To Appeals Commission

 May 21, 2017

Request to reconstitute appeal panel

 

I request that the Appeal Commission reconstitute the appeal panel in accordance with policy.  My reasons were previously submitted and my previous request was denied (Rebuttal to Appeal Notice).  In light of the recent resignation of Dr. Peckham I make my request again.  I am not only asking for a continuance, although that would be necessary, I am asking the Appeal Commission to follow policy by constituting the appeal panel in compliance with policy. 

 Lattis wrote “The only “appeal” from a statement of charges that is provided for in chapter UWS 4 is the right to a hearing on the charges set forth in § UWS 4.04. The charging statement issued to Dr. Burton (administration’s Exhibit A) provided her with notice of her right to request a hearing on page 5.  But she did not address the other procedures available to Dr. Burton.  Chancellor Shields should have given Dr. Burton “a statement of the appeal procedures available to the faculty member.”  There are other appeal procedures available to Dr. Burton and the statement did not include them.

Conduct of the appeal hearing

I accept the submission of (Exhibit E) that was introduced to Dr. Peckham by Ms. Lattis on May 17, 2017 at 11:38 AM.   I submit this rebuttal (ResponsetoChancellorLtr-8-31-16) – Note: This dismissal came 20 months after the Throop complaint was filed and ten months after the investigation report was written.  I also submit this rebuttal to the associated investigation report, which was illegally withheld from me for over a year (Barraclough_Report-Rebuttal). 

 Two days is not nearly enough time to address the numerous false charges against me.  I will need much more time than two days to adequately address these issues.  I request assurance that the appeal panel will comply with policy by giving me as much time as I need to present my evidence and arguments for each and every charge against me.  This may take a few months as allowed by policy as shown here (Appeals Commission’s responsibilities).

 I request that the length of the hearings be limited to half-days due to my severe medical condition, which is exacerbated by stress.  I become very stressed at the thought of facing an appeal panel whose strings are being pulled by Attorney Lattis.   I request a week between hearings to allow me to recover from the stress of each hearing.  If the Appeal Commission reconstitutes the appeal panel to comply with policy, as I requested, I will probably be able to face the hearing without as much stress.  Facing a kangaroo court is more stressful than facing a fair court.

 

 

Attorney Lattis has referred to the appeal panel as the Appeals Commission and vice versa.  This is confusing and can lead to misunderstandings.  I understand the terms “Appeals Commission” (note: appeals is plural) “the Commission” to refer to the 9 member commission that “Hears any faculty member's appeal.”   It is my understanding that the terms “appeal panel” (note: appeal is singular) and “review panel” and “hearing panel” and “appeal hearing panel” refer to the 5 member panel elected from within the Appeals Commission to hear one specific appeal.   I request that the Appeals Commission and appeal panel take steps to ensure that proper terminology be applied in future communications.  Please correct anyone, on the record, who confuses issues unnecessarily by misuse of terminology. I am unfamiliar with some of the terminology and would appreciate correction if I misuse a term. I believe Attorney Lattis purposely misuses terminology and misinterprets policies and laws to confuse people so she can unfairly influence the process and outcome of my appeal.   I ask the Appeals Commission and the appeal panel to diligently verify every reference to and interpretation of laws, policies or procedures before accepting them as fact. 

I will soon submit a rebuttal to Dr. Peckham’s email of 5/15/17 at 11:53 AM, (Appeal-DenialofReqst-5-15-17).

  

Rebuttal to Lattis’ 5-19-17 response to Burton’s pre-hearing filings

 Re: Ms. Lattis’ response to my filing of 5-15-17 (Lattis-5-19-17-response-burton-filings):   My response to Ms. Lattis’ 5-19-17 response:

Dear Appeals Commission:

This letter serves as My response to the administration’s response to my briefs filed by my attorney Kara Amouyal on May 15, 2017. 

The brief entitled “Violations of UWS Chapter 4” explains some of the actions by the university that violated UWS chapter 4 in regards to my appeal, such as the Roter investigation, Chancellor Shields’ refusal to offer me an informal meeting, and the Chancellor’s failure to include appeal procedures with his formal statement of charges.  The brief entitled “First Amendment Issues” explains actions by the administration and its agents that violate my First Amendment rights.  The brief entitled “Violations of Policy and Procedures for Grievances” explain some of the policy and procedural violations that have been committed against me in three grievances.   I believe it is intuitively obvious to the most casual reader that I am seeking to expose these violations so the appeal panel will consider them as they deliberate.  It seems quite clear that these violations of my rights shout to the appeal panel that I do not deserve to be dismissed and that some other people do.    It is unbelievable that a career attorney is so easily confused as to the purpose of these briefs.   I believe Attorney Lattis pretends not to understand the importance of these violations to distract the appeal panel and misdirect their efforts away from her own violations of policy and law.  Meanwhile she attempts to misdirect the appeal panel to my actions which do not violate any law or policy.

