JASON B. ABBOTT PRINCIPAL DEPUTY STATE'S ATIANE'Y. State’s Attorney for Prince George’s County 14735 Main Street, Suite M3403 Upper Marlboro, Maryland 20772 301-952-3500 case numsen: ce SECO ZOY OST The Office ofthe State's Attorney for Pince George's County (SAQ) Citizen Complaint Bureau (CCB) iscor virtua. in. ‘order for this case to be properly evaluated and prepared, you MUST interview by telephone or video caference(in- Person meeting will bea rare exception and by appointment only) with a representative ofthe SAO, j I rane Sedan email fo PGSAOCCB@ea.peind.ts Inthe subject line ofthe email put the DEFENDANTSNAME and CASE NOMBDR. tn the body ofthe email simply write, “I want to seen this ease” You wil gt an ates coal Teal it the seresning instructions. Ifthe automatic email i notin your Ibo, check your Junk Soan ers. Kyou idl not receive it you may contact us atthe below contact information. ‘This email addres is UMLAGHTOIRID og {s only being used to send the automated reply withthe instructions. Please be advised that you will not reodve any further response from this email address, ‘When you appear to soreen your ease, you MUST have a completed Advice of Rights Form. The instrusias will be in tea pagmated response you recive ffom our office after sending an ema fo PASAOCCR@so peas You ell ad crceag ange time the ease number, and «government issued identfeation to complete the frm I shipful hove already submitted any supporting documentation and evidence related tothe incident Pe SE “**DF YOUR CASE IS NOT SCREENED By __//- 8-202 Is warxsy, ‘THE STATE’S ATTORNEY'S OFFICE WILL NOT PROSECUTE THIS CASE.-++ (QUESTIONS OR NEED FURTHER ASSISTANCE? Contact the CCB Screening Unit at: 301-952-2862 INTERPRETER NEEDED? Check: 0 YES a NO | Language: : a ae ee TACKNOWLEDGE RECEIPT OF THIS FORM AND UNDERSTAND I MUST MEET WITH TRRSTATE'S ATTORNEY'S OFFICE AS OUTLINED ABOVE. CTaye Cc Z L8/ay 2%, it COMPLAINANT (SIGNATURE) DATE i FOR ANY CASES INVOLVING INTIMATE PARTNERS OR CHILD ABUSE, please contet i specialvstimssvu@co.pg.md.s o call (301) 952-3147, Original—Commissioner __Yellow~Complainant Pink—State’s Attorney's Offi,DISTRICT COURT OF MARYLAND FOR Prince George's County Located at Courthouse, Bourne Wing, Upper Marlboro, Mayland 20772 Case No: $E00704051 STATE OF MARYLAND VS. —_- HOLLY, JERRY LEE 13204 DULEY STATION ROAD UPPER MARLBORO, MD 20772-0000 cee: sip: Lip: DLi Race:2. Sex:M Ht: 5110" " We20S Hair: BRN Eyes: BRN DOB: 04/15/1945 Home: Charge | Statute | Arrest et Axa CRUELTY oR 19804 1121) ‘Aha RUE. PAu PROVIDE GR TOOT TAT ANNI CRUELTY CaUSEIMU'E | OX eb4 ae URT ORIGINAL STATE ATTY COPY ' [ ] DEFENDANT COPY CRIMINAL SUMMONS ON qHANGNOBOCOMENT STATE OF MARYLAND, Prince George's County, to wit! [ ].COMPLAINANT COPY To the defendant: ae ee |) YOU ARE SUMMONED AND COMMANDED to appear for a Trial/Hearing on a date to be set by the Clerk to answer the charge(s) lodged against you in the charging document attached hereto. ne: 301-627-1979 Cellphone: NOTICE TO DEFENDANT:If you fail to appear at the place, time and date set forth above, a warrant for your arrest ‘may’be issued. If you change your name, address, of telephone number, you must notify the court at the above location prior to the hearing/trial date. To request a foreign language interpreter or a reasonable accommodation under the Americans with Disabilities Act, please contact the court immediately. TTY users call Maryland RELAY: 711. Possession anid use of cell phones and other electronic devices may be limited or prohibited in desigriated areas of the court facility. Date: 10/19/2021 pesmi egy 1D:5217 Given to: PRINCE GEORGE'S CO. SHERIFF'S DEPT. NOTICE TO OFFICER: If not served by 11/23/2021, ary RueyPouft. ACKNOWLEDGEMENT acknowledgé receipt of a copy of this Summons and Charging Document and hereby promise to appear in the District Court as