The story of Attorney Jennifer Sloan Lattis – is she over-involved in Dr. Burton’s case? Public - Private

https://www.wicourts.gov/courts/offices/docs/olrscr20annotated.pdf

At the 9-19-17 appeal hearing Attorney Kasieta informed Lattis that he had not received the exhibits in the package Attorney Lattis sent to him (Hearing transcript of 9-19-17 pg105 ln 20-25). It looks shady when an attorney fails to provide requested documentation. Lattis wrote that it was a problem with her scanning. Hmmm.

Lattis seems to have overstepped her authority by attempting to influence the Appeal Hearing Panel to retain Dr. Demaree.

May 9, 2017 at 2:29 PM - Lattis wrote an email to Dr. Peckham saying “I have just finished the letter opposing disqualification which you indicated I could provide. It is attached. Please review and reconsider.” Attached was a letter opposing Dr. Burton’s request to disqualify Dr. Demaree from the Appeal Hearing Panel (Demaree-Disq-LattisLtr-5-9-17).

Lattis seems to have been trying to keep Dr. Demaree on the hearing panel after receiving this argument that he should be removed: (Demaree-Disqual-Rqst-5-8-17).

The arguments set forth by Lattis in her opposition seem to be an overreach because:

1. Dr. Peckham had not indicated that Lattis could provide a letter opposing disqualification.

2. Atty Lattis knew that Dr. Demaree had already been disqualified before she submitted her opposition argument.

3. Attorney Lattis’ opposition argument seems weak, confusing, hurried and non-applicable.

4. Faculty Handbook 2016: (also Faculty Handbook 2017) 6.3.12.3 Section 6 says:

a. that either party may offer testimony from any source;

b. that the appeal panel is not bound by statutory rules of evidence but may hear testimony having reasonable probative value;

5. Faculty Handbook 2016: 6.3.12.3 Section 7 says: “Procedure for Evidentiary Hearing and Deliberative Meeting - The chairperson of the appeal panel convenes the hearing and serves as presiding officer. The chairperson assumes all the normal responsibilities of a committee chairperson and rules on such questions as may arise on the procedure of the hearing, admissibility of evidence, and all other matters related to the hearing.”

Attorney Lattis seems too personally involved in the issues of the appeal so I think she should be removed from any involvement in the proceedings.

Lattis seems to have advised Chancellor Shields that he does not need to follow Policies established by the Board of Regents

At an audio recorded Dec 2, 2013 grievance hearing someone, probably a grievance committee member, said: “I do want to point out though that article Wisconsin 36.09 does begin with the statement that all of the decisions are ultimately the decision of the chancellor and the chancellor’s advisory, so basically the Provost and the Dean. So, Bottom line is that faculty governance is not a legal contract. That, in the end they can do whatever they choose to do. And that is the case. So it seems to me that arguing that these laws, which are not really laws, were broken is not real useful to us at this point. I think what’s more useful to us is to just look at: Was procedure violated, was there clarity in why procedure might have been violated, or, I shouldn’t say violated,. was procedure followed and if there wasn’t a following of that procedure was there clarity provided in why that procedure was not followed? And then from there it’s up to whoever, to either go to the courts of law to make those decisions or to settle for what has been passed down. I think that’s where we are.” Attorney Lattis was in the room and did not correct the statement. This seems to indicate that she agreed with the statement. Note: I’m not positive who said this. It might even have been Attorney Lattis, although it doesn’t sound like her. It sounds most like Mary Rose William’s voice to me, but I’m not positive about that. I’m positive it wasn’t me, Sabina or her attorney.

A13 - Grievance - Throop - 12-2-13, Grievance-Throop-Transcript

However 36.09 actually begins with “(1) The Board of Regents: (a) The primary responsibility for governance of the system shall be vested in the board which shall enact policies and promulgate rules for governing the system, plan for the future needs of the state for university education, ensure the diversity of quality undergraduate programs while preserving the strength of the state's graduate training and research centers and promote the widest degree of institutional autonomy within the controlling limits of system-wide policies and priorities established by the board.”

Wisconsin 36.09(1)(f) states “The board shall delegate to each chancellor the necessary authority for the administration and operation of the institution within the policies and guidelines established by the board. The board may also delegate or rescind other authority to chancellors, committees of the board, administrative officers, members of the faculty and students or such other groups as it deems appropriate.”

Attorney Lattis seems to have allowed the grievance hearing committee to wrongly believe that Chancellor Shields can chose to fail to follow policies established by the Board of Regents. However, the state statute referenced seems to say the exact opposite.

WI 36.01(2) states “Basic to every purpose of the system is the search for truth.” I believe Chancellor Shields acted outside this priority by misrepresenting facts in his statement of charges (sburtonstmtofchrgs-Rebuttal-3-30-17). I believe he acted outside this policy by delivering an uncorroborated hearsay investigation report that seems to be a forgery and whose alleged author was not available for comment or testimony supporting its contents. There seems to be a lot of cover up and very little “search for truth.”

UWS 4.02(2) says ”Any formal statement of specific charges for dismissal sent to a faculty member shall be accompanied by a statement of the appeal procedures available to the faculty member.” I believe Chancellor Shields acted outside the policy established by the board and Attorney Lattis covered for him (anderson_ltr_4-21-17). I believe she did this to keep Dr. Burton in the dark as to her options for appeal. It seems the reason for withholding the policies is that Lattis didn’t want Dr. Burton to notice the numerous procedural violations in forming the committee and process of the appeal hearings.

Since, I believe, Chancellor Shields acted outside the established guidelines or policies established by the board he acted, I believe, outside the authority delegated to him by the board and therefore he acted without necessary authority. If, as I believe, Chancellor Shields acted without the necessary authority the Board of Regents should, I believe, invalidate his statement of charges against Dr. Burton. The Board of Regents could also send the matter back to the university level with instructions to start the process again but this time following the letter and intent of all policies, rules, guidelines and laws that apply to the process.

It seems Attorney Lattis advised Chancellor Shields to act outside of the policies, guidelines and/or priorities established by the board. It seems likely that Lattis was instrumental in the manner in which the appeal panel was formed. It seems likely that Lattis orchestrated these violations in order to create a kangaroo court where Dr. Burton’s arguments would remain unspoken and hidden. It seems likely that Lattis timed the hearings to be during the summer so Dr. Burton would have difficulty getting people to show up for the hearings. It seems to be a breach of contract to require Dr. Burton to attend these hearings during her non-contract summer vacation rather than holding the hearings during her contracted 9 months.

