Complaint March 2018 PDF

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- 1 1 ,
THE AMIIAL DEFENSE PARTNER1:11f)
David Ebert • Co-Founder

david@ animalde fens ep artnership.org
(212) 907-9603
March 28, 2018
By Overnight Mail and Email

(dgifweb@dgif.virginia.gov ; WildCrime@dgilvirginia.gov)
Virginia Department of Game and Inland Fisheries

P.O. Box 90778
Henrico, VA 23228-0778
Atm: Robert W. Duncan - Executive Director; Gary Martel - Deputy Director; Maj.
Scott Naff - Operations Law Enforcement; and David Whitehurst - Wildlife
Resources Bureau
Re: Natural Bridge Zoo Permit Revocation and Request for Sekure of Asha The Elephant
Dear Messrs. Duncan, Martel, Whitehurst and Major Naff:
I am a co-founder of The Animal Defense Partnership, Inc. ("ADP"). ADP, together with
Save Nosey Now, In Defense of Animals, One World Conservation and Anna Katogyritti of Jane
Goodall's Roots and Shoots Program (Greece) (collectively, the "Coalition"), write on behalf of Kim
Hogan, Tonya Dyer and Suzanne Rodeman, each a resident of the Commonwealth of Virginia (the
"Residents").
The Animal Defense Partnership, Inc.

3 West Main Street — Suite 201C, Irvington, New York 10533
A 501(c)(3) Not-For-Profit Corporation
IRS EIN:3109559
NYS Reg. No. 45-57-36
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The Residents wish to file a civil and criminal wildlife complaint against Natural Bridge Zoo
("NBZ") and its owner, Karl Mogensen ("Mogensen") for abuse and neglect of the elephant housed
at NBZ known as "Asha." In addition, we urge DGIF to revoke Mogensen's exhibitor permit, seize
Asha and place her at either the Performing Animal Welfare Sanctuary ("PAWS") in California or
The Elephant Sanctuary in Tennessee ("TES"), both of which are GFAS (Global Federation of
Animal Sanctuaries) accredited sanctuaries. The Residents and Coalition stand ready to assist DGIF
in investigating NBZ and Mogensen, and in securing a place for Asha at PAWS or TES.
NBZ and Mogensen's Long-Standing Record of Abject Abuse and Neglect of Asha
As DGIF is aware from its prior experience with NBZ and Mogensen, NBZ and Mogensen
have a long and ugly history of animal abuse and neglect at NBZ, which is a matter of public record.
Mogensen signed a USDA consent decree on October 12, 2007, following a USDA investigation, in
which he agreed to comply with the Animal Welfare Act ("AWA"). A copy of the consent decree is
attached as Exhibit A. As DGIF is aware, Mogensen failed and refused to fulfill, and thereby
breached, its obligations under the consent decree, and continues to do so to this day.
Most recently, in March 2015, NBZ was shut down following a USDA investigation that
yielded a staggering 44 separate violations of the Animal Welfare Act. (See Exhibit B attached.)
According to DGIF records, DGIF reinstated the permit after determining that NBZ had come into
"substantial compliance." As with the consent decree, however, NBZ and Mogensen quickly fell
out of "substantial compliance" (if they were ever in compliance at all). NBZ and Mogensen
continue to operate, notwithstanding that they still engage in the same conduct that was the cause
for suspending its permit in the first place, and doing so with impunity.
For your reference, attached as Exhibit C are the reports of five USDA inspections
conducted after Mogensen's permit was reinstated. As can be seen, Mogensen and NBZ were found
to have committed numerous AWA violations, many of which repeat prior infractions.

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NBZ and Mogensen's Continuing Abject Abuse and Neglect of Asha
Are far as we have been able to determine, Asha continues to be held in winter as a solitary
elephant (her companion having died in 2007) in an unheated barn on a cement floor. While
Mogensen represented in 2015 that he was adding a layer with heated coils underneath the concrete
floor (see http://wset.com/archive/worst-zoo-for-elephant-natural-bridge-zoo-speaks-on-handling-
of-asha), there is no indication that he has done so, or intends to.
Here is what is currently known about Asha's current conditions:
Barn
• Unheated or inadequately heated Metal 50' x 56' barn

• Concrete floor
• Inadequate bedding to absorb urine and prevent it splashing up on her legs causing urine
scald.
• No rubber mats to cushion joints and for sleeping.
Paddock
• No shade even while giving rides in extreme heat

• No physical enrichment - except a couple stumps and a tire.
• No feeding enrichment
• Inadequate barriers to contain elephant and keep public safe or prevent escape
Exhibition Description
• Rides Tues-Sun 6 days a week

• Public feeding
• No shade in ride area
• Not allowed to eliminate during rides — feeding schedule manipulated accordingly
• Inadequate rest period during exhibition/rides

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NYS Reg. No. 45-57-36
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Attached as Exhibit D is a preliminary assessment by Toni Frohoff, Ph.D., a leading wildlife

behavioral scientist, specializing in elephants and other mammals in captivity and in the wild. Dr.
Frohoff explains the serious adverse effects these conditions have on elephants in general, and how
these conditions relate to Asha's particular circumstances. Among Dr. Frohoff's findings are:
1. Asha is isolated from other elephants, which has been critically damaging to her
psychological and physical health and well-being. The science is clear that social
isolation is cruel and inhumane for elephants.
2. Asha's deplorable living conditions cause Asha great physical harm and psychological
distress. The harmful conditions include but are not limited to, inadequate space,
inadequate temperature controls and concrete flooring, which harms Asha's feet and
joints. Individually and collectively, these inhumane and harmful living conditions are
universally recognized by scientists as causes of captivity-related pain, ilhiess and
early mortality.
3. The manner in which Asha is exhibited presents a significant risk to the public.
We have also compiled a list of NBZ and Mogensen's on-going AWA violations, which is
attached as Exhibit E.
The Applicable Virginia Statutes
NBZ and Mogensen's cruelty and abuse violates several provisions of the Virginia Code.
This includes Virginia Code § 3.2-6503, which governs care of companion animals, provides, in
relevant part, as follows:
§ 3.2-6503. Care of companion animals by owner; penalty
A. Each owner shall provide for each of his companion animals:
1. Adequate feed;

IRS EIN:3109559
NYS Reg. No. 45-57-36
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2. Adequate water;
3. Adequate shelter that is properly cleaned;
4. Adequate space in the primary enclosure for the particular type of animal
depending upon its age, size, species, and weight;
5. Adequate exercise;
6. Adequate care, treatment, and transportation; and
7. Veterinary care when needed to prevent suffering or disease transmission.
The provisions of this section shall also apply to every public or private animal shelter, or
other releasing agency, and every foster care provider, dealer, pet shop, exhibitor, kennel,
groomer, and boarding establishment. This section shall not require that animals used as
food for other animals be euthanized.
B. Violation of this section is a Class 4 misdemeanor. A second or subsequent

violation of subdivision A 1, 2, 3, or 7 is a Class 2 misdemeanor and a second or
subsequent violation of subdivision A 4, 5, or 6 is a Class 3 misdemeanor.
Asha is a companion animal within the meaning of Virginia Code § 3.2-6500 and, as such is
entitled to all of the protections afforded by Virginia Code § 3.2-6503.
Virginia Code § 3.2-6570, which governs animal cruelty, provides, in relevant part, as
follows:
§ 3.2-6570. Cruelty to animals; penalty.
A. Any person who: (i) overrides, overdrives, overloads, tortures, ill-treats,

abandons, willfully inflicts inhumane injury or pain not connected with bona fide
scientific or medical experimentation, or cruelly or unnecessarily beats, maims,

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NYS Reg. No. 45-57-36
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mutilates, or kills any animal, whether belonging to himself or another; (ii)

deprives any animal of necessary food, drink, shelter or emergency veterinary
treatment . . . (v) willfully sets on foot, instigates, engages in, or in any way
furthers any act of cruelty to any animal; (vi) carries or causes to be carried by
any vehicle, vessel or otherwise any animal in a cruel, brutal, or inhumane
manner, so as to produce torture or unnecessary suffering; or (vii) causes any of
the above things, or being the owner of such animal permits such acts to be done
by another is guilty of a Class 1 misdemeanor.
Finally, Virginia Code § 3.2-6569, which governs seizure of animals subjected —as with
Asha—to cruelty, abuse and neglect, provides in relevant part as follows:
§ 3.2-6569. Seizure and impoundment of animals; notice and hearing; disposition

of animal; disposition of proceeds upon sale.
A. Any humane investigator, law-enforcement officer or animal control officer may

lawfully seize and impound any animal that has been abandoned, has been cruelly
treated, or is suffering from an apparent violation of this chapter that has
rendered the animal in such a condition as to constitute a direct and immediate
threat to its life, safety or health
The humane investigator, law-enforcement officer, or animal control officer shall provide
for such animal until the court has concluded the hearing. Any locality may require the
owner of any animal held pursuant to this subsection for more than thirty days to post a
bond in surety with the locality for the amount of the cost of boarding the animal for a
period of time set by ordinance, not to exceed nine months.
Other Concerns
Mr. Mogensen's son-in-law, Dr. Allan Earl Strecker, functions as his veterinarian and should
be held liable for his actions and inactions. Pursuant to Virginia Code 3.2-6564, 3.2-6565, and 3.2-
6574 through 3.2-6580, "In no event shall a licensed veterinarian who has acted in good faith and

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properly exercised professional judgment regarding an animal be subject to liability for his actions in:
(i) acting in accordance with subsection A; or (ii) reporting cases of suspected cruelty to animals.
We believe that Dr. Strecker has acted in bad faith and needs to be held accountable to the extent he
has been complicit in any of the conduct at issue.
DGIF permit regulations state, in relevant part, "Permanent exhibits must be open to the
public. A private menagerie is not considered an educational exhibit." NBZ is not currently open to
the public, and has not been for months. Mogensen is maintaining a private menagerie, a permit
violation he has perpetuated for years. This is yet another compelling reason to revoke Mogensen's
permit and seize Asha.
Finally, NBZ is scheduled to reopen for the season on March 31, 2018. Attached as Exhibit
F are relevant pages of an NBZ brochure, which, at page 31, promotes its encounters with tiger
cubs, a flagrant violation of AWA and the Endangered Species Act. And in doing so Mogensen
disregards his own prior promises of discontinuing this substantial threat to public safety, a violation
of the AWA and abuse of the tiger cubs he is shamelessly exploiting (see
http://wset.com/archive/owner-of-natural-bridge-zoo-says-hes-in-compliance-and-ready-for-
inspectors).
Conclusion
Based on its long-standing history and pattern of inflicting abuse, neglect and cruelty on
Asha, NBZ and Mogensen have violated a slew of Virginia's anti-cruelty prohibitions and care and
maintenance directives, which more than justifies seizing and placing Asha in PAWS or TES.
DGIF has historically taken the position that these animal welfare issues are solely in the
hands of USDA/APHIS. Although we understand that DGIF may be inclined to defer to the
USDA/APHIS, that agency will not and cannot enforce the Virginia Code, which speaks quite
clearly to the duties and responsibilities of DGIF, regardless of what actions the USDA/APHIS may
or may not take, and regardless of what conclusions it may reach.

