CIRCUIT COURT FOR WASHINGTON COUNTY, TENNESSEE, RANDOLYN LAFERNEY, Plaintiff, v. DOCKET NO. S464 KIM LIVESAY, PAEZHA MARAE MCCARTT, ASHLEY VAUGHN WEST, AMY BRYANT, fied SS day of JANET MCDANIEL KEENER, Cy ae ee HANNAH CARLEY, Yom 80 LOURIENNE LONG, 4-40 sek CANDISE LEJEUNE, NICOLE STUWA, Individually, Brenda f TAMMY DAVIS, Individually, and WASHINGTON COUNTY, TENNESSEE. Defendants. COMPLAINT Comes now the Plaintiff, Randolyn LaFerney (hereinafter referred to as “Plaintiff”), by and through counsel, pursuant to the laws and Constitution of the State of Tennessee and submits her Complaint against Defendants (hereinafter referred to collectively as “Defendants” and/or individually as follows) Kim Livesay (hereinafter referred to as “Defendant Livesay”), Paezha Marae MeCant (hereinafter referred to as “Defendant MeCartt), Ashley Vaugh West (hereinafter referred to as “Defendant West”), Amy Bryant (hereinafter referred to as “Defendant Bryant”), Janet McDaniel Keener (hereinafter referred to as “Defendant Keener"), Hannah Carley (hereinafter referred to as “Defendant Carley”), Lourienne Long (hereinafter referred to as “Defendant Long”), Candise Lejeune (hereinafter referred to as “Defendant Lejeune”), Animal Control Officer Nicole Stuwa, Individually (hereinafter referred to as “Defendant Stuwa”), TammyDavis, Individually (hereinafter referred to as “Defendant Davis”), and Washington County, ‘Tennessee (hereinafter referred to as “Defendant County”). PARTIES 1. Plaintiff is a citizen and resident of Sullivan County, Tennessee and resides in Piney Flats, Tennessee 37686. 2. Upon information and belief, Defendant Livesay is a citizen and resident of Washington County, Tennessee and may be served with process at 3408 Stoneridge Dr., Johnson City, Tennessee 37604. 3. Upon information and belief, Defendant McCartt is a citizen and resident of Washington County, Tennessee and may be served with process at 3408 Stoneridge Dr., Johnson City, Tennessee 37604. 4, Upon information and belief, Defendant West is a citizen and resident of Sullivan County, Tennessee and may be served with process at 1355 Highridge Drive, Kingsport, Tennessee 37664 5. Upon information and belief, Defendant Bryant is a citizen and resident of Knox County, Tennessee and may be served with process at 4324 Lamour Dr., Knoxville, Tennessee 37909. 6. Upon information and belief, Defendant Keener is a citizen and resident of Hawkins County, Tennessee and may be served with process at 145 Parkview St., Church Hill, Tennessee 37642. 7. Upon information and belief, Defendant Carley is a citizen and resident of Sullivan County, Tennessee and may be served with process at 1222 Sussex Drive, Kingsport, Tennessee 37660. Page 2 of 218. Upon information and belief, Defendant Long is a citizen and resident of Knox County, Tennessee and may be served with process at 1851 Serene Cove Way, Knoxville, Tennessee 37920. 9. Upon information and belief, Defendant Lejeune is a citizen and resident of St Charles Parrish, Louisiana and may be served with process at #21 Wildcat Lane, Destrehan, Louisiana 700747. 10. Upon information and belief, Defendant Stuwa is a citizen and resident of Sullivan County, Tennessee and may be served with process at 3322 Wil Rho Cir., Kingsport, Tennessee 37660. 11. Upon information and belief, Defendant Davis is a citizen and resident of Washington County, Tennessee and may be served with process at 1816 McClellan Dr., Johnson City, Tennessee 37604 12. Washington County, Tennessee may be served with process by and through Mayor William “Joe” Grandy at 100 E. Main St., Jonesborough, Tennessee 37659. JURISDICTION & VENUE 13. Plaintiff's causes of action arise in tort under and by virtue of the laws of the State of Tennessee for the damages and injuries Plaintiff has sustained and continues to sustain as @ result of Defendants’ defamatory, negligent, reckless, intentional and malicious acts surrounding events which occurred in Washington County, Tennessee. 14. This Honorable Court has personal jurisdiction in this matter pursuant to Tenn. Code Ann, §§ 20-2-222, 20-2-223 and, as well as, subject-matter jurisdiction pursuant to Tenn. Code Ann. §§ 16-10-101 and 29-20-305. Page 3 of 2115. Venue is proper before this Honorable Court fora trial on the merits in Washington County, Tennessee pursuant to Tenn. Code Ann. §§ 20-4-101, 20-4-102 and 29-20-308. BRIEF STATEMENT OF FACTS 16. On May 2, 2019, an American bull terrier named Dallas passed away while in the care of Andrew Hunigan (hereinafter referred to as “Mr. Hunigan”), an independent contractor for Plaintiff's Off the Leash canine training facility located in Washington County, Tennessee. 17. Off the Leash is a national canine training franchise, of which Plaintiff is a franchisee with multiple facilities located in Tennessee and other states. 18. ‘The owners of Dallas, Brian and Susan Arnold (hereinafter referred to collectively as the “Amolds”), delivered Dallas to Mr. Hunigan on or about March 18, 2019 to board and train at Mr. Hunigan’s residence. 19, The Amolds delivered Dallas to Mr. Hunigan directly and did not communicate with Plaintiff, after the initial consult, until Plaintiff received the deceased dog from Mr. Hunigan. 20. Plaintiff did not observe or interact with Dallas up until the date of his death when Plaintiff obtained Dallas’ corpse from Mr. Hunigan, 21, After learning of Dallas’ death, Plaintiff obtained Dallas’ corpse, wrapped in a blanket, from Mr. Hunigan whereby Plaintiff sought to make arrangements with the Amolds for Dallas’ corpse. 22. Dallas’ body was later taken to Mountain Empire Small Animal Hospital in Johnson City, Tennessee and a necropsy was performed on May 3, 2019 by Dr. Mee Ja M. Sula, DVM, DACVP. Page 4 of 2323. On May 7, 2019 and based upon the sworn oath of Defendant Stuwa, an arrest warrant for Plaintiff was issued by the General Sessions Court for Washington County, Tennessee for the crime of aggravated cruelty to animals, 24. On January 30, 2020, District Attormey General Kenneth Baldwin and the State of Tennessee dismissed Plaintiff's charge of aggravated cruelty to animals. CAUSES OF ACTION Count One: False Light Invasion of Privacy by Defendants Livesay. Bryant, Carley. McCartt, Lejeune, West, Long and Keener 25. Plaintiff hereby adopts and incorporates by reference all prior paragraphs set forth in this Complaint as if sated verbatim herein. 26. Since May 2, 2019, certain named Defendants have commenced a campaign of disseminating false and misleading information relating to Dallas’ death in an effort to have Plaintiff falsely imprisoned and in an attempt to assassinate Plaintiff's character, reputation and pecuniary interests. 27. Plaintiff avers Defendants Livesay, McCartt, West, Bryant, Keener, Carley, Long and Lejeune have each publicized, by social media posts and other online publications, accusations regarding Plaintiff's association with and culpability for heinous acts which undoubtedly are highly offensive to a reasonable person. 28. Plaintiff avers the above-named Defendants knew of or acted in reckless disregarded as to the falsity of their publications concerning the facts of Dallas’ death; Plaintif’s involvement with Dallas’ death and Plaintiff's criminal culpability, as well as, the falsity of their publications made concerning Plaintiff's businesses and business relationships. Page 5 of 2129. Plaintiff avers the above-named Defendants maliciously, intentionally and/or recklessly publicized false, misleading and or misrepresented information to skew the public's perception of Plaintiff as being culpable for Dallas’ death, as well as, other instances of animal abuse and neglect. DEFENDANT LIVESAY'S FALSE LIGHT INVASION OF PLAINTIFF'S PRIVACY 30. Plaintiff avers Defendant Livesay launched her attack against Plaintiff within hours ‘of Dallas’ death and has continued to publicize false and misleading information regarding Dallas’ death, Plaintiff and Plaintiff's businesses in effort to inflame the public’s perception of Plaintiff and her businesses. See photographs of Defendant Livesay’s publications attached hereto as “Exhibit A” 31. On multiple occasions, Defendant Livesay publicized false and misleading information concerning Dallas’ body being frozen and thawed, as well as, Dallas’ loss of 2/3 of his body weight while in the care of Plaintiff and her business. See “Exhibit A”. 32. Defendant Livesay published a link from a local news station showing Plaintiff's canine training facility in Johnson City, Tennessee and captioned the link with “!!!!UPDATE!!!! ‘The dog’s death was an accident ... What a damn lie!!!”