 I do not expect the Appeals Commission to dismiss the charges as Ms. Lattis wrongly indicates.  The Appeals Commission is not even the entity that hears the appeal.  She was probably referring to the appeal panel.  The appeal panel can recommend dismissal of the charges against me.  They can also recommend that Attorney Lattis and Chancellor Shields’ violations of policy and law be investigated.   I did not ask the Appeals Commission or the appeal panel to exclude evidence.  Indeed, I want the appeal panel to examine all evidence completely.   My goal is to convince the appeal panel to deliver a recommendation that the charges against me be dropped.  In order to make an informed decision they must evaluate all of my rebuttals to the numerous false charges against me. This is well within the appeal panel’s authority.  Attorney Lattis is incorrect to limit the appeal panel’s ability to only recommendations about the charges against me.  The appeal panel can make whatever recommendations it sees appropriate.  The appeal panel can, and should, recommend that an in-depth investigation be conducted into the violations of policy and law that I describe in my rebuttals, briefs and other documentation on my website, including the formation of the appeal panel. 

 My attorney, Kara Amouyal, did not “withdraw” as Lattis falsely claims.  I take offense to this underhanded attempt to indicate that there is some friction between my attorney and me.   Attorney Amouyal informed Ms. Lattis that “Dr. Burton will represent herself at the hearing scheduled for May 25-26, 2017. Dr. Burton may also invoke her right to “an advisor…or other representatives, and to offer witnesses” pursuant to UWS Ch. 4.05(1)(d).”

I fear that this hearing will be just a kangaroo court if it continues without reconstitution of the appeal panel.  The appeal panel has already been formed in violation of numerous policies as I have pointed out previously (appeal_panel_Violations). Dr. Peckham has published that I have already been dismissed, which is not true.   I hope there are enough members of the appeal panel who care about truth, honor, integrity and justice to reconstitute the appeal panel fairly.   If the appeal panel has more corrupt people than honest people I will lose.  If it has more honest and courageous people then I will win.  It is that simple because the evidence so overwhelmingly leans in my favor.   The appeal panel, and the entire Appeals Commission needs to stand up and say “WE WILL FOLLOW POLICY AND PROCEDURES” or Attorney Lattis will continue to violate my rights and I will be fired unfairly.  If they can fire me this way they can fire anybody, including the members of the Appeals Commission.   The administration and Lattis are fighting against truth, policy, law, openness and integrity in their attempts to deny me a fair hearing.    If the administration had truth on its side it would be able to confidently follow the policies and laws.    I don’t believe spending big bucks on an attorney will change the outcome of the hearing and that is the main reason I plan to represent myself.   If I get a fair chance to address the issues I will be able to convince a fair and objective appeal panel that the charges must be dismissed.  If I am not allowed to address all the important issues in this case the truth will remain hidden, whether I am paying a high-priced attorney or not.

Attorney Lattis seems to be convinced the appeal panel will deliver an unfavorable recommendation against me, or that the Chancellor will ignore their recommendation to dismiss the charges.  She wrote “when the matter is placed before the Board for its decision.”  She makes this statement as though there are no options other than sending this matter to the Board of Regents but she lies again.  The appeal panel can and should recommend that I not be dismissed.  They can, and should, recommend that Attorney Lattis be investigated for serious violations.  They can and should start over, elect a new appeal panel in compliance with law and begin, and conduct the whole process fairly from beginning to end. I do not fear facing a fair appeal panel. 

 Further, Ms. Lattis is incorrect in her statements concerning the “Roter report.”  Her false statements seem to stem from her desire to mislead the appeal panel and cloud the issue.  Chancellor Shields appointed Dr. Roter to “serve as an investigator into the attached complaint…I am seeking your determination of the facts at issue in the complaint(Shields-appoints-Roter).   Ms. Lattis is wrong.  Dr. Roter was appointed as a fact finder and not to offer any opinions.   The point of the investigation was to determine the FACTS!   But that is not what is in the “Roter report.”  It is filled with fabrications, misquotes, and biased opinions.

