Washington State

Office of the Attorney General

Attorney General

Bob Ferguson

FOR IMMEDIATE RELEASE:

PORT ANGELES — The Attorney General’s Office announced today that it filed 30 felony animal cruelty charges against Angela Jacobsen of Sequim in Clallam County Superior Court.

If convicted, Jacobsen faces a maximum penalty of five years in prison and a $10,000 fine for each charge of first-degree felony animal cruelty.

The criminal charges stem from the discovery of hundreds of dogs, turkeys, pheasants, goats and more on Jacobsen’s property that were living in unsanitary conditions — both inside and outdoors — without access to food or fresh water. Some animals had bite wounds, and many were emaciated, malnourished and dehydrated.

Members of the Welfare for Animals Guild discovered the condition of the animals in late December 2021. Clallam County Sheriff’s officers removed more than 200 animals from Jacobsen’s property over the following weeks in early 2022. The majority of those removed animals were sent to a local animal rescue for treatment, rehabilitation, housing and care.

The 30 felony animal cruelty charges Jacobsen faces are for the animals that were most in distress. Veterinary records documented that many animals were in immediate danger of starving to death or dying of dehydration when they were removed. The animals for which Jacobsen is charged with felony neglect include 13 geese, eight ducks, six chickens and roosters, two dogs and an emu.

Assistant Attorneys General Scott Halloran and Courtney Blackburn are handling the case for the Attorney General’s Office.

Below, the affidavit of probable cause filed with the court is included in its entirety.

The information contained in the affidavit of probable cause are only allegations.  A person is presumed innocent unless and until he or she is proven guilty beyond a reasonable doubt in a court of law.

The Attorney General’s Environmental Protection Division is prosecuting the case. Under state law and the Washington State Constitution, the Attorney General’s Office does not have authority to initiate criminal investigations, unless it receives and accepts a referral from a county prosecutor or the governor. The Attorney General’s Office accepted a referral from the Clallam County Prosecuting Attorney in this case.

The Rules of Professional Conduct govern what a prosecutor in a criminal case may say publicly before trial. As the prosecutor in this criminal matter, the Attorney General’s Office and its representatives are prohibited from making public statements beyond the narrow scope allowed by the Rules of Professional Conduct. The office will make every effort to be transparent with the public, while upholding its responsibilities as a criminal prosecutor.

AFFIDAVIT OF PROBABLE CAUSE

The undersigned certifies that I am an Assistant Attorney General for Washington, and make this affidavit in that capacity; that criminal charges have been filed against the above named defendant in this case, and that I believe probable cause exists for the arrest of the defendant on the charges because of the following facts and circumstances. This information is not based upon any independent or personal knowledge of these events, unless specifically noted.

The following is based on reports, statements, and items provided by law enforcement, investigators, regulatory agencies, experts, and public information and not on personal knowledge. The purpose of this affidavit is to establish probable cause for the crimes charged, not to summarize the entire case. In Clallam County, Washington, the defendant committed the acts described below.

Clallam County Animal Control Deputy Tracey Kellas has periodically interacted with Angela Jacobsen, and has observed her to keep a variety of animals on her rural Toad Road property in Sequim, WA. So too have employees of the Welfare for Animals Guild (WAG), an award winning dog rescue based in Sequim. Jacobsen occasionally asked WAG for assistance with matters relating to her dogs.

On November 18, 2021, Jacobsen asked WAG to take an Anatolian dog that killed one of her chickens. WAG employee Kathleen Coakley observed that the dog appeared to be starving, with its ribs, backbone and hipbones all visible even through its thick fur. On December 28, 2021, Coakley and WAG manager Mel Marshall helped Jacobsen feed some of her outside dogs. Coakley noted that Jacobsen provided no water for her many outside animals. Jacobsen promised to provide water for her animals after that.

Two days later, on December 30, 2021, Jacobsen asked Marshall for a ride to urgent care due to chest pain and breathing issues. Marshall agreed to feed the outside dogs that night. Marshall and Coakley used WAG supplies to feed and provide water for what turned out to be twenty-five outside dogs and well over 200 animals, comprised of chickens, ducks, geese, pheasants, turkeys, a goat and an emu. Almost all of Jacobsen’s animals were emaciated.

