Dr.

Robert Gibbens 11/17/17

Director, Western Region, USDA/APHIS/AC,
2150 Center Ave.
Building B, Mailstop 3W11
Fort Collins, CO 80526-8117

Dr. Gibbens,

I am writing to you today to file an Official Complaint against Antibodies Inc. (93-R-0158) of Davis (CA) for clear violations of
the Animal Welfare Act . Antibodies Inc. Correspondence (attached) provides details of the negligent deaths of five alpacas
due to Oleander poisoning. The report states:

"Five alpacas died at our facility as a result of an accidental poisoning by oleander on the weekend of 14 - 16 July, 2017.
The oleander was part of a brush pile dumped on the property by an employee on Friday (July 14). . . . investigation and
have identified the root causes as (1) a failure to comply with AWA Ss. 3.131 - Sanitation (c) Housekeeping."

The report goes on to say that:

"Lack of training of all the employees in these procedures governing the health and welfare of animals. Although the
employee, as a member of the maintenance crew, had legitimate access to the area, the establishment of a 'burn pile' in an
area accessible to the alpacas was poor judgment."

I agree with their analysis and would suggest that an additional citation should be issued under Ss. 2.32 Personnel
Qualifications, because in their own words, this was due in large part to a "Lack of training."

Due to the serious and fatal nature of this incident, I hereby file an Official Complaint against Antibodies Inc. relevant to the
unnecessary and negligent deaths of five alpacas.

I know that your office considers major violations of the Animal Welfare Act to be very serious in nature, especially when
these violations kill, abuse, or seriously injure animals. Since the Antibodies Inc. has negligently killed five animals, I must
insist that you take the most severe action allowable under the Animal Welfare Act and immediately begin the process of
issuing the maximum fine allowable against Antibodies Inc. at the completion of your investigation -- $10,000 per infraction,
per animal.

I look forward to hearing from you in the near future about the fate of this facility.

Sincerely,

Michael A. Budkie, A.H.T.,

Executive Director, SAEN

1081-B State Route 28 #280 Milford, OH 45150 513-575-5517 www.SAENonline.org