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EXECUTIVE SUMMARY

THE HSUS "LOBBY MILL" AND ITS 101 "DAMNATIONS"

By Frank Losey

"Under the Internal Revenue Code, all section 501(c)(3) organizations are absolutely prohibited from directly or indirectly participating in, or intervening in, any political campaign on behalf of (or in opposition to) any candidate for elective public office."

"Lobbying" "In general, no organization may qualify for section 501(c)(3) status if a substantial part of its activities is attempting to influence legislation (commonly known as lobbying). A 501(c)(3) organization may engage in some lobbying, but too much lobbying activity risks loss of tax-exempt status.

Legislation includes action by Congress, any state legislature, any local council, or similar governing body, with respect to acts, bills, resolutions, or similar items (such as legislative confirmation of appointive office), or by the public in referendum, ballot initiative, constitutional amendment, or similar procedure. . . . An organization will be regarded as attempting to influence legislation if it contacts, or urges the public to contact, members or employees of a legislative body for the purpose of proposing, supporting, or opposing legislation, or if the organization advocates the adoption or rejection of legislation."

"Exempt Organizations Annual Reporting Requirements - Form 990, Parts I-V: Reporting Number of Volunteers . . . . Make a reasonable estimate of the number of persons that did any type and amount of volunteer work for your organization during the tax year."

The Lobbying Disclosure Act requires that all persons or organizations that have more than one "contact" with a "Covered Executive Branch Official" or a "Covered Legislative Branch Official" be registered as a Lobbyist or Lobbying Organization with the Secretary of the Senate and the Clerk of the House. "The term "lobbying contact" means any oral or written communication (including an electronic communication) to a covered executive branch official or a covered legislative branch official that is made on behalf of a client with regard to (i) the formulation, modification, or adoption of Federal legislation (including legislative proposals);(ii) the formulation, modification, or adoption of a Federal rule, regulation, Executive order, or any other program, policy, or position of the United States Government."

Each of the first ninety-seven (97) of the 101 "Damnations" of the Humane Society of the U.S. (HSUS) that are summarized in the attached Treatise discusses and references the fact that the HSUS never fully disclosed on any of its Tax Returns the time and expenses of the HSUS that were devoted to the above defined Lobbying and Prohibited Political Campaign Activities by it and its Paid Management and Staff; and its Millions of Members and Volunteers who were asked by the HSUS to lobby directly and indirectly on its behalf. In the last 10 years the HSUS orchestrated literally Tens of Millions of lobbying-related contacts with its Members and Volunteers, and cumulatively their combined lobbying actions and contacts with elected officials and their staffs at the federal, state and local level conservatively totaled in excess of 5 Million "contacts."

The final four (4) "Damnations" address the "Dark Side" of the Corporate Ethos of the HSUS, with respect to its support of Domestic Terrorism and its alleged violations of the Animal Enterprise Terrorism Act and the Racketeer Influenced and Corrupt Organization (RICO) Act.

THE HSUS "LOBBY MILL" AND ITS "101" DAMNATIONS!

“It’s not the crime that gets you… it’s the cover up.”

President Richard M. Nixon

Currently, the Humane Society of the United States (HSUS) and Mr. Pacelle, its President and CEO, are riding the wave of favorable perceptions about them in the minds of Tens of Millions of U.S. Citizens, Elected Officials, Political Appointees, Government Employees and Law Enforcement Personnel. However, when those Tens of Millions of "cult-like" followers of the HSUS fully become aware of the documented magnitude of the following "101" Damnations of the HSUS, they will experience a sense of betrayal. And they will realize that the "101" Damnations represent the equivalent of a Criminal "Bill of Indictment" which supports the proposition that no person or entity shall be permitted to act as if they are "Above the Law." In short, if a former President of the U.S. was not permitted to act "Above the Law," then why should Mr. Pacelle and the HSUS be permitted to "cover-up" and act "Above the Law?!?!?"

While some may suggest that the HSUS should not be held accountable for its non-compliance with the U.S. Tax Code Standards because it is perceived by many to be doing "Good Deeds," the U.S. Tax Code does not provide for a "Good Deed" Exception or Exemption from compliance with the U.S. Tax Code. In short, "The "Law is the Law," and the HSUS is expected to be held to the same objective standard by the IRS as is applied each year to Tens of Millions of U.S. Tax Payers, "For-Profit" Corporations, and all other Tax-Exempt, Public Charities, such as the HSUS.

THE REPEATED FAILURES OF THE HSUS TO COMPLY WITH THE U.S. TAX CODE AND THE IRS IMPLEMENTING REGULATIONS; AND ITS FRAUDULENT MISREPRESENTATIONS ON ITS IRS TAX RETURNS

DAMNATION 1: In the last five years, a week has never gone by without the HSUS literally and braggadociously chronicling its lobbying and political campaign activities, and detailing how it lobbies in support of or in opposition to legislation by:

"Walking the Halls of Congress;"

Walking the Halls of State Legislatures in all 50 State Capitals;

Posting on its Website "Lobby Day" Events each year in State Capitals, which Events include Workshops which teach attendees how to "Lobby;"

Posting on its Website Suggested E-Mails to send to Members of Congress;

Posting on its Website how to find the phone numbers of Elected Officials while urging callers to support the Lobbying Agenda of the HSUS;

Posting Lobbying-Related BLOGS on its Website, which were authored by Mr. Pacelle;

Posting Lobbying-Related Press Releases on its Website;

Posting on its Website "TAKE ACTION," Lobby-Related Notices to contact Legislators or Government Officials for the purpose of influencing their decisions;

Sending "TAKE ACTION," Lobby-Related E-Mails to its Millions of Members and Supporters;

Posting Criticisms of Elected Officials on its Website;

Posting "Lobbying Successes" on its Website; and by

Posting on its Website details of its "Political Campaigns" that support or oppose political candidates; and posting details of the Federal, State and Local Laws and Bills, and State Ballot Initiatives that are the subject of its Lobbying Activities.

The above 5 year summary of the excessive lobbying activities and the explicitly prohibited political campaign activities figuratively "paints" the mosaic image of the most prolific and sophisticated Lobbying Organization in the United States! And what is so Fraudulent is that the representations on the HSUS IRS Tax Returns repeatedly misrepresent the fact that the HSUS, a Tax-Exempt, Public Charity, has continuously asserted that it does not engage in "too much lobbying," and that it does not engage in prohibited political campaign activities, which limitations and prohibitions are explicitly set out in the U.S. Tax Code and the IRS Implementing Regulations.

DAMNATION 2: In 2011, Mr. Pacelle stated that "We have passed 1,000 laws in the last decade." The IRS Regulations expressly state that a Public Charity may have its Tax-Exempt Status revoked if it engages in "too much lobbying." Notwithstanding the fact that no Multi-Billion Dollar "For Profit" Corporation could ever claim to have "passed 1,000" laws in any decade, the IRS has ignored for more than two years this damning "confession" of excessive lobbying by Mr. Pacelle. In this regard, the IRS Office, under the former Leadership of Ms. Lerner, who is a Member of the HSUS, has had a CD Voice Recording of Mr. Pacelle's confession for more than two years and has ignored it. (IRS "COVER-UP?!?") (NOTE: To listen to the CD Voice recording of Mr. Pacelle's INCRIMINATING ADMISSION, go to www.franklosey.com and click on the link entitled "Pacelle's Confession.")

Since no Multi-Billion Dollar "For Profit" Corporation that spends Millions of Dollars each year on its Lobbying and Political Campaign Activities has ever "passed 1,000 laws in any decade," one is left with the inescapable conclusion the HSUS has engaged in "too much lobbying" by a Tax-Exempt, Public Charity; and its failure to accurately report the magnitude and expenses associated with its direct and indirect lobbying and prohibited political campaign activities on its Annual Tax Returns constitutes irrefutable evidence that the HSUS has made Fraudulent Misrepresentations on each of its Tax Returns since 2004. This irrefutable evidence warrants immediate revocation of the Tax-Exempt, Public Charity Status of the HSUS, as well as appropriate Taxes, Penalties and Interest being assessed against the HSUS by the IRS.

DAMNATION 3: "We are here lobbying." That was the four word response of Mr. Pacelle when he was asked the following question by Greta Van Susteren: "Why are you in Washington now?" Those four words personify the perception of Mr. Pacelle that he and the HSUS have an "inalienable right" to act "Above the Law," and to lobby and engage in political campaign activities without regard to the express limitations and prohibitions that apply to all 501 (c) (3) Tax-Exempt, Public Charities, which limitations and prohibitions are set out in the U.S. Tax Code and Implementing IRS Regulations. (NOTE: To listen to this CD Voice recording of Mr. Pacelle's INCRIMINATING ADMISSION, as well as his other INCRIMINATING ADMISSION THAT "We have passed 1,000 laws in the last decade," go to www.franklosey.com and click on the link entitled "Pacelle's Confession.")

DAMNATION 4: Shortly after Mr. Pacelle became the President and CEO of the HSUS in 2004, he "founded" the Humane Society Legislative Fund (HSLF), a Lobbying Organization Subsidiary that it has used, and continues to use to "launder" much of its lobbying activities and some of it political contributions, but it did not register the HSLF with the Secretary of the Senate or the Clerk of the House until February of 2012. In short, neither the HSUS nor the HSLF were registered as a Lobbying Organization between the period of August 2006 and February 2012 - - a continuous violation of the Lobbying Disclosure Act!

DAMNATION 5: The following quote was originally found on a link on the HSUS Website, but was removed after Mr. Losey brought it to the attention of the IRS. This is but one of the more than 25 documented examples of the HSUS removing postings or transferring postings to the Website of its self described "Lobbying Subsidiary," the Humane Society Legislative Fund (HSLF), in the on-going efforts of the HSUS to "cover-up" the Lobbying and prohibited Political Campaign Activities of the HSUS.

“While we’ve endorsed hundreds of Congressional candidates for election, . . . we’ve never before endorsed a presidential candidate. . . . the HSLF board of directors . . . has voted unanimously to endorse Barrack Obama for President.

IRS Guidance explicitly states that “All 501 (c) (3) organizations are absolutely prohibited from directly or indirectly participating in, or intervening in, any political campaign on behalf of (or in opposition to ) any political candidate for elective public office.”

Since the above quote originally was posted on a link on the HSUS Website; and since Mr. Pacelle was the President and CEO of the HSUS at the time the above endorsement was made; and since Mr. Pacelle "founded" the HSLF, and served as its Vice President and as a Member of the HSLF Board of Directors at the time that the HSLF endorsed "Barrack Obama for President," these uncontroverted facts constitute irrefutable evidence that the HSUS violated the explicit IRS provision that states that a 501 (c) (3) organization MAY NOT "directly or indirectly participat(e) in, or interven(e) in, any political campaign on behalf of (or in opposition to ) any political candidate for elective public office.” To date, the IRS has ignored this uncontroverted fact which was documented by Mr. Losey nearly five years ago when he first began submitting supporting documentation to the IRS, and to the IRS Tax-Exempt Office whose Director was Ms. Lois Lerner, who was later identified as being a Member of the HSUS - - a major "Conflict of Interest!"

DAMNATION 6: The HSUS stated on its 2004-2006 Tax Returns that "No Paid Staff or Management" and "No Volunteers" of the HSUS attempted "to influence national, state, or local legislation, including any attempt to influence public opinion o a legislative matter or referendum." However, the HSUS, a tax-exempt, public charity, had continuously filed Lobbying Reports during 2004-2006 as a "Lobbying Organization" with the Secretary of the Senate and the Clerk of the House, which Reports specifically listed Mr. Pacelle, the President and CEO of the HSUS, as one of its Lobbyists! (NOTE: The HSUS terminated its registration as a "Lobbying Organization" in August of 2006 - - a "cover-up" and a fraudulent misrepresentation on its IRS Tax Returns.)

DAMNATION 7: The HSLF reported contributing Tens of Millions of Dollars to political candidates to the Federal Election Commission between 2004-2013, and the HSLF opposed or endorsed nearly 1,000 Congressional Candidates. While a "Lobbying Organization" may lobby, it may not be used as a "ruse" to "cover-up" or "launder" the lobbying activities of the Senior Staff of the HSUS. In this regard, Mr. Pacelle not only "founded" the HSLF, but he and three of the most Senior Officers of the HSUS serve as the four most Senior Officers of the HSLF. In short, Mr. Pacelle and three other Senior Officers have a direct "conflict of interest" in that they serve as the "Lobbying Puppeteers" of the HSLF to mask and "cover-up" the excessive lobbying and expressly prohibited political campaign activities of the HSUS!