3 West Main Street — Suite 201C, IrvMgton, New York 10533
IRS EIN:3109559
NYS Reg. No. 45-57-36
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The USDA/APHIS and DGIF have dual authority (see Exhibit G). The USDA/APHIS
inaction to remove Asha to a sanctuary does not excuse DGIF from fulfilling its duties as proscribed
by Virginia Code. Each day that DGIF permits Asha to suffer and be harmed by conditions caused
by Mogensen at his Natural Bridge Zoo is another day that Asha is refused relief by the State of
Virginia and its Department of Game and Inland Fisheries.
For the forgoing reasons, the Residents and Coalition urges DGIF to revoke NBZ and
Mogensen's permit, seize Asha and transfer her to PAWS or TES pending a hearing on the merits.
The Animal Defense Partnership
Name: David Ebert

Title: Co-Founder and President
cc: Tom Wilcox (Tom.Wilcox@dgilvirginia.gov)

Jim Husband (Jim.Husband@dgif.virginia.gov)
Michelle Welch (mwelch@oag.state.va.us )
Mathew Hull (MHull@oag.state.va.us)

IRS EIN:3109559
NYS Reg. No. 45-57-36
Exhibit A
Consent Decree
l
UNITED STATES DEPARTMENT OF AGRICULTURE
BEFORE THE SECRETARY OF AGRICULTURE
In re: AWA Docket No.07-0144
Karl Mogensen, d/b/a

Natural Bridge Zoo,
Consent Decision
Respondent and Order
This proceeding was instituted under the Animal Welfare Act, as amended (7 U.S.C.
§ 2131 et by a complaint filed by the Administrator, Animal and Plant Health Inspection
Service, United States Department of Agriculture, alleging that the respondent willfully violated
the Act and the regulations and standards issued pursuant to the Act (9 C.F.R. § 1.1 et seq.). This
decision is entered pursuant to the consent decision provisions of the Rules of Practice applicable
to this proceeding (7 C.F.R. § 1.138).
The respondent admits the jurisdictional allegations in paragraph I of the complaint and
specifically admits that the Secretary has jurisdiction in this matter, neither admits nor denies the
remaining allegations, waives oral hearing and further procedure, and consents and agrees, for
the purpose of settling this proceeding and for such purpose only, to the entry of this decision.
The complainant agrees to the entry of this decision.
Findings of Fact
1. Karl Mogensen, hereinafter referred to as the respondent, is an individual doing
business as Natural Bridge Zoo with a mailing address of P.O. Box 88, Rt 11 North, Natural
Bridge, VA 24578.
2
2. The respondent, at all times material herein, was licensed and operating as an
exhibitor as defined in the Act and the regulations.
Conclusions
The respondent having admitted the jurisdictional facts and the parties having agreed to
the entry of this decision, such decision will be entered.
Order
1. Respondent, his agents and employees, successors and assigns, directly or through
any corporate or other device, shall not violate the Act and the regulations and standards issued
thereunder, and in particular, shall not:
(a) Fail to construct and maintain housing facilities for animals so that they
are structurally sound and in good repair in order to protect the animals from injury, contain them
securely, and restrict other animals from entering;
(b) Fail to store supplies of food so as to adequately protect them against
contamination; and
(c) Fail to construct and maintain facilities for animals so that they are
structurally sound, in good repair, and appropriate for the animals involved, including a suitable
perimeter fence.
2. Respondent is assessed a civil penalty of $10,000, which shall be paid by a
certified check or money order made payable to the Treasurer of the United States.
3. Respondent's license is suspended beginning on January 1, 2008, up to and
including January 30, 2008, and continuing thereafter until he demonstrates to the Animal and
Plant Health Inspection Service (APHIS) that he is in full compliance with the Act, the
3
regulations and standards issued thereunder and this order, including payment of the civil penalty
imposed herein. When the respondent demonstrates to APHIS that he has satisfied this
condition, a supplemental order will be issued in this proceeding upon the motion of APHIS,
terminating the suspension.
The provisions of this order shall become effective on the first day after service of this
decision on the respondent.
Copies of this decision shall be served upon the parties.
Karl Mogensen
Respondent
Alliaostaba,
H. David Natkin
Attorney for Respondent
Frank Martin, Jr.

Attorney for Complainant
Done at Washington, D.C.

this I Z day of Oczfo 6te, 2007
Administrative Law Judge

S. CL: in
Exhibit B
2015 Permit Revocation

Molly J. Ward
COMMONWEALTH of VIRGINIA Robert W. Duncan
Secretaiy of Natural Resource., Department of Game and Inland Fisheries Erecative Director
March 9, 2015
Mr. Karl Mogensen

Natural Bridge Zoo
P.O. Box 88
Natural Bridge, VA 24578
Dear Mr. Mogensen:
The Department of Game and Inland Fisheries (DGIF) has formally been asked by
Humane Society of the United States (HSUS) to investigate Natural Bridge Zoological Park's
(NBZ) general operation and animal husbandry, handling, housing, and exhibition practices. The
request to investigate NBZ's operations and animal practices was received on January 22, 2015.
On January 27, 2015 DGIF was contacted by the United States Department of Agriculture,
Animal and Plant Health Inspection Service (USDA-APHIS) about an inspection they conducted
January 6-9, 2015. USDA- APHIS provided DGIF with a full inspection report that documents
serious noncompliance at NBZ. As a USDA licensed facility you must be in compliance with the
Animal Welfare Act. It is our understanding that you are working with the USDA inspectors to
correct the identified deficiencies.
Based on the documented citations noted by the USDA, the Department is suspending NBZ's
Exhibitor Permit #52797. It is clear to the Department that you are in violation of several general
conditions of your Exhibitor Permit. Specifically, it has been documented that many of the
animals are confined under unsanitary and inhumane conditions (#4) and your permit does not
absolve you of any responsibilities or conditions of any other federal, state, or
local laws and regulations (#17).
Therefore, your Exhibitor Permit is suspended until substantive compliance is achieved with the
USDA, as determined by the Department staff for two consecutive inspections of your facility.
You have the right to appeal this decision, in writing, to the Director, DG1F, within 30-days the
date of this letter. The appeals process is available for review and download at DGIF's website:
www.dgif. virginia.gov/perrnits/permit-appeal-process.pdf.
4010 WEST BROAD STREET, P.O. BOX 11104, RICHMOND, VA 23230-1104

(804) 367-1000 (V/TDD) Equal OpportaniV Employment, Programs and Facilities FAX (804) 367-9147
Mr. Karl Mogensen
March 9, 2015
Page 2
Please feel free to contact the Permits Section at (804) 367-9588, or by email at
collectionpermits@dgiEvirginia.gov , if you have questions.
Ince ly,
Ja es E. iànd
sh & Wildlife Information Service/Permits Manager
JEH/ES/MK
cc: Robert Duncan, Director

David Whitehurst, Director, Bureau of Wildlife Resources
Colonel R. Henry, Law Enforcement
Matthew Hull, Office of the Attorney General
Michelle Welch, Office of the Attorney General
Jeff Trollinger, Deputy Director, Bureau of Wildlife Resources
Rick Busch, Assistant Bureau Director, Region IV
Dana M. Miller, DVM, USDA, APHIS, Animal Care
Carolynn Bissett, DVM, VDACS
Megan Kirchgessner, DVM, Bureau of Wildlife Resources
Ed Steinkoenig, Permits Supervisor
Sgt. Gregory Funkhouser, Law Enforcement, Region IV
Al Bourgeois, District Wildlife Biologist, Region IV
Dianne Waller, Permits Specialist
Exhibit C
USDA Post Reinstatement Inspection Violations
KCOHEN
USDA United States Department of Agriculture
Animal and Plant Health Inspection Service
Inspection Report
Customer ID:
NATURAL BRIDGE, VA
Certificate:
Site: 001
Type: ROUTINE INSPECTION

Date: 24-OCT-2017
2.131(c)(1) REPEAT
HANDLING OF ANIMALS.
The public is permitted to walk directly up the primary enclosures containing several species of animals. This
includes camels, sheep, goats, pigs, muntjac deer, fallow deer, bongo, llama, giraffe, sitatunga, oryx, zebra, and
kudu. These animals are housed in the walk through area of the zoo which is open to the public. Additionally, one
temporary pen was set up on a grassy section of the zoo grounds to allow public interaction with two young llamas.
There are no barriers present to discourage public contact and the guests are encouraged to feed food sold at the
entry gate and coin feeders are located throughout the facility. There are no attendants present during public
contact and guests may walk directly up to enclosures and pet the animals. Primary enclosure fences are made of
material with spaces large enough for the guests to reach through and touch the animals. Unattended public
contact does not ensure safe public interaction with these animals. Licensees must ensure that during periods of
public exhibition animals are handled with sufficient distance and/or barriers between the animal and the general
viewing public so as to assure the safety of animals and the public. Correct by placing barriers to prevent public
contaCt with these animals or by ensuring that an adequate number of attendants are present at each of these
locations to ensure the safety of both the public and the animals.
— The camel identified for a veterinary care issue on the last inspection was seen by the veterinarian.
*"* The inspectors were unable to assess the presence or absence of the elephant handler during periods of public
exhibition due to limited public attendance during the inspection.
*** The citation under Section 3.127 (d) from the previous inspection report has a correction date of March 1, 2018.
This inspection was conducted on Tuesday October 24, 2017 with the facility representative and the owner.
The exit interview was conducted with the owner and his wife on Wednesday October 25, 2017.
Prepared By: COHEN KIMBERLEY, D V M

Date:
COHEN KIMBERLEY, D V M USDA, APHIS, Animal Care
25-OCT-2017
Title: VETERINARY MEDICAL OFFICER 6105
Received By:
Date:
Title: 25-OCT-2017
Page 1 of 2
KCOHEN
Animal and Plant Health Inspection Service Insp_id
Inspection Report
Additional Inspectors
Coleman Randall, Animal Care Inspector
Brunkhorst Susanne, Veterinary Medical Officer
Prepared By: COHEN KIMBERLEY, D V M

Date:
25-OCT-2017
Received By:
Date:
Title: 25-OCT-2017
Page 2 of 2
KCOHEN
Inspection Report
NATURAL BRIDGE, VA Customer ID:
Certificate:
Site: 001

Date: 22-FEB-2017
2.40(b)(2) DIRECT REPEAT
ATTENDING VETERINARIAN AND ADEQUATE VETERINARY CARE (DEALERS AND EXHIBITORS).

