Notice of Injury and Claim

Pursuant to Wis. Stat. Section 893.82

Claimant’s name: Dr. Sabina Burton

Address: 5768 Maple Glen Lane, Platteville, WI 53818

Phone: 608-331-0203

Time and date of Occurrence: Various, as shown in the Statement below

Location: University of Wisconsin, Platteville

I request an investigation into the following matters:

On 5/10/17 this notarized claim was sent certified mail to the AG using this form: https://www.doj.state.wi.us/sites/default/files/dls/injury-claim-form.pdf

This electronic version of the notice contains links to supporting evidence and is located online at: http://universitycorruption.com/uw/upaft-3-7-17-pub/Ltr-to-AG-5-10-17.htm

1. Major problems with managing my personnel file.

On December 31, 2016 8:46 AM I sent an email to Janelle Crowley detailing major problems with my personnel record. I questioned her ability to ethically maintain my records and pointed out major problems with the condition in which she maintained my personnel file. On Sat 12/31/2016 8:53 AM I forwarded the email to the Assistant AG Kilpatrick and asked for an investigation into the matter (PersFile-MajorProblems-12-31-16).

On January 11, 2017 I received a letter from Janelle Crowley (Crowley-persfile-1-11-17) in which she confirmed receipt of my 12/31/16 email but called it a “request to review” my personnel record. I asked for the matter to be investigated, not reviewed (PersFile-MajorProblems-12-31-16). I had already reviewed it and found it to be seriously lacking. HR director Crowley did not correct the mistakes. She did not say she had corrected the mistakes. She merely offered for me to see the record again. This damages me because the record will be reviewed in my upcoming dismissal proceedings. If the mistakes, errors and omissions are not corrected a clear picture will not be presented to the hearing panel or to the board of directors when they decide on my dismissal.

2. Complaint against me based on false charges threatens my employment

On January 4, 2017 1:05 PM - Chancellor Shields sent an email to me (SuspensionLtr-Shields-1-4-17-email). Attached to the email was his letter suspending me (Chancellor-Suspends-Burton-1-3-17). I was forced to collect my belongings from my office under police escort. My campus email account was cut off and the password on my office computer was changed. Chancellor Shields’ decision to suspend me was based on fabrications and was unwarranted and unfair (Rebuttal-Shields Suspension-1-4-17). The charges against me do not warrant dismissal.

On January 19, 2017 I received a letter from Chancellor Shields in which he wrote “Enclosed is my letter appointing Dr. Petra Roter, of the University of Wisconsin System Administration, to investigate the Wis. Admin Code ch. UWS 4 complaint filed against you by Provost Throop and Dean Gormley” (Chancellor-investigation-ltr-1-19-17). However, there was no appointment letter enclosed so I still don’t know exactly what his appointment letter appointed Roter to do. The appointment letter probably specifies what Dr. Roter is supposed to investigate. It seems Chancellor Shields doesn’t want me to know exactly what he wrote in the letter appointing Dr. Roter. I still do not have the appointment letter.

Biased, Fraudulent and Circumscribed investigation report

On Feb 9, 2017 – I met with Dr. Petra Roter for the investigation into the false charges against me. Dr. Roter recorded the meeting and I can provide the audio files on request.

On March 4, 2017 1:38 PM– Chancellor Shields sent me an email with a report attached. Chancellor Shields identified the report as “Dr. Petra Roter’s report” however, I have reason to believe the report was “altered by a third person” before Chancellor Shields delivered it to me. If the report was altered by a third person it seems someone committed fraud and/or forgery. The “Roter report” is very biased against me, contains factual inaccuracies, is unfairly circumscribed (only persons hostile to me were interviewed) and offers opinions which are outside the scope of a “fact finding” investigation. Chancellor Shields did not cc Dr. Roter in his email in which he delivered to me the “Roter report.” I believe it is likely that he kept her out of the loop because he changed the report and did not want her to know. Dr. Roter did not sign the report and refused to validate the report when asked.

