Dear Mr Avery;
We are general counsel to the Toronto Humane Society.
It has come to our attention that the OSPCA has decided to terminate the
overnight shift at the Society.
It is our position that the warrant giving the OSPCA access to the
premises does not authorize your client to interfere with our employees
and regular operation of the premises.
By removing the animal care attendants in this fashion you are putting
the health and welfare of the animals who require care at risk. We
understand that you are planning to remove a large number of animals that
would normally receive care over the night shift. We would ask that you
advise your client to bring back the night shift employees immediately.
We will hold your client responsible for the health and well being of any
animal moved out of the premises by this illegal and unwarranted
exercise.
In view of the fact that this matter is in dispute and will be challenged
in court by my client, we require that all activity that takes place at
the Toronto Humane Society be video taped so that your client's
activities on the premises can be reviewed by all parties concerned and
the trier of fact.
We hold your client responsible for any costs that may result from this
and the death of any animal caused by the OSPCA's illegal activities.
Govern yourself accordingly
Pell Capone
Bodnaruk and Capone
53 Yonge St, Suite 300
Toronto M5V 1J3
For further information: Ian McConachie, (416) 984-3097
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