One adult male giraffe had an approximately 4" crack on the lateral aspect of the lateral hoof of the left rear foot.
There was no documentation to indicate that this deficit in the hoof had been observed by facility personnel. A
crack in the hoof of a giraffe can become a serious issue should the crack become infected or further damaged
resulting in an inability to walk.
Two adult female giraffes had excessively overgrown hooves on both front feet. Overgrown hooves when left
uncorrected can potentially lead to foot and joint problems that can cause gait abnormalities. For the comfort and
health of the animals trimming must occur frequently enough to prevent this condition.
A female nyala was observed standing with a hunched posture in the outdoor pasture area. She appeared to have
an adequate body condition however her coat was not smooth similar to the other nyalas in the pasture area. The
front of her body did not coordinate with the rear part of her body when she was walking resulting in a swaying
motion. When she attempted to run down the slope of the pasture her gait was uncoordinated with her front legs
crossing each other as she moved. This instability in her gait caused her to wobble in attempt to regain her balance
without falling over. The licensee stated the nyala was eating well and in good body condition with no change in
her condition since it was first observed on 8/24/16. There is no documentation to indicate that any veterinary
evaluation of this animal has been performed.
All daily observations of problems in animal health need to be communicated to the veterinarian to ensure that an
appropriate diagnosis is made and a treatment plan can be instituted to ensure the health of the animals and the
safety of the public that has contact with the animals. A veterinarian needs to examine the giraffes for their hooves
and nyala for her hunched posture and uncoordinated gait to determine a diagnosis and set up a treatment plan.
COHEN KIMBERLEY, D V M
Prepared By:
Date:
23-FEB-2017
Received By:
Date:
Title: 23-FEB-2017
Page 1 of 3
KCOHEN
Inspection Report
3.75(a) REPEAT
HOUSING FACILITIES, GENERAL.

The roof of the building housing the ringtail lemurs, black and white ruffed lemurs and red ruffed lemurs is in need of
repair. The eave portion of the roof to the right of the entrance door is deteriorating. The roof tiles are crumbling on
the edges and the visible wood underneath appears rotted. On the inside of the building in the corresponding part of
the blinding the ceiling is wet showing that water is leaking through the damaged roof area. In addition, an
approximately two foot section of the roofline appears to be sagging compared the rest of the roofline with a dented
area visible in the slant of the roof just below that section of the roofline. Tree branches are visible resting on the
roof. A roof in need of repair can lead to leakage into the building and may not remain structurally sound. The lemur
housing facility needs to be kept in good repair.
3.76(b)
INDOOR HOUSING FACILITIES.

The building referred to as the "mouse house" currently houses capuchins (brown tuff and black & white) along with
birds and rodents. Upon entering the building a strong odor of ammonia was noted by the inspectors. This odor
remained strong throughout the entire time the inspectors were in the building. One window was opened about six
inches. At least one floor fan was noted. The facility representative states that windows are opened when cleaning
is done and then closed. The capuchin cages appeared to have just been cleaned. The bird cages and rodent
cages were in need of cleaning. The current level of ventilation is not sufficient to remove the currently high levels of
ammonia odors. Prolonged exposure to excessive ammonia odors can lead to respiratory, eye and mucus
membrane problems for the capuchins. Indoor housing facilities for the capuchins must be sufficiently ventilated at
all times to provide for their health and well-being and to minimize odors, drafts, ammonia levels and moisture
condensation. Correct by Mar. 14, 2017.
3.125(a) REPEAT
FACILITIES, GENERAL.
There are several areas of primary enclosure fencing for the goat, pig, muntjac, fallow deer, bongo, sitatunga, oryx,
and blesbok where trees and vines have grown through the fence and areas that are impossible to inspect because
they have been overgrown by brush. These areas of fencing are not functional in the current condition. The licensee
must ensure that no trees or brush are affecting the structural strength or the ability to inspect the fencing. Failure to
maintain a functional primary enclosure fence does not ensure that all animals can be properly contained and
protected from injury. Correct this by conducting a thorough self-inspection of the all enclosure fencing to ensure
Prepared By:
Date:
23-FEB-2017
Received By:
Date:
Title: 23-FEB-2017
Page 2 of 3
KCOHEN
Inspection Report
that all areas are functional and comply with written requirements.
""*The facility is currently closed for the season so APHIS personnel were unable to determine to adequacy of the
elephant enclosure barriers and the presence/absence of an attendant during periods of public exhibition.
***The perimeter fence variance requests are under review.
This inspection and exit interview were conducted with the owner and another facility representative.

Prepared By:
Date:
23-FEB-2017
Received By:
Date:
Title: 23-FEB-2017
Page 3 of 3
KCOHEN
Inspection Report
NATURAL BRIDGE, VA Customer ID:
Certificate:
Site: 001

Date: 20-JUN-2017
2.40(b)(2) REPEAT

An adult female camel was observed by inspectors to have a large amount of fluid soaked hair on both rear legs.
The fluid was of sufficient amount that it coated and discolored the hair of the hind legs from the back of the upper
thighs down to towards the feet. A thin trail of the fluid was noted on the front of the right leg below the knee and
was red in color. The camel appeared to have a normal gait and was not in obvious distress however a red fluid
present on the hind limbs of a camel is not a normal condition.
All daily observations of problems in animal health need to be communicated to the veterinarian so that an
appropriate diagnosis can be made and a treatment plan instituted as needed to ensure the health of the animals
and the safety of the public that has contact with the animals.
2.131(c)(1) REPEAT
During a recent visit to the zoo by an APHIS official, the African elephant was observed without her handler
immediately available when the public was present in the zoo. The elephant was contained in her enclosure on the
back side of the elephant barn. The keeper was reported to have been in the barn however there are no windows
or other openings within the wall of the barn to visualize the elephant when she is positioned on the south facing
wall of the barn. The barrier between the elephant and the public consists of either single strand electric wire
fencing or areas of livestock panel/gates that are not structurally strong enough to contain the adult elephant should
she choose to get out of her area and into the public areas. The facility must ensure that the handler is with the
elephant at all times when the facility is open or choose to construct a primary enclosure that will adequately contain
the elephant.
The public is permitted to walk directly up the primary enclosures containing several species of animals. This
includes camels, sheep, goats, muntjac deer, fallow deer, bongo, llama, giraffe, sitatunga, oryx, zebra, and kudu.
These animals are housed in the walk through area of the zoo which is open to the public. Additionally, two
Prepared By:
Date:
21-JUN-2017
Received By:
Date:
Title: 22-JUN-2017
Page 1 of 4
KCOHEN
Inspection Report
temporary pens were set up on two grassy sections of the zoo grounds to allow public interaction with a young
camel and young goats. There are no barriers or signs present to discourage public contact and the guests are
encouraged to feed food sold at the entry gate and coin feeders are located throughout the facility. Also, inspectors
noted members of the public picking grass from the facility grounds and feeding it to the fallow deer. There are no
attendants present during public contact and guests may walk directly up to enclosures and pet the animals.
Primary enclosure fences are made of material with spaces large enough for the guests to reach through and touch
the animals. Unattended public contact does not ensure safe public interaction with these animals. Licensees must
ensure that during periods of public exhibition animals are handled with sufficient distance and/or barriers between
the animal and the general viewing public so as to assure the safety of animals and the public. Correct by placing
barriers to prevent public contact with these animals or by ensuring that an adequate number of attendants are
present at each of these locations to ensure the safety of both the public and the animals.
3.75(a) REPEAT

The roof of the building housing the ringtail lemurs, black and white ruffed lemurs and red ruffed lemurs is in need of
repair. The eave portion of the roof to the right of the entrance door is deteriorating. The roof tiles are crumbling on
the edges and the visible wood underneath appears rotted. On the inside of the building in the corresponding part of
the building the ceiling is wet showing that water is leaking through the damaged roof area. In addition, an
approximately two foot section of the roofline appears to be sagging compared the rest of the roofline with a dented
area visible in the slant of the roof just below that section of the roofline. Tree branches are visible resting on the
roof. The owner stated that the roof was not yet repaired as one of the lemurs was pregnant. A roof in need of repair
can lead to leakage into the building and may not remain structurally sound. The lemur housing facility is still in
need of repair in order to maintain the animals in a safe and secure manner.
3.80(b)(2)(i)
PRIMARY ENCLOSURES.
Two gibbons are being housed in primary enclosures in the mouse house building that are 6 feet in height.
These primates are brachiating species in Group 6 and require enclosures that are 84" (7 feet) in height to allow for
normal movement. These animals require additional height to meet their minimal space requirements. Lack of
adequate height does not allow these brachiating species to engage in normal species-type behavior including
swinging and may lead to physical and behavioral problems. The licensee stated that these animals are new
acquisitions and they plan to move them to another enclosure. Correct this by providing these animals an enclosure
Prepared By:
Date:
21-JUN-2017
Received By:
Date:
Title: 22-JUN-2017
Page 2 of 4
KCOHEN
Inspection Report
meeting their height requirements.
Correct by: September 20, 2017
3.125(a) REPEAT
There remain several areas of primary enclosure fencing for the goat, pig, muntjac, fallow deer, bongo, sitatunga,
oryx, and blesbok where trees and vines have grown through the fence and areas that are impossible to inspect
because they have been overgrown by brush. The only difference noted on this inspection is that a tree had fallen
on the back fence of the muntjac enclosure. The vegetation and downed tree branch were removed from the
affected area in order to replace damaged fencing. The overgrown areas of fencing are not functional in the current
condition. The licensee must ensure that no trees or brush are affecting the structural strength or the ability to
inspect the fencing. Failure to maintain a functional primary enclosure fence does not ensure that all animals can be
properly contained and protected from injury. Correct this by conducting a thorough self-inspection of all enclosure
fencing and clearing all vegetation needed to ensure that all areas of fencing are functional, inspectable and in
compliance with written requirements.
3.127(d)
FACILITIES, OUTDOOR.
The facility currently does not have a secondary or perimeter fence for some portions of the zoo. Several primary
enclosures, including those housing the goats/sheep/zebu petting zoo, pigs, muntjac, fallow deer, bongo, giraffe,
and sitatunga, back up to a county road with the primary enclosure fence and some vegetation the only barriers
between the public on the road and the animal enclosure. In one section there is an area where the public can climb
up a short rise and get directly up to the giraffe enclosure fencing. In addition, there is another area of the zoo
where the camel and kudu enclosures abut the neighbor's property. The neighbor's backyard can be seen through
the fence and on the previous inspection the neighbor's dog was seen running along the fence adjacent to the
camels. The lack of perimeter fencing can allow for contact between the public and unwanted animals with the
exhibited animals which could be dangerous for both the animals and the public. The perimeter fence should also
act as a secondary containment system in case of damage to the primary enclosure fencing. The facility shall
address the lack of secondary perimeter fencing by adding additional fencing or by other corrective measures as
required by the regulation.
Prepared By:
Date:
21-JUN-2017
Received By:
Date:
Title: 22-JUN-2017
Page 3 of 4
KCOHEN
Inspection Report
Correct by: March 1, 2018.
3.131(d)
SANITATION.
** Several rodent holes were found behind the porcupine enclosure near the cougars. A live rat was observed
inside the muntjac enclosure and also in the feed pan for the muntjac. Other rodent holes were found by the tufted
capuchin enclosure near the front of the facility and next to the Mandrill exhibit. There were also rodent paths worn
in the grass area near the Mandrill. The presence of these mammalian pests is a potential disease hazard to the
animals as these rodents can be carriers of disease and parasites. Safe and effective programs of control for these
pests must be established and maintained to minimize the risks to the animals. Correct by evaluating the current
pest control program and ensuring that effective methods are maintained.
Correct by: July 21, 2017
This inspection was conducted on 6/20/2017 with owner and facility personnel.
The exit interview was conducted on 6/21/17 with owner and his wife.
Prepared By:
Date:
21-JUN-2017
Received By:
Date:
Title: 22-JUN-2017
Page 4 of 4
RCOLEMAN
2016082567919034 Insp_id
Inspection Report
Karl Mogensen Customer ID: 2468
Po Box 88 Certificate: 52-C-0035

