DECLARATION OF RUSS MEAD

I, Russ Mead, state under oath and penalty of perjury under the laws of the State of Nevada, that I am over 21 years old, of sound mind and have personal knowledge of the facts stated in this declaration.

1.1 am General Counsel for Best Friends Animal Society. We are the nation's largest no kill sanctuary for domestic animals. We also have an extensive outreach program helping animal in need in times of disasters. We took on the nation's largest animal hoarding case last year involving over 1,400 animals. Coincidentally that case was in Nevada.

2. After our staff recently worked several days at FLOCK, I met with the Board of Directors and president of FLOCK on Thursday, July 5^th, 2007. I pointed out the animals were in grave need of medical care and suffering under the harsh temperatures and awful conditions of the so-called sanctuary, and the situation could not be rectified long term until serious changes were made in the operation of the facility and the care of the cats.

3. On behalf of Best Friends, I made the following specific recommendations:

a. The colony of 400 cats must be broken down into small groups of less than 35 cats. With all the cats in one large 400 animal colony, there is no way to control disease. If one cat becomes ill or diseased, it is likely to spread through the entire herd. In addition, there are so few caregivers and none with adequate veterinary training, that it is not possible to inspect the cats daily to see who needs medical attention. Finally, cats that ' are put on medical treatment cannot be located to receive treatment.

The response of the Board was that it was a fundamental tenet of FLOCK to let all 400 cats run free in the yard as one large colony. They did not want to implement this change.

b. The cats now roam free on the dirt yard. The dirt is hard packed and cannot be disinfected. The cats defecate in the yard and there are piles of fly- and maggot-infested feces everywhere, and the flies and maggots swarm the cats' runny eyes and nose and wounds. Some of the cats are obviously sick with respiratory illnesses and likely other airborne diseases. We recommended the grounds be concreted and sealed. This will allow for disinfecting at regular intervals.

The response of the Board was that they could not afford to concrete the entire 2.5 acres and they did not want to place the cats in smaller quarters. They were not inclined to do anything to clean up the facility.

c. We noticed the walls in the cat sheds are made of particleboard. This material is not impervious to moisture and not possible to disinfect. The surfaces in a cattery must be disinfected at regular intervals. I recommended the walls be lined with some other material that would allow the walls to be disinfected.   The Board responded that it was too expensive to change the walls, but they would look into a power washer to clean the floors of the cat sheds.

d. I also pointed out a series of operating deficiencies including gross lack of sanitation and routine cleaning, no routine veterinary care, far too few staff to humanely care for the number of cats and, of course, the inhumane, neglectful and abusive treatment of the animals because of insufficient shelter despite extremely hot

weather, failure to evaluate, diagnose and treat even obviously severe injuries and illnesses; and inexcusably filthy and unsanitary conditions.

The general response of the Board was a combination of it is all the prior president's fault, or they are doing the best they can with the resources they have. Frankly, they seemed unconcerned about the condition of the cats or the way they are forced to live.

e. Other information I learned from the Board: They make no effort to adopt out animals. Our staff noticed they added animals to the facility while we were there. The claim is that they trap these allegedly feral cats in Las Vegas and bring them to Pahrump. But we found most of the cats are either friendly or at least not feral. We found some had microchips and no effort had been made to identify the owners. Our staff concluded this is likely a clear case of institutional hoarding.

Dated this     1 2  day of  July, 2007.

Russ Mead

DECLARATION OF SHERRY WOODARD

I, Sherry Woodard, state under oath and penalty of perjury under the laws of the State of Nevada, that I am over 21 years old, of sound mind and have personal knowledge of the facts stated in this declaration.

1. I have worked for several years as an animal behavior consultant. I am also a nationally certified dog trainer.

2. From Sunday, July 1, 2007 until Wednesday, July 4, 2007,1 visited and volunteered at FLOCK, allegedly a cat sanctuary, in Pahrump, Nevada.

3. This declaration was very difficult for me to write. It is so hard to think about the horrible conditions I saw the cats living in there and how they are suffering.

4.1 entered FLOCK through an unfinished building that contained 17 cats. Those cats are living inside. All are underweight, show signs of starvation and malnutrition, and most have signs of illness, particularly upper respiratory infections, skin conditions, wounds, and diarrhea. The litter boxes were all soaked with urine and filled with diarrhea. At least one male cat is intact.

5. Through this building I entered the back yard. The cat colony is the largest I have ever seen. Hundreds of cats live together. I quickly realized that the ground is covered in feces. Some had been raked into piles but not removed. Hundreds of pounds of feces remained on the ground in this yard. The cats I saw were all underweight. There were flies everywhere. The flies in the yard were swarming on the cats' runny eyes, noses, wounds and the visible diarrhea There were also maggots everywhere including in the cats' runny eyes, noses, wounds and visible diarrhea.

6.1 looked into the small shed like buildings that are in the back yard. These small sheds or buildings are made of wood chip board, plywood. The sheds or buildings are filled with flies, feces and vomit. The cats in most of these buildings were inside by choice because evaporative coolers were running inside, but I understand they were not turned on this summer until very recently. The temperature during my visit was around 114 degrees F each day. There are 2 cat doors to the buildings. I watched as cats lay in the cat doors, blocking entry access to other cats.

