Other LanguagesPASCO — The Attorney General’s Office announced today it has filed 48 total criminal charges of animal cruelty against two individuals and their organization, Neo’s Nation Animal Foundation, which previously managed the Pasco shelter.
The charges, which include six felonies and 42 gross misdemeanors, allege that former Neo’s Nation director Rebecca Howard, 46, of Kennewick, and office manager Justin Hernandez, 36, of Pasco, committed animal cruelty while they managed the Tri-Cities Animal Shelter in 2021. The Attorney General’s Office also filed charges against Neo’s Nation, a Washington nonprofit professional service corporation that received the contract to run the Pasco shelter.
The criminal charges stem from events occurring after Neo’s Nation Animal Foundation took over management of the shelter, which Tri-Cities taxpayers pay for, in January 2021. Howard was the director of Neo’s Nation and had previously worked at the shelter for more than a decade. Hernandez served on the Neo’s Nation board of directors and worked directly for Howard.
By the summer of 2021, shelter employees spoke with outside animal clinics about abuse and neglect at the shelter. One employee removed a dog a few weeks after it arrived at the shelter because the animal’s health deteriorated quickly under the defendants’ care. The dog later died from kidney failure, which can happen to malnourished dogs.
On Nov. 11, 2021, police served a search warrant on the shelter and a veterinarian accompanied them. Police discovered malnourished dogs and crates of cats and kittens in a laundry room. Many of the animals were severely ill and had multiple infections. A detective learned from employees that only Howard and Hernandez made all medical decisions regarding the animals at the shelter.
Police also searched an outbuilding on the grounds, which employees said only Howard or Hernandez had access to. Detectives described the outbuilding as infested with mice and in poor condition. Inside the outbuilding were crates of cats stacked on top of each other. Most of the cats had respiratory and eye infections, and some could not open their eyes due to the severity of the infections.
Howard, Hernandez and Neo’s Nation no longer manage the shelter.
If convicted, Howard and Hernandez face up to five years in prison and a $10,000 fine for each of the two felony charges of first-degree animal cruelty. Howard and Hernandez also face up to 364 days in jail and a $5,000 fine for each of the 14 gross misdemeanor charges of second-degree animal cruelty. Additionally, Neo’s Nation faces a fine of up to $500,000 for each of the two felony charges and $250,000 for each of the 14 gross misdemeanors if convicted.
Assistant Attorney General Scott Halloran, and paralegal Virginia Castro and legal assistant Sydney Stern are handling the case for Washington.
Below, the affidavit of probable cause filed with the court for Neo’s Nation 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. The Attorney General’s Office filed these charges in Franklin County Superior Court. 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. Because the shelter is a county-owned facility, Franklin County officials asked Grant County to take over the investigation. The Grant County Prosecuting Attorney subsequently referred the case to the Attorney General’s Office and the Franklin County Prosecuting Attorney agreed with that decision.
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 FOR DETERMINATION 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 cause, 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 the affidavit is to establish probable cause for the crime charges, not to summarize the entire case.
The Tri-Cities Animal Shelter and Neo’s Nation Animal Foundation
The city of Pasco owns the Tri-Cities Animal Shelter (TCAS). Kennewick, Richland and Pasco taxpayers fund the shelter. The shelter’s purpose is to facilitate the temporary care of stray, lost or abandoned, sick or injured cats and dogs. These animals are supposed to be restored to health if needed, spayed and neutered, and then adopted out. Contracts to operate the shelter are periodically bid for, and generally awarded to a nonprofit 501(c)(3) designed for that purpose. After winning such a bid, the nonprofit Neo’s Nation Animal Foundation (Neo’s Nation) began running the shelter in January of 2021, under the leadership of Director Rebecca Howard.
Rebecca Howard had extensive experience working and volunteering at the shelter for over a dozen years. Her Neo’s Nation leadership team included Office Manager Justin Hernandez and Chief Financial Officer Julie Chambers. All three were members of the Neo’s Nation board of directors. Howard and Hernandez were also listed as governors when Neo’s Nation filed incorporation with Washington State.