Natural Bridge, VA 24578 Site: 001
NATURAL BRIDGE ZOO

Date: 09-AUG-2016
2.40(a)(2)

*** On March 9, 2016 the attending veterinarian conducted an exam of a female spider monkey and recommended
"diagnostics and physical exam" for an enlarged abdomen. The facility has not given the AV permission to
complete these recommended procedures. The animal is currently at the facility. The licensee must ensure that
all recommendations for treatment/care/exams/testing are followed and that the AV have the authority to make
those decisions. Failure to assure the appropriate authority of the attending veterinarian does not ensure adequate
care for animals at the facility.
Correct by: September 1, 2016
2.40(b)(2) REPEAT

*** Several sheep and goats on exhibit in the petting area enclosure are in need of veterinary care:
*At least four goats (two black and two brown colored goats) were noted to have multiple approximately silver dollar
size round to oval areas of hairloss on their sides/trunk. These areas had distinct margins between normal and
abnormal areas. The skin in these areas was flaky in appearance with white/grey flakes visible adhered to the skin.
*One adult large white sheep and one adult brown goat had visible areas of swelling. The white ram had a large
baseball size swelling under the left side of its jaw/neck. The brown goat had an egg size swelling in front of left
shoulder/lower neck area.
The facility representatives with the inspectors during the inspection were not aware of any sheep/goat issues when
asked. Multiple versions of caretaker records were reviewed. None noted the skin lesions. Regarding the swellings,
one version of the 8/8/16 record (Vet Care) show no mention of any goat or sheep issues. A second version of the
8/8/16 records (Daily Care) mentions that "noted female goat with abscess on shoulder will have vet check on Wed
and recheck lamb with growth on neck". No previous notations of evaluations, diagnosis or treatment of a lamb with
a growth on neck could be found in the records. A veterinarian had been out to the facility on 8/8/16. He was
RANDALL COLEMAN, A C I
Prepared By:
Date:
RANDALL COLEMAN USDA, APHIS, Animal Care
12-SEP-2016
AKIIKAAI CAPP INICPPrTrIR 10A1
Title:
Received By:
(b)(6), (b)(7)(c)
Date:
Title: CERTIFIED MAIL #70160600000051706146 13-SEP-2016
Page 1 of 4
RCOLEMAN
Animal and Plant Health Inspection Service 2016082567919034 Inspid
Inspection Report
contacted and stated that he saw two other animals on the afternoon of 8/8/16 but was not asked to look at any
sheep or goats. He did state that he was coming out on Wednesday afternoon 8/10/16 to look at some animals
including a goat.
All daily observations of problems in animal health need to be communicated to the veterinarian to ensure that an
appropriate diagnosis is made and a treatment plan can be instituted to ensure the health of the animals and the
safety of the public that has contact with the animals. A veterinarian needs to examine the goats and sheep to
determine a diagnosis and set up a treatment plan for the skin lesions and swellings. Documentation should be kept
of all communications with the veterinarian, the diagnosis and all treatments.
— A female spider monkey was euthanized on July 20, 2016 according to facility records. During the exit interview
the licensee stated that the animal had been going downhill for quite some time. There are no records on hand for
this animal prior to the day of euthanasia (7/20/16). After veterinary exam on 7/20 revealed difficulty breathing in
the animal, euthanasia was elected.
2.131(c)(1)
*"* During this inspection, the African elephant was observed on 2 occasions without her handler immediately
available when the public was present in the zoo. The first occasion was after the handler gave her a bath and left
her unattended while he worked on cleaning the barn. The second was after rides were completed for the day at
which time he drove up in his truck after inspectors noted the elephant was alone. The barrier between the elephant
and the public consists of either single strand electric wire fencing or areas of livestock panel/gates that are not
structurally strong enough to contain the adult elephant should she choose to get out of her area and into the public
areas. The facility must ensure that the handler is with the elephant at all times when the facility is open or choose
to construct a primary enclosure that will adequately contain the elephant.
— The public is permitted to walk directly up the primary enclosures containing several species of animals. This
includes camels, sheep, goats, muntjac deer, fallow deer, bongo, llama, giraffe, sitatunga, oryx, zebra, and kudo.
These animals are housed in the walk through area of the zoo which is open to the public. There are no barriers or
signs present to discourage public contact and the guests are encouraged to feed food sold at the entry gate and
coin feeders are located throughout the facility. Also, inspectors noted members of the public picking grass and
weeds from the facility grounds and feeding it to the giraffe. There are no attendants present during public contact
and guests may walk directly up to enclosures and pet the animals. Primary enclosure fences are made of material
with spaces large enough for the guests to reach through and touch the animals. Unattended public contact does
not ensure safe public interaction with these animals. Licensees must ensure that during periods of public exhibition
Prepared By:
Date:
12-SEP-2016
Title: ANIIKAM rAPP INJPPflTñR 1nwl
Received By:
(b)(6), (b)(7)(c)
Date:
Page 2 of 4
RCOLEMAN
2016082567919034 Inspid
Inspection Report
animals are handled with sufficient distance and/or barriers between the animal and the general viewing public so
as to assure the safety of animals and the public. Correct by placing barriers to prevent public contact with these
animals or by ensuring that an adequate number of attendants are present at each of these locations to ensure the
safetj/ of both the public and the animals.
Correct from this day forward
3.81 REPEAT
ENVIRONMENT ENHANCEMENT TO PROMOTE PSYCHOLOGICAL WELL-BEING.

*"* The current primate enhancement plan still does not address special considerations for nonhuman primates that
need special attention regarding environmental enhancement, such as nonhuman primates showing potential signs
of psychological distress through their behavior or appearance to ensure that their psychological needs are met. As
part of the plan for environment enhancement, the licensee must ensure that all nonhuman primates showing signs
of psychological distress through appearance or behavior are evaluated by a veterinarian and provided special
attention regarding the enhancement of their environment in addition to, taking into consideration the needs of the
individual species and in accordance with the instructions of the attending veterinarian. The facility must develop,
document, and follow an appropriate plan for the environment enhancement for these animals and any other
nonhuman primates requiring special considerations. No written changes to the plan have been documented.
3.125(a) REPEAT
"** The buried fence flooring for the African crested porcupine enclosure near the freezer has areas under both
shelters where the flooring has been significantly uncovered by the animals and/or the sand has eroded. This area
is in need of repair or replacement to ensure the animals are able to rest on a solid area not on wire and to avoid
potential injury to the animal feet/legs. The facility must ensure that all animal enclosures are maintained to
adequately contain the animals and protect them from injury.
3.127 REPEAT
FACILITIES, OUTDOOR.
***The facility was notified by APHIS in a letter dated January 21, 2016 that the variance for the perimeter fence
was rescinded. Currently, there is no perimeter fence for several animal enclosures including the breeding farm
area (specifically the zebra and camels), and the breeding muntjac, fallow deer, bongo, camels, zebra, kudu,
blesbCk, and portions of the giraffe and sitatunga at the main zoo.
Prepared By:
Date:
12-SEP-2016
Title: Anrito raPP INSPPCSI:11:2
Received By:
(b)(6), (b)(7)(c)
Date:
Page 3 of 4
RCOLEMAN
Animal and Plant Health Inspection Service 2016082567919034 Inspid
Inspection Report
"** Areas of the perimeter fence areas are impossible to inspect because it has been overgrown by brush. This
includes the west side of the facility and behind the fallow deer, bongo, and sitatunga enclosures. This area of
perimeter fence is not functional in its current condition. The licensee must ensure that no trees or brush are
affecting the structural strength or the ability to inspect the fence.
Failure to maintain a functional perimeter fence does not keep unwanted persons out or act as a secondary
containment for the animals. The licensee must conduct a thorough self-inspection of the entire perimeter to ensure
that all areas have an appropriate perimeter fence that is functional and complies with written requirements.
***Inspection conducted on August 9, 2016 with the licensee and other facility staff. Exit interview conducted with
the licensee on August 10, 2016. APHIS officials were Randy Coleman, ACI, Susanne Brunkhorst, VMO and two
representatives from USDA-APHIS Safety and Security Staff.
Elephant inspected: Asha
Susanne Brunkhorst, Veterinary Medical Officer
Prepared By:
Date:
12-SEP-2016
41\11MAI CAPP iniqPpr -rnp inkq
Title:
Received By:
(b)(6), (b)(7)(c)
Date:
Page 4 of 4
United States Department of Agriculture
USDA Animal and Rent Health Inspection Service 959151322400740
iccriamw
levee
inspection Report
Karl Mogensen
Neural Bridge Zoelogical Park Customer ID: 2468
Site: 001
NATuRAL BRIME 203

