Last week lawyers for the Animal Legal Defense Fund filed a Reply Brief in Support of Motion in the case against Wisconsin’s now-closed Special Memories Zoo. The ALDF presented further arguments and evidence as to why they should be awarded $72,172.56 in legal fees in the case that resulted in a default judgement against the roadside zoo.
According to documents, nowhere in the claim submitted by SMZ does zoo owner Dona Wheeler and zookeeper Gretchen Crowe say they are unable to pay an award of fees and costs to the ALDF. Once the court entered default judgment against the zoo, “it must accept as true all factual allegations in the complaint,” according to documents.
Those allegations include claims dating back to 2008 that the zoo restricted animals' food which caused them to starve to death, the zoo orchestrated mass burials of the neglected animals on the property, and documented incidents where USDA inspectors witnessed mistreatment including the zookeeper severely restricting drinking water for some of the animals.
In March of 2020 the zoo announced they were closing and began selling some of the animals. Days later a fire broke out in a barn on the property, causing the death of 35 animals. Authorities found an additional 18 animals decaying on the property that zookeeper Crowe admitted she hadn't checked on for more than two months.
As of Feb. 20, 2021, the Greenville, WI, location of the zoo appears to be abandoned with a For Sale sign in front. No trespassing signs are hung at every entrance, the parking lot has not been plowed, and a single set of footprints in the snow appear to lead into the zoo and also appear to lead back out.
Lawyers for SMZ are expected to file a reply brief opposing the motion in the next few weeks before the judge makes his final ruling.
Roadside Zoo News is still working to determine the location of a black leopard, two wolves and numerous other animals that disappeared from the zoo last year. Anyone with information is asked to email firstname.lastname@example.org.
Full court documents: