E012021017008 William E Pflaum V Joann Miller Et Al COMPLAINT AMENDED 5

FILED: COLUMBIA COUNTY CLERK 07/02/2021 11:42 AM INDEX NO.
E012021017008
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 07/02/2021
STATE OF NEW YORK SUPREME COURT COUNTY OF COLUMBIA
William Pflaum, .
Plaintiff, . gMMo AJ
: Notice of
-against -
: Complaint
:
JoAnn Miller : Index number:

and
Danielle Infantino,
Defendans
PLEASE TAKE NOTICE that the annexed Complaint of William Pflaum, Plaintiff, dated Thursday,
July 2, 2021, and the exhibit annaxcd thereto, and upon all the pleadings and pracêad|ñgs
heretofore had herein, the undêrsigned will move this Court on August 2, 2021, at 9:30 a.m. in the
moming of that day or as soon thereafter as counsel can be heard, at the Suprama Court of the
State of New York, County of Columbia, 401 Union Street, Hudson, NY 12534 for the fcilowiñg
relief:
1. Pursuant to CPLR 3016, Plaintiff prays for relief and a judgmant of fibel and dêfamation by
Defendants;
2. Punitive damavoo, Interest as a|lowad by law; Costs of suit; and Such other and further relief
as this court may deem just and proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 2214(b) answering papers, if any,
must be served n the undersigned at least seven (7) days before the retum date of this maticñ.
KRISTEN M SCHIFFER
••t et
Notary Pubile, State of New York . •> er
N
Reg. No. 01SC6394591 0 .
Qualmed In Columbia ....
County
Commission Expires July 8, 20 d *
Plaintiff:
Will Pflaum, 3 Rybka Road PO Box 40, Stuyvesant Falls, NY 12174, 518-470-3981
glencadia@gmail.com
Attomey for Rieliftiff Henry R. Kaufman, Henry R. Kaufman, 60 East 42nd

P.C., Street, 47th Floor
New York, NY 10165, 914-589-7963, Hkaufmaii@iirkaufman.com
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FILED: COLUMBIA COUNTY CLERK 07/02/2021 11:42 AM INDEX NO. E012021017008
STATE OF NEW YORK SUPREME COURT COUNTY OF COLUMBIA

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PLEASE TAKE NOTICE ha he anne ed Com lain of William Pfla m, Plain iff, da ed Th da ,
J l 2, 2021, and he e hibi anne ed he e o, and on all he leading and oceeding
he e ofo e had he ein, he nde igned ill mo e hi Co on A g 2, 2021, a 9:30 a.m. in he
mo ning of ha da o a oon he eaf e a co n el can be hea d, a he S eme Co of he
S a e of Ne Yo k, Co n of Col mbia, 401 Union S ee , H d on, NY 12534 fo he follo ing
elief:
1. P an o CPLR 3016, Plain iff a fo elief and a j dgmen of libel and defama ion b
Defendan ;
2. P ni i e damage ; In e e a allo ed b la ; Co of i ; and S ch o he and f he elief

a hi co ma deem j and o e .
PLEASE TAKE FURTHER NOTICE, ha an o CPLR 2214(b) an e ing a e , if an ,

m be e ed on he nde igned a lea e en (7) da befo e he e n da e of hi mo ion.
Plain iff:
Will Pfla m, 3 R bka Road PO Bo 40, S e an Fall , NY 12174, 518-470-3981
glencadia@gmail.com
A o ne fo Defendan : Hen R. Ka fman, Hen R. Ka fman, P.C., 60 Ea 42nd S ee , 47 h

Floo , Ne Yo k, NY 10165, 914-589-7963, Hka fman@h ka fman.com
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STATE OF NEW YORK SUPREME COURT COUNTY OF NASSAU

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William Pfla m, being d l o n, de o e and a : Yo de onen i he named Plain iff he ein. I,

he nde igned, William Pfla m, do he eb decla e nde he enal of e j a follo :
1. Plain iff WILLIAM PFLAUM ( Plain iff ) fo hi Com lain ae he follo ing:
2. Plain iff i an indi id al and ole o ne of Glencadia Co o a ion, DBA Glencadia Dog
Cam , and i no , and a all ime men ioned in hi com lain a , a e iden of Col mbia
Co n , Ne Yo k. Plain iff ha o ked a he o ne and o e a o of Glencadia fo 16 ea
and ha e ided a 3 R bka Road, S e an Fall , NY 12174 ince 2004. The b ine
al o o e a e a he ame loca ion.
3. Defendan JoAnn Mille i an indi id al and i no , and a all ime men ioned in hi
com lain a a e iden of Na a Co n , Ne Yo k.
4. Defendan Danielle Infan ino i an indi id al and i no , and a all ime men ioned in hi
com lain a a e iden of Na a Co n , Ne Yo k.
Na C a
5. Unde Ne Yo k la , he elemen of a defama ion claim a e: 1) a fal e a emen ; 2)

bli hed o a hi d a i ho i ilege o a ho i a ion; 3) i h fa l amo n ing o a lea
negligence; 4) ha ca ed ecial ha m o defama ion e e.
6. CPLR 3016 (a) e i e ha in a defama ion ac ion, " he a ic la o d com lained of * * *

be e fo h in he com lain ." The com lain al o m allege he ime, lace and manne of
he fal e a emen and ecif o hom i a made (A ena l Fo e , 197 AD2d 554;
Va di M al Life In . Co., 136 AD2d 453).
7. The follo ing a e he fo elemen of a libel ca e a e he Dillon ma e abo e:
a. The fal e a emen he e in he in an com lain i of ab e of he dog Timbe made

b Defendan on Facebook and GoF ndMe. The a emen i o ed in f ll belo
i h fal e and libelo a age indica ed.
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b. Sc een ho and o he oof of blica ion i anne ed. The e can be no do b he

a emen a bli hed i h Glencadia Dog Cam clea l labeled and
c. A o negligence, h o gho hi com lain , Defendan eak o e-e i ing

condi ion , he nia , alle gie , anemia and o he ca e of eigh lo . A eigh
lo and gene al li le ne a e he onl con i en ea on fo he ab e allega ion,
and a he e a e man o he mo e likel ea on fo hi condi ion, a no ed b
Defendan hem el e io o la nching he ab e allega ion, he e can be no
do b ha he Defendan did no hem el e belie e he ab e allega ion hen he
bli hed he acc a ion.
d. A o ha m, anne ed he co ill find fal e Google e ie ill ac i e on Plain iff

e ie online, a am le of he man na me age end o Plain iff b an
en aged b ill-info med in e ne mob and o he e idence of ha m. F he ,
c een ho indica ing he e l of Google ea che ha link he malicio
GoF ndMe cam aign back o Plain iff b ine emain ac i e e en no .
8. Th , all he fo elemen of a libel/defama ion ac ion a e no ed in he com lain .
Fa
9. Defendan JoAnn Mille con ac ed Glencadia Dog Cam b e me age on S nda ,

No embe 29, 2020 i h he follo ing me age: Hello. I o ld like o boa d Timbe long
e m. I had een a co of $500. Plea e cla if ha a e fo long e m. I defini el need
Decembe 3 d h Jan a 2nd. Thank o .
10. Defendan e e ed long- e m ca e fo no a a en com elling ea on. In follo - call ,

Defendan indica ed he no longe an ed he dog a all. Glencadia em lo ee Pa icia
Ba e follo ed hi me age i h a b e en hone call. Defendan offe ed no
cohe en ea on h he needed o boa d Timbe . She a no a eling. In a follo -
hone call, Defendan aid he did no an o kee he dog, Timbe , and a looking fo a
ne home. A diffe en ime , Defendan e e ed diffe en leng h of a fo he dog fo
diffe en ea on . Ba e no ed Defenan a emen in he co e ondence en b
email a he ime in Decembe 2020 and anne ed he e.
11. Ba e ad i ed Plain iff, me, ha hi c ome a e ionable. Unfo na el , Plain iff did
no li en o hi i e ad ice of hi e cellen admini a i e a i an and i a ing fo ha
e o no . See email con e a ion in A endi C.
12. Ba e job i o hel c ome make e e a ion a Glencadia, do a oll fo he

em lo ee , handle in i ie , and lan deli e o e . She ha ab ol el no incen i e o
make o in en he commen ha a c ome i looking fo a home fo hei dog. Thi
email a en befo e an conflic be een he a ie had commenced.
13. F he , he ick- add e , deli e add e , and con ac add e fo Timbe e e all
diffe en . F he , o don need o boa d a dog fo 20 da if o a e mo ing. A h ee
diffe en eo le in e ened o comm nica ed i h Glencadia aff - Mile , Danielle, and
JoAnn - i a diffic l o fig e o ho dog Timbe a and he e he li ed. The e da a
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oin con ib e mo e e idence, a if he a emen o Ba e b Mille on he hone e e

in fficien , ha Timbe a no a ell-ca ed fo and lo ed membe of an gi en ho ehold.
14. The c o chid condi ion on Timbe e icle look a if i had fe e ed fo ea hen hi
condi ion all eme ge hen a dog i a and ea l ca a ion ol e he oblem.
The g o e e and long- anding cha ac e of he g o h ha e i ing on he da boa ding
commenced i clea in he ho o anne ed o hi com lain .
15. In he ie he con e a ion, Ba e o e: Thi dog i onl o ed o be he e fo

o eek ...b he o ne j old me oda i ' beca e of he li ing i a ion and ha he
i ing o find a ne home (A endi D).
16. Timbe a icked b a Glencadia d i e o ide a e office on he e ening of