The outside dogs were ravenous and fought over the bags of food Marshall fed them. Jacobsen had provided no food or accessible water for the hundreds of animals she kept. When Jacobsen entered the hospital that night, she gave Marshall and Coakley permission to feed the animals again the next day, including entering her house to feed the indoor dogs.

On December 31, 2021, Marshall and Coakley entered Jacobsen’s house to feed the small indoor dogs there. The two encountered a hazardous mess inside. Five dogs and twenty or more birds were located in the house. Coakley and Marshall stated that the overwhelming smell of ammonia made their eyes water and throats choke, even when wearing masks. All of the floors were slick with accumulated feces and urine. Chickens and dogs ran wild throughout the house. Live and dead animals were caged together, including ferrets and chickens. Dead ducks were located on the kitchen and bathroom counters. Jacobsen provided no food or accessible water for any of the animals kept in her house.

Jacobsen also failed to provide any food or accessible water for the hundreds of outside animals. Outside conditions were also dangerous. Many outside dogs had bite wounds, consistent with fighting over scarce food. A female Pyrenees dog was found in a locked, wooden shed with no windows, food, water or way out. The inside of her shed door displayed bite marks from her futile attempts to escape. Another dog was trapped in a pen with its roof having collapsed from snow accumulation. Nearly collapsed roofs and fallen trees endangered several other outside dogs in their pens. All of the birds were starving and dehydrated, literally climbing out of their cages into the feed pail, swarming Coakley and Marshall for food. Marshall described the entire Jacobsen property, inside and out, to be hazardous and unlivable for any animals. Marshall called 911 to report the conditions Jacobsen had created for those animals over time.

Clallam County Deputies Pickerell and Estep met Marshall and Coakley at the Jacobsen property shortly thereafter. WAG President Barbara Brabant was also present. Officers noted that the overpowering smell of ammonia in the house caused watery eyes and choking, even with masks worn. The deputies wrote initial reports describing the neglected state of Jacobsen’s animals, and photographed the scene. The police authorized WAG to remove those animals in the most immediate danger.

The first removed animals included very thin small dogs from inside the house. All were covered in feces and grime, some with bite wounds from being pecked by chickens or bitten by rats. Rat feces was abundant throughout the house, and is dangerous to dogs if eaten. WAG also removed five outside dogs that were imperiled by the collapsed or collapsing roofs of the pens housing them.

Over the next couple of days, WAG personnel returned again, using their own supplies to give necessary food and water to Jacobsen’s neglected animals. This took several hours each time. They also brought in bales of straw to provide weather protection for the numerous birds and waterfowl living on a substrate of mud and feces. On January 1, 2022, Coakley observed yellow snow appearing, demonstrating that nutrition was passing through some of the animals for the first time in days. Brabant and the others continued finding additional dead and starving birds in various parts of the Jacobsen property.

On January 4, 2022, Deputy Kellas served a search warrant on Jacobsen, who was back in her home by then. This first warrant addressed the initially removed most endangered animals. Police served additional search warrants on January 11, 2022. Jacobsen became upset when officers served the warrant, and refused to gather, calm, or help her animals in any way. A Peninsula Behavioral Health Designated Crisis Responder (DCR) spent time talking with Jacobsen and determined that there was no basis to recommend involuntary treatment (ITA).

Officers spent four hours gathering and seizing fifteen large outside dogs and a goat. The dogs were all thin to very thin, skittish and hard to catch. No animals had access to clean water, only to fetid brown muddy puddles and feces laden bowls. Due to snowy, icy weather, limited resources, transportation and other logistical issues, the officers delayed removing the numerous other animals listed in the warrant.

In multiple trips over the next few weeks, officers seized the remaining dogs, a pygmy goat, and hundreds of birds and waterfowl. No poultry food was present during these visits, nor had Jacobsen provided any accessible source of water for the hundreds of birds she kept. The only food observed in all the various interventions was a few bags of unopened dog food seen in a car on Jacobsen’s property. Jacobsen appeared to continue failing to provide necessary food or water to her animals during the ongoing removal process. Officers sent the vast majority of the 200-plus removed animals to the Center Valley Animal Rescue (CVAR) in Quilcene for treatment, rehabilitation, housing and care.

CVAR is a thirty-acre animal rescue and rehabilitation organization that has cared for all manner of abused, neglected, sick or injured animals and wildlife since 2002. CVAR founder Sara Penhallegon is a licensed veterinary technician and licensed wildlife rehabilitator. She also works closely with local animal control, and helped in safely gathering most of the neglected animals from Jacobsen’s property.

