PATRICIA SONS BISWANGER Adtuney are 358 Sou Manos and, Havertowe, ZA 15089 620.505.0687 dirext 966.751.9601 fax peshinrangermgmadlcom patrisisblewanger com May 24, 2015, Vin fas to. 717-772-4552 Sisen Dooooys,Desser “PURE Bust obey Los Baer Pennsylvania Deparmenrotagic J dey. VE ran ton Gorcne nee Ko! Hovabre PA Tio ‘ re: We Love Rescue Pets gaat Kennel License No. 3940 [Dear Ms Donayer AS you know, this office represents We Love Rescue Peis, Inc. (“WLRP") and its owner, Michael Gill. Please direct all finure correspondence fo this afice. We call your atention 10 hice issues that WLRP has withthe Bureau. 1, Please refrain from fulfilling any future Open Records Law requests We request that you feu ftom flfilling ny requests under the Open Records Law regarding WLRP. As you are aware, WLRP is the subject of an ongoing campaign of harassment and lfamation that has eselated to treats oF physic! violence ‘Accordingly, pursuant 19 Section 708(4)() of the Open Records Act, we request that no funher requests for documents relating to WLRP be honored, because such disclosure is reasonably likely to result ina substantial and demonstrable risk of physical ham to or the personal secuity fof persons associated with WLRP, particularly Michael and Deaise Gill and their young daughter.ruten Dov Sy 24,2015, Pope2es 2. Please acknowledge that WLRP is property classified as a Non-Profit Keanel We write ia response tothe Notice of Violation dated May 12, 2015 (Ihe “Notice”), According to the Notice, WLR? is required to obtain a "K” class pet shop-lype Kennel Hoonse, Further according to the Notice, WLRD ia required to make thie appicason by Tuesdsy, May 26, 2015. Please be advised thar WLRD hereby invekes its right, as set forth in the concluding passage of the Notice, to inform the Bureau that we believe shat st has rezeived the Nose in er, fr the following reasons. + WLEP is recognized a5 a nonprofit organization pursuaat to 26 U.S.C. § 501(0\3) by the Inetnal Revenue Service, The Bureas lacks the power to challenge that designation, and any atcmat to do so would conflict with federal las, which would therfore preempt tis Bureau's decision. ‘+ WLRP is incorporated in the Commonsvealth of Peansylvania as a domestic nonprofit entity, Accordinely, WLRP fits the defintion of a nouprotit kemael "A Eenael registered under the law of this Commonwealth as » nonprofit enity or a noaprofit sninial conol kennel under sections 901 and 1072” +A pet shop kennel is defined by the Dog Law as one shat “acquires and sells dogs forthe purpose of resale, whether es owner, agent or consignee, and sells or offer to sell such dogs ona retail basis” © WLRP does not self dogs, ust ike every other rescue in the Commonwealth of Pennsylvania, WLR charges ax adoption fee. That fee ranges fiom $0 to $750, enending on the age, heel, and general devisabiity of the doe (© Fast like every other rescue in the Componweath of PeansyWvania, WLRP plows {he adoption fees back into is operations” No profit is earned or retained, and in fact WLRP spends an exorbitan sum on veterngry bils for dogs for which it charges no adoption fee a al, just to get the dog a home. LWLRP is present 2 licensed nonprofit reseue and kennel that operates ‘fom a location in Media, Deleware County, Peansyivania. This isthe comect designation, aad there is no reason for it to apply for anew license specifying any other designation 3. Please rescind the April 13, 2015 Kennel Inspection and remove it from the public eee Furie, we request thatthe Apeil 13, 2015 Kem Inspoction be taken down fom your website Tes incor in stating tat the owner filed to obtain the proper license, and, as more filly set forth in my leer dated April 14, 2015, a copy of which is atashed hereto, it is incorectKruten Donmeser Sav 26.2015, Page sors regarding the six week old puppies. This Kennel Inspection is highly deleterious to WLRP, and is being used by persous who harass and defame WLR? in furtherance of thes campaizn against ‘WLRP. Therefore itis essential that this Kennel Inspection be remaved ffom the public recar. 1am available to tlk to you or one of your attorneys about these three issues any time at your ‘Thank you for your very kind time and attention. Sincerely, Patricia Bigwanger ia Patricia Sons Biswanger