

Prosecutors said in Berndt’s “tasting games” he fed students his semen on cookies and by spoon, sometimes blindfolding and photographing them. Berndt, who taught for 32 years at the South Los Angeles school, has pleaded not guilty in the criminal case.

Springer has also pleaded not guilty.

The allegations against Berndt came to light when a drugstore photo technician noticed dozens of odd photos of blindfolded children and reported them to authorities. Investigators said they discovered a plastic spoon in Berndt’s classroom trash bin that was found to contain traces of semen.

Boucher, who represents 13 of the 58 students in the settlement, said proving some of the claims would have been a problem at trial.

Some children did not have photographs of themselves eating the cookies laced with a milky white substance, or of being fed spoonfuls of it, he said.

In addition, there was no way to prove the substance in photos was semen, he added.

Parents also understood that with so many claims, a jury verdict could bankrupt the district, he added.

“We had to do a balancing act and we understood, if you go that second route and you wind up (with the district) in bankruptcy, these clients will never receive compensation for what they’ve been through,” Boucher said.

Frank Perez, an attorney representing eight students, said parents chose to settle rather than put their children through the emotional upheaval of litigation and to put the case behind them.

Other attorneys blasted the settlement amount as paltry and said they would proceed with their cases.

“This is lifelong trauma,” lawyer Brian Claypool said.

Attorney John Manly said the district has not yet explained how the alleged incidents went undetected for so long.

“The district got a great deal today,” he said. “There’s not been a single explanation of who knew what when.”

The case led to a wide-ranging overhaul of how the nation’s second-largest school district handles allegations of sexual abuse after it was revealed that previous complaints about Berndt’s behavior were ignored.

It also shined a light on how slowly state officials act to censure teachers and led to a flurry of allegations of teacher-student sex abuse in the district and in other school systems...

AIG to pay L.A. Unified nearly $79 million in claims settlement

AIG has been one of the largest investors in L.A. Unified's school-construction bonds. It also has provided investment accounts for teachers who want to put aside savings for retirement.

AIG to pay L.A. Unified nearly $79 million in claims settlement
L.A. Unified had sued insurer AIG over its refusal to pay claims on schools needing environmental cleanup.
August 06, 2012
By Howard Blume
Los Angeles Times

Insurance giant AIG will pay nearly $79 million to the Los Angeles Unified School District to settle a lawsuit over its failure to pay claims on properties with environmental and pollution hazards, The Times has learned.

Although AIG admitted no wrongdoing, the $78.8-million settlement, combined with earlier payments under the policy, approach the full value of $100 million in coverage the district purchased in 1999.

"This is a gold medal, not a bronze, in terms of success, a lot of money," said David Tokofsky, a former member of the Board of Education that voted to purchase the policy and later sued to enforce it. "Sometimes the huge L.A. Unified is the little guy against such giants as AIG."

The district's goal at the time was to provide a financial hedge against any extraordinary cleanup costs incurred during its $20-billion school construction effort.

The move proved wise for L.A. Unified and a poor gamble for AIG, which is best known for its central role in helping trigger the nation's 2008 economic crisis.

The district paid about $7.5 million up front for the 20-year policy and also agreed to pay the first $100,000 on any claim. Even so, the claims quickly absorbed what the district put in, and AIG resisted paying more. L.A. Unified filed suit in 2006, beginning a protracted legal battle that consumed millions of dollars, according to people inside the district who were not authorized to disclose the information.

Both sides agreed to keep the settlement confidential, except as legally required. L.A. Unified disclosed the settlement terms in response to a public records request, but officials declined to comment.

"We're pleased that we were able to reach an amicable resolution with LAUSD and have no comment beyond that," said Frank Kaplan, an attorney who represented AIG and its affiliates.

According to court documents filed by L.A. Unified, AIG's intention "was, all along, to book the premium on the policy — and the business from a prominent public agency — and to resist subsequent claims payments they had promised to pay."

AIG, on the other hand, said in court filings that L.A. Unified was planning "to undertake an extensive program of environmental investigation and remediation … with the intent to deceive [AIG] and to induce it to provide coverage."