. See “Exhibit A”. 33. Defendant Livesay publicized false and misleading information concerning Plaintiff's involvement with other canine deaths at training facilities located in the State of Florida, as well as, Plaintiff's knowledge of Mr. Hunigan’s abuse of animals while in his employment with Plaintiff. See “Exhibit A”. 34. Plaintiff avers Defendant Livesay disseminated photographs of Dallas’ corpse following its necropsy to mislead potential viewers along with a caption which indicates Plaintiff or her business may have intentionally killed Dallas. In the same publication, Defendant Livesay Page 6 of 21held herself out to viewers as a cond (0 attorneys involved in prosecuting Plaintiff and requested others to supply her “additional info” presumably related to negative information concerning Plaintiff. See “Exhibit A”. 35. Plaintiff avers Defendant Livesay publicized false and misleading information related to Plaintiff's former involvement in an organization called the Southeast German Shepard Rescue. See “Exhibit B” 36. Plaintiffavers Defendant Livesay has directly implicated Plaintiff for Dallas” death while simultaneously holding herself out to the public as an individual involved with the investigation of Dallas’ death. See “Exhibit A”. 37. Plaintiff avers Defendant Livesay repeatedly publicized Plaintiff's ownership of other businesses while discussing matters related to Dallas’ death in an effort to inflame public perception of the Plaintiff and injure Plaintiff's business interests. See “Exhibit B”. DEFENDANT BRYANT'S FALSE LIGHT INVASION OF PLAINTIFF'S PRIVACY 38. Plaintiff avers Defendant Bryant, a presumed associate of and conspirator with Defendant Livesay, repeatedly publicized Plaintiff's ownership of other businesses while discussing matters related to Dallas’ death in an effort to inflame public perception of the Plaintiff and injure Plaintiff's business interests. See “Exhibit A”. 39, Plaintiff avers Defendant Bryant publicized false and misleading information regarding Dallas’ body being frozen to further the proposition that Plaintiff took part in some form of cover-up related to Dallas’ death, See photographs of Defendant Bryant's publications attached hereto as “Exhibit B”. 40. Plaintiff avers Defendant Bryant publicized false and misleading information regarding Plaintiff's involvement in animal neglect cases in the State of Florida, as well as, Page 7 of 23,reiterated the conspiracy that Plaintiff has hidden other instances of abuse and neglect. See “Exhibit BY. DEFENDANT CARLEY’S FALSE LIGHT INVASION OF PLAINTIFF'S PRIVACY 41. Plaintiff avers Defendant Carley, a presumed associate of and conspirator with Defendant Livesay, attacked Plaintiff's other business interests by publicizing false and misleading information concerning other cases of neglect, abuse and death of canines caused by Plaintiff and her businesses. See photographs of Defendant Carley’s publications attached hereto as “Exhibit ey 42. Defendant Carley publicly labeled Plaintiff as “a soon to be convicted felon who has continually contributed and covered up the deaths of countless family pets. Don’t bring your dong to get donuts... they aren't dog friendly.” See “Exhibit C”. DEFENDANT MCCARTT'S FALSE LIGHT INVASION OF PLAINTIFF'S PRIVACY 43. Defendant McCartt, a presumed associate of and conspirator with Defendant Livesay, publicized false and misleading information regarding other instances of animal abuse Plaintiff's canine training facilities, as well as, publications which directly implicated Plaintiff for Dallas’ death. See photographs of Defendant McCartt’s publications attached hereto as “Exhibit Db”. DEFENDANT LEJEUNE'S FALSE LIGHT INVASION OF PLAINTIFF'S PRIVACY 44. Defendant Lejeune, a presumed associate of and conspirator with Defendant Livesay, publicized false and misleading information regarding Plaintiff's involvement with other canine deaths in the State of Florida at other canine training facilities. See photographs of Defendant Lejeune’s publications attached hereto as “Exhibit E”. DEFENDANT LONG'S FALSE LIGHT INVASION OF PLAINTIFF'S PRIVACY Page B of 2345. Defendant Long, a presumed associate of and conspirator with Defendant Livesay, publicized false and misleading information related to Plaintiff's former involvement in the Southeast German Shepard Rescue organization in relation to other publications conceming, Plaintiff and Dallas’ death. See photographs of Defendant Long’s publications attached hereto as “Exhibit F” DEFENDANT WEST'S FALSE LIGHT INVASION OF PLAINTIFF'S PRIVACY 46. Defendant West, a presumed associate of and conspirator with Defendant Livesay, repeatedly publicized false and misleading information concerning Dallas’ death, Plaintiff and Plaintiff's businesses, as well as, communicated such false and misleading information to entities with whom Plaintiff has business relationships. See photographs of Defendant West's publications attached hereto as “Exhibit G”. DEFENDANT KEENER’S FALSE LIGHT INVASION OF PLAINTIFF'S PRIVACY 47, Defendant Keener, a presumed associate of and conspirator with Defendant Livesay, publicized the events surrounding Dallas’ death by means of a petition titled “#JusticeFor Dallas — Puppy starved to death at training facility” wherein she solicited individuals to sign the petition 48. Plaintiff avers Defendant Keener publicized false and misleading information concerning Dallas’ death and/or Plaintiff's involvement therewith in an effort to inflame public perception of the Plaintiff whereby pressuring Plaintiff's prosecutors to prolong Plaintiff's criminal prosecution without probable cause to believe Plaintiff committed the crime of aggravated cruelty to animals. 49, Asaresult of the above-named Defendants’ online publications, Plaintiff's privacy has been violated by exposure to threats, harassment and intimidation; her name has been Page 9 of 21disparaged; she has been subjected to contempt; she has endured great mental anguish and embarrassment and she has suffered pecuniary damages Count Two: Malicious Prosecution by Defendants Livesay, McCartt, West, Bryant and Keener 50. Plaintiff hereby adopts and incorporates by reference all prior paragraphs set forth in this Complaint as if stated verbatim herein. 51. Plaintiff avers Defendants Livesay, McCartt, West, Bryant and Keener maliciously and intentionally procured Plaintiff's prosecution by means of misleading information, misrepresentations and false statements made to law enforcement officers and prosecutors involved in the criminal proceedings related to Plaintiff. 52. Plaintiff avers the above-named Defendants utilized their respective social media, as well as, other online forums, to propagate an army of followers thereby distributing Defendants? stream of falsehoods, misrepresentations and misleading information concerning the Plaintiff and her businesses. 53. Plaintiff avers the above-named Defendants deliberately spread such false, misleading and outrageous allegations concerning Plaintiff to ensure her criminal prosecution and to injure Plaintiff financially, 54. Plaintiff avers the above-named Defendants’ expansive online propaganda campaign against Plaintiff was and is still improperly motivated by their desire to manipulate and influence Plaintiff's criminal prosecution. 55. Plaintiff avers the above-named Defendants’ online campaign generated enough Public uproar that prosecutors felt pressured to maintain the criminal proceeding against Plaintiff, without probable cause, for aggravated cruelty to animals until its dismissal on January 30, 2020. Page 10 of 2356. Plaintiffhas incurred expenses for attomey's fees in defending said criminal charge, she incurred the costs of the bond posted in the criminal proceeding, she suffered mental anguish, humiliation and embarrassment and sustained a loss of earnings and loss of ability to earn money in her business as a direct result of the above-named Defendants’ acts. Count Three: Malicious Prosecution by Defendant Stuwa 57. Plaintiff hereby adopts and incorporates by reference all prior paragraphs set forth in this Complaint as if stated verbatim herein. 58. Defendant Stuwa commenced investigation of Dallas’ death after viewing the corpse on May 2, 2019 in response to a telephone call from Dr. Robert Monin, DVM, at Mountain Empire Small Animal Hospital. 59. Plaintiff was interviewed telephonically on May 6, 2019 by Defendant Stuwa and Defendant Davis, Director of the Washington County Animal Shelter, regarding Dallas’ death and Plaintiff's interaction, or lack thereof, with Dallas. 