Document Library



Legal Documents and Criminal Proceedings

 

2014 Criminal Contempt Hearings

  • The court orders that Caboodle Ranch must remove all animals from the property, terminate all operations, and liquidate all assets by October 1, 2014.
  • The Sheriff petitions the court for order to show cause, alleging that Caboodle Ranch is in possession of animals in violation of the court’s 2012 injunction.
  • Caboodle Ranch is ordered to appear before the County Court to answer charges that it is in criminal contempt of court for violation of the 2012 injunction prohibiting the Ranch from possessing or having custody of live animals.

2012 Criminal Trial

  • Craig Grant and prosecutors reach a Deferred Prosecution Agreement, suspending criminal action on the case provided that he does not violate the terms of his agreement.
  • Craig Grant’s attorney files a Motion to Continue due to the fact that Craig is negotiating a plea bargain.
  • State’s Discovery Exhibit in criminal trial of Craig Grant and unnamed co-defendant.
    Personal information and identity of some witnesses have been redacted for the safety of those individuals.
  • Arrest Warrant for Craig Grant, Feb 24th, 2012
    Craig Grant’s arrest warrant lists one count of scheming to defraud, one felony count of animal cruelty for Lilly‘s neglect, and three misdemeanor counts of animal cruelty (for “Duchess”, “Grey”, and an unnamed brown tabby). The warrant stems from evidence gathered by PETA. Bail was fixed at $250,000.00 “with further condition that he not be involved with operation of Caboodle Ranch if released”.

Custody Hearing Appeal

  • Appellant’s Initial Brief to File Appellant’s Initial Brief.
    Caboodle Ranch’s initial brief claims that the “vast majority of the 653 cats seized were in fine shape,” and that the Court erred in declaring that each cat was in danger by virtue of its exposure to deadly disease at the Ranch without examining the condition of each cat individually.
  • Motion for Extension of Time to File Appellant’s Initial Brief.
    The Court has granted Caboodle Ranch an extension to file a brief in their appeal because their counsel, David Collins, is withdrawing from the case.

