“To be hopeful in bad times is not just foolishly romantic. It is based on the fact that human history is a history not only of cruelty, but also of compassion, sacrifice, courage, kindness. What we choose to emphasize in this complex history will determine our lives. If we see only the worst, it destroys our capacity to do something. If we remember those times and places—and there are so many—where people have behaved magnificently, this gives us the energy to act, and at least the possibility of sending this spinning top of a world in a different direction. And if we do act, in however small a way, we don’t have to wait for some grand utopian future. The future is an infinite succession of presents, and to live now as we think human beings should live, in defiance of all that is bad around us, is itself a marvelous victory.” Howard Zinn





What concessions should students ask for?  - I’d recommend asking for accountability, transparency and a place at the table.  I’d ask that:












What Questions would be good to ask?


My wife, Sabina Burton has been asked by a lot of people “what can I do to help?”  There seems to be a number of people who want to take questions to the administration but they are not sure what questions to ask.   


I have compiled information from the Timeline that helps bring up some questions that you may consider to be important enough to ask.  Some questions would be appropriate to ask the UW-Platteville administration while others may be appropriate for the UW Regents and still others may be best heard by your representatives in local government or state government. Some questions would be appropriate for all of these levels.   I recommend that you try to keep in mind as you formulate your questions: “what questions have the best chance of forcing appropriate changes?”   It's all about accountability and transparency.   Perestroika and Glasnost (Russian for Transparency and Accountability) peacefully brought down the Soviet Union and the Berlin Wall!   It will work with UW Platteville.


I believe the most important thing to remember in asking questions is that you want to hold individuals accountable for their actions.  You are not likely to do that if you are not persistent in asking your questions.   Read through the depositions and get a feel for how our former attorney Tim Hawks asked deposition questions for an example of how not to do it.  I have found the administration to be very quick to deflect questions, change the subject, make counter accusations and blame someone else.  In my opinion our former attorney, Tim Hawks, failed to hold these people accountable in the depositions thereby damaging our case and allowing it to be dismissed in summary judgment.   Don’t make the same mistakes in asking your questions.    


Suggestions for delivery of your questions:


1.       Be prepared. 

2.      Deliver questions in writing and verbally. 

3.      Keep a record that shows time and date of delivery (email or certified mail).

4.      Questions should be pointed, well thought out, well researched, well-formed. 

5.      Ask verbal questions exactly how you formulated them.  Don’t change the questions if they ask you to.  If you formulated the questions well there should be no need to change it on the spot, risking the possibility of accidently changing a critical component of the question.  If they pretend not to understand the question (a common Dalecki tactic) just say something like “I asked you a simple, well-structured question in English, the official language of this country.  You do speak English don’t you?”   Repeat the same question as often as necessary to get the answer that satisfies you.

6.      Be satisfied with any question that implicates the speaker and use it against them in a follow on question.

7.      Formulate the questions so the answer will be easy to verify. 

8.      Don’t ask a question you don’t already know the answer to, or have a good hunch about.

9.      Have follow up questions ready.  The way to do this is to thoroughly understand the topic.

10.  Don’t stop asking until you are satisfied with the answer.

11.  Be ready for follow on questions. 

12.  Any answers that surprise you should be researched.



Note:  Since I copied much of the text below from the timeline, which I wrote in first person for Sabina, many of the information is written as though she were writing it.  I have not had time to edit this web page to correct this inconsistency.  Some of it sounds like me talking and some of it sounds like my wife talking.  I’ve made every effort to keep it correct but there is a lot of information and there may be a few mistakes here and there.   If you find any material mistakes please let me know so I can correct it.   I will be glad to post any response from the university administration if they would like to rebut something.    – Roger Burton   





Chancellor Shields: 


Q:  How invested are you in UW Platteville? 


Q:  Why did you apply for a job with Chicago State if you like it here?


Q:  Was your plan to bleed us dry to make yourself look good and then leave us just before we collapse?



It’s a great day to be a Pioneer!!!!!      Finally, corruption is being exposed!!!!!!!!!!!!!!!!!!!!!!!!



Note:  Dr. Burton has one child graduating this year from UW Platteville and another going to UW Whitewater.   She is invested in helping UW Platteville succeed.   Step one: Turn the culture of corruption upside down.  Step two: rebuild using sound principles of good management with good people involved in, and in charge of, the restructuring.






Oct. 11, 2012 (9:31 pm): Dkt 53-26, pg 2. Dkt 36-5 pg3.  Dkt 40-4.  Dkt 40-7.   I asked Dr. Caywood if I was part of the experiment.  That question has never been answered.  (exhibit EZW, also exhibit EZZZY)


Which of the following statements by the administration is true?


Q:  The solicitous note passing incident described in (Dkt 51, and Dkt 51-1) was

A.    Sexual Harassment                                                                         (Dkt 101-20)

B.     An unsanctioned experiment [to get peoples eractions [sic]”      (Dkt 53-24)

C.     An example of a breach experiment                                             (Dkt 44 pg5)

D.    A report by a biased student                                                         (Dean Throop deposition pg 115)



A:  The administration can’t seem to get its story straight but here is how the student describes the incident:  (Dkt 51) and here is a copy of the note: (Dkt 51-1).  


Whatever happened in that incident is probably not legally material to the events that followed.  My wife helped the student report the incident in accordance with policy and instructions from the dean.  She believed the note to be, and the student believed the note to be sexual harassment.   Sabina suffered retaliation for her acts in assisting the student with what she believed to be a serious sexual harassment incident.  If a tenured professor is not safe from retaliation, then who is?  If nobody is safe, we can expect sexual harassment and sexual violence to continue to be swept under the rug.  If sexual harassment and violence continues to be swept under the rug we can expect more victims to be quietly discarded into silent, somber isolated despair and the number of number of victims to quietly add up tremendously over time, one isolated helpless victim at a time.


If the administration would go to such lengths to silence what the administration claims to have been “a professor’s harmless lecture about breach experiments” to what lengths would they go to silence complaints of actual rape?  How many rapes have they covered up in the past four years?   We are fighting for the right of victims of sexual harassment and for victims of sexual violence to be heard without fear of reprisal on themselves and on those to whom they turn for help and support.


Q:  What will the administration do to protect the rights of sexual harassment and sexual violence victims at UW-Platteville?

Q:  What will the administration do to protect the rights of advocates of sexual harassment and sexual violence victims at UW-Platteville?







Feb. 7, 2013 (8:30 -9 am) :  I met with HR Director Jeanne Durr to discuss how to handle the hostile work situation.      Jeanne Durr told me that Dr. Caywood “doesn’t need to answer your questions.  You would like him to answer your questions, but he doesn’t need to.”  She said “he could totally ignore everything that you send him from now till you both retire.” “He can continue to ignore you forever.”   She also said that “Tom is probably going to feel battered” by my letter to Dr. Caywood of 1/24/13 (exhibit EZZQ).    I am not battering anyone.  I am trying to expose some serious problems and I am having a great deal of difficulty finding someone in a position to help who will really try to understand what is going on and not pressure me to continue to accept the abuse.    


Q:  Why doesn’t Caywood have to answer Burton’s Questions?


Q:  Why was Dr. Caywood allowed to “continue to ignore [Dr. Burton] forever?”

Q:  If a department chair can do this to a faculty member what protections do students have from similar abuse?





Q:  Why has Dr. Burton never received an apology for the way Dr. Caywood handled the solicitous note passing incident and his subsequent actions?  Caywood admitted to handling the incident poorly and that he owes Dr. Burton an apology.   (Caywood depo pg 50) Dkt 42-98


Q:  Why has Dr. Burton never received an apology for Dean Throop’s false accusation that she cancelled class?     (Throop deposition pg 124)  The dean admitted that she owes Burton an apology.






On Jan 24, 2013 Dr. Caywood and Dean Throop suddenly and without warning withdrew their support for Dr. Burton’s efforts to create a cyber security program giving Burton only vague reason why (Caywood’s withdrawal), (Burton’s response to Caywood), (Throop’s withdrawal).  On 11/10/15 (almost three years later) Burton finally got an indication that one reason for the withdrawal was because Throop claimed that Burton called herself an expert on this press release and on these websites (Dkt 37-2), (Dkt 37-3), (Throop Decl., ¶ 13.), (Dkt 37-4), (Dkt 53-55).   Nobody ever told Dr. Burton that her expertise, or lack thereof, or her advertisement of her expertise was a problem.   Caywood had gone to Dean Throop in November 2012 complaining of Dr. Burton’s representations of expertise in cyber-security rather than confronting Dr. Burton himself (Throop’s notes).  Burton asked Caywood “why do you question my expertise?”  But Caywood did not answer the question because he didn’t think it was relevant (Caywood’s deposition pg 7).   There are some real problems with the argument that they withdrew support because of Burton’s claims of expertise:

a.       Burton is an expert in cyber security. (V1 - Faculty Forum  (video))  On April 3, 2014 Dean Throop speaks of Burton’s “expertise in cyber security.”

b.      Burton didn’t claim to be an expert in cyber-security on the websites or on the press release. 

c.       There is no requirement to be an expert in cyber-security in order to accept the ceremonial grant check she was to accept in a few days or to follow through with her plans.

d.      The money for the grant had already been accepted by the university and was in the UW-Platteville foundation account.  After Throop withdrew support Burton could not legally use the money in the account so it sits there still as of 12/15/16 (as far as I know).



