pg. 1

To:

Mr. Louis Massi

Veterinary Medical Board

1747 N. Market Blvd, Suite 230, Sacramento, CA 95834

phone: 916-515-5220 | email: vmb@dca.ca.gov

From:

Saskia Boisot, MD

Founder, No Kill Shelter Alliance

6463 Paseo Delicias, #1833, Rancho Santa Fe, CA 92607

cell: 619 895-0599 | email: sboisot@yahoo.com

(Note: because Slideshare – where this letter is posted for public consumption – does not enable

links until page 4, all text with links are repeated on page 4.)

Dear Mr Massi,

I am writing to find out the status of my prior complaint #NV 2016 220 that I lodged last

October against Dr. Jennifer Hawkins at Orange County Animal Shelter.

My original complaint #NV 2016 220 dated (around September 2015)

Your response to my complaint #NV 2016 220 (dated 10/2/2015)

Given that it has now been 9 months, coupled with the wealth of supporting information I

submitted along with my complaint at the time, I can only hope that the substantial time lapse

since my submission means that it is being given appropriate and full consideration. Since the

time the complaint was generated, my group has been doing a considerable amount of research

on OCAC through numerous public records requests, whereupon a significant amount of

additional disturbing information has come to light, much of which pertains not only to how they

are inappropriately labeling dogs as aggressive in order to justify killing them, but also with

respect to their handling of medical dogs.

Whilst I am aware that overall regulation of California animal shelters does not necessarily fall

under the purview of either the American Veterinary Medical Association or the California

Veterinary Medical Board, it certainly seems that oversight for the medical management of

animals under their care should meet the criteria for this. I would therefore like to draw your

attention to one particular aspect of operations at this facility, namely that of delegating the

responsibility of determining whether an animal is considered to legitimately fall under the

category of so-called “irremediable suffering” to registered veterinary technicians. We have

systematically put in public records requests for all owner-surrendered dogs killed under the

auspices of this designation between October 2015 and now, and have found that a vast majority

of these assessments are being made by RVTs (Registered Veterinary Technicians), and not by

veterinarians. Additionally, we have had our data analyst (who also happens to be a

veterinarian) do an in-depth evaluation of the euthanasia data, and she has calculated the median

time to death for animals in the so-called “owner-surrender” category to be only 60 minutes, with

many being killed within only a matter of minutes upon relinquishment.

pg. 2

This above paragraph raises two important issues; firstly, how is it possible for a full medical

evaluation and review of any supporting documentation to be adequately performed in such a

short time-frame, especially given that this will seal an animal’s ultimate fate? Secondly, I am

perplexed as to how it is acceptable that such a task be delegated to a low-level employee such as

an RVT, someone who has only 18 months of education beyond high school, when clearly this

represents a form of diagnosis? If a dog is brought in by an owner who claims that his or her dog

is suffering just because they say so, doesn’t this warrant a more substantial assessment than an

RVT merely walking over, prodding the dog for a minute, and agreeing with the owner? Surely

the AVMA and California Board of Veterinary Medicine must recognize that a certain degree of

diagnostic acumen is required to ascertain an animal’s prognosis, and in reviewing the job

description of allowable versus non-allowable duties that can be carried out by an RVT, medical

diagnostics clearly and specifically falls into the latter category. I don’t know if this is an

accepted practice at all California shelters, but if it is, then it certainly seems to devalue the

veterinary profession as a whole, and raises the question of why an RVT would not simply be

able to set up their own independent practice within the community.

Obviously we recognize that there are many instances where an animal truly is suffering, and

humane euthanasia is entirely appropriate, and sometimes in cases of massive traumatic injury

this may even have to be executed expediently; but when you have a shelter that lacks

transparency, and whose mission appears to be more about protecting the status quo of its

operations rather than the interests of its resident animals, heavy scrutiny and questioning are of

paramount importance.