60. Plaintiff avers Defendant Stuwa intentionally misled Plaintiff as to the purpose of the May 6, 2019 interview and Plaintiff further avers she was never Mirandized by Defendant ‘Stuwa before being questioned by Defendants Stuwa and Davis, 61. Plaintiff avers Defendant Stuwa spoke with Mr. Hunigan and the Amolds during her investigation of Dallas’ death and all indicated Plaintiff had no contact with Dallas during his training. 62. Plaintiff avers Defendant Stuwa caused an arrest warrant to be issued for Plaintiff on May 7, 2019 based upon Defendant Stuwa’s false oath that probable cause existed to believe Plaintiff committed the crime of aggravated cruelty to animals. Page 11 of 21,63. Thereafter, Plaintiff tured herself into custody of the Washington County Sheriff's Office and criminal charges were brought in the General Sessions Court for Washington County, Tennessee. 64. On June 12, 2019, Defendant Stuwa testified during Plaintiff's Preliminary Hearing on the charge of aggravated cruelty to animals wherein Defendant Stuwa admitted her investigation showed Dallas was never in Plaintiff's custody or control from March 18, 2019 until May 2, 2019. See excerpt of Defendant Stuwa’s testimony from Transcript of Preliminary Hearing in the General Sessions Court for Washington County, Tennessee in State of Tennessee v. Randolyn LaFemey and Andrew Hunigan attached hereto as “Exhibit H”. 65 On January 30, 2020, rict Attomey General Kenneth Baldwin and the State of, Tennessee dismissed Plaintiff's charge of aggravated cruelty to animals. 66. Plaintiff avers Defendant Stuwa, in her individual capacity, intentionally and/or maliciously caused criminal proceedings to be brought against Plaintiff for aggravated cruelty to animals without probable cause to believe Plaintiff committed such crime. 67. Plaintiff avers Defendant Stuwa’s acted with malice and/or improper motive in causing Plaintiff's arrest for aggravated cruelty to animals when Defendant Stuwa knew probable cause did not exist for said charge, 68, Plaintiff avers Defendant Stuwa was improperly motivated by other named Defendants to cause Plaintiff's arrest for aggravated cruelty to animals even though probable cause did not exist to believe Plaintiff committed such crime. 69. _PlaintifFhas incurred expenses for attorney's fees in defending said criminal charge, she incurred the costs of the bond posted in the criminal proceeding, she suffered mental anguish, Page 12 of 21humiliation and embarrassment and sustained a loss of earnings and loss of ability to earn money in her business as a direct result of Defendant Stuwa’s actions. Count Four: Malicious Prosecution by Defendant Davis 70. Plaintiff hereby adopts and incorporates by reference all prior paragraphs set forth in this Complaint as if stated verbatim herein. 71. Plaintiff avers Defendant Davis, in her individual capacity, influenced and/or encouraged Defendant Stuwa to proceed upon causing Plaintiff's arrest even after investigation showed Plaintiff was not culpable for aggravated cruelty to animals. 72. Plaintiff avers Defendant Davis acted with malice and/or improper motive based upon her friendship with Defendant Livesay and/or personal animosity toward Plaintiff in utilizing Defendant Stuwa’s law enforcement powers to effectuate Plaintiff's prosecution for the untenable charge of aggravated cruelty to animals. 73. Plaintiff has incurred expenses for attorney's fees in defending said criminal charge, she incurred the costs of the bond posted in the criminal proceeding, she suffered mental anguish, humiliation and embarrassment and sustained a loss of earnings and loss of ability to eam money in her business as a direct result of Defendant Davis’ actions, Count Five: Intentional Interference with Business Relations by Defendants Livesay, McCartt, West, Bryant, Keener, Carley, Long, Lejeune and Davis 74, Plaintiff hereby adopts and incorporates by reference all prior paragraphs set forth in this Complaint as if stated verbatim herein. Page 13 of 2175. Plaintiff avers Defendants Livesay, McCartt, West, Bryant, Keener, Carley, Long, Lejeune and Davis were aware of Plaintiff's ownership of multiple dog training facilities in various states, as well as, other businesses located in East Tennessee, 76. Plaintiff avers she would have entered into other, future business relationships with clients for her dog training and other businesses, but for the tortious actions by the above-named Defendants. 77. Plaintiff avers the above-named Defendants made and/or shared communications upon social media and other online forums with false and misleading information intended to harm Plaintiff's businesses and relationships. 78. Plaintiff avers the above-named Defendants’ communications which “tag” or reference Plaintiff and her businesses with false and misleading information related to Dallas’ death are intended to harm and/or destroy Plaintiff's businesses and relationships. 79. Plaintiff avers the above-named Defendants’ communications and actions induced the online followers to harass, intimidate and threaten Plaintiff, Plaintiff's businesses and other entities having business relationships with Plaintiff. 80. Plaintiff avers the above-named Defendants deliberately spread false and misleading information to inhibit Plaintiff's ability to obtain new clients and business relationships, as well as, severing existing relationships with customers who were influenced by Defendants’ propaganda. 81. Plaintiff avers the above-named Defendants knew such interference was certain or substantially certain to occur as a result of their publication and promotion of false and misleading information. Page 14 of 21,82. Plaintiff has been directly damaged by the above-named Defendants’ willful, malicious and intentional interference with Plaintiff's current. and prospective business relationships in that she has lost profits, business relationships and/or other business opportunities. Count Six: Libel by Defendants Livesay, McCartt, West, Bryant, ner, Carley, Long and Lejeune 83. Plaintiff hereby adopts and incorporates by reference all prior paragraphs set forth in this Complaint as if stated verbatim herein. 84. Plaintiff avers Defendants Livesay, McCartt, West, Bryant, Keener, Carley, Long and Lejeune have continuously published or spread falsehoods and defaming statements concerning Dallas’s death, Plaintiff's criminal culpability for Dallas’ death and Plaintiff's history of animal cruelty and neglect since Plaintiff's arrest on May 7, 2019. 85. Plaintiff avers the above-named Defendants knew or should have known through the exercise of reasonable care and investigation that their statements concerning Plaintiff were false. 86. Plaintiff avers the above-named Defendants’ libelous conduct is maliciously and intentionally motivated by their intent to injure Plaintiff by association with heinous acts of animal abuse and cruelty. 87, Plaintiff avers she has been and continues to be injured in her good name, credit and reputation and brought into public scandal and disgrace as a result of the false and defamatory statements published by the above-named Defendants. 88. Plaintiff has suffered and continues to suffer lost profits, as well as, humiliation, mental anguish and embarrassment as a result of Defendants’ libelous publications. Page 15 of 21,Count Seven: Civil Conspiracy by Defendants Livesay, McCartt, West. Bryant, Keener, Carley, Long and Lejeune 89, Plaintiff hereby adopts and incorporates by reference all prior paragraphs set forth in this Complaint as if stated verbatim herein. 90. Plaintiff avers Defendants Livesay, McCartt, West, Bryant, Keener, Carley, Long and Lejeune conspired to defame Plaintiff by the purposeful dissemination and online publication of false and misleading information concerning Plaintiff's involvement in the abuse, neglect and death of canines. 91. Plaintiff avers the above-named Defendants conspired to injure Plaintiff by means of concerted attack of Plaintiff and her businesses through social media and other online forums. 92. Plaintiff avers the above-named Defendants further conspired to cause, manipulate and prolong Plaintiff's prosecution by pressuring Plaintiff's prosecutors with the social uproar resulting from Defendants’ propaganda campaign. 93. Plaintiff avers the above-named Defendants planned and undertook to put into operation a plan whereby Plaintiff's character, reputation and pecuniary interests have suffered damage resulting from Defendants’ false light invasion of Plaintiff's privacy; malicious prosecution of the Plaintiff; intentional interference with Plaintiff's business relations and/or libel of the Plaintiff. 