March 20, 2013 late morning: I found my permission request in my mailbox with Dr. Caywood’s comments and red marks correcting my punctuation (exhibit C). Dr. Caywood wrote “If she (Dr. Burton) chooses not make changes I will not sign off on this.”  This indicates that he expected me to resist making changes and is confrontational.  I have always given Dr. Caywood my best efforts and do not resist his direction.  He is implying that I resist making appropriate changes to documents such as this, which is not the case.  He also wrote “This looks like a bare bones proposal.”   My proposal was of average or greater length and content when compared to other graduate course development permission requests.   This demonstrates Dr. Caywood’s propensity to throw hurdles in my path as retaliation against me.  This form should have easily passed his desk and all the issues he pointed out could have been discussed and finalized by the grad council.  Dr. Caywood also questioned my ability to teach about encryption asking “are you bringing in experts to discuss encryption?”

March 20, 2013 (12:18 pm):  Dkt 36-2 CAYWOOD EXHIBIT TT - 011.    Email from me to Dr. Caywood reminding him that cyber-security is part of my professional expertise. I asked him “why do you question my expertise?”  He never answered this question.  SB000906]

5-15-13 – Throop wrote a letter to Nimocks Den Herder about the Burton Grievance.  [UW-P 005429] also [UW-P 005733]   She wrote “Dr. Burton is not an expert in cyber-security.”  She wrote “she created websites (since taken down) in which she claims that UW Platteville has a “program in cyber-security, which we most assuredly do not.”  She wrote “I was put in the very awkward position of having to correct a number of incorrect statements made by Dr. Burton to AT&T as she made comments on a press release.”  She wrote “If Dr. Burton’s reputation has been damaged, it has been largely due to her own behaviors and not those of me or my office.  It is for these reasons that I am unwilling to write a letter to AT&T.”    Note:  Dean Throop spoke of my expertise in the video of April 3, 2014.   Also, Caywood called me an expert in his deposition in Aug 21, 2015  Dkt 40,   (searchable file of Dkt 40).   Page 113, at 9-14.   This contradicts the Throop’s assertion that Burton was not an expert in cyber security.  This indicates that Caywood and Throop did not believe their stated reason for adverse actions on Jan 24, 2013 and in the defense summary judgment motion.    The defense has not produced any evidence that Caywood or Throop ever informed me that their adverse actions (withdrawal of support for cyber program) had anything to do with my expertise.    This indicates they didn’t believe the reason.  They never communicated it to me.  I found out after we received their notes in discovery.

Throop referred to my expertise in cyber security at a faculty forum on April 3, 2014.  This indicates she didn’t believe her reason for withdrawal of support. Dkt 98 para 3a.  (first three minutes)  (Click Here to view video)  The argument that Throop became convinced, during the two months between Jan 24, 2013 and April 3, 2013, that I obtained expertise in cyber security is absurd.   This argument is especially absurd considering that Caywood and Throop withdrew their support for my work in cyber security on Jan 24, 2013 which eliminated my opportunity to gain more expertise in the field.

Defense asserted on Dkt 62, para 122 that as of Jan 2013 Throop did not believe Burton was an expert in cyber-security.   This is false as shown by the contradictions.  

I wrote a rebuttal and some deposition questions for Throop.    Den Herder did not mention anything to me about Throop claiming that I did not have expertise in cyber-security in my Aug 8, 2013 meeting with her.  Nobody EVER mentioned to me that part of the reason for the withdrawal of support had anything to do with my expertise (or lack thereof) in cyber-security.  This way they could keep me from addressing the issue.  Smoke and mirrors.  [pretext]




Q:  Why didn’t Dean Throop or Dr. Caywood ever tell Dr. Burton that the reason they withdrew support for her cyber-security efforts was that she had claimed to be an expert on websites and a press release? 


Q: How can a person address a perceived problem if they are never told what they are alleged to have done wrong but are punished for it?


Q:  Dr. Burton did not make a claim of expertise on the press release or websites so, why was she punished for something she didn’t do?  Was it because she helped a student with a sexual harassment complaint?


Q:  What safeguards will be enacted to prevent this sort of thing happening to other faculty members who assist victims of sexual harassment and sexual violence?





They “took no action” on my tenure request

Apr 07, 2013 08:12 PM – I received an email from Elizabeth Gates saying “Hopefully it’s just an administrative mistake.”  It wasn’t, it was intentional.  She wrote “I’m trying to assume that it’s just a simple mistake at this point.”  Easy for her to try to assume they were being fair to me but it really let me know that they were out to get me. (exhibit EZZZZL-3)   SB001369]

Apr 08, 2013 06:59 AM– I sent an email with a Tenure question to Elizabeth Schall. (exhibit ZZO-2

Apr 08, 2013 08:19 AM Late tenure letter - email from Mittie.  She called it an “administrative oversight,” an “office error” and “simply a glitch in process” but it was intentional. -(exhibit ZZO-4SB001371]    (exhibit EZZZZUSB001372]  (exhibit EZZZZU-1) (exhibit EZZZZU-2) (EZZZZL-4) If I had not fought for my tenure there is no way I would have gotten it.

Apr 08, 2013 10:20 AM – I wrote an email to Nimocks Den Herder saying I was worried about my tenure. (exhibit EZZZZL-5) SB001372]   

Apr 8, 2013 - I found a letter with tenure recommendation in my mailbox. (exhibit ZZO-6) (exhibit ZZO-7) The letter was dated Apr 5, 2013 and stamped “Revised.” Tenure was to be effective August 20, 2013.


1.       Who caused the “administrative oversight?”  

2.      Exactly what was the “glitch in the process” and who was responsible for it?”  

3.      Who committed the “office error?” 

4.      On whose authority did that person commit this “office error?” 

5.      Why were several vague comments used to describe this event rather than a clear explanation?

6.      Who originated the vague comments and who parroted them?  

7.      Would Burton be tenured today if she had not fought for the Chancellor’s office to process her paperwork, that had already been approved? 

8.      Was there a plan to simply “forget” to give Burton tenure?   Whose plan was it?

9.      How can other faculty members have confidence that this sort of “simple mistake” won’t happen to them if they assist a student with a complaint of sexual harassment?   

10.  Who oversees the Chancellor’s office to make sure they are treating faculty and staff fairly?

11.  If the administration treats their faculty and staff this poorly what have they been doing to the students behind their backs?








5-25-13 2:53 PM – Den Herder sent an email to Throop. [UW-P 000133]    In this email Den Herder corroborates with Throop in what seems like an effort to help Throop write the final say for the grievance hearing which included allegations against her.   Den Herder makes a confusing question/statement writing “It is accurate that the committee never sought your input regarding any of these matters?” [sic] 


Q:  Was Den Herder asking Throop or telling her?  

Q:  Why was Throop consulted in the process of formulating a response to the grievance against her?   Isn’t there a conflict of interest? 

Q:  Is this question mark a form of encryption that the administration uses to tell someone something while maintaining the alibi that they were just asking a question and not offering advice or instruction?   Hmmm.  

Q:  If the Attorney General collected all the emails between Den Herder, Throop, Shields, Dalecki, Caywood, Rice, Balachandran, Barraclough, Fairchild and Fuller how many statements like this would end in a question mark?    Would the AG be able to show that these “questions” were actually encrypted instructions?



 5-25-13 3:02 PM –[UW-P 000133] also [UW-P 005744]        Den Herder sends an email to Throop saying that she “just read the administrative code that is referenced and Dennis was suppose to respond within 30 days so he is out of compliance.” [sic]   Admission of guilt.  

She wrote “I’ll draft something from the Chancellor indicating that you will make sure recommendations 2-4 occur but recommending that the grievance committee should hear your input – and he will not require that you send a letter to AT&T?”  

1.       Was the Provost asking permission from the Dean, who was implicated in the grievance?  She ended the last sentence with a question mark?

2.      Why was she telling Throop, who was accused of wrongdoing in the complaint, about what the Chancellor’s findings would be before the Chancellor published it?  Was it so Throop could oppose anything she didn’t like before it was published thereby ensuring a good cover up?  It seems that Dean Throop was deciding the grievance herself, isn’t that a conflict of interest?  Why didn’t the grievance committee talk to Burton after the Chancellor remanded the matter back to them for a second finding?   Why didn’t the Chancellor accept the initial grievance committee report?  Why did Attorney Jennifer Sloan Lattis “frame” the issues without input from Dr. Burton?

