Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 1 of 13 - Page ID#: 1
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF KENTUCKY
`AT LEXINGTON
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`
`WORLD HERITAGE ANIMAL
`GENOMIC RESOURCES
`
`
`AND
`
`
`
`LUCINDA CHRISTIAN
`
`
`
`PLAINTIFFS
`
`
`v.
`
`
`
`ALTON H. STULL SR.
`4366 Turley Road
`Mt. Sterling, KY 40353
`
`
`AND
`
`
`
`BRENDA STULL
`4366 Turley Road
`Mt. Sterling, KY 40353
`
`
`AND
`
`
`
`PHILLIP STULL
`2565 Stepstone Road
`Mt. Sterling, KY 40353
`
`
`AND
`
`
`
`PATRICIA STULL
`2565 Stepstone Road
`Mt. Sterling, KY 40353
`
`
`
`DEFENDANTS
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`) CIVIL ACTION NO.
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`) Demand for Jury Trial
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`COMPLAINT
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`I. Preliminary Statement
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`
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`
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF KENTUCKY
`AT LEXINGTON
`
`
`WORLD HERITAGE ANIMAL
`GENOMIC RESOURCES
`
`
`AND
`
`
`
`LUCINDA CHRISTIAN
`
`
`
`PLAINTIFFS
`
`
`v.
`
`
`
`ALTON H. STULL SR.
`4366 Turley Road
`Mt. Sterling, KY 40353
`
`
`AND
`
`
`
`BRENDA STULL
`4366 Turley Road
`Mt. Sterling, KY 40353
`
`
`AND
`
`
`
`PHILLIP STULL
`2565 Stepstone Road
`Mt. Sterling, KY 40353
`
`
`AND
`
`
`
`PATRICIA STULL
`2565 Stepstone Road
`Mt. Sterling, KY 40353
`
`
`
`DEFENDANTS
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`) CIVIL ACTION NO.
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`) Demand for Jury Trial
`)
`)
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`COMPLAINT
`
`I. Preliminary Statement
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`
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 2 of 13 - Page ID#: 2
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`1. This is a federal question action for injunctive relief and damages caused by Defendants’
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`fraudulent, grossly negligent, and illegal conduct. Plaintiffs allege that Defendants
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`illegally disposed of animal carcasses which in turn contaminated a large portion of the
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`land Defendants sold to Plaintiffs. Plaintiffs further allege that Defendants knew of this
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`latent defect and intentionally mislead Plaintiffs during the land inspection process.
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`Plaintiffs further allege once Plaintiffs’ livestock became infected, Defendants continued
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`their fraud and began a campaign of harassment to the ongoing detriment of Plaintiffs and
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`their livestock. Plaintiffs further allege that Defendants allowed a known dangerous dog
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`to injure, kill, maim, and destroy Plaintiffs’ livestock and other property. Plaintiffs further
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`allege that Defendants were grossly negligent in the keeping and warning of this dog
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`necessitating punitive damages. Due to this illegal conduct by Defendants, Plaintiffs are
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`currently forbidden by federal law from moving the animal herds necessitating injunctive
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`relief under federal regulation.
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`II. Jurisdiction and Venue
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`2. Jurisdiction is conferred upon this Court by 28 U.S.C. § 1331 which provides for original
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`district court jurisdiction over cases presenting a federal question.
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`3. Jurisdiction over the state law claims is conferred upon this Court by 28 U.S.C. § 1367,
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`which provides for supplemental jurisdiction over state law claims which are so related to
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`the federal law claims that they form one case or controversy for Article III purposes.
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`4. All Defendants reside in this district and, upon information and belief, this is the only
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`district where a substantial portion of the events or omissions giving rise to the claims set
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`forth in this lawsuit took place and that has personal jurisdiction over all defendants;
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`therefore, venue in this district is proper pursuant to 28 U.S.C. § 1391.
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`2
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 3 of 13 - Page ID#: 3
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`III. Parties
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`5. The plaintiff, World Heritage Animal Genomic Resources (“WHAGR”), at all times
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`material hereto was and is a non-profit entity incorporated in the state of California with a
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`principle place of business in Kentucky.
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`6. The plaintiff, Lucinda Christian (“Christian”), at all relevant times hereto was and is a
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`resident of Kentucky.