DAMNATION 8: The U.S. Tax Code and implementing IRS Regulations prohibit a tax-exempt, Public Charity from supporting or opposing a political candidate. Notwithstanding this fact, Mr. Pacelle's BIO, which is posted on the HSUS Website, expressly stated: "Pacelle has helped to defeat some of the most active anti-animal welfare politicians in the United States, including Rep. Joe Knollenberg of Michigan (2008), Rep. Richard Pombo of California (2006), and Rep. Chris John of Louisiana (2004)." This "criminal-like" admission repudiates the assertion that the HSUS does not engage in political campaign activities, which activities are prohibited for all Tax-Exempt, Public Charities.

DAMNATION 9: The HSUS stated on its 2008 Tax Return that it did not "engage in direct or indirect political campaign activities on behalf of or in opposition to candidates for public office." Once again, this is a Fraudulent Misrepresentation on the HSUS Tax Return for 2008, in that the HSLF, its Lobbying Subsidiary, which was directly controlled by Mr. Pacelle in his capacity as Vice President of the HSLF, not only endorsed and opposed nearly 200 Congressional Candidates during the 2008 Congressional Election, but it also endorsed the then Senator Obama for President.

DAMNATION 10: The U.S. Tax Code and implementing IRS Regulations prohibit a tax-exempt, public charity from participating in political activities, which includes state "referendums." Notwithstanding this fact, Mr. Pacelle's BIO, which is posted on the HSUS Website, expressly states: "Pacelle . . . played a central role in more than 25 successful statewide ballot measure campaigns. In 2010, Pacelle led the effort to pass HYPERLINK "http://www.humanesociety.org/news/press_releases/2010/11/prop_b_historic_victory_110310.html" Proposition B in Missouri, which is the first statewide ballot measure addressing the problem of cruelty at puppy mills." Since Mr. Pacelle claimed to have "led the effort to pass HYPERLINK "http://www.humanesociety.org/news/press_releases/2010/11/prop_b_historic_victory_110310.html" Proposition B in Missouri," that constitutes an admission by the President and CEO of the HSUS that he and the HSUS, a public charity, participated in political campaigns and lobbying activities that were not accurately and fully reported on its Tax Returns.

DAMNATION 11: On the 2009 HSUS Tax Return, the HSUS listed as a "Grant" a total of $450,000 to the "Missourians for the Protection of Dogs." This organization was registered with and listed by the Missouri Ethics Commission as a "Lobbying Organization" in the State of Missouri. Here it is also noteworthy that the Treasurer of this "Lobbying Organization" was a Member of the HSUS Board of Directors! Additionally, the reports submitted by this "Lobbying Organization" to the Missouri Ethics Committee validated that the HSUS had cumulatively contributed over $2.1 Million in support of just one of the 25 Ballot Initiatives that Mr. Pacelle referenced in his BIO. This is yet another classic example of how the HSUS has made Fraudulent Misrepresentations to the IRS on its Tax Returns through the use of a criminal-like pattern of conduct that obfuscates and "covers up" the magnitude of the Millions of Dollars that the HSUS expends each year in its direct and indirect lobbying activities.

DAMNATION 12: On the 2010 HSUS Tax Return, the HSUS listed as a "Grant" a total of an additional $1,350,000 to the "Missourians for the Protection of Dogs." This organization was listed by the Missouri Ethics Commission to be a "Lobbying Organization" in the State of Missouri. And for emphasis, it bears repeating that the Treasurer of this "Lobbying Organization was a Member of the HSUS Board of Directors! Additionally, the reports submitted by this "Lobbying Organization" to the Missouri Ethics Committee further validated that the HSUS has actually contributed over $2.1 Million in support of just one of the 25 Ballot Initiatives that Mr. Pacelle referenced in his BIO. This is yet another classic example of how the HSUS has made fraudulent misrepresentations to the IRS on its Tax Returns through the use of a criminal-like pattern of conduct that obfuscates and "covers up" the magnitude of the Millions of Dollars that the HSUS expends each year in its direct and indirect lobbying activities in support or in opposition to State Ballot Initiatives. Yet another Fraudulent Misrepresentation.

DAMNATION 13: To further mask and cover up the financial contributions that the HSUS orchestrates to be made to State Ballot Initiative Campaigns, the HSUS, under the leadership of Mr. Pacelle, "launders" lobbying contributions by having them made by subsidiaries of the HSUS. For example, The Doris Day Animal League and the Fund for Animals - - two subsidiaries of the HSUS - - contributed a total of $90,000 over and above the $2.1+ Million that the HSUS contributed to directly support the Missourians for Protection of Dogs Ballot Initiative Campaign in Missouri in 2009-2010. Once again, none of these types of expenditures were used in the IRS formula for determining if the "too much lobbying" threshold was exceeded by the HSUS. Yet another Fraudulent Misrepresentation.

DAMNATION 14: On September 7, 2010, Mr. Pacelle participated in a "Town Hall Conference Call" that addressed the Ballot Initiative that was to be voted on in Missouri in the November Election. (Even though the IRS ignored a CD Recording that it received in September 2010, the following recorded quotes of Mr. Pacelle from that CD Voice Recording are illustrative of his style of grass roots lobbying in its rawest and most blatant form.) During this “Town Hall Conference Call,” which was initiated by the HSUS, Wayne Pacelle stated:

“We need every one of you . . . all 15 thousand or so on the call . . .” (to help pass Proposition B).

“We must have a robust campaign.”

“We must win.”

“We have learned how to do it . . . just have to execute it. . . . In the last three years we have passed more than 200 state laws.”

“Get support out to vote Yes on Prop B.”

“Remember . . . vote Yes on Prop B.”

“Rank and file supporters need to get the word out.”

“Need to change the law.”

“We gathered . . . 190,000 signatures to put the initiative on the ballot.”

“Organizational meetings in Columbia on September 13, . . . St. Louis on September 14, . . . Kansas City on September 15, . . . and Springfield on September 16.”

“Hosting parties on October 3^rd. . . in all 114 counties in Missouri”

“Need TV ads on all media markets in Missouri. . . . to encourage everyone to vote YES on Prop B.”

“Need everyone to dig deep . . . and donate now.”

“Need to have TV advertising to encourage everyone to vote YES on Prop B.”

“We hope to raise $3 Million for a major campaign.”

“We need to send a signal to politicians in Washington and Missouri.”

“This is a political campaign.”

These quotes are so telling as to the how deep-rooted and focused Mr. Pacelle is when it comes to Lobbying! And the fact that the HSUS did not report any of its administrative support expenses, to include Mr. Pacelle's time and travel expenses associated with his follow-on multiple trips to the State Capitol in Missouri, represents a major Fraudulent Misrepresentation on its IRS Tax Returns.

DAMNATION 15: On September 10, 2010 Wayne Pacelle, President and CEO of the HSUS, sent out a “blanket” E-Mail with respect to the Missouri Proposition B Ballot Initiative, and he stated in the E-Mail: “We’ll be giving it our all to make sure this initiative passes.” "Giving it our all" is yet another illustrative example of Lobbying by the most Senior Ranking Officer of the HSUS, and yet none of this activity was reported as "Lobbying." Yet another Fraudulent Misrepresentation

DAMNATION 16: Mr. Pacelle was so active in his direct and personal lobbying activities in the State of Missouri on matters involving legislation that affected the Proposition B Ballot Initiative that he actually registered himself as a State Lobbyist with the Missouri Ethics Commission, and was so registered for two years. That is just one other illustrative example of the depth and magnitude of Mr. Pacelle's excessive lobbying activities on behalf of a public charity, and yet the HSUS asserts on its Tax Returns and its representations made to the IRS that it does not engage in "too much lobbying." (NOTE: Reflect and ask yourself, what other President and CEO of a Public Charity with revenues in excess of $100 Million a year is or ever has been registered as a state lobbyist?!?)

DAMNATION 17: A total of 148 incriminating E-Mails were ordered to be produced by the Cole County Court in Jefferson City, Missouri in a Lawsuit that was filed in 2010. These E-Mails were exchanged between Members of the Ballot Initiative Coalition in Missouri and Senior HSUS Staff between the 217-day period of July 8, 2009 and February 9, 2010. Each of the E-Mails discussed “internal deliberations” concerning the Ballot initiative in Missouri. Ninety-Nine (99) of the 148 E-Mails were authored by or received by Mr. Jonathan Lovvorn, the HSUS Vice President and Chief of its Litigation Division. Of note, this is the same Jonathan Lovvorn who is a named Defendant in a RICO (Racketeer Influenced and Corrupt Organization) Lawsuit - - HSUS is also a named Defendant in the same Lawsuit. Of further note, nine (9) of the 148 E-Mails were authored by or received by Mr. Pacelle. Since the E-Mails were directly related to the Ballot Initiative in which the HSUS "officially" contributed over $2.1 Million to support the Lobbying effort in support of the Ballot Initiative, the time and expenses associated with the 148 E-Mails should have been allocated to the Lobbying Expenditures that were reported on the HSUS Tax Returns for 2009 and 2010. However, they were not. Yet another Fraudulent Misrepresentation.

DAMNATION 18: On the 2009 HSUS Tax Return, the HSUS listed as a "Grant" a total of $1,500,000 to the Ohioans for Humane Farms to support a Ballot Initiative Campaign that resulted in the expenditure of additional and substantial time, expenses, energy, and lobbying efforts of the HSUS which were never accurately and fully identified as "lobbying-related" expenses on its 2009 Tax Return. Yet another Fraudulent Misrepresentation.

DAMNATION 19: Yet another Multi-Million Dollar HSUS lobbying campaign in support of a Ballot Initiative occurred in California in 2008. Once again the HSUS made a fraudulent misrepresentation on its 2008 Tax Return when it listed its lobbying contributions of $2.25 Million to the Californians for Humane Farms as a "Grant" on its 2008 Tax Return. This Humane-Sounding Organization was yet another "Lobbying Front" for the major campaign of the HSUS to persuade Californians to vote in favor of a Ballot Initiative that was sponsored by the HSUS. In point of fact, the HSUS dedicated in excess of $5 Million to the direct and indirect Lobbying Campaign in support of this Ballot Initiative. For example, extracts from the records maintained on the Website of the Secretary of State for California reveal that the HSUS and its employees contributed at least $4,244,708.86 to the “Yes on Prop. 2 – Californians for Humane Farms," a surrogate "Lobbying Front” that the HSUS used to lobby in support of the Ballot Initiative in California. And that amount did not include any direct and indirect internal staff and administrative expenses that were expended by the HSUS to support its largest "Official" Expenditures for any of the 25 Ballot Initiatives for which Mr. Pacelle and the HSUS claim responsibility.

DAMNATION 20: To put the emphasis that the HSUS places on State Ballot Initiative Campaigns in perspective, in a letter that Mr. Losey sent to Ms. Lois Lerner that was dated March 2, 2013, he attached at Tab 2-A a Search Document from the HSUS Website which stated that: "Your search for "ballot initiative" returned 100 results." In contrast, when Mr. Losey did a new search for the words "ballot initiative" on January 25, 2014, the search revealed "about 482 results" - - a nearly five-fold increase in 10 months! And yet the HSUS does not report as "Lobbying Expenses" any of the expenses associated with its pro-active support and lobbying efforts of State Ballot Initiatives. Yet another Fraudulent Misrepresentation.

DAMNATION 21: During the 2012 Congressional Election, Mr. Pacelle continuously vilified Iowa Incumbent Congressman Steve King on his BLOG that was posted on the HSUS Website in a blatant effort to defeat Congressman King in much the same manner as the HSUS had previously done, as documented in Mr. Pacelle's BIO, with respect to claiming credit for the defeat of "Rep. Joe Knollenberg of Michigan (2008), Rep. Richard Pombo of California (2006), and Rep. Chris John of Louisiana (2004)." And once again, through the auspices of the HSLF, which was directly controlled by Mr. Pacelle, the HSLF contributed, as documented in reports filed with the Federal Election Commission, over $750,000 in its failed attempt to defeat Congressman King. In short, Mr. Pacelle was indirectly and directly engaging in a political campaign activity that was opposing a candidate for public office - - an absolute PROHIBITION as set out in the U.S. Tax Code and Implementing IRS Regulations.

DAMNATION 22: On Page 3 of the 2012 HSUS Tax Return, the HSUS stated that it did not "engage in political campaign activities on behalf of or in opposition to candidates for public office," which was yet another fraudulent misrepresentation made on its Tax Return. In this regard, Mr. Pacelle and the HSUS posted on the HSUS Website at least 10 Articles that were critical of Congressman King during 2012 and prior to the 2012 Congressional Election; and the HSLF, which was founded by Mr. Pacelle, who serves as its Vice President, funneled and "LAUNDERED" over $750,000, as reported to the Federal Election Commission, in opposition to the re-election of Congressman King. And Congressman King was but one of approximately 200 Candidates that the HSLF opposed or endorsed in the 2012 Congressional Elections. If that is not "direct," it most certainly constitutes "indirect political campaign activities," which activities on behalf of the HSUS were UNLAWFUL because they are expressly prohibited by the U.S. Tax Code and Implementing IRS Regulations.