Date - Dec-15-2015
2.40 lb) 12) REPEAT

***Several animals were identified by APHIS personml to have excessive hair loss;
-One black female llama had areas ot hair loss over es shoulders and hips. the underlying skin had a normal
appearance.
-One female mandrill had areas of hair loss on her left forearm, extending from the &tow to her wrist and on her
right forearm just below the e1bow.
-One brown capuchin housed in the elephant barn had patchy hair loss on its back extending from the neck to the
base of the tail, Additionally, this animal was observed by APHIS personnel to excessively scratch his back.
-One brown capuchin housed in the mouse-house building, had hair loss on its tail extending from the base lo the
-Cine white-faced capuchin housed in the mouse-houee buildina, had areas of hair loss on its back, over its
shoulders extending into the fumbar region and at the base ol the tail.
From records supplied fc APHIS personnel, one capuchin known as Little Qin was evaluated on 52015 tor patchy,
unresoNed, chronic hair loss The records show a skm scrape and CBC,iChem were perierrned, however the results
of these diagnostics were not supplied to APHIS personnel nor noted in the records. Additionalfy, tere was no plan
for monitoring or treatment foe that animal. There were no records indicating the above five animals have been
evaluated by a veterinarian for their conditioe,
Excessive stretching. hair loss and over-grooming can be tial indicators ol underlying medital conditions or
psychological distress in anienaZ,
— One female camel was observed to have an abnormal right hind loot confirmation and an abnormal gait While
standing, the right hind boot had an abnormal angle, approximately 30 degrees to the ground, with the toes oft the
ground pointing in an upward direction. While ambulating, it was observed that the right hind fetlock joinl would
dip/sink further to the ground as compared to the lett, Additionally, the toe nails of the right hind foot were abnormally
shaped and long, possibly due to abnormal wear.
Abnormal feet gait and confirmations may be indicators of previous ancVor ongoing medical conditions.
RMIDALL COLEMAN., A C I
Prepared By:
RANDA L E COLEMAN, A C I USDA, API-HS, Animal Care Date:
Title: ANIMAL CARE INSPECTOR Inspector 1063 Dec-16-2015
Received Sy:
03)(6)..(b)(7)(c) Date:
Title: Dec-16-2015
Paw et 3
USDA Animal and Plant Health inspection Service
1034144A14
35015132240074D inepJcl
inspection Report
Depending on the cause. tnese conotors car he both progressive and painful,
The licensee must ha.1.6e the animals listed above exammed by a veterinarian to obtagi accurate diagnoses and
appropriate treatment plans for the issues cited above The outcome of this consultation must be provided to the
inspector upon request This documentation should include the vetennary diagnosis, all diagnostic tests and the
outcome of those tests that were performed by the veterinarian, any medications prescribed along with the dosing
instructions, and entries DTI a log andOr calendar andlor animal health record that list when the medication is
administered to the animals.
3,75
HOUSING FAC1UTIES, GENERAL.
— "Facility records indicate that Wally, a red-ruffed lemur, was able to get oct of the sheltered part of his enclosure
into the enclosed keeper common area. Daily keeper logs from 8/11/15 until 9323/15 state that Wally was still getting
out of his enclosure. On 923/15, the records state that Wally can no longer get out, as he is too big to in between the
enclosure mesh When asked what corrective action was taken to prevent the animal from gettirig out of his
encloSure. facility personnel stated nothing was done. The facility personnel stated they siniply wailed until he was
too big to get out The keeper area Wally gained access to contained open electrical outlets, extension cords, facility
heater and chemical% for cleaning. This area contained hazards that pose a risk of injury to the animal when he
gained access.
The facility must ensure that housing facilities tor nonhuman primates ere designed and constructed so that they
protect the animals from infury and contain the animals securely.
To be corrected by: 12117115
3.81 (c)
ENVIRONMENT ENHANCEMENT TO PROMOTE PSYCHOLOGICAL WELL-BEING.
The facility's current primate enhancement plan does not address special considerations for nonhuman primates
that need special attention regarding environmental enhancement, suCh as nonhuman primates showing potential
signs of psychological distress through their behavior or appearance to ensure Mal their psychological needs are
met.
APHIS personnel observed one female Mandrill which appeared to be in distress. The female was observed to pace
around her enclosure. uying to avoid the male she is housed with. APHIS personnel also noted the mandrill
enclosure Contained minimal enrichment (only two bamboo shoots and one PVC toy). APHIS personnel also
observed one while-laced capuchin cribbing el its enclosure on a den box. abaviors of the mandrill and capuchin, in
addition to several nonhuman primates that have excessive hair loss, may be indicators of psychological distress.
As part of the facility s plan for environment enhancement, the licensee must ensure that all nonhuman primates
showing signs of psychological distress through appearance or behavior are evaluated by a veterinarian and provided
special attention regarding the enhancement of their environment in addition to, taking into consideration Me needs of
the individual species and in accordance with the instructions of the attending veterinarian. The facility must develop,
document, and lollow an appropriate plan for the
FL4NDALL COLEMAN.. A C I
RANDALL E COLEMAN, A C I USDA, APHIS, Animal Care Date:
Title: ANIMAL CARE INSPECTOR Inspector 1063 Dec-16-2015
Received 8y:
ap)(6),(b)(7)(2) Date:
Title: Dec-16-2015
Paw 2 or 3
United States Department of Agricutkre FiC0.114414
Animal and Plant Health Inspection Service 350151322401740 Inep jci
inspection Report
environment enhancement for these animals and any ether nonhuman primates requiring special considerations,
To be corrected by: 1217,15
3.125 lc) REPEAT

FACILMES, GENERAL
*** The flbor of the welkin freezer used to store meat to feed the animals is difty and there* ice accumulating on the
floor under the tan in the rear of Ihe freezer_ The floor has several areas of blood that has dripped onto the floor and
is now frozen. A plastic tub has been placed under The fan to collect water dripping from this fan. There Is a carcass
of a calf uncovered in a bin and also lhe hind legs of a carcass protruding from a bag CX1 a shelf, This freezer
requires a thorough cleaning and the leak repaired. Addlionally, ail frozen food must be wrapped or stored in closed
containers to protect the food supplies from deterioration, contamination, and freezer burn,
3.127 Id) REPEAT

FACILITIES, OUTDOOR,
"" Several areas of the perimeter fence have trees growing through the fence or areas that are impossible to inspect
because if has been overgrown by brush. This includes the southeast corner of the facility near Ihe vehicte gate, and
behind the fallow deer, bongo, and sitalunga enclosures. The perlrnotel fence is not functional in its cunont
condition, The licensee must ensure that no trees or brush is affecting the structural strength or the ability to inspect
the fence. Failure to maintain a functional perimeter fence does not keep unwanted persons out or act as a
secondary containment for the animal& The licensee must conduct a thorough self-inspecten of the entire perimeter
to ensure that all areas of perimeter fence are functional and comply with written requirements.
"'The facility is currently closed for the season so APHIS personnel were unable to determine to adequacy of the
ele0ant enclmure barriers and the presenceiabsonce of an attendant during periods of public exhibition.
— All animals cited kinder' 2.40(113)I21 Qn the inspection report dated Mey 19, 2015 have been addressed by the facility
and the attending voterinartan.
This inspection was conducted uri Deoamber 15 and 16, 2015 with the licensee and several facility
representatives as well as Animal Care staff ACI Randall Coleman VMO Aaron Rhyner, Director Robert Gibbens,
representatives frem USDA-APHIS Safety and Security, and two local sheriff deputies.
A formal exit interview was conducted with the licensee On December 16, 2015,
Prepared By:
RANDALL E COLEMAN, A C I USDA, API-HS, Animal Car Date:
Title: ANIMAL CARE INSPECTOFI Inspector 1063 Dec16-2015
Received 6yt
(Li)(6),(b)(7)(c) Date:
Title: Dec-16-20 5
Paw 3 Of :3
USDA Animal and Plant Health Inspection Service 141150851070383
SBRUNKHORST
insp_id
Inspection Report
Karl Mogensen
Natural Bridge Zoological Park Customer ID: 2468
Site: 001
NATURAL BRIDGE ZOO

Date: May-19-2015
2.40 (b) (2) REPEAT

*All four feet of the female African elephant, Asha, are in need of foot care and trimming. All four feet show excessive
pad overgrowth with built up areas and flaps present that can allow foreign objects to lodge under them and penetrate
the sole. One nail on the left front foot appears chipped/broken. The elephant keeper reported that this occurred
recently on a rock and that he is addressing this nail. Several other nails appear long and irregular in shape. Toenails
need to be trimmed so that the elephant is not putting weight or pressure on the nails. The keeper indicated that he
does footwork only as needed and does not currently have a routine footcare program in place. No documentation of
footcare was available for review.
The skin of the female African elephant, Asha, appears dry and thickened with a cracked looking appearance
especially over her back and on her head. The keeper indicated that he does do baths with water and uses a small
wire brush on her skin occasionally. There is a container of Zafari, commonly used to bathe elephants with dry skin,
present at the facility but the amount of dirt on the container and the difficulty of opening the lid indicate that it has not
been used recently or regularly. The elephant enclosure does not have a pond or pool available for her to soak in.
Healthy skin and feet are important to the overall health of the elephant.
The feet and skin of the elephant Asha should be evaluated by a veterinarian and a written foot and skin care
maintenance program needs to be established by June 21, 2015. The program shall meet current professionally
accepted standards. Ongoing maintenance of the feet and skin of the elephant should be documented and available
for inspection.
*The approximately 15 year old male serval appears thin. The serval has a tucked up/tucked in appearance with the
vertebral bodies (spine) and hip bones slightly showing. His cheek/face bone structure also appears more
pronounced than normal. The facility representative stated that he has been like this for a while and that they are
feeding him more than the other serval. There is no documentation available to show that the attending veterinarian
was contacted to evaluate the serval prior to the start of this inspection.
Prepared By:
SUSANNE BRUNKHORST, V M 0 USDA, APHIS, Animal Care Date:
Title: VETERINARY MEDICAL OFFICER Inspector 1076 May-22-2015
Received By:
KARL MOGENSEN Date:
Title: FACILITY REPRESENTATIVE May-22-2015
Page 1 of 6
USDA Animal and Plant Health Inspection Service 141150851070383
SBRUNKHORST
insp_id
Inspection Report
Loss of weight can be associated with old age however it can also be an indication of illness, disease, or nutritional
imbalance.
The facility needs to have the serval evaluated by a veterinarian and a medical workup done to determine if there is
an underlying cause and to determine the best feeding/nutritional plan for this animal. A licensed veterinarian met
with APHIS officials during the inspection process on May 20, 2015 and stated that she had just looked at the serval
and was establishing a veterinary care plan for him.
This is a repeat non-compliant item based on section and subsection numbers. All veterinary care issues cited under
this section and subsection on the March 10, 2015 inspection report have been addressed. Newly identified issues
shall be addressed as indicated above.
2.131 (e)
' 10 rabbits are being housed in the 3 enclosures on the porch by the keeper building. An adult female is housed in
a metal water trough with 3 nursing young (kits). Two adult rabbits are being housed in a second metal water trough.
Four juvenile rabbits are housed in an elevated enclosure with wire walls and flooring. The temperature at 4 pm
ranged from 85 to 87 degrees inside and near the enclosures. The adult female with kits was lying elongated along
the edge of the metal trough and was panting. In addition, her 3 young had spread themselves apart in the nest area
in an attempt to stay cool. The two adult rabbits in the second metal trough were lying along the edge of the trough,
had elongated their bodies, and pushed the wood shavings away from them in an attempt to stay cool. One of the
juvenile rabbits in the third enclosure had moved to lay next to the water receptacle and the other three were still
slightly huddled together. They had mildly increased breathing rates. The three adult rabbits and the kits are showing
signs of heat stress by panting, elongating their bodies, and/or attempting to move away from each other. All animals
must not be subjected to conditions of temperature, humidity, and time that are detrimental to the animals' health.
The licensee must correct this by providing these animals with cooler conditions (for example, provide ventilation,
misters, moving the animals to a cooler area of the facility, etc). This was first identified by inspectors and reported to
the licensee on May 19, 2015.
"** NOTE: The licensee corrected this by May 20, 2015 at 9 am.
3.75 (c) (1) (i) REPEAT