Decembe 3, 2020 a 73 W Me ick Rd, Valle S eam, NY 11580. I i no clea he e
Timbe a li ing io o beginning hi boa ding a Glencadia and he ick- and deli e
add e e e e diffe en f om each o he and f om he add e li ed in he membe a ea of
Glencadia.com a anne ed a A endi A.
17. On F ida , Decembe 4, 2020, he ne da , Glencadia aff o e o Plain iff, Hi Joann I m

eaching o fo a li le mo e info on Timbe , can o lea e ell ha going on a o nd
hi omach a ea? Glencadia e onnel en o ho og a h of a la ge g o h on he leg
of he dog (A endi E). Glencadia kennel manage Ve non Do le ook h ee ho o and
fo a ded o of ho e ho o o Defendan . The e hocking ho o a e anne ed he e i h
da e, hone e, and loca ion info ma ion incl ded.
18. Defendan e onded, Hi, he ha a c o chid, an in e ed e icle. I i no ainf l, b ill

e i e a com lica ed ne e oced e. Hi Ve e ina , Cen al Ve e ina , 73 We Me ick
Road, Valle S eam, 11580, j a e ed him fo ge . (A endi F)
19. He e Defendan admi ha he dog ha a e io e-e i ing condi ion ha e i e

com lica ed ge i da befo e he dog colla ed and needed eme genc ca e hile a
Glencadia. The c o chid condi ion o ld a ea long- anding d e o he eno mo i e
of he g o h in he ho o anne ed.
20. R an Lle a, BSc, DVM; Robin Do ning, DVM, CVPP, CCRP, DAAPM, E ne Wa d, DVM in
hei a icle on c o chidi m in dog (A endi G), i e, C o chidi m i he medical
e m ha efe o he fail e of one o bo h e icle ( e e ) o de cend in o he c o m.
F he , he no e a a ea on o ne e ch dog ea l in life ha , Dog i h a e ained
e icle a e mo e likel o de elo a e ic la mo (cance ) in he e ained e icle. Timbe
a 11 ea old hen he boa ded a Glencadia Dog Cam and ma ha e had hi i e fo
man ea , hich gge manife l oo ali dog ca e b Defendan .
21. On Th da , Decembe 10, 2020, Plain iff o e o Defendan Mille , Hello Jo Ann. Timbe
eemed ick oda and en o he e . He had dia hea, didn' ea b eakfa , and a
li le . In he af e noon e decided o go he e . The e fo nd ele a ed hi e blood cell
and he' on an ibio ic . We'll kee o da ed b he doe eem a li le be e hi e ening.
He' j no doing ell. I can o in o ch i h he e fo mo e info and I ill email o
he ecei i h ome diagno ic info. Thank o . (A endi H)
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22. Timbe a anemic and o ld ha e likel died i ho he in e en ion of ale Glencadia

e onnel and he e cellen and ick ca e of D . Mongil. No mall , e he e a Glencadia
don e c ome hocking me age ch a o e dog i d ing b ha i he
ob io b e of he abo e me age.
23. Glencadia kennel aff ook Timbe o H d on Ve e ina Clinic in H d on NY. Eme genc
ca e co $248 and Plain iff aid he bill on he a m ion ha Defendan o ld eimb e
him fo life- a ing eme genc ca e fo he dog b he did no (A endi I). A e e m
and condi ion , he i e i ed o a hi bill.
24. The claim ha Defendan o hi em lo ee ab ed Timbe i ende ed ab d b he

e idence e ook Timbe o he e and in i ed abo a e io and g o e e g o h on
hi ea , if he e-e i ing condi ion, he nia diagno i , and alle g h o he i a e no
fficien ef a ion of he non en ical allega ion.
25. On Monda , Decembe 14, 2020 Timbe a e ned o Plain iff of a ocia e in he ame
diffic l heal h ci c m ance a hen he a i ed.
26. On F ida , Dec 18, 2020, fo da af e ecei ing Timbe , Plain iff on o e (A endi J)
o Plain iff Glencadia aff, He ho i going Pa icia. Ho e all i going ell. J had a
conce n abo imbe hen I ecei ed him, I nde and he a ick fo a bi and didn ea
m ch. B f om ha I emembe e e e ed ha he ha e ome chicken o ke in o
hi food if he a being bbo n (co ec me if I m ong) Wh did I ge him i h ed ma k
on hi elbo , lo e abdomen, e icle ( i h cab ), ed and c a ch no e and an
looking o e? And hi o e all beha io com le el off like ome hing ha ened. He a
aken o he e befo e boa ding i h o g , and he kne abo hi i e . Tha i m
main conce n, and al o hi d o eigh i ome hing abno mal. I e had him no fo 3-4 da
d ing a an ine beca e of bbo nne . B I a hi ib , and I co ld a m hand
a o nd hi ine. I can end ome ideo of him. B I d j like a f ll de c i ion and
an e ca e ome hing mi ing. Ma be he had an alle gic eac ion o ha , o he dog , o
ome hing in a ail. B I d like o kno . Thank o .
27. Plea e no e, Plain iff on en hi email fo da af e Timbe e ned home. Plain iff
on i n e of h he dog lo eigh and gge alle gie . F he , Plain iff ne e
e e ed e chicken o ke in o hi food and doing o o ld no ha e c ed
life- h ea ening anemia.
28. On Sa da , Decembe 19, 2020, Plain iff o e back o Defendan (A endi K): Hello Jo
Ann, Thank o fo ending Timbe . I e onall a n' he one ho ook him o he e -
Ve n did ha and e ha e he ecei he e. Ca men ho o k i h D . Mongil can al o
eak o o . The condi ion a a he e io - o o e ho gh - and e hed o he
e . He a h o ing and had dia hea. The condi ion abili ed af e e a ed he
medicine b he ne e back on he eigh he lo . I eemed like a e io medical
oblem o me b I'm no e of he diagno i if an . I'm glad Timbe made i home oka .
He al o ha a la ge a a en l benign mo hen he came - no e ha he o i i h
ha ei he . We ill di c and con ac o again. Thank .
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29. On Decembe 21, 2020 Diane Godigkei , a ange fing he in e ne i h no connec ion
o Plain iff o Defendan , e o ed he e i ence of a GoF ndMe cam aign eeking mone
on he ba i of ab e of Timbe hile a Glencadia Dog Cam (A endi J).
30. The GoF ndMe age o iginall con ained he name Glencadia Dog Cam . A a e l ,
a o ima el 12 fal e one- a e ie fo Plain iff b ine a ea ed in o da on
Google Re ie and Yel , ome of hich a e ill i ible a of J ne 1, 2021 (A endi L).
31. Defendan , eali ing ha ing Plain iff name on hei fal e and libelo o ing
emo ed he name Glencadia and enco aged hei follo e o o o ing fal e and
defama o e ie (A endi M).
32. The GoF ndMe and Facebook o ing cam aign i libelo and defama o .
33. On Facebook, Defendan o e, ABUSED AT DOG TRAINING FACILITY, no ho i ali ed.

Timbe en o Glencadia Dog Cam in S e an Fall , fo en da hile m bo f iend
and I e e in he oce of mo ing. Timbe a al ead kno n o ha e c o chidi m,
ba ed on e ea ch done b he famil . Timbe a in good heal h befo e lea ing b
e ned e e da (12/18/20 @10:47AM) and a emacia ed and lo o ghl 12 o nd .
The ke in con ac i h he famil hile Timbe a he e, ho e e , e e no o ided
o e da e on Timbe heal h, and doc men he og e ion of he dog heal h. And
no i ha o en ince hi i i . ( ic)
34. The en i e GoF ndMe age, a of J l 1, 2021, ead :
35. Decembe 30, 2020 b Danielle Infan ino, O gani e . Danielle, Mile and I o ld like o
hank GoF ndMe, and i ' o e , ho follo ed Timbe ' o . Timbe ha had ge ,
and i home, eco e ing, hank o he e e ca e he ecei ed a Long I land Ve
S eciali .We canno hank LIVS, and Timbe ' o e eno gh! The fo m fo
e amina ion of he doc men ed fac and comm nica ion , a) ega ding Timbe ' medical
condi ion, b) hi ca e hile a a f om , c) hi medical a e hen he a e ned o ,
and d) he life a ing medical ca e he ecei ed once back i h , and all ele an e ion
encom a ing he e fac , ill be lef o he ofe ional indi id al and/o o gani a ion
be alified o de e mine, i h ce ain , ha occ edAgain, e a e o g a ef l o o
a hea d. We ill gladl an e an e ion o o gani a ion ha . Thank o ! -Jo Ann
Mille Timbe en o a do a dog cam fo en da hile m bo f iend, Mile and hi
mo he JoAnn, e e in he oce of mo ing. Timbe a al ead kno n o ha e
c o chidi m, hich i hen a e icle doe no de cend. He en o he e fo a o ine
check befo e going o he dog cam . When he e ned back f om he dog cam hi
ima e a going o e fo m a ne e ing. Timbe a in good heal h befo e lea ing b
e ned e e da (12/18/20 @ 10:47am) and a emacia ed. The da befo e lea ing fo
cam he eighed 70lb and hen he e ned he a 54lb . He lo 16 o nd i hin 20
da . The dog cam a e ke in con ac i h Timbe ' famil h o gh e me age .
The dog cam info med Timbe ' famil ha Timbe a ha ing dia hea and omi ing. On
Decembe 10 h he b o gh Timbe o he e e ina ian in a ocia ion i h he dog cam .
The e e ina ian f om a e called Timbe ' famil and aid ha Timbe had an ele a ed
hi e blood co n and ea ed him i h an ibio ic . The e a e e f om he o ne of he dog
7 of 63
cam a ing Timbe a heal h and feeling be e af e he i i i h he e he ook him o.

