no safe shelter - animal legal defense fund...prosecuting hoarding cases can leave animals...

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If you think this is a slam dunk for a convic- tion, think again. The Patty’s Angels case demon- strates how one hoarder can manipulate the system and keep animals in a persistent state of suffering. Abezis hired and fired legal counsel, impeded the ability of the court to set hearing dates, and then, ALDF seeks justice against animal hoarders W hen hoarders take root in a com- munity, the result for their ani- mals is always suffering and hard- ship. That’s definitely the case with “Patty’s Angels,” a hellish, self-described “animal shelter” in Accord, New York, where owner Patty Abezis and her employee Tracey Ann Pennington were found guilty on dozens of ani- mal neglect charges earlier this year. But the case goes all the way back to 2002 and highlights one of the major problems facing ALDF in tackling the crisis of animal hoarding: as we have seen so tragically with Patty’s Angels, lengthy delays and the difficulty associated with prosecuting hoarding cases can leave animals lan- guishing helplessly in appalling conditions for months, even years, as the case awaits trial. When Abezis was arrested back in December 2002 on charges of drunk driving, local authori- ties were concerned that there would be no one on site at her “shelter” to care for her animals. So, an Ulster County SPCA (USPCA) official went to the Abezis property to investigate. When he stepped inside, he grabbed a video camera to document the appalling conditions the animals there were enduring. In all, approximately 90 dogs and 24 cats were living in small, filthy stacked cages and crates, standing and lying in their own excrement, visibly emaciated with open wounds. One cat lay dead. The USPCA took the evidence to the Ulster County District Attorney’s office, which filed 38 charges of animal cruelty against Abezis and Pennington. Fall 2005 Volume 24 Number 2 A NEWSLETTER FOR SUPPORTERS OF THE ANIMAL LEGAL DEFENSE FUND INSIDE: Another Win for Sanford, N.C. Dogs See Page 5 No Safe Shelter Continued on page 4 Life in a lonely, filthy cage at Patty’s Angels

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Page 1: No Safe Shelter - Animal Legal Defense Fund...prosecuting hoarding cases can leave animals lan-guishing helplessly in appalling conditions for months, even years, as the case awaits

If you think this is a slam dunk for a convic-tion, think again. The Patty’s Angels case demon-strates how one hoarder can manipulate the systemand keep animals in a persistent state of suffering.Abezis hired and fired legal counsel, impeded theability of the court to set hearing dates, and then,

ALDF seeks justice againstanimal hoarders

When hoarders take root in a com-munity, the result for their ani-mals is always suffering and hard-ship. That’s definitely the case

with “Patty’s Angels,” a hellish, self-described“animal shelter” in Accord, New York, whereowner Patty Abezis and her employee Tracey AnnPennington were found guilty on dozens of ani-mal neglect charges earlier this year.

But the case goes all the way back to 2002 andhighlights one of the major problems facingALDF in tackling the crisis of animal hoarding:as we have seen so tragically with Patty’s Angels,lengthy delays and the difficulty associated withprosecuting hoarding cases can leave animals lan-guishing helplessly in appalling conditions formonths, even years, as the case awaits trial.

When Abezis was arrested back in December2002 on charges of drunk driving, local authori-ties were concerned that there would be no oneon site at her “shelter” to care for her animals. So,an Ulster County SPCA (USPCA) official wentto the Abezis property to investigate. When hestepped inside, he grabbed a video camera todocument the appalling conditions the animalsthere were enduring. In all, approximately 90dogs and 24 cats were living in small, filthystacked cages and crates, standing and lying intheir own excrement, visibly emaciated with openwounds. One cat lay dead. The USPCA took theevidence to the Ulster County District Attorney’soffice, which filed 38 charges of animal crueltyagainst Abezis and Pennington.

Fall 2005Volume 24 Number 2

A NEWSLETTER FOR SUPPORTERS OF THE ANIMAL LEGAL DEFENSE FUND

INSIDE:

Another Win for Sanford, N.C.Dogs

See Page 5

No Safe Shelter

Continued on page 4

Life in a lonely, filthycage at Patty’s Angels

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2

Fall 2005

Katrina’s Other Victims Most of us could only watch in horror as, day after day, the news reports came out about the

devastating impacts of Hurricane Katrina. Worse than the natural disaster was the distress-ing realization that it took so long to send help to those who were desperately in need. I was sad-dened and angered to see so many humans suffering and, because my constituency is the animals,it was very distressing to see how thoroughly official policies failed the countless animals who wereleft behind, helpless, during this time of crisis.

