Second Request for Information Dated 9/9/21 From Wendy Schneider to "The Board"

From: Wendy S <XXXXXXXXXXXXXXXXX>

Sent: Thursday, September 9, 2021 10:54 AM

To: 'awulbrecht@comcast.net' <awulbrecht@comcast.net>; 'tamrarabold@gmail.com' <tamrarabold@gmail.com>; 'starlainek9@msn.com' <starlainek9@msn.com>; 'turbodobes@yahoo.com' <turbodobes@yahoo.com>; 'pajant@aol.com' <pajant@aol.com>; 'winmardobermans@hotmail.com' <winmardobermans@hotmail.com>; 'glen@srsranch.com' <glen@srsranch.com>; 'darwindobes@gmail.com' <darwindobes@gmail.com>; 'msfoxfire@roguelink.us' <msfoxfire@roguelink.us>; 'cidendobe@yahoo.com' <cidendobe@yahoo.com>; 'dobejensen@gmail.com' <dobejensen@gmail.com>; 'touchstone0525@att.net' <touchstone0525@att.net>; 'mormons@bektel.com' <mormons@bektel.com>

Cc: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg

Subject: Second Request for Hearing Information

Ms. Lisa Burroff

Recording Secretary

Doberman Pinscher Club of America

On August 23, 2021 we sent you the letter (see below) which requested information necessary for us to prepare for our grievance hearing. Neither you, nor anyone else on the Board, has yet responded.

In the event that our request was not clear enough, we are once again requesting the following sent to us on DPCA letterhead:

1. The name of the individual who filed the grievance;

2. There four separate grievances. Was a filing fee of $500 paid for each? Provide a copy of the cancelled checks;

3. Was the Dispute Resolution Committee involved in this process, and if so, why were we not informed and included;

4. You have not provided the names those on the Hearing Committee;

5. The accusations are overly broad and vague, and do not specify the allegations against each of us. Provide that information; and

6. A list of witnesses, and all evidence to be submitted at the hearing for all the allegations.

We demand that you send to us the requested information to us individually three days prior to the hearing. Failure to do so will deprive us of due process. Further be advised that we have retained counsel so you might want to alert your insurance provider.

Other matters will also be considered depending upon the outcome of the hearing, and whether or not you comply with this request to provide specific allegations against each individual, including all information and documentation that will be used to support each such allegation.

Electronically signed,

Wendy Schneider

Jann Selleck

Angela Sparks

Margaret Lehmberg

From: Wendy S <XXXXXXXXX>

Sent: Monday, August 23, 2021 6:14 PM

To: 'awulbrecht@comcast.net' <awulbrecht@comcast.net>; 'tamrarabold@gmail.com' <tamrarabold@gmail.com>; 'starlainek9@msn.com' <starlainek9@msn.com>; 'turbodobes@yahoo.com' <turbodobes@yahoo.com>; 'pajant@aol.com' <pajant@aol.com>; 'winmardobermans@hotmail.com' <winmardobermans@hotmail.com>; 'glen@srsranch.com' <glen@srsranch.com>; 'darwindobes@gmail.com' <darwindobes@gmail.com>; 'msfoxfire@roguelink.us' <msfoxfire@roguelink.us>; 'cidendobe@yahoo.com' <cidendobe@yahoo.com>; 'dobejensen@gmail.com' <dobejensen@gmail.com>; 'touchstone0525@att.net' <touchstone0525@att.net>; 'mormons@bektel.com' <mormons@bektel.com>

Cc: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg

Subject: Your letter dated August 16, 2021

Ms. Lisa Burroff

Recording Secretary

Doberman Pinscher Club of America

Dear Ms. Burroff:

We are in receipt of your letter dated August 16, 2021 which appears to provide copies of a grievance. The correspondence is curious as it isn’t on any DPCA corporate letterhead.

Furthermore, other significant relevant information is lacking:

(1) Nowhere does it indicate who has filed the grievance;

(2) Was a complaint submitted to the Dispute Resolution committee first; and if it wasn’t, why wasn’t that part of the process employed for this complaint. If it did go to the Dispute Resolution Committee, why were we not included in that process;

(3) Was a $500 fee paid and if so, by whom. Please provide a copy of the cancelled check; and

(4) The allegations are difficult to follow as they do not specifically state which of alleged violations are ascribed to the individuals named and what the evidence is for the violations claimed. Would you please provide the aforementioned information not later than September 1, 2021 so that we may effectively prepare for the hearing.

Once this information is provided, we may have additional questions. Your prompt cooperation in this matter is appreciated.

