KRISTINA M.

BRUNNER
Complaint Letter
Page 1 of 4

Kristina M. Brunner
10403 Lion Moon
San Antonio, Texas 78251
United States Department of Agriculture (USDA)
Attention: Dr Robert Gibbens, D.V.M.
Director - Animal Care - Western Region
Animal Plant & Health Inspection Service (APHIS)
Animal Care (AC)
2150 Centre Ave B 3W11
Fort Collins, Colorado 80526-8117

FILE COPY

March 24, 2006

Dear Dr. Robert Gibbens, D.V.M.:

I am submitting this letter as a Formal Complaint against the Wild Animal Orphanage
(WAO), Animal Sanctuary of the United States (ASUS), located at 9626 Leslie Road,
San Antonio, Texas 78254, and its owners/operators, Ms. Carol Asvestas and her
husband, Mr. Ronald Asvestas.
The grounds for this complaint are regarding
questionable care and housing of over 800 animals, many of which are considered
endangered.
In my former capacity as Vice President and Treasurer at the WAO, I am familiar with
the following alleged activities:
a) Ms. Carol Asvestas does not maintain proper animal records. I am not
aware of any veterinarian care records maintained for the 800 plus animals
located on the Leslie and Talley Road facilities. I am only aware of the
unofficial red log book that the Office Manager maintained which listed
animal deaths, injuries and sedations. (9 C.F.R. 2.126);
b) Ms. Carol Asvestas does not provide veterinary care for over 800+ animals.
She does not have a written program of veterinarian care and regularly
scheduled visits. I spoke to the WAO veterinarians, Dr. Henry, Dr. Lambert
and Dr. Ehrlund, DVM, and all three veterinarians told me they relied on the
WAO In-house Veterinarian, listed on the WAO website as Dr. Rachelle
Farvour, DVM, as the primary WAO veterinarian. According to a recent
Department of Labor OSHA complaint, Ms. Carol Asvestas stated that Ms.
Farvour is only an animal care technician and does not perform veterinarian
medicine at WAO. (9 C.F.R. 2.40);

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Complaint Letter
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c) The WAO Leslie Road quarantine housing facility, the large bear enclosure,
and the tiger enclosure (all on concrete pads) were not equipped with
disposal facilities and drainage systems that are constructed and operated
so that animal waste and water are rapidly eliminated and animals stay dry
(9 C.F. R. 3.125(d));
d) Ms. Carol Asvestas failed to store supplies of food in facilities that
adequately protect the food against deterioration or contamination by vermin,
and specifically, cat and rodent urine and feces can be found all over the dog
and bird food bags. (9 C.F.R. 3.125 (c));
e) Excreta from primates and big cats were not removed from quarantine
enclosures daily, to prevent soiling of the big cats and to reduce disease
hazards, insects, pests and odors. (9 C.F. R. 3.125(d));
f) Primates in outdoor quarantine housing facilities were not provided with
adequate protection from the elements. Five primates at the Leslie Road
location died due to freezing weather from November December 2005.
(9 C.F.R. 3.127 (b));
g) Housing facilities for the WAO bears were not of an adequate size for the
16+ animals at the Talley Road facility. The bears have been housed in
small quarantine cages for the last several years (9 C.F.R. 3.128);
h) Animals maintained at both WAO facilities were not provided with
wholesome and palatable food of a sufficient quantity, nutritive value with
consideration for the age, species, condition, size and type of animal. Many
WAO animals were not fed at least once per day as required. Since October
2005 the big cats (tigers, lions, cougars, ligers, etc) are fed raw chicken as
their primary meat source. Bears are fed dog food as their main food
source. Primates at the Leslie Road facility are fed dog food as their main
food source. According to Ms. Asvestas written statement made on
December 27, 2005, primates are given fruits and vegetables as treats
only. Only chimpanzees at the Talley Road location receives monkey
biscuits. The remaining 300 primates at the Talley Road facility receives dog
food as the primary food source. (9 C.F.R. 3.129);
i) Ms. Carol Asvestas failed to provide clean and sanitary water at all times.
During freezing weather, the water lines froze and animals were denied
water until the lines defrosted. Big cats water receptacles are not kept
clean. Water receptacles contain food debris, animal waste, and algae.
(9 C.F.R. 3.130);
j) Primary enclosures for tigers and bears living on concrete pads were not
kept clean and sanitized as required. Animal diarrhea is not completely
2

KRISTINA M. BRUNNER
Complaint Letter
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washed away and no disinfectant is used to sanitize the concrete surfaces.