3.      Way before the Chancellor’s findings were published and before the Grievance committee returned their second findings, or even knew they would be asked to return another finding, Throop was already off the hook for sending a letter to restore my rep to ATT.  It didn’t matter to the Chancellor whether the committee agreed with me or if they uncovered the truth.  He had already decided.  Why bother with the grievance process at all?  It seems that is what the Chancellor was asking himself and that’s why he blocked my future efforts to be heard.



Den Herder did not seem to be aware at that time that the Chancellor was required to respond within 30 days.  This is possibly because few grievances have ever been conducted to completion in her employ in Platteville.  Or perhaps she knew about the requirement but ignored it.   Maybe the only reason she would read a policy is to try to figure out how to get around following it.


Q:  How many other policy requirements are routinely ignored?






5-25-13 3:17 PM – [UW-P 000133]    Throop responds to Den Herder’s email saying that she “already said something to Tom about getting a facilitator to come in.”  But a facilitator never came in.  [Communication Training]    She wrote “I have already warned Lorne and Tom that something of that nature can never happen again.”   So, Gibson’s punishment for the solicitous note incident was just a warning with no investigation.  She wrote “It is exactly right that the Grievance Committee did not contact me about anything.”

Q:  Why was it “exactly right” that the Grievance committee did not contact Throop about “anything?”  

Q:  How is the committee supposed to write a fair report if they don’t even talk to the accuser or the accused?

Q:  How is the grievance committee staffed?  Who assigns people to the committee?   Who have been members of the grievance committee in the past four years and what is their affiliation with Chancellor Shields?  Why were they chosen to be members of the committee?  Who chose them?  Why were they not elected to the position?  Why were their names not posted on the university website so people know who is on the committee?


 May 28, 2013Dkt 42-88 ,  Chancellor Shields wrote a draft response to the grievance committee.  [UW-P 000111]   His final draft was signed on June 4, 2013 .  I wrote a comparison of the two documents.     This contains good deposition question for Chancellor and highlights how he changed direct verbiage to vague direction.    Another draft version Ok’d on 5/30/13 was included in defense response to document requests [5441-5443].


1.      Why does the university have grievance procedures?  Can it be so that employees and students “believe” there is a chance their grievances might be fairly heard?

2.      Are grievance requests used by the administration to identify targets for termination?

3.      How many people who filed grievances in the past four years are still with the university?   My guess is one-Dr. Burton.

4.      How many grievance hearings and complaint investigations have there been at UW Platteville since 2009?  Will the administration make these records available to the public?  Why not?  Ohhhh,  it’s a personnel matter so the administration must keep it quiet?  Ok then, how about you redact the names?   Can’t do that either?  Why not?  Ohhhh, you don’t have the records?  What happened to them?  Have they been shredded?   Hmmm.

5.      May we see the records of these grievances and complaints?   Aren’t they open records?

6.      Why are there so few grievance and complaint records?    Is it because records have been quietly “disappeared to protect the university’s brand?”   Is it because any complaint is quashed by forcing the grievant to withdraw the allegations long before a grievance committee delivers a finding?

7.      Where are the records for the grievance that Dr. Dalecki mentions in his deposition pg 152? 

8.      With a recent study reporting that one in four women are victims of sexual harassment or sexual assault on college campuses there should be quite a number of files describing how the university handled complaints of sexual harassment and sexual assault.   Why are there not records of the way the university has handled recent sexual harassment cases?   We don’t want the victim’s names publicized but tell us how the cases were resolved, who was fired, who was reprimanded, were the victims blamed?  What are the statistics concerning sexual harassment/sexual violence complaints at UW-Platteville?  How do they reconcile with reality?

9.      In Chancellor Shields’ draft version of a Mar 28, 2013 letter he wrote “Dean Throop reports that Dr. Burton presented inaccurate information to AT&T regarding her expertise and the University’s program” (Dkt 42-88).  In his final letter he wrote something vague and does not mention any claim of misrepresentation of expertise.    Why did the Chancellor remove the admonition that Burton had made claims of expertise?   Was it to keep Burton, the department and the grievance committee in the dark about why she was being punished? 

10.  When is Dean Throop planning to finally inform Dr. Burton that she removed her support for Burton’s cyber security efforts because of Burton’s alleged misrepresentation of expertise?    It has been over three and a half years already.

11.  Where exactly did Dr. Burton misrepresent her expertise?  We couldn’t find it.

12.  How can a faculty member address the Dean’s concern if the Dean does not communicate the concern to the faculty member but punishes her for it anyway?


13.  How can students feel safe that faculty members they go to for help with sexual harassment or sexual violence matters will not be retaliated against for helping the student?






  1. Communication and Harassment Training was ordered, recommended, urged, needed and requested but was never conducted.  


    1. Then Dean Den Herder wrote “I charge Dr. Caywood with inviting a speaker/workshop leader to conduct a workshop with department members on conflict resolution, civility, and team building to take place at some date before or near the beginning of the fall semester 2010.  This will be a mandatory event for everyone in the department.”
    2. On April 19, 2013 A grievance committee recommended that “the Criminal Justice department take steps to resolve the dysfunction within the department, such as communication training.”
    3. On July 10, 2013 a grievance committee wrote to Chancellor Shields “at our June 20 meeting, you indicated that Provost Nimocks Den Herder will meet with the Criminal Justice Department in order to help the members resolve their differences.” 
    4. On July 26, 2013 Chancellor Shields wrote “I also urge them (VC Den Herder and Dean Throop) to assist the department by employing outside consultants to work with the entire Criminal Justice Department to build a stronger team, work on communication and conflict resolution skills, and begin to resolve some of the conflict that has built up over time.  This consultation shall take place as early in the academic year as possible.”
    5. On 12/11/13 HR director Lohmann wrote “We need diversity and harassment training. CJ would be a good place to start.”
    6. On Apr 28, 2014 Dr. Burton requested that communication training be conducted.  It was not.




1. Did the university conduct mandated communication training?  No?  Hmmm.

2. Why not? 

3. How can a communication problem be corrected by mandated communication training if the training is never conducted?

4. Was the training ordered with no intention of conducting the training?  Why?   Hmmm.

5. Was it so people would think that the administration takes communication training seriously while still allowing the administration to continue to push their own brand of communication training?  Listen to A28 - Dalecki Threatens grad student Nov 2014 for an example of the brand of communication training conducted behind closed doors at UW Platteville.

6. Why does the Chancellor have a “no email” policy?  Is it so victims like Dr. Burton won’t be able to maintain records of their abuse?




Circumscribing Burton’s grievance against Caywood  -  Try to find the disconnect between Burton’s grievance, the audio of the grievance hearing and the Chancellor’s vague decision on July 26, 2013 and his letter to the entire department publicly blaming Burton and Caywood equally without saying what either of them did wrong.  Chancellor Shields’ letter to the department was much like a pastor standing at a pulpit who points at the virgin in the front row and shouts to the congregation “That woman should not be sleeping with my brother.   The Chancellor’s decision did not address any of Burton’s demands.  It seems that the decision was for a completely different complaint and hearing.   Burton wrote draft rebuttals: (exhibit ZA-9) and (exhibit ZA-9a). 




1.      Did the university post notices to all employees advising them of their rights under the laws EEOC enforces and their right to be free from retaliation as Dr. Burton demanded in item four of her grievance demands?  Why, almost four years later are those notices still not posted?  You can order them from the EEOC for free.  It is required that employers post those notices.

2.      Has a copy of the UW-Platteville Discrimination and Harassment Policy and the procedures for implementing it been distributed annually to all University of Wisconsin-Platteville students, faculty, academic staff, and classified staff as required by policy and demanded in Dr. Burton’s grievance?  (appendix VIII)

3.      Have educational programs been conducted regularly to sensitize members of the university community to the issues covered by the UW-Platteville Discrimination and Harassment Policy as demanded in Dr. Burton’s grievance and as required by policy?  (appendix VIII)

4.      Why does it take a swell of public support for Dr. Burton for the administration to address her demands and to follow policy?

5.      How can the administration assure students, staff and other faculty members that they won’t need this volume of support and publicity in order to get their complaints, grievances or reports of sexual harassment or violence addressed?

6.      How can the administration convince students, faculty and staff that laws and policies concerning sexual harassment, sexual violence and discrimination will be followed in the future?









Fri, Aug 09, 2013 07:38 AM (exhibit EZZZZZJ-1) I requested a face to face meeting with the Chancellor as soon as possible. I was running out of time before the statute of limitations would begin to nullify my ability to use Dr. Caywood’s dept meeting retaliation for the student complaint in court. I wanted to find out if the Chancellor was planning to do anything and see if there was a glimmer of hope to resolve the issue in house rather than involving federal agencies and the courts. The chancellor ignored my email and that answered my question. 


1.      Why did Chancellor Shields ignore Dr. Burton’s request to meet, forcing her to take the matter to the EEOC?   






Provost Den Herder meets with Dr. Burton on Aug 8, 2013 and writes to an attorney about the meeting.  See if you can find the disconnect between the audio of the meeting and the description of the meeting by Provost Den Herder.  Hint:  see timeline of Aug 14, 2013 for some interesting commentary.


