Q Did you ever walk around the property and determine where the horses had access to?
A I was on the property, yes. We had access to the paddock and the fields to the north of the house.
Q Where the creek ran through, right?
A Yes.
Q And the creek ran through a stiller area which was a pond, correct?
A I don't necessarily recall a pond, but I remember a low lying area or a swampy area.
Q And the creek ran through that low lying or swampy area, correct?
A There was water running through that area, yes.
Q Good source of water, correct?
A The water I saw on my visits and during the search warrant were -- didn't appear to be running water through there. It was -- it seemed like it was stagnant water.
Q The creek ran through it, didn't it?
A If there was -- maybe you're referring to an underground creek or something. I don't recall seeing a creek running by anywhere.
Q The area that you're talking about is to the north of the buildings, correct?
A Yeah, north -- a northerly direction.
Q And the buildings -- the property itself being to the north of the highway, correct?
A Yes.
Q I'm going to show you a photograph and just ask you if you can recognize what generally is depicted in that photograph. If you can't get oriented, just tell us.
A Okay, the (indiscernible) would be over here.
Q All right. I'm going to ask you just to hold it up a little bit so the judge can see where you're describing and what.
A Okay, this --
Q First of all, let me stop you. You recognize this to be a photograph of a portion of the property that we're speaking of?
A It looks familiar.

THE COURT: There's a similar shot in the booklet, I think, at least of that shelter. I may be wrong.
MR. BETTON: No, it's not the same. I don't believe it's the same area, Your Honour.
THE COURT: Okay.

Q Sir, let me assist, perhaps. I'm going to suggest to you that that's a photograph taken looking northward away from the buildings and structures on the property where this search and seizure occurred.
A Okay.

THE COURT: Taken this year?
MR. BETTON: Taken this year.
THE COURT: By the look of the snow.

Q And there's a creek running through it, correct?
A There appears to be some sort of -- some water running through there, yes.
Q All right.
A (Indiscernible) creek.
Q Did you -- is it possible that there was a creek running through the property and although you didn't notice it, with aid of that photograph you're able to see it?
A Sir, I don't recall that, no.
Q If there was a creek there, you'd certainly agree it's a good source of water for horses, right?
A It would be, yes, if there was a creek there.
Q So whatever examination you did of the property, you were not able to -- or did not determine that there was a creek in existence for the horses to water from, correct?
A During the search warrant I recall having to assist pulling a horse out of the bog at the back of the property, the north end of the property. She was stuck up to her belly in mud.
Q Is that when people were trying to chase her to get her loaded?
A Nobody chasing her.
Q Let's keep our eye on the ball for a second. Is it possible there was a creek there that you didn't see or didn't pay attention to or didn't notice?
A If there was a creek that size, I would've noticed it and I don't recall seeing a creek.
Q So you would say that that photograph can't be a picture of this property?
A Well, I'm just saying that there was -- I don't recall a creek that size on the property at that time.

MR. BETTON: Your Honour, I'm going to ask that that photograph be marked as an exhibit for identification.
THE COURT: Okay, A for identification.
A FOR IDENTIFICATION: Photograph depicting creek.

Q One of the concerns you had was that there wasn't an adequate water source for the horses, correct?
A That's correct.
Q So, in fact, if there was a creek there, that wouldn't be a very well justified concern, would it?
A If there was a creek there, yes.
Q One of the other horses that was seized, aside from Sully, was a brown mare with a black tail and mane that was pregnant, correct?
A Yes.
Q Now, for sake of referencing consistency, and again I appreciate that you would have no idea if this is the case, I'm going to refer to that horse as Cocoa, all right?
A Okay.
Q It was your opinion that Cocoa was in distress?
A Yes.
Q What was wrong with Cocoa?
A Well, when the -- after being examined by the veterinarian, her body conditioning score was not adequate and she was pregnant. There was concerns of the debris in the -- in the paddock and also lack of adequate water.
Q Right, assuming there was no creek, correct?
A That's correct.

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Q If I were to suggest to you, sir, that that is a photograph showing from obviously a particular angle, the property to the north of the buildings that the horses had access to, to range in, in December of 2002, would that be consistent with your observation of the property?
A It's difficult to tell, sir. I can't --
Q In one of those photographs you can see a collection of water.
A Yes.
Q I'll call it a pond.
A Yeah, I see that.
Q Does that look familiar at all?
A No, offhand I can't -- it looks similar to the area, but I --
Q All right.
A -- can't say for sure.
Q Did you go down to the pond area to see if it was fed at all by a creek or the creek, or if it was spring fed, or do you know?
A I have no idea, sir.
Q Certainly a pond that's spring fed is a fine source of drinking water for horses.
A An open pond like that would be, yes.

B-2 FOR IDENTIFICATION: Photograph depicting two horses and a collection of water.

This would be laughable if it weren't for all the victims. First, the seized animals that are carted off in terror to god only knows where, but we have proof that horses in the SPCA's custody fare terribly, being returned, but only on payment of whatever amount of money the SPCA demands, sick, thin, and injured. The seized animals that are made sick by the SPCA and then killed. The animals that are subjected to unnecessary and harmful medical treatments and procedures so that the SPCA can show that they were necessary and were not being done by the owners. The seized animals that are injured in seizures by ham-fisted SPCA employees and hangers-on.

Second, the people who are demonized and destroyed by the SPCA both emotionally and financially; the people who are more humane to their animals than the SPCA is. The people who are providing food, water, and shelter, even though the SPCA testifies that they weren't. The people who were giving their animals medical treatment even though the SPCA testifies that they weren't. The people who were trimming their horses' hooves even though the SPCA makes it look like they weren't. The people whose horses drank creek water, but were made to look inhuman by the SPCA denying the existence of the water.

Linda Douglas was denied her day in court, to describe, among other things, the way the horse was driven into the pond, as she described it to us.