At the audio recorded interveiw with me Dr. Roter said  1:57: I was charged by Chancellor Shields to conduct an investigation of the complaints submitted by Provost Throop and Dean Gormley.  They provided me with a packet of information as well. My role in this is basically to pull all this together.  It’s more of a finding of fact there are no judgments or recommendations that would be included in what I submit to the Chancellor.  It is just an opportunity to get some clarification and more importantly, in my mind, to have an opportunity to talk to the people involved and get their account and get some clarification.  2:56”  (A41-PetraRoter-Burton-interview-Pt2). 

There are other rules that address the content or scope of the investigation, contrary to Ms. Lattis’ false assertion.  UPS OPERATIONAL POLICY  - GEN 14 States: “Just Cause” means … the investigation was conducted fairly and objectively.  If the investigation was conducted unfairly or was not objective, then it cannot support a finding of dismissal for just cause.  The report is clearly biased, full of lies, misleading statements and misquotes.  The investigation was circumscribed to include only witnesses hostile to me.   There are also numerous case law examples that explain what is and is not a fair investigation, some of which are explained here (Circumscribing).

 I question the validity of the Roter Report. I believe that it was "edited by a third person" just like the Burke report was as explained in (Rebuttals-RiceComplaint). Investigator Burke admitted in December, in response to accusations of false statements in his report, that his report was indeed "edited by a third person." It is a forgery and the Roter report probably is too.  We will need Dr. Roter to confirm or deny this.   The Roter report was not signed.  The only evidence that the Roter report was written by Dr. Roter comes from Chancellor Shields and Attorney Lattis, two people who I have officially and publicly accused of severe corruption and unethical behavior.  They had motive and opportunity to forge the “Roter report.”   Dr. Roter refused to claim responsibility for the “Roter report.” The appeal panel needs to hear from Dr. Roter in person.  The burden of proof is on the administration to prove that the “Roter report” is the actual report that was written by Dr. Roter.  

Chancellor Shields already threatened me with termination in Aug. 2016 on false allegations, without any evidence, and subjected me to a witch-hunt investigation in October 2016. He didn't inform me of my rights then either.  He dropped both complaints as unfounded and this recent complaint is also unfounded.

I am not asking that the appeal panel exclude the investigation report.  I am asking that the appeal panel require that the administration prove it to be Dr. Roter’s actual report or admit that it is a forgery.  I believe it was edited by a third person after Dr. Roter submitted it, that third person is probably Ms. Lattis.  It is not up to me to prove the report’s validity but it is up to the administration to get Dr. Roter to prove that it is her own work.   If Dr. Roter admits to writing the terribly biased and factually flawed report the appeal panel should recommend that charges against me be dismissed because just cause does not exist and the appeal panel should also recommend that Dr. Roter be investigated for fraud.  If Dr. Roter refuses to acknowledge that the report is her own work the appeal panel should recommend an investigation into Chancellor Shields and Attorney Lattis as they both claimed it was Dr. Roter’s work.  This would indicate that one, or both, of them forged the document.  The appeal panel members are free to ask Dr. Roter directly if she takes responsibility for the flawed report.  Her email address is: proter@uwsa.edu.  She refused to respond when my attorney asked for validation.

Atty Lattis wrote “Burton has filed a baseless complaint against me with the Office of Lawyer Regulation (OLR).  That office is woefully behind in resolving complaints, but I have been informed that the investigator will, when he is able, send the complaint back to the OLR with a recommended finding that no rules of professional conduct have been violated.  I was also informed that Attorney Amouyal had spoken with the investigator, and he firmly told her that Burton could not use the fact of the complaint to gain any advantage in her disputes with UW-Platteville.  That is precisely what she is attempting to do here.   

The complaint I filed with the Office of Lawyer Regulations against Attorney Lattis is based on facts.  

I filed my complaint against Attorney Lattis with the OLR in late March 2016.  The initial communication was with a secretary in the office and I gave only a general outline of the issues over the phone in a phone conversation that lasted about , and Special Investigator Cade sent an email on June 3, 2017 dismissing the matter.  During that time I never once received any indication that the office was behind in resolving complaints.  However, the university failed to timely deliver my personnel records to the Attorney Cade and this contributed to the delay in processing.   Attorney Cade said that the university attributed this delay to the absence of the person who normally does that sort of thing.  But Janelle Crowley was present during the time the request for my records was open.  

