UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MISSOURI

AL, |
Plaintiffs and Counterclaim ! Case No. 4:16-cv-02163
Defendants,
-against- i DECLARATION OF CASEY TALBOT
‘ INSUPPORT OF COUNTERCLAIM
PEOPLE FOR THE ETHICAL TREATMENT i p e F E N D A N T ’ S MOTION FOR
OF ANIMALS, INC., ET AL, CONTINUANCE

Defendants and Counterclaim

Plaintiffs.

I, Casey Talbot, do hereby declare:

1. I am licensed to practice veterinary medicine in the State of Missouri,

and have been licensed since 2012.

y* I earned my Doctorate in Veterinary Medicine and Masters in Public

Health from the University of Missouri College of Veterinary Medicine. Both degrees

were conferred in 2012.

3. I am currently a member of the American Veterinary Medical

Association and the Missouri Veterinary Medical ‘Association, and have been a

member of each organization since 2008.

4. I am experienced in, and am competent to, provide general veterinary

and diagnostic care to primates, including ahinianede 3

5. Counterclaim Defendant Tonia Haddix first hired me to provide

veterinary care to the chimpanzees Tonka, Crystal, and Mikayla in Ielnrtiey 2020.
Including that visit, I have seen Tonka in my professional capacity approximately 3

1
times, and have seen Crystal and Mikayla in my professional capacity approximately

2 times.

6. A l l statements of belief as to a matter of fact stated herein convey my

professional opinion as to that matter, informed by my education and experience.

iF On or about 5/20/21, Ms. Haddix asked me to come to her property

because Tonka had seen a significant muscle loss, decrease in activity, decreased

ability to move around and ambulate normally including lack of normal use of his left

a r m and leg.

8. Upon arriving I performeda visual exam of Tonka prior to sedation, Tonka had

changed dramatically since my previous visit. He was still v e r y interactive. He

had lost a significant amount of lean musculature, there w a s edema noticeable

around the ankles and wrists. He held his left a r m awkwardly adducted

against his body. There was mild swelling at the elbow joint. His abdomen
appeared mildly pendulous. Increased effort climbing/jumping, especially

using his left a r m and leg. Otherwise was is v e r y bright, alert and responsive.

It was evident when we attempted to dart him that after a few minutes of

excessive activity avoiding the dart he would start to cough and require a rest

for a few moments to regain his breath. Hes boil raise and grasp with his left
a r m but did not utilize it acura, He struggled to climb or jump.
9. For Tonka’s safety, as well as mine, I had to anesthetize bea using a
blow dart g u n before entering the his enclosure and examining him. This is standard

practice when providing care to chimpanzees. Typically, when Tonka or other chimps
see the dart gun, they begin running around their enclosure. Tonka did exactly this.

However, unlike a typical, healthy chimp, within a few moments he would have to

stop and would cough and catch his breath. This indicated that his cardiac output

w a s reduced.

10. Once sedated physical exam and diagnostics performed as rapidly as

possible to avoid complication with sedation. He remained stable throughout

sedation. On auscultation of his lungs there were mild crackles in caudal l u n g fields,

the heart ausculted normal. Ultrasound of the abdomen was unremarkable, no free

fluid or obvious abnormalities on a quick scan of his abdominal organs. Radiographs

of the heart show that his heart has enlarged further since o u r visit in January.

Radiographs of his left a r m showed a distal humeral epicondylar fracture w i t h the

distal humerus displaced proximally. Blood was drawn for diagnostics and he was

returned to enclosure and his anesthesia was reversed. Total time sedated was

approximately 15 minutes. No complication under sedation, mucous membranes

remained pink, his capillary refill time was < 2 seconds. CBC shows a mild

neutrophilia likely associated with injury to elbow. His recovery quiet and

uneventful.

Prognosis guarded. Tonka had definitely started showing clinical signs associated

with congestive heart failure. Recommend lasix, potentially enalapril. Treatment for

the fracture was discussed at length, including the difficulty of stabilizing and

treating fracture surgically. Surgery to stabilize carries a difficult outcome due to

location of fracture and inability to properly stabilize without implants. Also difficulty

keeping the surgical wounds clean and dry. Treatment with furosemide was initiated

immediately. The inability to safely assess his heart, blood pressure and other

parameters associated with cardiac failure while awake on a day to day basis makes

treatment and adjustment of treatment difficult so response to initial treatment was

initial phase of treatment. Pain control obtained with NSAIDs and gabapentin and

reasonably limited space to prevent need for climbing or excessive activity.

11. I t i s , and at all relevant times was, my belief that, given Tonka’s rapid

physical decline since my previous visit that his prognosis was poor and if Tonka did

not respond to the furosemide or other cardiac associated medication, it was probable

that his heart failure could be fatal. Euthanasia was discussed at length in the days

immediately following this visit, citing poor prognosis, rapid decline, poor current

health and p a i n associated with elbow injury. While a timeline for death associated

with cardiac failure is difficult to determine I was certainly not surprised when, on

or about the 5th of June, Ms. Haddix called and informed me that Tonka had died.

12. It is my understanding, based on conversations w i t h Ms. Haddix, that

Crystal and Mikayla have had minimal contact‐and thus, have not been socialized‑

with other chimpanzees. From my o w n observations of Crystal and Mikayla, it is my

belief that neither Crystal and Mikayla are particularly assertive. On this basis, It is

my belief that Crystal and Mikayla would be at significant risk of i n j u r y, including

serious i n j u r y, if they were to be introduced to chimpanzees w i t h whom they w e r e

unfamiliar.
r y 5 B i

I declare under penalty of perjury under the laws of the United States of

America that the foregoing is true and correct of my o w n knowledge.

Dated this day 13th day of July, 2021

Casey Talbot, D V M