As I announced earlier this month, the $10 million defamation suit against me by University of California, Santa Barbara archaeologist Danielle Kurin is moving into the critical discovery phase, where both sides of the litigation will begin to gather evidence relevant to proving its case. That means issuing subpoenas to produce documents, posing questions under oath, and, very importantly, live witnesses.
Normally, potential witnesses are subpoenaed to give depositions, in which they sit down with the attorneys and answer questions (under pandemic conditions, depositions are often done remotely rather than in person.) In a document called "disclosures," each side reveals to the other which witnesses and documents it is likely to seek. That has now been done.
A party to a lawsuit can oppose a subpoena, seeking to "quash" it in the legal sense, but that requires filing a motion to the court citing good reasons why a witness should not be obliged to testify. We do not expect any such efforts to block our witnesses to be successful. The parties have already agreed that both Kurin and I will be deposed.
Here then is our list:
Michael Balter: the Defendant.
Danielle Kurin: the Plaintiff.
Enmanuel Gomez Choque: Kurin's former husband.
Kevin Vaughn: Vaughn, currently at University of California, Riverside, was the academic dean for UCLA Extension at the time of Kurin's 2016 Title IX. In that capacity, he was involved in cancelling Kurin's field school in Peru that year, which was under the auspices of the Institute for Field Research (IFR.)
Ran Boytner: As the former executive director of IFR, Boytner was involved both in the 2016 events as well as the investigation of misconduct at Kurin's 2018 field school in Peru.
Willeke Wendrich: Wendrich, as director of the Cotsen Institute of Archaeology at UCLA and chair of the IFR board of governors, has knowledge both of the 2016 and 2018 events and related matters.
Fred Limp: Limp, a professor at the University of Arkansas and member of IFR's academic board, was a member of the committee that investigated the 2018 events at Kurin's field school.
Julie Stein: Stein, at the University of Washington, is, like Limp, a member of IFR's academic board and served on the 2018 investigative committee.
Richard Kurin: Kurin, a well-known scientist and official at the Smithsonian Institution, is Danielle Kurin's father. He has knowledge relating to a number of issues in the lawsuit.
Stuart Tyson Smith: Smith, a member of the UCSB anthropology department, was department chair during key events related to the lawsuit, including Kurin's Title IX and earlier episodes.
Amber VanDerwarker: VanDerwarker, a former chair of the UCSB anthropology department, is a former department chair and undergraduate advisor, has knowledge of issues related to Kurin's conduct in the department.
Casey Walsh: Walsh is the current chair of the UCSB anthropology department.
Charles Hale: Hale is UCSB's dean of social sciences and has considerable knowledge of Kurin's conduct and disciplinary proceedings.
Roger Nisbet: Nisbet is a former UCSB dean and has knowledge of issues related to this lawsuit.
Melvin Oliver: Oliver, currently president of Pitzer College in California, was UCSB's dean of social sciences at the time of Kurin's 2016 Title IX and has knowledge of issues related to this lawsuit.
David Marshall: Marshall is executive vice chancellor of UCSB and has considerable knowledge of issues related to this lawsuit, including Kurin' 2016 Title IX.
Henry T. Yang: Yang is Chancellor of UCSB and in that capacity has knowledge related to the issues in this lawsuit.
Ariana Alvarez: Alvarez is UCSB's Title IX officer and was directly involved in Kurin's 2016 Title IX proceedings.
Brian Quillen: Quillen, now at CalTech, was a Title IX analyst at UCSB and directly involved in Kurin's 2016 Title IX proceedings.
Cindy Doherty: Doherty is UCSB's director of academic personnel and had direct knowledge of Kurin's 2016 Title IX proceeding.
Leila Rupp: Rupp is interim dean of social sciences at UCSB and has information relevant to this lawsuit.
Lara Wilkinson: Wilkinson was a student at UCSB and was severely bullied by Kurin, causing her significant harm including dropping out of the university.
This is just a preliminary list, and it is quite possible that other witnesses will be added as the case goes on. Deposing these witnesses is expensive, especially paying for the obligatory court reporter who must be present. Each deposition could cost $1500 or more depending on its length. I hope readers will consider contributing to my GoFundMe, as little or as much as you can. Do it not just for me, but for freedom of the press and the right of survivors to tell their stories. Thank you.