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1 Diane Aqui, SBN 217087
daqui@smithdollar.com
2 David J. Leonard, SBN 217443
dleonard@smithdollar.com
3 SMITH DOLLAR PC
Attorneys at Law
4 418 B Street, Fourth Floor
Santa Rosa, California 95401
5 Telephone: (707) 522-1100
Facsimile: (707) 522-1101
6
Attorneys for Defendants SPURGEON PAINTING, INC., THOMAS BOYD MEACHAM III, and
7 TIJA BUCKALEW
8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
9
10 MAYA CASTRO, an individual, CASE NO.: SCV-269513
11 Plaintiff, DECLARATION OF DIANE AQUI IN
SUPPORT OF DEFENDANT SPURGEON
12 v. PAINTING, INC.’S MOTION IN LIMINE
NO. 1 THROUGH NO. 4
13 SPURGEON PAINTING, INC., a California
Corporation; THOMAS BOYD MEACHAM Date: April 5, 2024
14 III, an individual; TIJA BUCKALEW, an Time: 8:30 a.m.
individual and DOES 1-50, Dept.: 18
15
Defendants. Judge: Hon. Christopher Honigsberg
16
Complaint Filed: October 15, 2021
17 Trial Date: April 5, 2024
18
I, Diane Aqui, declare as follows:
19
1. I am over the age of 18 and am an attorney at law duly licensed to practice before all of the
20
Courts of the State of California. I am an attorney with the firm Smith Dollar PC, counsel for
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Defendant Spurgeon Painting, Inc. I have either personal knowledge of the facts set forth in this
22
Declaration and could testify competently thereto if called upon to do so or I am informed and
23
believe those facts.
24
2. I am informed and believe that Plaintiff, Maya Castro, began working for Spurgeon
25
Painting, Inc. in January of 2021.
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3. I am informed and believe that it became apparent to Defendant that she was unable to
27
perform the duties of her position, including the job duties of sales and bidding projects; she was
28
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DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION
IN LIMINE NO. 1 THROUGH NO. 4
1 forgetful, unorganized, not prepared and did not retain information.
2 4. I am informed and believe that on April 9, 2021, Plaintiff was terminated from her position
3 for those reasons.
4 5. I am informed and believe that Sometime in March of 2021, Ms. Buckalew noticed a mass
5 on the Plaintiff’s neck and advised her to get it checked out.
6 6. I am informed and believe that on March 6, 2021, Ms. Castro went to the emergency room,
7 and was referred to a thyroid doctor whom she saw on March 17, 2021. During that visit, samples
8 were taken of her right thyroid.
9 7. I am informed and believe that on March 23, 2021, samples were taken of Ms. Castro’s left
10 thyroid.
11 8. I am informed and believe that on March 31, 2023, Ms. Castro returned to the doctor and
12 was told that the mass on her right thyroid was benign (i.e., non-cancerous).
13 9. I am informed and believe that on April 8, 2021, Plaintiff returned to the doctor for the
14 results of her left thyroid test, which were “nondiagnostic” (i.e., inconclusive”). At that time, she
15 decided to have surgery to remove both the right and left thyroid “regardless of the biopsy results”.
16 10. I am informed and believe that Ms. Castro ultimately had surgery on April 29, 2021, twenty
17 days after she was terminated.
18 11. I am informed and believe that on or about June 8, 2021, it was determined that the left
19 thyroid, which had been removed, was cancerous.
20 12. During the course of discovery in the instant litigation, I discovered that Ms. Castro has
21 filed a wage claim against Defendants at the California Department of Labor alleging that she is
22 owed wages and waiting time penalties.
23 13. During the course of discovery in the instant litigation, Ms. Castro served discovery requests
24 aimed at determining whether Mr. Mecham and Ms. Buckalew had a sexual/romantic relationship.
25 14. An excerpt from Special Interrogatory No.: 55, propounded by Ms. Castro and served on
26 August 31, 2022, states: “ Have you ever had sexual relations with defendant, Tija Buckalew? If
27 so, please list the approximate dates of those sexual relations, where those sexual relations occurred
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DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION
IN LIMINE NO. 1 THROUGH NO. 4
1 . . .”