Dr. Burton filed a complaint against Atty Lattis:

Dr. Burton filed a complaint with the Office of Lawyer Regulation in April 2016. She explained her grievance in a letter to the investigator in this letter (OLR-Complaint-Lattis-4-19-16), (ClaimagainstLattis-4-19-16).

Tue 4/19/2016 8:42 AM - Burton sent an email to Nate Cade (NateCade-OLR-4-19-16). Attached were (Letter-to-NateCade-4-19-16), (Dkt 103 - Brf in Spt of Motion to Recons and alter Judgment). She asked him to investigate her allegations of corruption at UWP.

4/19/2016 - Nathaniel Cade, Jr. of Cade Law LLC sent a letter to the UWP Office of Human Resources asking for a complete copy of Sabina’s personnel file. (exhibit Cade-RequestsPersFile) His contact info: nate@cade-law.com, 414-255-3802/T, 414-255-3804/F, 414-405-7801/M. Website: cade-law.com, P.o. Box 170887, Milwaukee, Wi 53217.

April 19, 2016 at 10:42 AM – Dr. Burton sent an email to Special Agent Cade. Subj “Re: Grievance against Sloan Lattis, OLR Inquiry No. 2016Ma00469” (EmailfromCade4.19.16).

4/19/2016 12:05 PM – Special Agent Cade wrote back saying that he was only looking at the facts to determine if a basis exists to proceed (EmailfromCade4.19.16).

Tue 4/19/2016 5:31 PM – Dr. Burton wrote an email to Ed Lawson of the FBI asking him to investigate her allegations of corruption at UWP (EdLawson-FBI-requestforInvestigation-4-19-16). Attached was (Dkt 103 - Brf in Spt of Motion to Recons and alter Judgment).

Tue 4/19/2016 7:59 PM- Dr. Burton sent more info to Nate Cade (NateCade-moreinfo-4-19-16). She wrote “I fear this report will lead to more retaliation… I am not certain that you will get much usable documentation from UW-P. The university is good about misplacing or losing things. Several pages were removed from my DRB folder and of course the department and college does not make copies of evaluation forms. against me. I have been subjected to adverse employment actions for almost 3 years.” She attached several documents (Lattis-OLR), (exhibits-Lattis).

Tue 4/19/2016 8:06 PM - Dr. Burton sent more documents to Special Agent Cade (EmailtoCade4.19.16c). Attachments (Lattis-OLR), (exhibits-Lattis).

Tue 5/3/2016 11:51 AM (1:51 PM) – Dr. Burton sent an email to Special Agent Cade asking him to include the failure to give her due process in his investigation (EmailtoCade5.3.16).

5-3-16 10:43 PM - Dr. Burton sent an email to the Board of Regents which opened with “I am reporting to you that I believe that UW-Platteville is plagued with severe and wide spread systemic corruption.” (exhibit emailtoRegents-5-3-16) She sent this email to many members of the board of Regents and to members of AFT. She spelled out problems and asked for investigations. On 6-20-16 they declined to investigate.

6-20-16 – Dr. Burton filed with the OCR Department of Education: OCR-EEOC-filed-6-20-16. She also sent consent for the OCR to tell her employer about it (OCR-ConsentForm). Dr. Burton asked for a copy of the original complaint on 11/29/16. She received it soon after and here it is (OCR-Complaint-6-20-16).

Here is a Timeline of events concerning the OCR complaint (OCR-timeline).

6-20-16 – Board of Regents sent Dr. Burton an email response (exhibit RegentsResponse-6-20-16) with attached letter (exhibit Dr. Burton - 6-2016) - She did not drop the discrimination complaints because she didn’t think she could win it; She dropped them because retaliation was the main issue. Hawks advised her to drop them. The court found that the evidence on record supported summary judgment. I believe Sabina’s attorney misrepresented her case and that is why the case was dismissed on summary judgment.

7/15/2016 1:39 PM - Dr. Burton sent an email to mr. O’Donnell of OCR. She added to her complaint the discrimination she suffered by being removed from a grant application (OCR-addldisc-7-15-16).

Sat 7/16/2016 5:19 PM – Dr. Burton wrote to Special Agent Cade with more info (EmailtoCade7.16.16c).

Sat 7/16/2016 5:24 PM – Dr. Burton forwarded evidence of blackmail from another faculty member to Special Agent Cade saying “Please use the information below with discretion. I don't want (the person) to get hurt even more. This is blackmail!” (EmailtoCade7.16.16d).

July 20, 2016, 4:18:50 PM MDT - Special Agent Freymiller, DOJ, DCI responded to the email.

7-21-16 - The faculty member sent me an email about their contact with the DOJ about Throop’s blackmail.

Thu 7/21/2016 9:18 PM - Freymiller replied with some statutes:

August 18, 2016 4:47 PM – Dr. Burton sent an email to Michael O’Donnel saying she had not heard from the EEOC. She informed him that she had been contacted by an investigator. (OCR-Threats-fm-Employer)

August 19, 2016 7:22 AM – O’Donnell wrote back that he was looking into it. (OCR-Threats-fm-Employer)

Aug 22, 2016, at 2:12 PM - O’Donnel wrote again saying that my EEOC case # 443-2016-01415N was assigned to Melissa Lawent on Aug 8, 2016. (OCR-Threats-fm-Employer)

September 12, 2016 1:00 PM - Lattis is involved - Crowley forwarded Dr. Burton doctor’s note to Lattis and wrote “FYI…now what?”

September 12, 2016 1:05 PM - Lattis is involved - Lattis wrote back “I don’t think we can delay the investigation. Apparently the condition is not such that she cannot continue to perform her other duties and this is one of her duties. I think you should write to Sabina and tell her that. However, since we are going to wrap her complaint against Deb in with Deb’s complaint against her, it may also change the time line.” So, Attorney Lattis believes that submitting to an investigation while she is sick is part of Dr. Burton’s “duties.” That seems quite a stretch to me.

I think the timeline Lattis was referring to was the timeline to fire Dr. Burton with minimal damage to the schedule and at the same time to harass Dr. Burton while she was preparing the appeal brief.