DAMNATION 23: When the HSLF filed its 2007 Tax Return, it listed as its four most Senior Officers: Mr. Pacelle, the President and CEO of the HSUS, Mr. Markarian, the Executive Vice President of the HSUS, Mr. Waite III, the CFO and Treasurer of the HSUS, and Mr. Kindler, the General Counsel for the HSUS. Those four were also the four most Senior Officers for the HSUS. What makes this fact so telling and "incriminating" is the fact that on the HSLF 2007 Tax Returns, it stated that each of the four most Senior HSUS Paid Officers were devoting an average of 10 hours a week conducting the affairs of the HSLF, a LOBBYING 501 (C) (4) ORGANIZATION. Consequently, at least 25% of their time, and the time of their support staff, should have been reported as "Lobbying Expenses," but it was not. In short, the "25%" establishes a "prima facie" basis for asserting that the HSUS and its Senior Leadership have exceeded the "substantial" threshold for "too much lobbying." However, far, far more egregious is the blatant effort to conceal and cover-up the magnitude of the Lobbying by the Senior Staff of the HSUS in that when the HSLF filed its 2008 Tax Return, it "reported" that the average number of hours per week devoted by the HSUS Senior Staff was REDUCED from an average of 10 hours a week to only 1 hour a week, even though the intensity and amount of lobbying by the HSLF continued to increase. What is also so damning is that the reduction in the average number of hours occurred after Mr. Losey had submitted to the IRS documentation that highlighted the fact that the HSLF admitted that the Senior Staff of the HSUS was devoting an average of 10 hours a week to lobbying efforts on behalf of the HSLF. This not only suggested that someone within the IRS was leaking information back to the HSUS to assist in its cover-up of excessive lobbying activity, but that, in fact, the Senior Leadership of the HSUS made a conscious decision to "cover-up" its Fraudulent Misrepresentations that it had been making on its Tax Returns that recorded that the Senior Leadership of the HSUS were devoting an average of 10 hours a week in the routine, daily, non-stop lobbying activities of the HSUS. In short, the "true facts" established that the HSUS was excessively lobbying, and, even worse, was engaging in expressly prohibited campaign activities by a public charity.

DAMNATION 24: Quote from Page 59 of HSUS 2007 Tax Return reads as follows: "Government Affairs focuses on Federal, State and Local Legislation." However, on Page 17 of the same Tax Return, the HSUS contradicted itself by stating that it did not "attempt to influence national, state or local legislation." Yet another Fraudulent Misrepresentation on its 2007 Tax Return.

DAMNATION 25: Quote from Page 78 of the HSUS 2007 Tax Return reads as follows: At the Federal Level, the HSUS advocated for Animal Welfare Legislation. However, on Page 17 of the same Tax Return, the HSUS contradicted itself by stating that it did not "attempt to influence national, state or local legislation." Yet another Fraudulent Misrepresentation on its 2007 Tax Return.

DAMNATION 26: Each year the HSUS host Lobby Days in approximately 40 State Capitols. For example, in 2013 it hosted Lobby Days in over 40 different State Capitols. However, none of the expenses associated with up to 40 or more Lobby Day Events in different State Capitols each year were listed as Lobbying Expenses on any of the HSUS Tax Returns.

DAMNATION 27: The HSUS currently employs State Directors in 42 different States. Almost all of them are Registered as Lobbyists in their respective States, but the HSUS does not include their fully burdened salaries and expenses in the amount that it reports as lobbying expenses, which, in turn, understates the true amount of resources devoted to Lobbying on its Tax Returns. Yet another Fraudulent Misrepresentation on the HSUS Tax Returns.

DAMNATION 28: When the word "Lobbying" was entered into the Search Engine on the HSUS Website on January 22, 2014, it showed that 1,010 Articles were listed on the HSUS Website. For example, one of the 1,010 Articles is entitled: "Do's and Don'ts of Lobbying." This fact alone contradicts any assertion that the HSUS does not engage in excessive Lobbying, which Lobbying was never accurately reported on its Annual Tax Returns. Once again, another example of Fraudulent Misrepresentations on the HSUS Tax Returns.

DAMNATION 29: Lobbying related quotes from another HSUS Website posting dated February 7, 2013 poignantly illustrates the details of the strategic planning that goes into the HSUS Lobbying Campaigns:

"Getting Engaged - - Passing Laws for Animals. . . . On the legislative front. . . . The HSUS cannot do this work without you. We need every citizen to be engaged and to make the right choices. In this case, that means getting involved politically. . . . Go to our state pages and learn more about what's happening in your state, and please get involved with our campaigns and initiatives."

And the failure of the HSUS to account for these "lobbying efforts" on its Tax Returns cumulatively compounds the Fraudulent Misrepresentations of the HSUS.

DAMNATION 30: Another of the 1,010 Lobbying Articles is entitled: "Student Guide to Lobbying: Part 1." Two more listed Articles are entitled: "Student Guide to Lobbying: Part 2," and "Student Guide to Lobbying: Part 3." Most tellingly, no expenses associated with the preparation and distribution of these three "Student Guides" were ever reported on the HSUS Tax Returns as Lobbying-Related Expenses. These three subject matter omissions represent three more Fraudulent Misrepresentations on the HSUS Tax Returns, and they further illustrate the pervasiveness of the Lobbying Activities of the HSUS as it infiltrates our Nation's Schools in its efforts to brainwash school age children to lobby in support of the HSUS Legislative Agenda.

DAMNATION 31: One of the most egregious "Damnations" is found in the HSUS "Humane Action Guide for Youth . . . K-6," WHICH TARGETS CHILDREN AS YOUNG AS 5 YEARS OLD. Not only does this Guide discuss and instruct young children how to lobby, but it explicitly provides a child as young as 5 with the Telephone Number of the Congressional Switchboard, and further provides a script for children to use when calling their Member of Congress for the purpose of lobbying in support of the HSUS Legislative Agenda. Not only is this yet another masked and covered up grass roots lobbying initiative on the part of the HSUS which has not been identified by the HSUS as "Lobbying Expenses - - yet another Fraudulent Misrepresentation on its Tax Returns - - but it raises additional, collateral, ethical and moral issues with respect to the actions of the HSUS and its Senior Leadership and their "predatory-like" practices of targeting and attempting to "brainwash" school-age children to become "grass roots" lobbyists for the HSUS.

DAMNATION 32: The HSUS has also published a "Mission Humane Action Guide" for Teenagers. Extracts read as follows:

"Everything Teens Need to Speak Up for Animals. . . . How to Use This guide. . . . Middle-and-High-School Students: Using this guide is as easy as 1-2-3. . . . You'll also learn about lobbying. . . . Sincerely Wayne Pacelle, President and Chief Executive Officer of the Humane Society of the United States. . . . To contact legislators by phone, use the congressional switchboard number, (202) 224-3121. All you need to say is: "I'm a constituent and I am calling to ask my representative/senator to support/not support (bill number and title). . . . Take a free on line course: Using Legislative Process to Speak Up for Animals."

Once again, none of the costs associated with preparing and distributing this "Lobbying-Related" Guide, and providing its "free on line course," have been identified by the IRS as Lobbying Expenses on its Tax Returns. Thus, not only is this yet another masked and covered- up grass roots lobbying initiative on the part of the HSUS which has not been identified by the HSUS as "Lobbying Expenses - - yet another Fraudulent Misrepresentation, on its Tax Returns - - but it raises additional, collateral, ethical and moral issues with respect to the actions of the HSUS and its Senior Leadership and their "predatory-like" practices of targeting and attempting to "brainwash" school-age children to become "grass roots" lobbyists for the HSUS.

DAMNATION 33: As horrific as the shameless efforts of the HSUS have been to literally engage in the predatory-like acts to "brainwash" our young children into becoming an Army of Grassroots Lobbyists for the HSUS, the HSUS also has reached out to infiltrate the Churches throughout America to become lobbying disciples as well, as evidenced by its publication of the "Animal Protections Ministries: A Guide for Churches." Conspicuous by its absence from this HSUS Guide for Churches is the Biblical Quote from the Corinthians: "Often the Devil masquerades as an Angel of Light to deceive us."

DAMNATION 34: On Pages 101-102 of the HSUS 2005 Tax Return, the following statements are made: "DESCRIPTION OF LOBBYING ACTIVITY . . . . "The Humane Society of the United States plans, coordinates and implements a public policy program. This program includes maintaining and expanding contacts with Members of Congress, State Legislators, Executive and Regulatory Agencies . . . . At the Federal Level the HSUS advocated for Animal Welfare Legislation relating to the following issues:" (15 issues were listed.) "Lobbying on these issues included direct contact with Legislators and their Staff. . . . . In addition, the HSUS assisted in sending constituent E-Mail and Faxes to Lawmakers through a functionality of the Society's Website." However, on page 18 of the same 2005 HSUS Tax Return, the HSUS stated that No "Volunteers" and no "Paid staff or management" . . . attempted "to influence national, state or local legislation, including any attempt to influence public opinion or a legislative matter or referendum." These contradictions illustrate and hallmark the repeated pervasiveness of the HSUS' Fraudulent Misrepresentations that the HSUS has made on all of its Tax Returns for the years of 2004 through 2012."

DAMNATION 35: On Pages 102-103 of the HSUS 2005 Tax Return, the following statements are made: "The HSUS addresses Animal Welfare Issue through State Legislative efforts. With Staff of Our Government Affairs Section in Washington, D.C., Regional Staff in our Field Services Section across the Country, and a network of volunteers, we are active in more than 40 State Capitols across the Country. At the State Level, 60 Animal Welfare Bills were signed into law in 2005. The HSUS advocated for legislation on the following issues:" (9 issues were listed.) . . . . "Also at the State Level, the HSUS is active in Citizen-Initiated Ballot Measures. In 2005, the HSUS worked with State Residents and Coalition Partners on Statewide Petition Drives to secure Ballot Placement and Passage for three Measures. . . . Finally, HSUS training is offered to citizens who . . . wish to participate in the legislative process and influence public policy. In 2005, the HSUS organized taught "LOBBYING 101" Workshops in a number of locations." Again, these contradictions illustrate and hallmark the repeated pervasiveness of the HSUS' Fraudulent Misrepresentations that the HSUS has made on all of its Tax Returns for the years of 2004 through 2012.

DAMNATION 36: On Pages 24-25 of the HSUS 2006 Tax Return, the following statements are made: "The Humane Society of the United States plans, coordinates and implements a public policy program. This program includes maintaining and expanding contacts with Members of Congress, State Legislators, Executive and Regulatory Agencies . . . . At the Federal Level the HSUS advocated for Animal Welfare Legislation relating to the following issues." (15 issues were listed.) "Lobbying on these issues included direct contact with Legislators and their Staff. . . . . In addition, the HSUS assisted in sending constituent E-Mail and Faxes to Lawmakers through a functionality of the Society's Website." However, on page 20 of the same 2006 HSUS Tax Return, the HSUS stated that No "Volunteers" and no "Paid staff or management" . . . attempted "to influence national, state or local legislation, including any attempt to influence public opinion or a legislative matter or referendum." These contradictions illustrate and hallmark the repeated pervasiveness of the HSUS' Fraudulent Misrepresentations that the HSUS has made on all of its Tax Returns for the years of 2004 through 2012."

DAMNATION 37: On Pages 25-26 of the HSUS 2006 Tax Return, the following statements are made: "The HSUS addresses Animal Welfare Issue through State Legislative efforts. With Staff of Our Government Affairs Section in Washington, D.C., Regional Staff in our Field Services Section across the Country, and a network of volunteers, we are active in more than 40 State Capitols across the Country. At the State Level, more than 70 Animal Welfare Bills were signed into law in 2006. The HSUS advocated for legislation on the following issues:" (I8 issues were listed.) . . . . "Also at the State Level, the HSUS is active in Citizen-Initiated Ballot Measures. In 2006, the HSUS worked with State Residents and Coalition Partners on Statewide Petition Drives to secure Ballot Placement and Passage for three Measures. . . . Finally, HSUS training is offered to citizens who . . . wish to participate in the legislative process and influence public policy. In 2006, the HSUS organized taught "LOBBYING 101" Workshops in a number of locations." Again, these contradictions illustrate and hallmark the repeated pervasiveness of the HSUS' Fraudulent Misrepresentations that the HSUS has made on all of its Tax Returns for the years of 2004 through 2012.

DAMNATION 38: On Pages 78 of the HSUS 2007 Tax Return, the following statements are made: "STATEMENT OF LOBBYING ACTIVITIES . . . . "The Humane Society of the United States plans, coordinates and implements a public policy program. This program includes maintaining and expanding contacts with Members of Congress, State Legislators, Executive and Regulatory Agencies . . . . At the Federal Level the HSUS advocated for Animal Welfare Legislation relating to the following issues:" (15 issues were listed.) However, on page 17 of the same 2005 HSUS Tax Return, the HSUS stated that No "Volunteers" and no "Paid staff or management" . . . attempted "to influence national, state or local legislation, including any attempt to influence public opinion or a legislative matter or referendum." These contradictions illustrate and hallmark the repeated pervasiveness of the HSUS' Fraudulent Misrepresentations that the HSUS has made on all of its Tax Returns for the years of 2004 through 2012."