2 15. At her June 1, 2023, Deposition, Ms. Castro testified as follows regarding Special
3 Interrogatory No. 55:
4 Q. Is that a question that you submitted to ·Mr. Meacham?
5 A.· Yes.
6 Q.· And what was the purpose of you submitting that question to him?
7 A.· To find out whether or not they had a romantic relationship. ·
8 Q.· And what does that have to do with this litigation?
9 A.· That has everything to do with it. It has to do with the fact that he was taking
10 orders from her or conversing with her so often, I wanted to know if there was a
11 romantic connection there.
12 Q.· Again, what type of relevance does that have to this litigation?
13 A. That is a great deal. If you have a history with someone, romantically, either in
14 the past or currently, that can effect your judgment.
15 16. Attached hereto as Exhibit A is a true and correct copy of the above exchange from Ms.
16 Castro’s deposition transcript at RT 111:19-112:12.
17 17. Ms. Castro also testified as follows:
18 Q. So you believed that they had some type of a sexual relationship?
19 A.· I was trying to find out. Romantic relationship would be more of an accurate
20 but that goes hand and hand.
21 Q.· You think asking a question, whether they had a romantic relationship is more
22 accurate of what you actually asked?
23 A.· No. I feel both are accurate.
24 Q.· Okay. Let's look at question Number 54. And you asked, have you ever had a
25 romantic relationship with defendant, Tija Buckalew. If so, please list the
26 approximate date the relationship began. ·Is the relationship presently ongoing.·
27 When did the relationship end. And so your testimony is that you believe that is
28
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DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION
IN LIMINE NO. 1 THROUGH NO. 4
1 relevant to your lawsuit for wrongful termination?
2 A.· I note them both on this lawsuit, so I needed to decipher whether or not those
3 two had some type of relationship that would have effected decisions that were
4 made.
5 18. Attached hereto as Exhibit B is a true and correct copy of the above exchange from Ms.
6 Castro’s deposition transcript at RT 113:9-114:6.
7 19. Further a text exchange was produced by Ms. Castro at her deposition, which she also
8 testified about:
9 A. “ D-A, double D, you need to be upgraded to the notorious D-A, double D.
10 Your strategy was spot on. Those mother fuckers clearly had something to hide.
11 That was genius asking them questions about their relationship history.”
12 (See RT 115:1 -25; 118: 1-17)
13 20. Attached hereto as Exhibit C is a true and correct copy of the above exchange from Ms.
14 Castro’s deposition transcript at RT 115:1-25; 118: 1-17.
15 21. Defendants expect that at trial, Ms. Castro will attempt to produce evidence of a relationship
16 between Mr. Meacham and Ms. Buckalew.
17 I declare under penalty of perjury under the laws of the State of California, that the
18 foregoing is true and correct. Executed on March 26, 2024 at Santa Rosa, California.
19
20
21 DIANE AQUI
22
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DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION
IN LIMINE NO. 1 THROUGH NO. 4
Exhibit A
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SONOMA
6 MAYA CASTRO, )
)
Plaintiff, )
)
vs. ) No. SCV-269513
)
SPURGEON PAINTING, INC., a )
California Corporation; THOMAS )
10 BOYD MEACHAM III, an individual)
TIJA BUCKALEW, an individual )
And DOES 1 — 50, )
)
Defendant. )
)
DEPOSITION OF MAYA CASTRO, the Plaintiff herein,
16 noticed by SMITH DOLLAR, P.C., at 17877 Von Karman,
Irvine, California, at 9:47 a.m., on Thursday,
18 June 1, 2023, before Stephanie Hill-Larson,
19 CSR 11774.
20
Job Number 989407
22
MAYA CASTRO —
06/01/2023
Page 111
And then xight undex that paxagxaph it says,
2 dec lax'e under penal ty of pex" J ury that the f ox'cgoing is
3 txue and corxect.
And then you signed this document.
Correct?