Custody Hearing

  • Order On Motion To Amend August. 9, 2012 Order.
    The Court had previously placed restrictions on the ASPCA, ordering them to hold back Craig Grant’s “personal” cats from adoption, and forbidding the ASPCA from barring Caboodle Ranch supporters from adopting the rescued cats (despite the stated intention of many of those supporters to illegally return the cats to Craig Grant. This amended order acknowledges that the Court never had jurisdiction over the ASPCA, and retroactively removes all references to the ASPCA from the order.
  • Order Modifying Stay.
    A new order is issued by the Court, sternly warning Caboodle Ranch not to encourage its supporters to harass the judge with ex parte communications. If possible, the ASPCA is ordered to hold back five cats from the adoption: Tommy, Snoop Dog, Meatball, Toot, and Crackers. This suggests that negotiations may be underway for Craig to keep these “personal” cats, despite his having agreed that all cats seized were the property of Caboodle Ranch. Transfers of cats from the ASPCA to other shelters are temporarily halted, with the understanding that the hundreds of cats already transferred to other organizations are exempt. Finally, the ASPCA is enjoined from “blacklisting” adopters solely on the basis of their affiliation with Caboodle Ranch. The order does not apply to other shelters which have received Caboodle Ranch cats, and it does not preclude rejection on the basis of other pre-screening criteria.
  • Order on Caboodle Ranch’s Motion to Reduce Amount of Bond is denied.
    Because the case is officially being transferred to Circuit Court, Caboodle Ranch’s request to reduce the bond amount to the jurisdictional limit of $15,000.00 is rendered moot. The stay preventing adoption of the cats has been lifted; however, cats may not be euthanized without the written authorization of a licensed veterinarian. The stay may be reinstated if Caboodle Ranch can come up with the $1,800,000.00 bond.
  • County’s opposition to reducing the bond is explained in the Petitioner’s Memorandum of Law in Opposition to Respondent’s Motion to Reduce Amount of Bond for Stay Pending Appeal.
    The County lays out the reasons for why Caboodle Ranch’s request to reduce the $1,800,000.00 bond is invalid. The argument revolves around two facts: that Caboodle Ranch did not raise objections to the amount during the June 29, 2012 hearing; and that a transfer to Circuit Court is already pending.
  • Caboodle Ranch Opposition to Transfer to Circuit Court.
    Caboodle Ranch opposes the transfer to Circuit Court on the grounds that the case has been adjudicated, which “fully concludes the action”.
  • County’s Motion to Transfer Case to Circuit Court.
    The County petitions to have the case transferred to Circuit Court, citing Rule 1.060(a): “If it should appear at any time that an action is pending in the wrong court of any county, it may be transferred to the proper court within said county…”
  • Notice of Filing.
    The Court issues a formal notice that it will not read or respond to any email from a person who is not party to the case.
  • Judicial Acts to be Reviewed.
    Caboodle Ranch files an appeal on the grounds of sufficiency of evidence and evidence rulings.
  • Motion To Reduce Bond.
    Caboodle Ranch counsel files a notice of appeal, and requests that the court lower the bond amount to $15,000 on the faulty premise that the County Court cannot assess costs over $15,000. However, Florida law establishes that County Court has jurisdiction over cases where the damages are less than $15,000, irrespective of costs and legal fees assessed.
  • Order for Stay Pending Appeal.
    The Court grants Caboodle Ranch’s request to stay the release of the animals, forcing the ASPCA to suspend adoptions until an appeal can be heard. However, Caboodle Ranch must first post a bond of $1,800,000.00, which the Sheriff stated was the minimum cost of caring for the cats, and which Caboodle Ranch’s counsel did not object to in court.
  • Order Placing Animals, the final order of the Court awarding custody of the Caboodle Ranch cats to the Madison County Sheriff’s Office.
    The cats remain under the control of the court in the criminal case until their release to the Sheriff is authorized.
  • Letter from the ASPCA to the Court describing the care of the cats and plans for adoption.
  • The prosecution’s Memorandum of Law requested by the judge.
    The memorandum offers the legal reasoning that shows that the court may not return a portion of the cats to Caboodle Ranch, because the attorney for the defense made no such legal request. All the cats must be returned, or all the cats must be seized. It further states that if custody is granted to the Sheriff or the ASPCA, that agency will have full legal control over the disposition of the cats.
  • Official transcript of cross-examination of Dr. John C. Lewis by the attorney for Madison County, George T. Reeves, Esq.
    The testimony by Caboodle Ranch’s own veterinarian was devastating to Caboodle Ranch’s defense. Dr. Lewis acknowledges that he only has records for 200 cats, that many records are for dead cats, that disease was already widespread in 2009, that healthy cats were permitted to pass freely in and out of the sick ward, that the collars used by Caboodle Ranch were inadequate identification, and more.
  • Exhibit 8, map and a collection of photos submitted into evidence without objection from the defense.
    Individual photos and descriptions may be found in our article Caboodle Ranch Custody Hearing: Exhibit 8 and 13.
  • Exhibit 10, charting the locations and prevalence of cats with ringworm at Caboodle Ranch.
  • Exhibit 11, charting the locations and prevalence of cats with FeLV at Caboodle Ranch.
  • Exhibit 12, charting the locations and prevalence of cats with FIV at Caboodle Ranch.
  • Exhibit 13, detailing the suffering of the grey cat found suffering in the General Store.
    Dr. Miller testified that this cat had life-threatening conditions. He was hypothermic, with a temperature of 93.6 degrees, and was 8% dehydrated — both dangerous conditions. The cat was unable to walk or stand, and could not get to food on his own. He was covered in urine and feces. His legs were rigid and he could not move them. The cat had slow withdrawal reflexes. He had a head tilt and tremors, signs of neurological damage.
  • Exhibit 14, detailing the suffering of Cat #029, now permanently blinded due to neglect.
  • Exhibit 15, detailing the suffering of Cat #039, who died a protracted death from starvation and untreated infections.
  • Exhibit 16, detailing the suffering and rehabilitation of Cat #069, who died a protracted death from starvation and untreated infections.
  • Tommy’s condition, at the time of intake, and after proper veterinary care.
  • Unofficial summary notes from custody hearing, testimony of Jamie Willoughby.
  • Order Approving Stipulation and Altering Style of the Case.
    This document makes official Craig Grant’s assertion that he owns none of the cats as personal pets; they are all the property of Caboodle Ranch, including Tommy.
  • Final Judgment concerning Nanette Entriken
    Entriken’s attorney and the Sheriff’s attorney agreed to release Nanette Entriken’s cats to her if and only if the court in the criminal case against Craig Grant agreed to file a release order. Entriken’s attorney failed to petition that court, and so the cats were not released.
  • Petition for Custody, Control, and Disposition of Animals, March 2nd, 2012.
    The petition to permanently remove the cats from Craig, Nanette, and Caboodle Ranch alleges that Craig, Nanette, and Caboodle Ranch are “not able to provide adequately for” and are “not fit to have custody of” their animals. The petition was executed by Tina Demotsis, the Madison County Sheriff’s Office Investigator who was present during the 2009 veterinary inspection of Caboodle Ranch. The accompanying inventory of cats includes at least one cat quarantined for rabies.