When examining and documenting an animals nutritional health, a key veterinary tool is assigning a body condition score (BCS). Determining a BCS involves palpitating and observing fats under the skin, assessing muscle condition, and examining where fat and muscle are first depleted in an undernourished animal. The most commonly used and accurate BCS scale assigns a number from 1 (emaciated) to 9 (obese). Several dozens of Jacobsen’s seized animals were determined to have a BCS of 1, the lowest possible score while still alive.

Sara Penhallegon examined and scored most of the Jacobsen animals relevant to this case. Veterinarians Dr. Joel Cuthbert, Dr. Jan Richards, and Dr. Christine Parker-Graham, all CVAR board members, also performed multiple examinations and BCS scoring, with Penhallegon assisting. These veterinarians documented the dire conditions of Jacobsen’s neglected animals when removed, as well as the extensive time it took many of these animals to recover normal body weight with proper nutrition in the weeks that followed. The veterinary examination records demonstrate that Jacobsen starved and dehydrated numerous animals over extended periods of time.

A small number of Jacobsen’s animals had names recorded in their medical exams. For clarity and due to the continuing nature of animals being recovered over a few weeks, the animals are identified by the date of their initial examination and the number of that type of animal examined that day. For example, the goose identified as “01/13/22 #12 goose” refers to the twelfth goose in a batch of Jacobsen’s animals initially examined at CVAR on January 13, 2022. Each animal’s exam record contains additional specific identifying information, such as color, weight, characteristics, noted injuries, treatments administered, etc.

Washington’s Felony Animal Cruelty Statute

Various types of criminal conduct can result in violations of RCW 16.52.205. A person commits first degree animal cruelty when she, with criminal negligence, starves or dehydrates an animal, and as a result causes substantial and unjustifiable pain that extends for a period sufficient to cause considerable suffering in violation of RCW 16.52.205(2).

Evidence of Violations Regarding Animals Recovered in the Search of Jacobsen’s Property

01/11/22 #9 dog: Dr. Cuthbert assessed Butch, a large, male Anatolian shepherd dog to be in very poor condition, with a BCS of 2 of 9 (meaning very thin). He was very skinny, with his spine, ribs and hip bones all clearly visible. Butch’s dull dry coat further reflected his starving condition. His volume of muscle wasting and fat loss happened from being underfed or not fed at all over an extended period of time. Veterinary notes detail that such starvation is painful, resulting in muscle and joint pain and mental anguish. Butch’s feces contained dirt, feathers, feces and junk. An additional sign of neglect was that Butch’s filthy collar was caked into his neck so deeply that it had to be cut off. Once given basic care and proper feeding at CVAR, Butch gained twenty pounds in the first week.

01/25/22 #16 dog: An Anatolian shepherd named Austin was assessed as very underweight, with a BCS of 2 of 9, with long overgrown nails and fleas. Penhallegon noted that Austin was so malnourished that it took several days of proper feeding in order for his body to produce any feces. Austin’s starvation was painful, causing him muscle pain, joint pain and mental anguish. This neglected dog so feared people that at CVAR, he only allowed Penhallegon to feed him or bring him water. She had to physically lift him up to move him in any way. Austin gained 8.5 pounds in his first two weeks of proper feeding at CVAR.

01/13/22 #14 rooster: Duke was in immediate danger of starving to death when removed. Dr. Richards and Penhallegon assessed Duke’s BCS as 1 of 9. This blind, large red and orange rooster was severely emaciated, and so weakened that he could barely stand upright without support. Jacobsen kept Duke in a pen with no food or water. His feet and feathers were encased in mud and feces. He was infested with lice. Duke was so dehydrated from lack of water over time that CVAR had to give him warm injectable fluids and vitamins to save his life. He further required a separate heated clinic space for the first few weeks he was at CVAR. Duke’s long, slow process of starvation and dehydration under Jacobsen caused him pain and suffering as his muscles and joints broke down. He suffered additional stress and anguish searching for food that was not provided. Duke also had a heart murmur, which can occur from starvation. It took three days of proper feeding and hydration for Duke to be able to stand upright on his own. Following two months of proper care and feeding, Duke was up to normal body weight and had gained 76% of his initial body weight.