Howard’s extensive professional experience working at all levels at TCAS enabled her to know and understand how to operate the shelter efficiently and humanely. Yet once she and Neo’s Nation began running the shelter, financial improprieties occurred. For example, Howard, Hernandez and Chambers voted themselves $25,000 in bonuses with no other board members present, according to employees and other board members. Chambers was also alleged to have stolen $300,000 of a decedent’s donation to TCAS and then purchased a house with the money intended to care for the animals. Chamber’s case is charged under Franklin County cause # 21-1-50370-1. At the same time that the alleged financial improprieties were occurring, Neo’s Nation developed a pattern of failing to provide the necessary care, nutrition, sanitation and medical attention required by numerous animals in the shelter’s care.
Multiple employees and volunteers of TCAS became very concerned with the neglect of the cats and dogs under the leadership of Howard and Hernandez. These issues worsened from summer through fall of 2021. Some TCAS employees and volunteers expressed their concerns to outside animal clinics. Horse Heaven Hills Pet Urgent Care Veterinarian Dr. Denise Wilson arranged to do weekly visits to TCAS to examine individual animals needing medical attention. In October of 2021, Pasco Detective Julie Lee initiated an investigation into animal cruelty and neglect at TCAS, based on employee informants’ descriptions of conditions inside the shelter.
Washington’s Animal Cruelty and Neglect Statutes
Various types of criminal conduct can result in violations of Washington’s animal cruelty statutes. Animal cruelty in the first degree can be committed when a person, with criminal negligence, starves or dehydrates an animal, and as a result causes substantial and unjustifiable physical pain that extends for a period sufficient to cause considerable suffering or death in violation of RCW 16.52.205(2)(a). The definition of a “person” includes individuals, corporations, or other legal entities, and the agents of those entities. RCW 16.52.011(2)(p).
A person is guilty of animal cruelty in the second degree, if in relevant part, the person knowingly, recklessly, or with criminal negligence inflicts unnecessary suffering or pain upon an animal in violation of RCW 16.52.207(1). Additionally, an owner of an animal is guilty of animal cruelty in the second degree, if under circumstances not amounting to first degree animal cruelty, the owner knowingly, recklessly, or with criminal negligence fails to provide the animal with necessary sanitation, space or medical attention and the animal suffers unnecessary or unjustifiable physical pain as a result of the failure, in violation of RCW 16.52.207(2)(a). A person having lawful custody, control or possession of an animal meets the definition of “owner” under RCW 15.52.011(2)(o).
Cherie Jackson, an animal control officer, called Pasco police in October, 2021 to report ongoing cruelty at TCAS. Animal control officers have limited law enforcement commissions from each of the Tri-Cities, but are employed by TCAS. Animal control officers work at the shelter daily. Cherie Jackson reported directly to Howard and Hernandez. Jackson was also a board member of Neo’s Nation.
When an animal control officer brings a cat or dog from the field into the shelter, that officer performs intake procedures on the animal. Factors noted include general medical condition, weight, body condition score (BCS), and eye and skin condition. Each animal is photographed and checked for prior vaccination or microchipping, and tested for ringworm.
Jackson’s role as an animal control officer gave her personal knowledge of the condition of numerous cats and dogs at intake, and their subsequent neglect and deterioration under the Neo’s Nation run TCAS. Jackson reported that Howard and Hernandez alone made all medical decisions for the shelter animals. When interviewed by Detective Lee, multiple employees and volunteers also stated that Howard and Hernandez alone made all medical decisions for the cats and dogs at TCAS.
Cherie Jackson ultimately quit working at TCAS over the neglect of a white and grey terrier pit bull mix named Brandt. Jackson observed that Brandt appeared healthy at his intake photo on September 7, 2021, yet quickly sickened under Howard and Hernandez’s care. No one at TCAS provided Brandt with the care he needed. Jackson said that Howard and Hernandez failed to take any action after being informed by multiple volunteers that Brandt had stopped eating.
Jackson took matters into her own hands, smuggling Brandt to the Horse Heaven Hills Pet Urgent Care Clinic in Kennewick a few weeks later. Clinic doctors diagnosed Brandt with kidney failure. Kidney failure can be caused by starvation, because prolonged malnutrition can lead to electrolyte imbalances and loss of fluid, leading to organ damage and failure.
