Q: Was there any contemplation by APS of suing Laura and--oh, excuse me--suing Elliot and Jude for libel and slander before they filed their lawsuit? A: There may have been. I don't remember when the discussion started. Comment: In fact Ann Peterson faxed her approval to Pat Beyle on February 10 and the APS board voted to sue us on February 18, two days before we filed our lawsuit. ________________________________________________________________ Q: Okay. And now is the Exhibit 7 a fair and accurate copy of the HSUS report as submitted to the county commissioners in June of 2003? A: It--I'm assuming so. I mean that's what it looks like, and I haven't sat and compared it with the copy that I got. But it appears to be the Preliminary Report that we received at the end of June or beginning of July. ________________________________________________________________ Q: Okay. What other inaccuracies have you found in Exhibit 7? A: Well, there was--I remember discussing--and I can't say that I know for a fact that they are inaccurate. I just remember a discussion. On page 18 it says, "In numerous instances, animals were not given a physical exam until an adoption deposit had been placed on the animals or until the animals were scheduled to be transferred to a foster home." I know there was a discussion either at a board meeting or when some of us were over at the shelter talking to Laura and Claudia Shepherd about this report. I know that came up. Now--I remember discussing that. Q: And what was the discussion about that? A: The impression I have now--and I don't remember specifically. But the impression I had was that that was an unfair or inaccurate statement. Q: All right. And what was inaccurate-- A: I don't know. Q: --in that respect? A: I just told you I don't remember exactly. I just remember it coming up as being one of the things that Laura and Claudia felt--or at least it was my impression that they felt that that was not fair. Q: Do you remember what was inaccurate about when physical examinations of animals were performed? A: No, I don't. I don't recall. Q: Okay. Any other statements in Exhibit 7 that you think are inaccurate? A: No, not--I mean, there may well be some that are inaccurate, but those are the only ones that I recognize as I discussed with them. There may be others. I just don't have the information. Q: Okay. Has APS taken action against the HSUS for the inaccurate statements in Exhibit 7? A: The only action that I know of that was ever discussed was asking--was sending those--the records on what we felt were inaccurate about the vaccination wait times. I don't know whether the letter was sent. I know that we discussed having Laura send it to them and asking them for their justification for that, and whether she got that back or not, I don't know. Q: Okay. A: But other than that, we haven't taken any action. Q: Has APS filed an action for defamation or libel against HSUS for Exhibit 7? A: No. Q: Has that been considered by APS? A: No. Q: Why not? A: I don't know why not. I mean, I-- ________________________________________________________________ Q: Was the wildlife center able to continue to operate after Bobby Schopler left? A: We operated for a while, and we were attempting to get a federal license. And I felt that we would have ultimately gotten a federal license if some things hadn't happened that destroyed that. Q: What were-- A: So in-- Q: --the things that happened to destroy that? A: Bobby's employees out there were upset, and they called people in Washington where you get the federal license and told them things that I didn't feel were a fair representation. And as a result, they wouldn't consider giving us a license. Q: So did APS actually apply for a license? A: Yes. Q: And was turned down? A: That's my understanding. Q: And did the federal authorities give an explanation for declining to issue the license? A: I can't answer that because I didn't talk to them. Q: Okay. What did the employees represent to the federal authorities? A: They told them that we were taking in wildlife that we weren't supposed to be taking in because we didn't have the federal license, which wasn't--in my mind wasn't true. And the federal people--actually I did talk to one woman up--I take that back. I did talk to one woman up there, and she said, "We've gotten so many complaints from people at your wildlife place that we don't want to get involved." Q: All right. Who filed the application for a license? A: I believe Laura did. Q: And was that license to be issued in her name? A: You'd have to ask her that. I don't remember. I just know--having discussions with her about filling out the application. Q: Okay. And how do you know that the reports from the people who complained to the wildlife authorities were not true? A: How do I know they were? Q: Yeah. A: Because I talked to some of the--some of our employees, including Laura, including Darra. Q: Okay. So you-- A: There was one volunteer out there that I talked to. Q: Who was that? A: I can't remember her name. Q: Okay. So you relied on statements from