A. Correct.
Q. Okay.
8 Can you turn to page 18, Special Interrogatory,
9 Number 55.
10 And this question is a question that you were
11 directj.ng towards defendant, Boyd Meacham.
Coxxect'?
A. Correct.
14 Q. Okay.
15 And this question says, have you evex had sexual
16 xelations with defendant, Tija Buckalew'?
17 If so, please list the appxoximate dates of those
18 sexual relations, where those sexual relations occurred.
19 'Xs that a question, that you submitted to
20 Mx'. Meacham?
Q~ And'hat was the purpose of you submitting that
23 question to .him?
24 - . A.: find out whether'x'ot they.-had:
To a.'roin@ntj.c
25 x'elationship.
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MAYA CASTRO —
06/01/2023
Page 112
Q~ AM what does that have to do with th3.8
5 fx'Qm
A. 3.t.'t That has everything
to do with the fact that he.was taking orders
hBs
her Qx'onvers3.ng w3.th her so Qftell, I'.wanted
t'Q do w3.th
6 know 3.f thex'6 was B, romantic.c cQrlnect3.on there.
this 3.irrigation'P
9 A. 'hat 3.S B. gX'eat deal.
10'' .
'' Tf you'ave B h3.story w3.th someone, romantic.ca13.y,
ll either .3.n t116 past'x'urr6ntly, that can 8f f ect your
l.2 'udgment
13 Q. Dkay.
14 And why did you believe that they had had sexual
15 relations'P
16 A. Boyd made a comment to me about having met Tija
17 online. And that it was, a conversation for another
18 time.
Q. Now, Tija was the daughter of the former owner.
20 Correct'P
21 A. Correct.
Q. And she had woxked at Spurgeon Painting for many
23 years»
24 Cox rect'P
A. Again, I can't confirm or deny whether she
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Exhibit B
MAYA CASTRO —
06/01/2023
Page 113
worked, or 3.n wha't capac1ty.
Q. Okay.
But Boyd Meacham had woxked for Spuxgeon Painting
4 fox about 20 years.
5 Correct?
A. I don't know for 20 years, but for a long time.
7 Yes.
Q. Okay.
8o you believed .that they had some type of a sexual
3.4
3.5
16
'.
.3.3„.,:„:;.",,".:hut,::th@5:,qoeS„,I1aDd:, aD4.,4an4.-
'.
Ton AU;nk:asking a
romantic x'83.ationship
actua3 ly asked?
is mox'8
.questionq'Blether they had a
acc'ux'ate Qf 'what you
20 Jet's 3.ook at question Ãumber 54.
23. And you asked have'you evex'ad a romantic
22 x'83.ationship with defendant Ti3a Bucka3.8w. 3.f so
23 . p3.ease 3.3.st the appx'oximL@te date the.'x'83.ationship .beg'an.
:24 "- Xs. the re3.ationship present3y:..Ongoing'.:: %%en.'did .the
25 re3.ationship end.
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MAYA CASTRO —
06/01/2023
Page 114
Axed SQ youx'8stimony is that you believe that i'
"2 . x'elevaxlt to yQux" 1a'wsuk.t:for 'wx'Qngful.'texminat'3.QnV
5 relationship that would have effected decisions that were
'6 made
7 Q. I'm going to hand you a -- I identified it as
8 page 4 -- this is from Exhibit A-1 that you had provided
9 to -- in response to my discovery request.
10 Can you take a look at that and can you read it for
11 us'P
12 Nell, fixst of all, why don't you just tell me what
13 it is af ter you have looked a't itP
14 A. So I would 1dent3.fy thl.s as a prd.vate
15 conversation between my dad and I. Which I personally
16 don't believe is relevant to anything.
17 Q. Okay.
18 So
19 A. Kindly provided it.
20 Q. I'm
sorry'.
21 I kindly provided it.
Q. You kindly provided it in response to my Request
23 f ox'roductions ~ this morning's
A. Yes.
Q. Okay.
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Exhibit C
MAYA CASTRO —
06/01/2023
Page 115
A. .Octet)er..-- Monday, Octobex'.3.
Qkay-
And is that a text l5888age exchange'8 584wean you and
5 Luis Caitxo, yeux dadV.
A Yes'.