Although Hernandez wanted to euthanize Brandt, Horse Heaven released Brandt to the Forgotten Dogs Rescue, which cares for “hopeless” pit bulls and terriers. Forgotten Dogs’ Director Kathleen Farrington and business partner Kathleen Marrett told Detective Lee that several volunteers from TCAS had contacted them about Brandt being refused care by Howard and Hernandez. Brandt soon died of kidney failure and pancreatis, with a gaunt body condition score of 2 out of 9. A two is the second lowest possible score, just above totally emaciated, and represents loss of muscle mass, with ribs, pelvic and backbone visible. Veterinarian Dr. Vang stated that Brandt could have been saved if he was given proper medical attention even a week or two earlier.
Cherie Jackson showed Detective Lee pictures of multiple cats being neglected at the shelter. Most were documented as healthy at intake, only to develop serious infections and painful illness once under the care and control of Howard, Hernandez and Neo’s Nation. Multiple employee and volunteer witnesses, including Michael Metz and Julie Webb, reiterated to Detective Lee that Howard and Hernandez exclusively made all medical decisions for the shelter animals.
Hernandez appears to have no medical qualifications to treat animals, despite Howard claiming that he was “vet certified” when Neo’s Nation bid for the contract. Howard made the same claim in emails to volunteers concerned about the neglected condition of animals at TCAS on October 7, 2021. Prior employer Autumn White of the Benton Franklin Humane Society told Detective Lee that Hernandez may have falsely claimed veterinarian certifications that he did not have.
While Hernandez continually implied that he was a registered veterinary technician, he lacked the necessary education and credentials. WAC 246-934-020 defines “veterinary technician” to mean a person registered under RCW 18.92 to practice as a veterinary technician who is authorized to perform specific tasks. Rather, Hernandez appears to be an unregistered assistant, who can perform virtually no tasks on an animal unless under the direct supervision of a licensed veterinarian or veterinary technician, of which Neo’s Nation had neither. WAC 246-935-050 lists dozens of tasks that unregistered assistants are prohibited from performing, such as ear flushing or bandaging an animal.
Detective Lee and several Pasco Police detectives executed a search warrant on TCAS on November 11, 2021. Andrea Moreno, director of Mikey’s Chance, and Vista Veterinary Hospital Dr. Michelle Myer also took part in the search in order to evaluate and remove those cats and dogs most in need of immediate medical attention.
A laundry room of the main TCAS building housed multiple dogs. Dr. Myer determined that four of those dogs were so thin that they required immediate medical attention. The laundry room also housed several cat crates containing healthy kittens intermingled with cats that Dr. Myer determined to be extremely sick and infected. Detective Jon Davis photographed the areas searched and the neglected animals observed; multiple officer’s body cameras also recorded the search.
Detectives next searched an unheated outbuilding with a sign saying it was closed to the public. TCAS volunteer Julie Webb told Detective Lee that Howard and Hernandez warned employees and volunteers that they were prohibited from entering the outbuilding. The outbuilding door had a lock requiring a number code to enter. Webb stated one or two hand-picked employees a day might be allowed to enter, and no more. Excluding the public from the outbuilding violated Neo’s Nation’s contract with the city, because owners must be allowed to enter and search for lost pets.
Dozens of cats were stacked in crates three-high in the outbuilding. Each crate held multiple cats. Some crates had only Rubbermaid bin lids as a “floor,” with debris falling from cage to cage. Detectives observed that the outbuilding was infested with mice and in extremely filthy conditions. Detectives noted that debris around some cages appeared to not have been cleaned in months. Dr. Myer noted that most of the outbuilding cats were in dire need of intervening medical attention, suffering from severe and painful respiratory and eye infections. Many cats suffered from their eyes and noses being acutely matted shut from the severity of their infections.
As the search uncovered mounting evidence of the unsanitary conditions in TCAS, and the neglected state of dozens of cats and dogs, Detective Lee notified Pasco Administrative and Community Service Director Zack Rathkai. Rathkai had officers serve Howard and Hernandez with termination letters and trespassed them from TCAS property for violating terms of the Neo’s Nation contract with the city. The stated breach of contract included the poor health of the neglected cats and dogs, and the denial of public and staff access to the outbuilding, which materially breached the contract. The city cited evidence showing the ill-intent of Howard and Hernandez, and that their “dangerous, illegal, unsafe or disruptive” conduct showed bad faith in carrying out the purpose of the public shelter.