When the media belatedly focused on the animal victims of Katrina, over and over again, weheard about how their guardians were forced to evacuate and abandon them. Literally thousandsof animals were abandoned. It sickens all of us to think of their suffering...and their fates. Here atALDF, employees flew in to Louisiana to assist in search and rescue efforts, as did almost all of ourvolunteers from the Sanford, N.C. facility housing the dogs rescued from the Woodleys. ALDFalso donated critical supplies and researched legal issues that the rescuers faced, posting answers tofrequently asked questions on our web site. The sad fact is that this disaster overwhelmed theresources of all of us put together. We thank the many, many animal protection organizations andcaring individuals who helped and are still working to help these animals. But, what can we learnfrom this experience?

First, most of us have always assumed that if a disaster strikes, our federal and state governmentswill send help. In the America that I grew up in, that’s the way it was. What happened in com-munities along the Gulf Coast says otherwise--and that’s just plain wrong. It is up to us to raise astink and ask pointed questions of our local, state, and federal government.

Second (and this is nothing new), the well-being of animals wasn’t even on the radar. Reliefworkers who finally arrived to help the humans were told to order them to abandon their com-panion animals. We need to work more closely with and educate governmental agencies andhuman relief organizations, because abandoning animals should never be the answer. On Sep-tember 22, Rep. Tom Lantos introduced the Pets Evacuation and Transportation StandardsAct of 2005, H.R. 3858, to ensure that disaster relief plans include planning for companionanimals. Please contact your representative in Congress and urge him or her to vote for thisimportant bill.

Finally, each one of us needs to develop our own individual disaster preparedness plan. If a dis-aster strikes in your community, how will you get all of your family members, two-legged andfour-legged, to safety? How will you avoid being separated from them? When you finish readingthis newsletter, start developing your plan: check web resources, check with local agencies for whatinformation they offer, find out what supplies you need to keep in your home, and plan yourescape route. Do it now; do it for yourself and for those you love.

For the animals,

Joyce TischlerFounder/Executive Director

For the RECORD

“The losses of life and propertywere simply staggering, andon top of all that,the sight of evacuees choos-ing betweenbeing rescued or remainingwith their pets,perhaps evenhaving to leavebehind thetrained and faithful helpinganimals thatsome people with disabilitiesrely on every day,was just heart-breaking,”

—Rep. Tom Lantos,

D-San Mateo, September 23, 2005,

San Francisco Chronicle.

Letter from theEXECUTIVE DIRECTOR

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Unanswered Calls forHelp Lead to DirectAction from ALDFWhen continued calls to the Albany, Oregon

District Attorney’s office went unan-swered, Cat Champion Corp. (CCC), a smalllocal non-profit group in Linn County, Oregon,called ALDF for help. The CCC had been tryingin vain for more than a year to resolve the legalstatus of 11 cats rescued from abhorrent localhoarding conditions.

“This was a double call for help,” says ALDFSenior Attorney Dana Campbell. “Without a clar-ification of ownership, it was impossible to re-house the cats, many of whom were suffering frommalnutrition, skin conditions, and upper respira-tory disorders from their ordeal. And with theCCC acting as temporary custodians, they wereunable to care for other animals who needed help.”

When the case was dismissed early in 2005 bythe less than helpful District Attorney’s office, anopportunity was created for ALDF to work close-ly with the local sheriff ’s department to resolvethe issue.

ALDF stepped in to file an innovative motionfor a protective order for the animals. Workingwith the complete cooperation and enthusiasm ofthe sheriff ’s office and the county clerk’s office,ALDF attorneys set about interviewing the sher-iff ’s deputies who conducted the criminal animalneglect investigation, and then prepared their affi-davits. ALDF and CCC are now only waiting forthe judge to sign the Order which asks him toconsider the best interests of the cats alongsidethe interests of the defendant.

“Hopefully very soon, the CCC will be able tofind good homes for these cats and go on to helpother animals in need,” adds Campbell.