*** There are two primate enclosures that are severely rusted. One enclosure, housing two De Brazza 's monkeys, is
located within the Keeper building . The metal frame of this enclosure and the guillotine style door are severely rusted.
The second primate enclosure, housing two De Brazza' s monkeys, is located within the mouse house building . The
metal frame of this enclosure is severely rusted. The rusted areas, in both of these enclosures, are in contact with the
primates and are pitted and flaking.
Excessive rust can affect the structural strength of surfaces and prevents the required cleaning and
Prepared By:
Received By:
KARL MOGENSEN Date:
Page 2 of 6
USDA Animal and Plant Health Inspection Service
SBRUNKHORST
141150851070383 insp_id
Inspection Report
sanitization of enclosures.
Any surface that comes in contact with the nonhuman primates must be free of excessive rust that prevents the
required cleaning and sanitization, or that affects the structural strength of the surface. Correct by ensuring that all
rusted enclosures and any rusted surfaces that are in contact with the primates are repaired or replaced to ensure
structural strength and to allow them to be readily cleaned and sanitized.
3.77 (a)
SHELTERED HOUSING FACILITIES.
The sheltered mandrill building, housing five mandrills, is not sufficiently cooled within the sheltered portion of the
housing facility. The temperature within the indoor portion of the mandrill building at 1:50 pm on Tuesday May 19th
was 91.3 degrees Fahrenheit. The temperature at 3:47 pm on the same day was 90.1 degrees Fahrenheit. The
inspectors felt hot and were sweating within the building. There is no auxiliary ventilation within this building (fans,
open windows, air conditioning units, etc). A facility representative stated that they leave the door open to provide air
flow within the building. There are two separate enclosures within this building. One enclosure, housing three
primates had access to the outdoor portion of the sheltered housing facility. Two mandrills in the second enclosure
were locked in and had no access to the outdoor portion of the housing facility. The facility representative stated that
the two groups of animals are allowed access to the outdoor portion of the housing facility on alternating days.
According to the National Weather Service/NOAA Website, the high for the day in Roanoke, VA was 87 degrees at
approximately 4:00 pm. The minimum temperature for the day was 67 degrees and occurred prior to 7:00 am.
Exposure to excessive heat can lead to heat stress or other veterinary medical conditions and creates an
uncomfortable environment for the primates.
The sheltered portion of the sheltered housing facility must be sufficiently cooled (and heated when necessary) to
protect the nonhuman primates from temperature extremes, and to provide for their health and well-being. The
ambient temperature in the sheltered part of the facility must not rise above 85 degrees Fahrenheit for more than 4
consecutive hours unless temperatures above 85 degrees Fahrenheit are approved by the attending veterinarian and
are in accordance with generally accepted husbandry practices. Correct by ensuring that the ambient temperature is
maintained at a level that ensures the health and well-being of the species housed, as directed by the veterinarian, in
accordance with generally accepted professional and husbandry practices and does not rise above 85 degrees
Fahrenheit for more than four consecutive hours.
To be corrected by: May 24th, 2015
Prepared By: t \

Received By:
KARL MOGENSEN Date:
Page 3 of 6
SBRUNKHORST
141150851070383 insp_id
Inspection Report
3.125 (a) REPEAT

*" A portion of the primary enclosure fencing for the pigs is made of movable metal livestock fence panels with
horizontal bars. The spacing of the bars is large enough at the bottom that the smallest piglets in the enclosure are
able to escape from the enclosure if they were motivated to do so. Additionally, the area where the sections of metal
panels are connected has areas large enough for the piglets to get through. This area is in need of repair or
replacement as it is a potential escape risk. The facility must ensure that all animal enclosures are maintained to
adequately contain the animals and protect them from injury.
3.129 (a)
FEEDING.
The facility 's current program for hand rearing tiger cubs is not adequate. Four tiger cubs were born on 9 April 2015
and were removed from the dam within one hour of birth. Each cub was fed reconstituted commercially available
cattle colostrum (Bovine IgG Calf' s Choice Total) for the first two days before being transitioned to formula. The
facility is currently using Fox Valley Day One 32/40 Formula to comprise the bulk of the cub diet. Directions on the
formula recommend reconstitution by mixing 1 part powder to 2 parts water. The keeper responsible for care of the
tiger cubs stated that the formula is currently being made by mixing 1/4 cup of formula powder with 1/4 cup goat 's
milk and then diluting the mixture to approximately 1000 ml with water. This represents approximately a 1:15 dilution
of formula (seven and a half times more dilute than recommended) with the small addition of goats milk. Formula is
refrigerated until feeding at which time it is transferred to a bottle which is then microwaved for approximately one
minute to warm. Currently the facility is feeding dilute formula ad libitum 4 - 5 times per day. The feeding plan states
that meat is added to the formula diet at 8 weeks of age. When meat is introduced, the current diet plan calls for a
small amount of Feline T-Oasis Vitamin supplement to be sprinkled on beef. According to the keeper, there are no
other dietary supplements given prior to feeding meat.
One tiger cub remains at the facility at this time. In the week preceding inspection, facility records indicate the cub
had an average weight of 4.6 kg (10 lbs) and consumed a daily average of over 2 liters of dilute formula. Based on
expected nutritional intake, this cub is currently consuming approximately 30% less than required. In order to take in
enough nutrition a cub of this size would need to consume approximately 3 liters of dilute formula/goat milk mix per
day. At the time of inspection this cub was bright and alert but had a rough hair coat, a prominent pelvis, and a pot-
bellied appearance.
The current feeding practices in use by the facility are not appropriate for the age, species and size of this animal.
Bovine colostrum has not been demonstrated to provide immune protection to exotic felines such as tigers and the
facility is not currently addressing passive transfer of immunity to the cubs in any other manner. Failure to ensure
that cubs receive adequate immunity from their dam or an alternate source places cubs at increased risk of disease.
Prepared By:
Received By:
KARL MOGENSEN Date:
Page 4 of 6
SBRUNKHORST
141150851070383 insp Id
Inspection Report
The extreme dilution of the formula by the facility requires the cub to drink an excessive volume of dilute
formula/goat's milk mix and therefore, as it is currently being prepared, is not of sufficient nutritive value to
appropriately maintain the health and allow for normal growth of this cub. Additionally, microwaving formula for
excessive periods of time is not consistent with the manufacturer's recommendations for preparing the formula. This
may lead to additional health complications.
Although meat is not currently being added to the diet, the approved feeding plan fails to provide specific guidance
regarding measuring the amount of supplement (Feline T-Oasis Vitamin supplement) and meat to which it is added
and is therefore inconsistent with manufacturer 's recommendations. Failure to properly supplement meat fed to
growing cubs may lead to health complications such as the development of metabolic bone disease. Additionally,
the accepted industry standard includes introduction of meat products as early as 2-3 weeks old (added to the
formula) and a gradual increase in meat consumption until weaning.
Correction of this noncompliance shall involve three steps. First, the facility must contact the attending veterinarian to
develop a plan for this cub to immediately transition her to a diet that is wholesome, palatable and of sufficient
nutritive value. Complete by 5:00 pm on 23 May 2015. Second, a cub feeding plan which meets all nutritional needs
for cubs throughout all their growth stages and meets currently accepted industry standards must be developed and
approved by the attending veterinarian no later than 30 May 2015. Third, the facility must seek guidance from the
attending veterinarian regarding developing a hand rearing protocol for tigers that is in accordance with generally
accepted industry standards for all aspects of care prior to any future hand rearing of tiger cubs.
3.131 (a) REPEAT

SANITATION.
The shelter for the 4 bongo requires cleaning. The bedding inside the shelter has accumulated to at least 2 feet
deep. In addition, there are numerous flies around the shelter and the animals, especially near the shelter entrance.
The facility must ensure that animal enclosures are cleaned on a regular basis and that excreta is removed from
primary enclosures as often as necessary to prevent contamination of the animals and minimize disease hazards,
odors, and pests. Correct by cleaning and maintaining this and all enclosures on a regular basis.
3.131 (c) REPEAT

SANITATION.
At least 75% of the muntjac enclosure is overgrown with knee high grass and weeds. The licensee 's wife stated
that they normally mow approximately half of the enclosure while leaving the rest of the enclosure longer to allow the
muntjac a place to hide and bed down if they choose. The facility must, however, ensure that the grasses and weeds
are controlled to allow them to observe the animals daily, monitor for pests, and remove animal waste as needed.
Correct this by trimming and maintaining weeds and grasses in this and all animal enclosures.
,-
Prepared By: ..
Received By:
KARL MOGENSEN Date:
Page 5 of 6
SBRUNKHORST
141150851070383 inspid
Inspection Report
All veterinary care citations from the March 10, 2015 inspection report have been addressed by the facility and the
attending veterinarian.
"** This inspection was conducted on May 19 and 20, 2015 with the licensee, the wife of the licensee, and several
facility representatives as well as staff from the Virginia Department of Game and Inland Fisheries, and multiple staff
representing the USDA-APHIS-Animal Care including: VMO Heather Cole, SACS Dana M. Miller, ACI Randall
Coleman, and VMO Susanne Brunkhorst.
***A formal exit interview was conducted with the licensee, his wife, licensee's attorney (for a portion of exit) and the
above listed APHIS Officials on May 22, 2015.
Prepared By:
SUSANNE BRUNKHORST, \-/MOL
USDA ,-)‘/
:IS, Animal Care Date:
Received By:
KARL MOGENSEN Date:
Page 6 of 6
Exhibit D
Report of Toni Frohoff, Ph.D.
Overview of a Preliminary Assessment of
Asha, a Solitary African Elephant at Natural Bridge Zoo
3/19/2018
Toni Frohoff, Ph.D., Wildlife Behavioral Biologist and Elephant Scientist for
In Defense of Animals.
I hAvP An M.c.in Wilinifp n d Fiqhprieq SrienrPc and A ph.n. in Wildlifp Rehavinral RinIngy
from Texas A&M University. I have specialized in the study of welfare of mammals,
particularly whales, dolphins and elephants, for over thirty years and have conducted
numerous captive-display facility assessments for government agencies and nonprofit
animal protection organizations nationally and internationally. I have also contributed to
research on elephants and other animals in the wild and have published extensively for the
public and in scientific fora, including encyclopedia entries on animal welfare. I have also
been a member of various U.S. and government task-forces and committees, including the
U.S. Fish and Wildlife Service, Washington Department of Fish and Wildlife, and the U.S.
National Marine Fisheries Service.
Overview
This is a summary of a preliminary assessment of Asha, a female, wild-caught, African
elephant of approximately 35-years of age based primarily on observable photographic and
video documentation of her enclosure, behavior, and treatment by her owner, Karl
Mogensen. I have also reviewed the available U.S. Department of Wildlife (USDA) Animal
Welfare (AWA) records of investigations and violations.
Based on the staggering number and dangerous nature of the violations for which Natural
Bridge Zoo has been cited over the years, some of which appear to repeatedly reoccur
and/or persist, combined with the solitary confinement of Asha relative to conspecifics for
roughly a decade, I strongly urge and recommend the immediate confiscation of this
elephant and transfer to one of the two certified elephant sanctuaries in the U.S. It is in one
of these sanctuaries where she can be most assured of receiving the medical treatment and
social and environmental provisions she needs, particularly given the poor conditions
under which she has been forced to live for more than three decades.
Lack of accessibility to thoroughly assess Asha's physical condition, enclosure, and