Several dozen cats and dogs found during the search were in terribly neglected condition. Yet the Humane Society assisting in the search could only provide safe sanitary conditions for thirty cats and five dogs. Dr. Myers gave those 35 animals priority in removal. Numerous cats whose intake records showed they arrived safe and healthy had, within three weeks under Howard and Hernandez’s care, developed ringworm, respiratory infections, and eye infections so severe that many required enucleation to surgically remove their eyes. Multiple dogs were severely malnourished. A few animals had open, untreated wounds. Some kittens were sneezing blood. Many of the cats removed in the search went to the Tumbleweed Cat Rescue (TCR) for proper medical care and attention.
Evidence of Violations Regarding Animals Recovered in the Search
One of the severely malnourished dogs removed in the search was a puppy named Romeo. Veterinarians diagnosed Romeo as very underweight at 22 pounds when removed. After two weeks of proper feeding and nutrition, the ravenous puppy weighed 31.7 pounds. This 50% weight gain from two weeks of proper care and feeding demonstrates the negligent starvation inflicted on the puppy prior to the search.
Fourteen of the cats removed in the search provided evidence of Howard and Hernandez’s negligent failure to provide necessary sanitation or medical care which resulted in unnecessary pain and suffering to the animal. These included the following:
Cora is a black and white bicolored shorthaired domestic cat. At her intake into TCAS on August 26, 2021, records and photos show Cora was a healthy kitten. Under the care and control of Howard and Hernandez, Cora developed ringworm, respiratory and ocular infections so bad that that an outside veterinarian performed surgery to remove an eye two weeks prior to the search. TCAS then continued to neglect her. Arriving at Tumbleweed Cat Rescue (TCR) after the search, Cora was sneezing blood and had very inflamed inner eyelids. TCR reported that there was no reason why Cora should have lost an eye due to severe infection, based on her healthy intake records upon initially entering TCAS. After a month of proper medical care and treatment, Cora was restored to health and available for adoption.
Curly is a mostly white shorthaired cat with a bit of grey on his head. At intake to TCAS on June 23, 2021, records and photographs show he was a small, normal, healthy kitten. When removed during the search, TCR documented that Curly was suffering from significant ringworm and respiratory infections acquired under the care of Howard and Hernandez at TCAS. Once given proper care and medical treatment at TCR, Curly was restored to being completely clear of his TCAS respiratory condition and 90% clear of ringworm within a few weeks.
Ice is a kitten who had been examined at TCAS by outside veterinarian Dr. Denise Wilson a week before the search. Dr. Wilson noted that Ice had a condition called pectus excavatum, which causes a concave chest, and was suffering from herpesvirus and severe upper respiratory infections. Dr. Wilson documented that kittens like Ice could do very well with a chest brace or splint, even with the respiratory infection, but not if he remained in TCAS. She noted that Ice’s best chance of recovery was with a dedicated foster and that he would be unlikely to survive if he remained inside TCAS.
Indigo is a small female grey and white tabby with no documented health issues at her TCAS intake on June 3, 2021. When examined by Dr. Wilson on October 14, 2021, Indigo was suffering from severe conjunctivitis and apparent uveitis (inflammation inside the eye resulting from infection). Dr. Wilson noted that she was unable to fully visualize Indigo’s cornea due to the severity of conjunctival swelling. Her left eye was entirely sealed shut from swelling. Indigo had bilateral nasal discharge, and herpesvirus infection. Indigo’s medical assessment included stress induced infections resulting from overcrowding and poor ventilation inside TCAS.
Jackie Chan is a black and white male cat with no noted health issues at his TCAS intake on September 8, 2021. By the time of his removal during the November 11, 2021, search, Jackie Chan had lost an eye to the severity of untreated infections he suffered while under the care and control of Howard and Hernandez.
Jackson, an orange male domestic shorthair tabby, was documented as a healthy cat at his TCAS intake on June 26, 2021. His records show no ringworm, and a mild ocular discharge. By August, his records document normal eyes but note ringworm. When removed during the November search, Jackson was suffering from eye infections so severe that they caused permanent scarring and damage to his eyes. Jackson’s painful conditions were acquired during the months he was under the care of Howard and Hernandez.
