Contra Costa Collies |
|
|
Representing: AMICUS CURIAE for all animals at issue IN THE SUPERIOR COURT, COUNTY OF CONTRA COSTA, STATE OF CALIFORNIA COMES NOW, Central Valley Collie & Sheltie Rescue, a duly registered non-profit association, legally recognized in the state of California as an animal rescue agency, and moveant on behalf of the animals at issue in this matter, and states as follows:
- That Defendant Chauncey Wilson, who at all times relevant hereto, is a resident of El Sobrante, a subdivision of the City of Richmond, County of Contra Costa, State of California, and subject to the laws and ordinances therein;
- That Defendant Chauncey Wilson has now in his possession and/or control approximately 53 Collie dogs, ages ranging from under one year to over ten years;
- That Defendant Chauncey Wilson is prohibited by a permanent injunction issued by this Court March 2, 1995 from having in his possession more than three (3) dogs concurrently, and specifically prohibited from maintaining and conducting any and all activities connected with the operation of a dog kennel without having first obtained a "conditional use permit" issued by the City of Richmond;
- That Defendant Chauncey Wilson was commanded to appear before this Court in May 1999 for alleged violations of said permanent injunction; and having appeared thereto, has been found guilty and ordered to disburse all dogs in his possession except three by the date of October 2, 1999; and to be personally present for an inspection of his premises by the court-designated animal control officials of the City on that date;
- That Defendant Chauncey Wilson absconded with all the animals at issue herein before the October 2, 1999 and further failed to appear personally for said inspection by officials; and that he has further failed to inform the court or any of its designees as to the whereabouts, disposition, conditions, and welfare of said animal;
- That Central Valley Collie & Sheltie Rescue, its agents, volunteers and administration; has an interest in this matter, having earlier intervened to rescue 5 Collie dogs surrendered by Defendant to Pinole Animal Shelter in February 1999; said dogs being in need of immediate medical treatment for scabies, a disease communicable to humans;
- That Central Valley Collie & Sheltie Rescue did provide necessary medical treatment, socialization and foster or adoptive placements for each of the animals rescued at an average cost of $300 per animal entirely through its volunteer network and from chaitable donations to their organization;
- That Central Valley Collie & Sheltie Rescue has been present in each proceeding involving Chauncey Wilson and this Court, the City of Richmond, and any and all animal control entities which may have jurisdiction in this matter; and has knowledge that the remaining animals (approximately 53) are all afflicted with, exposed to or carrying sarcoptic mange (scabies), which poses a public health hazard to humans and animals and which requires medical treatment to eradicate;
- That Central Valley Collie & Sheltie Rescue remains interested in the disposition of each and every Collie dog in this matter and remains available and ready to provide the necessary care and treatment for these animals in order to facilitate rehabillitation and rehoming;
NOW THEREFORE MOVES that the appearance of Michael Love, Director, Central Valley Collie & Sheltie Rescue be entered by this Court as Amicus Curiae on behalf of all the animals at issue, for reasons set out in the attach Petition and Plan in Support of Amicus Curiae. Further, that this Motion be heard at the time scheduled for review of this case, November 8, 1999 at 9:00AM in the Superior court of Contra Costa County, barring any objection by Plaintifs.
Back to Contra Costa Collies Home Page