frog complaint pdf

8/17/2019 Frog Complaint PDF

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Complaint Alleging Criminal Wrongdoing

Tennessee Attorney General’s OfficeP.O. Box: 20207

Nashville, TN 37202-0207

RE: Organized Animal Cruelty

COMPLAINT

PRELIMINARY STATEMENT

1.

Global Conservation Group (Global Conservation, LLC) (hereinafter “GCG”) files this

complaint alleging the “DeKalb County Young Farmers and Ranchers” (hereinafter

“DCYFR”) organization is in violation of state animal cruelty, child welfare and hunting laws.

2. As set forth below, DCYFR violated T. C. A. § 39-14-201 to 217 in that “A person

commits an offense who intentionally or knowingly tortures, maims or grossly overworks an

animal; transports or confines an animal in a cruel manner; or inflicts burns, cuts, lacerates, or

causes other injuries or pain, by any method.” In this case, the species of victim are frogs, which

is included in the definition of “animal,” in that “Animal means a domesticated living creature or a

wild creature previously captured.” Further, DCYFR violated § 39-15-401(c)(1), in that “A parent

or custodian of a child (8) years of age of less commits child endangerment who knowingly

exposes such child to or knowingly fails to protect such child from abuse or neglect.”

Additionally, “The use of firearms is prohibited for bullfrog hunting,” according to tn.gov.

Furthermore, pursuant to § 39-13-101 “a person commits assault who intentionally or knowingly

causes another to reasonably fear imminent bodily injury; or intentionally or knowingly causes

physical contact with another.”

JURISDICTION AND VENUE

http://tn.gov/


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3. This agency has jurisdiction over this complaint.

4.

Venue is proper because Defendants are located within the State of Tennessee,

specifically the City of Smithville and the County of DeKalb.

5. A substantial part of the acts or omissions giving rise to this complaint arose from events

occurring within this jurisdiction.

DEFENDANTS

6. Defendant “DeKalb County Young Farmers and Ranchers (DCYFR)” is a person within

the meaning of 42 U.S.C. § 2000e(a).

7. Defendant DCYFR is a chapter within the Tennessee Farm Bureau (TFB), and as such

TFB should be a suspect or defendant as well. TFB is a person within the meaning of 42 U.S.C.

§ 2000e(a).

8.

Defendant DeKalb County Community Complex is a party to the crime as they willingly

allow event organizers to meet and host the event on their premises. DeKalb County

Community Complex is a person within the meaning of 42 U.S.C. § 2000e(a).

FACTUAL ALLEGATIONS

Disregard for T. C. A. § 39-14-201 to 207

9. On the dates of July 19, 2015, July 20, 2015, June 27, 2014, June 28, 2014, July 12,

2013, July 14, 2013 and the presumptive dates of June 24, 2016 and June 25, 2016, DCYFR

convened and organized an event in which our complaint is based on. (See , exhibit A)

10.

DCYFR’s event titled, “Giggin’ For Grads,” involves inter alia , that groups of both young

children and grown adults roam the county of DeKalb between the times of 7:00pm - 1:00am

with pitch-forks, spears and gigs stabbing at moving objects, which the participant assumes are

frogs. It is nearly impossible for the participant to accurately identify the animal, particularly the


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proper species, within a few seconds in the dark, that they have to impale the animal with a

“gig.”

11. On July 12, 2013, a representative or participant of the event indicated to a GCG

investigator that “we don’t stab them [frogs], we shoot the mother *******,” while another

representative or participant admitted to a GCG investigator that they “beat the hell out of some

frogs.” These statements were recorded on video and constitutes the admission of a crime. It is

unlawful to shoot frogs with a firearm and it is unlawful for an individual to mistreat a frog.

Moreover, state law allows a “bag limit” of 20 frogs per person, however an event representative

or participant indicated that they would “kill them all,” which far exceeds the 20 frogs per person

limit as determine by the legislature. This statement was recorded on video and constitutes the

admission of a crime. (See , exhibit B)

12.

On July 12, 2013, several representatives or participants of the event were seen and

recorded by a GCG investigator slamming live frogs onto the concrete parking lot at DeKalb

County High School, located at 1130 W Broad St., Smithville, Tennessee 37166. Investigators

determined that the frogs were alive as they were being slammed into the concrete by way of

the vocal distressing noise being made by the animals. GCG investigators subsequently took

pictures of the crime scene, which depicts a graphic blood-covered parking lot with pieces of

body parts scattered around the lot. After subsequently contacting the school administration, the

school refused to host future “Giggin’ for Grads” events. Currently, events are being held at the

DeKalb County Community Complex. (See , exhibit C)

13. On July 12, 2013, a representative or participant of the event threw a live, injured frog at

a GCG investigator from a moving vehicle, which constitutes four separate crimes: assault on a

human being, traffic violations, obstruction of traffic, and mistreatment of animals. (See , exhibit

D)


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14. On July 12, 2013, a representative or participant of the event was seen by a GCG

investigator playing “catch and toss” with a captured frog with another associate of the event. It

is unknown if the frog was alive or deceased at the time of the activity. GCG investigators

thoroughly screened the area after the event was completed at approximately 2:30am on July

13, 2013 in an attempt to find the body, but was unsuccessful.