Loverboi’s intake records from late September, 2021, document that he was a healthy white domestic shorthaired kitten with no medical issues. After six weeks under the care and control of Howard and Hernandez, Loverboi was underweight and suffering from significant respiratory infections, herpesvirus, painful ear mites, bleeding from his left nostril, and with debris in his ears. These painful conditions were documented by TCR after his removal from TCAS. Once he was treated with proper care, sanitation and medical attention at TCR, Loverboi was restored to good health within a month.
Nacho was a healthy orange male domestic shorthaired cat with no medical issues at her TCAS intake on August 11, 2021. When examined by Dr. Wilson on October 13, 2021, Nacho was suffering from herpesvirus infection, bronchopneumonia, bilateral nasal discharge, and mucus and pus discharge from both eyes due to infection and inflammation. Nacho’s left eye had sealed shut from the severity of ocular discharge and his lungs were diagnosed as abnormal.
Nubbins weighed only 2.8 pounds when examined by outside veterinarian Dr. Wilson on October 14, 2021. The grey and white domestic shorthaired male tabby was a normal healthy cat as documented by his intake records from September 21, 2021. After three weeks under the care of Howard and Hernandez, Nubbins suffered from painful conditions including severe ear mite infestation, herpesvirus infection, bilateral conjunctivitis, and bilateral nasal discharge, along with inflamed and crusted over ears and nose from lack of necessary sanitation and medical attention.
Ronnie was a healthy grey and white domestic shorthaired male cat at his TCAS intake in early October, 2021. After two weeks under the care of Howard and Hernandez, Dr. Wilson diagnosed Ronnie with a nailbed infection, herpesvirus infection, a left hind foot wound, and severe eye infections which caused permanent ulceration and corneal edema (a blue cobblestone effect in the eyes resulting from severe untreated infection). Ronnie was assessed with bilateral severe blepharospasm, tearing, conjunctivitis, and corneal neovascularization as a result of the untreated eye infections he endured within weeks of entering TCAS.
Ryder was a kitten removed during the search and suffering from a severe urinary tract infection acquired at TCAS. After a few weeks of proper care and medical treatment at TCR, Ryder was restored to good health.
Serrano was a cat covered in fleas, infected with ringworm, and suffering from a severe respiratory infection acquired at TCAS. Upon examination following the search, Serrano’s eyelids were so inflamed that the TCR veterinarian could not see or examine his eyes until after a full week of antibiotics made that viewing possible, following his removal from the unsanitary outbuilding. Serrano’s eyes were so severely ulcerated and damaged that they had to be surgically removed.
Sweetheart, a grey and white domestic shorthaired female tabby was documented as healthy in her TCAS intake records from September 28, 2021. When removed during the search, Sweetheart was sick with ringworm. After a month of proper sanitation and medical attention at TCR, Sweetheart was restored to good health.
A kitten with no identifying information (“unnamed abscess kitten”) was removed during the search. This kitten was crowded into a cage with 3 other kittens and no name tag identifying her. This kitten was suffering from an open and untreated wound over her trachea that appeared to be an abscess that burst. A burst abscess results from diseased tissue that leads to pain, foul odor and discharge. Treating veterinarian Dr. Alison Brendel noted the pain this kitten suffered at TCAS, and the kitten’s treatment included required sutures to her open throat wound as well as a course of pain medication.
Detective Lee’s investigation gathered statements from multiple TCAS shelter employees and volunteers regarding Howard and Hernandez’s pattern of neglect toward the cats and dogs in their care. TCAS employee Michael Metz told Detective Lee that Howard and Hernandez moved hundreds of cats into the poorly ventilated, unheated outbuilding with one sink and no hot water around July, 2021. Metz found this senseless and unreasonable because all of the supplies needed for the cats’ care were located in the main building.
Metz believed that Howard and Hernandez moved the animals into the bleak outbuilding to hide the numerous sick and neglected cats and kittens from public view. Because sick cats cannot be sterilized, and cannot be adopted out until they are sterilized, this warehousing of sick cats in the outbuilding became worse and worse over time.
TCAS volunteer Julie Webb told Detective Lee that Howard and Hernandez warned that no volunteers were allowed to enter the locked outbuilding hiding the sick cats. Webb stated that none of the dozens of terribly sick cats in the outbuilding were seen by a veterinarian, no matter how dire their medical condition. Howard and Hernandez alone dealt with caring for those cats. Michael Metz told Detective Lee that when he informed Hernandez of extremely sick individual cats in need of immediate medical attention, Hernandez would claim they would be taken to an outside veterinarian, but then failed to arrange any actual medical attention for the suffering cats and kittens.