02/11/22 #1 rooster: Charley was a large extremely underweight turken rooster with a BCS of 2 of 9. Charley lived in Jacobsen’s house and was covered in lice and scaly mites. He was missing feathers and had multiple wounds consistent with being pecked by other birds. Penhallegon noted that housing multiple birds together with no food or water causes regular fighting. Such fighting is painful and stressful to the birds. Charley’s parasite load would also have been painful, as would being bitten by numerous lice and mites. Normal care and feeding at CVAR brought Charley’s initial body weight up 27% in five weeks.

01/13/22 #0 emu: Jacobsen kept a large emu in a pen with one dog and varied poultry. No food or water was present. This emu was very weak and emaciated. His full spine, hips, chest, ribs and leg bones were plainly visible and easily felt. This gave him a BCS of 1 of 9, meaning severely emaciated. It took an extended period of starvation to cause the emu to lose all the fat and muscle mass that he did. This caused pain and suffering over time as his muscles and joints deteriorated. Dr. Cuthbert assessed the emu to be in extremely poor body condition, with significant skeletal atrophy. The emu was so weak that he allowed Penhallegon to pick him up to be removed. Penhallegon worried that he might not survive the drive to CVAR. The emu required a modified starvation diet to prevent him from getting sick when eating again. Three days later the emu was gaining weight and had a BCS of 2 of 9. Jacobsen nearly starved the emu to death. Lack of food and water alone caused his condition. The emu gained 23% of his initial body weight after two months of feeding at CVAR.

01/13/22 #12 goose: This frizzle brown and white goose was very weak and emaciated, with a BCS of 1 of 9. No food or water was present where Jacobsen kept any of the removed geese. Muddy puddles with feces were the only accessible water. Volunteers assisting with animal removal observed a few whole avocados in the geese pens. Avocados contain persin, a poison toxic to birds. All of the geese were kept without any dry or clean ground; only sludge full of feces from the hundreds of animals was present. Ongoing starvation and dehydration left this goose lame, weak, sick and in pain for an extended period of time. He was near death when removed. This goose also had a very low heart rate, painful ulcerative pododermatitis (bumblefoot) developed over a long period of time, and difficulty walking.  Treating veterinarians observed that this goose had a healed wing fracture, which they concluded would have been painful, and healed without known medical treatment. Prey animals show pain or weakness only when in dire condition, so as to avoid being eaten by predators. Yet this goose and others exhibited greatly weakened condition, pain and distress. It was so severely dehydrated that its skin tented when pinched, rather than return to its normal shape. This goose required immediate medical intervention, including injectable fluids to regain basic hydration to survive.

01/25/22 #44 goose: This white-chested tan goose was so dehydrated and emaciated that extra skin hung from its neck where normal fat and muscle should be. No food or water was present, and it was covered in mud and feces that made it no longer waterproof. It suffered painful loss of muscle and wasting over an extended period of time. This goose had collapsed from lack of food and water, and was being trampled by the other geese when removed. It was near death when brought to CVAR. This goose was so weak that when being weighed it laid flat upside down and needed human assistance to hold its head up. Penhallegon scored its BCS as 1 of 9, but noted that was only because zero was not an available option. Two months of proper food and care allowed this goose to gain 50% of its initial body weight.

02/02/22 #22 goose: This goose also lived without food or water, among muddy puddles full of feces. Penhallegon assessed this goose with a BCS of 1 of 9, being very weak and severely emaciated. It took a long period of being malnourished to suffer the loss of muscle and fat that this goose did. Its pain and suffering from lack of food and water extended for a significant period of time. Penhallegon noted that it would be obvious to any untrained person that this goose, like the others, was sick, starving and in pain. This goose was so weakened that it could not hold its own wings or head up normally when walking. It also suffered from severe and painful bumblefoot due to the filthy sludge it lived on. Penhallegon noted that this goose would likely have died from starvation in a few days without immediate intervention.

01/13/22 #2 chicken: This black, white and cream-colored bantam chicken weighed only 0.7 pounds on arrival at CVAR. Dr. Richards noted the chicken was weak, pale, and so starved and dehydrated that it had difficulty standing. It required injectable fluids to gain enough hydration to survive. It had a BCS of 1 of 9, meaning severely emaciated. Jacobsen had to have starved this bird for an extended period of time in order for it to lose the amount of muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. After two weeks of feeding and care, this chicken had doubled its body weight.