Mon 9/12/2016 1:40 PM – Dr. Burton wrote an email to Special Agent Cade saying “If you're still investigating Lattis then please let me know asap. I have brand new evidence of her harassment” (EmailtoCade10.20.16). Cade did not respond.

9/12/2016 8:33 PM - I sent Sabina some suggestions for a response to Lattis . This list of questions and statements shows some of the problems with Lattis’ involvement but Dr. Burton didn’t feel it was appropriate to send this rather harsh response at the time. Dr. Burton felt it might be viewed as too “in your face” and didn’t think sending the email would resolve anything. Roger agreed, and Dr. Burton did not send this to Lattis. Perhaps a better forum for this response would be in a courtroom.

This email documents that we had hay in the field that day. Weather records will confirm that it rained hard that afternoon. Some of our hay was rained on because it took longer to get it picked up due to Sabina’s ulcer flare up. Dr. Burton wasn’t able to help pick up the hay.

Roger wrote: “Inflexible scheduling for no good reason is a form of harassment too.”

September 16, 2016 3:45 PM Crowley-investigate-without-you - Crowley wrote that the investigation would be conducted with or without Sabina’s participation. It seems they really just want to get Sabina fired and are not interested at all in finding the truth.

Sept 30, 2016 – Dr. Burton submitted a complaint to ERD (ERDcomplaint-9-30-16).

Thu 10/20/2016 7:11 PM - Dr. Burton wrote an email to Special Agent Cade saying “I have never heard back from you or OLR. Would you please update me on the stand of the investigation (EmailtoCade10.20.16)?”

Timeline of Jennifer Sloan Lattis:

Below is a timeline of events involving Jennifer Sloan Lattis. This was copied and pasted from the main timeline. Some of it is in Sabina Burton’s voice, though it was mostly written by Roger Burton. I have edited it to tell the story of Lattis but there are still stories of others mixed in to give context. Lattis’ involvement was as a puppet master so there always seems to be someone else involved too. I have highlighted the points that seem to be most important. – Roger Burton

June 27, 2013 Lattis wrote guidelines under which the grievance committee was ordered to re-discuss Sabina’s grievance against Dr. Caywood [UW-P 005749-52 – pg 20]. She eliminated all reference to sexual harassment, sexual discrimination, and retaliation. She did so after the grievance committee had already sent their findings to Chancellor Shields on April 19, 2013 (Dkt 101-21) in which they found that Caywood handled the sexual harassment complaint very poorly, showed favoritism to a male colleague over Sabina, and that Throop should repair Dr. Burton’s damaged reputation with AT&T.

In this letter Lattis basically derails the real issues of Sabina’s grievance and directs Drefcinski away from a fair finding calling her corrupt actions “framing” the issues. This is not part of the grievance process. Why did Lattis write this instruction to the Grievance committee? It seems she did so to cover up a sexual harassment incident and to teach Sabina a lesson. The lesson seems to be “don’t complain or we’ll give you something to complain about.”

Because of Lattis’ involvement the grievance committee delivered another “findings” three months after the grievance hearing, without ever talking to Sabina again. Policy does not authorize a senior system attorney to “frame” the grievance issues without consent or knowledge of the grievant. It seems Lattis overstepped her authority. This does not seem ethical. We did not see this letter from Lattis until discovery in the lawsuit a year or so later.

In July 2013 Shields wrote that Caywood and Burton are equally to blame for the problems. He didn’t further elaborate on the details of our wrongdoings (exhibit ZA-6). His response does not address any of Dr. Burton’s demands (Grievance claim of 7-7-13 section 6d). Dr. Burton’s rebuttal to these letters are in (ZA-9-Rmks-ChancellorFindings-7-26-13), (ZA-9a-Rmks-Chancellormemo-7-26-13).

Around Nov. 2013 Dr. Burton’s then attorney Mary Kennelly said that Lattis referred to Dr. Burton as labile, emotional, unbalanced or words to that meaning in a conversation they both had. Lattis had never met Dr. Burton. It makes sense because in a meeting on 11/20/13 Lohmann took notes which showed that Lattis called Sabina “labile” in a meeting that seemed to be for deciding who would be chair of CJ. The notes seem to indicate that Dr. Burton was not allowed a fair election where she was the only qualified candidate because Lattis considered her to be “emotionally labile.” This violated policy and state law.

11/20/13 meeting -Dkt 48-137 -stamped Dkt 48-137 (complete set) Dkt 53-36 (partial set). Lohmann’s notes also say “Tom: Incompetent Chair – 5 major incidents” and Aric Dutelle – accused of taking bribes on paper. Academic staff person batshit crazy. He wrote “Lorne Wilson (probably Gibson) – bad news” no majority, Mike remains interim chair – 2 years. [UW-P 004842] On another page someone wrote “Sabina (Jennifer Lattice) Professor CJ. Assoc. Prof earned tenure, emotionally labile.” . This looks like a meeting to select the next chair of the CJ department. It seems that they eliminated Dr. Burton as a potential chair candidate because Lattis considered Dr. Burton to be “emotionally labile.”[ UW-P 004844] someone else took notes on page [UW-P 004842] but did not mention Sabina. On page [UW-P 004841] someone wrote “Sabina (Jennifer Lattice, loq) Assoc. Prof. earned tenure. Emotionally Labile.” The word “labile” is defined by http://www.thefreedictionary.com/labile as “1. Open to change; readily changeable or unstable: labile chemical compounds; tissues with labile cell populations. 2. Fluctuating widely: labile hypertension; labile emotions. 3. Decomposing readily: the labile component of organic matter.” On page [UW-P 004845] Lohmann wrote that Dutelle took bribes. Another female (most likely a female faculty member who also reported sexual misconduct in the CJ department) was labeled as “batshit crazy” (Dkt 48-137 (complete set of notes)). The attendees also discussed a bribery allegation by a DoD contractor against Mr. Aric Dutelle without labeling him in any way or form. Someone referred to Tom (likely Tom Caywood) as “incompetent chair.”

It appears that the real reason Sabina was denied the chance to be elected chair of the CJ department was because Jennifer Sloan Lattis called her to be “emotionally labile” in a high level meeting where Sabina could not defend herself. Dr. Burton did not learn of this meeting until she received these notes in discovery in a federal lawsuit.