A no ime a he famil o e l info med of hei dog' de e io a ing heal h a . The
e e o ided b a da e on Timbe ' heal h. The e a n' de ailed em ha i on ha
a going on. If Timbe ' heal h a o oo h a n' he famil no ified immedia el ?
And gi en he dog back o ge o e medical hel ? Timbe ' o ne emailed and called he
dog cam immedia el i h no e on e. The ne mo ning he b o gh him o he e and
a old ha Timbe ha an ing inal he nia (b lging of he bladde ) in addi ion o a e ineal
he nia ( ec m a ea). He a omi ing, had blood ool , and co ld no ina e o defeca e.
Timbe ha b i e and c a e h o gho hi bod . Hi a e e a (he ha hi e hai
in hi a , o i al o doe n' e lain he black hai in hi oo h) and hi no e and li had a
c a e on i . He ha cab on he one e icle ( een in he 4 h image belo ) ha i i ible
on he o ide of hi bod . Timbe e ned home imid, him e ing, and no i h man
heal h conce n ha he did no ha e io o hi a a he dog cam . Timbe ha been i h
hi famil ince he a a 3 eek old and i a e de a a ing o ecei e hei
ee Timbe back in ha condi ion. The an o o ide he be ca e fo Timbe , and an
amo n of f nding and o e e o ce o hel o ld be g ea l a ecia ed. Image 1:
Timbe he nigh he came home o ld no o ea ing. He a emacia ed. Image 2: Timbe
io o lea ing fo he dog cam 70 o nd and m c la . Image 3:Timbe ' no
c a ched hen e ned back f om cam . Image 4: Timbe ' e e e he nia i een he e
hen e ned back f om cam . Image 5:Timbe ' e ineal he nia and c a e on hi
e icle hen e ned back f om cam . Image 6: Timbe ' li e e c a ed and had dog
hai embedded be een oo h and g m hen e ned back f om cam . Image 7: Timbe '
a e e ed, i i a ed and bleeding hen e ned back f om cam . Image 8: Timbe a
he dog cam . Thi a he onl ho o ha a en o hi o ne . A of on o abo
Decembe 20, 2020 he e of he GoF ndMe age a imila , i h he added lang age
Danielle Infan ino need o o
36. The GoF ndMe age con ained he name of he b ine - Glencadia - hen o iginall
bli hed n il Defendan eali ed ha hi migh be libelo (A endi M) and Google
ea ch ill link Glencadia o he o abo e, e en a of J l 1, 2021.
37. Thi a emen a bli hed e e al ime on he in e ne , m l i le Facebook g o and

GoF ndMe.
38. The follo ing elemen of he a emen a e fal e.
a. Defendan a ed, ABUSED AT DOG TRAINING FACILITY, no ho i ali ed.

Timbe en o Glencadia Dog Cam in S e an Fall . Thi a emen i fal e
and Defendan kne he a emen a fal e.
i. Timbe a no ab ed in an a hile a cam . Glencadia aff a ending

o Timbe medical need and indeed ook him o he e , and he famil
comm nica ed i h bo h Glencadia aff and M . Mongil abo he condi ion
of he dog. Defendan did no a he e bill. The ca e of he illne a a
e-e i ing condi ion o ela ed he nia e o ed b Defendan Mille he elf.
The onl e idence Defendan offe of ab e i he lo of eigh , hich i
8 of 63
likel e lained in he e en Th da , Decembe 10, 2020, no ing

dia hea, no ea ing, and li le ne .
ii. Defendan on and/o bo f iend Mile emailed o o o e alle gie a a

ca e of eigh lo io o he blica ion of he a emen abo e.
iii. Defendan a ocia e Mile ne e men ioned an of he o he claimed ign

of ab e ch a c a che o hai in he ee h no ed belo .
i . Defendan e e a a e of an nde cended e icle and he nia io o

o ing he a emen abo e.
. Defendan e e a a e ha Plain iff o ided medical ca e o Timbe o of

ocke hile boa ding a Glencadia and a no e-imb ed.
b. Defendan a ed ha Plain iff onl en Defendan one ho o d ing he 20-da

a . Tha i fal e, a indica ed b he ho o anne ed he e. The e a e h ee
addi ional ho o anne ed o hi com lain .
c. The claim ha ho o e aining o c a che and hai occ ed a Glencadia a e

fal e. Defendan a ocia e Mile ne e claimed an ch condi ion in hi ea lie
email.
d. The a emen If Timbe ' heal h a o oo h a n' he famil no ified

immedia el ? i fal e in ha he famil a con ac ed immedia el , Timbe a
aken o he e , and he o ne did no a fo he e ca e.
e. Defendan a e, The ne mo ning he b o gh him o he e and a old ha

Timbe ha an ing inal he nia (b lging of he bladde ) in addi ion o a e ineal he nia
( ec m a ea). Thi a emen i dece i e and inflamma o , a he e condi ion
ha e no hing o do i h boa ding.
39. The dog emained a Glencadia fo eigh mo e da af e going o he e in Col mbia

Co n . Defendan e e onl abo h ee-ho d i e a a f om he cam and e e no
a eling. The e i no ea on he co ld ha e no come and icked Timbe and aken him
home. Al o, Plain iff offe f ee deli e e ice on Monda and Th da and o ld ha e
e ned Timbe on an of ho e ched led dog an o e , allo ing Plain iff o e ie e he
dog i ho d i ing and a no co .
40. If Timbe con in ed o lo e eigh , ha i o be e ec ed. Plain iff ne e old Defendan ha

he dog had eco e ed o ga -coa ed he e en of he di ea e. If Defendan do no a
fo medical ca e o come collec he dog, hei dog i nlikel o ecei e follo - ca e hile
a he boa ding facili .
41. Defendan a e en i el e on ible fo Timbe heal h condi ion . To claim ha Plain iff had
an ole in Timbe de e io a ing heal h i libelo , defama o , fal e, and Defendan kne
ha he claim a fal e a he ime of blica ion.
9 of 63
42. The GoF ndMe o incl de ho og a h of bill (A endi N). A he e e bill e ain o
ge ched led io o booking he boa ding and a he e l of he nia , fo hich an
ab e allega ion i non en ical (A endi F); o claim ha he e cha ge e e ba ed on
ab e i fal e and Defendan kne ha he claim a fal e on Decembe 20, 2020 and
kno o no b ha e no e ac ed he claim, hich emain bli hed and a ailable o he
blic on GoF ndMe.
43. In a linked oceeding befo e he Na a Co n S eme Co of Ne Yo k, Inde No.

603991/2021 Mille . Pfla m, in he com lain a a ag a h 27, Defendan Mille h o gh
co n el a , In fac , on e amina ion af e hi e n f om Glencadia, b hi eg la local
e e ina ian, Timbe a fo nd o ha e m l i le, ne e -befo e-e e ienced he nia
condi ion , e i ing immedia e ge .
44. The onl e idence of ab e offe ed b Defendan i eigh lo and io and o ed

da ed ho o loaded o GoF ndMe. Ye Defendan ackno ledge he nia and
c o chidi m. An nca a ed, male, 11- ea old i b ll i a oaching he end of hi life
e en i ho he e e-e i ing condi ion . Plain iff con ac ed Defendan abo li le ne
and anemia a cam and aid fo medical ca e o of hi o n ocke ing aff ime o ake
Timbe o he e , a ing he age of he em lo ee o a end o Timbe medical need
a ell. Eigh da ela ed i ho Plain iff aking an e o e ie e he dog de i e a
e o of ongoing li le ne and anemia.
45. The GoF ndMe cam aign e l ed in dona ion of ome $1600 fo Defendan . Mean hile,
he ongoing e i ence of bad Google ea ch e l , and fake one- a e ie on Plain iff
Google e ie , canno b ca e ongoing lo o income. Plain iff e a ion and ea ning
ha e ffe ed hen in fac he a oach of Plain iff and hi aff o he a ea ance of a dog
i h a e-e i ing condi ion a e book e fec , incl ding doc men ing he infi mi ,
con ac ing he o ne , and o iding e ca e a needed.
46. Plain iff con ac ed GoF ndMe man ime o a k hem o ake do n he cam aign and
ecei ed no e on e.
47. On o abo Decembe 20, 2020, JoAnn Mille called he olice. Mille claimed ha Will
Pfla m, m elf, ab ed he dog. She oke o T oo e Somme of T oo K Kinde hook.
48. F he , Defendan on, a no ed abo e, o e, ma be he had an alle gic eac ion. If he

eigh lo migh ha e been d e o a e-e i ing condi ion, o an alle g , acc ing
omeone of c iminal dog ab e fo he ame eigh lo i malicio .
49. O e he co e of a eek in la e Decembe 2020, Defendan and he a ocia ed libeled

and maligned Plain iff and hi b ine , a no ed in a le e o he e (A endi M). She
filed fal e cha ge i h he olice. She, i h he a ocia e , ai ed o e $1600 on fal e
e en e .
50. Plain iff n Glencadia Dog Cam and li e on he ame o e : 3 R bka Road,
S e an Fall , NY 12174. Plain iff hone n mbe and email a e bli hed online. When
T oo e Somme i i ed he i e, he oke fi o Plain iff eenage da gh e . When
10 of 63
intemet hoards inspired by the false Facebook and GoFundMe posts called Plaintiff, those
calls rang on his personal phone.
Conclusion
51. As a proximate result of the above-described publicaUon, Plaintiff has suffered loss of his
reputation, shame, mernñcancñ, and injury to his feelings, all to his damage in $10,000 or, if
the action is brought in superior court, a total amount to be established by proof at trial.
52. The above-described publicati0ñ was not privileged because it was published by defendants
with malice, greed and ill will toward Plaintiff and the desire to make money off of
defendants'
GoFundMe. Because of malice in publishing, Plaiñuff seeks punitive damages in
$1,000,000 if the action is brought in state court, a total amount to be established by proof at
trial.
WHEREFORE, Plaintiff demands judgment against defendants, and each of them, for
Compensatory damagês accciding to proof; Judgement; Punitive damages; interest as anowad by

law; Costs of suit; and Such other and further relief as this court may deem just and proper.
KRISTEN M SCHIFFER
Notary Public, State of New York . ..
Reg. No. 01SC6394591
Qualified In Columbia County . *
Commission Expires July 8, 2023
Will Pflaum, 3 Rybka Road PO Box 40 /