Okay.
. Can .you Read it
out loud f ox'h% 'x'ecox'd7.
9 .A. D-A, double D, you need. to-be upgxaded to tbe
10 notoxious D-A, double D. Your strategy was spot on.
11 Those motbex -- blanked out '-- clearly bad something to
12 tbel.x'3:
bide. Tbat. was geQiu8 a8king tbem qQestiQns about
-..+elat3.oQ8h'3p .bi8tox'y.
18 tbe--
NR PIESNER- It'8 a "yes" ox "no" question
THE NITNESS: No.
%%at was .that iQ x'8I8Pon88 t07
A. I don t x'ecall.
g. %hat is the &ox'd aha't'8 Maoked ou'tP
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MAYA CASTRO —
06/01/2023
Page 118
3.' 3.n itg but you.x'e not ah3.e to reca3.3. what that wox'd, was'
A ..It cOU3;d ..be you know., f Uckex'8,.
Could 'be ~
tx'Uckex'8 .
MR. PIESNER: (Indicating) .
THE WITNESS': Qh nice. .It was .fuckex's.
NR. PIHSNER: I'm soxx'y. I can xead it on the
MS. AQUI:
Right.
Q.
10 So the text that you sent to your dad said, those
11 mother fuckex s clearly had something to hide.
Is that corr ec't7
A. Coxrect.
Q. And who who axe you refexring toP
15 A. More than likely, Boyd and Tija, and
16 potentially, you.
I don't know.
18 Q. Okay.
19 then you say, that was genius asking them
And
20 questions about their relationship history.
So what questions were you asking about their
22 relationship history'P
23 A. I mean, 'tha,t could have been x'e f e1 1 ing to a
24 d1af t of a copy.
25 That could be referring to this (indicating).
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MAYA CASTRO —
06/01/2023
Page 235
1 STATE OF CALIFORNIA ) ss
I, Stephanie Hill-Larson, CSR 11774, do hereby
That, prior to being examined, the witness named in
7 the foregoing deposition was by me duly sworn pursuant to
8 Section 2093(b) and 2094 of the Code of Civil Procedure;
10 That said deposition was taken down by me in
11 shorthand at the time and place therein named and
12 thereafter reduced to text under my direction.
I further declare that I have no interest in tbe
15 event of the action.
16
I declare under penalty of perjury under tbe laws of
18 tbe State of California that the foregoing is true and
19 correct.
20
WITNESS my band this 5th day of June, 2023.
Stepbanie Hill-Larson., CSR 11774
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Tbe LIT Group 079F
1 PROOF OF SERVICE
2 I am employed in the County of Sonoma, State of California. I am over the age of 18 years
and not a party to the within action. My business address is 418 B Street, Fourth Floor, Santa Rosa,
3 CA 95401. On March 27, 2024, I served the attached DECLARATION OF DIANE AQUI IN
SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION IN LIMINE NO. 1
4 THROUGH NO. 4 on the parties to this action by serving:
5
Mr. Mark Piesner
6 Arc Point Law PC
22287 Mulholland Highway, #198
7 Calabasas, CA 91301
mark@arcpointlaw.com
8 Attorney for Maya Castro
9 /X/ BY EMAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an agreement
of the parties to accept service by e-mail or electronic transmission, I caused the documents to be
10 sent to the persons at the e-mail addresses listed above. No electronic message or other indication
that the transmission was unsuccessful was received within a reasonable time after the transmission.
11
I declare under penalty of perjury under the laws of the State of California that the foregoing is true
12 and correct.