01/13/22 #8 chicken: Dr. Richards scored this silky grey breed of chicken with a BCS of 1 of 9. The black and grey, top-knot chicken weighed 0.95 pounds, and was emaciated and dehydrated. It required injectable fluids to regain hydration. Jacobsen had to starve this bird for an extended time in order for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. After two weeks of feeding and care, this chicken had doubled its body weight. This chicken lived with feet encrusted in feces, and suffered severe and painful bumblefoot as a result.

01/13/22 #9 chicken: This black silky breed was assessed a BCS of 1of 9. It too required injectable fluids to gain hydration. The emaciated and dehydrated chicken weighed one pound on arrival. Jacobsen would have to have starved this bird for an extended time for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. Dr. Richards noted that this bird also suffered from feces encrusted feet, moderate bumblefoot, missing nails, and plumage in poor condition.

01/13/22 #10 chicken: This black, tan, and cream-colored bantam breed was so dehydrated that it required injectable fluids to gain hydration. Dr. Richards scored the bird a BCS of 1 of 9, reflecting its emaciation and loss of fat and muscle. The chicken was very pale, suffering from the pain of Jacobsen starving and dehydrating it over time. It also had bumblefoot and a deformed right foot. Two weeks of feeding and care doubled this chicken’s body weight.

02/11/22 #6 duck: CVAR assessed this white Muscovy duck with BCS of 1 of 9. Jacobsen would have to have starved this bird for an extended time for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. This duck also suffered from severe bumblefoot, and was missing nails on its right foot. It had sores on both wings and Jacobsen’s neglect of the bird left its feathers without waterproofing in the snowy icy weather.

02/11/22 #8 duck: This white, brown and black colored Muscovy duck suffered from painful bumblefoot caused by the substrate of feces and trash sludge they were kept on. This duck suffered from sores on both wings, including a bloody and ulcerated right wing. This duck suffered pain over an extended period of time as its muscle and fat wasted away, leaving it with an assessed BCS of 1 of 9.

02/11/22 #9 duck: CVAR assessed this brown with white and black speckles Muscovy duck with BCS of 1 of 9. Jacobsen starved this bird for an extended period of time in order for it to lose the muscle and fat that it did. Such starvation and dehydration would cause significant pain and suffering over time. This duck also suffered from severe bumblefoot, and split nails on its right foot. It also had painful sores on both wings.

02/02/22 #13 duck: Penhallegon assessed this black, white and grey speckled Muscovy duck with BCS of 2 of 9. Jacobsen had to starve this bird for an extended time in order for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. This duck also suffered from moderate bumblefoot, and split nails on its right foot. It had carpal sores on both wings. The feathers on its right wing were badly damaged.

02/02/22 #14 goose: This white and brown colored grey goose had a BCS of 1 of 9. As with the other aforementioned animals, Jacobsen starved this bird for an extended period of time in order for it to lose the muscle and fat that it did. Such starvation and dehydration would cause extended pain and suffering. This emaciated goose was so dehydrated that Penhallegon needed to administer injectable fluids for it to survive. It was extremely lethargic, not even struggling when being injected or held down, indicating weakness and behavior not natural to geese.

02/02/22 #15 duck: This black and white Muscovy duck had a BCS of 1 of 9. Jacobsen had to starve this bird for an extended time for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. The poor substrate Jacobsen gave these animals to live on resulted in this duck having severe bumblefoot on its left foot, and moderate bumblefoot on its right foot. Both of the bird’s wings had painful sores and its wing and tail feathers were damaged from being covered in mud and feces.

02/02/22 #18 goose: CVAR assessed this grey, white and brown colored grey goose to have a BCS of 1 of 9. Jacobsen would have to have starved this bird for an extended time for it to lose the muscle and fat that it did. Such starvation and dehydration caused pain and suffering over time. This emaciated goose was so severely dehydrated that it required immediate injectable fluids to survive. The goose was blind in one atrophied eye and had mild bumblefoot from its poor substrate conditions.

02/02/22 #19 goose: This white goose with blue eyes and orange feet had a BCS of 1 of 9. Jacobsen had to starve this bird for an extended period of time in order for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. This emaciated goose was so severely dehydrated that it required immediate injectable fluids to survive. It also had mild bumblefoot from its poor substrate conditions.