Search and Seizure

  • Financial Information Sheet.
    The Financial Information Sheet that Craig Grant was required to fill out in jail contains several falsehoods, including listing his son’s address as his home; stating that he has no debts when he has stated in fundraisers that he owes money to the veterinarian and has outstanding mortgages; and stating that he has no personal property when he in fact has filed official paperwork for improvements to the property, and owns a vehicle.
  • Offense Incident Report for Caboodle Ranch arrest and seizure.
    Personal information redacted.
  • Probable Cause Affidavit.
  • Affidavit for Search Warrant.
  • Search Warrant, February 24th, 2012
    The search warrant authorizes the Sheriff to seize any animals (alive or dead) on Caboodle Ranch property, any and all financial documents, and other evidence related to the neglect of the cats. It alleges violations of Florida Statutes 828.12 (cruelty to animals), 828.13 (confinement of animals without food or water), and 817.034 (scheme to defraud).

Other

  • Text of Ordinance 2011-196, Excess Animal Habitat.
  • Court Order to Show Care, May 6th, 2009
    Following inspection reports that reveal cats “residing within deplorable conditions”, Craig Grant is served with an Order to Show Care. The order warns that “[i]f compliance is not met within the specified time frame, appropriate action will be taken for the health and welfare of the animals.”
  • Order Granting Attorney’s Fees
    Caboodle Ranch is found to be in contempt of court on three separate violations for refusing to turn over evidence in their own defamation suit against Conley, Jonasson, and Logan, resulting in an award of attorney’s fees.
  • Appeal of ruling and sanctions against Craig Grant resulting from defamation suit against Gary Conley, Pamela Jonasson, and Carolyn Logan
    Craig Grant loses his defamation suit against three whistleblowers who exposed neglect and abuse at Caboodle Ranch. He is sanctioned by the court and compelled to pay the defendants’ legal fees. He appeals the sanctions, and loses.
  • Dismissal of Craig’s appeal
  • Felony arrest, obtaining money under false pretenses, 1992
    Craig Grant is arrested on felony charges of obtaining money under false pretenses. His contractor’s license is subsequently suspended for breach of contract.
  • Contractor license suspension for breach of contract, 1992


Complaints and Investigations

  • Personal enrichment complaint
    A collection of IRS complaints filed by Elise Perkins. These complaints allege perjury and schemes for personal enrichment by Craig Grant, Rob Grant, and Nanette Entriken.
  • Perjury complaint filed by Elise Perkins with IRS
    IRS complaint and documentation regarding perjury by Caboodle Ranch and its principals. Filed by Elise Perkins, Sep. 14, 2011.
  • Fundraising complaint filed by Elise Perkins with IRS
    IRS complaint and documentation regarding improper fundraising by Caboodle Ranch and its principals. Includes extensive documentation. Filed by Elise Perkins, Sep. 14, 2011.