DAMNATION 39: On Pages 19-22 of the 2008 HSUS Tax Return the following statements are made: "OHER LOBBYING ACTIVITIES . . . . "The Humane Society of the United States plans, coordinates and implements a public policy program. This program includes maintaining and expanding contacts with Members of Congress, State Legislators, Executive and Regulatory Agencies . . . . At the Federal Level the HSUS advocated for Animal Welfare Legislation relating to the following issues:" (28 issues were listed.) (NOTE: It is more than a coincidence that after Mr. Losey began submitting the first of more than 30 submittals to the IRS which chronicled examples of the contradictions being made on its tax returns for the years of 2005-2007, the HSUS FINALLY began admitting on its Tax Returns that its Volunteers and Paid Management and Staff were lobbying. However, the HSUS not only did not reduce the level of its lobbying, but it actually increased it while simultaneously making other Fraudulent Misrepresentations on its Tax Returns, as well as the Tax Returns that were filed on behalf of the HSLF.

DAMNATION 40: On Pages 22-24 of the HSUS 2008 Tax Return, the following statements are made: "The HSUS addresses Animal Welfare Issue through State Legislative efforts. With Staff of Our Government Affairs Section in Washington, D.C., Regional Staff in our Field Services Section across the Country, and a network of volunteers, we are active in all 50 State Capitols across the Country. At the State Level, 93 Animal Welfare Bills were signed into law in 2008. The HSUS advocated for legislation on the following issues:" (18 issues were listed.) . . . . "Also at the State Level, the HSUS is active in Citizen-Initiated Ballot Measures. In 2008, the HSUS worked with State Residents and Coalition Partners on Statewide Petition Drives to secure Ballot Placement and Passage for two Measures. . . . Finally, HSUS training is offered to citizens who . . . wish to participate in the legislative process and influence public policy. In 2008. the HSUS organized taught "LOBBYING 101" Workshops in more than 40 States." In short, the level of HSUS lobbying at the State Level increased in 2008. That increase added to the overall percent of lobbying by the HSUS which far exceed the permissible threshold of lobbying by a public charity, but this level was Fraudulently Underreported by the HSUS on its Tax Returns.

DAMNATION 41: Conspicuous by its absence was any detailed discussion of the HSUS Lobbying Activities in the HSUS 2009 Tax Returns, such as those that were detailed in prior year HSUS Tax Returns. However, the HSUS did post on its Website its 2009 Accomplishments. Those accomplishments included "an unprecedented 121 pro-animal state laws." Such an "unprecedented" accomplishment speaks volumes as to the magnitude of the Lobbying Activities of the HSUS which were never accurately reported by the HSUS to the IRS in its continuing pattern of obfuscation and cover-up to facilitate its Fraudulent Misrepresentations to the IRS as to the magnitude of its lobbying activities.

DAMNATION 42: Conspicuous by its absence was any detailed discussion of the HSUS Lobbying Activities in the HSUS 2010 Tax Returns, such as those that were detailed in prior year HSUS Tax Returns. However, Mr. Pacelle did discuss the highlights of the 2010 HSUS Accomplishments in his January 3, 2011 Blog which included such accomplishments as:

"In the U.S. Congress in 2010, we worked to put three major priorities on President Obama’s desk."

"The House passed nine other HSUS-backed animal protection measures."

"On Nov. 2, we scored two major state ballot measure victories."

Additionally, the HSUS posted on its Website its 2010 Accomplishments, which included the statement that: "This year, 97 new state laws and regulations were enacted to protect animals." Those HSUS accomplishments in 2010 again speak volumes as to the magnitude of the Lobbying Activities of the HSUS which were never accurately reported by the HSUS to the IRS in its continuing pattern of obfuscation and cover-up to facilitate its Fraudulent Misrepresentations to the IRS as to the magnitude of its lobbying activities.

DAMNATION 43: The HSUS has never reported the amount of revenue it receives from its collection of Annual Membership Fees on any of its 2004-2012 Tax Returns. Its Annual Membership Fee is $25.00. Thus, since it claims that it has 11+ Million Members and Supporters, that number multiplied by 9 years by $25.00 would equal almost $2.5 BILLION. Recognizing that that only 5% of its Members and Supporters may actually be paying dues, that would still amount to approximately $227,000,000 of underreported income. If this is not under-reported income, and the HSUS has listed it elsewhere on its Tax Returns, it would further corroborate the fact that the HSUS plays "Fast and Loose" with the information that it lists on its Tax Returns. And that pattern of playing "Fast and Loose" corroborates the allegations that the HSUS has made Fraudulent Misrepresentations on its Tax Returns for each year since 2004 - - the Year that Mr. Pacelle became the President and CEO of the HSUS.

DAMNATION 44: The HSUS claims that it has a data base of approximately One Million E-Mail addresses of its Members and Supporters. Typically, the HSUS will send out "TAKE ACTION" E-Mails to its Members and Supporters on average of at least once a month for the purpose urging its Members and supporters to Contact their Members of Congress, Governor or State Legislators and to urge them to support or oppose or to sign or veto a bill. With that being the case, 10 years X 12 Months X 1,000,000 Members and Supporters would equal 120 Million E-Mails that would constitute "Grass Roots" Lobbying that the HSUS has under-reported with respect to its Fraudulent Misrepresentations on its Tax Returns. If those 120 Million E-Mails were stacked SKY HIGH, the Stack would tower over 7.5 Miles Sky High. That is a lot of Grass Roots Lobbying, and the expenses to support just that one example of grass roots lobbying has never been reported on the HSUS Tax Returns for the last 10 years. Again, another example of a Fraudulent Misrepresentation by the HSUS.

DAMNATION 46: On Pages 24-26 of the HSUS 2011 Tax Return, the following statements are made:

"The HSUS utilizes unpaid volunteers to collect signatures for referenda, contact legislators and their staffs."

"HSUS Management and Staff plan, coordinate, and implement a Public Policy Program. This Program includes maintaining and expanding contacts with Members of Congress, State Legislators, Executive and Regulatory Agencies."

"The HSUS published advertisements through the Media in an effort to influence legislation and to influence public opinion on Legislative Matters or Referenda."

"Mailing to Members, Legislators, or the Public. . . . The HSUS assisted interested parties in sending EMAIL and FAXES to Lawmakers through the Society's Website."

"The HSUS made statements in its electronic and print publications as well as in published or broadcast statements intended to influence Legislation and to influence Public Opinion on Legislative Matters or Referenda."

"The HSUS made several GRANTS to State Ballot Committees."

"Direct contact with Legislators, their Staffs, Government Officials or a Legislative Body: In furtherance of its efforts to influence Legislation and to influence Public Opinion on Legislative Matter of referenda, HSUS Staff, unpaid Volunteers, ad Paid Consultants have direct contact with Legislators and their Staff, Government Officials, and Legislative Bodies"

"The HSUS held Lobby days in various State Capitols for citizens who . . . wish to participate in the Legislative Process and influence public Policy.

"The HSUS also held a "Taking Action for Animals" Conference which included a Lobbying Day for Volunteers and attendees" (In the Nation's Capitol).

"The HSUS utilized Paid Consultants to assist with media advertisements and engage in direct contact with Legislators and their Staffs."

The following quotes are found on Pages 104-114 of the HSUS 2011 Tax Return:

The HSUS employed State Directors in 41 States during 2011. State Directors advance Animal Protection in outreach to the Public, network with grassroots advocates, LEGISLATORS, and others."

"State Directors supported efforts to pass 91 Pro-Animal State Laws and Regulations.

"State Directors also worked to defeat 70 Bills threatening Animal Welfare in the States."

"Members of the Section worked to defeat AGGAG Bills."

"This Section also helps to pass stronger Laws to protect Dogs in Puppy Mills. In 2011 alone, seven States enacted Laws concerning Puppy Mills."

"In 2011, the Campaign expanded its involvement in anti-poaching Legislation, . . . working to introduce Bills."

"The Campaign's commitment to grassroots action helped to ensure that none of these Bills were successful."

"A review of bad Bills we defeated this past State Session."

"The HSUS Federal Affairs Section focuses on support and passage of Animal Protection Legislation and Regulatory Measures at the Federal Level."

"The Program also worked with the Appropriations Committees to include helpful language for Federal Agencies."

"Staff Members helped . . . to defeat an Anti-Wildlife Rider in the Interior Department Funding Bill."

The above 21 quotes from just this one of thousands of documents, that the HSUS generates each year, capture and illuminate the breadth and magnitude of the "all-consuming" lobbying activities of the HSUS, but precious little, if any, of the expenses in support of these lobbying activities were reported on the 2011 HSUS Tax Return. Yet another Fraudulent Misrepresentation.

DAMNATION 46: The Federal Election Commission Data Base reveals that Mr. Pacelle, who serves as the HSUS President and CEO, as well as the Vice President of the HSUS Legislative Fund, made political contributions to the Humane Society Legislative Fund Political Action Committee and to three Congressional Candidates in 2011. Additionally, the HSLF, under the leadership of Mr. Pacelle and Mr. Markarian, the two most Senior HSUS and HSLF Officials, made political contributions to political candidates in 2011. However, the HSUS stated on Page 3 of its 2011 Tax Return that the HSUS did not "engage in direct or INDIRECT political campaign activities on behalf of or in opposition to candidates for public office." Yet another Fraudulent Misrepresentation.

DAMNATION 47: A review of the Wayne Pacelle BLOGs that were posted on the HSUS Website in 2011 clearly reveals that Mr. Pacelle personally excoriated such Congressional Candidates as Iowa Congressman King. Furthermore, Millions of Dollars were contributed to Congressional Candidates in 2012 by the HSLF, under the Leadership of Mr. Pacelle and Mr. Markarian, the two most Senior Officers of the HSUS. However, the HSUS stated on Page 3 of its 2011 Tax Return that the HSUS did not "engage in direct or INDIRECT political campaign activities on behalf of or in opposition to candidates for public office." Yet another Fraudulent Misrepresentation. And it would defy all common sense logic for anyone to suggest that the use of the "ruse" that the HSLF is totally independent of the HSUS when the two most Senior Officers of the HSUS are the two most Senior Officers of the HSLF.

DAMNATION 48: Federal Election Commission Documents filed by the HSLF for 2012 political contributions, and the HSUS 2012 Website Postings, reveal the enormity of the direct and indirect political campaign activities of Mr. Pacelle and Mr. Markarian, the two most Senior Officials of the HSUS and the HSLF. However, once again, the HSUS stated on Page 3 of its 2012 Tax Returns that it did not "engage in direct or INDIRECT political campaign activities on behalf of or in opposition to candidates for public office." Again, it is noteworthy to point out that the HSLF, in addition to endorsing or opposing nearly 200 Congressional Candidates in 2012, made specific contributions, as reflected on its filings with the Federal Election Commission, in excess of $750,000 in its unsuccessful effort to oppose the re-election of Iowa Congressman King. Yet another Fraudulent Misrepresentation, especially in light of the fact that Mr. Pacelle is the "founder" and the Vice President of the HSLF!

DAMNATION 49: On Page 65 of the HSUS 2012 Tax Return, the HSUS lists as a "GRANT" the contribution of $100,000 to the "NORTH DAKOTANS TO STOP ANIMAL CRUELTY;" yet another 501 (c) (4) Lobbying Organization that it supported in 2012 with not only this "GRANT" but with extensive support through the use of the HSUS Website. However, none of those Lobbying related expenses in support of this Ballot Initiative Campaign were reported as Lobbying Expenses on its 2012 Tax Return. Yet another Fraudulent Misrepresentation.

DAMNATION 50: Under the Guise of the HSLF, which is being used as a ruse to mask, obfuscate and cover-up the direct and indirect lobbying activities and prohibited political campaign activities of the HSUS, the HSLF endorsed the then Senator Obama for President in 2008.

DAMNATION 51: The White House Visitors Log documents that Mr. Wayne Pacelle made multiple visits to the White House. Obviously those visits were intended to perpetuate and facilitate the brazen Lobbying Activities of the HSUS. However, details of the purpose of those visits were never publicly disclosed. Nevertheless, the number and timing of these "Contacts" confirm multiple Lobbying Contacts with "Covered" Officials at the highest levels in the Executive Branch of Government. However, these Lobbying Related Contacts were never reported as being "lobbying related" with respect to any Tax Returns submitted by the HSUS to the IRS.