Furthermore, it is noteworthy that, in comparison to a number of other shelters of similar intake

size, this shelter has an inordinately high number of so-called “owner requested euthanasias”

(OREs), and nowhere on the form signed by these owners is it clearly delineated that the owner’s

intended purpose of surrender is for euthanasia. Therefore it is entirely possible that these

owners think they are handing over their animal to the shelter thinking there is a small but real

possibility of him/her having a chance at survival through adoption, while in fact the shelter is

making the decision to kill. Even more nefarious though is the fact that the cost incurred to

relinquish one’s animal for “euthanasia” is only $41, compared to $110 for the shelter to take the

animal in and make it available for adoption. Needless to say that in a place where a substantial

demographic is economically challenged, the financial motivation to kill cannot be ignored.

When shelter performance measures are largely based on ASILOMAR calculations of live-

release rates where animals killed under the “owner requested euthanasia” category can be

subtracted out, this clearly illustrates how data manipulation can falsely elevate the live-release

rate, and therefore give that shelter a significantly more favorable rating.

You may well ask what makes this shelter particularly egregious, when there are many other

high kill shelters in the vicinity who seemingly fare no better. OCAC continually nurses up to

200 empty kennels at any given time, yet kills on a daily basis regardless, and we have been

documenting this week after week. In our view, this alone exemplifies their absolute disregard

for animal life, and highlights their complete lack of commitment to saving lives, a sentiment we

feel should represent the cornerstone of modern animal sheltering.

pg. 3

In support of the allegations I have made above, I am enclosing some of the records from dogs

killed between October 2015 and early 2016, as examples (there are many more), so that you can

see for yourself what I am talking about, as well the list of acceptable and unacceptable duties

that can be performed by an RVT, according to the California Code of Regulations Veterinary

Medicine Practice Act (2036).

One record is for a dog (Jade) that was brought in with a vet note stating that the dog should not

receive any rabies vaccination because of autoimmune hemolytic anemia, yet the shelter

conveniently misconstrued this note as appropriate documentation of “irremediable suffering”,

and the dog was summarily killed. As a human physician myself who specializes in blood

disorders, I know very well that autoimmune hemolytic anemia represents a treatable disease,

and even if the owner did not want to pay to treat the dog’s condition, the Hayden Act militates

that this dog should have been made available to rescues and given a chance at survival.

Another record pertains to two dogs (Shelby and Brewzer) brought in by the same owner, one 7

years of age, the other 8; the statistical likelihood of two dogs owned by the same person and at

such a relatively young age having the misfortune of meeting the criteria for “irremediable

suffering” at exactly the same time is practically zero, and therefore the only conclusion that can

be drawn in this case is that the shelter obliged in convenience killing, again violating the

Hayden Act, which would have afforded at least one of them a chance at survival through rescue.

I am also including three additional records (Chanel, Duke, Annie) that show RVTs as the sole

evaluators for dogs surrendered for supposed irremediable suffering, but we have many more of

these should you need further proof.

I am also including two records from dogs (Mack and Spanky) that were killed for alleged

aggression, simply to demonstrate the complete absence of appropriate documentation. Mack,

was owned by an OCAC staff member who clearly just wanted to get rid of him, and according

to the record, even tried dumping him in a local park the day before he was surrendered to be

killed; Mack was killed within 30 minutes of surrender, and clearly in the absence of any

documentation. Sparky was brought in with a hand-written note by his owner describing

purported aggression, but no supporting evidence for this contention; Sparky was killed within

103 minutes of relinquishment.

I sincerely hope that at this time you will ensure that my complaint is given a higher priority than

previously, as many animals continue to die needlessly and inappropriately at the hands of

shelter management.

Many thanks in advance for your attention to this matter.

Sincerely,

Saskia Boisot, MD

Reference Links repeated on next page

pg. 4

Reference Links repeated

My original complaint #NV 2016 220 dated (around September 2015)

Your response to my complaint #NV 2016 220 (dated 10/2/2015)

list of acceptable and unacceptable duties that can be performed by an RVT, according

to the California Code of Regulations Veterinary Medicine Practice Act (2036).

Jade

Shelby and Brewzer

Chanel, Duke, Annie

Mack and Spanky