Electronically signed,

Wendy Schneider

Angela Sparks

Jann Selleck

Margaret Lehmberg

Response to Request for Information by Ann Wulbrecht on 9/9/21

From: awulbrecht@comcast.net' <awulbrecht@comcast.net>

Sent: Thursday, September 9, 2021 2:35 PM

To: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg,

Cc: dpcaofficersbod@dpca.org <dpcaofficersbod@dpca.org>

Subject: Grievance Hearing Information

Wendy, Jann, Margaret and Angela:

This grievance is being handled in accordance with the DPCA Bylaws.

I will email each of you an outline of the hearing procedures on Saturday, September 11, 2021. It will include time limits for each portion of the hearing. We expect each hearing to last 30 to 40 minutes.

After the hearing is called to order and the charges and specifications are read, you will each be asked to answer guilty or not guilty to those charges and specifications.

Once those formal steps conclude, there are 3 sections to the hearing. In each section, the grievant presents first. Each party will have time to:

1) Make an opening statement

2a) Present the evidence for each specification (grievant)

2b) Present the defense for each specification (defendant)

3) Make a closing statement

As you plan for the hearing, opening and closing statements should be no more than 4 minutes and 6- 7 minutes to state your defense. Both parties will be accorded the same amount of time.

If you plan to have witnesses attend on your behalf, please provide their names and phone numbers and they will be added to the conference call when they are needed to provide information.

Also in accordance with the Bylaws, the Board has determined that neither party may have counsel present at the Grievance Hearing.

The answers to your specific questions are highlighted in yellow below within the email you sent to the Board today.

Ann Wulbrecht

DPCA President

On 09/09/2021 1:54 PM Wendy S <XXXXXXXXXX> wrote:

Ms. Lisa Burroff

Recording Secretary

Doberman Pinscher Club of America

On August 23, 2021 we sent you the letter (see below) which requested information necessary for us to prepare for our grievance hearing. Neither you, nor anyone else on the Board, has yet responded.

In the event that our request was not clear enough, we are once again requesting the following sent to us on DPCA letterhead:

1. The name of the individual who filed the grievance; Denise Rohweder

2. There four separate grievances. Was a filing fee of $500 paid for each? Provide a copy of the cancelled checks; The appropriate filing deposit was received and recorded by the Recording Secretary in accordance with the Bylaws.

3. Was the Dispute Resolution Committee involved in this process, and if so, why were we not informed and included; No the Dispute Resolution Committee was not involved. Once a formal grievance has been filed, the Dispute Resolution Committee is not involved.

4. You have not provided the names those on the Hearing Committee; In accordance with the Bylaws and AKC Policy, the DPCA Officers and Board of Directors will hear the grievance.

5. The accusations are overly broad and vague, and do not specify the allegations against each of us. Provide that information; All of the charges apply to each of you and Specifications 1, 2 and 6 apply to Wendy and Jann only. Specifications 3, 4, 5 and 7 apply to all of you. and

6. A list of witnesses, and all evidence to be submitted at the hearing for all the allegations. No witnesses will be appearing on behalf of the grievant. The evidence for the specifications has been taken from your written posts on Focus on the DPCA. That information is currently available to you on Focus on the DPCA, the Facebook group you belong to and Wendy and Jann serve as administrators of.

We demand that you send to us the requested information to us individually three days prior to the hearing. Failure to do so will deprive us of due process. Further be advised that we have retained counsel so you might want to alert your insurance provider.

Other matters will also be considered depending upon the outcome of the hearing, and whether or not you comply with this request to provide specific allegations against each individual, including all information and documentation that will be used to support each such allegation.

Electronically signed,

Wendy Schneider

Jann Selleck

Angela Sparks

Margaret Lehmberg

Request for Additional Clarification dated 9/10/21 From Wendy Schneider to "The Board"

Response from "The Board"
(through Ann Wulbrecht) dated 9/12/21

From: Wendy S <XXXXXXXXX>

Sent: Friday, September 10, 2021 12:20 PM

To: 'awulbrecht@comcast.net' <awulbrecht@comcast.net>; 'tamrarabold@gmail.com' <tamrarabold@gmail.com>; 'starlainek9@msn.com' <starlainek9@msn.com>; 'turbodobes@yahoo.com' <turbodobes@yahoo.com>; 'pajant@aol.com' <pajant@aol.com>; 'winmardobermans@hotmail.com' <winmardobermans@hotmail.com>; 'glen@srsranch.com' <glen@srsranch.com>; 'darwindobes@gmail.com' <darwindobes@gmail.com>; 'msfoxfire@roguelink.us' <msfoxfire@roguelink.us>; 'cidendobe@yahoo.com' <cidendobe@yahoo.com>; 'dobejensen@gmail.com' <dobejensen@gmail.com>; 'touchstone0525@att.net' <touchstone0525@att.net>; 'mormons@bektel.com' <mormons@bektel.com>

