Complaint Alleging Criminal Wrongdoing !

Tennessee Attorney Generals Office !

P.O. Box: 20207!
Nashville, TN 37202-0207!

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RE: Organized Animal Cruelty !

COMPLAINT!

1. !

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PRELIMINARY STATEMENT!
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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!

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.!

DCYFRs 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

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 dont 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)!

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 Sheriffs

Office, Smithville Police Department, Tennessee Department of Childrens 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. Thats a strong indicator that the agencies are either extremely
biased or extremely incompetent; in either case, the Tennessee Attorney Generals Office
should investigate. ! !

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Disregard for 39-15-401(c)(1)!
18.!

The events 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 Childrens 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

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)!
26.!

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

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!

27.!

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

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!

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Respectfully submitted, !

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Global Conservation, LLC

Cruelty Investigation Department!
808 Fieldcrest Court!
Watertown, WI 53094 !

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investigations@GlobalConservationGroup.org!
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shunter@GlobalConservationGroup.org !
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EXHIBITS:!

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

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THREE:!
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FOUR:!
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