As part of this alleged scheme, the insurance company contended that L.A. Unified tried to avoid its own responsibility to pay for cleaning sites long known to contain toxins. Time after time, the district "concealed material information" and converted an insurance policy into a $100-million construction subsidy, according to AIG.

The decision to seek environmental insurance grew out of the district's experience with the Belmont Learning Complex — erected on property that was not fully investigated before its purchase. The eventual cost of that school ballooned to more than 10 times early estimates — for many reasons — and its completion was delayed more than a decade. Belmont became a symbol of the school system's dysfunction.

The policy specifically excluded Belmont, which finally opened in 2008 as the Edward R. Roybal Learning Center.

But an older hot spot, Park Avenue Elementary in Cudahy, became a focus of contention. Park Avenue, which opened in 1968, was built atop a toxic dumpsite; and before long, a chemical, tarry sludge seeped periodically to the playground. In 1989, the district closed the school for a year, performed an interim fix, then abandoned further efforts.

Years later, when new problems arose there, the district resumed work at Park Avenue and filed insurance claims with AIG for the costs. The insurer paid $6.3 million, but the claims soon exceeded $11.1 million, according to court documents. AIG refused to pay more and threatened to take back earlier payments.

Sites with problems known before the policy term, such as Park Avenue, were not eligible for claims, AIG insisted. The insurer also said the work was unnecessarily expensive and that AIG had the right to approve cleanup measures in advance.

The district contended that AIG failed to exclude Park Avenue from potential claims when it had the chance and that L.A. Unified performed work under the direction of state regulators. AIG had access to public officials and reports as well as to the district's environmental consultants and records, according to L.A. Unified. The situation at Park Avenue and some other properties also had been the subject of news reports.

The parties disputed claims arising from more than three dozen schools.

Under state rules, all or most settlement money is likely to go into construction and maintenance funds, according to the district.

By next year, the district will have completed about 140 new schools and hundreds of improvement and renovation projects.

AIG has been one of the largest investors in L.A. Unified's school-construction bonds. It also has provided investment accounts for teachers who want to put aside savings for retirement.

Why do schools litigate instead of settling when they have done wrong? Follow the money: JPAs, insurance brokers, lawyers

Photo: Lora Duzyk (left) is San Diego County Office of Education's Assistant Superintendent for Business Services.

Who is profiting from inflated insurance premiums in San Diego schools? Perhaps just about everyone involved in school liability insurance.

Sometimes my commenters know more than I do about a subject, and school insurance is one of those subjects. A recent comment caused me to do some research. I already knew that the San Diego County Office of Education-Joint Powers Authority was paying millions of tax dollars each years for lawyers who cover up wrongdoing in schools. I didn't know how far up (or down) the corruption went.

I found this:

County pushing suit alleging misdeeds in insurance industry
By Julie O'Shea
San Jose Recorder

Following New York's lead, Santa Clara County is suing several top insurance brokerage firms, claiming they have duped customers out of millions through secret "kickbacks" and other "lucrative" service deals.

"It's almost cartel-like," said the county's outside counsel, Louise Renne, a for-mer San Francisco city attorney who wasbrought on board because of her extensive experience with this type of litigation. "We believe that every public agency in the state of California has been affected."

In a complaint filed in Alameda County Superior Court in November, Santa Clara is alleging that industry giants Marsh & McLennan Cos., Driver Alliant Insurance Service and Keenan & Associates are "steering" clients toward insurers that are offering brokers undisclosed commissions, funded through insurance premiums.

"In the end," the complaint alleges,"clients paid more for less insurance, with defendants siphoning off the difference to pad their bottom line..."





Here is part of what my commenter wrote:

"...Three insurance brokers namely Driver Alliant, Keenan and Associates and Marsh & McLennan manage these super pools. These insurance brokers are being sued in Alameda County where the allegations are for unlawful business practices, in violation of California Business and Profession Code section 17200 et. seq. false and misleading advertisement where they cream millions of dollars in public funds in violation of Business and Profession Government Code Section 17500 et. seq., breach of fiduciary duty, illegal and secret kickbacks, steering premium dollars and getting public agencies to purchase services at high rates.