Cc: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg

Subject: RE: Grievance Hearing Information

Ms. Ann Wulbrecht

President

Doberman Pinscher Club of America

In response to your email dated September 9, 2021:

In the event that our request was not clear enough, we are once again requesting the following sent to us on DPCA letterhead:

The name of the individual who filed the grievance; Denise Rohweder

A quick Google search reveals that this is apparently Denise

Mormon, the DPCA Membership Secretary. Why wasn't this grievance filed under the

name she uses as a member, and most recently used to run for elected office?

There four separate grievances. Was a filing fee of $500 paid for each? Provide a copy of the cancelled checks; The appropriate filing

deposit was received and recorded by the Recording Secretary in accordance with the Bylaws.

You did not answer our question and the request for documentation. Please provide copies of a

cancelled check in the amount of $2000.00 or four separate cancelled

checks in the amount of $500 each since you are actually dealing with

four individuals.

Was the Dispute Resolution Committee involved in this process, and if so, why were we not informed and included; No the Dispute

Resolution Committee was not involved. Once a formal grievance has been filed, the Dispute Resolution Committee is not involved.

Was the DRC involved before a grievance was filed ?

The accusations are overly broad and vague, and do not specify the allegations against each of us. Provide that information; All of the charges apply to each of you and Specifications 1, 2 and 6 apply to Wendy and Jann only. Specifications 3, 4, 5 and 7 apply to all of you.

Again these a four separate grievances and per the Constitution

and ByLaws cannot be lumped together. From the DPCA's Constitution

and By Laws, ARTICLE VI: Discipline, SECTION 2 "Any member may prefer

charge against A (our emphasis) member for alleged misconduct ....".

"A member" is one individual; not four members lumped together and all

charged, word for word, with the exact same violations.

The evidence for the specifications has been taken from your written posts on Focus on the DPCA. That information is currently available

to you on Focus on the DPCA, the Facebook group you belong to.

There are approximately 240,000 comments, posts and reactions on the

Focus - less than 1% dealing with the DPCA. Promptly submit the

specific evidence of alleged infractions so that we may contact our

witnesses and provide to our attorney. As defendants, it is not our

responsibility to find the discussion or guess, only to be ambushed at the

hearing with minimal and insufficient time to respond if you can't provide

the particular posts and evidence.

Electronically signed,

Wendy Schneider

Jann Selleck

Angela Sparks

Margaret Lehmberg

From: ANN WULBRECHT <awulbrecht@comcast.net>

Sent: Thursday, September 9, 2021 4:35 PM

To: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg

Cc: dpcaofficersbod@dpca.org

Subject: Grievance Hearing Information

Wendy, Jann, Margaret and Angela:

This grievance is being handled in accordance with the DPCA Bylaws.

I will email each of you an outline of the hearing procedures on Saturday, September 11, 2021. It will include time limits for each portion of the hearing. We expect each hearing to last 30 to 40 minutes.

After the hearing is called to order and the charges and specifications are read, you will each be asked to answer guilty or not guilty to those charges and specifications.

Once those formal steps conclude, there are 3 sections to the hearing. In each section, the grievant presents first. Each party will have time to:

1) Make an opening statement

2a) Present the evidence for each specification (grievant)

2b) Present the defense for each specification (defendant)

3) Make a closing statement

As you plan for the hearing, opening and closing statements should be no more than 4 minutes and 6- 7 minutes to state your defense. Both parties will be accorded the same amount of time.

If you plan to have witnesses attend on your behalf, please provide their names and phone numbers and they will be added to the conference call when they are needed to provide information.

Also in accordance with the Bylaws, the Board has determined that neither party may have counsel present at the Grievance Hearing.

The answers to your specific questions are highlighted in yellow below within the email you sent to the Board today.