DAMNATION 52: A "clue" as to the purpose of the above referenced White House Visits may be deduced from the fact that in January of 2009, Mr. Pacelle and the HSUS ballyhooed on the HSUS Website the launch of its “ HYPERLINK "http://www.hsus.org/web-files/PDF/change-agenda-for-animals-hsus-hslf-1-30-09.pdf" \t "_blank" Change Agenda for Animals." In this regard, on January 19, 2009 Mr. Pacelle posted the following on his HSUS Website BLOG: "With the changing of the guard at the White House comes the prospect of new possibilities for moving our goals forward, and to mark this latest transfer of power, The HSUS and the Humane Society Legislative Fund (HSLF) are advancing a 100-point “ HYPERLINK "http://www.hsus.org/web-files/PDF/change-agenda-for-animals-hsus-hslf-1-30-09.pdf" \t "_blank" Change Agenda for Animals." This Agenda included 102 very specific recommendations for the new Obama Administration to adopt which would affect the activities of 18 different Federal Agencies. And Mr. Pacelle used the HSUS Website to urge the Administration to adopt the HSUS “ HYPERLINK "http://www.hsus.org/web-files/PDF/change-agenda-for-animals-hsus-hslf-1-30-09.pdf" \t "_blank" Change Agenda for Animals," and the HSUS has each year given the Obama Administration a "Grade" on how well it has supported the HSUS Lobbying Agenda. Once again, none of the expenses associated with lobbying the Administration and 18 Executive Agencies have been reported as Lobbying Expenses on the HSUS Tax Returns. And since the Lobbying Disclosure Act defines Lobbying to included "Contacts" with the "Covered Executive Branch Officials;" and since the Lobbying Disclosure Act expressly lists the President of the U.S. as a "Covered Executive Branch Official," the omission of these Lobbying-Related Contacts at the Highest Level of Our Government represents yet another Fraudulent Misrepresentation by the HSUS as to the calculation of whether the HSUS exceeds the "substantial" threshold for "too much lobbying."

DAMNATION 53: On May 29, 2009, the HSUS posted on its Website "HSUS Accomplishments." Included among its accomplishments was the following quote: "We released a 100-point “ HYPERLINK "http://www.hsus.org/web-files/PDF/change-agenda-for-animals-hsus-hslf-1-30-09.pdf" \t "_blank" Change Agenda for Animals" to the Obama Administration and began campaigning for these reforms in Congress and in executive agencies with jurisdiction over animal issues." It is most noteworthy that neither the HSUS nor the HSLF nor any of its paid management and Staff were registered with the Clerk of the House or the Secretary of the Senate at any time during 2009, notwithstanding the fact that literally 1,000s of multiple "contacts" were made in 2009 by HSUS Paid Staff and Management with most of the 535 Members of Congress and Hundreds of Federal Employees in the 18 Federal Agencies that were included in the “ HYPERLINK "http://www.hsus.org/web-files/PDF/change-agenda-for-animals-hsus-hslf-1-30-09.pdf" \t "_blank" Change Agenda for Animals." Furthermore, when the HSUS filed it 2009 IRS Tax Return, it did not include any portion of the fully burdened salaries of the HSUS Paid Management and Staff who literally made 1,000s of "lobbying" "contacts" with "Covered" Members of the Executive and Legislative Branches of Government. Yet another Fraudulent Misrepresentation to the IRS by the HSUS.

DAMNATION 54: Another blatant example of the "Cover-Ups" orchestrated by the HSUS to conceal the magnitude and pervasiveness of the Lobbying Activities of the HSUS is the fact that prior to when Mr. Losey began sending over 3,200 pages of incriminating documents to the IRS, which substantiated the Fraudulent Misrepresentations of the HSUS with respect to its Lobbying Activities, the BIO for Ms. Connie Harriman-Whitfield, which was posted on the HSUS Website, and which was printed with the HSUS LOGO on it stated the following:

Senior Advisor, Presidential Initiatives

The Humane Society of the United States

Connie Harriman-Whitfield develops initiatives in the areas of outreach, policy and legislation for President and CEO Wayne Pacelle.

This meant that her fully-burdened salary was being paid by the HSUS, but none of those expenses were reported by the HSUS as Lobbying Expenses, even though she expressly developed legislation for President and CEO Wayne Pacelle. However, when the HSLF belatedly registered itself as a "Lobbying Organization" with the Secretary of the Senate and the Clerk of the House, and listed Ms. Harriman-Whitfield as its Chief Lobbyist, her BIO was transferred to the HSLF Website, and it was changed to read: "senior policy adviser for the Humane Society Legislative Fund where she develops initiatives in the areas of outreach, policy, and legislation." The tweaking and the transfer of her BIO is nothing more than a blatantly obvious and unadulterated attempt to cover-up her lobbying activities on behalf of the HSUS and Mr. Pacelle, who "coincidentally" also serves as the Vice President of the HSLF. In short, changes in the wording of her BIO did not change the fact that she continues to be a major architect of the Legislative and Lobbying Agenda of the HSUS. In short, a MAJOR FRAUDLENT MISREPRESENTATION!

DAMNATION 55: The above "smoke and mirror" game of deception and obfuscation by the HSUS is but one of the more than 25 examples of transfers and deletions from the HSUS Website that Mr. Losey Documented as Cover-Ups in the letters that he sent to the IRS, including 15 Letters which were personally addressed to Ms. Lerner who asserted her Fifth Amendment Right not to incriminate herself, and who has never "OFFICIALLY" been asked the question as to WHY the HSUS was never held accountable for non-compliance with the U.S. Tax Code and Implementing IRS Regulations that limit the amount of lobbying that a public charity may do; and which explicitly prohibits participation in political campaigns at the Federal or State or Local Levels of Government. And if the opportunity ever arises to ask Ms. Lerner that question, she should also be asked if her Membership in the HSUS represented a "Conflict of Interest" with respect to the Oversight by her Office of all Tax Exempt Organizations.

DAMNATION 56: When the HSUS recruits State Directors, they are expected to Lobby, as evidenced by an HSUS “Employment Opportunities” Posting that was dated July 9, 2010, and which sought to fill four vacancies in Alaska, Kansas, New Jersey and Nebraska. Published qualifications for these open positions included the following quotes: “Other duties include . . . advance state and federal legislative priorities; build activist coalitions and work with grassroots supporters; establish and build professional working relationships with government agencies. . . . . 1-2 years lobbying experience, and grassroots advocacy and political campaigning are highly desirable.” Despite the explicit emphasis that the HSUS places on "lobbying" qualifications for its State Directors, the HSUS has never listed its State Directors as Lobbyists for purposes of determining what percent of their activities should be counted in its determination of whether or not the HSUS engages in "too much lobbying."

DAMNATION 57: None of the fully burdened HSUS salaries, office and administrative support expenses for each of the HSUS State Directors in over 40 States who lobbied in support of State Bills were included in the 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011 and 2012 HSUS Tax Returns. And their stated purpose is to Lobby in support of or in opposition to bills supported or opposed by the HSUS. For example, extracts from the records maintained on the Website of the Secretary of State for California reveal that the HSUS and Ms. Jennifer L. Fearing “lobbied” with respect to a total of 26 bills and resolutions being considered by the California Legislature during the 2009 and 2010 sessions. And none of her fully burdened salary and administrative support expenses were reported as Lobbying Expenses. To put the salaries of 40 HSUS State Directors who lobby in perspective, even if their fully burdened salaries, without regard to collateral support expenses, averaged $50,000 a year, that would cumulatively amount to direct lobbying expenses of $2 Million a year, and not a dime was reported as "Lobbying Expenses on the HSUS Tax Returns!" Yet another Fraudulent Misrepresentation.

DAMNATION 58: Mr. Pacelle is obviously aware of the fact that States require the HSUS to provide salary information on individuals that it employs as Lobbyists. Proof of that fact is the letter that was signed by Mr. Pacelle on November 30, 2009, which letter was addressed to the New York State Commission on Public Integrity. This letter informed the State of New York that "Dora Schomberg will receive a salary for a period of two years totaling $81, 240.64 . . . for lobbying." However, those expenses were never reported on the HSUS Tax Returns for 2009 and 2010 as "Lobbying Expenses." Yet another Fraudulent Misrepresentation.

DAMNATION 59: On October 11, 2013 Mr. Pacelle stated in his BLOG that was posted on the HSUS Website: "Gov. Jerry Brown today signed legislation to make California the first state in the nation to halt the use of lead ammunition in hunting. The HSUS led the fight . . . . In all, since voters passed Proposition 2 in California in 2008, state lawmakers and two governors have together enacted more than 40 new statutes for animals . . . . Hats off to my colleague, California senior state director Jennifer Fearing, and the rest of our team for leading the advocacy efforts and skillfully working with so many lawmakers and with Gov. Brown." Yet another "official" admission that HSUS State Directors play a dominant role in the overall Matrix of the most sophisticated Lobbying Organization in the U.S. And the referenced "40 new statutes" in a period of but 6 years in just one State illustrates why Mr. Pacelle was able to boast and state that: "We have passed 1,000 laws in the last decade."

DAMNATION 60: Many of the HSUS State Directors not only lobby, but they increasingly set the stage for the HSUS Members and Supporters to complement the active lobbying agenda for the HSUS with intimidating threats to elected officials. For example, their "vindictive" agenda is best personified by the Jennifer Fearing, the HSUS "Senior" State Director for California who stated: “Elected officials need to be held accountable for their actions. Remember this when you vote.” This quote from the "Senior" HSUS State Director in California is a blatant violation of the absolute IRS prohibition that provides that no, without exception, Public Charity may be "indirectly or directly involved in political campaign activities of supporting or OPPOSING a political candidate." And oh yes, she is registered to Lobby in the State of California!

DAMNATION 61: Two of the most blatant quotes that Mr. Pacelle has made about the commitment of HSUS to lobby and to lobby effectively are cited below.

“Our . . . lobbyists . . . have the experience, training, and resources to do the work you expect of us.”

“We employ teams of . . . lobbyists.”

Once again the HSUS highlights and brags about its commitment to lobbying. However, it goes to great lengths not to tell the IRS the true amount and magnitude of its direct and indirect Lobbying Activities on its Tax Returns, which is blatantly contradicted by what the HSUS Senior Leadership says and posts what it does on its HSUS Website. Yet another Fraudulent Misrepresentation. In short, how can Mr. Pacelle brag about passing "1,000 laws in the last decade" without devoting literally Tens of Millions of Hours and Several Hundred Millions of Dollars in the last 10 years to raw, unadulterated "LOBBYING?????"

DAMNATION 62: The BIO of Ms. Nancy Perry, the former Vice President of the HSUS for Government Affairs, stated that the following: “She oversees lobbying efforts in state legislatures, including ballot measure campaigns, and Congress and directs grassroots activities nationwide. She also lobbies directly for federal animal protection legislation.” However, none of her fully burdened salary, nor the fully burdened salaries of her Support Staff were reported as "Lobbying Expenses" on the HSUS Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 63: In September of 2012, a search of the HSUS Website, that used "Government Affairs" as the search phrase, produced documents that outlined the Bills that the HSUS was supporting or opposing in 46 States, as well Federal Bills being considered by Congress. And what was so telling is that at the top of each page was the following quote: "Legislation. . . . The Government Affairs section supports public policies - - principally at the state and federal levels." Yet another illustrative example of Lobbying-Related Expenses that were never included in the Lobbying Expenditures reported by the HSUS on its Tax Returns.

DAMNATION 64: When Ms. Perry vacated her position in 2011 to become the Senior Vice President for the American Society for the Prevention of Cruelty to Animals (ASPCA), which now co-sponsors the HSUS Lobby Day Events in the State Capitols, the title of her vacated position was changed to Vice President for Federal Affairs, and it is currently filled by Ms. Cece Kremer. Although the words "lobby," "lobbies," and "lobbying" do not appear in Ms. Kremer's job description - - yet another "cover-up" by the HSUS after Mr. Losey included a copy of Ms. Perry's BIO in his submission to Ms. Lois Lerner that was dated October 29, 2010 - - Ms. Kremer does "Lobby" and has oversight over Lobbying Activities conducted by the HSUS. However, none of her fully burdened salary or those of her support staff, or the administrative costs incurred as a result of the activities of her Office have ever been reported as "Lobbying Expenses" on the HSUS Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 65: To put the "COVER-UP" of the true nature of the Lobbying Activities of the HSUS Federal Affairs Office in perspective, one only needs to review the job description posted on the HSUS Website under the title of "Employment Opportunities." It stated that the HSUS is now seeking "Legislative Interns" to augment its staff of its "Federal Affairs Section, which handles all federal legislation and regulatory issues for the Humane Society of the United States." In short, "Lobbying" by any other name is still "LOBBYING." And consistent with a criminal pattern of conduct, none of the Fully Burdened Salaries of any Paid Employee within the HSUS Federal Affairs Office has been reported on the HSUS Tax Returns as "Lobbying Expenses." Yet another Fraudulent Misrepresentation.