Aug 14, 2013 – Nimocks Den Herder sent an email to Paige Reed [UW-P 005783]  (5783-ProvosttoReed-8-14-13)  Den Herder’s notes about her meeting with me were included.   


Den Herder wrote that she “encouraged her (Sabina) to try to let this go; Tom will no longer be chair and she needs to focus on the work she’s so excited about.  I don’t know if she heard or even is able to hear me.”    


1.      How could Sabina focus on the work she was excited about when Dean Throop ruined her source of funding, refused to correct the defamation, withdrew support for her efforts, refused to restore her reputation and never told Burton why she did those things?

2.      Why didn’t Den Herder tell Burton anything about Throop’s super-secret misrepresentation of expertise allegation? 

3.      At the end of the meeting Den Herder told Burton that she would look into the defamation but did she even have any intention of doing so?   

4.      Why didn’t Den Herder tell Burton about the Chancellor’s decision concerning her grievance hearing?

5.      Was Den Herder able to hear Burton?

6.      Is it part of the standard UWP grievance process to get the grievant to drop the issue without resolving it or is this pressure reserved for targeted employees who help students with sexual harassment /sexual violence complaints?  

7.       Is it possible that Burton couldn’t hear what Den Herder was saying because her message was hidden between the lines? [{whispered between the lines -Let it go or you will be fired- whispered between the lines.}]

8.      Who couldn’t hear whom?  (audio exhibit A7) 




Aug 21, 2013 09:37 AM – I wrote an email to Dalecki asking that email addresses show that I have a PhD as does Caywood.  Dalecki’s response was harsh, lengthy and unreasonable. (exhibit 518)

  8-21-13 – 9:37 AM – Dalecki’s response was BCC’d to Throop.  She was already keeping tabs on me.  She was looking for a way to hurt me.  Why else would Dalecki inform her of the conversation?  How does this fit with her statement that I was not chair material because I couldn’t handle problems on a local level?  This shows Throop’s desire to keep tabs on me and Dalecki’s involvement in her scheme.  Dalecki bcc’d her on a matter as benign as a request for email addresses to show my title, the same as Caywood’s.  (Dalecki deposition) [UW-P 000101]   



1.      Why did Dalecki BCC Throop on emails he sent to Sabina? 

2.      Was she on double secret probation?

3.      Was he ordered to do that?  Why?  

4.      Why didn’t Dalecki just change the email address instead of writing the long email?  It would have taken less time.

5.      Was Dalecki put in place primarily to keep an extra special close watch on Burton, to fire her, to get her to drop the lawsuit or to destroy her?

6.      How can students be confident this won’t happen to faculty members to whom they go for help?









Dec 2013  (estimated date) Throop’s notes:   Dkt 42-82  Dean Throop wrote a chronological list of events in CJ since June 2012.  [UW-P 005940 to 5941  (Dkt 101-20)      She wrote “It of course is NOT a proper breach experiment and was interpreted by the student as sexual harassment.”  She wrote “Burton and Caywood kept drawing me into their problems.”




“Caywood knowingly altered the start date for Lomax to 31 days after his official date of retirement, in direct violation of the law and committing fraud.  His illegal behavior resulted in Lomax donating his time to the university as a volunteer.


When I confronted Caywood on his illegal activity, he laughed and said that’s what you get when you deal with former law enforcement: “we know how to get around the law.” I didn’t think it was funny.”


“He also seemed to be encouraging, or at least abetting, bad behaviors by his male colleagues Gibson and Dutelle and ignoring or denigrating the excellent work of his female colleagues.”


She speaks in paragraph 5 of Dutelle asking for what he called a “finder’s fee” but that was interpreted by the HR department director at a DC-based defense contractor as a request for a “bribe.”


She wrote of the another incident of sexual harassment but did not mention her name.


She wrote in paragraph 7 “we offered to send Caywood to chairs’ workshops, management training, or conflict resolution training.  He refused to consider any of these options.  I then said, “well, Tom, how do you plan to avoid having another year like the one we just finished?” He said “I will just hope for the best, I guess.”  I said “That troubles me a great deal.  That can’t happen.”  He said “Maybe it’s time for new leadership.”  I said “Maybe it is.  Are you stepping down?” “I guess so,” he said.  “Who would you suggest replace you as temporary chair?” I asked.  He suggested Mike Dalecki.”


 Throop wrote “I will agree that an election should have been held in the summer before opting for an external candidate. I actually did not expect that Caywood would step down; I was very hopeful that he would have been willing to acquire the management skills necessary to allow the department to run at a minimally acceptable level.”




1.      Why didn’t Throop admit she “removed” Caywood?  Why try to pretend that he “stepped down?”

2.      Was Caywood “removed” or did he “step down?”

3.      If he was removed, why was he removed?

4.      Why did Throop aspire for the CJ department to be run by a “minimally acceptable” chair?








May 22, 2014 10:56:33 PM – Rex Reed sent an email to Fuller and the department members subj: Re: EMAIL UPDATE Staff position Announcement and qualifications. (exhibit 687a)   Now this is interesting: Reed's openly critiques the job announcement/hiring procedure under Dalecki, that forgoes dept support, yet I was held to higher standards by Throop. Reed no longer with CJ .This is interesting because it shows that there was a problem with the process of searches before I complained of the problems with Solar’s search.   Reed asks “How come we were not informed of the announcement going out without a final review by staff? Without seeing the final announcement, how can I tell if my initial input had any impact. It makes me wonder why I go through the process of reviewing the initial draft if I don't get to see the outcome. Furthermore, where was the announcement placed?”


1. How will the administration ensure that faculty governance matters such as search and screens, voting and evaluations will be conducted fairly?  

2. How will the administration ensure that policies won’t be misapplied to discredit and silence targeted individuals?





Oct 2, 2012 12:18 PM - Dkt 34-6 pg5 & 9    Dalecki wrote an email to me forwarding the student’s email.  He wrote that his interaction with the student led him to believe that the conversation he had had with me, which he thought was between he and I, was relayed to the student.  Dalecki wrongly stated that he believed himself to be quite professional.  He wondered if I questioned his professionalism in the student’s presence and that I had shared his emails with the student.  Exposure is terrifying to corrupt people.    He wrote that it is not uncommon for students to believe “the right to an opinion includes the right to have it taken seriously by others.”




1.  Do students, who pay about 80% of the university’s budget, have the right to be taken seriously at UW-Platteville or does the Chancellor and Provost hold the same opinion as Dr. Dalecki?





June 6, 2014 3:38:44 PM   (Dalecki_issue-3-Kang).   Dkt 43-1 BENSKY EXHIBIT YYY – 001       Dkt 41-37.  I sent an email to Dalecki saying “Then why, WHY did you not call me or ask me to talk to you? You had my number. Your previous long email "incited a strong emotional response." Next time follow your own advice.”

Dalecki did not answer my question.   The fact that he acted against his own advice and didn’t answer my question shows that he didn’t believe what he told Throop.  The fact that Throop didn’t ask me about it or investigate the matter but instead reprimanded me shows that she didn’t believe Dalecki’s claims.  She knew he was lying and didn’t want to know my side of the story; she wanted to harass me.  Throop didn’t respond to any of my allegations against Dalecki, which were all true and verifiable.  She didn’t investigate my claims.


1.      Why didn’t Dalecki call Burton and follow his own advice?

2.      Why didn’t Throop investigate Burton’s claims against Dalecki but instead wrote this incident as part of her letter of direction against Burton?

3.      When will the administration bring in outside, independent, well respected consultants to educate administrators (especially administrators), faculty, staff and students about the right way to communicate in a healthy organization?   How will the administration ensure that ALL administrators go through this training?


Here is one service, the Workplace Bullying Institute, that might be able to help conduct needed training:







Jun 10, 2014 03:27 PM – Dalecki wrote me an email (exhibit 580b) in which he called the delegation “my guests.”  He said that he assumed I would want to be involved and asked some directed questions, which I answered.  He later excluded me from events and only allowed me to give my presentation on Sunday evening with no money for sandwiches for the delegates.   Note: I donated $6,400 to the exchange program but Dalecki couldn’t even give me money to buy twenty sandwiches.



1.      Why did Dalecki change the location of the breakfast when the meal service was operating?  Note: the meal service was operating! (Timeline)

2.      Why didn’t he tell Burton the new location of the breakfast when he called Burton that morning? (phone records prove he called but are not provided due to privacy issues).

3.      Why did Dalecki say in his deposition, under oath, that he didn’t call Burton that morning?

4.      Why is Dalecki still employed by UW Platteville?




Jun 26, 7:34 PM -  Dkt 48-139  Dalecki wrote an email to Lohmann and Decoste putting my work down. [UW-P 004754]    He wrote something interesting.  He wrote “My response (again, coached by John).”   What does that mean?  Maybe a good deposition question.   He wrote that I supplied information gradually and incompletely but I gave him everything he asked for quickly and I can prove it.  He can’t verify his statement because it is a lie.  I had the bus arranged except for payment.    He considered the fact that I did not go to Germany to be verification that I “baled on the German visit.”  That is baloney.