Rebuttal to the biased “Roter report:” (Rebuttal-RoterReport3-4-17) (RoterInvestigationReport-3-4-17) (Shieldsofferstomeet-3-4-17) (EmailfmShields-3-4-17)

On March 19, 2017 Attorney Lattis wrote that the suspect “Roter report” was the “final version” however, Dr. Roter did not sign the report and its validity is still in question (Roterreport-Kara-asks-Lattis-responds-3-19-17). I believe the report was altered after Dr. Roter delivered it to the administration and before Chancellor Shields delivered it to me. Chancellor Shields and Attorney Lattis both had opportunity and motive to alter the report. I believe Chancellor Shields committed fraud and forgery by presenting the edited version as Dr. Roter’s as described in Wisconsin Statutes 943.38 and 943.39.

Chancellor Shields violated UWS 4 (offer to meet)

Chancellor Shields is required by UWS 4 to offer to meet with me informally however, he refused to meet with me unless an attorney who is hostile to me was in the room. I offered to meet with any other attorney in the room but requested that attorney Lattis not be in the room. The Chancellor denied my request for a meeting in which I could be comfortable. He failed to offer an informal meeting but offered one which was sure to worsen my already serious ulcer condition. (RoterInvestigationReport-3-4-17) (Shieldsofferstomeet-3-4-17) (EmailfmShields-3-4-17)

Chancellor Shields violated UWS 4 (appeal procedures)

Fri 3/31/2017 5:07 AM - Chancellor Shields sent the Statement of Charges for dismissal to me (sburtonChargesforDismissal-3-3017-email ), (sburtonstatementofcharges3-30-17). The charges are fabrications and the acts described do not amount to any offense that would warrant dismissal. Note: 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” however, Chancellor Shields did not include appeal procedures with his statement of charges. I believe he purposely excluded the procedures to confuse me as to my options in appeal. Rebuttal: (sburtonstmtofchrgs-Rebuttal-3-30-17).

Attorney Jennifer Sloan Lattis became involved in the attempt to deceive me as to appeal procedures available to me (Anderson-4-21-17), (anderson_ltr_4-21-17).

On April 21, 2017 I finally received links to the appeal procedures that should have accompanied Chancellor Shields’ statement of charges. (AttyBrianVaughan-4-21-17), (AttyVaughan-sendsProcs-4-21-17),

(Wisconsin Administrative Code chapter UWS 4),

(Employee Handbook Article III, Section 6),

(UW-Platteville Faculty Handbook, chapter 6.3.12.3 section 7).

Shortly after I received these links the link to the Faculty Handbook was broken and I no longer had access to the procedures. I finally received the Faculty Bylaws on May 8, 2017 after asking for it again. It seems someone took the bylaws offline to keep me from reading it. (Ltr-to-Vaughan-5-5-17), (FacHandbook-Spr-2017-recfmVaughan-5-8-17).

3. Chancellor Shields wastes university funds on investigations into bogus charges:

Chancellor Shields used university funds to pay for an investigation into false allegations against me and dropped the charges without explanation: (BurkeInvest-invoice-3-8-17-email), (BurkeInvest-invoice-3-8-17). He soon after initiated his third investigation against me.

4. Chancellor Shields - responsible for fraudulent policy which was used to deny my due process rights.

On April 5, 2017 11:23 AM - Lisa A Merkes-Kress sent an email saying “Part III in the bylaws is the amendments only” (FacBylaws-4-5-17). Attached was (4.2 Faculty Bylaws as of January 2017.pdf), (A42-RogerrequestsFacultyBylaws-4-5-17). This indicates that Grievance Hearing Procedures, which were used to deny my due process rights, were produced on false authority. I believe the procedures were fraudulently produced to deny my right to grievance hearings. I had asked for verification of the authenticity of the procedures but my requests had been ignored until Merkes-Kress confirmed the non-existence of authority of the Grievance Hearing Procedures (SFDGHP).

Dr. Sabina Burton