ALDF Animal CrueltyExperts Speak Out

We’re working as closely as ever with lawenforcement communities around the coun-

try – but this fall ALDF takes law enforcementagency education to a new level. With “Investigat-ing & Prosecuting Animal Cruelty Cases”, a two-day seminar co-sponsored with the WhatcomCounty Sheriff ’s Department in Bellingham,Wash., ALDF for the first time will be reaching allregional law enforcement agencies in one coordi-

nated event. Attendees will include local police,sheriff ’s office, the District Attorney’s office, andrepresentatives from the Humane Society.

“We’ve conducted more than 50 law enforce-ment seminars from coast to coast, but this really isa first of its kind initiative that we hope willbecome the model for education going forward,”says Dana Campbell, ALDF senior attorney. “Inthe past we’ve focused efforts on educating agencieson a one-on-one basis. But bringing everyonetogether offers great operational efficiencies andalso allows us all to learn from each other in onecohesive environment.”

Designed for Whatcom and surrounding coun-ties’ law enforcement and animal welfare commu-nity workers, the seminar will feature DanaCampbell, Pam Frasch, director of ALDF’s Anti-Cruelty Division, Penny Cistaro, executive directorof Whatcom Humane Society, and Al Brantley,formerly of the Federal Bureau of Investigation(FBI). Subject matter will include a discussion ofthe link between violence against animals and vio-lence against humans, an in-depth study of Wash-ington’s animal cruelty laws, and an in-depthexploration of protocols and process tips, includ-ing: investigation techniques; how to document acase; what to charge; and factors for plea bargainsand jury selection. ALDF will also offer attendeesa detailed overview of the many services and toolsavailable to prosecutors and the animal communi-ty, as well as the particulars on handling specialcases, including hoarding. Visit www.aldf.org formore information.

3Animal Legal Defense Fund

BRIEFS…

Pam Frasch and DanaCampbell of ALDF’s

Anti-Cruelty Division

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4

Fall 2005

rific conditions. Clearly, urgent action was neededto help these animals and, thanks to the interven-tion of an Ulster County resident who calledALDF in the spring of 2004, we got involved tomove the case forward.

ALDF sent its attorneys, Len Egert and AmyTrakinski, to investigate conditions at the Patty’sAngels facility, and they immediately set towork collecting evidence and information tohelp convince the Ulster County District Attor-ney’s office that the time for serious action hadcome. They worked with the DA’s office toexplain the true problem of animal hoardingand the extreme likelihood the animals wouldcontinue to suffer if they were not removedfrom Abezis’ custody. ALDF also mounted anintensive campaign to publicize the case, work-ing with local newspapers to report on theongoing conditions at the shelter and with localresidents who had collected their own evidencedocumenting the shocking neglect.

This past April, the criminal trial finallybegan, and ALDF worked with the DistrictAttorney’s office to have every last animalremoved from Abezis’ custody. The animals arenow getting the medical attention and tenderloving care they deserve from dedicated veteri-narians and foster families. Just before thisnewsletter went to press, Abezis and her employ-ee Pennington were sentenced to three years pro-bation, limited to having only two dogs, andordered to forfeit all of the animals. Abezis mustalso submit to a psychological evaluation. How-ever, in the likely event of an appeal, there will bemore delays negatively affecting these animalsand their foster situations with Accord area ken-nels and foster families, who are burdened withthe ongoing cost of care. ALDF will be there onbehalf of these abused animals until this impor-tant victory is finalized.

“Animal hoarding cases are up more than 150percent in the last few years,” says Joyce Tischler,ALDF’s executive director, of situations like thePatty’s Angels case. “We help every single timewe can, but fighting legal cases like this costsmoney, and we’d never be able to do it withoutthe ongoing support of our many volunteers anddonors around the country. A special thank yougoes out to our many friends who help howeverthey can.”

alleging that she was being harassed, she won acourt order that significantly limited the USPCAand law enforcement’s ability to check the livingconditions and health of animals on her property.Her shenanigans tied up the legal process for closeto 18 months, during which time her dozens ofdogs and cats continued to endure the same hor-