Jun 26, 2014 07:39 PM –     Dkt 48-139,    Dkt 48-140,   Dalecki sent an email to Lohmann writing “Despite telling her we’d handle it, and directing her to do no more planning, she continued to call to make arrangements;  It looked silly when Deb rice calls someone only to find Sabina just called.  Makes us look like one hand doesn’t know what the other is doing.”  - This is a lie designed to get Lohmann to see me as out of control.  [UW-P 004744].   He wrote “So, I asked again, for information below.  I bolded the “please do no more” planning line, because she wasn’t getting the message.”   The timeline shows that Burton did a great deal of very accurate, organized and complete coordination.


1.         How do you reconcile Dalecki’s complaint that Burton wasn’t doing enough (gradual and incomplete) and then five minutes later complain that she continued to try to help despite Dalecki telling her to do no more planning? 



1.      Why did the university cancel mediation between Dr. Dalecki and Dr. Burton?  Was it because they suspected Burton had recorded the first mediation meeting?   (Search for “mediation” in timeline)

2.      Why would a recording of the session cause the university to cancel future meetings without any indication as to why they cancelled the mediation?

3.      Why was the university involved in the decision whether to mediate at all?  Shouldn’t the two employees be the ones to decide if they want to mediate?  Shouldn’t the university provide mediation services any time two employees desire mediation? 

4.      Is there a law against Students recording their closed door encounters with staff, faculty and administrators at UW-Platteville?

5.      Is there a school policy against making audio/video recordings in meetings?  If so, where is it and who authorized it and why?

6.      Does school policy trump state law that allows individuals to record conversations?

7.      Almost everyone these days carries an audio recording device everywhere they go.  Should administrators be concerned that students and targeted employees now know that Wisconsin state law allows them to make recordings? (audios) Note: not all states have this provision.   Will public knowledge of this fact loosen the grip of corruption? 

8.      If faculty members of UW Platteville begin recording closed door meetings and sharing them with others will that help curb corruption? 

9.      Should targeted employees record meetings in which they believe they will be harassed?

10.  Which would win this epic battle of titans:  the First Amendment vs. the Second Amendment?  Aren’t you glad they are both on our side?   Which is more like Batman and which is more like Superman?

11.  Why is Dalecki still employed at UW Platteville?






 Aug 8, 2014 - Dalecki wrote to Lohmann “She wants me to explain- - I of course have a number of reasons but I will not explain them without consultation with you.”    [UW-P 004709]    This has some good deposition questions for Dalecki. 



1.      Why would an employer not give the reasons for punishing someone? 

2.      What were the reasons of which Dalecki spoke? 

3.      Why was Burton blindsided with a ridiculous explanation for the removal of her mentoring assignment in a letter of direction months later?

4.      How can you expect someone to correct a “behavior” if you don’t tell them what they did wrong?  

5.      If this can happen to a senior tenured faculty member what is to stop similar things from happening to students who have complained of sexual harassment?  

6.      How do the laws protect students if the administration violates the laws?




September 24, 2014 12:44:56 PM -  Dkt 42-92.   Reed sent an email to Throop with the form that was approved by six of seven votes.  (email fm Reed to Throop 9-24-14)  


October 7, 2014 8:11:50 AM -  Dkt 41-35.  Throop sent an email to Reed saying “I've also attached a revised copy of the job ad so that we can throw, as Rex put it in our meeting, "the widest net possible."”  Again she is blaming someone else for her decision.  She unilaterally changed the advertisement so the net would include Dalecki without a vote.  She implies that Rex approved the change but he didn’t.   As you can tell by the meeting I recorded we were adamant that the advertisement be written so that it would not include Dalecki as a viable candidate. (email fm Throop to Reed 9-24-14)  [Blame 3d party] [corrupt vote]  The original wording was approved by the department on 9-24-14 .     Reed sent the final draft of the ad to Throop on  September 24, 2014 12:44:56 PM     Throop’s actions seem similar to Donald Thrump’s ‘Many people are saying’ = ‘I made this up.’   (article of Aug 8, 2016)  This isn’t the only time Throop did this.


Note:  Fuller sent an email to Throop explaining that the department didn’t want Dalecki as chair.  (Subpoena emails)


Q:  Why did Throop make this change without first getting approval from the committee?

How do you deny that you made this change to enable Dalecki, who was disqualified by the original version and qualified after you altered the ad, to become the next chair of the CJ department?   


Q:  Why did Throop get involved in faculty governance matters in this instance yet refused to help Burton with her allegations of retaliation claiming that she didn’t want to “interfere in faculty governance matters” on Dec 11, 2012 (7:29 AM): Dkt 42-89,   SB000003]    SB000840]  Dkt 37-13?






Sept 30, 2014 – Throop claims- several suggested Zauche  in an email saying “I am happy to tell you that Tim Zauche (who several of you suggested) has agreed to serve as the chair of this search committee.  I will be contacting some of you, asking you to serve as members of this very important committee.”  


1.    Of the 12 CJ members Throop addressed this email to, which of them suggested Zauche?  Can that be considered “several?

2. Can the university produce evidence that several faculty members of the CJ department actually suggested that Zauche chair the committee?   

3. How does the selection of Zauche reconcile with the 8/29/14 department meeting where it was agreed that it would be best to select someone to chair the committee who “has a vested interest in the department” Dkt 37-15 (pg 21)?  

4. Other than a friendship with Dr. Dalecki what vested interest did Dr. Zauche have in the department?   

5. Wasn’t it really Dean Throop who unilaterally selected Zauche to chair the search for the new CJ chair with the intention of rigging the selection process to produce Dalecki as the final candidate?  

6. How does the administration explain Dean Throop’s removal of Dr. Burton from the committee? 

7. Why did Dean Throop put Burton on the committee in the first place?  Was it so Burton could not apply for the chair position?  Did Throop have intention of removing Burton from the very beginning?  Why did Throop get so involved in faculty governance matters in this instance yet refused to help Burton with her allegations of retaliation claiming that she didn’t want to “interfere in faculty governance matters” on Dec 11, 2012 (7:29 AM): Dkt 42-89,   SB000003]    SB000840]  Dkt 37-13




Oct 9, 2014 -  I looked for the email I sent to the Chancellor on Oct 2, 2014 but it has disappeared from my account.  Fortunately I still have it (exhibit 551-a). (Dkt 101-11)     Dean Throop admonished me in a letter of direction for writing this email and when I asked her to provide the email in question she denied even mentioning it in her letter of direction.  This smacks of cover up.  Someone is deleting incriminating emails from my account.  Fortunately I back things up.




  Dr. Burton’s email account was hacked.  Some of the incriminating emails in this case were erased.  Does the administration know anything about this?   How does the administration protect student email accounts from hacking by high level administrators and attorneys?


Who has been given access to the UW-Platteville servers to be able to perpetrate this sort of hacking?     There should be a public list of people with this high level access and nobody else should be allowed to access that level.    How is the university protecting students from cyber-crime such as this?


If someone hacks an employee or student’s email can that person be identified by using cyber-forensic techniques?  How much would that cost?  Not much huh?  Why don’t we do that and find out who deleted Dr. Burton’s emails?


If an employee or student sends sensitive information over their email account how many people will have access to that information? 


Does Attorney Jennifer Sloan Lattis or any other attorney have, or ever had, access to UW-Platteville electronic records systems such as email, financial accounts, web page access and leave status?  Why would a lawyer need this kind of access?  Who authorized her to have this access?  Who controls access?


Will the university make public the database showing who accessed various levels of the system and when?  We don’t need passwords but just date and time of login and level of access was granted since 2009.   Will this information be available on request in the event of future cyber-crimes?  


Did the administration oppose Dr. Burton’s Cyber-Security program because they feared that she might expose their involvement in this sort of cyber-crime?





Oct 17, 2014 10:57 AM – (Dkt 42-78,   Dkt 37-15-THROOP EXHIBIT WWW – 028Dkt 42-78,   Dkt 37-15 (exhibit H)   Solar complains to Fuller about my refusal to drop the issue of his violation.  In his email Solar writes “If I screwed up, I’ll take the repercussions and learn.”  But at the same time he is saying that he refuses to take any repercussions for his screw up.   The question whether he violated policy is the hinge pin for this issue.  The fact is that he violated policy and I can prove it.    Fuller forwarded this email to Throop and she included it as Exhibit H in her UWS 6.01 complaint.   In this email Solar calls me a “bully.”   He forwarded my email of Oct 16, 2014 04:34 PM. 


Q:  Why didn’t Throop investigate Burton’s allegations?