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`7. The defendant, Alton H. Stull Sr., at all material times hereto was and is a resident of
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`Kentucky.
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`8. The defendant, Brenda Stull, at all material times hereto was and is a resident of Kentucky.
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`9. The defendant, Phillip Stull, at all material times hereto was and is a resident of Kentucky.
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`10. The defendant, Patricia Stull, at all material times hereto was and is a resident of Kentucky.
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`IV. Nature of Defendants’ Conduct
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`11. Upon information and belief, Plaintiffs allege: (i) that defendants individually and in
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`conspiracy with one another engaged in the conduct described herein; (ii) that the
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`defendants named above knowingly and/or negligently participated in, acquiesced in,
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`encouraged, implicitly authorized, explicitly authorized, implicitly approved and/or
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`explicitly approved the conduct described herein; (iii) that the conduct described herein
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`resulted from the defendants Alton H. Stull Sr., Brenda Stull, and Phillip Stull (a) failing
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`to properly dispose of animal carcasses pursuant to state law, (b) actively concealing the
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`improper disposal during the land sale process, (c) breaching the land sale contract due to
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`these failures and other breaches of the contract, and/or (d) harboring and failing to warn
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`about a dangerous dog; and/or (iv) that defendants’ conduct was intentional, deliberately
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`3
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 4 of 13 - Page ID#: 4
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`indifferent, negligent, and/or grossly negligent with regard to their legal responsibilities,
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`and justifies an award of actual and punitive damages.
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`V. Facts
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`12. WHAGR is a California non-profit entity whose mission entails the collection and
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`preservation of rare and endangered animals.
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`13. WHAGR promotes the breeding and genetic storage of these rare and endangered animals
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`14. WHAGR maintains custody of several priceless animals and maintains custody of valuable
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`animal genetic material used in its breeding programs.
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`15. In 2018 WHAGR began the process of developing an educational research facility in the
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`state of Kentucky.
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`16. WHAGR was in the process of reviewing a proposed site when it was introduced to Alton
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`and Brenda Stull (the “Stulls”) who offered favorable terms to WHAGR for the purchase
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`of their property at 2526 Stepstone road in Mt. Sterling, KY (the “Property”).
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`17. On or about October 10, 2018, WHAGR and the Stulls entered into a purchase agreement
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`for the Property as well as a temporary lease for a portion of the Property.
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`18. The lease and purchase agreements are intertwined and heavily reference each other.
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`19. WHAGR would not have entered into the lease without entering into the accompanying
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`purchase agreement.
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`20. During the pre-contract negotiations and again during the due diligence period provided
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`under the purchase contract WHAGR asked the Stulls if any animals on the Property had
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`been diseased and if any animals owned by the Stulls had died on the Property.
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`21. The Stulls answered “no” to both questions.
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`4
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 5 of 13 - Page ID#: 5
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`22. The Stulls also represented that only a small number of beef cattle were raised on the
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`property.
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`23. In reality, the Stulls had a larger herd farming operation on the Property and at least 2 of
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`their cows died on the Property.
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`24. The cow carcasses remained on the Property but were concealed by vegetation at the time
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`WHAGR entered into the purchase contract and were not visible under reasonable
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`inspection.
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`25. The cow carcasses were not burned, boiled, buried, nor disposed of in any sanitary fashion.
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`26. WHAGR planned to use grant funds from State and Federal sources to close on the
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`purchase of the property.
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`27. Due to unforeseen governmental closures the grant processing could not be accomplished
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`in the amount of time originally set forth in the contract.
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`28. The Stulls verbally indicated and entered into a course of performance that they would
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`extend WHAGR’s time to close on the property.
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`29. Phillip Stull is the owner of land directly adjacent to the Property.
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`30. On or about November 20, 2019 a dog owned by Phillip Stull escaped from its electric
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`fence.
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`31. The dog killed a rare rooster, maimed a rare newborn horse, and destroyed the newborn
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`horse’s placenta which was to be used in gene therapy.
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`32. The loss of potential gene therapy caused the loss of use and downfall of the horse’s
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`grandfather during the last 6 months of its life.
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`33. Upon information and belief, all Defendants were aware of the violent and aggressive
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`nature of this dog and took no action to warn the plaintiffs.
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`5
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 6 of 13 - Page ID#: 6
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`34. Phillip Stull took no action to physically fence his dog and allowed the electric fence
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`containing his dog to become uncharged.
