Dallas-Ft. Worth Metro Golden Retriever Club Lawsuit

 

 

     

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              Plaintiff's Rebuttal to Affidavit of  Lynda Williams:

 


 

4.  Alan Meyer attempted to call Dr Kirk Esmond, Ellen Meyer was not given a chance to testify as to the charges against her.  Charge #1 specifically addresses liability against the Club.  Plaintiffs had already proven their timeline that they did not violate any Board directive as they did not speak with Linda Marquart after receiving either verbal or written information that the Board was ‘hesitant’ to reactivate Plaintiff’s contracted litter listing.  Plaintiff’s Exhibit 2, page 35:    Debbie:  okay, we already conceded that point…  Rita:  that’s why I went through the timeline…  Lynda:  okay, clarified  Debbie… Board’s conceded…  However, even after Board concedes Plaintiff’s timeline, and Ellen says to Alan “So that charge is now gone… so we don’t have to…”, Sherri Farmer heard Ellen and says “That’s to be debated” .  Plaintiff’s also brought Ann Horton as a but were not given the opportunity to bring Ann Horton in as once Board conceded on Plaintiff’s timeline, they were told they had 15 minutes and Ellen had not even had a chance to testify on her own behalf yet.  Ann Horton was a witness for charges 2, 3 & 4. 

 

7.  The hearing itself, Exhibit 2, in its entirety is prima facie evidence of total lack of due process, violations of Roberts Rules Of Order, Chapter XX, Discipline, lack of an impartial tribunal, and that this hearing was run in bad faith and with malice towards Plaintiffs with the predetermined decision of Plaintiff’s guilt and punishment before Plaintiffs walked into the hearing. 

 

 

 

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