directed by the Summons. I understand that acceptance of this Summons is not an admission of guilt but that my failure to appear at the place, time and date herein set forth will result in the issuance of a warrant for my arrest. Date: Signature of Defendant: RETURN OF SERVICE Oi Lcertify that 1 delivered a copy of this Summons and Charging Document to the defendant personally at otclock _M. on, at 7 5 Dae Fras I certify that the defendant could not be found. O Leertify that I personally attempted to deliver a copy of this Summons and Charging Document to the defendant, but they refused to accept and/or sign a receipt for the document(s). “ignanare of Tsing Officer Opieers Tie Prine Name of Officer ~ 7 Dae 7 Agen ib Arey, TD. DC-CR-005 (Rev. 05/2021) ‘Tracking No. 211001542463OIA DISTRICT COURT OF MARYLAND FOR Prince George's County ‘Located at Courthouse, Bourne Wing, Upper Marlboro, Maryland 20772 STATE OF MARYLAND VS. _—_ HOLLY, JERRY LEE 13204 DULEY STATION ROAD COMPLAINANT: UPPER MARLBORO, MD 20772 TAYLOR, RODNEY 3750 BROWN STATION RD UPPER MARLBORO, MD 20772 cH: SID: LID: DL#: . A Race: 2 “Sex:M_-HtsS'10" — Wi:205__" Hair: BRN Eyes: BRN a DOB: 04/15/1945 Home phone: 301-627-1979 Cellphone: t STATEMENT OF CHARGES UPON THE FACTS CONTAINED IN THE APPLICATION OF TAYLOR, RODNEY IT IS FORMALLY CHARGED THAT HOLLY, JERRY LEE at the dates, times and locations specified below: NUM CHGICT STATUTE PENALTY DESCRIPTION OF THE CHARGE Case No, $E00704051 01 10500, CR 10604 ((@X12X3OD Aor Si,000.00 ANIMAL CRUELTY On or About 08/26/2021 13204 DULBY.STATION RD, UPPER MARLBORO PRINCE GEORGE'S COUNTY, MD Aid deprive of necessary sutenanceinfit unnecessary suffering or pain on a be. ‘Against the Peace, Goveroment, and Dignity of he Stat 07210503 _CR10604.(@S)) 90D BorS1,00000 ANIMAL CRUEL FAIL: PROVIDE On or About 08/26/2021 13204 DULEY STATION RD, UPPER MARLBORO i PRINCE GEORGES COUNTY, MD did unnecessarily fil to provide Zebra with mutton fod in sufiient ‘ quantity, and proper shelter while sai animal was in his charge and custody Against the Peace, Government, and Dignity ofthe Stat. 00310501 CR10.604 (@X4)) 90D &/or $1,000.00 ANIMAL CRUELTY CAUSE/AUTH i On or Aboot 0872672021 . 13204 DULEY STATION RD, UPPER MARLBORO PRINCE GEORGE'S COUNTY, MD 4id unlawfully cause, procure, or authorize the deprivation of necessary sustenance and infliction of unnecessary suring o pain on a Zabra ‘Agins the Peace, Government, and Dignity ofthe Sate Date : 10/19/2021 27:11PM ‘Tracking No. 211001542463 5217DISTRICT COURT OF MARYLAND FOR —___ —_{(CityCounty) {LOCATED AT (COURT ADDRESS) oe art ‘ATED CASES: INTEC TS COMPLAINANT Ta DNDN “Assos Distr Radey Taylor Tey Lae Hall Rana a Fase eae Sb Brown Staion Road . 1320 Daly Staion Road ae aa : ‘Ups Marre MD 207m 01.760.207__ Cape Matter MD 20772 301.677.1979 oes ae een tase ‘Neeney, Sub-agency, and 1D. # Wiicer Oa) oe DEFENDANT'S DESCRIPTION: Driver's License #____________Sex male __ Race white _ pp S'10__w 205Ib__ Hair brown __ Byes brown _ Complexion, Other_ DOB 4-15-1945 1D. APPLICATION FOR STATEMENT OF CHARGES: Poge of 2 ___ (Include a statement of facts within your personal knowledge (what you saw or heard, what someone said to ‘You, etc.) showing that there is probable cause to believe that a crime has been committed and that the defendant has committed it, Please see the “NOTICE TO APPLICANT FOR A CHARGING DOCUMENT” for further information.) 