Stuyvesant Falls, NY 12174, 518-470-3981; qlencadia@qmail corn .... .
Att0msy for Plaintiff: Henry R. Kaufman, Henry R. Kaufman, P.C., 60 East 42nd Street, 47th Floo
New York, NY 10165, 914-589-7963, Hkaufman@hrkaufman.com
11 of 63
Index of Appendices
Appendix A: Boarding agreement
Appendix B: Text message screenshots
Appendix C: Email from Patricia Basset warning of shady behavior
Appendix D: Patricia Bassett write up based on conversation with Plaintiff
Appendix E: Message and photos from Vernon Doyle inquiring about Timber's ccñditicñ
Appendix F: Plaintiff admitting a serious pre-existing condition
Appendix G: Cryptorchidism in dogs article
Appendix H: Message advising Plaintiff that her dog was ill
Appendix I: Invoice for hospitalization
Appendix J: Email from Plaintiff's son
Appendix K: Defendant's email to Plaintiff about Timber's ccñdition
Appendix J: Stranger on the internet spots libel campaign
Appendix L: GoFundMe libel, Facebook posts, and fake one-star reviews
Appendix M: Plaintiff's ass0ciate tries to walk back her libel campaign
Appendix N: False financial instruments posted by Plaintiff's associates
Appendix M: Defendant's letter to vet's office
12 of 63
Appendix A: Boarding agreement
13 of 63
M Gmai Will Pflaum <glencadia@gmail.com>
Confirmed Reservation Number 1014211

1 message
support@glencadia.com <support@glencadia.com> Tue, Dec 29, 2020 at 9:46 AM

Reply-To: support@glencadia.com
To: glencadia@gmail.com
Confirmed Reservation Number: 1014211
RESERVATION DETAILS
Glencadia Dog Camp

Columbia County New York, NY 12174 +1 (518) 294-4343 voice +1
(518) 333 9202 text Email: support@glencadia.com
Reservation Ref 1014211
Arrival Date Thursday 3 December 2020
Departure Date Thursday 17 December 2020
Length Of Stay 14
Total Dogs 01
Dogs Names Timber

• Reservation
Extra Services
Service Fee ( Quantity: 01 )
Total Reservation Cost US $ 559.44
Deposit Paid US $ 559.44
Balance To Pay US $ 0.00
Free Pick Up Monday or Thursday

Free pick up (dog goes up to Glencadia) in
Manhattan or Brooklyn (partsof) Monday or
Thursday evening after 6 PM. Sidewalk pick
Pick-Up up/drop off as per conditions. Additional free
pick up and drop off days as per the calendar in
the members area of glencadia.com Pick-Up
Address:229-19 Merrick Boulevard Suite 347,
Laurelton New York, 11413
Free Delivery Monday or Thursday

Free drop off (dog return) in Manhattan or
Brooklyn (parts of) Monday or Thursday
evening after 6 PM. Sidewalk pick up/drop off
Delivery as per conditions. Additional free delivery/pick
up days may be available by checking the
calendar when you book at glencadia.com
Delivery Address:229-19 Merrick Boulevard
Suite 347, Laurelton New York, 11413
DO address is 1034 Arthur Street, Uniondale,

NY 11553. Timber's dad is Miles, phone
Special Request/Comment
718.962.5585. Please text Miles with updates
on his return.
Ms. JoAnn Miller (glencadia@gmail.com)

229-19 Merrick Boulevard Suite 347 Laurelton
Booked By New York, 11413 booking made on 3 December
2020 (09:07)modified on 15 December 2020
(13:00)
Reservation Policies
No Liability
14 of 63
Glencadia Dog Camp accepts no liability for your dog in our care
excepting an act of gross negligence. By sending your dog to
Glencadia, you waiving your right to sue, with the limited exception
above.
Payments
Reservations should be paid half at the time of booking and the other
after when the reservation starts.
Visiting the Camp

Drop off and visiting hours: Tuesday, Wednesday and Friday from 8
AM to 3 PM. Monday, Thursday and Saturday from 9 AM to 12 noon.
Vaccines
AII dogs must have current rabies and bordatella (kennel cough).
Distemper and canine influenza are recommended.
Social Boarding
The philosophy of this model of dog boarding is that the benefits of a
social setting and open space outweigh the increased risk of a fight.
Medicine
If you give
me medicine, keep a couple days worth with you in case I
do forget to bring it back so I can mail it back to you later without a
crisis, or count out what I need for the stay and only give me as much
as I need. Make sure the medicine is in a secure container that a dog
or small child open and clearly
cannot labelled with the name of the
medicine, the of the dog, and the instructions
name for giving the
medicine. You should also put this information into your reservation in
the comments field. Thank you.
Dog food
We offer natural hypoallergenic food - or you can send whatever food
you'd prefer we feed your dog.
Time
Sidewalk pick up/delivery on Monday and Thursday evening is
included with the free van delivery option. Times are estimates.
Dog Stuff
Don't give me anything you want back. Try not to give us anything.
Terms and Conditions

You must agree to Glencadia Camp terms and conditions.
Dog The
venue for any legal action stemming from these terms and conditions
is Columbia County New York.
Dog photography
Images of all dogs at camp are regularly posted online and freely
shared. Glencadia owns the copyright to photos taken by our staff and
unless otherwise agreed, dog owners agree to give us permission to
take and share videos and photos of all dogs.
Individual Boarding
If your dog cannot be left with other dogs at all, please let us know.
Vet Bills
There is a link on the site to an insurance plan if you are interested (we
are not associated with insurance company). Customer responsible for
vet bills regardless of cause of vet visit.
Privacy
We do not share or sell your contact info with anyone. Glencadia
agrees not to provide any information about you or your dog to anyone
without your permission. Privacy policy posted online.
15 of 63
No Aggressive Dogs
Routinely or habitually aggressive dogs are not allowed at Glencadia
Dog Camp. If your dog has aggression issue, you must tell us about
his or her behavioral issues.
Payments are Final

AII credit card charges and other forms of electronic payments are final
and there will be no chargebacks. This agreement means internal
charge dispute procedures of financial institutions do not pertain and
are not available for this transaction and
any dispute in terms of
payments may only be settled as per the conditions above consistent
with the law in the Town of Stuyvesant Columbia County, and New
York State as determined in a court of law.
Definition of Boarding
Boarding means we housed the dog. If we housed the dog for more
than eight hours or transported the dog in the van for any distance, we
have housed the dog as per the definition and a stay has occurred.
Definition of negligance
The standard of gross negligence is under New York State law and by
common agreement here Sommer v. Federal Signal Corp., 79 N.Y.2d
540, 554 (1992).
16 of 63
Appendix B: Text message screenshots
17 of 63
Jo Ann TIMBER
Will v
718 736 3679
https://www.glencadia.com/our-
Message sent from
members/
Hello. I would like to board Timber long term. I had seen a
cost of $500. Please clarify what rate for long term. I
definitely need December 3rd thru January 2nd. Thank
you.
11:25AM
Hi Jo. Evenings and weekends it

may take a little longer
for us to get back to you. We will be with you as soon as
we can. Thanks for contacting Glencadia.
11:25 AM
Thank you.
11:26 AM
Thank you for writing Jo Ann.
18 of 63
Appendix C: Email from Patricia Basset warning of shady behavior
19 of 63
Will Pflaum <glencadia@gmail.com>
Re: Timber
1 message
Will Pflaum <glencadia ymuii.com> Mon, Dec 21, 2020 at 11:51 AM

To: Patricia Bassett <patricia@glencadia.com>
Noted! We will never let in a red flag again!
Will Pflaum
will@glencadia.com
glencadia@gmail.com
Glencadia Corp.
42 Tiemann Place, Suite 204, New York, NY 10027
3 Rybka Road, PO Box 40, Stuyvesant Falls, NY 12174
+1 (518) 294-4343 voice
+1 (518) 333 9202 text
http://glencadia.com
On Mon, Dec 21, 2020 at 11:36 AM Patricia Bassett

<patricia@glencadia.com> wrote:
>
> I red flagged this from the first phone call because she was dishonest and the dog was being picked up at a Vet's. I
spend time on the phone to make sure everything is kosher, and when it's not, I let you know right away. Please, please
trust me and let's just say no to these troubled cases. This woman was a con artist but tried to sound so nice. If you lie,
you have something to hide. We just don't need these kinds of people's money if they are going to try to ruin our
reputation. Sorry, this
is my two cents because it upsets me when I know something doesn't feel right from the beginning
and it ends up a disaster. I'm sorry this happened.
>
> On Sun, Dec 20, 2020 at 2:41 PM Will Pflaum <glencadia@gmail.com> wrote:
>>
>> The lady with timber is on a roll posting nutty stuff on Instagram and sending messages everywhere. Keep an eye on
Facebook for malicious stuff please and remove as soon as possible. Thanks--
>> Sent from Gmail Mobile
>
>
>
> --
> Patricia B
> Administrative
> Glencadia Dog Camp
> patricia@glencadia.com
20 of 63
Appendix D: Patricia Bassett write up based on conversation with Plaintiff
21 of 63
Will Pflaum <glencadia@gmail.com>
****SPECIAL INSTRUCTIONS***TIMBER (PITBUL-11 YRS OLD)