Additional evidence supports that assertion. When Dr. Wilson made weekly visits to TCAS in October of 2021, the purpose was for her to examine those animals most needing medical intervention. Yet Michael Metz told Detective Lee that the sickest cats and kittens from the forlorn outbuilding were never brought to see Dr. Wilson on those visits to TCAS. Only cats from the main building were brought to her attention. Dr. Wilson told Detective Lee she was very upset to learn of the conditions in the outbuilding, because Howard and Hernandez never made her aware of the dreadful circumstances of the cats and kittens there.
Dr. Wilson was concerned that cats and kittens which she did examine were not improving over the five weeks she visited TCAS. Dr. Wilson told Detective Lee that the cats and kittens she examined should have improved with proper sanitation and medical attention at TCAS, but their medical conditions did not improve.
Detective Lee’s investigation also gathered evidence that Howard and Hernandez willfully disregarded taking steps that could have mitigated the suffering of the cats and dogs that became progressively sick under their care. For example, in the fall of 2021, Dr. Wilson arranged Zoom meetings with Hernandez, herself, Dr. Erica Schumaker, a veterinary shelter medicine expert from the University of Wisconsin, and a consulting veterinarian from the national American Society for the Prevention of Cruelty to Animals (ASPCA).
Dr. Shumaker gave Hernandez specific detailed advice on improving sanitation in the shelter, modifying cage sizes and conditions, how to reduce stress on the cats and dogs, ways to reduce infectious disease, etc. This included very precise technical advice on vaccination increases to combat specific contagious feline infections like calicivirus. Dr. Shumaker authorized TCAS to submit samples and necropsies to the university as needed to reduce disease outbreaks. Her detailed instructions included a video on proper sample gathering and labeling.
Yet Howard and Hernandez never replied to the experts’ emails or follow up, failing to implement the changes that would have improved the health of the cats and dogs in their care, according to Dr. Wilson and Dr. Schumaker. Treatment records and emails document times that Dr. Wilson recommended necessary medical treatment, but Howard and Hernandez declined. Numerous cats and kittens who arrived at TCAS perfectly healthy ended up with permanent damage, such as loss of eyes due to untreated infections under the care and control of Howard and Hernandez.
Howard and Hernandez repeatedly failed to meet the standards of sanitation and medical attention they promised to implement in the Neo’s Nation bid to run TCAS. At least 15 animal control officers, shelter employees and volunteers ultimately quit their positions, rather than continue to watch cats and dogs needlessly suffer and die at TCAS. Cherie Jackson provided Detective Lee with a list of the names and titles of those who quit rather than watch animals needlessly suffer, such as Michael Metz and Mikayla Sailee. Several other employees and volunteers, including Julia Schroder and Liz Randall, had complained of the neglect and suffering of cats and dogs under Howard and Hernandez.
Evidence gathered in the investigation also suggests consciousness of guilt. The defendants moved hundreds of cats into the unsanitary outbuilding, hiding the sickest cats and kittens from their own employees and volunteers, and the public. They did not allow visiting Dr. Wilson to enter the outbuilding. Nor did they allow her to see the cats and kittens most in need of immediate medical attention, hiding those away in the outbuilding, according to multiple TCAS witnesses. Howard, Hernandez and Chambers also voted themselves pay raises, without any other board members being present.
Rebecca Howard and Justin Hernandez took each and every of the aforementioned actions while acting as an officer, governor and employee of Neo’s Nation Animal Foundation. Both were listed as the two governors of Neo’s Nation Animal Foundation when the organization’s incorporation was filed with Washington State. When interviewed, multiple TCAS employees and volunteers told Detective Lee that Howard and Hernandez alone made all health, sanitation and medical decisions for the cats and dogs under their care and control. Those two engaged in or tolerated the conduct constituting the aforementioned animal cruelty, while acting within the scope of their duties and on behalf of Neo’s Nation. Neo’s Nation was aware of the required standards of sanitation and medical care required, as the company outlined in detail when it published its bid to operate TCAS. The three codefendants failure to provide necessary care constituted a gross deviation from the standard of care that a reasonable person would exercise in the same situation.
I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct.
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