"...Keenan and Associates has a “HYBRID SELF-INSURANCE and REINSURANCE” [SDCOE has SELF-JPA where Keenan is also a member of this “Super Pool”] pooling program for nearly 400 schools and community colleges.

"Keenan advertised for its Super Pool’s conference at Lake Tahoe as, “The Pudding is in the Pooling,” in their invitations. Yes, the pudding is good, they are raking in Millions of PUBLIC FUNDS through their billable hours...

"Daniel Shinoff and his SASH firm takes the cream of the Southern District billable hours for BOTH Keenan and SELF which are brokered by Marsh & McLennan. The premium billable hours are steered to his firm with the blessing of Keenan, SELF and Diane Crosier.

"Keenan and Marsh and McLennan as the agents of California’s public entities have a fiduciary duty to recommend the best coverage at the best price for its clients. They are to provide independent, objective advice, and to put ‘their clients best interests’ ahead of their own. Keenan and Driver and Marsh and McLennan are hired to act as consulting, billing/premium administration, and claims administration. Their duty is to provide full disclosure, candor, and loyalty. Disclose the amounts of income; Contingent Commissions Agreements and remuneration they receive form all transactions to the public agencies they represent. Keenan has a policy where every employee, associate and partner has to belong to several churches, golf clubs, non-profit organizations and civic groups. This is how they create friendships with judges, political figures, churches and organizations who look the other way. While attorneys like Daniel Shinoff bully public boards into contractual agreements and decisions that are not in the best interest of PUBLIC AGENCIES but bring in a lot of billable hours to his firm and bigger premiums for insurance Brokers and JPA’s.

"The agreements that the PUBLIC AGENCIES get pressured into signing with the JPA’s have different names like: “Contingent Income Agreements” “Production Service Agreements” “Volume Based Commission Agreements” “Profit-Sharing Commission Agreements” “Commission Override Agreements” Premium Value Contingent Commission Agreements” “Preferred Agency Agreements” and “Platinum Profit Sharing Agreements.”

"These commissions create a blatant CONFLICT of INTEREST and a direct financial interest for these brokers, JPA’s and preferred law firms. These commission and preferred agreements cause CONFLICT of INTEREST, along with premium prices in many cases with lower benefits. The insurance companies recoup the kickbacks paid to marsh & Marsh and McLennan, Keenan and Driver by higher insurance prices passed on to the public agencies. Whereby, suppressing competition in the market of insurance.

"This is the reason why the PUBLIC AGENCIES in San Diego cannot get insurance apart from the JPA’s. No insurance company can do business in California without belonging to one of the three “insurance brokers.” The insurance brokers have contractual agreements with certain JPA’s; like SDCOE SELF and these JPA use the same law firms they have contractual agreements with like Best Best and Krieger, Stutz, Artiano, Shinoff and Holtz “SASH” and Winet..."

(End of quote of commenter to this blog.)

It turns out that insurance companies were doing a lot of harm long before they helped bring down the US economy in 2008 with their credit default derivatives. The derivatives were too complicated and clever by half, a scheme to get rich quick while promising that there would be no consequences. The government failed to regulate these scams, pretending they weren't really insurance policies. Institutions began to fail once it was discovered that the institutions didn't have any protection against defaults because they were unknowingly insuring themselves.


Many local school districts belong to the San Diego County Office of Education-JPA. Diane Crosier is the Executive Director of the SDCOE-JPA, and she works under the direction of SDCOE Superintendent Randolph Ward and Asst. Supt. Lora Duzyk. Crosier represents the SDCOE-JPA at a bigger JPA called SELF.

Diane Crosier then goes on to represent SELF when the other JPAs come together to form what it is called a “super pool,” then she reports back (delivers instructions) to SELF and SDCOE-JPA (which she herself directs).