Thu, Oct 23, 2014 09:10 AM  -  Dkt 46-123, 124.   I wrote an email to Fuller with my esignature.  I explained that I did not sign the other overload contract as that course should be part of my regular load and not overload.  I asked her “Are you punishing me for having filed a grievance? Are you stating that teaching a grad course was not part of my contract or not discussed at my job interview on March 27, 2009?”  I received no answer to these questions.  I asked her to “please honor my contract and assign the CJ 7340 Cyber Crime course to me as part of my regular load.”  I reminded her that Pat Solar teaches online as part of load.  (exhibit 568-4)  Attached was (exhibit 568-4a).  See Fuller’s email of 11-02-06 to show the release time for online as part of load discussion. 


 10/28/14 – I sent an email to Fuller asking again “Are you punishing me for having filed a grievance?”  [UW-P 005837]    I told her that Solar teaches online as part of load and why not me?    This would be a good deposition question for Fuller.


Q:  What are the answers to Burton’s questions?  Why didn’t Fuller give Burton an answer at the time?

How can students be confident that their questions will not be ignored after they have reported sexual harassment?




10/29/2014 7:59 AM –  I received an email from Throop (exhibit 570).  Attached was a letter of direction, dated Oct 28, 2014, which violated my due process rights (exhibit 570a) also [UW-P 005456 to 5458].    Dkt 42-78,   Dkt 37-15 (exhibit A(pg4-6)) .   Dkt 48-143,     I wrote a rebuttal -  (Dkt 42-78,   Dkt 37-15 pg 30(exhibit I)) (interactive exhibit i571) and continue to update this interactive file.  This has a good discovery or deposition question or two in it.   

Dean Throop’s letter of direction came two months after my initial request for a grievance hearing with no date for the hearing on the calendar and no prospect of ever having the hearing.   The UWS 6.02 (appendix XVI-1) states: “The aggrieved faculty member is entitled to a hearing before the Commission within 20 working days of the written submission of the grievance to the Commission chairman.  This deadline may be extended upon the consent of the grievant or by order of the Commission.”  I never consented to an extension and I never received an order from the Commission extending the deadline.  UWS 6.02 also says “All parties are due as prompt a resolution of the matter as practicable.” 

Dean Throop’s letter of direction was an attempt to intimidate me into keeping my legitimate grievances quiet.  She wrote: “Direction #1. You will actively work to resolve your complaints and issues on the most local level possible: your department, before invoking assistance from the administration.”  This direction was intended to force me to limit my complaints to only Dr. Dalecki’s authority.  The trouble is that 1) Dr. Dalecki is abusing me so I need to take the matter over his head if I am to gain resolution and 2) it is a violation of my due process rights for Dean Throop to threaten me with discipline if I exercise my rights to grievance resolution through legitimate process.

 I filed a grievance against Dean Throop on with three issues: 1. Dean Throop’s unfair letter of direction.  2. The policy violations of the search for a new chair of the Criminal Justice department.  3. The policy violations of the search for three new Criminal Justice faculty members.

Q:  Ask the questions in the rebuttal




11-1-2014 8:48 AM – Balachandran wrote an email to Den Herder, T Stafford, Fairchild, Michael Thompson, Theron Parsons, Miyeon Kwon, Donita Cartmill asking for them to review the “Letter3Nov2014SBalach…” that was attached.   [UW-P 005851]  He wanted to get it reviewed so he could send it to me by Nov 3.   He wrote that he had been working with UW System Legal Counsel Attorney Thomas Stafford,,   and   to develop the Standard Operating Procedure for the Hearing Panel.     Maybe Tim should contact Stafford and ask him to verify the legality of the grievance procedures he and Balachandran wrote.


Deposition questions for Stafford may be:


Ask him if he authorized the procedures to say "The hearing panel may hold a grievance hearing in closed session." (exhibit 602f)


Ask him if Balachandran consulted him prior to writing "The Commission and the Hearing Panel will schedule a closed hearing of Issues #1 & #2 in your grievance dated Nov. 12, 2014 after you and the respondent agree to a date and time that convenient to the Panel."


Ask him if he thinks he could defend the document as conforming to the letter and spirit of Wisconsin Open Meetings Law.


Ask him if he knew Balachandran based his authority to write the Grievance hearing Procedures on this statement “As per UWS 6.02 Grievances, “The Commission is authorized to establish its own procedures to investigate a grievance that it is hearing.”’”  (exhibit 602a).  He makes a similar misrepresentation in (exhibit 599c).


Shouldn't the procedures be titled "Investigation Procedures" and not "Hearing Procedures?"  The "authorization" in the questionable and suspect text does not attempt to authorize the committee to formulate "hearing procedures" but "investigation Procedures."  There is a difference.   Balachandran's procedures are clearly to handle "hearing" a complaint but even the questionable and suspect text does not authorize that.


Ask him if he knows why that statement is on the university website here:   How did it get put on the website?  When was it authorized to be on the site?  By whom?  Was it ever voted on by faculty senate?  If so, when?  Let's get the faculty senate audio for that meeting as well as the faculty senate meeting minutes.  let's find out what rules were broken to get it on the website.


Ask him if he can verify the legitimacy of the statement and prove that it was authorized properly.


Ask him if he knew that one of the reasons Balachandran violated Sabina's right to expeditious hearing was so he could have time to write the bogus procedures.


Ask him why the procedures were not voted on by the Faculty Senate but only mentioned as an informational item.


Ask him why the procedures had not already been written since it was on the Faculty Senate agenda several times in the past year.  Why rush it just for Sabina's grievance hearing?  Why not use the old procedures until they had time to produce new procedures?   Why make Sabina wait while they rushed this through?


Ask if he knows why Balachandran would not divulge his name when Sabina asked for it on 12/10/2014 9:13 PM    We only found his name through discovery, nine and a half months after asking for it.


Q:  Why was this policy pushed through shady approval while Dr. Burton was awaiting a grievance hearing?  Why was it used as a reason to delay her grievance hearing?   What is the proper process to approve this sort of policy?  Was this process followed in this case?  Why not? 


Who put the suspect text on the university website?  Who authorized that text to be placed on the website?   Who wrote the suspect text?   How can we prevent shady characters from changing policy and posting those changes online without authorization from proper personnel? 


Does the Faculty Senate have a spine?  Why did they not respond to Dr. Burton when she told them about the bogus and discriminatory grievance hearing procedures?  Is the Faculty Senate afraid to fight for the rights of the faculty?  How omnipotent do they think Shields is?  Are there no good, honest courageous people left on the faculty senate or have they all been replaced by cronies?


How can students expect to be treated if they fight for the rights of students?


Can the administration prove that the Seriously Flawed and Discriminatory Grievance Hearing Procedures were approved by all the members of the Grievance Commission? 



1.      Why has the university failed to announce grievance hearings at least 24 hours in advance as required by Wisconsin Open Meetings Law?



May 8, 2016 11:14 PM -  I sent an email to the Faculty Senate (EmailtoFacSenate5-8-16).  Attached was Fairchild’s letter refusing my hearing (Fairchildrefusalletter).  This email was deleted from my email account.


Q:  Why did the Faculty Senate not act on Dr. Burton’s email.






November 03, 2014 8:49 PM –  Dkt 42-81  - I sent an email to Throop saying “In your letter of direction you referenced an "email of October 2, at 8:40 PM." I don't have such email in my sent folder. Please send me a copy of the email in question.” (exhibit 551-c)


Nov 7, 2014 2:06 PM - Dkt 42-81  - Throop responded saying “You are incorrect. There is no reference to an Oct. 2, 2014 email in my letter of direction.”


Q:  Is this the level of integrity and accuracy we can expect from our new Provost?


Why was Throop promoted instead of fired?




December 4, 2014 1:02 PM through 12/5/2014 6:06 PM – Emails between Zauche and I. (exhibit 593).  Zauche reminded us to send our votes.  I had trouble opening the form on my computer and Zauche sent me another form that worked.  I asked some questions about why Zauche changed percentages of categories and explained that I didn’t want to send my form and gave reasons why.   Zauche and I exchanged emails and he ended saying that my votes would not be included if I didn’t send them in.  Here is what he was really trying to do:  He wanted all of us to email our votes so he could manipulate the numbers so Dalecki wins.  Then he would say “That’s the way everybody voted” and nobody could refute that because he would be the only person in the world who knew how the votes actually went.   This sort of thing is common practice at UW Platteville. Votes are routinely manipulated and influenced to produce the administration’s desired result while maintaining the appearance of propriety.  [corrupt vote]


Q:  Answer the questions about why Zauche changed percentages (exhibit 593).    Was it to rig the search?





12/5/2014 12:15 AM I wrote an email to Balachandran (exhibit 601) and attached my comments to Throops memo (exhibit 595d).  I have made updates to (interactive exhibit i595d).  In


Q:  Answer the questions in the updated rebuttal. (interactive exhibit i595d)




December 8, 2014 10:36 PM –  Dkt 42-80,   Dkt 42-78,   Dkt 37-15 (exhibit C) .     Dkt 42-78,   Dkt 37-15 (exhibit E)    I replied to Throop (exhibit 597) asking her many questions about why she had been doing the things she had been doing.  These were all good questions to ask in deposition.  She never answered any of the questions I asked.   