Ann Wulbrecht

DPCA President

Request for Additional Clarification Dated 9/12/21 from Wendy Schneider to "The Board

From: Wendy S <XXXXXXXXX>

Sent: Sunday, September 12, 2021 2:25 PM

To: 'awulbrecht@comcast.net' <awulbrecht@comcast.net>; 'tamrarabold@gmail.com' <tamrarabold@gmail.com>; 'starlainek9@msn.com' <starlainek9@msn.com>; 'turbodobes@yahoo.com' <turbodobes@yahoo.com>; 'pajant@aol.com' <pajant@aol.com>; 'winmardobermans@hotmail.com' <winmardobermans@hotmail.com>; 'glen@srsranch.com' <glen@srsranch.com>; 'darwindobes@gmail.com' <darwindobes@gmail.com>; 'msfoxfire@roguelink.us' <msfoxfire@roguelink.us>; 'cidendobe@yahoo.com' <cidendobe@yahoo.com>; 'dobejensen@gmail.com' <dobejensen@gmail.com>; 'touchstone0525@att.net' <touchstone0525@att.net>; 'mormons@bektel.com' <mormons@bektel.com>

Cc: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg

Subject: RE: Grievance Hearing Information

MEMORANDUM

To: Board of Directors

Doberman Pinscher Club of America

Do these Adobe pdf attachments constitute the extent of evidence you plan on using at the hearing?

Since each of these complaints overlap, the four of us will be witnesses for each other, and thus will appear together.

Wendy Schneider

Jann Selleck

Angela Sparks

Margaret Lehmberg

From: ANN WULBRECHT <awulbrecht@comcast.net>

Sent: Thursday, September 9, 2021 4:35 PM

To: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg

Cc: dpcaofficersbod@dpca.org

Subject: Grievance Hearing Information

Wendy, Jann, Margaret and Angela:

This grievance is being handled in accordance with the DPCA Bylaws.

I will email each of you an outline of the hearing procedures on Saturday, September 11, 2021. It will include time limits for each portion of the hearing. We expect each hearing to last 30 to 40 minutes.

After the hearing is called to order and the charges and specifications are read, you will each be asked to answer guilty or not guilty to those charges and specifications.

Once those formal steps conclude, there are 3 sections to the hearing. In each section, the grievant presents first. Each party will have time to:

1) Make an opening statement

2a) Present the evidence for each specification (grievant)

2b) Present the defense for each specification (defendant)

3) Make a closing statement

As you plan for the hearing, opening and closing statements should be no more than 4 minutes and 6- 7 minutes to state your defense. Both parties will be accorded the same amount of time.

If you plan to have witnesses attend on your behalf, please provide their names and phone numbers and they will be added to the conference call when they are needed to provide information.

Also in accordance with the Bylaws, the Board has determined that neither party may have counsel present at the Grievance Hearing.

The answers to your specific questions are highlighted in yellow below within the email you sent to the Board today.

Ann Wulbrecht

DPCA President

PDF Files Attached to Ann Wulbrecht's Response

Response from "The Board" (through Ann Wulbrecht) dated 9/12/21

From: ANN WULBRECHT <awulbrecht@comcast.net>

Sent: Sunday, September 12, 2021 4:25 PM

To: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg

Cc: dpcaofficersbod@dpca.org

Subject: RE: Grievance Hearing Information

Ms. Wendy Schneider, Ms. Jann Selleck, Ms. Angela Sparks, Ms. Margaret Lehmberg:

Yes, this is the extent of the evidence that has been turned in. When you refer to "you", I assume you are not referring to the Board, as the Board did not file the grievance, Denise Rohweder filed the grievance. I would like it to be clear that the Board simply entertained jurisdiction when presented with the grievance.

Please provide cell phone numbers for each of you so you can be added to the hearing conference call as witnesses when it is time for you to provide testimony. Wendy and Jann will be added when it is time for them to provide testimony at Angela and Margaret's hearing and conversely, Angela and Margaret will join the call when needed to testify in Jann and Wendy's hearing.

If you have any other questions, please let me know.

Ann Wulbrecht

DPCA President

From: Wendy S <XXXXXXXXX>

Sent: Sunday, September 12, 2021 2:25 PM

To: 'awulbrecht@comcast.net' <awulbrecht@comcast.net>; 'tamrarabold@gmail.com' <tamrarabold@gmail.com>; 'starlainek9@msn.com' <starlainek9@msn.com>; 'turbodobes@yahoo.com' <turbodobes@yahoo.com>; 'pajant@aol.com' <pajant@aol.com>; 'winmardobermans@hotmail.com' <winmardobermans@hotmail.com>; 'glen@srsranch.com' <glen@srsranch.com>; 'darwindobes@gmail.com' <darwindobes@gmail.com>; 'msfoxfire@roguelink.us' <msfoxfire@roguelink.us>; 'cidendobe@yahoo.com' <cidendobe@yahoo.com>; 'dobejensen@gmail.com' <dobejensen@gmail.com>; 'touchstone0525@att.net' <touchstone0525@att.net>; 'mormons@bektel.com' <mormons@bektel.com>

Cc: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg

Subject: RE: Grievance Hearing Information

MEMORANDUM

To: Board of Directors

Doberman Pinscher Club of America

Do these Adobe pdf attachments constitute the extent of evidence you plan on using at the hearing?