This complete circle leaves me wondering who is in charge, the people at the bottom or the people at the top? There is some evidence that the person in charge is Stutz Artiano Shinoff & Holtz attorney Daniel Shinoff, whom Diane Crosier most often selects to represent school districts in San Diego.

What do San Diego county schools have in common with Iraq defense contractors? AIG insurance!

Students and employees in San Diego county have something in common with private-company contractors who work in Iraq beside American troops: when they are harmed, they are at the mercy of AIG lawyers and other insurance company lawyers.

Both deserve better.

From "The Wars Come Home":

"Insurance companies alone have pocketed $600 million in excessive profits over the past five years, says a staff report from the House Oversight and Government Reform Committee, but the Defense Department refuses to adjust its approach for managing the program."

A poorly run Pentagon program for providing workman's compensation for civilian taxpayers, a House oversight committee said Thursday.

Insurance companies alone have pocketed $600 million in excessive profits over the past five years, says a staff report from the House Oversight and Government Reform Committee, but the Defense Department refuses to adjust its approach for managing the program.

According to the committee, the Pentagon allows its contractors to negotiate their own insurance contracts. By contrast, the State Department, U.S. Agency for International Development and the Army Corps of Engineers have all selected a single insurance carrier to provide the insurance at fixed rates.

"What makes the situation even worse is the people this program is supposed to benefit - the injured employees working for contractors - have to fight the insurance companies to get their benefits," committee Chairman Henry Waxman, D-Calif., said at a hearing Thursday. "Delays and denials in paying claims are the rule."

KBR Inc., one of the largest defense contractors in Iraq, paid the insurance giant AIG $284 million for medical and disability coverage under the Defense Base Act, a reference to the federal law mandating the insurance. Due to the way KBR's contract is structured, this premium, along with an $8 million markup for KBR, gets billed to the taxpayer.

"Out of this amount, just $73 million actually goes to injured contractors, and AIG and KBR pocket over $100 million as profit," Waxman said.

Full Story

JPAs, insurance brokers, lawyers: who is profiting from school litigation? Santa Clara v. Keenan & Associates

Photo: Lora Duzyk (left) is San Diego County Office of Education's Assistant Superintendent for Business Services.

Who is profiting from inflated insurance premiums in San Diego schools? Perhaps just about everyone involved in school liability insurance.

Sometimes my commenters know more than I do about a subject, and school insurance is one of those subjects. A recent comment caused me to do some research. I already knew that the San Diego County Office of Education-Joint Powers Authority was paying millions of tax dollars each years for lawyers who cover up wrongdoing in schools. I didn't know how far up (or down) the corruption went.

I found this:

County pushing suit alleging misdeeds in insurance industry
By Julie O'Shea
San Jose Recorder

Following New York's lead, Santa Clara County is suing several top insurance brokerage firms, claiming they have duped customers out of millions through secret "kickbacks" and other "lucrative" service deals.

"It's almost cartel-like," said the county's outside counsel, Louise Renne, a for-mer San Francisco city attorney who wasbrought on board because of her extensive experience with this type of litigation. "We believe that every public agency in the state of California has been affected."

In a complaint filed in Alameda County Superior Court in November, Santa Clara is alleging that industry giants Marsh & McLennan Cos., Driver Alliant Insurance Service and Keenan & Associates are "steering" clients toward insurers that are offering brokers undisclosed commissions, funded through insurance premiums.

"In the end," the complaint alleges,"clients paid more for less insurance, with defendants siphoning off the difference to pad their bottom line..."





Here is part of what my commenter wrote:

"...Three insurance brokers namely Driver Alliant, Keenan and Associates and Marsh & McLennan manage these super pools. These insurance brokers are being sued in Alameda County where the allegations are for unlawful business practices, in violation of California Business and Profession Code section 17200 et. seq. false and misleading advertisement where they cream millions of dollars in public funds in violation of Business and Profession Government Code Section 17500 et. seq., breach of fiduciary duty, illegal and secret kickbacks, steering premium dollars and getting public agencies to purchase services at high rates.

