Paragon Kennels

My complaint is against Paragon Kennels Reg'd, ***. ***t is a Dog Breeder of Standard Poodles. We made contact with . ***t, CKC on July 11, 2017. Shortly, thereafter, we discussed (by phone) in great detail, the personality type we were looking for in a puppy. We have previously owned 2 Standard Poodles. Both dogs had very different personalities, but, the two Poodles had many similar breed standard traits. We wanted to do Obedience work with the new puppy, as we had with the first two.
The litter was born the first week of August 2017. Dogs cannot be shipped before they're 12 weeks old. (3 months)
. ***t and I spoke on the phone several times over the course of the 12 weeks. Very shortly before ***, the puppy, was shipped, *** told me of a behavior issue. She said the puppy spends a lot of time on her hind legs. She advised me that this was not good for her hips and I should discourage the behavior. That turned out to be a serious understatement!
The puppy arrived Nov 1. *** persistently jumped up on my husband and me, nipping/biting us almost constantly for a week. We tried every method of positive reinforcement training we had learned in the schooling of our previous two dogs (We trained them to levels of Show Competition; both had earned titles.) Nothing worked on this puppy! There was no, "willingness to learn, desire to please" in this pup. Not a good obedience dog in the making!
. ***t obviously knew of this behavior issue and DIDN'T or COULDN'T correct it before she shipped ***, Nov. 1. After the week, we couldn't stand it any longer and advised *** we were shipping *** back to her, Nov. 11. . ***t did email me to say the puppy was safely home as I requested. That was the LAST I heard from ***.
I called a few days later and got no answer....went to message after 3 rings; no longer about 10 rings before message. I realized she was screening her calls. After a few attempts, I did leave a message a few days later. I asked her to call me and indicated I would like a refund of my $1,500.00. Shipping charges both ways were my responsibility and the deposit I knew would be forfeit. I did NOT receive a suitable puppy and diven . ***t's experience, she had to know this.
I sent an email November 18th to . ***t explaining the unsuitability of the puppy. I, again, requested a refund of my $1,500.00.
I have not received a reply to that communication either. I feel this is no way to treat a customer who has acted in good faith and trusted her. I believe she sent me a puppy with a serious behavior issue that she knew about and COULDN'T or DIDN'T address before selling her to me. I would have preferred her to tell me she didn't have a suitable pup for me.
I have enclosed copies of supporting receipts and communications. Thank you for your patience.
Yours truly