15. The event in and of itself constitutes criminal activity due to the willful, wanton, and

intentional disregard of the law, specifically animal mistreatment statutes and child

endangerment laws. Frogs are stabbed to death for no other reason than entertainment and

profit. GCG senior biologist Susana Paco reviewed footage of the event and concluded, “A

method such as stabbing is extremely painful for the frog, who dies of massive hemorrhaging

and usually asphyxiates on its own blood.”

16. Unlike responsible frog hunting activities, “Giggin’ for Grads” is more closely associated

with cult-like organized crime by way of reckless and harmful behavior toward people and

animals and the absolute disregard of applicable laws. This event poses a very real danger to

both animals and the community.

17. In the years of 2013 and 2014, GCG filed complaints with the DeKalb County Sheriff’s

Office, Smithville Police Department, Tennessee Department of Children’s Services, and the

Tennessee Wildlife Resources Agency. All agencies dismissed our complaints without proper

investigation. Evidence of such allegations can be found in previous years events, where some

of the above mentioned agencies indicated to us that they had agents and officers attending the

events in an effort to ensure compliance. However, a GCG investigation uncovered a whole

series of unlawful behavior explained above, which went undetected by all law enforcement

agencies involved in the event. That’s a strong indicator that the agencies are either extremely

biased or extremely incompetent; in either case, the Tennessee Attorney General’s Office

should investigate.


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Disregard for § 39-15-401(c)(1)

18.

The event’s time frame of 7:00pm - 1:00am, in which children are encouraged to roam

the county may be in violation of applicable curfew laws and regulations as set forth by the

municipality or county, often limiting youth engagement to 12:00am on weekends.

19.

Young children “of any age,” are welcome and encouraged to participant in an event

which arms the child with a spear or “gig.” The minors are then directed to wander the county at

night stabbing objects that move. This poses a significant safety concern for everybody

involved.

20. In 2014, Tennessee Department of Children’s Services indicated to us that they

“understood” our complaint, but was unable to take action at that time.

Disregard for § 39-13-101

21. On July 12, 2013, an event organizer or participant sprayed GCG investigators with

water without provocation or cause. The water was believed to be discharged from a large water

bottle in possession of an individual driving a pick-up truck as they were exiting the “Giggin’ for

Grads” event. They further intentionally blew heavy exhaust on GCG investigators with pick-up

trucks. These actives were recorded on video.

22. On July 12, 2013, an event organizer or participant threw a live, injured frog at a GCG

investigator without provocation or cause. While the investigator was not substantially harmed,

the frog suffered numerous injuries, particularly to its back leg. Pictures of the frog in question

were taken as evidence by GCG investigators. After attempts to locate a veterinarian were

unsuccessful, it was determined that the frog may heal on its own and the animal was released.

23. In 2013, a series of online threats of physical violence made by who we presume are

event organizers or participants targeted individual GCG investigators in an unsuccessful


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attempt to cease our investigation. A majority of the threats were made on a Facebook event

page created by the “DeKalb County Young Farmers and Ranchers” organization.

CLAIMS FOR RELIEF

COUNT 1

Violation of T. C. A. § 39-14-201 to 207

24. As alleged in this Complaint, Defendants DeKalb County Young Farmers and Ranchers,

Tennessee Farm Bureau, and DeKalb County Community Complex are engaged in, and

continue to engage in, a pattern of practice of criminal mistreatment of animals in violation of T.

C. A. § 39-14-201 to 207.

25.

As alleged in this Complaint, Defendants DeKalb County Young Farmers and Ranchers,

Tennessee Farm Bureau, and DeKalb County Community Complex have engaged in a pattern

or practice of resistance to compliance with applicable laws and regulations as set forth by the

State of Tennessee. All the above organizations received numerous letters, phone calls, emails

and other communications from GCG investigators informing them of their unlawful activities

and offered to assist them in forming a new fundraiser without the use of animals. Those offers

were ignored.

COUNT II

Violation of § 39-15-401(c)(1)


Tennessee Farm Bureau, and DeKalb County Community Complex are in violation of §

39-15-401(c)(1) as determined by the legislature.

COUNT III

Violation of § 39-13-101


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Tennessee Farm Bureau, and DeKalb County Community Complex are in violation of §

39-13-101 as determined by the legislature.

PRAYER FOR RELIEF

WHEREFORE, the Global Conservation Group respectfully requests that this agency:

A. Investigate the allegations set forth in this complaint under the following statutes: T. C. A.

§ 39-14-201 to 207, § 39-15-401(c)(1), and § 39-13-101.

B.

Place Defendants DeKalb County Young Farmers and Ranchers, Tennessee Farm

Bureau, and DeKalb County Community Complex on the Tennessee Animal Abuse Registration

as required by Public Chapter No. 413 and Tennessee Code Annotated, Title 39; Title 40 and

Title 44, which created the “Tennessee Animal Abuser Registration Act.”

C.

Make efforts to implement a preliminary and permanent injunction to prevent further

violations of state law; and

D. Grant such additional relief as the needs of justice may require.

Dated: May 17, 2016

Respectfully submitted,

Global Conservation, LLC

Cruelty Investigation Department 808 Fieldcrest Court Watertown, WI 53094

[email protected]

[email protected]

mailto:[email protected]:[email protected]


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EXHIBITS:

ONE:


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TWO:

https://www.facebook.com/gcg3000/videos/vb.267461951766/10152769591191767/?type=2&theater

THREE:

https://www.facebook.com/gcg3000/videos/vb.267461951766/10152769591191767/?type=2&theater


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FOUR:

frog complaint pdf

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