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Plaintiff,
)
vs.
) JUDGE_________________
ACADEMY OF CANINE BEHAVIOR
)
Defendant.
COMPLAINT
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GENERAL ALLEGATIONS
7. Plaintiff and his former Partner trained and boarded Livi with AOCB on several
occasions in 2014-2016.
8. On December 29, 2016 Livi was killed by another dog after Livi and her family
sibling Fang Weatherwax were left completely unattended with inappropriate dogs
not of their pack.
9. On or about December 31, 2017 Plaintiff and his former Partner adopted Pepper
and notified Defendant that they were desirous to start training and/or occasional
boarding arrangements for Pepper with Defendant.
10. Defendant was well aware of the Livi’s history and successful litigation and
settlement with Attorney Adam P. Karp, through social media and personal contact
with Plaintiff and his former Partner.
11. Plaintiff specifically inquired about a death they had heard about at AOCB.
12. Two individuals responded and told Plaintiff and his former Partner that a dog
was killed in their kennel by his canine household family member.
13. On information and belief culled from several current and/or former AOCB
employees this was and is a materially false account as to the death of the dog
involved, who shall be known as Moxie the MinPin.
14. On information and belief Moxie the MinPin wound up destroyed and partially
eaten by a dog not in Moxie’s household.
15. On information and belief a third dog was kenneled with Moxie and her family
member and that dog was Moxie’s killer.
16. On information and belief the offspring of a lead trainer was responsible for the
placement of Moxie’s killer with Moxie and her household sibling.
17. The apparent material misrepresentation was given to Plaintiff and his then-
Partner because Defendant knew that any other explanation would result in the
termination of any relationship between the Parties and Defendant knowingly
interjected this material falsity into the chain of commerce with the express intent
of retaining a business relationship in spite of the falsity.
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18. Based on this material and intentional misrepresentation, Plaintiff and his then-
Partner continued a relationship with Defendant, taking Pepper to two types of
training at AOCB, general obedience and Rally, and sending Kenton a high-resolution
DSLR photograph for him to use for marketing purposes.1
19. The Defendant’s statements where issued by and through persons of apparent,
actual and ostensible authority and Plaintiff and his then-Partner placed reasonable
reliance on the statements in continuing their relationship with Defendant.
20. Meanwhile, Plaintiff authored a draft bill entitled “Livi’s Law,” designed to
penalize kenneling with dogs not known to each other without express written
consent.
21. Plaintiff raised the proposal to Defendant and was met with a complete lack of
interest, a fact he found odd.
21. Plaintiff boarded Pepper for approximately four (4) days in spring, 2018.
22. On returning from the East Coast and retrieving Pepper he questioned AOCB
staff because they had told him Pepper was doing great with no problems at one
point, but then subsequently told him that she was not eating well and had diarrhea.
23. Plaintiff contemporaneously wrote Livi’s lawyer and his former Partner and
advised them that there were conflicting stories and he stated that he felt Pepper
had been drugged.
24. Plaintiff’s former Partner advised him to trust his intuition.
25. Plaintiff expressly stated that he had no intention of suing over it, but added that
he was concerned and that he would be interested in seeing the full records.
26. Defendant provided what Plaintiff believes to be partial records.
27. Plaintiff was informed that AOCB has a pattern and practice of drugging dogs
without prior consent and without post-hoc acknowledgement.
28. In July, 2018 Plaintiff became aware of a viral video in which a trainer beats an
allegedly belligerent dog with a thin-walled whiffle bat.
29. Plaintiff also began to see other allegations of abuse as intimated above, and he
therefore demanded all of Pepper’s records, on video.
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30. Livi’s former trainer Kenton and AOCB owner “Jack” brought Plaintiff inside into
a back room under the pretense that they would talk openly about all of Plaintiff’s
questions. Instead they kicked Plaintiff out of the room as soon as he mentioned
Moxie the MinPin, denying his request for Pepper’s records.
31. Incensed and shocked, Plaintiff returned the following day to narrow the issues.
He sought only Pepper’s records, whereupon both Kenton and Jack ended up
making physical contact with him in threatening manner.
32. Kenton and Jack also ordered the maintenance man to run a loud, gas-powered
two-stroke leaf-blower in and around Plaintiff to attempt to jar him and to drown
out his video.
33. Speaking of two-strokes, Kenton then actually ran and got his car, a recent
Subaru sport-ute/station wagon, and attempted to block in Plaintiff’s motorcycle.
34. Instead of simply providing the records that are owed, Defendant called in a 911
to the County Sheriff, asking that Plaintiff’s motorcycle be towed.
35. Plaintiff calmly met the Sheriff Deputies and explained what was really going on,
whereupon said Deputies had a cordial conversation with Plaintiff and informed
Defendant that Plaintiff’s motorcycle was actually on an easement and that it could
not be towed and that they would lose that battle. As the Deputies escorted Plaintiff
back to retrieve his motorcycle to illustrate the complete lack of tension coming
from Plaintiff, one of them stated “Nice motorcycle!” whereupon a short discussion
was had about the particular machine.
36. The Plaintiff is suffering, and continues to suffer severe emotional distress and
loss of enjoyment of life, among other general damages, as a direct result of
Defendants’ acts and omissions.
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CLAIMS
Per CR 8(e)(2), the Plaintiff pleads the following as to Defendants:
PRAYER
_________________________________
Christopher King, J.D.
Attorney Pro Se