7. Most of the cats are in the yard and are desperate for shade. There is just no adequate shelter for them. They are truly suffering in the extreme summer heat.

8. There is one building labeled Hospital. I entered to see almost 20 cats running free in the building. There are cats in cages as well. There were filthy litter boxes soaked with urine, diarrhea, flies, and vomit. I asked about medical care and I was told most of these cats had not seen a veterinarian. Untrained volunteers and staff including a 16 year old

girl were prescribing, administering and changing medications. Staff and volunteers spoke of disagreeing about vet care and hiding from each other what they do medically. I observed what went on at the hospital during my visit, and I can confirm they did not have any consistent care from needed daily cleaning to keeping a routine schedule for medical care to professional veterinarian services. There was really no cleaning or care at all except the untrained volunteers and staff guessing at what vet care they should administer and even that wasn't consistently given to the cats. Cats died while I was there. I called and asked for help from a local DVM. Dr. Suzanne Zervantian did come to FLOCK on the 4^th of July. She will have test results from the cat that died that morning.

9. Many of the cats in the yard look as ill as the cats in the hospital building.

10. Approximately 85% of the cats are showing signs of sickness, and almost every cat is underweight and shows signs of starvation and malnutrition. I saw chronic upper respiratory, drooling, skin conditions, and various wounds which were covered in flies and maggots. One cat had his right eye hanging out of the socket. None of these medical issues had been diagnosed let alone treated.

11.1 saw no measures to control diseases. There is no proof of vaccines on this cat colony. When I asked about records for the cats, I received multiple answers ranging from every cat had a record but they were stolen to we never really had a database. While I was there, I saw mounds of feces and vomit everywhere. There did not appear to be routine cleaning or sanitation at all inside any of the buildings or outside in the yard.

12. There was only one staff person there at a time for all of these cats. On two occasions while I was there, staff did not show up at all. Other times the staff person was late.

13. The cats are guarding from each other due to a lack of basic needs being met. The cats guard shade, water, food, and access to cool air. Many of the eats are not having then-basic needs met for survival. I understand there are times when the cats are not fed and do not have clean or any water. I understand about 100 cats froze to death last winter, and the shelter during this summer of 100 degree plus temperatures is very inadequate or non­existent for many of the cats.   The feral cats do not have enough adequate shade or shelter, water or food available. None of the cats has their medical needs met yet there are terrible medical emergencies there; they are just ignored. Also, the cats are forced to live in a growing herd in a harsh fenced in yard that is covered with piles of feces and vomit, and there are flies and maggots everywhere. The flies and maggots cover the cats' runny eyes and open wounds. An unknown number of cats have gone over the fence and are living outside with unknown support for their basic needs.

14. The Board members whom I met with showed no concern about these horrific conditions. This leads me to believe this situation is not new nor is it worse than things that have happened in their past.

15. Troy Snow was there at the same time I was and took photos of the condition of many of the cats.

(Document notorized July 11, 2007)

DECLARATION OF TROY SNOW

I, Troy Snow, state under oath and penalty of perjury under the laws of the State of Nevada, that I am over 21 years old, of sound mind and have personal knowledge of the facts stated in this declaration.

1.1 am a professional photographer. I volunteered at FLOCK in Pahrump, Nevada from July 1, 2007 until Wednesday, July 4,2007. While I was at FLOCK on these dates, I took the attached photographs that I have numbered from one to nine. These photographs fairly and accurately depict what I saw at FLOCK. The photos are true representations of what I saw.

2. Photograph one shows a black and white cat with blood running from its nostrils.

3. Photograph two shows the open yard. The cats are in one large colony and live on hard packed dirt. There is no way to disinfect the ground. There is no shade to speak of ,and the cats were suffering in the heat, looking for any shade at all. When I was at FLOCK it was over 110 degrees. The animals share food and water trays. Many seemed to be starving.

4. Photograph three shows a cat that is skin and bones. Also, look at its ears. They have some type of disease. This cat could barely walk. It wasn't getting any medical care.

5. Photograph four shows one of the many mounds of cat feces you, can see everywhere at FLOCK. You can't smell a photograph, but it did stink. Flies and maggots are on the feces and swarm around "goop" in the cats' eyes and nose and also on their wounds.

6. Photograph five shows the inside of one of the few, small cat buildings and made of just pressboard or plywood. Again, flies are everywhere. Notice how many flies are on the food bowl. This was typical of what I saw while I was there.

7. Photograph six is difficult to even look at. It shows a black and white cat with its eye out of the socket. It has been neglected so long that a growth of some kind has crusted over the eye. There are also two maggots that are emerging from the eye itself. If that is not enough suffering for this cat, look at its lower right leg. It has an open wound. None of these conditions appeared to be treated. This cat was roaming free in the yard.

8. Photograph seven shows a yellow cat that is very skinny and has an injury to its right ear. This cat did not appear to be receiving any treatment and was roaming the yard.

9. Photograph eight shows a black cat with an untreated eye injury. You can see a fly resting on the injured and infected eye. This cat also has some kind of ooze coming from I its right eye. You can see the flies that surround these cats in this photo as well.

10. Photograph nine shows a skinny cat with a bloody discharge from its right eye. This cat also has some kind of disease on its right ear. This cat was roaming free in the general cat population.

(Document notorized July 11, 2007)