How did Attorney Lattis know, on 5/19/17, that Attorney Cade would “send the complaint back to the OLR with a recommended finding that no rules of professional conduct have been violated” but attorney Cade asserted, on 6/3/17, that “I have not communicated my findings (until now) with anyone at the OLR or any other special investigator” unless ex-parte communications had taken place on or prior to 5/19/17.   Did Attorney Cade communicate to Attorney Lattis his intention to dismiss the matter or did Attorney Lattis lie to the hearing panel?    One of these attorneys lied in official written communication. 

 

How can Attorney Lattis know what I am attempting?  She is speculating and her speculation is incorrect.  What I am attempting to do is to get a fair hearing.  Attorney Lattis is not fair.  She is biased.  I am trying to get the hearing panel, or whomever has the authority, to disqualify Attorney Lattis from serving as the counsel to the university because of her bias against me, her willingness to violate ethical practices and her propensity to twist my statements, misrepresent facts and to lie.  I am not attempting to gain advantage; I am attempting to gain fairness.  

 

 

Lattis’ false claims about the status of the OLR investigation and statements made to Attorney Amouyal are irrelevant to this discussion.  The fact that there is a pending OLR investigation against her is relevant.   I was terribly uncomfortable being in the same room with Ms. Lattis, who has mercilessly harassed me at every opportunity ever since 2013.   The thought of being in the same room with her makes me physically ill.  She has conditioned me this way over the past several years by harassing me from the shadows.   I explained this to Chancellor Shields when I asked that she not be present at the “informal” meeting and he didn’t agree to reduce my stress by disallowing Lattis to attend.  There is no policy that allows Chancellor Shields to have a representative in the “informal” meeting.   UWS 4.01 states “the chancellor, or designee, shall … offer to discuss the matter informally with the faculty member.   It does not say “the chancellor and his attorney may gang up on and intimidate the faculty member in a stressful discussion.”  The word “informal” is defined as “having a relaxed, friendly, or unofficial style, manner, or nature.”

The appeal panel can make whatever recommendation it deems appropriate.  The appeal panel can recommend that Attorney Lattis be investigated for violations of policy and law, for example.  I have given ample evidence to show just cause that Attorney Lattis should be stripped of her license to practice law.  The appeal panel does not have the authority to disbar anyone but they can surely recommend an investigation into Attorney Lattis’ conduct in this matter, which could lead to her losing her license.  Contrary to Ms. Lattis’ statement, the appeal panel can and should recommend dismissal of all charges against me based on any violation of law or policy the university, or its agents, has committed.  For example; if the Chancellor violated any law, policy or established procedure, like offering to meet me informally or failure to timely provide me with appeal procedures, then he acted outside the authority vested in him by the Board of Regents (AppealRights-Highlights).   Attorney Lattis attempts to deceive by making the one-third-true statement that the appeal panel “cannot dismiss the complaint based on the alleged inadequacy of the informal meeting offering.”  While the appeal panel is not empowered to dismiss the charges they can recommend dismissal of the charges and they can do so based on the failure of Chancellor Shields to offer an informal meeting.    

Attorney Lattis’ arguments in her letter to Laura Anderson dated April 21, 2017 were as wrong then as they are now.  Wis. Admin. Code UWS § 4.02(2) provides that “[a]ny 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.  It does not say “an appeal procedure.”  It does not say “some of the appeal procedures.”   It says “the appeal procedures.”  Anyone who speaks English knows that “the appeal procedures” means “all of the appeal procedures.”  Ms. Lattis can read English so it is clear that she is purposely twisting the meaning of UWS § 4.02(2) to confuse the issue.  There is an obvious reason for this; most people who are being charged, including me, don’t know which procedures are available to them and they need to be informed about all of the procedures available in order to make informed decisions in the limited time they are given.   Without this information, a charged faculty member is at risk of not knowing when a corrupt Chancellor or his corrupt attorney have violated her rights by hand-picking the appeal panel. 

It is unclear what Lattis means by her statement “the only “appeal” from a statement of charges that is blab la bla  this just doesn’t make sense.  It seems she is trying to say that I should not have been given the procedures that Attorney Vaughan gave me in response to my request for the appeal procedures available to me.  Lattis seems to be confused about the difference between an “appeal” a “hearing” and a “procedure.”   It is beyond me how someone of her background can mix those up, unless she is trying to blow smoke and confuse the appeal panel, which appears to be her goal. 

I was provided with UWS 4 once previously.  That does not negate the requirement that “the appeal procedures available” be provided to me with the statement of charges.  It also does not satisfy the requirement to deliver all of the appeal procedures.   This is such an obvious attempt to keep me in the dark that any reasonable person can see it.   UWS 4 is not the entirety of appeals procedures available (AppealRights-Highlights).  