On Dec. 2, 2013 Lattis attended the grievance hearing against Dean Throop. At the meeting, with Lattis listening, Throop stated that Sabina was unqualified to be chair because she couldn’t handle Caywood’s retaliation “on a local level” (audio exhibit A13) , (audio exhibit ZZA - Grievance-Throop-Transcript) (see audio short clips-A13). By her inaction Lattis sanctioned Throop’s adverse employment actions against Sabina for having engaged in the grievance process and reached out to HR and the Dean for help in what she perceived to be retaliation for having reported a student sexual harassment complaint. Audio of the meeting shows that at least one member of the committee understood. The committee member said (talking to Throop): “I’m hearing a concern here that there is a pattern of behavior to which she (Burton) has been subjected, and as a result of having to deal with that pattern she is at least feeling, and there are indications that it might be the case, that she is being further punished as a result of that pattern of behavior against her. And so, … I can also understand her position of what you have really experienced with her is this pattern of behavior against her that she had nowhere else to go but to you. And so it seems that now she is being penalized because she had nowhere else to go and she went to you.” (see audio short clips-A13). Lattis heard this and allowed Throop to continue down this road.

In Aug. 2013 Throop with approval of Shields (and most likely with approval of Lattis) gave a female faculty member the ultimatum to resign ‘voluntarily’ within 3 hours or the administration would make sure she couldn’t collect unemployment benefits (EmailtoCade7.16.16d). The female faculty member, a single mother, resigned but put the episode in writing cc’d to Shields.

In July 2014 the UWP administration canceled mediation between Dalecki and Burton (exhibit 559). Mediator Assistant Chancellor Jen DeCoste said Sabina had the right to file a grievance against Dalecki. Sabina filed a grievance on Aug 27, 2014 (exhibits 558, 558a, 558b, 529, 536, 508, 529a, 533, 537) (updates: interactive exhibit i558a) (folder exhibit FE 4). A grievance hearing was promised but never scheduled. Sabina never received good reason or explanation for the delays and on Nov 4, 2014 she withdrew her request, knowing she would never gain resolution through the grievance process (Dkt 43-12 BENSKY EXHIBIT JJJJ – 006). Why would the administration so blatantly violate Sabina’s due process rights? Likely because Lattis assured them that she would make it all go away.

Discovery revealed that Dalecki had multiple communications with Lattis during early Oct 2014 (redacted emails) (Dkt 53-13), (YoustillTreatmeUnfairly), (Subpoena-Dalecki - October 3, 2014 8:52:41 AM). So, it seems that Lattis advised the department chair not to talk to Dr. Burton at all. That’s what Dalecki did. The interim chair stopped all communication with Dr. Burton, a fully tenured faculty member in the CJ department.

October 7, 2014 10:57:55 AM – a heavily redacted string of emails discussing Burton’s email to Rice. Rice sent it to Dalecki without comment. Dalecki forwarded it to Lohmann and Lattis, cc to Throop. Lattis responded with a redacted message. Then Throop replied with a redacted message. After Rice forwarded the email to Dalecki it took 22 minutes for three people to respond. (Subpoena-Throop) It looks like they were all primed just waiting for Burton to do something so they could all dog-pile on her. It didn’t seem to matter what she did, they just needed anything to jump on. This email from Burton to Rice, which was arguably a legally protected activity, found its way into Throop’s Oct 28 Letter of direction. Since there is no legitimate reason to discipline Dr. Burton for writing this email it seems that Lattis was involved in a materially adverse action against Dr. Burton; including this email in the Throop LOD. It appears that Lattis was instrumental in, and maybe even orchestrated, discipline against Dr. Burton based on a protected activity.

Oct 8, 2014 9:27 AM – Sabina told Dalecki that she thought they should talk in person about the conflict between them. , Dkt 53-13. Dkt 41-47. Dalecki forwarded Burton’s email to Throop, Lohmann and Lattis (Subpoena-Dalecki-10-3-14-852AM) Dalecki wrote that he had asked the dean and general counsel’s office (Probably Lattis) about talking to Sabina and so he refused to talk to her. So, Lattis may have violated an ethics code by advising Dalecki to ignore one of his senior faculty members. As Dr. Burton points out in her forwarded email to Roger, the fact that Dalecki took this matter to the Dean and general counsel indicates that Throop’s stated reason for excluding her from eligibility to be chair, that she couldn’t handle matters on a local level, was pretextual.

On Oct. 29, 2014, 9 days after Sabina filed a second EEOC claim (Dkt 54-2). Dean Throop sent a letter of direction based on false allegations, protected activities and fabricated accounts. Dkt 48-143, Rebuttal - (Dkt 42-78, Dkt 37-15 pg 30(exhibit I)) updated rebuttal (interactive exhibit i571). On the same day Throop issued the letter of direction she planned to later file a Ch. 6 complaint to get Sabina fired (RE_Letter-of-Direction).

Sabina filed a grievance hearing request in early Nov. 2014 against Throop to address the LOD Dkt 54-17. It was delayed for 11 months without reason Dkt 54-17. Throop stated that she didn’t want the hearing (Dkt 42-70), Rebuttal to Throop’s flawed logic: (exhibit 601) (exhibit 595d), updates:(interactive exhibit i595d). Burton was offered a grievance hearing during the busy time of working on the response to the Motion for Summary Judgment in Nov. 2014. Burton expected the hearing to be a kangaroo court so on advice of her counsel she withdrew the grievance hearing request (Dkt 43-12 BENSKY EXHIBIT JJJJ – 006).

On Dec. 16, 2014 Throop falsely accused Burton of canceling class and announced discipline Dkt 42-78, Dkt 37-15 (exhibit J). Dkt 43-3 BENSKY EXHIBIT AAAA – 002 Dkt 41-42. Burton proved that she indeed held class but instead of apologizing Throop filed a Complaint against her with the Chancellor on Jan. 5, 2015, ConflictingReports, Dkt 43-3 BENSKY EXHIBIT AAAA – 001, Dkt 42-78, Dkt 37-15 (exhibit J), Dkt 54-11 - Dkt 42-78, (exhibit 619b) Dkt 37-15. Dkt-53-56--9454 (exhibit 619a). Rebuttal to Throop’s complaint (never sent 619d) Sabina learned of the complaint on Jan 15, 2015. updated the rebuttal (i619d-RebuttalThroopcomplaint-1-5-15). (Short Story – Class Cancellation)

Sabina’s health deteriorated and her doctor ordered a sick leave from Jan. 22 to April 17, 2015. here is a picture of Sabina in the hospital on Aug 15, 2014.