DAMNATION 66: On December 30, 2013 the HSUS stated in a Motion that was filed in Lawsuit in the United States District Court for the District of Columbia (Case 1:13-cv-01982-RLW): "The Final Rule is the culmination of years of efforts on the part of the HSUS to bring about meaningful change to existing law. . . . One way that The HSUS works . . . is to regularly seek legislative and regulatory changes on the local, state and Federal level. . . . the Final Rule that The HSUS worked so hard to see published." In short, the HSUS made a judicial confession that it lobbied the Department of Agriculture for a number of years "to bring about meaningful change to existing law." In this regard, existing Federal Laws and Regulations define lobbying to include "contacts" with any "Covered" Official in the Executive Branch of Our Government. These types of contacts with Executive Officials at the Federal and State Levels of Government have routinely occurred almost every business day for the last 10 years by an HSUS Paid Staff or Management person who receives his or her salary from the HSUS. However, not a single dime of their fully funded salaries and expenses have ever been listed as lobbying expenses on the IRS Tax Returns for the last 10 years. Yet another Fraudulent Misrepresentation on the Tax Returns of the HSUS.

DAMNATION 67: The HSUS claims to have more than 2,000 Attorneys who provide "Pro Bono" free legal services to the HSUS. Many of the tens of thousands of otherwise billable hours provided by Pro Bono Attorneys directly and indirectly support the overall lobbying agenda of the HSUS. However, the HSUS has never identified a single hour of pro bono legal services in the IRS formula for determining if the "too much lobbying" threshold for a public charity has been exceeded. Yet another Fraudulent Misrepresentation.

DAMNATION 68: Yet another damning and incriminating quote of Mr. Pacelle occurred on December 30, 2013. This quote highlights how the HSUS uses the Judicial Branch of our Government to perpetuate its comprehensive and sophisticated "Lobbying Machine."

"After I was elected president of The HSUS nearly a decade ago . . . one thing I set out to do was to create a dedicated unit of animal protection lawyers . . . to support our legislative . . . campaigns."

"Over the last eight years, our Animal Protection Litigation team has filed more than 130 legal actions."

Almost without exception, the HSUS has cited its lobbying activities within either the legislative or executive branches of Government as the basis for its "legal standing" to become a party to the 130+ Lawsuits. Most tellingly, none of those "legal expenses" are listed as "lobbying expenses" on the HSUS Tax Returns. Yet another Fraudulent Misrepresentation on its Tax Returns.

DAMNATION 69: On September 25, 2013 the Judge for the United States District Court for the District of Columbia (Case 1:12-cv-01582-ABJ) made a telling, revealing and damning judicial finding that the HSUS was a LOBBYING ORGANIZATION. The specific quote of the Judge, that is found on page 32 of the Judge's "Memorandum Opinion," reads as follows:

"Spending funds to counteract opposition to a legislative agenda is a normal and critical part of the Humane Society . . . mission and operations. Put another way: LOBBYING is what these organizations do."

In light of the Judicial Determination made by a U.S. Federal District Judge in the District of Columbia that "Lobbying" is what the HSUS does, does not that conclusively prove, beyond any reasonable doubt, that a dominant portion of the annual expenditures of the HSUS is dedicated to lobbying and prohibited political campaign activities, and that the associated expenses of such lobbying activities have never been reported on the HSUS Tax Returns? Yet another Fraudulent Misrepresentation.

DAMNATION 70: On December 5, 2013 Mr. Pacelle stated in his BLOG that was posted on the HSUS Website: "The HSUS helped to secure 107 new state laws to protect animals in 2013 . . . the highest number in four years." This "accomplishment" highlights the fact that a major mantra of the Corporate Ethos of the HSUS is to willfully and wantonly lobby at the State Levels of Government without regard to the lobbying limitations that are set out in IRS Implementing Regulations. In short, the HSUS consistently acts as if it is "Above the Law," and most disturbingly, the IRS has ignored the illegal and non-compliant activities of the HSUS for the last 10 years.

DAMNATION 71: On November 15, 2013 Mr. Pacelle stated in his BLOG that was posted on the HSUS Website: "Last night , the Senate gave final approval to a bill - - backed by The HSUS. . . . The passage of this legislation . . . caps a remarkable series of successful initiatives executed by the HSUS." Yet another example of how the HSUS consistently acts as if it is "Above the Law."

DAMNATION 72: On November 1, 2013 Mr. Pacelle stated in his BLOG that was posted on the HSUS Website: Our team blocked so-called 'ag-gag' legislation in 11 states - - Arkansas, California, Indiana, Nebraska, New Hampshire, New Mexico, North Carolina, Pennsylvania, Tennessee, Wyoming and Vermont. . . . .The HSUS is working hard to build a body of law to shield animals from cruelty and abuse. Please get involved with your state and your HSUS state director." Once again Mr. Pacelle highlights the comprehensive involvement of the HSUS State Directors in their Lobbying Efforts, notwithstanding the fact their salaries and expenses are never reported on the HSUS Tax Returns as "LOBBYING EXPENSES." Yet another Fraudulent Misrepresentation on its Annual Tax Returns.

DAMNATION 73: In 2010 Pacelle sent out signed invitations to prospective new dues-paying “members,” and he cited the following quote as one of the “REASONS TO JOIN THE HSUS TODAY: . . . Your membership ensures that your HSUS will continue to be the leading voice for animal protection in the United States by effectively lobbying for the passage of dozens of laws to protect animals.” Since one of the cited purposes for soliciting new members was to be able to "effectively lobbying for the passage of dozens of laws," at least a portion of the expenses incurred as a result of the "New Membership Drive" should have been allocated to the category of indirect lobbying expenses. However, no such allocation was reported on the HSUS Tax Returns for 2010. Yet another Fraudulent Misrepresentation.

DAMNATION 74: The HSUS has scheduled another of its "Taking Action for Animals" (TAFA) Event that will take place in Washington DC from June 27-30, 2014. Quotes from its promotion of this Event from past years clearly substantiate that its focus is on Lobbying Members of Congress. Extracted Quotes from its TAFA Event in 2010 included:

“Get Ready to Lobby Training Session.”

“Required to attend Monday Lobby Day."

“If you plan to attend Lobby Day on Monday, you must attend this Lobby Day training session before joining us on Capitol Hill. This program will give you all the skills you need to meet your legislators or staff and discuss important animal protection legislation. Lobby Day packets will be available at the HSUS Government Affairs table at the Exhibit Hall all weekend, and you can pick them up right before Lobby Day training.”

“JOIN US FOR LOBBY DAY. . . Monday, July 26 . . .9:30 a.m. – 4:00 p.m. . . . Russell Senate Office Building, Room 385.”

On Monday, you can put your new skills into practice as you join us on Capitol Hill and meet with your legislators or their staff to discuss . . . legislation. Our lobbyists will be there to help you with any questions about your meetings - - we'll give you everything you need to be effective.”

“Your appointments will be made for you.”

Despite the fact that the primary purpose of the 4-Day Event is to train the hundreds of attendees on how best to lobby their respective Members of Congress to support the HSUS Legislative Agenda, which culminates with the hundreds of HSUS trained "grass roots" lobbyists descending upon the U.S. Capitol on the Fourth Day of the Event, not a single dime of these lobbying related expenses were reported as Lobbying Expenses on the HSUS Annual Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 75: The HSUS prepared, published and posted on its Website three Lobbying related Documents: "What Influences a Legislator," "A Handbook for the Citizen Lobbyist," and "Tips for Successful Lobbying." These publications are also made available to the cumulative 1,000s of attendees at the HSUS "Taking Action for Animals" (TAFA) Events, as well as the hundreds of Lobbying Workshops that the HSUS has conducted throughout the U.S. since 2004. None of the expenses associated with the research, preparation, publishing, Internet Postings or reproduction of these documents have ever been reported as "Lobbying Expenses" on the HSUS Annual Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 76: The above referenced "Handbook for the Citizen Lobbyist" makes reference to the "HSUS Action Network (which) is a national grassroots project of the HSUS that organizes individuals by legislative district to develop grass roots support for animal protection legislation at the state and federal levels. When urgent action is needed on animal protection legislation, the network is activated and activists are called to contact their legislators about a particular piece of legislation." Obviously this Lobbying "Network" involves a sophisticated use of the Internet that requires HSUS support staff to support the functionality of this grassroots Lobbying "Network." However, the HSUS has never reported the costs to support this Lobbying "Network" as "Lobbying Expenses" on its IRS Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 77: Each Year the HSUS conducts Hobby Day Workshops in the State Capitols. Found on the HSUS Website is its current posting about Hobby Day Workshops scheduled for 2014. (Similar Postings were made on the HSUS Website for past years.) A quote from the HSUS Website currently reads: "Humane Lobby Days are events sponsored by The Humane Society of the United States in state capitals across the country. Citizen animal advocates like you gather to learn and practice lobbying for animal protection laws at the state level. These full-day events include a lobbying workshop and an overview of relevant bills in your state legislature. Appointments are made for you with your state legislators so that you can meet with them (or their staff) face to face and ask for animal-friendly votes. Click your state below for details and to RSVP. No Humane Lobby Day listed for your state yet? Check back soon—more events will be added." (As of February 1, 2014, the HSUS had already scheduled and posted a listing of 23 State Capitols where the Humane Lobby Day Workshops and Events will be held.) None of the expenses associated with Humane Lobby Day Workshops and Events have ever ever been reported as "Lobbying Expenses" on the HSUS Annual Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 78: Each year the HSUS and the HSLF prepare a "Humane Scorecard" which tracks the voting records of all Members of Congress on Bills "sponsored" by the HSUS. And then around the March timeframe of each year, the HSUS sponsors a Congressional Awards Dinner inside of the U.S. Capitol Building which gives special recognition to those Members of Congress who have best supported the HSUS Legislative Agenda in the prior year. (Note: After Mr. Losey "outed" these events to the IRS, the HSUS ceased posting the Humane Scorecard on its Website, and transferred the Humane Scorecard postings to the HSLF Website - - Mr. Pacelle and Mr. Marakarian are the two Most Senior Officers for both the HSUS and the HSLF) Although the HSUS claims that this is a permissible "contact" event because it is conducted under the ruse of the HSLF, what is so telling is the fact that after the events, photos of Mr. Pacelle and Mr. Markarian, with Members of Congress, are posted on the HSUS and the HSLF Website, AND WITHOUT EXCEPTION, the background for each of these photos has been the LOGO of the HSUS, and not the LOGO of the HSLF. In short, yet another blatant and conscious attempt to "cover-up" the fact that the Congressional Award Dinners that are held inside of the U.S. Capitol Building are actually hosted and sponsored by the HSUS. And once again, none of the "Lobbying Expenses" associated with the HSUS Congressional Awards Dinner have ever been reported as "Lobbying Expenses" on the HSUS Annual Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 79: In addition to honoring Members of Congress each year for their support of HSUS Federal Legislative Agenda, the HSUS also honors State Legislators by presenting to them the HSUS State Legislator Awards. For example, in 2008 the HSUS honored a total of 36 State Legislators from 20 different states. However, none of the lobbying contacts nor the expenses associated with presenting the awards to State Legislators for 2008, or for any other year, were ever reported as "Lobbying Expenses" on the HSUS Annual Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 80: Each year the HSUS hosts various types of events and receptions that allow its Paid Officers and Staff; HSUS Members; and HSUS Volunteers to have contact opportunities with State Legislators so that they may lobby directly with State Legislators in support of the HSUS Legislative Agenda. For example, on February 8, 2010, the HSUS hosted a Reception in the State Capitol Rotunda in Sacramento, CA. The invitation expressly stated: "hosted by The Humane Society of the United States featuring President and CEO Wayne Pacelle . . . . Hosted bar and appetizers. . . . Note: attendance at this event by a public official will constitute acceptance of a reportable gift." Documentation received from the California Legislature Joint Committee on Rules stated that the HSUS paid "$822 for use of Capitol facilities." It is unknown how much the HSUS paid for the "bar and appetizers," or the cost of Lodging and Air Fare for Mr. Pacelle to fly from Washington DC to Sacramento, CA to attend the Reception for California State Legislators. However none of those costs and none of the $822 that was paid "for use of Capitol facilities" was reported as "Lobbying Expenses" on the HSUS 2010 Tax Return. Yet another Fraudulent Misrepresentation by the HSUS.