1 message
Patricia Bassett <patricia@glencadia.com> Thu, Dec 3, 2020 at 3:15 PM

To: Will Pflaum <support@glencadia.com>
TIMBER IS NOT NEUTERED
Timber does not always socialize well with other dogs. His respónse varies depending on gender and/or the number of
dogs.
We are requesting that his interactions be initially limited so his behaviors can be evaluated.
He is bonded to my son, Miles, and has been the only dog in our home for 11 years.
Thank you for your guidance.
Yea the only concerns for socializing him, would be to muzzle him and have him around dogs his size or larger.
He won't be use to that amount of dogs being around him, kind of like an antisocie! child in a sense.
He's not too fond of smallsr dogs though. But the trend with him is bigger female dogs. He won't show any
aggressicñ towards them, or large dogs with calm demeanor.
This dog is only supposed to be here for two weeks...but the owner just told me today it's because of the living situation
and that she is trying to find a new home.
Patricia B
Administrative
Glencadia Dog Camp
patricia@glencadia.com
22 of 63
M Gmai Will Pflaum <glencadia@gme!! com>
Re: inquiry closed but still needs attention

1 message
Patricia Bassett <patricia@glencadia.com> Mon, Nov 30, 2020 at 11:22 AM

To: Will Pflaum <glencadia@gmail.com>
I called her. She's going to book for a month for Timber starting this Thursday at the $700/m0ñth. But this elder pit bill is
not necessarily good at socializing and can be unpredictable at times.
On Mon, Nov 30, 2020 at 7:41 AM Will Pflaum <glencadia@gmail.com> wrote:

timber chekkit
Patricia B
Administrative
Glencadia Dog Camp
23 of 63
Appendix E: Message and photos from Vernon Doyle inquiring about Timber's condition
24 of 63
IMG-2248.jpg
12.2MP 4032 × 3024 1.2 MB
Apple iPhone 8 Plus

f/1.8 1/120 3.99mm ISO50
f.., Uploaded from web browser
Home (D
stu vesant
.
25 of 63
IMG-2249.jpg
12.2MP 4032×3024 1.5MB
Apple iPhone 8 Plus

. f/1.8 1/120 3.99mm ISO50
1 Uploaded from web browser
HomeQ
Stuyvesant
26 of 63
× Info
Add a description
DETAILS
Dec 4, 2020
Fri,1:08PM GMT-05:00
>
IMG_3998.JPG
12.2MP 4032×3024 2.7MB
Apple iPhone 8 Plus

f/1.8 1/120 3.99mm ISO50
'
, Uploaded from iOS device
f..,
Home (D
27 of 63
Appendix F: Plaintiff adrñitting a serious pre-existing condition
28 of 63
Jo Ann TIMBER
718 736 3679

W/// v
Q b
Fri Dec 04 2020
Patricia Bassett assigned this conversation to Will
Hi Joann I'm reaching out for a little more info on Timber,
can you please tell us what's going on around his
stomach area?
Vern Doyle 1:22 PM
Hi, he has a cryptorchid, an inverted testicle. It is not
painful, but will require a complicated neuter procedure.
His Veterinary, Central Veterinary, 73 West Merrick Road,
Valley Stream, 11580, just assessed him for surgery.
1:29 PM
29 of 63
Appendix G: Cryptorchidism in dogs article
30 of 63
We are committed to caring for your pet - while

maintaining
X
the highest level of safety for our Associates and pet owners.
Face coverings/masks are required at all of our U.S.
hospitals. We thank you for your continued patience and
support. Learn more about our COVID-19 response and
guidelines.
Retained Testicle (Cryptorchidism) in Dogs
By Ryan Llera, BSc, DVM; Robin Downing, DVM, CVPP, CCRP, DAAPM, Ernest Ward,
DVM | Medical Conditions, Surgical Conditions, Pet Services
What is cryptorchidism?
Cryptorchidism is the medical term that refers to the failure of one or both testicles
(testes) to descend into the scrotum. The testes develop near the kidneys within the
abdomen and normally descend into the scrotum by two months of age. In certain
dogs it may occur later, but rarely after six months of age. Cryptorchidism may be
presumed to be present if the testicles cannot be felt in the scrotum after two to four
months of age.
If the testicles aren't in the scrotum, where are they?
In most cases of cryptorchidism, the
testicle is retained in the abdomen or in etai d esticle
the inguinal canal (the passage through

Inguinal canal
the abdominal wall into the genital
region through which a testicle Position of

normally
decended testicle
descends). Sometimes the testicle will be
located just under the skin (in the
ci nbri stanoni ic ticci noc in the ornin
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features and to analyze our traffic. See our p_rivacy_p_ojjcy. You can use
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31 of 63
In cases of abdominal cryptorchidism, the testicle cannot be felt from the outside.
Abdominal ultrasound or radiographs (X-rays) may be performed to determine the
exact location of the retained testicle but this is not often done before surgery as it is
not required to proceed with surgery. Typically only one testicle is retained, and this is
called unilateral cryptorchidism.
If you have a dog that does not appear to have testicles but is exhibiting male
behaviors, a hormonal test called an hCG stimulation test can be performed to see if
he is already neutered. Even simpler, your veterinarian can check for penile spines
which are dependent on testosterone and will disappear 6 weeks after neutering.
What causes cryptorchidism, and how common is it?
Cryptorchidism occurs in all breeds, but the toy breeds, including toy Poodles,
Pomeranians, and Yorkshire Terriers, are at higher risk. Approximately 75% of cases of
cryptorchidism involve only one retained testicle while the remaining 25% involve
failure of both testicles to descend into the scrotum. The right testicle is more than
twice as likely to be retained as the left testicle.
Cryptorchidism affects approximately 1-3% of all dogs. The condition appears to be
inherited since it is commonly seen in families of dogs, although the exact cause is not
fully understood.
What are the signs of cryptorchidism?
This condition is rarely associated with pain or other signs, until or unless a
complication develops. In its early stages, a single retained testicle is significantly
smaller than the other, normal testicle. If both testicles are retained, the dog may be
infertile. The retained testicles continue to produce testosterone but generally fail to
produce sperm.
infertile."
"If
both testicles are retained, the dog may be
One complication of cryptorchidism is spermatic cord torsion (twisting onto itself). If

.. . .. ... . . . . ... . . . . . . . . . .
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32 of 63
Neutering and removal of the retained testicle(s) are recommended as soon as
possible. If only one testicle is the will have two incisions - one for
retained, dog
extraction of each testicle. If both testicles are in the inguinal canal, there will also be
two incisions. If both testicles are in the abdomen, a single abdominal incision will
allow access to both.
What if I don't want to neuter my dog?
There are several good reasons for neutering a dog with cryptorchidism. The first is to
remove the genetic defect from the breed line. Cryptorchid dogs should never be
bred. Second, dogs with a retained testicle are more likely to develop a testicular
tumor (cancer) in the retained testicle. Finally, dogs with a retained testicle typically
develop the undesirable characteristics associated with intact males like urine
marking and aggression.
"The risk of developing testicular cancer is estimated to be at least
ten times greater in dogs with cryptorchidism than in normal

dogs."
The risk of developing testicular cancer is estimated to be at least ten times greater in
dogs with cryptorchidism than in normal dogs.
What is the prognosis for a dog with cryptorchidism?
The prognosis is excellent for dogs that undergo surgery early, before problems
develops in the retained testicle. The surgery is relatively routine, and the outcomes
are overwhelmingly positive.
Contributors: Ryan Llera, BSc, DVM; Robin Downing, DVM, CVPP, CCRP, DAAPM, Ernest
Ward, DVM
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33 of 63
Appendix H: Message advising Plaintiff that her dog was ill
34 of 63
Jo Ann TIMBER
Will
718 736 3679
Thu Dec 10 2020
Hello Jo Ann. Timber seemed sick today and went to the
vet. He had diarreah, didn't eat breakfast, and was
listless. In the afternoon we decided to go the vet. The
vet found elevated white blood cells and he's on
anitbiotics. We'll keep you updated but he does seem a
little better this evening. He's just not doing well. I can put
you in touch with the vet for more info and I will email you
the receipt with some diagnostic info. Thank you.
Will6:18 PM
Hello, and thank you for looking after him . I would like to
speak with the Vet please. I am at work this evening until
11 pm, but am available in the morning until 11 am. Thank
you.
6:31 PM
35 of 63
Appendix I: Invoice for hospitalization
36 of 63
263 FAIRVIEW AVE Glencedia 263 Pa|rv6w Ave

Dog Camp
HUDSONNY 12534 PO Box 40 NY
Hudson,
518-671-600s Stuyvesant, NY 12174 12534
(518) 470-3981 United States
Terminal ID: h761 m4
--------------..--------..-------- (518) 671-6000
12/10/20 4: 83 PM ---____ _ _____ --------.. ...
Discover Credit - INSERT
AID: A8888881523818
ACCT s: *_S7g3
cadia Dog Camp
CREDIT SALE
UID: e34519149475 REF 8: 8382
BATCH 3: 597 AUTH s: 81829P
19936
$248.89 12/10/2020 4:04 PM
APPROVED $248.00
ARQC - 82 16 14CSA6BE5153
Discover $248.00
pgg;cgDUE
TO LEGAL RESTRICTIONS
Last 4 of Credit Card:
IPTIONS CAlelDT BE RETURMED
5703
CUSTOMiR COPY Kody P.
, Invoice Number 19645