94, Plaintiffavers the above-named Defendants engaged in a common scheme and plan to affect public perception of the Plaintiff by flooding online forums with false, misrepresented and/or misleading information thereby pressuring the District Attorney General's office to continue Plaintiff's prosecution without probable cause for aggravated animal cruelty. Page 16 of 2395. Plaintiffavers the above-named Defendants engaged in a common scheme and plan to damage Plaintiff's business interests and sever Plaintiff's business relations by flooding online forums with false, misrepresented and/or misleading information in order to injure Plaintiff via lost profits and/or lost business relationships. 96. Plaintiff avers the above-named Defendants took overt actions by planning and synchronizing their efforts in publishing the numerous false and misleading publications mentioned herein. 97. Plaintiff avers the above-named Defendants took overt actions by jointly recruiting followers with each other's false or misleading online publications, as well as, jointly advocating for individuals to join in injuring Plaintiff personally and financially, along with such entities having business rel nnships with Plaintiff, 98. Plaintiff avers the above-named Defendant's overt actions were performed in furtherance of unlawful purposes and in concert one with another, thereby engaging in a civil conspiracy. 99, Plaintiff has endured and continues to endure relentless mental anguish, humiliation, embarrassment and pecuniary loss due to the concerted action. the above-named Defendants. Count Eight: Civil Conspiracy by Defendants Livesay and Davis 100. Plaintiff hereby adopts and incorporates by reference all prior paragraphs set forth in this Complaint as if stated verbatim herein. 101. Plaintiff avers Defendants Livesay and Davis conspired to cause Plaintiff's prosecution by influencing Defendant Stuwa’s investigation and perception of Plaintiff. Page 47 of 21,102. Plaintiff avers Defendants Livesay and Davis improperly motivated and mislead Defendant Stuwa in an effort to ensure Plaintiff's arrest and prosecution. 103. Plaintiff avers Defendants Livesay and Davis planned and undertook to put into operation a plan whereby they manipulated Defendant Stuwa and exploited her law enforcement powers to cause Plaintiff's arrest and prosecution. 104. Plaintiff avers Defendants Livesay and Davis engaged in a common scheme and plan to attack Plaintiff's reputation and damage Plaintiff financially by causing Plaintiff arrest and prosecution for aggravated cruelty to animals. 105, Plaintiff avers Defendants Livesay and Davis took overt action to influence Defendant Stuwa’s investigation of Plaintiff by actively assisting Defendant Stuwa and/or providing Defendant Stuwa with false and/or misleading information regarding the Plaintiff or her businesses. 106. Plaintiff avers Defendants Livesay and Davis’ concerted actions have caused Plaintiff to endure arrest and prosecution for aggravated cruelty to animals, relentless mental anguish, humiliation, embarrassment and pecuniary loss for which Defendants are liable. Count Nine: Negligent Hiring, Training, and Supervision of Defens wa by Washington County, Tennessee 107. Plaintiff hereby adopts and incorporates by reference all prior paragraphs set forth in this Complaint as if stated verbatim herein 108. Plaintiff avers Defendant County is liable to Plaintiff for its negligent hiring, training and supervision of Defendant Stuwa. Page 18 of 23109. Plaintiff avers Defendant County is directly liable to Plaintiff for breach of its standard of care in hiring, training and supervising Defendant Stuwa in how to properly, lawfully and constitutionally perform her duties as an Animal Control Officer. 110. Plaintiffavers Defendant County's aforementioned breach of its standard of care in hiring, training and supervising Defendant Stuwa directly led to Plaintiff's arrest and prosecution for aggravated cruelty to animals without the existence of probable cause that Plaintiff had committed such crime. 111, Defendant Stuwa admitted during Plaintiff's Preliminary Hearing for the charge of aggravated cruelty to animals that her only training at that point consisted of “ride-alongs with the senior animal control officer” and “pamphlets and a book of the laws and regulations that we review ourselves” 112. Plaintiff avers Defendant Stuwa was permitted by Defendant County to perform the law enforcement duties of an Animal Control officer without proper training and supervision. 113, Plaintiff avers Defendant County should have reasonably foreseen or anticipated that Defendant Stuwa’s lack of training and supervision would lead to her violation of citizens” constitutional rights associated with investigation and arrests related to criminal offenses involving animals. 114. Plaintiff avers she has been damaged by Defendant County’s negligent hiring, training and supervision of Defendant Stuwa in that she has incurred attorney's fees in defending said criminal charge, she incurred the costs of the bond posted in the criminal proceeding, she suffered mental anguish, humiliation and embarrassment and sustained a loss of earnings and loss. of ability to eam money in her businesses. Page 19 of 21,PRAYER FOR RELIEF WHEREFORE, Plaintiff, Randolyn LaFerney, prays for the following relief: 1, That proper process issue to Defendants requiring them Answer this Complaint within the time allowed by law; 2. That Plaintiff be awarded judgment for compensatory damages against Defendants in the amount of Eight Million Five Hundred Thousand Dollars ($8,500,000) as a result of the tortious conduct stated above herein. 3. That Plaintiff be awarded punitive damages against Defendants in the amount of One Million Dollars ($1,000,000), for their recklessness, malice, and a specific intent to injure Plaintiff by means of the tortious conduct stated above herein, 4, That Plaintiff be awarded all costs, fees and/or expenses incurred in this cause of action. 5. Any further and general relief, in law or equity, as she may be entitled to. Respectfully submitted, LEITNER, WILLIAMS, DOOLEY & NAPOLITAN, PLLC ZA ‘A. FRASER (BPR No. 20087) ETHAN D. LAVELLE (BPR No. 35629) Attorney for Plaintiff Randolyn LaFerney. 900 South Gay Street Suite 1800 — Riverview Tower Knoxville, Tennessee 37902 (865) 523-0404 Page 20 of 21,COST BOND 1, Randolyn LaFemey, as Principal, and Leitner, Williams, Dooley & Napolitan, PLLC, as Surety, are held and firmly bound unto the Washington County Circuit Court Clerk, for the payment of all costs awarded against the Principal, To that end, we bind ourselves, our heirs, executors and administrators. The Principal is commencing a legal proceeding in the Circuit Court for Washington County, Tennessee. If the Principal shall pay all costs which are adjudged against her, then this obligation is void. If the Principal fails to pay, then the Surety shall undertake to pay all costs adjudged against the Principal in accordance with Tenn, Code Ann, §§ 20-12-120 et. seq RANDOLYN LAFERNEY 405 Sugar Hollow Private Drive, Piney Flats, Tennessee 37686 PRINCIPAL LEITNER, WILLIAMS, DOOLEY & NAPOLITAN, PLLC 900 South Gay Street, Suite 1800, Knoxville, Tennessee 37902 ee Page 21 of 21(> 2020/06/09 14:27:29 3/49 CIRCUIT COURT FOR WASHINGTON COUNTY, TENNESSEE, RANDOLYN LAFERNEY, Plaintiff, % DOCKET NO, 39969 KIM LIVESAY, PAEZHA MARAE MCCARTT, ASHLEY VAUGHN WEST, AMY BRYANT, JANET MCDANIEL KEENER, HANNAH CARLEY, LOURIENNE LONG, CANDISE LEJEUNE, NICOLE STUWA, Individually, TAMMY DAVIS, Individually, and WASHINGTON COUNTY, TENNESSEE. Defendants, NOTICE OF LATE-FILED EXHIBITS TO COMPLAINT Comes now the Plaintiff, Randoiyn LaFemey, by and through counsel, and hereby gives notice of late filing the attached Exhibits A, B, C, D, E, F, G and H to Plaintiff's Complaint that were inadvertently omitied therefrom when filed om June $, 2020. Respectfully submitted, LEITNER, WILLIAMS, DOOLEY BY: ‘SER (BPR No. 20087} Attorney for Plaintiff Randotyn LaFerney, 900 South Gay Street Suite 1800 - Riverview Tower Knoxville, Tennessee 37902 (865) 523.0404(~ 2020/06/09 14:27:29 4/49 E) )F SERVICE |, the undersigned attorney, do hereby certify that the foregoing document has been delivered to all parties at interest in this cause by sending a true end correct copy of same in the United States mail, postage prepaid, in a properly addressed envelope to the following: Kim Livesay Paszha Marae