"...Keenan and Associates has a “HYBRID SELF-INSURANCE and REINSURANCE” [SDCOE has SELF-JPA where Keenan is also a member of this “Super Pool”] pooling program for nearly 400 schools and community colleges.

"Keenan advertised for its Super Pool’s conference at Lake Tahoe as, “The Pudding is in the Pooling,” in their invitations. Yes, the pudding is good, they are raking in Millions of PUBLIC FUNDS through their billable hours...

"Daniel Shinoff and his SASH firm takes the cream of the Southern District billable hours for BOTH Keenan and SELF which are brokered by Marsh & McLennan. The premium billable hours are steered to his firm with the blessing of Keenan, SELF and Diane Crosier.

"Keenan and Marsh and McLennan as the agents of California’s public entities have a fiduciary duty to recommend the best coverage at the best price for its clients. They are to provide independent, objective advice, and to put ‘their clients best interests’ ahead of their own. Keenan and Driver and Marsh and McLennan are hired to act as consulting, billing/premium administration, and claims administration. Their duty is to provide full disclosure, candor, and loyalty. Disclose the amounts of income; Contingent Commissions Agreements and remuneration they receive form all transactions to the public agencies they represent. Keenan has a policy where every employee, associate and partner has to belong to several churches, golf clubs, non-profit organizations and civic groups. This is how they create friendships with judges, political figures, churches and organizations who look the other way. While attorneys like Daniel Shinoff bully public boards into contractual agreements and decisions that are not in the best interest of PUBLIC AGENCIES but bring in a lot of billable hours to his firm and bigger premiums for insurance Brokers and JPA’s.

"The agreements that the PUBLIC AGENCIES get pressured into signing with the JPA’s have different names like: “Contingent Income Agreements” “Production Service Agreements” “Volume Based Commission Agreements” “Profit-Sharing Commission Agreements” “Commission Override Agreements” Premium Value Contingent Commission Agreements” “Preferred Agency Agreements” and “Platinum Profit Sharing Agreements.”

"These commissions create a blatant CONFLICT of INTEREST and a direct financial interest for these brokers, JPA’s and preferred law firms. These commission and preferred agreements cause CONFLICT of INTEREST, along with premium prices in many cases with lower benefits. The insurance companies recoup the kickbacks paid to marsh & Marsh and McLennan, Keenan and Driver by higher insurance prices passed on to the public agencies. Whereby, suppressing competition in the market of insurance.

"This is the reason why the PUBLIC AGENCIES in San Diego cannot get insurance apart from the JPA’s. No insurance company can do business in California without belonging to one of the three “insurance brokers.” The insurance brokers have contractual agreements with certain JPA’s; like SDCOE SELF and these JPA use the same law firms they have contractual agreements with like Best Best and Krieger, Stutz, Artiano, Shinoff and Holtz “SASH” and Winet..."

(End of quote of commenter to this blog.)

It turns out that insurance companies were doing a lot of harm long before they helped bring down the US economy in 2008 with their credit default derivatives. The derivatives were too complicated and clever by half, a scheme to get rich quick while promising that there would be no consequences. The government failed to regulate these scams, pretending they weren't really insurance policies. Institutions began to fail once it was discovered that the institutions didn't have any protection against defaults because they were unknowingly insuring themselves.


Many local school districts belong to the San Diego County Office of Education-JPA. Diane Crosier is the Executive Director of the SDCOE-JPA, and she works under the direction of SDCOE Superintendent Randolph Ward and Asst. Supt. Lora Duzyk. Crosier represents the SDCOE-JPA at a bigger JPA called SELF.

Diane Crosier then goes on to represent SELF when the other JPAs come together to form what it is called a “super pool,” then she reports back (delivers instructions) to SELF and SDCOE-JPA (which she herself directs).

This complete circle leaves me wondering who is in charge, the people at the bottom or the people at the top? There is some evidence that the person in charge is Stutz Artiano Shinoff & Holtz attorney Daniel Shinoff, whom Diane Crosier most often selects to represent school districts in San Diego.