13 Dated: March 27, 2024
14 ____________________________________________
Stephanie D. Abbott
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2024-4-5 dec of da for mils -1-
PROOF OF SERVICE
Preview
1 Diane Aqui, SBN 217087 daqui@smithdollar.com 2 David J. Leonard, SBN 217443 dleonard@smithdollar.com 3 SMITH DOLLAR PC Attorneys at Law 4 418 B Street, Fourth Floor Santa Rosa, California 95401 5 Telephone: (707) 522-1100 Facsimile: (707) 522-1101 6 Attorneys for Defendants SPURGEON PAINTING, INC., THOMAS BOYD MEACHAM III, and 7 TIJA BUCKALEW 8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA 9 10 MAYA CASTRO, an individual, CASE NO.: SCV-269513 11 Plaintiff, DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON 12 v. PAINTING, INC.’S MOTION IN LIMINE NO. 1 THROUGH NO. 4 13 SPURGEON PAINTING, INC., a California Corporation; THOMAS BOYD MEACHAM Date: April 5, 2024 14 III, an individual; TIJA BUCKALEW, an Time: 8:30 a.m. individual and DOES 1-50, Dept.: 18 15 Defendants. Judge: Hon. Christopher Honigsberg 16 Complaint Filed: October 15, 2021 17 Trial Date: April 5, 2024 18 I, Diane Aqui, declare as follows: 19 1. I am over the age of 18 and am an attorney at law duly licensed to practice before all of the 20 Courts of the State of California. I am an attorney with the firm Smith Dollar PC, counsel for 21 Defendant Spurgeon Painting, Inc. I have either personal knowledge of the facts set forth in this 22 Declaration and could testify competently thereto if called upon to do so or I am informed and 23 believe those facts. 24 2. I am informed and believe that Plaintiff, Maya Castro, began working for Spurgeon 25 Painting, Inc. in January of 2021. 26 3. I am informed and believe that it became apparent to Defendant that she was unable to 27 perform the duties of her position, including the job duties of sales and bidding projects; she was 28 -1- DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION IN LIMINE NO. 1 THROUGH NO. 4 1 forgetful, unorganized, not prepared and did not retain information. 2 4. I am informed and believe that on April 9, 2021, Plaintiff was terminated from her position 3 for those reasons. 4 5. I am informed and believe that Sometime in March of 2021, Ms. Buckalew noticed a mass 5 on the Plaintiff’s neck and advised her to get it checked out. 6 6. I am informed and believe that on March 6, 2021, Ms. Castro went to the emergency room, 7 and was referred to a thyroid doctor whom she saw on March 17, 2021. During that visit, samples 8 were taken of her right thyroid. 9 7. I am informed and believe that on March 23, 2021, samples were taken of Ms. Castro’s left 10 thyroid. 11 8. I am informed and believe that on March 31, 2023, Ms. Castro returned to the doctor and 12 was told that the mass on her right thyroid was benign (i.e., non-cancerous). 13 9. I am informed and believe that on April 8, 2021, Plaintiff returned to the doctor for the 14 results of her left thyroid test, which were “nondiagnostic” (i.e., inconclusive”). At that time, she 15 decided to have surgery to remove both the right and left thyroid “regardless of the biopsy results”. 16 10. I am informed and believe that Ms. Castro ultimately had surgery on April 29, 2021, twenty 17 days after she was terminated. 18 11. I am informed and believe that on or about June 8, 2021, it was determined that the left 19 thyroid, which had been removed, was cancerous. 20 12. During the course of discovery in the instant litigation, I discovered that Ms. Castro has 21 filed a wage claim against Defendants at the California Department of Labor alleging that she is 22 owed wages and waiting time penalties. 23 13. During the course of discovery in the instant litigation, Ms. Castro served discovery requests 24 aimed at determining whether Mr. Mecham and Ms. Buckalew had a sexual/romantic relationship. 