During that time Throop communicated with Lattis (ConflictingReports). So, it is apparent that Lattis was involved in the false accusation against Dr. Burton about cancelling class and the bogus chapter 6 complaint against her that was later withdrawn.

January 26, 2015 1:11:14 PM - Throop assumes that being sick is reason to exclude Burton from even being on campus while she is recovering. She wrote “I assume she (Burton) is not to be on campus or to engage in any activity work-related, and that she’ll need clearance from her physician before we can allow her to return to campus.” Throop doesn’t want Burton even to be allowed to be on campus because she is sick. The reason for this is probably that she didn’t want Burton to be involved in the discussion to select the next chair. (Subpoena-Throop) Why would someone need a doctor’s note before they would be “allowed” to return to work after they recover from being sick? This seems quite odd. Throop seems to have been actively pushing Dr. Burton away from campus.

Sabina’s doctor wrote a letter requesting reasonable accommodations to allow for healing Dkt 41-59. Dkt 48-147. Lattis was involved in the communication and showed no flexibility (Throop-to-BurtonAttorneys), (April 15, 2015 4:25:10 PM-Subpoena-Dalecki). Lattis made a false statement regarding one of the requested accommodations. Lattis wrote “We are unable to provide a graduate assistant for Dr. Burton. The monies that you identified in your letter are for the exclusive use of the on-line Masters in Criminal Justice program (MSCJ) for which Dr. Cheryl Banachowski-Fuller is the director” (exhibit 678b), (exhibit 678a). However, money was available (Dkt 52 para 6). Lattis was instrumental in making Sabina’s return to work as difficult on her as possible. There was no good will.

Lattis was very involved in making Sabina’s return to work a stressful experience (April 20, 2015 11:28:45 AM, 11:33:12 AM, 4:20:15 PM Subpoena-Dalecki).

April 20, 2015 4:20:15 PM -Subpoena-Throop)

One of the requests were that the current graduate assistant Ron Jacobus would assist with some of Sabina’s class work or be there to back her up (something he did for multiple department members during his assistantship in the months prior). Ron Jacobus’ assignment was terminated despite there were efforts under way to rehire him for the next academic year and the money was already allotted for his position. Likely, he was let go BECAUSE he was a support for Dr. Burton and because he had “leaked” information to her. By letting him go they took away Dr. Burton’s relief valve for classes during her recovery and they eliminated a “mole” who had funneled information, and may again, to Dr. Burton. They, (the corrupt) seem to have perceived Dr. Burton as “the enemy.” Getting rid of the grad assistant made things double bad for Burton and that was double good for “the corrupt.” The inflexibility in accommodating Dr. Burton’s medical needs indicates that “the corrupt” desired that Dr. Burton’s ailments to worsen. It seems the corrupt wanted Dr. Burton to become completely incapacitated physically, or die. This is not ethical.

In June 2014 on a Sat. evening Lattis contacted Sabina’s then attorney Hawks complaining, in essence, that she was trying to defraud the university and claimed to be at work when she was on sick leave (exhibit 682), (exhibit 682e). She demanded that Sabina immediately addressed “her” error. Someone must have altered the online reports without Sabina’s knowledge or permission. It was unheard of at UWP that UW Legal would get involved in sick leave issues. Those have always been addressed by HR. After Sabina could produce evidence that her leave of absence reports were indeed correctly filed someone changed her HR account back to the original entry while she was logged on and while she was on the phone with Hawks. Sabina took screen shots (exhibit 682a), (exhibit 682b). Lattis then replied to Hawks with a ‘never mind.’ She only backed off because Sabina was able to provide proof. Hawks states in an email to Sabina: “Now we know who is part of the problem” (he was referring to Lattis) (exhibit 678). This seems to have been part of a harassment package that involved multiple harassers. This episode was unusual in that Lattis acted directly to harass Sabina rather than going through someone else. Maybe it is a sign of her desperation or a sign of her personal involvement. This act seems to indicate that Lattis was feeling threatened personally.

Somebody routinely deleted incriminating emails from Sabina’s school email account. She has no proof who, but she suspects it was Lattis. This went on for four years. Fortunately, Sabina saved her emails.

In Sept. 2015 Sabina noticed that someone changed her HR job title in her school account from Associate to Assistant Professor (Record-issues). According to HR Director Crowley in May 2016 only someone in a key position could access the account for such changes. Lattis occupies a key position. We suspect Lattis made this change.

Sabina wrote to Governor Walker on Aug. 22, 2015 asking for help in what she perceived to be systemic corruption at UWP Dkt 39-8. She wrote: “Please look into public corruption at UW system universities, especially UW-Platteville.” The governor’s office must have forwarded her note to UW-Legal because the defense tried to use it against her and intimidate her with it (Burton deposition pg335). The email was included as a “finding of fact” in the defense docket submission on 11/10/15 (Dkt 45-para227). Sabina’s attorney wanted to try to get her communication with Walker thrown out but she wanted it to stay in the lawsuit. She should be allowed this free speech.

On 3-28-16 Sabina sent an email to her attorney with a list of her Lattis concerns (Something I need to share - Sabina Burton to Tim Hawks 3.24.16). Attached was (My concerns (to Tim re Lattis.MSJ)).

In her conversation with Hawks Lattis on numerous occasions attacked Sabina’s character. The attacks were much more personal than one would expect from a legal counsel for the university. E.g., Lattis was involved in an email string that led Dean Throop to write “But if she (Dr. Burton) was too incapacitated to work for UW Platteville, I'm not sure how she was well enough to work for UW Milwaukee.” They knew Dr. Burton’s teaching for UW Madison was all online. They knew her doctor, in her note from April 2015, had no issue with her teaching online even encouraged that over in-class teaching TeachingOnlinethisSpring. It seems they were just trying to block Sabina’s ability to bring in income, and to harass her.

During fall 2015 Lattis attended the deposition of Stackman. The LOD allegation of “pressuring to housesit” and the LOD mentoring issue came up. Stackman clearly discredited Throop’s account in the LOD. Yet Lattis did not make any efforts to correct or pull the LOD. She knowingly and purposefully supported, by her silence, false allegations against Sabina!

Lattis also attended the deposition of HR Director John Lohmann and Deb Rice which also supported Sabina’s account over Throop’s and Dalecki’s. Lattis seems to be an accessory to the character assassination committed against Sabina, if not the principal.