McCartt Ashley Vaughn West 3408 Stoneridge Dr. 3408 Stoneridge Dr. 1355 Highridge Dr. Johnson City, TN 37604 Johnson City, TN 37604 Kingsport, TN 37664 Amy Bryant Janet McDaniel Keener Hannah Carley 4324 Lamour Dr. 145 Parkview St. 1222 Sussex Dr. Knoxville, TN 37909 Church Hill, TN 37642 Kingsport, TN 37660 Lourienne Long Candise Lejeune Nivote Stawa 1851 Serene Cove Way #21 Wildeat Lane 3322 Wil Rho Ci. Knoxville, TN 37920 Destrehan, LA 700747 Kingsport, TN 37660 Tammy Davis Washington County, TN 1816 McClellen Dr. clo Mayor William “Joe” Grandy Johnson City, TN 37604100 E, Main St Jonesborough, TN 37659 This the 9" day of June, 2020, LEITNER, WILLIAMS, DOOLEY Page2of2(> 2020/06/09 14:27:29 5/49 3 VZW Wi-Fi 14:03 +. < 2 Kim Livesay Kim Livesay wee tmin RUPDATEDS on the dog DEATH at Off Leash KQ training in Johnson City. The following information was obtained through CREDIBLE sources whose involvement in the situation will not be discussed. Aiso, if this were not factual, | would have never even made the post yesterday... it is being reported by the trainer and the owner of the franchise that this dog died in a tragic accident when his head was caught in a wire crate yesterday morning. This scenario is 100% INCOMPATIBLE with the facts. This dog lost 2/3rds of his body weight while in their care. This dog had sores on his body This dog had no scratches, cuts or brulsing to his head or neck This dog’s body had been frozen and thawed Is it any wonder the owner of this franchise offered to immediately have this dag’s body cremated at her expense’ we we Also, | was contacted by the manager of another facility within this owner's franchise holdings. | was asked to take my post down or to, at the very least, amend my post from yesterday so that no other trainers will lose their livelihood. | refused. While | agree that the actions/neglect/deception/ coverup by any individuals involved with this specific case do not impiicate those at another location, the fact remain: o fF ® ea au2020/06/09 14:27:29 6 /49 ue 12:08 ‘ Shop Now © comment @ Share kim Livesay “ iin @ TELTUPDATE ET TT ‘The dog’s death wes an accident”..... What a damn WCYB.COM Johnson City dog training company owner, trainer charged with aggravated cruelty to animat (> Like © Comment E> Share Christy Cottrelt o 38 Happy School Nurse Day!!> 2020/06/09 14:27:29 7 /49 A el oe kim Livesay cs o LOOM AT HIS BUCY!" Accident ony asst? hag Baas hohe 1 deatty ws 3 Te ene 189 Jone nd vithiother(> 2020/06/09 14:27:29 8 [49 — 1,095 shares Newest & Kim Livesay LET ME BE CRYSTAL CLEAR on one thing......in NO WAY/SHAPE/FORM/FASHION do the owners of this poor dog shoulder ANY responsibility for the MURDER of their dog. ZERO. None. Full stop. End of story. Anyone commenting otherwise is uneducated on this situation. Two week board and trains | within the professional dog training industry are i commonplace. The owners attempted to get/ see their dog MULTIPLE TIMES. They were lied to and misled and given the run around. Anyone commenting otherwise is doing so without knowing the details. | know them.... | | So, any keyboard warrior on here trying to shift | ANY of the blame onto the owners needs to stop. The ONLY people responsible for the murder of this dog are the owner of the facility and the trainer. id Like Reply OO«e GQ Niki Payne Wyatt Kim Livesay, the blame only falls in one dirartinn ane that's the trainar and numar (S) Write a comment... e2020/06/09 14:27:29 9/49 Verizon 1:25 PM 130 75% a Kim Livesay . Kim — aad 8 Randi LaFerney, who was charged with aggravated animal cruelty is Dallas’ death in Johnson City, also owns Duck Doughnuts in Knoxville. You can decide for yourself, but | will certainly not be spending my money at this... sa Amy Bryant (Qi. it recently Came to my attention that Randi Lafernay, who owns the Off Leash K9 Training Tri-Cities location and who was recently charged with aggravated cruelty to animals in the death of the 9 month old Bull Terrior named Dallas, also happens te be the franchise awner of Duck Donuts in Knoxville. Randi claims she is not responsible for the death ot Dallas. 1, for one, am responsible for where | spend my money and it wil not be at Duck Donuts(> 2020/06/09 14:27:29 10/49, wat Verizon 8:50 PM 104 78% om < & Kim Livesay ") Kim Livesay oe 2mins -@ ONLY an isolated incident with the Johnson City Off Leash location and Randi LaFerney??? Here is the evidence. You be the judge... Meet Oxana and Baloo. Their official stories, are in their owner's own words and official county reports and are in the comments. Read for yourself. : Both of these stories are with Randi Laferney’s West Palm Beach location and the same trainer she employed. included below is a brief synopsis of the documents and official accounts, Please read for yourself and decide... About the Palm Beach Off Leash report made by ANIMAL CONTROL in reference to Oxana, the German Shepherd. The call was toa private home, rented by two trainers and their employer RANDI LAFERNEY. The report _fmentions her by name and even her personal a 2 8 A “7> 2020/06/09 14:27:29 11 /49- ab Veriton & 2:50 PM 78 78% a < Kim Livesay Both of these stories are with Randi LaFerney’s West Palm Beach location and the same trainer she employed. Included below is a brief synopsis of the documents and official accounts. Please read for yourself and decide... About the Palm Beach Off Leash report made by ANIMAL CONTROL in reference ta Oxana, the German Shepherd. The call was to a private home, rented by two trainers and their employer RANDI LAFERNEY. The report mentions her by name and even her personal dog, Charlie. Oxana’s owner was denied information and access to his dog, so he became so worried, he drove to the home UNANNOUNCED. When he initially arrived, the trainer refused to allow him to see his dog. Leading the owner to call authorities. The trainer went back into the home and never came back out with his dog, So, the owner went into the home himself. He couldn't find his dog at first, but found multiple dogs in cages and 14 adult dags in the garage. He went outside and checked a> 2020/06/09 14:27:29 12 /49 sat Verizon 8:50 PM 1 OL 78% at < © Kim Livesay dog, Charlie. Oxana’s owner was denied information and access to his dog, so he became so worried, he drove to the home UNANNOUNCED. When he initially arrived, the trainer refused to allaw him to see his dog. Leading the owner to call authorities. The trainer went back into the home and never came back out with his dog. So, the owner went into the home himself. He couldn't find his dog at first, but found multiple dogs in cages and 14 adult dogs in the garage. He went outside and checked a horse trailer beside the garage and found his dog. The trailer was filthy. The dog was damp and covered in feces, She was underweight and had been neglected. The owner took her to his vehicle and went back to take pictures of the trailer to document and the trainer came outside and became aggressive with the owner and even threatened to send his dog out to bite him. The trainer went back into the house and the police officer showed up and the trainer came outside with an aggressive dog on a leash and was threatening to release the dog on the owner and this was observed by police. a 8 © @ A =/~ 2020/06/09 14:27:29 13 49, - ut Verizon F 6:51PM 7 Ob 78% a < Kim Livesay and covered in feces. She was underweight and had been neglected. The owner took her to his vehicle and went back to take pictures of the trailer to document and the trainer came outside and became aggressive with the owner and even threatened to send his dog out to bite him. The trainer went back into the house and the police officer showed up and the trainer came outside with an aggressive dog on a leash and was threatening to release the dog on the owner and this was observed by police. Also, they had no permit or paperwork for the dogs under their care. Animal control asked to see the paperwork and records and proof of ownership for the dogs in their care and they didn’t have any. The trainer said he was a trainer and not a bookkeeper, He also said owners are not allowed to visit their dogs at any time. About Baloo. This was also at the Palm Beach location. Baloo WAS an Akita, ona board and train, ee 3 &S nh a(> 2020/06/09 14:27:29 14 /49 - ab Verizon F 6:51PM FOR 78% mm < Kim Livesay He went to the same trainer, while the family went on a cruise. Emergency contact info was left with the trainer and all three of their adult sons were within a 30 min drive. After two weeks, the owner was notified by the trainer that Baloo was