25 14. An excerpt from Special Interrogatory No.: 55, propounded by Ms. Castro and served on 26 August 31, 2022, states: “ Have you ever had sexual relations with defendant, Tija Buckalew? If 27 so, please list the approximate dates of those sexual relations, where those sexual relations occurred 28 -2- DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION IN LIMINE NO. 1 THROUGH NO. 4 1 . . .” 2 15. At her June 1, 2023, Deposition, Ms. Castro testified as follows regarding Special 3 Interrogatory No. 55: 4 Q. Is that a question that you submitted to ·Mr. Meacham? 5 A.· Yes. 6 Q.· And what was the purpose of you submitting that question to him? 7 A.· To find out whether or not they had a romantic relationship. · 8 Q.· And what does that have to do with this litigation? 9 A.· That has everything to do with it. It has to do with the fact that he was taking 10 orders from her or conversing with her so often, I wanted to know if there was a 11 romantic connection there. 12 Q.· Again, what type of relevance does that have to this litigation? 13 A. That is a great deal. If you have a history with someone, romantically, either in 14 the past or currently, that can effect your judgment. 15 16. Attached hereto as Exhibit A is a true and correct copy of the above exchange from Ms. 16 Castro’s deposition transcript at RT 111:19-112:12. 17 17. Ms. Castro also testified as follows: 18 Q. So you believed that they had some type of a sexual relationship? 19 A.· I was trying to find out. Romantic relationship would be more of an accurate 20 but that goes hand and hand. 21 Q.· You think asking a question, whether they had a romantic relationship is more 22 accurate of what you actually asked? 23 A.· No. I feel both are accurate. 24 Q.· Okay. Let's look at question Number 54. And you asked, have you ever had a 25 romantic relationship with defendant, Tija Buckalew. If so, please list the 26 approximate date the relationship began. ·Is the relationship presently ongoing.· 27 When did the relationship end. And so your testimony is that you believe that is 28 -3- DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION IN LIMINE NO. 1 THROUGH NO. 4 1 relevant to your lawsuit for wrongful termination? 2 A.· I note them both on this lawsuit, so I needed to decipher whether or not those 3 two had some type of relationship that would have effected decisions that were 4 made. 5 18. Attached hereto as Exhibit B is a true and correct copy of the above exchange from Ms. 6 Castro’s deposition transcript at RT 113:9-114:6. 7 19. Further a text exchange was produced by Ms. Castro at her deposition, which she also 8 testified about: 9 A. “ D-A, double D, you need to be upgraded to the notorious D-A, double D. 10 Your strategy was spot on. Those mother fuckers clearly had something to hide. 11 That was genius asking them questions about their relationship history.” 12 (See RT 115:1 -25; 118: 1-17) 13 20. Attached hereto as Exhibit C is a true and correct copy of the above exchange from Ms. 14 Castro’s deposition transcript at RT 115:1-25; 118: 1-17. 15 21. Defendants expect that at trial, Ms. Castro will attempt to produce evidence of a relationship 16 between Mr. Meacham and Ms. Buckalew. 17 I declare under penalty of perjury under the laws of the State of California, that the 18 foregoing is true and correct. Executed on March 26, 2024 at Santa Rosa, California. 19 20 21 DIANE AQUI 22 23 24 25 26 27 28 -4- DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION IN LIMINE NO. 1 THROUGH NO. 4 Exhibit A SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SONOMA 6 MAYA CASTRO, ) ) Plaintiff, ) ) vs. ) No. SCV-269513 ) SPURGEON PAINTING, INC., a ) California Corporation; THOMAS ) 10 BOYD MEACHAM III, an individual) TIJA BUCKALEW, an individual ) And DOES 1 — 50, ) ) Defendant. ) ) DEPOSITION OF MAYA CASTRO, the Plaintiff herein, 16 noticed by SMITH DOLLAR, P.C., at 17877 Von Karman, Irvine, California, at 9:47 a.m., on Thursday, 18 June 1, 2023, before Stephanie Hill-Larson, 19 CSR 11774. 