Date 12/10/2020
Patient Provider Description Date Quantity Subtotal Tax Total
Mon
Timber Urgent Care Exam 12/10/2020 1 $75.00 $0.00 $75.00
Bêmardo Mongil, Complete Blood Count (CBC) -

12/10/2020 1 $35.00 $0.00 $35.00
D.V.M. Abaxis
Bemardo Abaxis - Comprehensive Diagnostic
Mongil, 12/10/2020 1 $60.00 $0.00 $60.00
D.V.M. Profile
Bemardo Mongil,
Timber Penicillin Inj 12/10/2020 1 $20.00 $0.00 $20.00
D.V.M.
Bemardo MongH'
Timber Ondansetron Inj 12/10/2020 5 $25.00 $0.00 $25.00
D.V.M.
Bemardo MongH· Metronidazole Tablets
Timber 500mg 12/10/2020 20 $18.00 $0.00 $18.00
Bemardo Mongil, Capsu!es 12/10/2020

Timber Amoxicillin 500mg 14 $15.00 $0.00 $15.00
D.V.M.
Subtotal $248.00
Tax $0.00
Invoice Total $248.00
Paid in Transaction $248.00
Paid to Date $248.00
Amount Remaining $0.00
37 of 63 Page
Appendix J: Email from Plaintiff's son
38 of 63
M Gmail Will Pflaum <glencadia@gme!!.com5
Fwd: Timber Miller

1 message
Patricia Bassett <patricia@glencadia.com> Fri, Dec 18, 2020 at 5:06 PM

To: Will Pflaum <will@glencadia.com>, Vern <vern@glencadia.com>
Timber inquiry.
---------- Forwarded message ---------

From: Miles Miller <milesmiller15@gmail.com>
Date: Fri, Dec 18, 2020 at 2:53 PM
Subject: Timber Miller
To: <patricia@glencadia.com>, Jo ANN Miller <jm92971654@gmail.com>
Hey how's it going Patricia. Hope all is going well.
Just had a cchcêm about timber when I received him, I understand he was sick for a bit and didn't eat much. But from
what I remêmbêr we requested that he have some chicken or turkey put into his food if he was being stubbom (correct me
if I'm wrong)
Why did I get him with red marks on his elbows, lower abdcmêñ, testicles (with scabs), red and scratchy nose and anus
looking sore? And his overall behavior completely off like samêthing happened. He was taken to the vet before bcarding
with you guys, and they knew about his issues.
That is my main concern, and also his drop weight is somêthing abnormal. I've had him not for 3-4 days during quarantine
because of stubbomness. But I saw his ribs, and I could wrap my hands around his spine.
I can send some videos of him. But I'd just like a full descriptich and answer cause somethings missing. Maybe he had an
allergic reaction to hay, other dogs, or something in a trail. But I'd like to know.
Thank you.
__
Patricia B
Administrative
Glencadia Dog Camp
39 of 63
Appendix K: Defendant's email to Plaintiff about Timber's condition
40 of 63
M Gmail Will Pflaum <glencadia@gme!!.com>
Re: Timber Miller

1 message
Will Pflaum <glencadia@yinaii.com> Sat, Dec 19, 2020 at 5:16 PM

To: Patricia Bassett <patricia g!encadia.com>, Jo ANN Miller <jm92971654@gmail.com>, milesrailler15@gmail.com, Vern
<vern@glencadia.com>
Hello Jo Ann,
Thank you for sending Timber. I pmuonally wasn't the one who took him to the vet - Vern did that and we have the receipt
here. Carmen who works with Dr. Mongil can also speak to you. The ccñditicñ was rather serious - or so we thought - and
we rushed to the vet. He was thr0wing up and had diarrhea. The condition stabilized after we started the medicine but he
never put back on the weight he lost. It seemed like a serious medical problem to me but I'm not sure of the diagncsis if
any. I'm glad Timber made it home okay. He also has a large apparently benign tumor when he came - not sure what the
story is with that either.
We will discuss and contact you again. Thanks.
On Sat, Dec 19, 2020 at 12:52 PM Patricia Bassett <patricia@glencadia.com> wrote:
---------- Forwarded message ---------

From: Miles Miller <milesmiller15@gmail.com>
Date: Fri, Dec 18, 2020 at 2:53 PM
Subject: Timber Miller
To: <patricia@glencadia.com>, Jo ANN Miller <jm92971654@gmail.com>
Hey how's it going Patricia. Hope all is going well.
Just had a concern about timber when I rêcêivêd him, I understand he was sick for a bit and didn't eat much. But from
what I remember we requested that he have some chicken or turkey put into his food if he was being stubborn (correct
me if I'm wrong)
Why did I get him with red marks on his elbows, lower
abdomen, testicles (with scabs), red and scratchy nose and anus
looking sore? And his overall behavior c0mpletely off like something happened. He was taken to the vet before
boarding with you guys, and they knew about his issues.
That is my main scncêrn, and also his drop weight is something abnormal. I've had him not for 3-4 days during
quarantine because of stubbumness. But I saw his ribs, and I could wrap my hands around his spine.
I can send some videos of him. But I'd just like a full descripticñ and answer cause somethings missing. Maybe he had
an allergic reaction to hay, other dogs, or something in a trail. But I'd like to know.
Thank you.
__
Patricia B
Administrative
Glencadia Dog Camp
41 of 63
Appendix J: Stranger on the internet spots libel carnpaign
42 of 63
M Gmai
Slander on FB!!!
1 message
Diane Godigkeit <dg0digkeiiGymuii.com> Mon, Dec 21, 2020 at 7:25 PM

To: support@glencadia.com
Please excuse any typos, this was sent from my iPhone and I have fat fingers:)
image0.png
1529K
43 of 63
Appendix L: GoFundMe libel, Facebook posts, and fake one-star reviews
44 of 63
Glencadia
"a--
Dog Camp
972F+XP, Stuyvesant Falls, NY
4.7 ****9 136 reviews
Robert Gill
1 review
* 5 months ago
Found an article -Upstate Glencadia more like Hound three distraught owners-
Dog Camp Hell, say dog
when researching. This article appeared in the Daily News and I don't think it seems like a good option
at all. Buyer Beware. Research!
IA 2
Response from the owner 4 months ago
Spam. Fake. Disregard. This perscñ is not a customer. The reviewer does not even claim to be a
customer. We maintain a database of customers and this person has no personal experience of our
services. Concerted extortion and fraud campaign. ... More
45 of 63
Glencadia Dog Camp

na-
4.7 ****9 136 reviews
O
Alexandra Rezler
1 review
* 5 months ago
DO NOT BRING YOUR DOG HERE. Read Timber's story! They abused and ñêg!êcted him for 20 days.
He lost 12 Ibs and was skin and bones, had raw paws and a scratch on his nose, a rectal and bladder
hernia which needs emergent surgery. DO NOT BRING ANY ANIMAL HERE.
gÈ 3
Spam. Fake. Disregard. Not a real review. This person is not a customer. Fake. The reviewer does not
even claim to be a customer. We maintain a database of customers and this perscñ has no parscñâi
experience of our services. This review ... More
46 of 63
Glencadia
"a--
Dog Camp
4.7 ****9 136 reWews
O
melissa tardi
3 reviews
* 5 months ago
Critical: Professionalism, Quality, Reliability, Value
Spam. Fake. Disregard. This persoñ is not a customer. Please disregard this fake review. The reviewer
does not even claim to be a customer. We ma|ñta|ñ a database of customers and this person has no
personal experience of our services. This ... More
Edit
47 of 63
google...com-
timber g|êñcadia × 4 Os
https://www.gofundme.com > dog-abused-in-dog-camp... i
Fundraiser by Danielle Infantino : Dog abused at dog camp ...
Dec 19, 2020 - Timber has had surgery, and is home, recovering, thanks to the expert care he
received at Long Island Vet Specialists. We cannot thank LIVS, ...
You've visited this page 3 times. Last visit: 5/18/21
48 of 63
.u cricket Wi-Fi 9 4:36 PM 1 75%
Facebook today.
or
Log In
9
Animal Rescue Network of Long Island
December 20, 2020 at 7:57 PM
ABUSED AT DOG TRAINING FACILITY, now

hospitalized.
Timber went to Glencadia Dog Camp in Stuyvesant
Falls, for twenty days while my boyfriend and his family
were in the process of moving. Timber was already
known to have cryptorchidism, based on research
done by his family. He went to the vet for a routine
checkup before going to Glencadia Dog Camp. Timber
was in good health before leaving but returned
yesterday (12/18/20 @ 10:47am) and was emaciated
and lost roughly 12 pounds. They kept in contact with
his family while Timber was there, however, were not
provided proper updates on Timber's health, and
document the progression of the dogs health. And how

it has worsen since his visit.
49 of 63
. cricket Wi-Fi 9 12:33 PM 198%B

-
Infantino lango (@deemarie2820)
Facebook > public > Danielle-Infant...
Danielle Infantino Profiles | Facebook
View the profiles of people named Danielle
Infantino. Join Facebook to connect with Danielle
Infantino and others you may know. Facebook
gives ...
nie GoFundMe > dog-abused-in-dog-ca...
Fundraiser by Danielle Infantino :