Sabina filed an OLR complaint against Lattis, by telephone, in late March 2016. OLR contracts with Nate Cade because of a conflict of interest that does not allow for the complaint to be investigated in house.

4-19-16 – Sabina wrote a timeline about Lattis’ wrongdoings: (ClaimagainstLattis-4-19-16-neversent) She did not send this to the administration but used it in her email to Atty Cade.

Tue 4/19/2016 8:42 AM - Sabina sent an email to Nate Cade (NateCade-OLR-4-19-16). Attached were (Letter-to-NateCade-4-19-16), (Dkt 103 - Brf in Spt of Motion to Recons and alter Judgment). I asked him to investigate the corruption at UWP.

4/19/2016 - Nathaniel Cade, Jr. of Cade Law LLC sent a letter to the UWP Office of Human Resources asking for a complete copy of Dr. Burton’s personnel file. (exhibit Cade-RequestsPersFile) His contact info: nate@cade-law.com, 414-255-3802/T, 414-255-3804/F, 414-405-7801/M. Website: cade-law.com, P.o. Box 170887, Milwaukee, Wi 53217.

April 19, 2016 at 10:42 AM – Dr. Burton sent an email to Special Agent Cade. Subj “Re: Grievance against Sloan La+s, OLR Inquiry No. 2016Ma00469” (EmailfromCade4.19.16).

4/19/2016 12:05 PM – Special Agent Cade wrote back saying that he was only looking at the facts to determine if a basis exists to proceed (EmailfromCade4.19.16).

Tue 4/19/2016 5:31 PM – Dr. Burton wrote an email to Ed Lawson of the FBI asking him to investigate the corruption at UWP (EdLawson-FBI-requestforInvestigation-4-19-16). Attached was (Dkt 103 - Brf in Spt of Motion to Recons and alter Judgment).

Tue 4/19/2016 8:06 PM - Dr. Burton sent more documents to Special Agent Cade (EmailtoCade4.19.16c). Attachments (Lattis-OLR), (exhibits-Lattis).

4-26-16 - Dr. Burton asked for grievance hearing against Throop to have the LOD removed based on the new evidence in the depositions and ask for a grievance hearing against Rice to address the ongoing defamation (ReinstateGrievance-ThroopLOD-Rice-4-26-16). The hearings are denied (Fairchildrefusalletter), (GrvnceDenial-5-3-16), (GvnceCommviolatesitsownrule5-3-16), (Re_ Fw_ DeniedGvncHrg-5-9-16) (Shields-LOD-6-3-16-Attachments), (EmailtoFacSenate5-8-16), ((Re_ Fw_ DeniedGvncHrg-5-9-16)-Attached-(LtrfmFairchild)-(Fairchild refusal letter-5-3-16)), (amplifying information-(interactive exhibit i617)). Dr. Burton’s due process rights were violated. Atty Lattis was likely responsible for the denial of due process.

5-3-16 10:43 PM - Dr. Burton sent an email to the Board of Regents which opened with “I am reporting to you that I believe that UW-Platteville is plagued with severe and wide spread systemic corruption” (emailtoRegents-5-3-16).

Dalecki harassed and threatened Dr. Burton. Burton asks Crowley for help (A34-Mtg-Burton-Crowley-5-9-16) (A34-TranscriptMtg-Burton-Crowley-5-9-16). Crowley did not investigate as she promised.

Dr. Burton asked new HR Director and Title IX Coordinator Crowley for help. She said she could pull the LOD with a simple memo from me and also says that I should be able to get a grievance against Rice. She promises an investigation into Dalecki’s alleged behavior. Her tone changes after talking to Throop (and most likely Lattis). The LOD stands and no grievance hearings. No investigation into Dalecki, only bogus explanations (RE_FairchildRefusal-CrowleyRefusal-5-17-16)..

Dr. Burton asks Crowley to add her rebuttal to Throop’s LOD and her rebuttal to Throop’s 2015 Complaint to her personnel file. She agrees ((RebuttaltoComplaint-5-9-16)-Attached-(Rebuttal-UWS601Complaint)).

Dr. Burton was pulled of a federal grant application by CJ chair Strobl (DidNOTResign).

The Chancellor issues a LOD on June 6, 2016 threatening Dr. Burton with discipline if she would continue to make “false allegations.” Shields bases his LOD on the controversial Throop LOD from 2014 ((Shields-LOD-6-3-16)-attached-(Shields-LOD-6-3-16-Attachments)-rebuttal-(ShieldsLOD-Rebuttal)). Lattis probably helped Shields with the wording of his LOD.

OLR contracted investigator Nate Cade complains to me that UWP won’t release my personnel file to him as requested (CadeRequest-ignored).

I file a complaint with OCR. The complaint is forwarded to EEOC in August 2016 ((OCR-EEOC-filed-6-20-16), (OCR-ConsentForm), (OCR-Complaint-6-20-16), (OCR-timeline).

Shields issues a Complaint filed by Rice for hostile work-environment and other allegations against me and threatens me with termination (Complaint-Rice-8-8-16), (Rebuttal-Shields-Invest-8-16-16). He contracts with an investigator Dale Burke (paying close to $ 10,000.-) who he sends to my home. Rice made the complaint without providing a single piece of evidence (she never submits any evidence at any point in time). Shields demands that Dr. Burton defend herself against the allegations even though Ch. 4 clearly states that the burden of proof is on the Complainant (Rebuttal-(DebRice-Complaint808016)).

Chair Strobl gives Burton teaching schedule for spring 2017 that indicates that she will probably not be teaching in spring (easy to replace her with adjunct instructors).

Burton has to cancel the meeting with Burke due to health complications. Her doctor starts her on a new treatment and recommends a 1 month delay of the Burke meeting until the meds take effect.

Lattis advises Crowley against giving Burton the 1 month break stating that the investigative interview was part of her ‘normal job duties.’ This is a violation of ADA requirements for accommodation and she knows it. She also writes to Crowley that she is concerned about the “timeline”(Lattis is involved). What timeline was she referring to? Probably her schedule for getting Sabina suspended and fired. Lattis has done everything she can to make things harder for Sabina. I’m sure she wanted to rush the investigation to add pressure to Sabina to injure her health. The best scenario, in Lattis’ mind, seems to be for Sabina to die of “natural causes.”