No Safe Sheltercontinued from front page

Another victim of animalhoarder Patty Abezis

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5Animal Legal Defense Fund

ALDF Drafts Model Law to Protect Animals

Intensive work by a team of ALDF litigation specialists has resulted in the cre-ation of a model Animal Cruelty Civil Injunction Act aimed at making it easier

for district attorneys, legal professionals, and state legislators to easily affect pro-gressive change in animal law statutes. Based on precedent-setting work in the caseof ALDF v. Woodley, Sanford, North Carolina, where ALDF brought civil pro-ceedings against local animal hoarders and won custody of more than 300 serious-ly sick dogs, the model law includes provisions for a civil right of action for anyconcerned individual, individuals, or parties seeking to enjoin an act or acts of ani-mal cruelty. The Act also provides remedies, including enabling rescuers to gaincustody of and provide veterinary care for abused animals and requiring the abuserto pay for the animal’s medical and caretaking costs. To see the model Animal Cru-elty Civil Injunction Act in its entirety, check out the “Laws and Legislation” pagein the Resources section of our web site, www.aldf.org.

STOP THE PRESSES!

Another ALDF Victory for Sanford DogsGood news just in from our legal team and

frontline volunteers in Sanford, N.C., wherein a Lee County District Court hearing, JudgeAlbert Corbett, Jr. approved a request by ALDF toallow veterinarians to treat a dozen seriously illdogs who were rescued from the Sanford propertyof convicted local animal hoarders Barbara andRobert Woodley. Back in March, Judge Corbetthad found the Woodleys guilty of multiple countsof animal cruelty and ordered the removal of all oftheir more than 300 animals — many of whomhad been living in their own excrement and urine,denied appropriate human contact and care, andkept for their entire lives in tiny crates. Custodywas awarded to ALDF, which continues to housethe dogs at their temporary shelter in Sanford—the Halls of Hope — and in the loving homes offoster families. Recently, however, ALDF had beenforced to delay vital veterinary care and initiate a formal court hearing while the defen-dants and their lawyers refused to respond to requests to approve the desperately neededsurgeries while the case is being appealed.

Along with granting ALDF’s recent motion for the surgeries, which addressed painfuland potentially life-threatening conditions including chronic bleeding, cancers, and tes-ticular and mammary tumors, Judge Corbett has instituted a new procedure to expeditetreatment of sick dogs in the future. He also granted a second motion brought by ALDFto severely restrict the defendants’ rights to visit the dogs at the Halls of Hope, after anALDF representative testified that Barbara Woodley continued to abuse the dogs evenon her visits to the shelter, and that Woodley threatened and harassed volunteers work-ing to rehabilitate them.

“This is fantastic news, for the dogs and for our trusted, beloved volunteers,” saysBruce Wagman, Director of Litigation, ALDF. “The dogs have suffered enough – andwe weren’t going to stand by and leave our Halls of Hope staff and volunteers to facefurther abuse from Barbara Woodley. We’re thrilled Judge Corbett felt obligated to actin the best interests of the animals and our shelter efforts.”

Thanks andTribute toMadeleineALDF has supporters, friends, and

generous donors across the coun-try from all walks of life, but once in awhile, we get a letter that makes usstop what we’re doing and give an extramoment of thanks. One such letterarrived from Barbara Bemelmans, whoshared the sad news of her motherMadeleine’s passing and an incredibletale about a woman who marched toher own, marvelous drummer.

Madeleine was married to authorLudwig Bemelmans, who wrote thepopular Madeline series of booksabout the adventures of a young girlin a convent school. She—and laterher daughter, Barbara –served as theinspiration for the series’ spunky titlecharacter. A long-time supporter ofALDF, Madeleine led a fascinating,passionate, and giving life. Afterleaving the convent herself, shebecame a model, she worked in aplant building aircraft during WorldWar II, and then she gained herdegree at Columbia University.Always willing to make a statementand try new things, she became avegan in her thirties and remainedone for life. Working with ChristineStevens, Madeleine was also instru-mental in the passage of theHumane Slaughter Act in the 1950sand served as president of the Societyfor Animal Protection Legislation forthirty years. A tireless campaigner foranimal rights, she was also a lovingfamily woman, helping to raise herbrother’s three sons and her owngrandchildren. She died at the age of93 and will be sorely missed.