taken to the vet because he was dehydrated, lethargic and non- responsive. The owner has this in texts. The next day, the vet called them and Baloo was dead. They immediately returned home. The trainer admitted in text that Baloo had stopped eating and drinking and they did nothing. A necropsy was done at the Univ of Florida. it shows he was 80 pounds at the time of death and was 109 pounds when he went in. And, that 80 pounds is AFTER receiving iv fluids. He also suffered organ failure and was unrecognizable. The family states that in their opinion, Baloo died due to starvation, dehydration, mishandling, reckless abandonment and neglect.y~ 2020/06/09 14:27:29 15 /49 < Kim Livesay Kim Livesay ae the ONLY an isolated incident with the Johnson City Off Leash location and Randi LaFerney??? Here is the evidence. You be the judge... Meet Oxana and Baloo. Their official stories, are in their awner's own words an... ©p> 2020/06/09 14:27:29 16/49 A < Kim's Post ue Amy Bryant | will be the first to say it: | call BULLSHIT! She has been burning bridges in the rescue community for at least 5 years. The rescue she was associated with prior to starting with OLKS completely distanced themselves from her. And there have been at least two reported cases of neglect under her FL franchise. No telling how many people she has paid off/settled with outside of the public eye. To {ittle, to late! 3h Like Reply ous ® Brandon Reese She acts like this has never happened before regarding her company, but the truth is this isn’t the first time her and her & @ © A =(7 2020/06/09 14:27:29 17 49. Kim Livesay me tar the facts. an the left: Off Leash KG. T: onsared ads on s TNVA is running who died by y at UT He was with OF Least rmined by an official necro he was killed in May 2019, wer right pic— ted and charge wer and trainer of Off Leash Ko th a Class E felony in Dallas’ death annot tell you where to s) ir money oF nake a well informed de: oe Off Leash K9 Training, Tri-Cities TN/VA 3 Uo really rocked treining and working throu 3e control while off leash holding their plac and. @ #: Tony cl us today about our training packages. 960-8887 ebsite:7> 2020/06/09 14:27:29 18 /49 ~ Verizon LTE 9:03 PM FON 77% a < Kim Livesay , Kim Livesay is with Paezha Marae McCartt and Tammy Davis. Friday at 1:26 PM + Melvin and Emmy were thrilled to present Tammy Davis and the Washington Co Animal Shelter with a check for $550 today from our T-shirt sales!!! @ In the meantime, we will be working with Emmy on proper picture taking etiquette. «u¢ Qe(© 2020/06/09 14:27:29 19 /49 Verizon LTE 8:08 PM 4 OTT, a < Kim Livesay The front of the shirt has SEVEN of my biggest Facebook and Rescue cases and the quote “You can do something big, or you can do something small. Because whatever you do, it's better than nothing at ali" The pic was drawn by the insanely talented Rebekah Judaun Alison, @*, LUNA -~ No longer with us. She was locked in a condo here locally and starved to death. Her owner was convicted. DALLAS - No longer with us. He was kilied while in training with Off Leash K9 in Johnson City. Owner and trainer charged with Class E felonies. NOEL - She is the puppy who was hung from the ceiling by the teenagers in Carter Co. She is alive and well. ZOEY - She was stolen from her backyard, in broad daylight, in Johnson City. She was returned safely several days later. She is> 2020/06/09 14:27:29 20 /49 ~ «Verizon LTE 9:06 PM ao < Kim Livesay Lock at what YOU didi!!! isn’t that TOGETHER, we save so many!!i! Fe PLEASE SHARE! The more | sell, the more we donate!l2020/06/09 14:27:29 21/49 - Kim Livesay 5 % Just your weekly reminder....in the case of Dallas’ death, where he was starved to death while in the care of Off Leash K9 in Johnson City, TN.....the case where the owner of the facility and the trainer have been charged with Class E felonies in his death... Did you knew that the owner of the facility maintains publicly and in court that she is NOT responsible because the trainer is an “Independent Contractor'27? a 'have included the IRS’ own 20-point checklist for independent Contractors. Please see #6. it states...."Do you train the worker to de the job in a particular way? (independent Contractors are aleady trained) in Datias’ case, the trainer was NOT a dog trainer prior to working at Of Leash and was sent by the owner to the company’s training lacility to be trained to use the techniques and methods of Off Leash, OWNER BOus(7020/06/09 14:27:29 22 /49- a Verizon TN15 AM 38% a < Kim Livesay ', Kim Livesay ‘ . Yesterday at 6:41 Pi - Just a reminder that Dallas was STARVED TO DEATH at Off Leash KQ in Johnson City. Randi LaFerney owns the franchise. Andy Hunigan was the trainer who had Dallas. They have BOTH been charaed with a Class E Felony. ‘The franchise is still open and taking clients. This isn’t the FIRST animal that Andy has abused or neglected in his care while with Off Leash, Randi was AWARE of the past CASES and KEPT HIM EMPLOYED. And....if i didn’t know this was 100% FACTUAL, | wouldn’t type the words. Documents don’t lie....but people do. +s(> 2020/06/09 14:27:29 23/49 SIE IT. OB vO Aguas TE OF Bas 10 Ge 2 SON SRO BG 9G cuainOpe sey u DoSBBLOY Ae One y DaTIMA WRAP OF SHON? LOL OE BEE Hy 38 34. abewsep Joy gees A Sacibey Bop Ley io ever 5 anit ® oe pubis hist eOTEI3y LUAGOS GH IY HOE ° ae Asan) wy a We aay MET mare(7 2020/06/09 14:27:29 24/49 — y 2019+ May» @ Couriney Neverline Does she have a rescue too?! é ee @ vrrtivesa Courtney Novarlina she WAS over SGSR in TN, She ran it into the ground and the TN division shut down. She left multiple dogs stranded and fosters stuck with dogs and their vet bills. @P Courtney Nevertine Kim Livesay ..., how the heck did she get the job she has now?! Sick woman, | Colleen Gites Courtney Neveriine she bought into the franchise, She wasn't hired Like Reoly 1¢ Courtney Neveriine © tobe met though? eo Raiy 18 Kristin . Ammolel The trainer starved the dog to death. That abuse takes weeks, Fucking bastard, ie opty 14 oe Cynthia Barb-Gray This poor baby was starved to death and the same thing needs to hapoen to whomever is responsible! 6 o are there not reciuirements ‘EXHIBIT© Write acomment... (> 2020/06/09 14:27:29 25/49 ~ Amy's Post Amy Bryant | agree she is guilty, but the dogs stay with the trainer (at their home) when they do board and train. She probably had no contact with the dog, but as the business owner, she is responsible for who she hires and the care of the dogs. th Like Reply Os Penny Massey Amy Bryant | agree it just infuriating that this has happened | still will boycott anything they are associated with ih Like Reply o Ashlynn Hill Penny Massey the disgusting thing is, is that it takes more(> 2020/06/09 14:27:29 26 j49- < Amy's Post ave 2n Like Reply ae @& amy Bryant Yes the dog was in fact frozen and then thawed prior to being returned to the owner. I'm not in any way defending their actions, but it is common practice to freeze the remains after the death of a dog or cat. The owners should have been contacted immediately, but in a situation where maybe you cannot get in touch with the owner the body would have been frozen. Not to be too graphic, but the remains would have become pretty ripe within a few hours. 2h Like Reply One e Amy Bryant That being said, by freezing Write a comment... e Oe os* > 2020/06/09 14:27:29 27 )49 ~~ + 2089 May ~ © o bess ahesta Coven Shai Shang to vee gad EEKHEY ts AAR {has BOF Barby Huflered ternary! Canad Vasc Gamat Tip mandy ang A dock Lee my dag Shee ant | Shed Anay Fert get a bad tossing. Out aw get dette 501 SF jcturie woke Nes Nadi Dien Zoe sereer athe a8 $ deawn bie % tamer nears of pecpie ant dings Food aggeseue azep! 1o By Gog. Gee vee * Eh Evane [ha tens th way they tal that suwer age aaeey auto. 28 coupe LeCity Renee Haut tne Gunees of thew Hag Been changed? 6 e ryamt The ommers Ox AO! deta They mrad OF Least 49 ta board an Gann her dog The Haier Ge thes fo the 09 The di Mas tawposed to be there Z weeks, ta tne ltaege clare Re needed move Tae in ak Ma Ye dog for ans Bawweks HARE Honey secs the Doely ais Hazes Laon ane realy rows hare ong ee SG (eto Ao dey teak yt a Lomien, pays Army Bryan Casignpake Fomeat the oonnes of Cie frairang tacity se mare an oF fash qacuoe Gane RE Lerongton ane ety Hart tif ARC caetiind Paxp Ratt eomead chemist caine {0 Mer to cea the Haiot loge ShOCK Callan aining But these tines dos? starved thes pone ea Leesiey Gomi Army Bryant | Asal sae Ot the bases bore the coreee. Shere Ought tg Oe kemotiy Adeionsl (9 Charge ‘haem woth he etessharatty mapieadiong the Chpee a sce soneaalavent Evzabieth Aon Prev! You cant test moet Kateregs Tey need Ye foe ornaneavtnd fe Ye Fedlst @st6r8 28 lew . 