Dr. Burton asked Crowley how she can file a complaint about Shields and Throop for harassment, intimidation, false allegations and perjury. Crowley refers her to UWS HR Director Brokenburr and to the Abuse, Waste, Fraud Hotline for Wisconsin (Crowley-refers-me-to-Hotline-8-24-16).

Dr. Burton wrote Brokeburr and filed the complaint against Shields and Throop (Brokenburr-referstoLegal-8-25-16). Brokenburr acknowledges receiving the reports and states that she is forwarding them to UW-Legal (that is Lattis). How can Sabina get fair treatment if the people she is complaining about are the people who handle the complaints?

Burton also filed a complaint with Brokenburr against Rice. Brokenburr sends the Rice complaint to Crowley (Brokenburr-referstoLegal-8-25-16).

Not expecting any help Burton filed a complaint against Throop and Shields with the Hotline. After not hearing back from either one of them she reached out to both. The Hotline informed her that they forwarded her complaints to UW-Legal (Lattis). Brokenburr writes that UWS HR will not entertain the complaints. Jane Radue with the UW Regents Office wrote Dr. Burton in May or June 2016 that they wouldn’t entertain her pleas for help because she lost her federal complaint in summary judgment (exhibit RegentsResponse-6-20-16) with attached letter (exhibit Dr. Burton - 6-2016). This seems terribly unfair. The court said flat out they didn’t look at Throop’s letter of direction for validity and the regents won’t look at it for validity because the court dismissed the case.

Shields gives disparate treatment to the complaint Dr. Burton filed against Rice despite the fact that she submitted evidence and Rice didn’t. Burke is ordered to investigate Dr. Burton’s claims against Rice and Rice’s complaints against me as a combined complaint. But Burton filed a grievance, not a complaint. There are different procedures for each. So, again, policy was violated.

Dr. Burton complained to HR Crowley, Shields and Burke that Shields entertains a new complaint while he hadn’t even ruled on Throop’s Jan. 5, 2015 complaint against Burton. Shields then issues quickly a decision in which he writes Throop’s complaint has merit without elaborating what merit. He chose not to act on it at that time (Chancellor-8-31-16-letter), Rebuttal: (ResponsetoChancellorLtr-8-31-16 ).

After Burke finishes his investigation Dr. Burton asked for his report and the Barraclaugh report (for the Throop 2015 complaint). Crowley and PR officer Erickson deny her request (InvestigationReport-request-for), -(Erickson.Denial11.30.16). This is a violation of law.

Burton emails the Assistant Attorney General to complain about UWP withholding the reports ((DenialofAccess-12-2-16)-attached-(Erickson.Denial11.30.16)),.

The next day Shields issues a dismissal letter of Rice’s complaint and Burton’s complaint against Rice and includes two separate reports (with different witnesses, accounts). (Rice v Burton Complaint Dismissal Packet and Burton Complaint v Rice Dismissal Packet), (Rebuttal-(DebRice-Complaint808016)).

Burton writes AAG again and complain that UWP is again in violation of law by not releasing the Barraclaugh report. She receives a report quickly. At first she believed it to be a report written by Barraclough but she has since come to believe that it is a forgery like the Burke report. Barraclough did not sign the report.

There are serious inaccuracies with the Burke, Barraclaugh and Roter reports. Burke admits that someone else (Lattis?) edited the report and excused the mistakes as editing issues. He wrote “My final draft was edited by a third person” (WhydidCrowleyLie) (WhydidCrowleyLie-2).

Three investigation reports into complaints against Sabina were submitted and none of them were signed (RoterInvestigationReport-3-4-17) (Rebuttal-RoterReport3-4-17); (Barraclough_Report), (Barraclough_Report-Rebuttal); (Rice v Burton Complaint Dismissal Packet), (Rebuttal-(DebRice-Complaint808016 ). All three of the reports are vague and terribly biased against Sabina. They all seem to be written in the same style even though, supposedly, three different people wrote them. We have an admission by investigator Burke, who Shields paid almost $10,000 for his investigation, that some unnamed “third person” edited his report before it was delivered to the university (BurkeInvest-invoice-3-8-17).

The university failed to give Sabina the Barraclough report for over a year and denied her request to see it, in violation of law.

The Burke report was also withheld from Sabina and the administration even used law that requires them to provide Sabina the report as reason to deny her request. They twisted and misinterpreted and violated the law.

Chancellor Shields delivered the Roter report to Sabina as though it was the actual report written by Dr. Roter. It is very likely a forgery presented as the legitimate report. It came from Chancellor Shields’ email account and was certified mailed to Sabina’s home address.

The Roter report also was devoid of signature. It too was vague and terribly biased against Sabina. Sabina’s attorney asked Dr. Roter if the copy Sabina was given was Dr. Roter’s actual final draft. Instead of answering the question Dr. Roter forwarded Sabina’s attorney’s email to Lattis. Lattis wrote to Sabina’s attorney that the copy she received was the “final draft.” This did not answer the question. Was it Dr. Roter’s final draft? So, it looks like someone (probably Lattis) altered, edited or completely re-wrote all three of the investigation reports against Sabina. It seems that Lattis completely re-wrote all three of the investigation reports. It is likely that she has done this sort of thing before. An investigation into Jennifer Sloan Lattis’ handling of prior employee issues should be conducted by a completely disinterested, and protected, third party. They will likely find some very interesting paperwork discrepancies. Atty Lattis should be removed from the appeal process.

Throop and Gormley file their Ch. 6 complaint against Sabina on Dec. 16, 2016 The complaint is based on Throop’s LOD. Complaint was issued by Chancellor on Jan. 3, 2017 (Chancellor-Suspends-Burton-1-3-17), (Chancellor-Suspends-Burton-1-3-17-Rebuttal.docx ), (Rebuttal-Throop-Gormley-complaint-12-16-16). It is likely Lattis timed this to increase stress at a time when Sabina was trying to complete her lawsuit documents.

Sabina asks for open records on her personnel file. Crowley gives her access on Dec. 22, 2016. She treats Sabina with hostility and rushes her. She grabs the file from Sabina at one point and hisses at her that she will make a copy of it. Sabina watched her copy the entire file. She carefully went over the file and noticed that important documents were missing (among others Throop’s 2014 LOD and both of Sabina’s rebuttals that Crowley said she added to the file) and items added that don’t belong in a personnel file. Sabina wrote a complaint to the AAG, cc’d to Crowley, Shields and others (PersFile-MajorProblems-12-31-16) – note from the header of this webpage that Lattis has an emphasis in public records law. These “mistakes” were not likely “mistakes” but planned omissions, inclusions, exclusions and inaccuracies. It is likely that Lattis was behind the messed up personnel file.