Dogs rescued from the Woodleys get a new start

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6

Fall 2005

The defense never rests. 2004 was an active,engaged, and busy year. ALDF’s hard-hitting workfor animals included:

ZERO TOLERANCE FOR CRUELTY CAMPAIGN

In 2004, ALDF’s Anti-Cruelty Divisionwas busy again, tracking hundreds of casesand frequently stepping in to offer lawenforcement officials expert advice. By theend of the year, ALDF staff offered assis-tance and support in more than 600 cru-elty cases. In addition, ALDF was signif-icantly involved in several high profileand difficult cases. For example, in thePatty’s Angels hoarding case in upstateNew York, ALDF agents went to the communityand worked closely with the local humane societyand prosecutor to pursue criminal cruelty charges.The hoarder was convicted of 38 counts of cruelty.

In addition, ALDF continued to educate lawenforcement officials, related agencies, law stu-dents, attorneys, and the general public throughongoing seminars and classes. Seminars havefocused on how widespread animal cruelty is andthe need for aggressive enforcement of anti-cruel-ty laws, how-to’s on prosecuting cruelty cases,particularly those involving animal hoarders, andthe link between animal abuse and violencedirected at humans.

The division also developed and published aprimer for attorneys on how to effectively assistprosecutors of cruelty cases and a report analyzingthe impact that enhanced anti-cruelty penaltieshave had on the number and quality of animalcruelty prosecutions. All of these resources, plus

tips on how to take action, are available atwww.aldf.org.

ALDF’s Anti-Cruelty Division works toensure that anti-cruelty laws are not

only enforced, but updated andimproved. In 2004, the divisionhelped to draft language to improve

South Carolina’s protection laws, solveda significant problem with the criminal

penalty provision of Maine’saggravated animal cruelty

provisions, helped draft anti-hoarder language for

Wyoming legislation, andprovided legal research and

counsel on proposed legisla-tion to improve anti-cruelty laws in anumber of other states.

PROTECTING DEFENSELESSANIMALS – ALDF V. WOODLEYALDF used a section of North Carolina’s civilcode to enjoin cruelty being committed by a cou-ple who were hoarding hundreds of dogs andsome birds. In late 2004, ALDF obtained a pre-liminary injunction against the hoarders and wasable to remove the approximately 100 animalswho were in need of the most critical medicalcare. Following the filing of ALDF’s lawsuit, andbased on the evidence of cruelty gathered byALDF, the local prosecutor filed cruelty charges.In early 2005, ALDF was granted a permanentinjunction and given custody of all of the animals(more than 300 in all, including pregnant dogs).

BUILDING THE FUTURE OF ANIMAL LAWThrough the Animal Law Program, ALDF con-tinued to help introduce Animal Law classes inlaw schools and to encourage the formation ofstudent groups. There are now 65 Student AnimalLegal Defense Fund (SALDF) chapters in lawschools (including two international chapters),and 59 law schools (up from 45 in 2003) thatinclude animal law as part of their curricula.

In the fall of 2004, ALDF, in conjunction withYale Law School, presented “The Future of Ani-mal Law” – a conference that attracted many ofthe best minds in animal law and helped toencourage the development of Animal Law class-es and legal scholarship in the field.

The Year in Review

report

ANNUAL

’04To protectthe lives and advancethe interestsof animalsthrough thelegal system.

—ALDF’s Mission

Yale Law School

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7Animal Legal Defense Fund

SUPPORTING ANIMAL ADVOCATESThrough its Project and Litigation Review Com-mittee, ALDF provides thousands of dollarsannually to attorneys working on important ani-mal law cases across the country. In 2004, ALDFalso provided 10 grants to attorneys handlinglawsuits that promote animal protection.

PROVIDING LEGAL EXPERTISE INCUSTODY & DAMAGES CASESALDF regularly files amicus curiae (friend of thecourt) briefs to provide courts with an analysis oflegal issues concerning animals. In particular,ALDF submits amicus briefs in cases where amajor issue is the measure of damages available tothe guardian of an animal who has been injuredor killed and in cases in which guardians are liti-gating over the custody of their animal.

EDUCATING THE PUBLICContinuing public education is critical to

changing the face of animal law. This processtakes many forms, including ALDF public edu-cation mailings, the quarterly Animals’ Advocatenewsletter, and our web site, www.aldf.org. Thesite, continually updated, offers legal information

and resources on a wide variety of topics includ-ing estate planning for companion animals, infor-mation for caretakers of animals who have beeninjured or killed, landlord/companion animalissues, losing a best friend (death of an animal),and much more. The site also features a wealth oflinks and resources for the attorneys handlingsuch cases (recovery of damages, establishing ananimal’s “value,” etc.). The Animals’ Advocate, andALDF Update, an animal law-focused publicationfor legal professionals, continue to effectively getour message of animals’ rights to protectionthrough the legal system to our supporters and tothose in need of help.