treatment has severely limited my ability to provide a comprehensive assessment
(especially since she was last observable in 2017). Yet some of the problems concerning
Asha's care on which I base my conclusions have already been noted and/or cited by the
USDA as violations. From the records that are publicly available and photographic and
video evidence, it is clear that the living environment and management of Asha the
elephant at Natural Bridge Zoo falls far below acceptable standards and is seriously
adversely impacting Asha's welfare, as well as placing the public at unnecessary and
excessive risk. This assessment, which is not intended to be comprehensive, summarizes
highlights of the most notable points given current constraints.
1
Elephant Welfare
Isolation from Conspecifics: There are many indicators of compromised welfare to Asha but
perhaps the most overt is that this elephant is alone and isolated from conspecifics. For a
female African elephant that has evolved to maintain exceptionally close and lifelong bonds
with other elephants, social isolation is an extreme and particularly devastating form of
cruelty and deprivation.
The scientific literature is replete with reference to the social companionship with other
elephants in captivity as a fundamental need vital to their psychological wellbeing and
genetic behavioral expression; especially for female elephants. As noted by two of the
foremost scientific elephant researchers Joyce Pool and Cynthia Moss, perhaps the most
critical source of stimuli for an elephant is the presence of conspecifics (2008). A review
determined that "The affinity for gregariousness - being with other elephants - is a basic
elephant "need." (Lee and Moss, 2009, pg. 31). In 2016, the American Zoological
Association's (AZA) own study found social aspects of elephant lives to be of paramount
importance to their wellbeing.
I note that Natural Bridge Zoo would not qualify for AZA accreditation as the AZA has more
respected, professional and humane criteria than does the association under which it is
accredited, the Zoological Association of America (ZAA). The ZAA accredits private
menageries, roadside and traveling "zoos" and promotes private ownership of wild, exotic
animals. But to further underscore why Asha's restriction from conspecifics is so blatantly
inhumane and cruel, AZA Standards of Elephant Management and Care related to elephant
sociality are listed here: (underlined for emphasis)
2.2 Social Considerations, 2.2.1 Group Composition, .2.1.1 Suggested age and sex structure of social group.
Standard: Each zoo holding elephants must hold a minimum of three females (or the space to hold
three females), two males or three elephants of mixed gender. [Underlined for emphasis]
3.3.1.1 Problems arising from isolation of social taxa

Standard: Every institution should have the ability to introduce, manage and maintain social groupings of
elephants.
Explanation: As a highly social species, female elephants must be returned to their social group as soon as possible.
Although interaction between elephant care staff and elephants can be beneficial, they are not a sufficient substitute
for species-appropriate elephant-to-elephant interactions. [Underlined for emphasis].
It is my professional opinion that forcing Asha to live alone and isolated from all tactile,
olfactory, visual and auditory interactions from other elephants is excessively cruel and
inhumane measured against modern-day and reasonably respectable professional
standards for elephant care. The chronically harmful impacts of social isolation for
elephants manifest in chronic psychological distress as well as stress-related behaviors,
physical ailments and diseases.
Lack of Adequate Shelter from Sunlight: My understanding is that Asha has been forced to
give rides to passengers in extremely high temperatures without adequate shelter from
sunlight. This would violate the following USDA Animal Welfare Act standards (from
2
https ://www. aphi s. usda.gov/anim al welfare/downloads/AC B lueB ook AWA FINAL 2017 508cornp.pdf):
§ 3.127 - Facilities, outdoor

(a) Shelter from sunlight. When sunlight is likely to cause overheating or discomfort of the animals, sufficient shade
by natural or artificial means shall be provided to allow all animals kept outdoors to protect themselves from direct
sunlight.
Lack of Appropriate Enrichment: Based on my observation of photos and videos, the

relative paucity of behavioral/psychological enrichment opportunities available to Asha,
especially given her solitary (relative to conspecifics) confinement, appears to be
inexcusably deficient.
AZA Elephant Care Manual
2.1.1.5 Provision of opportunities for elephants to process food in ways similar to their wild
counterparts and mechanisms that enable animals to work for food
Standard: Opportunities must be provided for elephants to acquire food using multiple foraging
behaviors.
Measurement: Written feeding and enrichment protocols must be maintained. Explanation: Opportunities for
searching, browsing, grazing, reaching, opening, etc. can be provided by scatter-feeding, hiding foods in crevices
and substrates around the exhibit, or by using_elevated feeders such as hanging hay nets that encourage an elephant
to reach for and manipulate its trunk to gain access to the food. [Underlined for emphasis]. Mechanisms that
promote physically active feeding behaviors can be incorporated into a comprehensive enrichment plan for the
elephants.
Direct Physical Health Impacts
Although I have only been provided with limited details of the barn in which Asha is
housed, the available information raises serious questions of whether the barn is suitably
heated and insulated - and whether appropriate substrate and space is provided for the
elephant for standing. walking. and sleeping.
Elephants who are kept in a small enclosures are in increased danger of developing chronic
foot disease and arthritis, both of which lead to frequent instances of death for captive
elephants. In fact, the most common reason for premature death of captive elephants is
lack of space and standing on hard and/or otherwise inappropriate surfaces.
All of these aspects of the enclosure are of exceptional importance for Asha given:
a) The unusually extensive amount of time Asha is forced to remain inside the barn due to
the unusually cold and long winters in this region of Virginia, especially relative to the
much warmer and more temperate weather to which African elephants have adapted for
millennia;
b) Asha being confined alone eliminates any opportunity for her to obtain heat or physical
comfort (let alone psychological comfort) through physical proximity or tactile interaction
with other elephants; and
c) Asha's solitary existence in the barn likely predisposes her to being even more sedentary
than if she were confined with a conspecific which contributes Asha's being excessively
3
susceptible to physical ailments and diseases involving extreme pain and possibly,
eventually death.
I was not able to assess the physical condition of Asha, yet because of her highly unusual
circumstances, I strongly recommend that a skilled veterinarian who can be objective and
is, in no way, affiliated with the facility or the owner, be invited to give Asha a thorough
health exam. It is well established that elephants in captivity require careful and vigilant
monitoring and management of the condition and health of their feet; especially the pads
and nails. Lack of physical conditioning, including obesity, is another contributing threat to
the health and wellbeing of captive elephants. Being confined within a barn for extended
periods with months without exercise, and being forced to stand on hard or otherwise
inappropriate surfaces that harm the feet and joints of elephants are recognized causes of
captivity-related pain, illness and early mortality.
Public Safety and Elephant Safety
Unnecessary and High-Risk Interaction with the Public: Mr. Mogensen puts the public at
risk of injury or death from excessive physical proximity and contact with Asha and by
offering interactive programs, including elephant rides. I offer just a few examples of this
starting with the fact that zoonotic transmission of Tuberculosis and other diseases
between humans and elephants (and visa versa) is common. Also, given the multitude of
instances in which elephants have injured and killed their keepers and members of the
public, offering elephant rides is putting the public at unnecessary and excessive risk. All
elephants, no matter how well trained, are wild animals and are not to be expect to conduct
themselves as domesticated animals.
Accordingly, the following USDA AWA standards:

§ 2.131(c)(1) "During public exhibition, any animal must be handled so there is minimal risk of harm to the animal
and to the public, with sufficient distance and/or barriers between the animal and the general viewing public so as to
assure the safety of animals and the public."
An additional problem lies with Mr. Mogensen's observed use of a bullhook (or similar
stick) to coerce Asha to give rides to the public. The bullhook is an instrument used
physically and psychologically to apply negative stimuli and has either been legislatively
banned in various regions of the U.S. (including Richmond, VA) or has been intentionally
phased out by most zoos and replaced by the more effective and safe procedure of
protected contact (see:
https://www.speakcdn.com/assets/2332/maxirnizing occupational safety of elephant care jprofessionals). The
application of the bullhook is an outdated mode of punitive stimuli that has been related to
elephants and other animals reacting with fear, aggression, and with displaced aggression
(either to another animal or to proximal humans). This is yet another example of outmoded
elephant husbandry methods, and in my professional opinion, poses an excessive public
safety risk.
4
Inadequate Fencing: Unless substantial changes were made, it would appear that the
fencing around the perimeter is inadequate to safely maintain Asha per USDA Animal
Welfare Act requirements:
§ 3.127 - Facilities, outdoor
(d) Perimeter fence. On or after May 17, 2000, all outdoor housing facilities (i.e., facilities not entirely indoors) must
be enclosed by a perimeter fence that is of sufficient height to keep animals and unauthorized persons out. Fences
less than 8 feet high for potentially dangerous animals, such as, but not limited to, large felines (e.g., lions, tigers,
leopards, cougars, etc.), bears, wolves, rhinoceros, and elephants, or less than 6 feet high for other animals must be
approved in writing by the Administrator. The fence must be constructed so that it protects the animals in the facility
by restricting animals and unauthorized persons from going through it or under it.
Virginia Zoo in Norfolk is an example of changing standards for the care of elephants. The
Zoo's media release stated that the Virginia Zoo was "Committed to doing what is best for
the Zoo's elephants". The Zoo closed its elephant exhibit in 2016 and relocated the two
remaining female elephants, to what they described as a warmer and more suitable
climate with more opportunities for social choice and engagement. The Zoo stated the
following: "Studies of elephants in the wild show that female elephants are very social and
naturally live in multigenerational herds with matriarchal leaders. Research in the past
decade and more recently has compelled the AZA leadership, elephant holding institutions,
and elephant care staff to put forth a requirement that by 2016 zoos must maintain
elephant herds with three or more members in order to maintain the complex social and
psychological health of the animals." http://virginiazoo.org/wp-
content/uploads/2015/11/Virginia-Zoo-Elephant-Relocation-Press-Release.pdf
Conclusions
For the reasons discussed above, I make the following recommendations:

It is my professional opinion that Asha the elephant is enduring excessively cruel and
inhumane treatment and conditions as measured against modern-day and reasonably
respectable professional standards for elephant care. Based on the staggering number and
dangerous nature of the violations for which Natural Bridge Zoo has been cited over the
years, (some of which appear to repeatedly reoccur and/or persist), combined with the
solitary confinement of Asha relative to conspecifics for roughly a decade, I strongly
recommend the immediate confiscation of this elephant and transfer to one of the
two certified elephant sanctuaries in the U.S. It is in one of these sanctuaries where she
can be most assured of receiving the medical treatment and social and environmental
provisions she needs, particularly given the poor conditions under which she has been
forced to live for more than three decades.
References
American Zoological Association Standards for Elephant Management and Care. Approved
March 2011, Revised April 2012
American Zoological Association, 2016. Maximizing Occupational Safety of Elephant Care
Professionals At AZA-accredited and AZA-certified Facilities.
5
https://www.speakcdn.com/assets/2332/maximizing_occupational_safety_of elephant_ca
re_professionals.pdf
Greco, B. J., Meehan, C. L., Miller, L. J., Shepherdson, D. J., Morfeld, K. A., Andrews, J., ...
Mench, J. A. 2016. Elephant Management in North American Zoos: Environmental
Enrichment, Feeding, Exercise, and Training. PLoS ONE, 11(7), e0152490.
http://doi.org/10.1371/journal.pone.0152490
Lee, P.C. and Moss, C.J. 2009. Welfare and Wellbeing of Captive Elephants: Perspectives
from Wild Elephant Life Histories. Pages 22-38 in An Elephant in the Room: The Science
and Well-Being of Elephants in Captivity (Eds. D.L Forthman, L.F. Iane, D. Hancocks, and
P.F. Waldau. Tufts University Center for Animals and Public Policy., Grafton, MA.
Poole, J.H., and Moss, C.J. 2008. Elephant sociality and complexity. Pp. 69-98 in Wemmer, C.
and K. Christen (eds.) Never Forgetting: Elephants, Ecology and Ethics. Baltimore, MD:
Johns Hopkins University Press.
United States Department of Agriculture (USDA). 2017. Animal Welfare Act and Animal
Welfare Regulations. Animal and Plant Health Inspection Service, January 2017.
https://www.aphis.usda.gov/animal_welfare/downloads/AC_BlueBook_AWA_FINAL_2017
508comp.pdf
6
Exhibit E
AWA Violations
AWA VIOLATIONS
Since the January 13, 1994 APHIS NEWS bulletin (and the date of the first
record The Coalition is currently in possession of) Mogensen has habitually and willfully
violated the AWA amassing countless violations since that time. Many of these citations
were for repeat violations continuing for almost a quarter of a century. Violations
identified by the USDA inspectors included but were not limited to the following:
• Failure to provide adequate veterinary care and an attending veterinarian 9
C.F.R. § 2.40(a)(2) and 9 C.F.R. § 2.40(b)(2)
• Failure to provide adequate space for normal postural adjustments and freedom
of movement, Repeat violations 9 C.F.R. § 3.128;
• Failure to adequately supervise Asha 9 C.F.R. § 2.131 (d)(1), and § 2.131
(d)(2);
• Failure to provide adequate barriers at the home facility 9 C.F.R.§ 3.127(d);
• Failure to provide sufficient and adequate food, and prevent contamination of
food, AWA §3.129(a);
• Failure to keep required records and make them available for inspection, 9
C.F.R. § 2.126;
• Failure to keep enclosures and facility ground clean, 9 C.F.R. § 3.131(a) and §
3.131(c)
• Improper handling of animals 9 C.F.R. § 2.131(c)(1)
• Inadequate Housing Facilities, General 9 C.F.R. §3.75(a)
• Improper primary enclosures 9 C.F.R. §3.80(b)(2)(1)
• Inadequate facilities, General 9 C.F.R. §3.125(a)
• Inadequate facilities, Outdoor 9 C.F.R. §2.127(d)
• Improper sanitation 9 C.F.R. § 3.131(d)
• Improper housing facilities, Indoor 9 C.F.R. §3.76(b)
• Failure to provide environment enhancement to promote
psychological wellbeing 9 C.F.R. § 3.81
• Improper sheltered housing facilities 9 C.F.R. §3.77(a)
• Improper feeding 9 C.F.R. §3.129(a)
Exhibit F
NBZ Brochure
TN's. your ,thance
cudaa 0Ae of thése'
Cann cots!
Pictures with baby tigers are available on weekends'

As always, the proceeds from
ALL photo shoots will
go directly to improving
the habitats for our
wonderful animals.
op feamres unique wildlife the

aro d, souvenir aefalt
ens t slurts, toys, plush
•
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Exhibit G
Email Regarding Dual Authority
Temkin, Debbie
From: Husband, Jim (DGIF)

Sent: Wednesday, September 09, 2015 3:40 PM
To: Whitehurst, David (DGIF); Trollinger, Jeff (DGIF); Brown, Ryan (DGIF); Henry, Ron (DGIF)
Subject: FW: Natural Bridge Zoo - Non-inspection
Attachments: Memo of non inspection walk through NBZ 06232015.pdf
No action required at this time
From: Miller, Dana - APHIS [mailto:Dana.Miller©aphis.usda.gov ]

Sent: Wednesday, September 09, 2015 3:19 PM
To: Husband, Jim (DGIF)
Cc: Welch, K. Michelle; Hull, Matthew R. (MHull@oag.state.va.us ); Kirchgessner, Megan (DGIF)
Subject: Natural Bridge Zoo - Non-inspection
Jim (and all),
Following our last inspection in May at the NBZ I know you are aware, we had significant concerns about the tiger
cub. As I'm sure you know feeding problems especially in these young exotic species that are being hand-reared can
become significant welfare concerns quickly. For big cats in particular we often see problems with metabolic bone
disease and vitamin A deficiency if they aren't properly supplemented during weaning. Because of those significant
concerns, I talked at length with one of the facility's veterinarians about hand-rearing to help them get set on the right
path, but we still wanted to check up on the cub quickly. I did send two inspectors back to the facility in June in hopes
of evaluating the facility's changes to the cub rearing program. Unfortunately, we were unable to complete an
inspection since we didn't have security support at that time.
Since our inspectors couldn't identify themselves, they did pay admission and walk through the park to see what they
could observe without a full inspection. Fortunately they were able to observe the cub who appeared ok at that
time. The inspectors did observe several other possible non-compliances that I thought you might be interested in as
well specifically with regards to the public feeding / barriers and the elephant enclosure. For our own internal purposes
I asked them to document their observations in a memo. Since you have dual regulatory authority I did want to also
share that memo with you. Please be aware that these findings were not shared with the facility since there was no
formal inspection. These are all issues that will be followed up on at the next inspection to determine compliance with
the AWA at that time. Please let me know if you have any questions about this document as well.
Thanks,
Dana.
Dana M. Miller, DVM

Supervisory Animal Care Specialist
USDA, APHIS, Animal Care
Cell: 317-771-6208

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1r ( -

THE AMIIAL DEFENSE PARTNER1:11f)

David Ebert • Co-Founder

March 28, 2018

By Overnight Mail and Email

Virginia Department of Game and Inland Fisheries

Dear Messrs. Duncan, Martel, Whitehurst and Major Naff:

The Animal Defense Partnership, Inc.

The Animal Defense Partnership, Inc.

NBZ and Mogensen's Continuing Abject Abuse and Neglect of Asha

Here is what is currently known about Asha's current conditions:

• Unheated or inadequately heated Metal 50' x 56' barn

• No shade even while giving rides in extreme heat

• Rides Tues-Sun 6 days a week

The Animal Defense Partnership, Inc.

Attached as Exhibit D is a preliminary assessment by Toni Frohoff, Ph.D., a leading wildlife

The Applicable Virginia Statutes

§ 3.2-6503. Care of companion animals by owner; penalty

A. Each owner shall provide for each of his companion animals:

The Animal Defense Partnership, Inc.

3. Adequate shelter that is properly cleaned;

6. Adequate care, treatment, and transportation; and

7. Veterinary care when needed to prevent suffering or disease transmission.

B. Violation of this section is a Class 4 misdemeanor. A second or subsequent

§ 3.2-6570. Cruelty to animals; penalty.

A. Any person who: (i) overrides, overdrives, overloads, tortures, ill-treats,

The Animal Defense Partnership, Inc.

mutilates, or kills any animal, whether belonging to himself or another; (ii)

§ 3.2-6569. Seizure and impoundment of animals; notice and hearing; disposition

A. Any humane investigator, law-enforcement officer or animal control officer may

The Animal Defense Partnership, Inc.

The Animal Defense Partnership, Inc.

The Animal Defense Partnership

Name: David Ebert

cc: Tom Wilcox (Tom.Wilcox@dgilvirginia.gov)

The Animal Defense Partnership, Inc.

BEFORE THE SECRETARY OF AGRICULTURE

In re: AWA Docket No.07-0144

Karl Mogensen, d/b/a

to this proceeding (7 C.F.R. § 1.138).

The complainant agrees to the entry of this decision.

1. Karl Mogensen, hereinafter referred to as the respondent, is an individual doing

exhibitor as defined in the Act and the regulations.

the entry of this decision, such decision will be entered.

thereunder, and in particular, shall not:

securely, and restrict other animals from entering;

(b) Fail to store supplies of food so as to adequately protect them against

2. Respondent is assessed a civil penalty of $10,000, which shall be paid by a

3. Respondent's license is suspended beginning on January 1, 2008, up to and

terminating the suspension.

decision on the respondent.

Copies of this decision shall be served upon the parties.

Frank Martin, Jr.

Done at Washington, D.C.

Administrative Law Judge

2015 Permit Revocation

Mr. Karl Mogensen

Dear Mr. Mogensen:

4010 WEST BROAD STREET, P.O. BOX 11104, RICHMOND, VA 23230-1104

cc: Robert Duncan, Director

Type: ROUTINE INSPECTION

Prepared By: COHEN KIMBERLEY, D V M

Coleman Randall, Animal Care Inspector