Summary of information which can be validated with Facebook messages:
Early December 2015 Defendant had a friend wanting to sell a gold female yorkie (Nutmeg "Meg") which was AKC registered for a settled price of $1200. At that point Defendant indicated the friend might consider me if Meg was staying forever. Plaintiff noted she was planning on keeping Meg but it depended on the money. This amount was paid with a receipt from Paypal. Defendant noted Meg's offspring were selling for $1850 each. Defendant continued to indicate she could not get the papers at the moment but was going to get them as soon as possible and send them to me – by Christmas. The conversations continued between the Plaintiff and Defendant about receiving the paper work. The Defendant stated she produced Meg and knew her sire and dam. Plaintiff continued to purchase dogs from the Defendant. In February Meg was bred and, although Plaintiff had tried to sell Meg back to the Defendant, she did not have the funds for the transaction. The Plaintiff told the Defendant she was keeping Meg and needed the paperwork. The Defendant would not provide the name of the official/registered owner so the Plaintiff could contact her about the paperwork. The conversations continued until Plaintiff was going to sell Meg due to illness and the need for money, but then the Defendant stated she was not going to provide the papers because the Plaintiff had promised to keep Meg forever, and the Defendant didn't want her to go to another breeder. Plaintiff has never received either the AKC paperwork or the name of the dam and sire so Meg could be registered and her two pups could have been registered. This cost me approximately $800 due to not selling with registration paperwork.
Coercion and harassment:
Facts about returning Meg, Biewer yorkie (Cara) pregnant, Brindle colored AKC Miniature Poodle (Jolie) and puppies, Parti-colored yorkie (Barbie)
At one time I agree to sell the Defendant the dogs but she did not have the money. Then Defendant started to become what I perceived as belligerent. At this time Defendant had another one of my females, Coco Chanel, who had been transported to the Defendants home for breeding purposes. Plaintiff was ill and trying to focus on new drug therapies while being stressed with the harassment from the Defendant, but also fearful Coco Chanel might not be returned or returned in an unsuitable condition (which was the case).
After continuing to request the paperwork for Meg, Defendant continued to harass me. After repeated request to take a picture of Coco Chanel, even with a camera phone, to ensure she was safe and actually still with the Defendant she took a blurry picture and sent it to me. At the same time Defendant was belligerent and outspoken about the Plaintiffs need to see Coco Chanel. After all of this I could not take any more of her harassment and I felt coerced to make up an agreement so she would leave me alone. Plaintiff developed a contract out of harassment and coercion which stated:
We will consider this then a binding contract: Elaine Townsley will return the dogs known as Meg, Barbie, Cara, and Jolee with her puppies for the sum of $1500 to be paid by August 29, 2016. In return Kimberly Orange-Lay agrees to pay for the transportation of Meg, Barbie, Cara, and Jolee and her puppies to your home, and will pay for the transportation to return Coco to the home of Elaine Townsley.
Defendant agreed on this contract. Plaintiff would never have written this out except for being ill and the Defendant's continual show of coercion and harassment causing the Plaintiff mental and emotional distress.
All dogs were to be transported to the Defendants home on June 14, 2016 with the exception of Meg. On June 13, 2016 something got into the Plaintiffs' fenced-in backyard and attacked Meg. Meg received emergency care and treatment along with continued follow-up treatment for many wounds, possible rabies, etc. The vet can provide a statement on Meg's medical condition if needed. Cara a Biewer yorkie (pregnant with 3-5 puppies), Jolie a poodle with five yorkiepoo pups, and Barbie transported to Defendants' home June 14, 2016. There has been no exchange of money as stated in the coerced contract.
I still have not received the registration paperwork for Meg but I would like to have them at all possible so I can register her and her puppies.
Kimberly Orange Lay Reviews
Summary of information which can be validated with Facebook messages:
Early December 2015 Defendant had a friend wanting to sell a gold female yorkie (Nutmeg "Meg") which was AKC registered for a settled price of $1200. At that point Defendant indicated the friend might consider me if Meg was staying forever. Plaintiff noted she was planning on keeping Meg but it depended on the money. This amount was paid with a receipt from Paypal. Defendant noted Meg's offspring were selling for $1850 each. Defendant continued to indicate she could not get the papers at the moment but was going to get them as soon as possible and send them to me – by Christmas. The conversations continued between the Plaintiff and Defendant about receiving the paper work. The Defendant stated she produced Meg and knew her sire and dam. Plaintiff continued to purchase dogs from the Defendant. In February Meg was bred and, although Plaintiff had tried to sell Meg back to the Defendant, she did not have the funds for the transaction. The Plaintiff told the Defendant she was keeping Meg and needed the paperwork. The Defendant would not provide the name of the official/registered owner so the Plaintiff could contact her about the paperwork. The conversations continued until Plaintiff was going to sell Meg due to illness and the need for money, but then the Defendant stated she was not going to provide the papers because the Plaintiff had promised to keep Meg forever, and the Defendant didn't want her to go to another breeder. Plaintiff has never received either the AKC paperwork or the name of the dam and sire so Meg could be registered and her two pups could have been registered. This cost me approximately $800 due to not selling with registration paperwork.
Coercion and harassment:
Facts about returning Meg, Biewer yorkie (Cara) pregnant, Brindle colored AKC Miniature Poodle (Jolie) and puppies, Parti-colored yorkie (Barbie)
At one time I agree to sell the Defendant the dogs but she did not have the money. Then Defendant started to become what I perceived as belligerent. At this time Defendant had another one of my females, Coco Chanel, who had been transported to the Defendants home for breeding purposes. Plaintiff was ill and trying to focus on new drug therapies while being stressed with the harassment from the Defendant, but also fearful Coco Chanel might not be returned or returned in an unsuitable condition (which was the case).
After continuing to request the paperwork for Meg, Defendant continued to harass me. After repeated request to take a picture of Coco Chanel, even with a camera phone, to ensure she was safe and actually still with the Defendant she took a blurry picture and sent it to me. At the same time Defendant was belligerent and outspoken about the Plaintiffs need to see Coco Chanel. After all of this I could not take any more of her harassment and I felt coerced to make up an agreement so she would leave me alone. Plaintiff developed a contract out of harassment and coercion which stated:
We will consider this then a binding contract: Elaine Townsley will return the dogs known as Meg, Barbie, Cara, and Jolee with her puppies for the sum of $1500 to be paid by August 29, 2016. In return Kimberly Orange-Lay agrees to pay for the transportation of Meg, Barbie, Cara, and Jolee and her puppies to your home, and will pay for the transportation to return Coco to the home of Elaine Townsley.
Defendant agreed on this contract. Plaintiff would never have written this out except for being ill and the Defendant's continual show of coercion and harassment causing the Plaintiff mental and emotional distress.
All dogs were to be transported to the Defendants home on June 14, 2016 with the exception of Meg. On June 13, 2016 something got into the Plaintiffs' fenced-in backyard and attacked Meg. Meg received emergency care and treatment along with continued follow-up treatment for many wounds, possible rabies, etc. The vet can provide a statement on Meg's medical condition if needed. Cara a Biewer yorkie (pregnant with 3-5 puppies), Jolie a poodle with five yorkiepoo pups, and Barbie transported to Defendants' home June 14, 2016. There has been no exchange of money as stated in the coerced contract.
I still have not received the registration paperwork for Meg but I would like to have them at all possible so I can register her and her puppies.