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Julie Main

Manager of both COAC, WCAC, Inc., and SBAC. She was responsible for
COAC's compliance with all applicable laws and regulations and
adherence to appropriate hiring, supervision and training practices for
all personnel. Main is also an officer and shareholder of JL Main, Inc.


Julie Main

Nearly four years after Yoni's death, on the day trial opened, she only
admitted she was negligent and the cause of Yoni Gottesman's death.

Highlights of the Verdict and Judgement

The Judgement against Julie Main included the following:

Question 5. Did the following defendants commit wilful misconduct?

Julie Main: YES.

Question 6. Did plaintiffs prove by clear and convincing evidence that
any of the following named defendants engaged in the conduct with
malice, oppression, or fraud?

Julie Main: YES.

Phase 2 ("Punitive Damages"):

Question 1. What amount of punitive damages, if any, do you award
plaintiffs against the following named defendants?

Julie Main: $xxx


Testimony Excerpt - Julie Main 11/24/2008

Q. In fact, it's my understanding Ms. Valentine
has never been disciplined for the death of
Mr. Gottesman; is that right?

A. Could you define "disciplined"?

Q. Sure. She's still the general manager. She
wasn't fired.

A. She was not fired.

Q. She didn't get suspended.

A. She did not get suspended.

Q. She didn't even get a verbal reprimand.

A. That is not true.

Q. Did she get a written reprimand?

A. No.

Q. She was given a bonus at the end of 2005.

A. All managers, general managers, of our clubs
and department heads are given bonuses based on
fiscal performance.

Q. So it doesn't matter how many people die in
the club that particular year. So long as the club
made money, the managers got a bonus. Is that what
you're saying?

Q. Go ahead and answer the question.

A. There's many criteria that go into making up
the bonus.

Q. All right. Is the criteria the fact that
there is a child that dies in the club and the club
may get sued for that and the club may have a huge
expense in defending itself because of that? Is that
taken into consideration?

THE WITNESS: Yes.

Q. Yes.
-- it's a certification. Are you familiar
with these little American Heart Association
certifications?

A. Yes, I am.

Q. And you would agree with me that where it is
blacked out or redacted, that is where it says
Infant/Child CPR and AED?

A. That's what I would assume.

Q. So if have a Heart Saver AED card and that's
blacked out, it would mean you are not certified for
infant and child. Wouldn't you agree?

A. That's -- I would agree with that.

Q. Did you not tell me at the beginning of this
deposition sometime that you were of the impression
or you believed that the rules were that your
lifeguards at Cathedral Oaks Athletic Club had to be
infant and child certified?

A. Yes.

Q. Now, looking at this, you can see that there
was a failure in that department, as well.

A That's correct.

Q. Do you consider yourself responsible at all
for this?

A. Yes, I do consider myself responsible
because of the drowning.

Q. Back in 2005, you ran other clubs. Did those
clubs have activity camps?

A. Yes.

Q. Did they have licenses?

A. No.

Q. After the event involving Yoni Gottesman,
did those Activity Camps get licenses?

A. Two of our other facilities ceased having a
license. Our facility up in Oakland, The Hills --

Q. You said ceased having a license?

A. I'm sorry. Ceased having a camp. Thank you
for the correction.

Q. If you were concerned about safety, ma'am,
why wouldn't you just go ahead and put those
procedures into effect rather than getting an
exemption?

A. Put what procedures into --

Q. The procedures that are required in order to
get licensing.

A. Oh, for childcare licensing. For childcare
licensing, a lot of the procedures that are required
entail huge facility changes that the clubs could not
meet.

Q. What about the Activity Camp? Instead of
getting an exemption, why didn't you just put in the
procedures?

A. Because it would take huge retrofit facility
changes to the clubs.



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Yoni Gottesman