1, the undersigned, apply for a statement of charges and a summons or warrant which may lead to the arrest of the above named defendant because on or about 8: : at 13204 Duly Station Roed Upper MD 20772 , the above named defendant (On §-26-2021 the Animal Services Divison received a call that 3 zebras were running at large in the 8400 blk of Croom Road, Upper Marlboro MD 20772, Animal Services made contact via telephone withthe animal caretaker Mr. Charles Gwynn regarding the at large zebras, Mr. Gwynn advised he would go an check onthe fence line and try to get an accurate count of te herd. Animal Services made contact with Mr. Jeny Holly who was avare the zebras were loose, but had no plan to recapture the zebras at that time ‘(Continued on attached _____ pages) (DC-CR-001A) solemnly affirm under the penalties of perjury that the contents of this document are true to the best of my knowledge, information, and belief, Die arate Thiave read or had read to me and I understand the notice on the back ofthis form. "==" Le, Ce bo Judg6/Commissioner. : understand that a charging document will be issued and that I must apfear for ti Toca Sie CO The applicant requests reasonable protection for safety of the alleged victim or the vitim’s family: Daa T have advised applicant of the right to request shielding. The applicant declines shielding. C1 I dectined to issue a charging document because of lack of probable cause, ~ bar minor Nabe DC-CR-001 (Rev. 10/2020) aad Nene §] Trt2tt0018¢2463. FFDISTRICT COURT OF MARYLAND FOR [EOCATED AT (COURT ADDRESS) Cniceaa VEEL DC Case : $£00704054 [DEFENDANTS NAME (LAST, FIRST, MI) |Holly, Jerry, L. APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page 2__ of 2 The caretaker has since made efforts, but has been unable to recapture the zebras, and they are sill at large, now for 54 days, The ‘zebras at large pose a théat tothe community bas they continue to wander through communities, railroad and public roads. The zebras are also at risk, as evidenced by the death of one ofthe zebras while at large. The zebras at large have not received adequate fod, wate, or veetnary cre. One of zabras died because it was a-lrge. One ofthe tree zebres running at large Was caught in a snare within two fet of the fencelin-diretly beside the fenced enclosure where the other 36 zobras were being held. The DNR Natural Resources Police investigating officer, Corporal Brown, bas stated that in his opinion, tie animal should have been seen or heard wile it was dying from being caught inthe snare ifthe caretaker bad attended to the zebras in the fenced enclosure, and mos likely died of dehydration ater a period ofa few days strugeling in the trap, However, by the time that DNR responded, on September 16th, the animal was completely decomposed and so cause of death could not be specifically determined. The flue to respond to an animal inthe enlosure today (October 19), who had been deceased long enough that it had entered the rigor-morts stage, andthe unexplained loss of one of the original herd of 40, the failure to provide forthe 3 at -large zebra, combined withthe description of the death of the at-large 2zbra above, is sufficient circumstantial evidence of neglect to warrant a criminal charge. The zebras at-large are a public nuisance. The media coverage surrounding the zebras has brought traffic and trespassers to surrounding homes. The animals are dangerous, and serve a risk to persons approaching them, and a risk to drivers on the public roadways, Zebras running at large are by County code declared a nuisance and dangerous tothe public health, safety, and welfare. These animals are being kept in the County in such manner as to disturb the peace, comfort, or health of neighbors and other residents of the County. Submiting charges for: Prince Georges County Animal Control Ordinance Subtie 3 Seo. 3-135 runing at large (criminally punishable by 3-116.01(d) Prince Georges County Animal Control Ordinance Subtitle 3 See. 3-180(a,(6\4) and (c) Cruelty & Neglect criminally punishable by 3-116.01(@)) Prince Georges County Animal Control Ordinance Subtide 3 Sec. 3-131(c) Manner of keeping (criminally © Suewer of Zesras Tacry Holly v/a. frm KO arta tee mo 277 ble by 3-116.01 bye ps marl (LAF zsrw ‘oat jl Tra#21 1001542463 DC-CR-OOLA (Rev. 04/2015)