Dog
abused in
day camp needs ...
Dec 2020 - Timber went to Glencadia

18, Dog
Camp in Stuyvesant Falls, for twenty ... Danielle
Infantino needs your support for Dog abused in ...
LM LIM College > info > author > danie...
-
Study Abroad Blog | Danielle Infantino
LIM College Blogs
I looked out the window of the

"
airplane thinking: Am I really
home? "Where did the last five
... posted 4 years ago by
Danielle Infantino ...
50 of 63
.u cricket Wi-Fi 9 6:02 PM 78%
Angela Beck (2 doesn't ...
recommend Glencadia dog

camp.
1h ·
0
STAY AWAY! This place abuses canines. If you
google Glencadia and abuse you will find the news
articles and GoFundMe pages for dogs that have
been severely abused and neglected. I personally
know someone who had their dog neglected and
starved there. I'm surprised they are still in
business and they should be investigated!
[Ò Like Q Comment Ñ Share
You're now interacting as yourself.
51 of 63
.u cricket Wi-Fi 9 10:50 AM 1 75% l_)
Catherine Gerbasi (2 doesn't ...
recommend Glencadia dog

camp.
49m ·
0
A friend sent her dog here and he came back in
dire condition, needing lifesaving surgery. Lots of
yelp reviews stating the same thing happens to
them!!! Do not use this service!!!!
https://www.gofundme.com/f/dog-abused-in-day-
camp-needs-lifesaving-surgery?
utm_source=fb-copy_link&utm_medium=social&ut
m_campaign=p_cp+share-sheet
at m ,s 9:50 AM 1 28 8
ValT,
( Back Reviews
Ourdoglost15pounds overtwoweeks at
GlencediaXmasUnacceptabio I tookhertothe
vetabout4 daysbeforefora spayingconsultation
andshewasweghedP£kedheruptwoweeks
laterandshewaswornsomely tNn,herharness
wascompletesyslackaroundherbody Wetook
go ome as nig an e was happy,hea y an hertothevetafterthreedaysofabschite lethargy
TIRED! So much better than him in the wsoa"vavenh*hea~9vo*ª"d"'ev'aa
boarding city shehadlost15%ofherbodyvaeghtandputheron
while we were for a week. He's a big goof who "vd"a
away
loves to run and and he definitely had a blast... y dogin y s fed/
play eating thatseemsprettybamc
Atter18daysatGlencadia.ourdog.Cah.Lostover
12%ofherbodyweghtHerhipbones,ribs,and
shoulderbladeswereshock·ngly andher
visably,
'"°°'å?‡'n°°'d's%* ;**c'"''
Our dog lost 15 pounds over two weeks at Glencadia ‡"°"17 y'f *Tw"°g
°aTngio"w°n','E"''e"°®
Xmas. Unacceptable. I took her to the vet about 4
"®° "
days before for a spaying consultation and she was
weighed. Picked her up two weeks later and she
was worrisomely thin, her harness was completely ...
c hev.m f eatry orv·rWt bemgfod
Peony M. W uh
9w m.m .vonderfu veviewsthat
thatUmyfedhe
Re-v1ewsGlencadmDogCamp ril
You're now interacting as yourself.
52 of 63
.u cricket Wi-Fi 9 7:00 AM 1 100% Lif)
Eliana Julie Vatip Powell
Eliana Julie Vatip Powell
VIEW PROFILE
7:00 AM
Shame shame shame on you.
Don't run a dog camp and let
people's dogs get hurt. I hope
it shuts down.
This person is unavailable on Messenger.
More options
53 of 63
. cricket Wi-Fi 9 11:09 PM
8 people donated.
Ñ Share
"*
Miles M Miller
Dec 20, 2020 ·

0
This is the info for Timber, if anyone can help in
anyway or atleast share. That would be super
appreciated
1
This content isn't available right now
When this happens, it's usually because
the owner only shared it with a small
group of people, changed who can see it
or it's been deleted.
1 2 Shares
[Ò Like Q Comment Ñ Share
"*
Miles M Miller updated his status.
Dec 20, 2020 ·

0
This content isn't available right now
When this happens, it's usually because
the owner onlv chared it with a cmall
54 of 63
Appendix M: Plaintiff's associate tries to walk back her libel campaign
55 of 63
M Gmai ·®a-- ->
Timber update
1 message
Bobbi Daury <thedaurys1@gmail.com> Mon, Dec 21, 2020 at 12:07 PM

To: Will Pflaum <g|êñcadia@gmail.com>
Tina kingship posted...
ORIGINAL POST DELETED; REPOST WITH UPDATE:
Thank you all for your concern about Timber. He is going into surgery as we speak as per a phone call with the surgeon.
The astimate is upwards of $8k, which we can prove once the vet sends it over. The family has one ask of all of us at this
point: PLEASE DO NOT REACH OUT TO THE CAMP. Do not mention their name any longer in the comments, do not
leave reviews on Yelp or Google or Facaback. As you can imagine, the family was in absolute panic mode this weekend,
and now that they have a second to breathe, are trying their best to go about this in a way that will not hurt them in a legal
sense going forward. Please, let's do this for Timber, all the dogs who the camp has hurt before, and to protect future
families from being hurt.
Please keep an eye on Timber's GoFundMe page, as that is where the family will be posting updates the quickest.
https://www.gofundme.com/f/dog-abused-in-dog-camp-needs-lifesaving-surgery?utm_source=
customer&utm_medium=copy_Iink&utm_campaign=p_cf+share-flow-1&fbclid=IwAR33A_
14MKtvzDFsWFB7sjeQryKvxrtYWmWEciUd5e_g-b299r9plchlzmE
56 of 63
Appendix N: False financial instruments posted by Plaintiff's associates
57 of 63
Veterinary Referral & Emergency Center of Westbury

'
609-5 Cantiague Rock Road| Westbury, NY 11590| (516) 420 - 0000
Brittany Sylvane, DVM | Date: 12/19/2020 at 16:19 | Invoice: 744670742 | Cashier: Ashling C
Ont PAtlENt
Timber (#88826)
Species: Canine (Terrier, Pit Bull)
Sex: Male Intact | Color: Brindle
Birth: 12/19/2011 | Age: 9y | Weight: 24.6 kg
M
Demned Visit Information
Date Description Qty Price Tam Total Price
12/19/2020 Emergency Exam 1.00 $180.00 $0.00 $180.00

Ultrasound FAST Test 1.00 $110.00 $0.00 $110.00
Urinary Catheter Place indwelling(not 1.00 $75.20 $0.00 $75.20
obstructed)
Subtotal: $365.20
ame•ame-v
Patient Name Total Price Total Tan Total Due
Ÿlmber $365.20 $0.00 $365.20
58 of 63
Mr
. 8 yearsand 5 montItsokl
Pirbull
BRINDLE
079558
Date Code Description Emp. Qty Price

Office Visit - Emergency V8KD 1.00 r,n S 20%
Hospitalization - Canine/Feline VSKD 1.00 rur p., S 215,00
555
L . Medical Waste Disposal Inputient VSKD 1.00 ,-.w S 9.00
P410
d 0 intensive care unit - Level 1 (Add On)
$1552 VSKD 1.00 n.n,, S 186.00
E Superchem w/CBC VSKD 1.00 a,n S 247.
- Preanesthetic/Prooperative
P451 ECG VSKD 1.00 s... S 89.
Blood Pressure Evaluation VSKD 1.00 r S 42.00
P417
50mg/ml (Carprofen) 31-60Ibs
M32071 RImadyl inj VSKD 2.40 m,, S 58.00
H Panacur Deworm VSKD 1.00 e., S 28.00
Lactulose 10g/15ml
M460412 H VSKD 1.00 ,a,, S 6.00
H Cefazolin inj 100mg/mI 31-60Ibs VSKD 5.40 ,4,, 5 52.00
. H Lactulose 10g/15rnI VSKD 1.00 mmo S 6.00
H Metronidazole Inj Smg/mi 31-60the VSKD 80.00 -ve S 58.00
172
Unasyn 30mgfmi VSKD 26.s0 -no S 186.00
M303411
H2107 IV catheterization VSKD 1.00 Fork $ 135.00
Total for Timber: $ 1,672.00
g IberineDiller - VSKD Total Invoice: $ 1.672.00
Oedt Belamoe S 1,672.00