Veterinary Records and Evaluations

  • Several deceased cats documented in veterinary records.
    These records demonstrate that the cats had received treatment previously, and declined while under Caboodle Ranch’s care; they were not dropped off in that condition, as Caboodle Ranch has claimed.
  • Veterinary records for Tommy, Craig Grant’s “favorite cat.”
  • First Excessive Animal Habitat inspection report, January 5, 2012
    Thirty-eight animal care violations are noted on this inspection report.
  • Second Excessive Animal Habitat inspection report, January 12, 2012.
    Inconsistencies between the reality of Caboodle Ranch and the claims of its staff and the deficiencies of the Ranch are evident in this second follow-up inspection report. The ever-changing number of cats on the Ranch (400 this time, according to Craig Grant), the cats roaming outside the property, the lack of veterinary records and individual identification of cats, the disrepair and filth of the buildings, overcrowding, and other issues are noted on the report. Particularly disturbing is the revelation that the Ranch intends to erect an electric fence to keep cats inside the property.
  • Veterinary assessment for three cats left at Caboodle Ranch
    Upon retrieving three cats — Hercules, Rocky, and Annie — from the Ranch, Shannon Bock was horrified to discover that they now suffered from a multitude of ailments. One cat had to be humanely euthanized due to its advanced illness and poor prognosis. March 31st, 2009.
  • Recommendations of Dr. John C. Lewis and Darren W. Baxley following the May 2009 veterinary inspection.
    Consistent with every other evaluation of the Ranch, Dr. Lewis urges Craig Grant to stop intake of cats immediately and to acquire more staff and volunteers to care for the existing population of cats. He recommends the euthanasia of all of the seriously ill cats on the Ranch, and advises Craig Grant to make changes to the facility, including a fence adequate to keeping predators out and cats in and the draining of the stagnant pond that infects the cats with giardia.
  • Summary of Findings by Dr. Julie Levy, DVM
    Findings of the 2009 inspection team show rampant illness, inadequate and random treatment by unqualified personnel, lack of identification, lack of medical records, no disease management or prevention protocols, unhygienic environment, inadequate staffing, refusal to follow veterinary recommendations, and unneutered cats. The conclusion is that the facility does not meet minimum guidelines for cat health and welfare, and recommends that the facility stop taking in cats immediately.
  • Summary of Findings by Laura Bevan
    Laura Bevan summarizes her findings in the 2009 inspection of Caboodle Ranch, confirming that the majority of cats were in poor health.
  • Notice from Madison County Animal Control of violation of court orders
    In 2010, Jamie Willoughby warns that Caboodle Ranch has been declining, and that Craig Grant’s failure to enact the recommendations made in 2009, he is in violation of the court order. Willoughby expresses concern that the future of the program is in jeopardy.
  • Records from John C. Lewis, DVM and Scott Mill Animal Hospital
    Spokespeople for Caboodle Ranch have claimed that the sick and injured cats seen in the video were all being treated. These veterinary records do not reflect adequate treatment for the number of wounded and sick cats documented by rescuers, much less preventive care for 700 cats.
  • Inspection summary by Jamie Willoughby, Dec. 6, 2010
    Jamie Willoughby issues a positive report on the improvements at the Ranch, noting only that cats are not properly quarantined, insufficient staff, and the refusal to stop taking in cats.
  • Correspondence: Nanette Entriken to Jamie Willoughby, Feb. 25, 2011
    In 2011, Nanette Entriken questions Animal Control officer Jamie Willoughby about his preference that no more cats be admitted to Caboodle Ranch. Willoughby asks Entriken not to take in more cats until the sick ones improve; this is two years after the 2009 inspection and recommendations that intake cease. Willoughby asks Entriken to stop referencing Madison County Animal Control as having endorsed the Ranch. Willoughby alerts Entriken to an upcoming “surprise inspection”.
  • Animal Control Inspection Report, March 16, 2011: After alerting Nanette Entriken in the above email correspondence that he will be out to the ranch soon, he inspects Caboodle Ranch on March 16, 2011. He falsely reports that it was an unexpected visit in his inspection report.


Bank Statements

Caboodle Ranch’s bank statements show irregularities that would call any nonprofit’s finances into question. In particular, there are several instances where hundreds of dollars in nonprofit donations were used to pay for personal expenses, such as clothing, food, and entertainment (e.g., tickets for the Daytona Speedway on Feb. 9, 2009 and “Disney on Ice” on Mar. 30, 2009).


Tax Filings


Debts, Defaults, and Foreclosures

  • Federal Tax Lien, 2000 – 2003
    Craig Grant accumulated $153,439.82 in tax debt racked up over a period of four years. The tax irregularities were discovered and penalized in 2008, when the Ranch began showing signs of increasing financial difficulties.
  • Federal Tax Lien, 2005
  • Auto loan default and suit, 2000
    Craig Grant defaulted on a 2000 auto loan and was successfully sued by the creditor for $6,960.08.
  • Notice of Foreclosure Action for Lots 33 and 34, April 29th, 2008
  • Foreclosure for Lots 33 and 34, October 20th, 2008
    Two of the parcels of land purchased by Craig Grant went into foreclosure and were seized in 2008.


Corporate Documents


Real Estate Deeds

Over a period of several years, Craig Grant acquires multiple parcels of land. Two are lost to foreclosure.