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`35. After the attack Phillip Stull failed and refused to provide documentation showing
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`mandated vaccinations for his dog.
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`36. Upon information and belief, Phillip Stull’s dog was not vaccinated against rabies.
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`37. Plaintiff was forced to vaccinate its own animals for rabies after the attack due to Phillip
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`Stull’s failure and refusal to vaccinate and provide vaccination records.
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`38. Despite this incident, WHAGR continued to occupy the property without any of its animals
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`becoming diseased until December 2019.
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`39. In December 2019 WHAGR’s animals began dying unexpectedly and at an unusually fast
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`rate.
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`40. After seeking professional opinions, WHAGR’s animals were diagnosed with a deadly
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`Salmonella Typhimurium (“Salmonella”) infection.
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`41. WHAGR discovered that the soil on a portion of the Property was contaminated with the
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`Salmonella bacterium.
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`42. After the Salmonella outbreak began, WHAGR discovered one of the Stulls’s cow
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`carcasses in a riparian corridor within 100 feet of a pond and stream network which was
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`upland from the contaminated area.
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`43. After the Salmonella outbreak began, WHAGR discovered a second cow carcass belonging
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`to the Stulls in a riparian corridor within 100 feet of a stream network.
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`44. Upon information and belief, these cows died of Salmonella infection.
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`45. At least nine of WHAGR’s animals have died due to Salmonella infection.
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`6
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 7 of 13 - Page ID#: 7
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`46. The remainder of WHAGR’s animals are now infected with Salmonella, necessitating
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`expensive, around the clock monitoring and treatment.
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`47. Prior to moving to the Property, WHAGR’s animals were examined by the Kentucky State
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`Veterinarian and did not display any signs or symptoms of Salmonella infection.
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`48. Since disclosing the infected land and herds to the Stulls, the Stulls have engaged in
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`retaliatory conduct by attempting to unilaterally dissolve the purchase contract, threatening
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`eviction despite knowledge of Plaintiffs’ diseased herds, entering onto portions of the
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`Property, and attempting to lock WHAGR out of portions of the Property.
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`49. The property is now useless for WHAGR’s intended purpose and all improvements they
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`have made to the Property will be lost.
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`50. WHAGR’s herds cannot leave the property until they are properly decontaminated because
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`WHAGR cannot obtain mandated health certificates and the movement could spread
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`infection to other sites.
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`51. WHAGR has begun the decontamination process, however, it is lengthy and expensive.
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`52. Plaintiff, Christian have devoted the majority of their lives to help restore and preserve the
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`animals under WHAGR’s care.
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`53. Since WHAGR’s animals began dying, Christian has suffered severe emotional distress.
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`54. Christian’s emotional distress is so severe it has manifested physically.
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`IV. Federal Cause of Action
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`Count I – Temporary and Permanent Injunctive Relief
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`55. Paragraphs 1-54 above are incorporated herein by reference and made this Paragraph 55.
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`56. Due to concealment of the facts related to diseased animals and animal deaths on the
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`Property Plaintiff, WHAGR, moved its herds of animals onto the Property.
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`7
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 8 of 13 - Page ID#: 8
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`57. Plaintiff, WHAGR’s, animals are now contaminated with a deadly and highly contagious
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`disease and must go through a lengthy and expensive decontamination process.
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`58. Defendants, Alton and Brenda Stull, have threatened to evict Plaintiff, WHAGR, after this
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`discovery and Plaintiff’s reporting of infection to the government.
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`59. Defendants, Alton and Brenda Stull, have attempted to lock Plaintiffs out of portions of the
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`Property making it more difficult to care for the vulnerable animals.
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`60. 7 U.S.C. § 8301-8317 authorizes 9 CFR § 71.3 states animals “affected with any of the
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`following diseases … or any other communicable disease which is endemic to the United
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`States… shall not be moved interstate.”
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`61. Plaintiff, WHAGR, would be barred from transporting its animals before the
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`decontamination process is completed because it would be unable to obtain mandatory
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`health certificates as required under federal law.
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`62. Plaintiff, WHAGR, would suffer massive, irreversible, and incalculable damages if
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`Defendants’ pattern of harassment and/or threatened eviction is allowed to continue.
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`63. Plaintiff, WHAGR, asks that necessary injunctive relief be granted to prevent further
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`damage to its herds.