2~ 2020/06/09 14:27:29 28 49 — Kim Livesay a ‘Wail, if you know me. if'lt be more than ona. gy Kye bees geting hundreds of messages and thought { eould atigmpt to address some af the most comman Of Leash K9 training in Johnson City 1s where Dallas died. This is a franchien of the large OH Leash Vaming sampany Dand Lakaraey, the: franchise owner of the JC one and ier whom the warsant was issued, owns: 19 {+\-} of these in vanaus states They are Of Leash locations a!) across. ine Country, Owned by other peupte. sore with ae deaths ane abuse complaints. ..but numerous others with hortic complaints and deaths Dallas’ death ss NOT an isolated “freak” case within the company OF Leash X9 is Aol the same as Southeasi German Shepherd Rescue {SGSR). Numerous people thought Callas’ death was “rescue related” i was NOT SGSR was achve in TN and Randi LaPerney was in chacge of (he TN and GA divisions. That, im fact, 1s how i met her many years ago. SBR is Shi active and saving ves mi other states and dmg an excellent the TN and GA divisions closed Whe can you thank for that... Ranch When i closed, dogs we had committed to were left stranded at sheliers: and foster dogs were LEFT WITH FOSTER FAMILIES and they had to strambie to make arrangements and pay vet bills SGSR has spent years atiempting to distance mxel from Rand: Think about this wath ie aw dropping number of German Shepherds and mixes that are ei need of fescue across the southeast how damn bad do yeu have to be for a group te say “No thanks. We don't want you anymore. Don’t lat the desr it you on the way oul. Stop using us in your advertiing” Well, it happened. As lar a3 dog training goas, There ate some excelent trainers here locally and af over the country. The first thing an owner needs to decide iw. what is your fraining goal and how do you want your dog traned? Oo you want positive or negative reiniorcement. Positive 18 “reward” based, negatve 1 “punishment” based. Not gona go in depth and gat inte an ethical chscussion over that because if's fhe discussing whether or not to spank your chédren As @-collar for dog training is sometimes called a shook collar and creates some confusion An e-collar is a collar on your dog that comes vath a remate control, This collar Ras 3 options: SOUND ia beep}, VIBRATION, and a"ShOck” which is. symbol. Now, this isn't a shock ikke a tasee on49 29 2020/06/09 14:27:2 inane Ssanu: JO SGIPap 81-GM Pa!BA09 DUE Da:ntuiC? Arenurwos seu ou Loy pais 9 91 UOOS & 16 jay20d oy) WI fevoU bunInd ax NOK ‘sseLySna Sil) Hod or AGA || “AUedwos si, fue IpUEY UjiM eap/esngefonSau jo se2uauiadxa jeuosied neu) inode Pies) Bulu0) Mou awe sayiee) aidniny) ued ue pueog, -e Suunp ABS HOU) Ul SEM YL a1iuan Hvac op Bop pp Hsp 62 paaiers2020/06/09 14:27:29 30 /49.— 2089 > phay ©(7 2020/06/09 14:27:29 31/49 -—~ < Kim's Post wee g Shelly Amber Js this the same franchise that would be up here in Roanoke??? Emmett goes for a 2 weeks board and train in 2 weeks and i stg ill cancel it if oO: & Paezha Marae McCartt Shelly Amber | would cancel it. 36m Like oO ij Shelly Amber ~ Paezha Marae McCartt gunna do that now. | got a human baby to take care of, and if something were to happen to either of my fur babies i would land in jail. My heart is breaking for this family:( 25m Like a & Paezha Marae McCartt Shelly Amber | totally agree and understand, It's just not worth chancing it. 2am Like th ao # @ @(~ 2020/06/09 14:27:29 32 49> 477 all > < WCYB was live. Wednesday at 11:35 AM @ 6 Candise Lejeune Andrew is her boyfriend who have been killing pups in Florida for years as well. Along with many other trainers at offleash kQ training for years 1d Like Reply OGys @G Kimtivesay Candise Lejeune share what else you know. Myrtle beach. Seattle..... td Like Reply o @ sallysue shackford Kim Livesay go to facebook page BRING Amadeus HOME also Bring Knox Home id Like Reply ous Ss Nate Mottern Pann anuana lena ners (6) Write acomment.. «©(7 2020/06/09 14:27:29 33 /49— S487 al > a) < WCYB was live. Wednesday at 11:35 AM - @ & Rhonda N Steve Cutshaw ! could never believe Andy Hunningan would ever be cruel to a animal. id Like Reply o & Mary Jo Shelton Rhonda N Steve Cutshaw id Like Reply @ write a reply... 6 Candise Lejeune They have killed many in Florida as well id Like Reply @Os Mary Womack | would be charged with aggravated assault after | whipped someone's tail. i cried when | saw the pictures of the daa (Q) Write a comment... BS # © ©7~ 2020/06/09 14:27:29 34 /49 — facebook a. ° a Lourienne Fedon Long Sale St And the lady who did this to me, Randi Laferney Is facing animal cruelty charges far the death of another dog at her training businese-€h gladd called her out, even when she told me to delete my post 5 Lourienne Feden Long Well, | wanted to avoid doing this publicly but when my post was deleted from a group page {hy the state directar) this has left me no choice. People deserve to know the truth and not have it swept under the rug | will post the dags in need ASAP and if you know a rescue or adopter willing to take them please let me know!!!(> 2020/06/09 14:27:29 35 /49— Lourienne Feden Long + SGSRTN, GA, ‘SW YA & Western NC Foster Group 4 has been two months since Ihe announcement of ceasing operations in TN and even after contacting the board directly 1 still have not received assistance th placing my area dogs mto another rescue, $0 | 4m posting this publicly 6 maybe it yall create a sense of urgency Lovett mull be transported Satusttay intl another foster home in east TN jlook aul lor ey post tomorrow and please hetp with hes transport if you Can), Victor has a potenteal adapter (thank you Heather Murphy} but | still do not have a rescue fot Oillgn oF Browime. have contacted 3 rescues tor Dution and am waiting to hear back trons the last one 30 Here is a slight chance but the dag {need the most help wath is Brownie {have contacted 4 local rescues and none are willing to take her in. i'm asking again # we can please move her toa foster home wn the adoptive area because after a year and a half in her current foster home, this is her only chance to find aforever home tam very disappointed that SGSA is, nat working together in this situation. It woukt have been right for SGSR fo cease intake in all slates unt! ail of the current dogs were placed in foster homes in ‘ouf adoption area before we started to pull any mere, These dogs have been m thes Josler homes for over ne yaar and a6 rurrant CESB tate then ¢haiitd she ee o(> 2020/06/09 14:27:29 36 /49 = ‘These dogs have heen in their foster homes for over one year and as current SGSR dogs they should take precedence. It is sad that | have to plead and beg for them and even contact the board and in turn get no assistance. In addition, | still have not heard back from anyone on what to do with my SGSR crates and supplies and | am moving in one week. Overall | am disappointed to be treated like this that after all the time | have put into SGSR, | really { don’t mind if my feelings are hurt but | do mind when it's the dogs that suffer. ® ©: @ Jamie Bosnjak and 10 others Seen by 17 people. Heather Duggan Randi LaFerney Shannon Thurston We have several as well including Buck (returning) and Turner who are mast urgent. Buck is super urgent as his family has been asking for him to be moved for a icng time, | had a potential adopter for him last week but Ci 2 Comment< 2020/06/09 14:27:29 37 /49 Kim's Post ace Cs) Dawn Williams Parker Kim | shared this in Knoxville. Something has got to be done to protect animals; ham seeing other horrific stories from across the country of animal torture and abuse pop up with the sick individuals just getting slaps on the wrist while | have been searching for reports on poor little Dallas. It just breaks your heart. — ism Like Reply Ashley Vaughn West | found out this morning and left a review on their Google page, including a link to the news report about her being charged. I'm sure no one would know the evil that they are supporting, otherwise. 