Charlotte Valentine

General Manager of COAC and WCAC, Inc. She was responsible for the hiring, supervision and training of all COAC personnel.

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, yet in deposition she denied any responsibility.


Highlights of the Verdict and Judgement

The Judgement against Charlotte Valentine included the

Question 5. Did the following defendants commit wilful misconduct?

Charlotte Valentine: 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?

Charlotte Valentine: YES.

Phase 2 ("Punitive Damages"):

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

Charlotte Valentine: $xxx

Testimony Excerpt - Charlotte Valentine 11/06/2008

Q.   -- question area.
When did you learn, if at all, that the State
of California required a license for the activity camp?

A.   I understand that we did not have to be
required to have a license.

Q.   Okay.  So it's your belief that you didn't need
a license?

A.   Correct.

Q.   First one, "Child care facilities licenses.
The investigation has determined that the facility, one,
provided child care when it operated an activity camp
during the summer."
Did you provide an activity camp during the

A.   Did Cathedral Oaks provide an activity camp?

Q.   Yes.

A.   Yes.

Q.   Next it says, "Did not have a license to
provide child care"; that's correct, right?

A.   Correct.

Q.   BY MR. CAPPELLO:  If your staff was poorly
trained and the child died because of that, whose
responsibility was it?

A.   I don't know.

Q.   Your department heads or yours?

A.   I don't know.  I can't answer that.

Q.   Well, you're certainly responsible for the
conduct of your department heads, aren't you?
THE WITNESS:  I said I couldn't answer that.

Q.    Whose responsibility was it to find out whether
or not you had the need for this license, yours or
Ms. Main's or both?

A.   Both of us, yes.

Q.   Did she think you were doing it and you thought
she was doing it?

A.   We didn't think we had to have a license.

Q.   But that certainly wasn't based on being told
by people that you didn't need a license, was it?

A.   Can you rephrase that?

Q.   Yeah.  You didn't -- your conclusion that we
didn't think we needed a license wasn't based upon the
fact that somebody told you --

A.   No.

Q.   -- you don't need a license, right?

A.   No.

Q.   It was just an incorrect assumption, wasn't it?
No.  Let me withdraw it.
It was just something you never thought about?

A.   Or knew about.

Q.   Or knew about?

A.   Yes.

Q.   Right?

Q.   And if somebody dies in the pool because of the
head of aquatics didn't do her job, isn't it as much
your responsibility as it is hers?

THE WITNESS:  I don't know how to answer that.

Q.   BY MR. CAPPELLO:  So you take no responsibility
in the death of Yoni Gottesman?

THE WITNESS:  Can I have you repeat it?

Q.   BY MR. CAPPELLO:  I'd be happy to repeat it.
Do you expect -- accept any responsibility at
all for the death of Yoni Gottesman?

THE WITNESS:  Me, personally?

Q.   BY MR. CAPPELLO:  You, personally.

A.   I've said no.

Q.   Now, as I understand it, you didn't discipline
Ms. Clark, correct?

A.   As I said earlier, yes.

Q.   And after reviewing the film, do you think
Ms. Clark should have been disciplined?

A.   I told you earlier, I didn't discipline her.

Q.   And I'm asking you, now that you've seen the
film carefully, do you think that she should have been

A.   No.

Q.   Now, I'm showing you her Heartsaver AED/CPR
certification, which is Exhibit No. 1, second page.
Does this refresh your recollection that at the
time of Yoni Gottesman's death, August 2005, she did not
have CPR certification --

THE WITNESS:  I can't answer.

Q.   BY MR. CAPPELLO:  Why can't you answer it?

A.   I don't know.

Q.   Did you get the certifications of Ms. Clark of
the lifeguards from the files of Cathedral Oaks Club?

A.   Yes.

Q.   BY MR. CAPPELLO:  Okay.  So did you recollect
that, in fact, child CPR was not a certification that
was reflected on them?

A.   I didn't recollect.

Q.   Now, looking at the document now, again, does
this refresh your recollection that, in fact, Ms. Clark
did not have child CPR certification in 2005?

THE WITNESS:  I can't answer that.

Q.   And you didn't do anything to verify that it
had been done; is that right?

A.   No.

Q.   No, meaning you hadn't done anything?

A.   No.

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