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`V. State Law Causes of Action
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`Count II – Damages Caused by Improper Animal Disposal, Strict Liability
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`64. Paragraphs 1-63 above are incorporated herein by reference and made this Paragraph 64.
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`65. KRS 257.160 states “All carcasses of domestic livestock, poultry, and fish which have died
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`or which have been destroyed on account of any disease, except as determined and
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`permitted by the state veterinarian or other representative of the board, shall be disposed
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`of by: Complete incineration…; boiling the carcass…; burying the carcass … in the earth
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`8
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 9 of 13 - Page ID#: 9
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`at a point which is never covered with the overflow of ponds or streams and which is [at
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`least 100 feet away] from any watercourse, sinkhole, well, spring, public highway,
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`residence, or stable… the entire carcass covered with two inches of quicklime and at least
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`three feet of earth; [or other methods requiring official approval].
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`66. Defendants, Alton and Brenda Stull, failed to lawfully dispose of their deceased animals
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`which then caused extensive damages to Plaintiff, WHAGR’s, herds by spreading the
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`disease.
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`67. KRS 257.160 is applicable to civil cases through KRS 446.070 which states that persons
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`injured by violation of any statute may recover from the offender such damages as
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`sustained by violation of the statute, regardless if a penalty is imposed.
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`68. Defendants, Alton and Brenda Stull, are strictly liable for these damages.
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`Count III – Civil Fraud
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`69. Paragraphs 1-68 above are incorporated herein by reference and made this Paragraph 69.
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`70. Defendants, Alton and Brenda Stull, made material representations to Plaintiff that were
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`false, specifically that no animals had been diseased on the Property, no animals had died
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`on the property, and that many fewer animals were present on the Property than actually
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`were present.
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`71. Defendants, Alton and Brenda Stull, made these representations with the knowledge they
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`were untrue or with reckless disregard for their accuracy.
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`72. Defendants, Alton and Brenda Stull, made these representations to induce Plaintiff to
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`continue with its purchase of the Property.
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`73. Plaintiff, WHAGR, relied on these representations when it progressed with the purchase of
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`the Property and moved its herds onto the Property.
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`9
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 10 of 13 - Page ID#: 10
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`74. Plaintiffs have suffered damages as a result of this fraud.
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`Count IV – Breach of Contract
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`75. Paragraphs 1-74 above are incorporated herein by reference and made this Paragraph 75.
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`76. Plaintiff, WHAGR, entered into a contract with Defendants, Alton and Brenda Stull, for
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`the sale of the Property.
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`77. Defendants, Alton and Brenda Stull, breached this contract and caused Plaintiffs to suffer
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`damages.
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`Count V – Negligence and Gross Negligence
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`78. Paragraphs1-77 above are incorporated herein by reference and made this Paragraph 78.
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`79. Defendants, Alton and Brenda Stull, had a duty to reasonably care for their animals to
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`prevent disease and had a duty to reasonably recognize obvious animal disease amongst
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`their own animals.
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`80. Defendants, Alton and Brenda Stull, were negligent and/or grossly negligent regarding the
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`care of their own animals and during the sale process when they represented the Property
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`had no diseased animals and no animal deaths due to disease.
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`81. Defendants, Alton and Brenda Stull, were negligent in the care they provided to their own
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`animals.
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`82. Defendants, Alton and Brenda Stull’s, conduct was so grossly negligent that any reasonable
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`person would recognize his conduct presented a grave risk of danger.
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`83. Defendants, Alton and Brenda Stull’s, conduct showed a reckless disregard for the safety
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`of Plaintiff’s person and property.
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`84. This negligence and/or gross negligence caused Plaintiffs to suffer damages.
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`Count VI –Damages Caused by Dog, Strict Liability
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`10
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 11 of 13 - Page ID#: 11
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`85. Paragraphs 1-84 above are incorporated herein by reference and made this Paragraph 85.
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`86. KRS 258.235(4) states “[a]ny owner whose dog is found to have caused damage to a
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`person, livestock, or other property shall be responsible for that damage.”
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`87. Defendants, Phillip Stull and Patricia Stull’s, dog caused damage to Plaintiff’s livestock
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`and property.
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`88. KRS 258.235(4) is further applicable to civil cases through KRS 446.070 which states that
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`persons injured by violation of any statute may recover from the offender such damages as
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`sustained by violation of the statute, regardless if a penalty is imposed.