I wrote “It seems to me that you are treating me disparately…”  Because I pointed out disparate treatement this may be considered a protected activity.    Because I pointed out that her demand is a violation of law this should be considered a protected activity.   Throop removed me BECAUSE I complained of disparate treatment and BECAUSE I refused to act on a direction that violated law.  She may say it was because I refused to recuse myself but that is not a violation of any policy.  One may recuse oneself for any reason.  One may decide not to recuse oneself for any reason.  It would not be me recusing myself if I did it at her demand.  Dean Throop could, and did, recuse me herself.  She cannot legally force me to recuse myself. 


Dec 8, 2014, 10:39 PM - Dkt 42-78,   Dkt 37-15 (exhibit C) .   Dkt 42-80     I re-sent the email because I hadn’t included Zauche originally. 



On December 8, 2014 11:03 PM  Dkt 42-80,    Dkt 42-78,   Dkt 37-15 (exhibit C)   Zauche said he would let me and Throop “figure this out.”   Zauche wrote “I am probably better than most people on CJ because I have no enemies in the departent or college, only respect for everyone.”  And “I declined the offer to serve as chair two times, but at the end, I serve at the discretion of the Dean. If needed, Liz can explain in further detail why she selected someone outside the department.”






December 8, 2014 4:42 PM -  Dkt 42-79  (exhibit 597aDkt 42-78,   Dkt 37-15 (exhibit E)  SB000227]   Throop emailed me and Zauche saying I had documented prejudgment of Dalecki’s ability to serve as chair.  She said I “must not participate in any activities of any kind, including interviews, discussions, and evaluations of Dr. Dalecki in the search process. If you attempt to participate, I will be forced to remove you from the search committee immediately.”   


On December 08, 2014 10:37 PM     Dkt 42-79   I responded with a lengthy, and informative, email.  I asked a bunch of questions Throop couldn’t answer.    This is important.


December 9, 2014 10:15 AM   Dkt 42-79,   Dkt 42-78,   Dkt 37-15 (exhibit E)  Dean Throop wrote “You will either refrain from discussing Dr. Dalecki’s candidacy, par/cipa/ng in decisions/recommenda/ons regarding his candidacy, and voting on his candidacy, or I will remove you immediately from this search committee.” (exhibit 597a)     Her direction was non sensical.  


Tue 12/9/2014 12:47 PM –  Dkt 42-79,   Dkt 42-78,   Dkt 37-15 (exhibit E)  I wrote a response saying “I will not bend to corruption, abuse and threats.”   Throop immediately removed me from the chair search committee. (exhibit 597a)  I accused Throop of corruption.  This should be considered protected activity.  I asked her some pointed questions which she never answered.






12/9/2014 1:52 PM    Dkt 42-78,   Dkt 37-15 (exhibit D) .   Dkt 42-80,        I wrote Zauche a rather long and informative email on telling him that he should do the right thing and recuse himself from the search due to major conflict of interest with Dalecki.  (exhibit 597)  Throop admonished me for this email in her UWS 6.01 complaint.  Since I pointed out corrupt behavior this should be considered a protected activity under the whistleblower law.  I wrote “I don't show loyalty to a corrupt, abusive system; and that is my "disqualification" for the search & screen chair position.”



Q:   There are many very good questions in the emails above.  Pick through them and find the best ones.





Jan 5, 2015  Dkt 54-11 - Dkt 42-78,   Throop filed a complaint with Chancellor Shields against me (exhibit 619b)   Dkt 42-78,   Dkt 37-15.      Dkt-53-56--9454   (exhibit 619a)..  SB000773 to 812]  I rebut Throop’s complaint in (never sent 619d)  I learned of the complaint on Jan 15, 2015.  I have updated the rebuttal here (interactive exhibit i619d).  I have not sent the rebuttal to anyone.   This contains good deposition questions for Throop.





1/17/2015 11:50 AM – I sent an email to Barraclough (exhibit 619c) requesting a copy of the rules and procedures for dealing with investigations.  I wrote  “I question the validity of the procedures located on this page of the university website: .“  I never received a response until months later when he referred me to Balachandran.


Q:  Why didn’t Barraclough, who was conducting an investigation into allegations against Burton, provide the rules and procedures Burton requested?  


How can students be sure rules and procedures are followed whenever they are investigated?



February 12, 2015 9:00 AM – Throop wrote back to Elmer, cc the department (exhibit 643) in which she used vague terminology to tell the department members that ‘you have good reason to be uncomfortable about discussing this situation in a face to face meeting.’  Again she lies about people telling her that they are not comfortable with or interested in a face to face meeting.  They are uncomfortable because they are afraid Throop will do to them what she has been doing to me.  Why would they communicate that to Throop?  They wouldn’t, so she lied.  Just like she lied about students reporting that I cancelled class.


This is similar to Donald Thrump’s 'Many people are saying' = 'I made this up.'    This isn’t the only time Throop did this.


Deposition question for anyone in the department. Fuller, Rice, Stackman, Reed, Caywood, Solar, Elmer, Nemmetz etc.   Were you one of the people Throop referred to?


Thursday, February 12, 2015 7:15 PM – Elmer responds with another email (exhibit 643) that makes it clear that he does not trust the legitimacy of the process to select a chair. 

Deposition question for anyone in the department. Fuller, Rice, Stackman, Reed, Caywood, Solar, Elmer, etc.   Have you read this email?   Have votes been conducted in a fair manner in the CJ department?   Why do you think Dean Throop added the phrase “or, at least, those of you interested in or comfortable with a discussion” in her email?    Why was this discussion even necessary?  

2/12/2015 7:30 PM – Throop responds with an email blaming her mandates on the phantom concerns of an unnamed number of unnamed people.  (exhibit 643)

Deposition question for anyone in the department. Fuller, Rice, Stackman, Reed, Caywood, Solar, Elmer, etc.   Were you one of the people Throop referred to? Who do you think those people are? And why are they uncomfortable?


February 17, 2015 2:19 PM – Gibson wrote an email to the department that really sheds light on what happened and is a must read (exhibit 643).

Deposition question for anyone in the department. Fuller, Rice, Stackman, Reed, Caywood, Solar, Elmer, etc.      Why did Gibson write “follow the bylaws?”  Had the department been disregarding bylaws?  Do you have any examples?    What fiascos do you think he refers to and how were bylaws not followed?    Who were the “few people” he refers to that made up the “process?”     Why do you suppose Gibson wrote “I worry about a department, administrator, or any organization that thinks so little of regulations, procedure, and process?”   He wrote that four out of five reasons personnel fail to follow regulations/orders were strongly in play and that the only reason not in play was “resource and time deficiency.”    Why do you think Gibson wrote to the dean and the entire department that lack of motivation, arrogance, corruption and  incompetence are strongly at play?   Do you know of any examples?   Gibson wrote that a large step in reducing the fear of giving public testimony would be discontinuing the practice, promotion, and tolerance of retaliation. This can be accomplished, in large part, by following and creating procedures, especially when it comes to personnel evaluations.   He seems to believe there is retaliation and corruption at play.  Do you agree?  What have you seen that suggests it is or is not in play?   .     


Q:  Why did Elmer write this email?  Why does he seem to distrust legitimacy of the process?

Lots of other questions in this mess.


How will the university ensure fair elections, searches and votes?





4/2/2015 4:30 PM -  Dkt 43-2 BENSKY EXHIBIT ZZZ – 001.   Dkt 41-41.  I sent an email to Dalecki (cc Lohmann, Shields, Throop, Lohmann and Decoste) asking if Dalecki told Throop that I cancelled classes on Dec 12, 2014 and other questions.  (Exhibit 652)  Dalecki did not respond to this email.

Nobody ever told me who reported that I cancelled class.  I didn’t find out until Throop’s deposition that she claimed that Rice had reported it.  Rice of course denied reporting it in her deposition.  This shows that Throop did not believe her accusation.

I asked Dalecki several questions that he never answered.  The fact that he didn’t answer my questions shows that he was hiding the truth from me.  He did not believe I had done anything wrong but was acting to enforce Throop’s gag-order on me.

One of the questions I asked was “Why did you not investigate this slander against one of your senior faculty members?”  The fact that he didn’t investigate shows that he didn’t knew I was right about the defamation and that the results of an investigation would support my claims.

I stated that Dalecki didn’t act on Lohmann’s recommendations.  This shows that Dalecki was not interested in setting right any wrongs to me but was interested only in shuting me up.

I made the claim that he had told others that I was faking my health issues and asked if it was true.  He did not reply.  This shows that he knew I was right and that he did not believe he was acting appropriately.


Q:  What are the answers to the questions in Burton’s emails?