20 Job Number 989407 22 MAYA CASTRO — 06/01/2023 Page 111 And then xight undex that paxagxaph it says, 2 dec lax'e under penal ty of pex" J ury that the f ox'cgoing is 3 txue and corxect. And then you signed this document. Correct? A. Correct. Q. Okay. 8 Can you turn to page 18, Special Interrogatory, 9 Number 55. 10 And this question is a question that you were 11 directj.ng towards defendant, Boyd Meacham. Coxxect'? A. Correct. 14 Q. Okay. 15 And this question says, have you evex had sexual 16 xelations with defendant, Tija Buckalew'? 17 If so, please list the appxoximate dates of those 18 sexual relations, where those sexual relations occurred. 19 'Xs that a question, that you submitted to 20 Mx'. Meacham? Q~ And'hat was the purpose of you submitting that 23 question to .him? 24 - . A.: find out whether'x'ot they.-had: To a.'roin@ntj.c 25 x'elationship. Litigation Services 800-330-1112 www.litigationservices.corn ~ ~ The LIT Group 079F MAYA CASTRO — 06/01/2023 Page 112 Q~ AM what does that have to do with th3.8 5 fx'Qm A. 3.t.'t That has everything to do with the fact that he.was taking orders hBs her Qx'onvers3.ng w3.th her so Qftell, I'.wanted t'Q do w3.th 6 know 3.f thex'6 was B, romantic.c cQrlnect3.on there. this 3.irrigation'P 9 A. 'hat 3.S B. gX'eat deal. 10'' . '' Tf you'ave B h3.story w3.th someone, romantic.ca13.y, ll either .3.n t116 past'x'urr6ntly, that can 8f f ect your l.2 'udgment 13 Q. Dkay. 14 And why did you believe that they had had sexual 15 relations'P 16 A. Boyd made a comment to me about having met Tija 17 online. And that it was, a conversation for another 18 time. Q. Now, Tija was the daughter of the former owner. 20 Correct'P 21 A. Correct. Q. And she had woxked at Spurgeon Painting for many 23 years» 24 Cox rect'P A. Again, I can't confirm or deny whether she Litigation Services ~ SOO-330-1112 www.litigationservices.corn ~ The LIT Group 079F Exhibit B MAYA CASTRO — 06/01/2023 Page 113 worked, or 3.n wha't capac1ty. Q. Okay. But Boyd Meacham had woxked for Spuxgeon Painting 4 fox about 20 years. 5 Correct? A. I don't know for 20 years, but for a long time. 7 Yes. Q. Okay. 8o you believed .that they had some type of a sexual 3.4 3.5 16 '. .3.3„.,:„:;.",,".:hut,::th@5:,qoeS„,I1aDd:, aD4.,4an4.- '. Ton AU;nk:asking a romantic x'83.ationship actua3 ly asked? is mox'8 .questionq'Blether they had a acc'ux'ate Qf 'what you 20 Jet's 3.ook at question Ãumber 54. 23. And you asked have'you evex'ad a romantic 22 x'83.ationship with defendant Ti3a Bucka3.8w. 3.f so 23 . p3.ease 3.3.st the appx'oximL@te date the.'x'83.ationship .beg'an. :24 "- Xs. the re3.ationship present3y:..Ongoing'.:: %%en.'did .the 25 re3.ationship end. Litigation Services 800-330-1112 www.litigationservices.corn ~ ~ The LIT Group 079F MAYA CASTRO — 06/01/2023 Page 114 Axed SQ youx'8stimony is that you believe that i' "2 . x'elevaxlt to yQux" 1a'wsuk.t:for 'wx'Qngful.'texminat'3.QnV 5 relationship that would have effected decisions that were '6 made 7 Q. I'm going to hand you a -- I identified it as 8 page 4 -- this is from Exhibit A-1 that you had provided 9 to -- in response to my discovery request. 10 Can you take a look at that and can you read it for 11 us'P 12 Nell, fixst of all, why don't you just tell me what 13 it is af ter you have looked a't itP 14 A. So I would 1dent3.fy thl.s as a prd.vate 15 conversation between my dad and I. Which I personally 16 don't believe is relevant to anything. 17 Q. Okay. 18 So 19 A. Kindly provided it. 20 Q. I'm sorry'. 