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`89. Defendants, Phillip Stull and Patricia Stull, are strictly liable for these damages.
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`Count VII – Negligence and Gross Negligence
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`90. Paragraphs 1-89 above are incorporated herein by reference and made this Paragraph 90.
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`91. Defendants, Phillip Stull and Patricia Stull, were negligent and/or grossly negligent when
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`they allowed the fence containing this dangerous dog to fall into disrepair and failed to
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`have this dog vaccinated against rabies.
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`92. All defendants were negligent and/or grossly negligent in their failure to reasonably warn
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`Plaintiffs of the dangerous nature of this dog and the completely inadequate fencing.
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`93. This negligence allowed Phillip Stull and Patricia Stull’s dog to cause damages to Plaintiff,
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`WHAGR’s, livestock and property.
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`94. Defendants’ conduct was so grossly negligent that any reasonable person would recognize
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`his conduct presented a grave risk of danger.
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`95. Defendants’ conduct showed a reckless disregard for the safety of Plaintiff’s person and
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`property.
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`96. This negligence and/or gross negligence caused Plaintiffs to suffer damages.
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`11
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 12 of 13 - Page ID#: 12
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`Count VIII – Failure to Vaccinate, Strict Liability
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`97. Paragraphs 1-96 above are incorporated herein by reference and made this Paragraph 97.
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`98. KRS 258.015 states “[e]very owner shall have his dog… initially vaccinated against rabies
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`by the age of four (4) months and revaccinated at the expiration of the immunization period
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`as certified by the veterinarian. The veterinarian who vaccinates a dog… shall issue to the
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`owner a vaccination certificate…”
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`99. Defendants, Phillip Stull and Patricia Stull failed to vaccinate his dog and failed to provide
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`the required certificate.
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`100.
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`101.
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`These acts caused damages to Plaintiff.
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`KRS 258.015 is further applicable to civil cases through KRS 446.070 which states
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`that persons injured by violation of any statute may recover from the offender such
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`damages as sustained by violation of the statute, regardless if a penalty is imposed.
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`102.
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`Defendant is strictly liable for these damages.
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`Count IX – Intentional and/or Negligent Infliction of Emotional Distress
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`103.
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`Paragraphs 1-102 above are incorporated herein by reference and made this
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`Paragraph 103.
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`104.
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`All Defendants intentional, negligent, and/or grossly negligent actions have caused
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`Plaintiff, Christian, to suffer severe emotional distress.
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`105.
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`106.
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`This emotional distress is so severe it has manifested in physical symptoms.
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`Christian has sought therapy to deal with the emotional toll.
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`VI. Damages
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`107.
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`Paragraphs 1-106 above are incorporated herein by reference and made this
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`Paragraph 107.
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`12
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`Case: 5:20-cv-00334-DCR Doc #: 1 Filed: 07/31/20 Page: 13 of 13 - Page ID#: 13
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`108.
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`Plaintiffs, World Heritage Animal Genomic Resources and Lucinda Christian, are
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`entitled to recover damages for destruction of property, reduction in value, loss of use, loss
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`of opportunity, medical treatment for both humans and animals, pain and suffering, and
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`out of pocket costs. The violation of Plaintiffs’ statutory and common law rights was
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`fraudulent, malicious, and evidenced a total and reckless disregard for its rights, entitling
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`Plaintiffs to recover punitive damages to deter such conduct in the future. This relief and
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`these damages are proper under KRS 411.184 and 411.186.
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`WHEREFORE, Plaintiffs request trial by jury of all allegations set forth herein, and that
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`plaintiffs be awarded all damages sought in Paragraph 108, including actual, statutory, and
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`punitive damages, pre- and post- judgment interest at the maximum legal rate, court costs,
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`attorneys’ fees and all other relief to which he is entitled under law or in equity.
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`Respectfully submitted,
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`/s/Rob Astorino Jr.
`Matthew W. Stein
`Rob Astorino Jr.
`STEIN WHATLEY ATTORNEYS, PLLC
`2525 Bardstown Road, Suite 101
`Louisville, KY 40205
`(502) 553-4750
`(502) 459-2787 (f)
`mstein@steinwhatley.com
`rastorino@steinwhatley.com
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`13
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