Ms. Lattis’ bloviation about traditional “appeal” and courts bla bla is nonsense.   It seems like she expects to win this argument by volume of words and not by quality of her points.   The policy is quite clear.  The Chancellor violated policy by not giving me the procedures and then Lattis violated policy further by refusing to give them to me when I asked specifically for them.   

Additionally, Lattis’ statement about creation of rights that do not exist seeks to answer a question that was never asked.  I never asked for rights to be created; I asked for established policies and procedures to be followed.   Ironically, the university is guilty of creating policy out of thin air and using it against me as explained here (SFDGHP).

By refusing to give me the procedures I asked for Attorney Lattis demonstrated a willful denial of my rights.  Lattis leaves off without discussing the obvious reason that the appeal procedures were withheld from me.  They were willfully withheld so I would not notice the violations committed against me.  The administration violated policy in many ways that I was able to see, after I read the procedures.  There are probably many violations I have not yet been able to prove. 

If, for example, Ms. Lattis has been communicating with the appeal panel without disclosing to me those communications she is probably violating policy.  I believe Ms. Lattis is communicating with the appeal panel through Dr. Anderson without disclosing to me those communications.  I believe she chose the appeal panel through Dr. Anderson and Anderson is acting as the “secret chair” of the appeal panel.   I believe Ms. Lattis is attempting to influence the appeal panel unfairly in this manner and I believe that violates at least one policy or law; it is certainly sneaky and underhanded.  The appeal panel should recommend an investigation into the communications between Ms. Lattis, Chancellor Shields and Dr. Anderson as they relate to the formation and conduct of the appeal panel.

First Amendment

Lattis is wrong again.   She twists my words and forms her arguments as though I admitted to things which I never did.  She demonstrates her lack of ethics by stating that I am guilty before I am given a chance to prove my innocence.  She should have said that I was alleged to do those things but instead stated, as though fact, (which it is not) that I had done them.  This seems like the sort of thing a desperate and evil person would do.  My husband published only information that had already been made public and was decidedly not confidential. I did not violate the laws cited in the charges against me as explained in my rebuttal (Rebuttal to Throop-Gormley Complaint).  I was always respectful of my colleagues though some of them were very disrespectful, harassing and intimidating to me and retaliated against me for coming to the aid of a student victim of sexual harassment.   Attorney Lattis has harassed me severely over the past several years and she continues to do so in this appeal process.  I believe she does so because I sought to address grievances in the proper manner and to cover-up her violations of law and policy.

Again, Attorney Lattis makes the assumption that this matter is destined to reach the Board of Regents, which has not yet been decided.    The appeal panel can make their own determination as to recommendations in this matter.   It does not need to follow Ms. Lattis’ or Chancellor Shields’ orders through Dr. Anderson.   Chancellor Shields can ignore any recommendation of the appeal panel.  Even if the panel recommends dismissal of charges against me the Chancellor can still recommend to the Board of Regents that I be dismissed.  The panel’s recommendation is the panel’s responsibility and should not be influenced by anyone outside the panel except through the established procedures controlling process of the appeal hearings.    Likewise the entire 9 member Appeals Commission has authority to start this process again by fairly electing a five member appeal panel as required by policy.

There is no reason for Dr. Laura Anderson to be involved in any way with this appeal process.  She should not be receiving communications regarding the hearings or procedures and should certainly not have selected the appeal panel or the appeal panel chair.  By including Dr. Anderson in the process each member of the Appeals Commission violated the procedures that were provided to me by Attorney Vaughan (appeal_panel_Violations).  This casts serious doubt over the legitimacy of this process, especially after I pointed out these violations and the Appeals Commission refused to correct their violations (Appeal-DenialofReqst-5-15-17).   This would lead any reasonable person to believe that the administration has influenced the appeal panel against me and that the appeal panel, which was hand-picked by Dr. Anderson in violation of policy, will continue to acquiesce to the instructions of the administration through Dr. Anderson.  The appeals hearing process needs to begin again.  It needs to be conducted in accordance with applicable and legitimate policies as directed by UWS 4 and other applicable statutes, policies and legitimately established procedures.   Dr. Anderson should not be copied on any more correspondence concerning my appeal proceedings.  She should not be involved at all.  The appeal panel needs to be reconstituted in compliance with policy.  I object strenuously to any further actions by the appeal panel as it exists today.  I request that the Appeals Commission begin the process of formation of the appeal panel again and that it be done in compliance with applicable and legitimate procedures.    