21 I kindly provided it. Q. You kindly provided it in response to my Request 23 f ox'roductions ~ this morning's A. Yes. Q. Okay. Litigation Services ~ 800-330-1112 www.litigationservices.corn ~ The LIT Group 079F Exhibit C MAYA CASTRO — 06/01/2023 Page 115 A. .Octet)er..-- Monday, Octobex'.3. Qkay- And is that a text l5888age exchange'8 584wean you and 5 Luis Caitxo, yeux dadV. A Yes'. Okay. . Can .you Read it out loud f ox'h% 'x'ecox'd7. 9 .A. D-A, double D, you need. to-be upgxaded to tbe 10 notoxious D-A, double D. Your strategy was spot on. 11 Those motbex -- blanked out '-- clearly bad something to 12 tbel.x'3: bide. Tbat. was geQiu8 a8king tbem qQestiQns about -..+elat3.oQ8h'3p .bi8tox'y. 18 tbe-- NR PIESNER- It'8 a "yes" ox "no" question THE NITNESS: No. %%at was .that iQ x'8I8Pon88 t07 A. I don t x'ecall. g. %hat is the &ox'd aha't'8 Maoked ou'tP Litigation Services ~ 800-330-1112 www.litigationservices.corn ~ The LIT Group 079F MAYA CASTRO — 06/01/2023 Page 118 3.' 3.n itg but you.x'e not ah3.e to reca3.3. what that wox'd, was' A ..It cOU3;d ..be you know., f Uckex'8,. Could 'be ~ tx'Uckex'8 . MR. PIESNER: (Indicating) . THE WITNESS': Qh nice. .It was .fuckex's. NR. PIHSNER: I'm soxx'y. I can xead it on the MS. AQUI: Right. Q. 10 So the text that you sent to your dad said, those 11 mother fuckex s clearly had something to hide. Is that corr ec't7 A. Coxrect. Q. And who who axe you refexring toP 15 A. More than likely, Boyd and Tija, and 16 potentially, you. I don't know. 18 Q. Okay. 19 then you say, that was genius asking them And 20 questions about their relationship history. So what questions were you asking about their 22 relationship history'P 23 A. I mean, 'tha,t could have been x'e f e1 1 ing to a 24 d1af t of a copy. 25 That could be referring to this (indicating). Litigation Services 800-330-1112 www.litigationservices.corn ~ ~ The LIT Group 079F MAYA CASTRO — 06/01/2023 Page 235 1 STATE OF CALIFORNIA ) ss I, Stephanie Hill-Larson, CSR 11774, do hereby That, prior to being examined, the witness named in 7 the foregoing deposition was by me duly sworn pursuant to 8 Section 2093(b) and 2094 of the Code of Civil Procedure; 10 That said deposition was taken down by me in 11 shorthand at the time and place therein named and 12 thereafter reduced to text under my direction. I further declare that I have no interest in tbe 15 event of the action. 16 I declare under penalty of perjury under tbe laws of 18 tbe State of California that the foregoing is true and 19 correct. 20 WITNESS my band this 5th day of June, 2023. Stepbanie Hill-Larson., CSR 11774 Litigation Services 800-330-1112 www.litigationservices.corn ~ ~ Tbe LIT Group 079F 1 PROOF OF SERVICE 2 I am employed in the County of Sonoma, State of California. I am over the age of 18 years and not a party to the within action. My business address is 418 B Street, Fourth Floor, Santa Rosa, 3 CA 95401. On March 27, 2024, I served the attached DECLARATION OF DIANE AQUI IN SUPPORT OF DEFENDANT SPURGEON PAINTING, INC.’S MOTION IN LIMINE NO. 1 4 THROUGH NO. 4 on the parties to this action by serving: 5 Mr. Mark Piesner 6 Arc Point Law PC 22287 Mulholland Highway, #198 7 Calabasas, CA 91301 mark@arcpointlaw.com 8 Attorney for Maya Castro 9 /X/ BY EMAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the documents to be 10 sent to the persons at the e-mail addresses listed above. No electronic message or other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. 11 I declare under penalty of perjury under the laws of the State of California that the foregoing is true 12 and correct. 13 Dated: March 27, 2024 14 ____________________________________________ Stephanie D. Abbott 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2024-4-5 dec of da for mils -1- PROOF OF SERVICE