4-28-15     Dkt 41-38.  Dkt 48-669  I received a letter from Chancellor Shields in the mail (exhibit 669), dated April 23, 2015, with his findings for my investigation requested on April 2, 2015.  I rebut the Chancellor’s findings in (exhibit 669a) and have some unanswered questions that could be used in depositions or discovery.  Needs finishing   I sent an email explaining the situation to Tim and Michele (Hawks 669b).     I plan to send a request to the Regents asking for a review of Chancellor Shields’ findings.  I may also ask them to review his findings from my grievance against Caywood if that would be helpful.  (I am waiting on this, showing great restraint)

 Q:  Answer Burton’s questions.




June 27, 2015 at 7:19:19 PM CDT – Lattis sent an email to Hawks (exhibit 682) about time slips saying “We recently learned that Dr. Burton submitted time slips for April in which she claimed no leave taken.  However, she was not cleared to return to work until April 17. She must resubmit time sheets as soon as possible showing sick leave for the first half of April. We have some strong guidance from the Board of Regents that we must ensure faculty members are claiming leave time when they are not working during a semester. Please have Dr. Burton contact John Lohman in Human Resources as soon as possible to make arrangements for correcting this error.”    First question that comes to mind is: Why is a lawyer getting involved in a simple clerical error?   Next question is: why does the lawyer feel that this issue is so important that she sends the communication about it to my lawyer?  Next question: why does she do so on a Saturday evening when she had just recently learned of it?    Who changed my entries? 

What was their motivation?   Was it to mess up my 50th birthday on Mon Jun 29th during my summer vacation hoping to provoke me to an angry act for which they could fire me?   It wouldn’t be the first time they used timing to maximize my pain.


In her email Lattis directed me to contact John Lohmann as soon as possible but John Lohmann was leaving the school’s employ on June 30th.  That gave me only one day, my birthday and his last day on the job, to even contact him about it.


I expect more of this type of harassment.

It seems that Lohmann is now the Special Assistant to the Vice Chancellor/Chief Business Officer at UWP:



6-28-15 – I sent a photo of the computer screen showing the Absence Request History on my account to Tim Hawks (exhibit 682a).  Note that it shows 8 hours on 4/1/15.  This had been changed from my previous entries that were approved by Jane Laufenberg in April.


Sun 6/28/15 8:09 AM – I sent proof that I had entered my leave correctly to my account (exhibit 682b) to preserve the evidence.

Sun 6/28/15 8:14 AM – I sent the information in (exhibit 682b) to Tim Hawks explaining that the administration went in and changed my records. I had everything entered until April 17.  So if there was a problem why didn't Jane contact me again as before? It's because they altered the records to build another fake case against me just like when they claimed I canceled class. They don't have anything real against me that is why they fabricate stuff. They are corrupt, deeply corrupt.



Sun 6/28/15 8:28 AM – I sent an email to Tim Hawks asking if I could send an email to jane Laufenberg.  He said I shouldn’t send the email so I did not, showing my great restraint.  In the email that I composed, but never sent, I wrote “My attorney was contacted by UW-System's lawyer this Saturday informing him that I made a mistake when filling out "no leave taken" for the remainder of April. I entered no leave taken for the time after April 17. If there was a question about my leave status why didn't you just contact me personally to give me a chance to make an adjustment where needed? Why was this forwarded to the legal department? This seems very odd.  Also, as the conversation below shows I did enter sick leave through April 17. When I logged in previously I saw it was all approved. Why now does it show a different record for April 1-6? Who changed it and why? I never claimed I was in during that time. I was on sick leave as all communication has shown.”

These may be some good questions to ask in deposition or in court.


6/29/15 at about noon I spoke with Tim on the phone about the incident, on my 50th birthday.

Mon 6/29/15 10:36 AM – Tim Hawks sent an email to Lattis which included the photo I had sent him earlier (exhibit 682a) and asked for clarification of a peculiar contradiction.    The email exchange between Hawks and Lattis is in (exhibit 682e). 


June 29, 2015 at 12:23:22 PM CDT -  Roger sent a picture (exhibit 682g) of the absence report to Tim Hawks.   My account had been changed again to reflect the correct leave time.  Somebody had changed it back.


June 29, 2015 1:27 PM - Lattis wrote “She (Burton) needs to claim sick leave for April 1 through April 16 (weekends excluded); probably one day at a time since it is difficult to figure out the multi day process and exclude weekends. They will, tomorrow, push back her April leave report and she needs to start over.” (exhibit 682e).


Monday, June 29, 2015 2:04 PM – I sent an email to Jane Laufenberg asking for assistance.  (exhibit 682f).

June 29, 2015 2:19 PM – Lattis wrote “I think they have figured it out and Sabina needs to do nothing.  It appears she filed more than one time sheet for the same period.  They have deleted the April time sheet with no leave claimed and substituted the other one.  Unless you hear otherwise from me, Sabina need do nothing further.  Phew.”    They only backed off because I had proof.  (exhibit 682e).

June 29, 2015 2:06:53 PM -  Laufenberg responded to my email with “HI Sabina – You are all set. The rest of April is considered your May leave (you’re on the 9 month academic payroll calendar). You already did your May leave report. Thanks for checking.” (exhibit 682f).





Q:   Why the HELL would the university attorney call Burton’s attorney about an administrative issue such as this?  What explanation could there be other than retaliation?  How were Burton’s records altered?  Who did it?


Are students at risk of this sort of cyber-crime?  How can the administration assure students that they are safe from this?





Click for  deposition questions for Caywood for his second deposition.


Draft Deposition questions for Throop

  (Lohmann Depo Questions)

 (Fuller Depo Questions)

 (Rice Depo Questions)

 (Stackman Depo Questions)


Click for Draft Deposition questions and other depo files:   Shields, Den Herder etc.  These files will be smoothed out for each individual prior to their deposition.  These questions give good indicators of what each individual has done to add to the problems



Sept 23, 2015 11 AM to 1 PM –   UWS601Complaintinvest-Barraclough -  I met with Barraclough for the investigation against me.  Also present were Tim Hawks and Jody McDermott, who took notes.  Barraclough audio recorded the meeting and sent me a link but the link doesn’t work.  Audio-UWS601Complaintmeeting  I have never been given Jody Mc Dermott’s notes.  The meeting went well with no real accusations against me sticking but almost a year later Chancellor Shields wrote that the allegations against me have merit, without saying what merit.

Q:  Please explain why Dr. Burton was not given the audio or the final results of the investigation.  


How can the university claim to be transparent when they conduct sham investigations such as this?




5-3-16 – Fairchild wrote a letter that denied my right to a grievance hearing.  (Fairchildrefusalletter) This refusal was based on the new Seriously Flawed and Discriminatory Grievance Hearing Procedures that were produced by Dr. Balachandran and attorney Stafford.  Dr. Balachandran is retired and atty Stafford will never be subject to the new policy.  So, the entire university is subject to procedures produced by two men who are not subject to its authority but it is used to deny Dr. Burton’s due process.


May 6, 2016 11:09 PM– I wrote an email to Mr. Fairchild about his refusal to hear my grievance.   I asked a lot of embarrassing questions.  (Re_ Fw_ DeniedGvncHrg-5-9-16)  This was cc’d to the Board of Regents.  (Shields-LOD-6-3-16-Attachments).   




Q:  On whose authority was this grievance hearing request denied?   Has the person who denied this grievance hearing been disciplined?

Why did Dr. Fairchild refuse to send this denial by email?  Is it because email is easier for Dr. Burton to forward by email?  Was it to delay Dr. Burton? 


Q:  Will the administration immediately invalidate the Seriously Flawed and Discriminatory Grievance Hearing Procedures that were produced by Dr. Balachandran and allow the faculty to produce their own grievance procedures as required by law?


Q:  How will the administration ensure that future complaints and grievances will be handled in accordance with law and policy that has been properly authorized?


Q:  Answer the questions in the May 6, 2016 email.





5-3-16 10:43 PM -  I 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)  I sent this email to many members of the board of Regents and to members of AFT.   I spelled out problems and asked for investigations.  On 6-20-16 they refused to investigate for bogus reasons.


6-20-16 – Board of Regents sent me an email response (exhibit RegentsResponse-6-20-16) with attached letter (exhibit Dr. Burton - 6-2016)



Q:  Why did the Board of Regents take over a month and a half to respond?  Why, when they finally did respond, did they refuse to investigate?   Why would the lawsuit cause them to ignore this request?


Does the corruption stop at Chancellor Shields or does it go higher?




Wed 9/21/2016 9:59 AM - ADA-accomodation-9-21-16   I sent an email to Crowley cc to:  Jennifer S. Lattis <>; Dennis J Shields <>; <>; Dale Burke <>; <>; Kim Kohlhaas <>; <>; Raymond Spoto <>; Staci Strobl <>; Jane Radue <>;  In which I explained that her persistent harassment was a violation of ATA law.   I asked some questions I did not expect to get any answers to.  Attached to the email was my letter from the doctor.  Med-Delay-Investigation


Q:  What are the answers to Burton’s questions?