CURRENT ASSETS

Cash and cash equivalents $1,069,128 Investments 2,303,332Accounts receivable 101,803 Prepaid expenses and other current assets 273,855 Total Current Assets $3,748,118

NONCURRENT ASSETS

Property and Equipment, net $28,670 Total Noncurrent Assets $28,670

$3,776,788LIABILITIES AND NET ASSETS

Current liabilities:Accounts payable and accrued liabilities $179,039Trust deposits and other liabilities 36,934

Total Current Liabilities $215,973Net assets:

Unrestricted 3,508,861Temporarily restricted 51,954

Total Net Assets $3,560,815$3,776,788

SUPPORT AND REVENUE

Donations $2,804,961 Foundations and estates 724,227 List rental 60,137 Interest and dividends 56,722 Unrealized gains (losses) on investments (123,935)Realized gains (losses) on investments 267,047Other 28,863 Total Support and Revenue $3,818,022

EXPENSES

Programs:Legal $1,350,323 Public Education 1,053,353

Administration 101,778 Membership development 567,013 Total Expenses $3,072,467Increase in unrestricted net assets 745,555 Increase in temporarily restricted net assets 51,954Increase in net assets 797,509Net assets at beginning of year 2,763,306 Net assets at end of year $3,560,815

FINANCIAL REPORT – 2004A copy of ALDF’s full audited financial statement may be obtained by writing to ALDF or visiting www.aldf.org.

report

ANNUAL

’04

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To some folks, animal law is still considered“on the fringe”— but with the introduction

of official Animal Law programs in more andmore law school curricula, it’s clear the field isnow widely recognized as cutting-edge. Early in2005, 40 law schools offered animal law courses.As of August, thanks to intensive marketingefforts from ALDF’s Animal Law Program (ALP),this number stood at 59 schools either offering orcommitting to offer an Animal Law class duringthe 2005-2006 academic year.

Now ALP is planning to build on that momen-tum with Animal Law 101 Conferences- – a roadtour series of workshops designed for law students,law professors, attorneys, and pro bono coordina-tors. Each 90-120 minute program will includetopics such as: what animal law is and why it is an

important component of the modern law curricu-lum; what Student Animal Legal Defense Fund(SALDF) chapters do; how one starts a SALDFchapter; what types of projects established chapterscan take on; and what volunteer and employmentopportunities are available to attorneys wishing topursue a career in animal law.

“What we’re seeing from a lot of schools is arealization of the needs and the benefits of offer-ing Animal Law classes,” says Steve Wells, direc-tor of ALDF’s Animal Law Program. “Facultyand administrators are seeing the real worldgrowth in the practice of animal law and arebecoming eager to help their students prepare formore specialized legal careers should they opt forthem. Our campus tour of classes will spread thatword even further.”

Nonprofit Org.U.S. Postage

PAIDTucson, AZ

Permit No. 3341

The Animal Legal Defense Fund is a nonprofit organization funded almost entirely byindividual, tax-deductible contributions. If you would like more information about ourwork, are interested in joining or wish to notify us of a change of address, write to theaddress above, or call (707) 795-2533.

Joyce Tischler Executive DirectorSteve Ann Chambers President

NEWSLETTER STAFF

Lisa Franzetta EditorStephen Farley Design Newsletter Design

David S. FavreChair

Sonia S. WaismanVice ChairSarah H. LuickSecretary

Robert L. TrimbleTreasurer

DirectorsKatie M. BrophyPaul Leonard

Cheryl Lightle Joshua K. Marquis Tracy A. Miller Katharina Otto-Bernstein Cheryl A. Teser

BOARD OF DIRECTORS

Animal Legal Defense Fund170 E. Cotati Ave., Cotati, CA 94931

http://www.aldf.org

Animal Law 101 Goes Back to School➤ ALDF Nabs NY Hoarder

page 1

➤ Helping Law Enforcementpage 3

➤ Victory for Sick Dogspage 5

➤ 2004 Annual Reportpage 6

IN THIS ISSUE

printed on recycled paper