DAMNATION 81: Tens of Thousands of HSUS "volunteers" cumulatively devote several Million Hours each year to attending Lobbying Workshops; gathering signatures for State Ballot Initiatives; communicating with their respective Members of Congress, State Governors and State Legislators; communicating with senior Officials in the Executive Branches of the Federal and State Governments; lobbying and advocating in support of the Legislative and Regulatory Agenda of the HSUS; "Walking the Halls of Congress;" Walking the Halls of State Capitols; meeting with Members of Congress and State Legislatures; communicating with News Media staff; and providing "pro bono" legal services. All of those Million of Hours are singularly dedicated to what the IRS considers to be grass roots "LOBBYING." And that is why the IRS Tax Form 990s that all Tax-Exempt, Public Charities must submit to the IRS each year ask the specific question: "During this year, did the filing organization attempt to influence foreign, national, state, or local legislation, including any attempt to influence public opinion on a legislative matter or referendum, through the use of . . . Volunteers?" Although the HSUS finally began answering that question with a "YES," after Mr. Losey "outed" the misrepresentations of the HSUS on its Tax Returns prior to 2008 when the HSUS answered that question with a "NO," THE HSUS HAS NEVER ACCOUNTED FOR, OR BEEN REQUIRED BY THE IRS TO ACCOUNT FOR, THE MILLIONS OF HOURS THAT ITS VOLUNTEERS CUMULATIVELY DEVOTE EACH YEAR TO THE LOBBYING ON BEHALF OF THE HSUS LEGISLATIVE AGENDA AT THE FEDERAL, STATE AND LOCAL LEVELS OF GOVERNMENT. Such a glaring omission represents yet another Fraudulent Misrepresentation by the HSUS.

DAMNATION 83: As documented in a letter that Mr. Losey sent to Ms. Lois Lerner that was dated April 9, 2013, Mr. Pacelle made a total of 21 incriminating admissions in his E-Mails and BLOGs that were posted on the HSUS Website during the first three months of 2013. His quotes capture the essence of the unbridled commitment of Mr. Pacelle to personally lobby and to oversee the enormity of the most sophisticated "LOBBY MILL" in the U.S. that deceptively cloaks itself in the role of a "Pubic Charity." Quotes included:

"Congress Comes Up Lame on Animal Issues. . . . For as long as I have been spending time on Capitol Hill and advocating for the HSUS and its concerns (18 years)."

"We'll work hard in the new 113th Congress. . . . Of course, we also concentrated our resources on state legislatures. . . . The HSUS is willing to confront our adversaries . . . in legislative bodies."

"Today we announce . . . the launch of a referendum campaign in Michigan to nullify the legislature's ill-considered action."

"In 2012, the HSUS helped pass 74 new laws and regulations and helped to defeat more than 100 harmful measures. In the last eight years, we've helped to pass about 700 laws. Most state legislatures are gearing up now for their 2013 sessions. We're going to work even harder this year."

"The Humane Society of the United States is urging the Wyoming Legislature to oppose anti-whistleblower legislation introduced by State Rep. Sue Wallis.

Humane Lobby Day is sponsored by the Humane Society of the United States. . . . In 2012, the Humane Society of the United States helped pass 74 new laws."

"Sign the pledge. . . . seeking to place a referendum on the Michigan ballot in 2014.. "We've petitioned the U.S. Department of Agriculture.

TAKE ACTION. Please make a brief, polite phone call to your U.S. Representative to urge co-sponsorship of H.R. 366. Look up your legislator's phone number (here). . . . After making your phone call (please do not skip that crucial step!), fill in and submit the form below to automatically send a follow-up message to your U.S. Representative."

"Oklahoma was one of the last states to outlaw cockfighting (a feat finally accomplished thanks to an HSUS ballot initiative."

The Humane Society of the United States invites our members, supporters, and other animal advocate to a special Lobby 101 Seminar. . . . RSVP today to become a successful citizen lobbyist."

"Tell the Commissioner to rethink it.

"Please urge Congress to pass the PUPS Act. . . . TAKE ACTION. Complete the form below to automatically send a message to your legislators to express your support for the PUPS Act. Look up your legislators phone numbers here. After making your phone call (please do not skip that crucial step!), fill in and submit the form below to automatically send a follow-up message to your legislators."

"Starting in the 1990s, The HSUS . . . launched statewide ballot initiatives."

TAKE ACTION. Please make a brief, polite phone call to your U.S. Representative and two U.S. Senators to urge co-sponsorship of H.R. 1094/S. 541. . . . Look up your legislators phone numbers here. . . . After making your phone call (please do not skip that crucial step!), fill in and submit the form below to automatically send a follow-up message to your members of Congress."

"The HSUS helped to organize a lobby day in Austin last week. . . . The HSUS is also working in states across the country on this issue and is actively working in New York, Maryland, Massachusetts and Delaware to pass laws."

"The HSUS submitted 253,705 signatures in support of a referendum to nullify the Michigan legislature's December 2012 act. . . . We . . . will have to conduct a sophisticated public-relations campaign to win that vote in a November 2014 election."

"Yesterday, The HSUS took out the first in a series of full-page advertisements in Indiana Newspapers condemning proposed anti-whistleblower or 'ag-gag' legislation."

"The Humane Society of the United States is urging the North Dakota House of Representatives to pass legislation that cleared the Senate last month.

"We urge the House of Representatives to oppose this bill."

"Last week, in Michigan, our organization turned in 253,000 signatures in support of a referendum."

These incriminating statements by Mr. Pacelle were made over a period of 3 months - - an average of 1 1/2 per week - - and they represent the all-consuming agenda of the HSUS to dedicate the bulk of its resources to "Lobbying." However, the HSUS does not report on its Tax Returns any of the associated time Lobbying Expenses used in support of these "unidentified" lobbying activities on its Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 83: In an ongoing effort to "conceal" and "cover-up" the excessive and pervasive lobbying activities of the HSUS, the HSUS uses its 501 (3) (c) Subsidiaries to launder some of its lobbying activities. For example, the Humane Society Veterinarian Medical Association (HSVMA) solicited Membership in its organization in January of 2013. In its solicitation Letter, it stated its four major accomplishments in 2012. The second accomplishment (25% of the four major accomplishments) reads as follows: "Lobby for various animal welfare reforms at the state and federal levels. . . . And in California, HSVMA support helped pass a landmark bill banning "hounding" of bears and bobcats. . . . At the federal level, HSVMA is supporting bills to protect egg laying hens and at-risk horses . . . ." Here it is also noteworthy that the address for the HSVMA is the same address as for the HSUS, which serves as the "LOBBYING PUPPETEER" for all of its subsidiaries.

DAMNATION 85: Any suggestion that the HSVMA acts totally independent from the HSUS is refuted when one reads the BIO of Ms. Holly Hazard, HSUS Senior Vice President, Programs and Innovations , which was submitted as Tab 11 by Mr. Losey in a letter dated February 5, 2013 that was addressed to Ms. Lois Lerner. A portion of BIO of Ms. Hazard reads as follows: "She is responsible for a majority of the programs . . . " that include "the Humane Society Veterinary Medical Association. . . . Hazard's duties include managing . . . program areas with the media, regulatory agencies, before state and local legislative bodies." This is yet another Senior HSUS Official, who has a support staff that engages in Lobbying Activities, and yet the HSUS has never reported any of the fully burdened salaries of Ms. Hazard or her support staff as "Lobbying Expenses" on the HSUS Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 85: Further substantiating the allegation that the HSUS uses the HSVMA to mask and launder some of its lobbying activities may be traced to fact that its Form 990 Tax Return for 2011 showed expenses of $1,157,127, but its revenue only amounted to $536,019. However, that short fall was covered by a contribution of $806,892 from the HSUS so that the HSVMA could continue to lobby in 2012. This fact was documented by the HSVMA Tax Return that was attached as Tab 1 to Mr. Losey's February 5, 2013 Letter to Ms. Lois Lerner. Of note is the fact that the Treasurer of the HSVMA is Mr. G. Thomas Waite, III, who also serves as the CFO for the HSUS. Since Mr. Waite, in essence, serves as the dual-hatted Treasurer of the HSUS and the HSVMA, and since he signed the 2011 Tax Returns for both the HSUS and the HSVMA, he knew or should have known that lobbying related expenditures had not been accurately reported on either of those Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 86: Compounding the above referenced Fraudulent Misrepresentation of the HSVMA on its 2011 Tax Return is the fact that on Page 3 of that Return, Mr. Waite, who signed the Tax Return, certified that the HSVMA did not "engage in lobbying activities" in 2011, notwithstanding the fact that its Membership solicitations and Website postings reference its lobbying activities. Such a "disconnect" may only be explained as another example of the Fraudulent Misrepresentations by the HSUS.

DAMNATION 87: Several years ago the HSUS created yet another subsidiary - - "The Humane Society University" (HSU). And when the curriculum "onion" of the HSU is peeled back, one discovers that the HSU offers an Undergraduate Course and a Graduate Course, both of which focus on "Social Movement Strategies: Policy Change Through Lobbying . . . and Ballot Measures." And so once more an HSUS 501 (c) (3) Subsidiary is being used to mask a portion of the lobbying by the HSUS, the Lobbying Puppeteer for all of the HSUS Subsidiaries. And even though the Past President and the Current President of the HSU are also listed as Senior Officers of the HSUS, none of their fully burdened salaries, or the fully burdened salaries of the Support Faculty and Staff of the HSU, or any of its Overhead Expenses, as they related to the courses that focused on Lobbying and Ballot Initiatives were reported on the Tax Returns of the HSUS, or any other Subsidiary of Affiliate of the HSUS. Yet another "Fraudulent Misrepresentation.

DAMNATION 88: The HSUS Website lists its Federal Legislative Agenda on its Website under the link of "Federal Legislation." The introductory paragraph on that link reads as follows: "View our federal legislation priorities for the 113th Congress. Bills are listed in alphabetical order. Or visit State Legislation in order to find out what we are working on in your state." Once again, an admission of the lobbying it does at the Federal Level; and the fact that no portion of the administrative expenses associated posting information about lobbying on the HSUS Website or for maintaining the functionality of its internet capabilities that facilitate its lobbying activities have ever been reported by the HSUS to the IRS on its Tax Returns represents yet another Fraudulent Misrepresentation.

DAMNATION 89: The "State Legislation" Link on the HSUS Website depicts a map of all 50 States and has the following information and guidance posted on that link: "We work around the country to support animal welfare legislation . . . . HSUS state directors work directly with residents and policy makers in their states. Click on a state below to learn more." Once again, an admission of the lobbying it does at the State Level; and the fact that no portion of the administrative expenses associated with posting information about lobbying on the HSUS Website or for maintaining the functionality of its internet capabilities that facilitate its lobbying activities has ever been reported by the HSUS to the IRS on its Tax Returns represents yet another Fraudulent Misrepresentation.

DAMNATION 90: On the topic of State Legislation, it is most significant to note the despite the fact that the HSUS often deceptively attempts to assert that it is the HSLF that conducts all of the lobbying on behalf of the HSUS, the HSUS "State Lobbying Guide" displayed only the name of "The Humane Society of the United States" on the top of the Cover Page, and did not mention or list the "Humane Society Legislative Fund." Even more noteworthy is the fact that the "State Lobby Guide" no longer is posted on the HSUS or the HSLF Websites. Yet another egregious "COVER-UP" orchestrated by the HSUS to avoid scrutiny of the IRS after Mr. Losey forwarded a copy of the HSUS "State Lobby Guide" to the IRS as Tab 18 to his letter that was dated February 11, 2009.

DAMNATION 91: Mr. Pacelle "founded" the Humane USA Political Action Committee (PAC), which cumulatively submitted over 2,300 pages of documents to the Federal Election Committee. Federal Election Commission Records confirm that Mr. Pacelle made personal contributions to this PAC; that Mr. Pacelle served as a Member of the Board of Directors of this PAC while also serving as President and CEO of the HSUS; and that this PAC contributed Millions of Dollars to the political campaigns of hundreds of candidates. Yet further documentation that the DNA of Mr. Pacelle and the HSUS is inextricably intertwined with participation in the political campaigns of candidates - - an absolute "NO-NO" with respect to prohibited activities for a Tax-Exempt, Public Charity.

DAMNATION 92: Whenever the HSUS does not succeed in its aggressive lobbying efforts to persuade elected Officials at the Federal and State Levels of Government to adopt the HSUS Legislative Agenda, Mr. Pacelle uses the HSUS Website to denigrate those Elected Officials who he blames for standing in the way of the HSUS Legislative Agenda. Illustrative, demagoguering and denigrating quotes of Mr. Pacelle, which impugn the integrity of Elected Officials at the Federal and State Levels include:

"In New Jersey today, Gov. Chris Christie has, for the moment at least, thwarted our efforts to override his veto. . . . We're not done yet in New Jersey."

“We must pursue such campaigns when lawmakers . . . slam the door in our face.”

“Missouri lawmakers are still threatening to gut Prop B - - a blatant subversion of democratic decision-making . . . . “Violating one of the basic principles of good Government"

"Some lawmakers are thumbing their noses at a statewide vote of the people.”

“A handful of Missouri legislators continue to thumb their noses at the people of Missouri in an irresponsible quest to gut Proposition B.”

"The attack in the state on Prop B has been a shameful example of politics at its worst, with a narrow majority of lawmakers and now the governor subverting a vote of the people.”

“Democracy Neutered . . . . There is an attack on democracy occurring now in the Missouri General Assembly."