The Roter investigation report also contains inaccuracies, leaves out important details, misquotes Burton (despite the fact that the meeting was recorded on Feb. 8, 2017 (BurtonInterview-audiolink-2-23-16), (A41-PetraRoter-Burton-interview-2-9-17-Pt1) (A41-PetraRoter-Burton-interview-2-9-17-Pt2) (A41a-PetraRoter-Burton-interview-transcript).) and is slanted against Burton (RoterInvestigationReport-3-4-17) (EmailfmShields-3-4-17), (Rebuttal-RoterReport3-4-17).

On 3/16/17 Shields offers to meet with Burton “informally” (Shieldsofferstomeet-3-4-17). He states that Lattis will be present and that Sabina can bring Atty Amouyal. Burton asks that Lattis recuse herself due to the ongoing OLR investigation into her harassment against her but Shields and Lattis are firm in the demand that Lattis attend. Burton refuses to attend if Lattis was present, offering that a different attorney could be there. The Chancellor blamed Burton for refusing the “offer” and so there is no “informal” meeting. The meeting offered was anything but “informal.” It was intended to be “intimidating.”

Lattis and Shields demanded that Lattis be present, making the “informal” meeting very uncomfortable for Sabina. Not informal at all.

Lattis seems to be worried that she is about to be exposed.

Chancellor Shields filed formal charges against Sabina. Sabina asked for the hearing to be open.

Bio - Jennifer Sloan Lattis – By Roger Burton:

According to her bio Jennifer Sloan Lattis is Senior System Legal Counsel for UW System. She received both her undergraduate and law degrees from the University of Wisconsin-Madison. Jennifer served as an Assistant Attorney General for the Wisconsin Department of Justice from 1989 to 2010 where she specialized in civil litigation with an emphasis on employment law, constitutional defense, and public records. She has over twenty years of experience representing the University of Wisconsin and state government clients in a wide variety of cases. She has had ample opportunity to learn all the little tricks that work to extinguish vocal opponents of the corruption machine.

Sabina and I didn’t understand, when this whole thing started, who Jennifer Sloan Lattis was. We didn’t know that she is a seasoned veteran who plays hardball and doesn’t seem to believe that ethics codes apply to her. I would not be surprised at all to find out that she has been using Chancellor Shields and Interim Provost Throop as puppets to harass my wife and make her so miserable she would leave. Don’t get me wrong, Shields and Throop are corrupt, but they seem to take their orders from Lattis. If I had to rate them on a corruption scale I would probably rate them about even, but I believe Jennifer Sloan Lattis is capable of damaging society more than Chancellor Shields and Interim Provost Throop combined.

According to this article: (“WI DOJ Defends Judicial Code in Front of 7th Circuit Court of Appeals”) it appears Lattis has worked in the court of appeals. It is not surprising that throughout Sabina’s first case against the administration the university, under the expert advisement of Jennifer Sloan Lattis, steadily created confusion that ultimately derailed Sabina’s first lawsuit. I must say that Lattis seems to have a mastery of the vague and confusing. She knows how to write text that seems to say Sabina is bad but doesn’t quite say it in a way that one could claim was a violation of law or policy. She seems to have taught Throop how to claim that someone else said something they didn’t. I don’t think she realized that I am pretty good at understanding the English language. Maybe she thought she could blindside Sabina since English is her second language. Jennifer Sloan Lattis is a true professional in every sense of the word except the integrity/ethics sense. It is not surprising that Sabina lost summary judgment on case #1 when one considers that we were up against a real pro with seemingly no scruples. I believe Jennifer Sloan Lattis is a very smart person. I rate her up there with Lex Luthor.

I have learned that people expect you to do what they would do in your situation. Sabina and I expected the university to treat Sabina fairly. In like manner, Lattis probably expected Sabina to take the bribe and come to the dark side or to give up and leave. She probably expected Sabina to do what she would have done. Lattis didn’t seem to consider the third alternative that Sabina and I viewed as our only option; to stand firm against corruption. By standing firm Sabina and I have been able to collect information and documentation that is quite revealing. We could not believe how readily people violate policies and laws, how shallow the figurative graves are buried at UW Platteville, or how readily and openly the administration protects the perpetrators of crimes. I didn’t see that coming. To be honest, I expected someone, like the Regents, to come along and finally say, “hey you guys, stop retaliating against Sabina.” But that has not yet happened. Instead the retaliation has escalated. The perpetrators seem fearless of the potential consequences as though they know they are protected by a powerful entity.

Somehow Jennifer Sloan Lattis seemed to know that she could violate certain laws and we wouldn’t be able to do anything about it. Maybe she has connections that prevent her legal violations from being investigated? We were trying to play by the rules against a hidden foe who only showed herself to do damage and then disappeared, like a shadow. Lattis was hidden behind smaller players in the university like Dr. Dalecki and Chancellor Shields and Interim Provost Throop. But evidence of her involvement can be seen if one looks in the right places. It seems as though she was using them as a shield, or pawns in a game of chess.

Lattis’ name has come up so often it is hard not to believe that she is personally invested in silencing Sabina. It seems that she has tried to keep herself hunkered down behind other people who would take the heat for her. Chancellor Shields seems to have done this too. The corrupt seem to all try to keep the targeted employee spinning their wheels on the lowest level possible so their attempts for fair treatment are always aimed at someone low on the totem pole. If the targeted employee makes too big a stink the power players simply promote their pawn to a generous position away from the turmoil leaving the target with nobody to complain about on the local level (Dutelle, Caywood, Dalecki). This strategy seems to have worked wonderfully for many years at UW Platteville. But Dr. Sabina Burton is not a typical target. She has stayed in this fight long enough to bring some heat to the levels of government where corruption can do some real damage to society.

Attorney Jennifer Sloan Lattis needs to be removed from the appeal process if Sabina is to get a fair hearing.

Note: Some of the statements above come from a timeline that was written in the voice of Dr. Sabina Burton. For this reason the person speaking may be confusing. I will try to sort this out later.