Total Payments - Thank you: 1 672.00
y
59 of 63
Date Descrlotion Low Qty Hioh Qty Low Price Hieh Price
Consumenon (IH ) - Surgery I 00 1 00 $ 0 00 $ 0 00
Perineal Hernia - Lev 3 I 00 1 00 $ 1.252 00 $ 1.164 00
Prooperanve RA•dcanone t00 1 00 $ 95 00 S 95 00
Inducson i 00 1 00 $ 110 00 $ 110 00
Anesthesia - General 1 00 1 00 $ 240 00 $ 240.00
Patient Recovery (General) I 00 1 00 $ 221 00 $ 221.00
Peripheral N Catheter Placement 1 00 1 00 $ 94 00 $ 94 00
W Flulde - Level 3/day I 00 1 00 $ 183 00 S 183 00
N Fluid Purnp per day 1 00 1 00 S 30 00 $ 30.00
Fluid Administramon Sol 1 00 1 00 $ 56 00 $ 56 00
EKO AAonitor (Introoperauve) 1 00 1 00 $ 104 00 $ 104 00
Pulso Oximetry (Introoporouvel 1 00 1 00 $ 104 00 $ 104 00
oR usage#Equip Sterdsamon - Lev. 2 I 00 1 00 $ 386 00 $ 386 00
stood Preneure asonnor (Introoperanve) I 00 1 00 $ 145 00 $ 145 00
Analgoalce - Level 3/dey I 00 1 00 S 137 00 $ 137 00
C•pneseain cape soo me Capeu*e 30 00 30 00 S 35 50 $ 35 50
Comiurt Conar - Large I 00 1 00 S 69 00 $ 69 00
Epidural Analgeola 1 00 1 00 $ 179 00 $ 179 00
Hospitalization - Level 3 per day 2 00 3 00 $ 479 00 $ 718 00
teedcallone S Suppmee (General) - Lev 3 2 00 3 00 $ 429 00 $ 643 00
atedcal Waste Fee 2 00 3 00 $ 37 00 $ 55 00
Clear FHm Oreening 3.8* m8" I 00 1 00 S 4 1 00 $ 41 00
Inguinal Hernia - Lev 3 1 00 1 00 $ 1.072 00 $ 1.072 00
Retained Inguinal Teeuc (Canine) - Lv 3 I 00 1 00 $ 631 00 $ 631 00
stopsy wanicroecepic Desertp (1 Satel 1 00 1 00 $ 307 50 $ 307 50
tsaropitant Inj per mL (to mghnL)4H 2 70 5 00 $ 77 50 $ 143 50
Ultrasound - hat 1 00 1 00 $ 424 00 $ 424 00
aseen Graft - Sman pm4) n no 1 an S 0.00 S 224.00
Total for Timber : S 6.938 50 S 7.611 50
son ,i ny ingp a is sy Total Invoice: S 6.938.50 S 7.611.50
60 of 63
Veterinary Referral & Emergency Center of Westbury

'
609-5 Cantiague Rock Road| Westbury, NY 11590| (516) 420 - 0000
Brittany Sylvane, DVM | Date: 12/19/2020 at 16:19 | Invoice: 744670742 | Cashier: Ashling C
GRt PAtlGMt
Timber (#88826)
Species: Canine (Terrier, Pit Bull)
Sex: Male Intact | Color: Brindle
Birth: 12/19/2011 | Age: 9y | Weight: 24.6 kg
M
98tnNad Visit Informall00
Date Description Qty Price Tam Total Price
12/19/2020 Emergency Exam 1.00 $180.00 $0.00 $180.00

Ultrasound FAST Test 1.00 $110.00 $0.00 $110.00
Urinary Catheter Place Indwelling(not 1.00 $75.20 $0.00 $75.20
obstructed)
Subtotal: $365.20
Patient Name Total Price Total Tam Total Due
Timber $365.20 $0.00 $365.20
61 of 63
Appendix M: Defendant's letter to vet's office
62 of 63
M Gmai a
Timber
1 message
Will Pflaum <glencedia@gmail.com> Mon, Dec 21, 2020 at 10:16 AM

To: Hudson Veterinary Clinic <hudsóñveterinaryclinic@ginail.com>, Vern <vern@g|êñcadia.com>, milesmiller15@ginail.com,
Jo ANN Miller <jm92971654@gmail.com>
Hello Carmen,
The owner of Timber sent us the dog with some kind of pre-existing
"abuse."
condition like cancer and is now attempting to fundraise off
She is also getting all her friends to downvote us on Google and
Facebeek. As you know, we brought the dog immediately to the vet after
arriving from the city.
Can someone try to explain to the owner that we did nething wrong? We
took the dog to the vet immediately? There is some kind of
pre-existing condition that is causing anemia?
https://www.gofundme.com/f/dog-abused-in-day-camp-needs-lifesaving-surgery?utm_source=
customer&utm_medium=copy_Iink&utm_campaign=p_cf+share-flow-1&fbclid=IwARODooOK6RPC5e-
9WIFuEZrN4Ml362vo7slivW-msHU985tM3afO66J2IM8
718 736 3679 Jo Ann Owner

718 962 5585 Boyfriend Miles
Thank you Carmen... no fun be libeled all over the internet, as you can imagine.
Will Pflaum
will@glencadia.com
glencadia@gmail.com
Glencadia Corp.
+1 (518) 294-4343 voice
+1 (518) 333 9202 text
http://glencadia.com
63 of 63

E012021017008 William E Pflaum V Joann Miller Et Al COMPLAINT AMENDED 5

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E012021017008 William E Pflaum V Joann Miller Et Al COMPLAINT AMENDED 5

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FILED: COLUMBIA COUNTY CLERK 07/02/2021 11:42 AM INDEX NO.

STATE OF NEW YORK SUPREME COURT COUNTY OF COLUMBIA

JoAnn Miller : Index number:

Attomey for Rieliftiff Henry R. Kaufman, Henry R. Kaufman, 60 East 42nd

STATE OF NEW YORK SUPREME COURT COUNTY OF COLUMBIA

2. P ni i e damage ; In e e a allo ed b la ; Co of i ; and S ch o he and f he elief

PLEASE TAKE FURTHER NOTICE, ha an o CPLR 2214(b) an e ing a e , if an ,

Will Pfla m, 3 R bka Road PO Bo 40, S e an Fall , NY 12174, 518-470-3981

A o ne fo Defendan : Hen R. Ka fman, Hen R. Ka fman, P.C., 60 Ea 42nd S ee , 47 h

STATE OF NEW YORK SUPREME COURT COUNTY OF NASSAU

William Pfla m, being d l o n, de o e and a : Yo de onen i he named Plain iff he ein. I,

5. Unde Ne Yo k la , he elemen of a defama ion claim a e: 1) a fal e a emen ; 2)

6. CPLR 3016 (a) e i e ha in a defama ion ac ion, " he a ic la o d com lained of * * *

7. The follo ing a e he fo elemen of a libel ca e a e he Dillon ma e abo e:

a. The fal e a emen he e in he in an com lain i of ab e of he dog Timbe made

b. Sc een ho and o he oof of blica ion i anne ed. The e can be no do b he

c. A o negligence, h o gho hi com lain , Defendan eak o e-e i ing

d. A o ha m, anne ed he co ill find fal e Google e ie ill ac i e on Plain iff

8. Th , all he fo elemen of a libel/defama ion ac ion a e no ed in he com lain .

9. Defendan JoAnn Mille con ac ed Glencadia Dog Cam b e me age on S nda ,

10. Defendan e e ed long- e m ca e fo no a a en com elling ea on. In follo - call ,

12. Ba e job i o hel c ome make e e a ion a Glencadia, do a oll fo he

oin con ib e mo e e idence, a if he a emen o Ba e b Mille on he hone e e

15. In he ie he con e a ion, Ba e o e: Thi dog i onl o ed o be he e fo

16. Timbe a icked b a Glencadia d i e o ide a e office on he e ening of

17. On F ida , Decembe 4, 2020, he ne da , Glencadia aff o e o Plain iff, Hi Joann I m

18. Defendan e onded, Hi, he ha a c o chid, an in e ed e icle. I i no ainf l, b ill

19. He e Defendan admi ha he dog ha a e io e-e i ing condi ion ha e i e

22. Timbe a anemic and o ld ha e likel died i ho he in e en ion of ale Glencadia

24. The claim ha Defendan o hi em lo ee ab ed Timbe i ende ed ab d b he

33. On Facebook, Defendan o e, ABUSED AT DOG TRAINING FACILITY, no ho i ali ed.

34. The en i e GoF ndMe age, a of J l 1, 2021, ead :

cam a ing Timbe a heal h and feeling be e af e he i i i h he e he ook him o.

37. Thi a emen a bli hed e e al ime on he in e ne , m l i le Facebook g o and

38. The follo ing elemen of he a emen a e fal e.

a. Defendan a ed, ABUSED AT DOG TRAINING FACILITY, no ho i ali ed.

i. Timbe a no ab ed in an a hile a cam . Glencadia aff a ending

likel e lained in he e en Th da , Decembe 10, 2020, no ing

ii. Defendan on and/o bo f iend Mile emailed o o o e alle gie a a

iii. Defendan a ocia e Mile ne e men ioned an of he o he claimed ign

i . Defendan e e a a e of an nde cended e icle and he nia io o

. Defendan e e a a e ha Plain iff o ided medical ca e o Timbe o of

b. Defendan a ed ha Plain iff onl en Defendan one ho o d ing he 20-da

c. The claim ha ho o e aining o c a che and hai occ ed a Glencadia a e

d. The a emen If Timbe ' heal h a o oo h a n' he famil no ified

e. Defendan a e, The ne mo ning he b o gh him o he e and a old ha

39. The dog emained a Glencadia fo eigh mo e da af e going o he e in Col mbia

40. If Timbe con in ed o lo e eigh , ha i o be e ec ed. Plain iff ne e old Defendan ha

43. In a linked oceeding befo e he Na a Co n S eme Co of Ne Yo k, Inde No.

44. The onl e idence of ab e offe ed b Defendan i eigh lo and io and o ed

48. F he , Defendan on, a no ed abo e, o e, ma be he had an alle gic eac ion. If he

49. O e he co e of a eek in la e Decembe 2020, Defendan and he a ocia ed libeled

Compensatory damagês accciding to proof; Judgement; Punitive damages; interest as anowad by

Will Pflaum, 3 Rybka Road PO Box 40 /

New York, NY 10165, 914-589-7963, Hkaufman@hrkaufman.com

Appendix A: Boarding agreement

Appendix B: Text message screenshots

Appendix C: Email from Patricia Basset warning of shady behavior

Appendix D: Patricia Bassett write up based on conversation with Plaintiff

Appendix F: Plaintiff admitting a serious pre-existing condition

Appendix G: Cryptorchidism in dogs article

Appendix H: Message advising Plaintiff that her dog was ill

Appendix I: Invoice for hospitalization

**SPECIAL INSTRUCTIONS*TIMBER (PITBUL-11 YRS OLD)