Since each of these complaints overlap, the four of us will be witnesses for each other, and thus will appear together.

Wendy Schneider

Jann Selleck

Angela Sparks

Margaret Lehmberg

Response from "The Board" (Through Ann Wulbrecht) dated 9/13/21

From: ANN WULBRECHT <awulbrecht@comcast.net>

Sent: Monday, September 13, 2021 8:23 PM

To: Wendy Schneider, Jann Selleck, Angela Sparks, Margaret Lehmberg

Cc: dpcaofficersbod@dpca.org

Subject: Reply to Your Request for a single hearing

Ms. Wendy Schneider, Ms. Angela Sparks, Ms. Margaret Lehmberg and Ms. Jann Selleck:

The Board agrees to your request to hold a single grievance hearing for all four of you. That grievance hearing is scheduled for tomorrow night, Tuesday, September 14, 2021 at 8:00 pm EDT, 7:00 pm CDT, 6:00 pm MDT and 5:00 pm PDT. While we are agreeing to your request for a single hearing, it does not mean that we agree that it needs to be held as a single hearing.

If any of you are unable to attend the hearing on September 14, 2021, the hearing will be rescheduled to Friday, September 17, 2021, at 8:00 pm EDT, 7:00 pm CDT, 6:00 pm MDT and 5:00 pm PDT. If any of you (Jann, Wendy, Angela or Margaret) are unable to attend the rescheduled hearing on September 17, 2021, the hearing will proceed with those who are able to attend.

You have replied that you will serve as each other's witnesses and you have not provided contact information for any additional witnesses by the requested cutoff of 9:00 pm EDT, Monday September 13, 2021. No other witnesses will be called on your behalf. As stated in my email of 9/11/2021, non DPCA members may not participate in Grievance Hearings unless appearing as a witness and when appearing as a witness may only be present when they are testifying.

If you have any written material to present as evidence, please provide it by noon PDT on September, 14, 2021.

Hearing Logistics

Hearing Date: Tuesday, September 14, 2021

Hearing Time: 8:00 pm EDT, 7:00 pm CDT, 6:00 pm MDT and 5:00 pm PDT

The conference call number is (720) 740-9849 Access Code 5189106

Hearing Agenda

Hearing called to order

Hearing Formalities/Guidelines

Charges and Specifications Read

The filer and the accused are each allocated the same amount of time to present in each portion of the hearing. Because you have chosen to have a single hearing, your time allocated is the same as that of the filer of charges. You do not have to use all of the time but you will never have less than the time listed. The filer of the charges goes first in each section.

Opening Statements 5 minutes each

Presentation of Evidence 20 minutes each

Closing Statements 7 minutes each

Ann Wulbrecht

President

Doberman Pinscher Club of America

---------- Original Message ----------

From: Wendy Schneider

To: awulbrecht@comcast.net, tamrarabold@gmail.com, starlainek9@msn.com, turbodobes@yahoo.com, pajant@aol.com, winmardobermans@hotmail.com, glen@srsranch.com, darwindobes@gmail.com, msfoxfire@roguelink.us, cidendobe@yahoo.com, dobejensen@gmail.com, touchstone0525@att.net, mormons@bektel.com

Cc: Jann Selleck, Angela Sparks, Margaret Lemburg

Date: 09/13/2021 10:01 AM

Subject: RE: Grievance Hearing Information

Ms. Wulbrecht:

After conferring with our attorney this morning, we have been advised as follows: This was filed as one grievance…not a four individual grievances as it should have been. Thus, we will appear together unless you can produce evidence of four cancelled checks in the amount of $500 each, or one check in the amount of $2,000.

Also, be advised that SE Texas (Houston) is under a hurricane watch for tomorrow. Should that occur, both Ms. Schneider and Ms. Lehmberg most likely be unavailable and you will have to reschedule.

Electronically signed,

Wendy Schneider

Margaret Lehmberg

Jann Selleck

Angela Sparks

Defense Against the Evidence Presented by "The Board"

This PDF was sent Tuesday, September 14, 2021, by Noon as the defense against the grievance evidence.

Grievance Hearing Results Dated 9/15/21

Notice that all of a sudden, this notification is on DPCA letterhead and is significantly more formal than any other correspondence.