02/02/22 #21 goose: This brownish, grey goose with orange feet had a BCS of 1 of 9. Jacobsen had to starve this bird for an extended period of time in order for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. This emaciated goose was so severely dehydrated that it required immediate injectable fluids to survive. It also had moderate bumblefoot from its poor substrate conditions.

02/02/22 #23 goose: This blue-eyed, white goose had a BCS of 1 of 9. Jacobsen had to starve this bird for an extended period of time in order for it to lose the muscle and fat that it did. This emaciated goose was so dehydrated that it required immediate injectable fluids to survive. The goose also had mild bumblefoot from its poor substrate conditions.

02/02/22 #24 goose: This blue-eyed, white goose had a BCS of 1 of 9. Jacobsen would have had to starve this bird for an extended time for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. It also had severe bumblefoot from its poor substrate conditions.

02/02/22 #25 goose: This partial frizzle goose had a grey head, dark brown feathers, and a white belly. Penhallegon assessed it with a BCS of 1 of 9. Jacobsen would have to have starved this bird for an extended time for it to lose the muscle and fat that was observed. Such starvation and dehydration caused pain and suffering over time. This emaciated goose was so dehydrated that it required immediate injectable fluids to survive. It also had mild bumblefoot from its poor substrate conditions.

01/25/22 #26 duck: This brown and black female mallard had a BCS of 1 of 9. Jacobsen had to starve this duck for an extended period of time in order for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. This emaciated duck also had severe bumblefoot from its poor substrate conditions.

01/25/22 #31 duck: This brown and black female mallard had a BCS of 1 of 9. Jacobsen would have to have starved this bird for an extended time for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. This emaciated duck also had discolored webbing on its left foot. Penhallegon noted this duck was severely dehydrated.

01/25/22 #42 duck: This brown mallard duck was assessed a BCS of 1 of 9. Jacobsen had to starve this bird for an extended time for it to lose the muscle and fat that was observed. Such starvation and dehydration would cause pain and suffering over time. Penhallegon noted this emaciated duck was weak, and missing nails on its feet. It also had mild bumblefoot and carpal sores.

01/25/22 #47 goose: This blue-eyed, white goose had a BCS of 1 of 9. Jacobsen had to starve this bird for an extended time for it to lose the muscle and fat it did. Such starvation and dehydration would cause pain and suffering over time. This emaciated goose also had severe bumblefoot and deformity in its left toes. Penhallegon noted that this goose was dehydrated.

01/25/22 #49 goose: This blue-eyed, tan, mild frizzle goose had a BCS of 1.5 of 9. Jacobsen had to starve this bird for an extended period of time in order for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. This emaciated goose also had moderate bumblefoot. Penhallegon noted that this goose was so dehydrated that it required injectable fluids to survive.

01/27/22 #3 goose: This white-masked, multicolored goose had a BCS of 1.5 of 9. Jacobsen would have to have starved this bird for an extended time for it to lose the muscle and fat that it did. Such starvation and dehydration would cause pain and suffering over time. This emaciated goose also had severe bumblefoot and a gnarled, twisted chest wound. It additionally had a keel injury. Penhallegon noted that this goose was severely dehydrated.

Dr. Cuthbert additionally summarized the conditions of the aforementioned animals to include that Jacobsen’s gross neglect of these animals resulted in their unnecessary suffering through starvation, exposure, and lack of medical attention. The lack of adequate nutrition (or any at all) resulted in cachexia, which is a painful wasting loss of lean body mass. The poor, inadequate substrate also resulted in most of the birds suffering from painful bumblefoot and damage to plumage. This too contributed to the pain and suffering of the animals over an extended period of time.

State’s Motion to Set Conditions of Release – The State moves the Court to order the defendant to not own, care for or reside with any animals during the pendency of this case. The State further moves the Court to order the defendant to have no criminal law violations. Should the defendant be convicted of first degree animal cruelty, she would be permanently prohibited from possessing or residing with any animal pursuant to RCW 16.52.200(4)(b).

Based upon a review of the database maintained by state and federal agencies, the State’s understanding of the defendant’s criminal history is set forth in Appendix B, attached hereto and incorporated herein by reference.

I certify under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct.

DATED this 18th day of April, 2024.

For the full document, click here: https://agportal-s3bucket.s3.us-west-2.amazonaws.com/uploadedfiles/Another/News/Press_Releases/2024_04_19_MotPC.pdf

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