The First Amendment limits a public employer’s ability to leverage the employment relationship to restrict, incidentally or intentionally, the liberties employees enjoy in their capacities as private citizens. See Perry v. Sindermann, 408 U. S. 593, 597. So long as employees are speaking as citizens about matters of public concern, they must face only those speech restrictions that are necessary for their employers to operate efficiently and effectively. See, e.g., Connick, supra, at 147. Pp. 5–8.  The matters I spoke of were matters of public concern, I spoke as a citizen and the effect my speech had on the university was to expose corruption.  My speech created an environment where the corrupt activities that are creating inefficiencies and ineffectiveness can be addressed, reversed and corrected.   Preventing rapes will increase effectiveness of student learning.  Promoting quality professors instead of driving them away will increase efficiencies.  Using student tuition money to send students to conferences instead of spending tens of thousands of dollars on sham investigations to torment well intentioned quality faculty members will decrease waste and increase efficiency.  Firing our corrupt Chancellor and replacing him with a good leader will increase efficiency.   Prosecuting Attorneys who violate laws and target quality instructors will increase harmony in the university, allow the low morale to improve and improve efficiency.   My speech was for the betterment of the university.   Limiting my speech profits only the corrupt.

Exposing corruption does not “injure,” the university, it “heals” the university.

I audio recorded violations of policy and law and that is what I have exposed.

The First Amendment was written before tape recorders were invented so of course it is not mentioned specifically.  However, State statute allows a citizen to record conversations of which they are a party as explained in my rebuttal (Rebuttal to Throop-Gormley Complaint).    

Drug kingpins are also very shy of recording devices.

I was always courteous to my colleagues.  Lattis is wrong in her mischaracterization of my manner toward my colleagues and she presumes my guilt before I have had opportunity to address the false charges against me.    I treated my colleagues professionally in spite of the terrible retaliation I received at some of their hands.  The only way my colleagues could have been intimidated by me is if they were corrupt and I exposed their corruption.   I contend that disrupting corruption increases overall efficiency and effectiveness of the university and that intimidating a corrupt person by exposing their corrupt activities is not an offense of any policy or law.  In fact, it should be applauded and encouraged by decent people.

I did not involve students in my personal grievances as explained in my rebuttal (Rebuttal to Throop-Gormley Complaint).  I did not disrupt the workplace.  I believe I have disrupted the corruption ring that has a stranglehold on UW Platteville and have provided a needed community service in doing so.    Lattis’ comparison to religious speech regarding homosexuality is completely ridiculous.   I didn’t talk to students about any forbidden topic in my classes as I demonstrate in (Rebuttal to Chancellor Shields’ Statement of Charges). 

I request that the appeal panel allow me to finally address the baseless allegations in the Throop Letter of Direction so I can show that the document, on which complaints against me are based, is itself based on fabrications, accusations of non-violations, accusations of legally protected activity, half-truths and lies.  The fact that I was denied a chance to address this document when I filed a grievance to address them is an indication that it fails the “just cause” test.

I was due a hearing.  I was not given a hearing.  Policy was violated.  It is simple.  There is no legal question about whether I was denied due process.  That is clear and we don’t need to wait for a court to determine that.   If the appeal panel agrees with Ms. Lattis’ arguments, about the court and due process concerning the Throop LOD, it must determine that the letter of direction cannot be used as basis to dismiss me until after the court has decided on it.   So, if the panel agrees with Ms. Lattis’ argument it must recommend dismissal of the charges, or postponement of further hearings, until after the court has ruled on the matter.

Attorney Lattis seems to be working against herself.  She has given very good reason why the appeal panel must consider my rebuttals to the Throop Letter of direction: Wis. Admin. Code § UWS 4.05 and Wis. Stat. §§ 227.45 (1) to (4).

Attorney Lattis wrote “The letter of direction which forms a basis of the charges for dismissal is highly relevant. Neither it nor testimony about it may be excluded from the record in this case.”   I agree.  I must finally be allowed to present my rebuttal to the flawed, biased, false and ridiculous Throop LOD before a fair and empowered hearing panel.  The LOD is the basis of the charges against me as Lattis confirms.  After I am given opportunity to expose the LOD as invalid the other charges against me will fall like a house of cards in a strong wind (Throop Letter of Direction Rebuttal).

Sincerely,

 

Dr. Sabina Burton PhD