The diarrhea is washed into other animal enclosures thereby infecting other
animals with bacteria and other germs. (9 C.F.R. 3.131(b));
k) The WAO premises including buildings and surrounding grounds, were not
kept in good repair, and clean and free of trash needles, darts, and beer
cans can be found around animal enclosures. (9 C.F.R. 3.131 (c));
l) Ms. Carol Asvestas failed to utilize a sufficient number of adequately-trained
employees to maintain a professionally-acceptable level of husbandry
practices for over 800 animals (to include hundreds of primates). The WAO
employs only two senior animal care technicians at the Talley Road facility.
Two animal care technicians care for the animals at the Leslie Road facility
and one of the two technicians also doubles as the facility tour guide. The
Office Manager helps care for exotic and domestic animals at the Leslie
Road facility as needed. One or two individuals care for the domestic cats at
the Leslie Road facility. (9 C.F.R. 3.132);
m) Ms. Asvestas failed to separate animals that clearly did not get along with
one another (i.e. fighting cougars, tigers, and lion cub) resulting in animal
deaths and extremity amputations. (9 C.F.R. 3.133);
n) The primates maintained in quarantine were housed in enclosures that did
not allow each animal to make normal postural adjustments with adequate
freedom of moment and did not provide each animal with a minimum floor
space equal to an area at least three times the area occupied by the primate
when standing on four feet, turn about freely and to easily stand, sit and lie in
a comfortable normal posture (9 C.F.R. 3.80(b) (1));
o) The WAO failed to develop, document, and follow an appropriate plan for
environmental enhancement adequate to promote psychological well-being
for the rhesus macaques and white crowned mangaby primates. (9 C.F.R.
3.81); and
p) I discovered approximately 225+ animals that died from 1998-present.
Based on the foregoing allegations, there appears to be a case of gross negligence,
extreme cruelty, egregious, inhumane treatment of animals, in the custody and control
of the WAO. Therefore, this entire matter is an extreme emergency that it demands
that the USDA take prompt steps to protect the WAO animals and immediately ban Ms.
Carol and Mr. Ronald Asvestas, including their family members, from any more contact
with these animals.
Please provide me a response, in writing, as to the USDA findings and the final
resolution of this complaint.
If you require additional information regarding this

KRISTINA M. BRUNNER
Complaint Letter
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complaint, please do not hesitate to contact me at either my home (210) 647-1789 or

work (210) 335-2369. Thank you very much for your time and consideration.
Sincerely,

Kristina M. Brunner

CERTIFICATION

I hereby certify to the best of my knowledge and belief that the foregoing statements
and allegations made by me are true. I am aware that if any of the foregoing
statements are willfully false, I am subject to punishment.

SIGNED
___________________________
Dated

_________________________________
Kristina M. Brunner

Enclosures:
1. Exhibit A: Certification of Kristina M. Brunner, dated March 13, 2006*
2. Exhibit B: Addendum to the Certification of Kristina M. Brunner,
dated March 16, 2006
3. Exhibit C: Certification of Mary Martinez, dated March 13, 2006
4. Exhibit D: DOL OSHA
4. Exhibit E: USDA Affidavit, Kevin G. Rogers, DVM, dated November 20, 1996
5. Exhibit F: USDA Affidavit, Board of Director for the Inland NW Zoological
Society, dated November 21, 1996
6. Exhibit G: USDA Affidavit, Carol Asvestas, dated May 8, 1997
7. Exhibit H: Wild Animal Orphanage web pages, Veterinary Care and Key Staff,
dated March 17, 2006
8. Exhibit I: Page copy from Ms. Norma Lagutchiks animals (WAO Office
Manager) sedation, injury, and death red log book
9. Exhibit J: USDA APHIS Investigative & Enforcement Services Report of
Investigation dated June 23, 1998 and USDA AWA Docket No. 99-0015.
10. Exhibit K: Certification of Kristina Brunner, dated March 25, 2006

KRISTINA M. BRUNNER
Complaint Letter
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* I did not include the Response to the Wild Animal Orphanage Meeting held on
12/27/05, dated January 17, 2006 (25-paged document plus 33 attachments). If
your office requires this document, please contact me so I can mail it to you