9m Like Reply 2 ty Ue(7 2020/06/09 14:27:29 38/49 — we Verizon FS 6:58 PM ON 77% a < All Inboxes Av From: Google My Business To: easttn@offleashk9trai.. Hide Ashley Vaughn answered a question on your Business Profile for Off Leash KO Training, Tri-Cities, TN/VA it 6.56 4 A customer answered a question about your business At what age should my puppy b agin obedience ieSson scuiry vaugne Dag died in their care this week fy> 2020/06/09 14:27:29 39 /49 ~ ait verizon F 10:12 PM 13 70% mH 4 hm Ashley Vaughn West > Animal Shelter of Sullivan County Thursday at 12:24 PM + @ A dog died in Off Leash Canine Training's care this week. They are located in Johnson City, TN. They did not contact the owner of the dog, the owner had te contact them. Once others posted about their neglectful experience, the company tock their FB page down. This content isn't available right now When this happens. it's usually because the owner only shared it with a small graup of peaple, changed who can see it or it's been deleted. ike & Share @:.0 Vicky Tate Darnell and 25 others 16 shares ~ & Claire Emilia This is so horrible. Andy? He actually worked with my dog and | a few times and was very professional and helpful.> 2020/06/09 14:27:29 40 /49-~ < Ashley’s Post oes ac Like Brandie Staubus Vance Has the page been taken down? | cant find it 4d Like €§ Ashley Vaughn West Brandie Staubus Vance yep they took it down. | just left a yelp review and going to leave a Google review, as well. They can't escape this. hitps://m.yelp.com/bi zfoff- leash-k9-training-johnson- city Off Leash K9 Training - _ Johnson City, TN 4d. Like o @ Toni Peters. SHUT THEM DOWN! 4d Like(> 2020/06/09 14:27:29 41 49 < Ashley’s Post nee Toni Peters SHUT THEM DOWN! ad Like €8 Ashley Vaughn West Toni Peters If you have time, please leave a review on their yelp and Google page 4d Like ip Christie Willard Marina Willard 4d Like t ye Samantha Nicole Mcpeters Never trusted them. They were real combative when anything was said regarding their techniques. 4d Like a oo @&2020/06/09 14:27:29 42/49 ~ ww Verizon 10:18 PM +E 76% mF < @ Ashley Vaughn West» Rhetts |. Place for Pets Thursday at 12:17 Pat» A dog died in Off Leash Canine Training's care this week. They are located in Johnson City, TN. They did not contact the owner of the dog, the owner had to contact them. Once others posted about their neglectful experiences, the company took their FB page down. This content isn't available right now When this happens, it's usually because the owner only shared it with a small group of people, changed whe can see it or it’s been deleted, a Like @ Share S28 2 shares 2 Kathy Lynne Swiney-Smith not worth the money. they make no on hand contact with the animals 900.00 for nothing Ad Like2020/06/09 14:27:29 43 /49,~ ley Vaughn West Randi LaFemey, the ewnar af this incatinn was charged with animal cruelly this month in Johnson City, TN, She also owns Off Leash K9 Training in Johnson City and a dog was starved to death (proven by the necropsy regort} while in their care. | need to ust the owners of the businas ses that | support. https: /Avcyb.com/news/local/off-leash-k? training-trierties-owner-tums-hersetl-in — caute-of-dogs-death-determined? fbclid=hwARTk27NW26T, 2FHVGB2UF bigshd TAOIbOZMFrXS.JucJ5056PiDhrSSe0NXO Logan Isom Randi LaFemey, who was charged with aggravated animal cruelty is Dalles’ death in Johnson City, also owns Duck Doughnuts tn Knoxvitte.(7 2020/06/09 14:27:29 44 /49-~ ab Verizon LTE 1:46 PM 49 35%m > < Ashley Vaughn West €3 doesn't recommend Duck Donuts (Knoxville, TN). 25 mins - @ https://weyb.com/news/local/off-leash-k9-training- tri citicn owner turns herself in eauce of doge death | can't support Randi LaFerney, the owner of the Knoxville, TN location. She has been charged with animal cruelty in Johnson City TN, which relates to a dog starving to death -while in the care of-her training facility. She claims it was an accident, but how do you accidentally starve a. dog down to zero percent fat content? (per necropsy report). Buyers, please beware af wha yau are supporting o> Like Comment @ Share (©) Writea comment... Ss © @a => 2020/06/09 14:27:29 45/49 ROUGH DRAFT A. Yes, siz. Q. -- you never talked to Ms. Laferney, you never texted Ms. LaFerney. Is that correct? A. That’s correct. Q. And to your knowledge, the dog was in Mr. Hunigan’s home, correct? A. As far as we knew, yes Q. Thank you. MR, SPIVEY: That's all, Your Honor THE COURT: Okay. General, call your next witness GENERAL RASNAKE: That's our proof, Judge. THE COURT: Does defense have any proof they wish to put on? MR. SPIVEY: Judge, yes, I’ve got a follow-up. Animal Control Officer Stewart to the stand. 18 that right? ‘THE WITNESS: Stuwa. MR, SPIVEY: Stuwa. NICOLE STUWA, the witness, was examined and testified as follows: ‘RERECT. EXAMINATION BY_MR,SPIVEY: Q. How are you today, ma’ am? A. Doing well. How are you? “ope ROUGH DRAFT | | F20 a1 22 (> 2020/06/09 14:27:29 46 /49/- ROUGH DRAFT Q. Thank you very much. Good, except my eyes are bloody. I had surgery and it didn’t turn out well. Now, let me ask you, ma’am, what is your position? =| A. Animal control officer. @. And how long have you been in that position? A. Since November roughly. Q. I'm sorry? A. Since November of last yaar roughly. @. Thank you. If T ask you any question you don’t understand, just let me know, okay? AL Yes. Q. You conducted an investigation into this matter, did you not? = AL OY @. And you found that this dog was in the sole custody and control of Mr. Hunigan the whole time, from the Lime Mee. Acnold let the dog out until the deg died, correct? A. I believe so. Q. The dog was never in the custody and control of Ms. LaFerney during that six-week period, was he? A. To my knowledge, no. From the interviews that I have conducted, it seems as though the dog was turned over to Andrew Runigan, and then after Dallas's passing, he was turned over to Randi LaFerney in her vehicl: 57 ROUGH DRAFT/-~ 2020/06/09 14:27:29 47 [49 - ROUGH DRAFT stubborn. MR. BOYD: One second, Your Honor. Judge, that’s MR. SPIVEY: 1 do, Judge. Thank you. AS a result of that, I do not mean any disrespect, Your Honor, not at all. THE COURT: Well, go ahead and ask your questions MR. SPIVEY: Thank you, Your Honor. REDIRECT EXAMINATION BY MR._SPIVEY: 0. Ma‘am, do you have the statement that you prepared as a result of your discussion with Ms, LaFerney?— A. I do have that transcribed as well, summarized, Could I have that? Yes. She was cooperative with you, vas she not? x , through the phone, yes. We were attempting to contact har on miltipla occasions. Unfortunately, she not available when we did not contact us, and she wi initially tried to contact her when we had agreed upon. Unfortunately, I don’t remember the exact time frame, but Bi ROUGH DRAFT10 u 7 18 19 20 a 2 2B 24 (> 2020/06/09 14:27:29 48 /49,— ROUGH DRAFT we had agreed upon a certain time, and I was attempting to contact her, and she had not contacted until, I believe, about an hour or so afterward. But that is the transcription from the conversation that ayself and Randolya LaFerney had with Tammy Davis, because we were in’ her office as well. @. Thank you, ma’an. A. That was through the phone. That was not in person. Q. Tunderstand. That was okay with you, correct? AL Yes. @. Thank you. Ma’am, your investigation clearly shows, and Mr, Hunigan’s statement clearly shows, that Dallas was always in his custody and control, correct? A. During the time of Dallas’s life, once he wa: passed over on March 18th to Andrew Hunigan and to the point where he had passed away on May 2nd, to ay knowledge—| that would be what would seem to be true. Q. Well, that’s what Mr. Hunigan said and that’s what Ms. LaFerney said, correct? A. Yes. Unfortunately, T don’t know other information other than what they told , x0 T can’t give you anything other than what I would surmise to be the exuth. @. Thank you. In other words, you don’t have any “oT ROUGH DRAFT16 ” 18 19 20 21 2B 24 28 /~ 2020/06/09 14:27:29 49 /49_- ROUGH DRAFT Proof otherwise? A. Other than conversations they provided to me, that they have, to their knowledge, told me is true. Q. Thank you. MR. SPIVEY: Thank you, Judge. That's all 7 have. THE COURT: (Indistinguishable.) MR, BOYD, May I ask two or three questions? = will keep it brief, I promise. RECROSS-| TON BY_MR._BoyD: Q. Officer, your affidavit that you had signed for both -- charging Ms. LaFerney and Mr. Hunigan, both state that there -- it quotes from the necropsy report and states that food was in Dallas’s stomach, correct? A. According to the necropay report, there wae a small trace amount of food in his stomach, but no food in his gastric system, and to my knowledge, as was explained by the veterinarian that provided this necropsy, they stated that it takes about 12 to 24 hours for the gastric system to pass any food, and so if there was no food in his system, that meant that he had not had anything in the past 12 to 24 hours. If there was food in his stomach, that meant prior to that, there was a small anount of food provided. 68 ROUGH DRAFT