Laura and Darra when you say that the reports from the employees were not true? A: Yes. Q: Okay. And did you consider Laura to be a credible person in making that report-- A: Yes. Q: --to you? A: Yes. Q: Even though you acknowledged that Laura had misrepresented what she had told you with regard to Bobby's staff performing surgeries; is that right? A: Yes. MR. MERRITT:I object to the form. Q: Okay. And even though there were other reports that you'd received about Laura making misrepresentations, such as about the dog with parvo, about the mislabeling of cages with pit bulls? A: I didn't consider those as misrepresentations by her. Q: Okay. But you had reports about that from other people who felt they were misrepresentations by her, didn't you? A: Sure. Pat Sanford. ________________________________________________________________ Q: So after Pat Sanford left, was there an occasion when Laura Walters reported that Pat Sanford had taken some files or computers with her? A: It wasn't just Laura. It was lots of people who reported that. Q: All right. And who else reported that? A: Some of the staff, some of the board members that were volunteers there. Q: Okay. And was that raised with Pat Sanford? A: There was a letter written to her. Q: Okay. And what did she respond, if anything? A: She denied it, but I don't remember whether it was--whether she wrote us back a letter or not. Q: Okay. Was there any further inquiry into it? A: Not that I know of. Q: Did she offer to come back and help you find the files or direct you to where the files were? A: I don't think so, but I don't remember. Q: Okay. And was there some concern expressed to Pat Sanford about her being on the premises after she was no longer Executive Director? A: I don't remember that. I don't remember. Q: Okay. You don't remember anything about allegations made to Pat Sanford that she was roaming around the shelter premises? A: I don't know. Q: Okay. A: I don't remember any of that. Comment: In fact Pat DID offer to help find the records but probably nothing was left after the "housecleaning" Laura was reported to have done. ________________________________________________________________ Q: And APS counsel, Ron Merritt, said that what Bobby was doing was illegal; is that right? A: What we determined after many months of discussions with the Vet Board was that we couldn't continue to do it and comply with the Vet Board requirements as we were at the time. Q: Okay. And-- A: Okay? Q: --nevertheless Laura wanted Bobby to continue to do it? A: She wanted him to continue and phase it out. Q: And that doesn't cause you any concern? A: It didn't cause me any concern because I felt like--it wasn't like we were committing an illegal offense or an act. It was a matter of sorting it out so that whatever system we did was in compliance with the Vet Board. Phasing it out didn't seem to be necessarily a bad thing to do, but Bobby didn't want to do it. So we said, "Fine. Don't do it." Q: Okay. Now, do you know whether Dr. D continued to perform spay/neuter operations on animals not owned by APS after Bobby was fired or resigned and before the lease arrangement was put into place? A: There was a time--and I don't--there was a time when we were doing none, and then Laura thought she had a system, two contracts, that worked. She told Dr. D to start doing the surgeries again. There was a short period of time when he did. When I found out what was going on, I said, "Laura, don't. We've got to go to the Vet Board first. Don't do it." So she called Dr. D and stopped it. Q: All right. Did it cause you any concern that Laura had instructed Dr. D to perform the surgeries before the status had been arranged so that you were assured that it would be legal with the Vet Board for him to do so? A: Some, yes. Comment: this doesn't quite jibe with Peterson's letter to the Vet Board shown later on this website. ________________________________________________________________ Q: Which staff members told you that they liked Laura? A: Nicole, for one. Q: Okay. Comment: In fact Nicole told both Jude Reitman and Cindy Bird that the staff all hated Laura but were afraid of losing their jobs. They wondered how they could confidentially convey this information to the BOCC ________________________________________________________________ Q: Does the board discuss any issues other than personnel issues, the lawsuit, or legal issues in executive session? A: Not that I recall. Comment: In fact many other things are discussed in executive session such as the bylaw change taking voting rights from the Membership. This was discussed at the October 2002 meeting despite assurance from Ronald Merritt who twice said "we have no intention". I was informed of the notice sent to the APS Board that the bylaws would be changed at that meeting and Pat Beyle lied to me about it. The Board voted in executive session that night to change the bylaws a few weeks later in a so-called public meeting that was never announced to the public, despite my request. 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