January 8, 2004

Mr. Carmel “Charlie” Azzopardi
4401 Redding Rd.
Amarillo, TX 79124

VIA FACSIMILE (806-374-4241: Western Cement Construction) and FIRST CLASS MAIL

This letter is written on behalf of People for the Ethical Treatment of Animals (PETA), an international animal rights organization with more than 750,000 members and supporters, and concerns recent statements made by you in public and published in the media in which you declare that the PETA investigator who exposed the severe neglect of animals at your facility (Amarillo Wildlife Refuge) “staged” the photographs and videotape recordings which PETA has used to support its complaints to authorities, and that the PETA investigator was responsible for the neglect herself. These are false statements, as you know, which are actionable under the law and will be addressed as such by PETA should you fail to cease these declarations immediately.

The statements are defamatory and thus subject you to liability in a court of law. E.g., Tex. Civ. Prac. & Rem. 73.001; Austin v. Inet Technologies, Inc., 118 S.W.3d 491 (Tex. App. 2003). The photographs and videotape recordings at issue depict the actual conditions uncovered by the PETA investigator: (1) when she arrived at AWR; (2) during the time she was employed at AWR; and (3) on her return visits to AWR subsequent to her dismissal (attributed by you to a lack of funds). Moreover, the PETA investigator was assigned her daily tasks by you and she was only directed, or even permitted, to clean the animals’ cages on an infrequent basis — in fact, she was expressly prohibited by you on a number of occasions. As you know, PETA has incontrovertible evidence that your statements are false.

You are hereby notified to take all steps necessary to ensure these misrepresentations cease immediately. In addition, we demand that you contact all individuals and entities to which you have made this misrepresentation and correct the error. Please copy PETA on this correspondence, at the address above, so that PETA is assured that proper remedial action has been taken.

Thank you for your prompt attention to this matter. I can be reached at 757-622-7382, extension 1646.

Sincerely,

Lori Kettler
Legal Counsel
Research & Investigations Dept.