“Subverting Democracy, Abusing the Process . . . . There’s been some very ugly, unfair, cruel, and anti-democratic work in some state legislatures and in Congress over the past few days."

"The Obama Administration . . . stalled, weakened, or exhibited indifference to some overdue reforms, and it even took some highly adverse actions against animal protection."

"We will endeavor to hold accountable the public officials."

“We will hold accountable the public officials.”

The last "threatening" quote - - “We will hold accountable the public officials” - - clearly violates the absolute prohibition set out in the IRS Implementing Regulations and the IRS Form 990s, which provide that a Public Charity, such as the HSUS may not "engage in direct or indirect political campaign activities on behalf of or in opposition to candidates for public office."

DAMNATION 94: With respect to Mr. Pacelle's political "threat "statement that “We will hold accountable the public officials,” Mr. Pacelle stated on his BLOG that was dated July 31, 2012 that "U.S. Rep. Steve King, R-Iowa, gives very literal meaning to the term "backward thinking." And during the 2012 Calendar Year, according to records filed with the Federal Election Commission, the HSLF, under the leadership of Mr. Pacelle, contributed over $750,000 in its unsuccessful efforts to oppose the re-election of Congressman King.

A Search of the HSUS Website lists 48 HSUS Articles that are critical of Congressman King.

IRS Regulations explicitly prohibit Public Charities from opposing political candidates for election. However, on page 3 of the HSUS 2012 Tax Return, that was signed by Mr. G. Thomas Waite, Treasurer and CFO of the HSUS, Mr. Waite certified that the HSUS did not "engage in direct or indirect political campaign activities . . . in opposition to candidates for public office." THIS CERTIFICATION WAS A FRAUDULENT MISREPRESENTATION THAT THE HSUS MADE ON ITS 2012 TAX RETURNS.

DAMNATION 94: The HSUS lobbies "Covered Executive Branch Officials," on a daily basis, year after year, in an effort to influence Government Policy and Programs. For example, Mr. Pacelle stated on his BLOG that was posted on the HSUS Website on October 10, 2012 that:

"The U.S. Fish and Wildlife Service delisted the Great Lakes wolf populations this year in spite of vigorous opposition from The HSUS and local wolf advocates. In prior years, we blocked de-listing efforts by both the Bush and Obama administrations."

The phrases of "vigorous opposition from The HSUS, and "we blocked de-listing efforts by both the Bush and Obama administrations," clearly substantiate the fact that the HSUS makes numerous contacts with the "Covered Executive Branch Officials" for the express purpose of attempting to persuade them to adopt the position of the HSUS. In a word, those contacts are unadulterated "Lobbying." However, no portion of the fully burdened salaries of the HSUS Paid Management and Staff who make hundreds, if not thousands, of contacts each year with "Covered Executive Branch Officials" has ever been reported as Lobbying Expenses on the HSUS Tax Returns. Yet another Fraudulent Misrepresentation.

DAMNATION 95: The HSUS also makes direct contacts with State Governors in an effort to lobby and persuade them to Veto Bills. For example, by letter dated April 18, 2013, Mr. Pacelle requested that Tennessee Governor Haslam to veto Tennessee Senate Bill 1248 which would have an impact on the Tennessee Walking Horse Industry. And in the last sentence of his letter to Governor Haslam, Mr. Pacelle stated: "We urge you to exercise your veto power." This is but one example of how Mr. Pacelle personally lobbies on behalf of the HSUS, but none of his fully burdened salary and that of his support staff has been listed as "Lobbying Expenses" on any Tax Return filed by the HSUS since Mr. Pacelle became its President and CEO in 2004.

DAMNATION 96: On November 6, 2012 - - Election Day - - Mr. Pacelle made another incriminating statement in his BLOG which was posted on the HSUS Website, and which was entitled "Your Vote Counts." In his BLOG, he summarized the very essence of the commitment of the HSUS to be comprehensively involved in the political process by lobbying and engaging in prohibited political campaign activities by stating:

"One essential component of any successful social movement is to invest in political activity. . . . a readiness to lobby lawmakers . . . and a determination to enact laws in the long stretches between elections."

"The HSUS exists, in part, . . . to drive the ideals of animal protection and to embed them in our legal codes."

The above quotes captures the very essence of the major DNA of the HSUS - - its unfettered commitment of resources to LOBBY and to do whatever it takes to INFLUENCE THE POLITICAL PROCESS TO SUPPORT THE LEGISLATIVE AGENDA OF THE HSUS!

DAMNATION 97: On May 31, 2013 Mr. Pacelle "mocked" and denigrated Missouri Congressman Blaine Luetkemeyer in his BLOG that was posted on the HSUS Website after he learned that the Congressman had requested that the Secretary of the Treasury ensure that the IRS thoroughly investigate the 1,000s of documents that the IRS had received which documented that the HSUS had engaged in excessive lobbying activities and prohibited political campaign activities. Mr. Pacelle further compounded the denigration of Congressman Leutkemeyer by orchestrating the publishing of his "Letter to the Editor" in dozens of Newspapers throughout the U.S., including Newspapers that are distributed in the Congressman's Congressional District. Mr. Pacelle's Letter to the Editor described the actions of Congressman Luetkemeyer in unflattering terms and made unsubstantiated allegations against him. Of glaring significance, these "retaliatory" actions of Mr. Pacelle and the HSUS are consistent with his documented and threatening quote of: “We will hold accountable the public officials.” Despite Mr. Pacelle's personal and publicized attack on the integrity of Congressman Luetkemeyer, the Treasury's Office of the Inspector General for Tax Administration is conducting an on-going investigation to determine if the IRS has properly reviewed the documentation in support of the allegations that the HSUS has engaged in excessive lobbying and prohibited campaign activities; and Congressman Luetkemeyer has been assured that he will be briefed on the results of the on-going investigation when it is completed.

THE "DARK SIDE" OF THE CORPORATE ETHOS OF THE HSUS WHICH FURTHER IMPUGNS THE INTEGRITY OF THE REPRESENTATIONS THAT THE HSUS MAKES ON ITS IRS TAX RETURNS

DAMNATION 98: In response to Mr. Losey's January 7, 2008 written request to Mr. Pacelle to publicly condemn all who explicitly violate the Animal Enterprise Terrorism Act (18 U.S. C. 43), a Federal, Domestic Terrorism Statement, Mr. Pacelle responded by Letter dated January 18, 2008. Conspicuous by its absence was any specific reference in the written response by Mr. Pacelle to the Animal Enterprise Terrorism Act. However, even more troubling was the fact that Mr. Pacelle suggested, by not so subtle innuendo, that the Animal Enterprise Terrorism Act was an "unjust law," and that "civil disobedience" is the appropriate vehicle for citizens to use to "draw attention to unjust laws" - - a classic example of an "Above the Law" mindset, which best characterizes the Corporate Ethos of the HSUS.

DAMNATION 99: Defiantly, the HSUS has encouraged others to harass owners of animals and to participate in vigilante-like "raids" on their homes and properties. And the HSUS has participated in many of these raids, as evidenced by Mr. Pacelle's quote that “We have raided so many of these operations.” Such improper "raids" fall within the definition of "interfering" as set out in the Animal Enterprise Terrorism Act. However, often these owners do not have the financial wherewithal to defend themselves from false allegations, but even when they are successful in defending themselves from false charges, they still do not have the financial wherewithal to engage in lengthy and costly litigation to recover damages. In short, the HSUS has mastered the Art of Bullyism and, to date, has succeeded in avoiding being held accountable for its violations of the Animal Enterprise Terrorism Act.

DAMNATION 100: "Judge a man by the company he keeps." That profound quote rings true with respect to the Corporate Ethos and "Above the Law" tactics that the HSUS has employed for the last 10 years. In this regard, Mr. John Goodwin has served as the HSUS Director for Animal Cruelty Policy for a number of years, and obviously has had "input" in the decisions of the HSUS to "have raided so many of these operations.” In short, the HSUS hired this person to make decisions and recommendations about actions to take by the HSUS that involve alleged animal cruelty. However, what is so chilling, but typical of the HSUS Corporate Ethos and Mindset of the HSUS to act "Above the Law," are the criminal "credentials" of Mr. Goodwin that qualified him to assume the position of HSUS Director, Animal Cruelty Policy. In this regard, during the sentencing hearing in Tennessee for Mr. Goodwin, following his conviction for "over 100 incidents of vandalism . . . between 1991 and 1992 at furriers and meat markets" in Memphis, Tennessee, the arresting officer testified that "upon arrest, Goodwin stated that his arrest would not result in a discontinuation of the Animal Liberation Front's activities." Here it is shockingly noteworthy that the Animal Liberation Front is recognized by the FBI as a Domestic Terrorist Organization. Furthermore, during a Congressional Subcommittee Hearing in 2004, that was chaired by Senator Hatch, which was considering an Amendment to the Animal Enterprise Terrorism Act that was being requested and supported by the FBI, a Senior FBI Official in charge of the Domestic Anti-Terrorism Division testified as follows:

"During the past several years, however, special interest extremism, as characterized by the Animal Liberation Front . . . has emerged as a serious domestic terrorist threat. . . . The FBI . . . will continue to strive to address the difficult and unique challenges posed by animal rights extremists and eco-terrorists."

The employment of Mr. Goodwin to fill a Senior Position within the HSUS, notwithstanding his past affiliation with the Animal Liberation Front, should, at the very least, raise serious questions as to the Corporate Ethos of the HSUS, as well as the credibility of any statement that it makes to Law Enforcement Personnel; to the IRS; to the President of the U.S.; to Members of Congress and their respective Staffs; to State Governors; to State Legislators; to County and City Officials, and to the News Media.

DAMNATION 101: THE RACKETEERING AND CORRUPTION LAWSUIT FILED AGAINST THE HSUS In 2010, the Feld Entertainment Corporation (Parent Company of the Ringling Brothers Circus) filed a Lawsuit (Case 1:07-cv-01532-EGS - - D.C. District Court) against 13 Animal Rights Organizations and Individuals. Two of the named Defendants are the HSUS and Mr. Jonathan Lovvorn, the Vice President and Chief of the HSUS Litigation Division. The allegations that were originally filed by the Feld Corporation read like a Bill of Indictment against the Mafia. The Original Allegations included;

"Racketeer Influenced and Corrupt Organization Act" (RICO).

"Conducting the Affairs of the Enterprise Through a Pattern of Racketeering Activity."

"Bribery."

"Illegal Witness Payments."

"Obstruction of Justice."

"Mail Fraud."

"Wire Fraud."

"Money Laundering."

"Conspiracy to Harm a Business."

"Abuse of Process."

"Malicious Prosecution."

The Feld Entertainment Corporation filed its Lawsuit after a Federal Judge had dismissed the Lawsuit that was originally filed against the Feld Entertainment Corporation after nearly 10 years of litigation involving the Original Lawsuit that had been filed against Feld. The major reason why the Lawsuit that had been filed against the Feld Entertainment Corporation was dismissed was based on a judicial determination by the Federal Judge that the key witness, Tom Rider, who had testified that the Ringling Brothers Circus was abusing elephants, was not a credible witness - - REPEAT, NOT A "CREDIBLE WITNESS" - - because, among other things, he was being paid to testify. And one of the damning documents that the judge considered in making his determination that Tom Rider was not a credible witness was a check that had been signed by Mr. Pacelle, which was made payable to the Account that was being used to pay Tom Rider! (A copy of that check may be found by going to www.franklosey.com and clicking on the link entitled: HYPERLINK "http://www.memoryofchaucer.com/feld.htm" Feld/HSUS Rico Lawsuit Info) In short, Mr. Pacelle and the HSUS were involved in "Money Laundering" in much the same way that they have "laundered" so much of their lobbying and political campaign activities with respect to the Fraudulent Misrepresentations that they have made on the IRS Tax Returns that are filed on behalf of the HSUS each year.

Since the Feld Lawsuit is based in large measure on a violation of the RICO Act, the HSUS and Mr. Lovvorn could be liable to pay the Feld Corporation at least $60 Million from the tax- exempt donations that unsuspecting donors have made to the HSUS. And to anyone who might suggest that the Feld Lawsuit is without merit, reflect on why the American Society for the Prevention of Cruelty to Animals (ASPCA) - - one of the original Defendants in the Feld Lawsuit - - "paid Feld Entertainment $9.3 million to settle all claims related to its part in more than a decade of manufactured litigation that attempted to outlaw elephants in the company’s Ringling Bros."

POSTSCRIPT: YOU BE THE JUDGE AS TO WHETHER THE HSUS HAS TOLD THE "TRUTH, THE WHOLE TRUTH, AND NOTHING BUT THE TRUTH" WITH RESPECT TO WHETHER IT HAS FRAUDULENTLY MISREPRESENTED THE MAGNITUDE AND PERVASIVENESS OF IT LOBBYING AND POLITICAL CAMPAIGN ACTIVIITES.