Affidavit of Dr. Lester Castro Friedlander DVM

I Dr. Lester Castro Friedlander, DVM., of Bradford County Pennsylvania do swear under penalty of perjury that the following statements are true to the best of my knowledge:

I am the president of Citizens Against Equine Slaughter (CAES) a national 501c3 non-profit based in Oregon.

The purpose of CAES is as follows:

  • Stop the practice of equine slaughter and protect equines from cruel and harmful practices; 
  • Monitor the government’s land use and resource management activities, as well as the impacts of agency decisions on equines;
  • Inform and educate the public about the decisions and activities of government agencies affecting equines; Work with the government, the public, and all interested parties to promote sound policies and laws that protect equines.

This is prominently displayed at our website at

I was a veterinarian for the New York State Racing and Wagering Board in the racehorse industry for 2.5 years as well as for the USDA for 10.5 years after that. And as such I am concerned about the Bureau of Land Management (BLM) diagnosis and euthanasia of horses as having pre-existing conditions that are both questionable and unlikely, as well as inadequately diagnosed in the absence of standard diagnostic tools.

BLM reports and documentation of injury and death after and during helicopter roundups shows extreme animal cruelty as well as is inconsistent. BLM does separate web pages for each gather. Each of these pages have links to click for the Daily Gather Reports. The daily gather reports include information on how many animals are gathered, shipped, injured, and.or dead. Some webpages have a second link or tab for veterinary reports significant to that gather, while yet other pages have no tab for veterinary reports. Even pages that report deaths often have a tab for these veterinary reports, but when you click on them no reports are available. 

Another recent helicopter round up was done at Warm Springs Oregon with multiple deaths also lacking information. Concurrently, CAES submitted a FOIA request for the veterinary reports on these recent deaths. Because the FOIA process takes a good length of time we do not have those reports back so I can only give my professional opinion of extreme animal cruelty based on the information provided by BLM this far.

BLM Helicopter Roundups:  Extreme Animal Cruelty and Transparency Issues.

Consistency and Transparency

Example 1. & 2. Shows a tab to click for the Daily Gather Reports, as well as a Tab for Veterinary Reports. Even though there are deaths reported there are no veterinary reports provided.

Example 1

Example 2

Example 3 Shows the same District Office, but a different HMA wild horse gather, with a tab for Daily Gather Reports, but no tab for Veterinary Reports, even though at the time of this affidavit that ongoing gather is at a 3.8% death rate.

Example 4 Shows, from a different district office, a tab to click for the Daily Gather Reports, Facility Reports (which outline the condition of the horse upon and immediately after arrival of the horses from the gather to the holding facility), and it shows the tab for Veterinary Reports, and in this example there are 4 of them with necropsy reports.

In these 4 examples I believe it is important to note that one district office does not provide veterinary reports at all, while another provides all reports, including facility reports. So our concerns about the transparency surrounding the deaths is further supported by this inconsistent reporting.

Extreme Animal Cruelty

There are a very large proportion of what BLM calls “pre-existing conditions” mentioned in these gather reports as determined AFTER the round ups. I question many of these determinations based on the lack of medical testing to determine the injury, or the age of the injury. Without those tests BLM cannot make a determination that an injury, such as bone fracture was pre-existing, unless that horse was documented as lame before the helicopter gather began, in which case stampeding it with a helicopter over long distances and varied terrains for extended periods would be extreme, painful, animal torture and cruelty and which would only make a condition worse.

In a video “North America’s Wild Horses” BLM contractors, who perform this and many gathers, Cattoor Livestock Roundup Company used a helicopter pilot named Jim Hicks who talks about some of the difficulties he encountered during a gather such as maneuvering to get horses to come out of the trees, and the statement that concerns me most because it is still an issue 12 years after this documentary came out, is the helicopter getting very close to the horses and as this documentary said “Jim has had to get close to the ground, pushing the stallions with the helicopter skids…” The narrator explains that Hicks feels stallions are the most difficult to drive into the traps and said “They are not as easily frightened by the helicopter (as mares or foals). 

Pushing the animals with the skids, if taken literally is not allowed per law, and in this Muddy Creek gather the pilot flew so low that the pilot is seen less than 100 feet from a human, a clear FAA violation 

Other conditions listed as pre-existing or chronic are simply medically impossible, some of those conditions include vaginal/rectal prolapse, colic and cervical injury resulting in loss of hind limb control. These are emergency situations where a horse would not survive for days, let alone months to be labelled a pre-existing condition. One must ask what BLM deems the length of time a horse must have had an illness or condition for it to be considered chronic/pre-existing. And if they can prove they were pre-existing again why were they inhumanely stampeded long distance over 5 – 10 minutes, with a helicopter?

I go into some of these in greater detail below. In my professional opinion, BLM is causing many of these injuries during the stampede, trapping, and transporting and again, if not, they should not be included in a stampede round up by helicopter over differing terrain and long distances. In the 2002 documentary BLM Wild Horse & Burro Specialist Bob Brown acknowledged that the gather put stallions together that have long been competing with each other. He stated: “Some of these stallions, they absolutely hate each other and uhm, I’ve seen them where they fight coming into the wings at the end of the trap, fighting going onto the trailer. They fight in the trailer and when we turn them into the stallion pen and they fight there until they ship. They fight on the truck when we ship them to Palomino Valley.” Dr. Lennart Curt Østblom, DVM comments he’s seen that behavior too and says they are mean. Bob Brown then says “They are. They can kill a mare, they can kill a foal really easily.” 

This supports my claims that BLM is knowingly breaking the animal cruelty laws both state and federally. Animal fighting and promoting it are so serious that the FBI tracks these types of individuals. 

Pre-existing Conditions Listed on BLM Daily Gather Reports Resulting in Euthanasia of Wild Equines That Are Medically and Scientifically Questionable

  1. BILATERAL RUPTURED SES(A)MOIDS Listed on the Warm Springs Wild Horse Gather, Daily Report dated 10/16/201

The first incidence is one I have only seen BLM use one time and that is “bilateral ruptured ses(a)moids”.

Sesamoid ruptures/fractures are an injury common in the race industry. The distal sesamoidean ligaments, suspensory ligament and sesamoid bones make up the suspensory apparatus and hold the fetlock in correct position. Injury of any of these leads to a failure of support of the fetlock joint (one of the common catastrophic injuries in the racehorse).

It is an injury caused by exposing the animal to high speeds that are unnatural to the ligamentory and skeletal load an equine is able to handle without such damage to the suspensory system.

The New York Sun explained that because “thoroughbreds are bred for flashy speed and to look good in the sales ring … the animal itself has become more fragile”  This statement is in stark contrast to the well known hardiness and physical strength and stamina of a wild mustangs.

According to a study done on 269 deceased Thoroughbred racehorses (Ref. 1) results showed that sesamoid bone fractures occur more often in horses that were sexually intact males, spent more time in active training and racing, completed more events, train and race longer and have higher exercise intensities.

From BLM  Warm Springs Daily Gather Report (below) you can see that this was a mare, which in a wild horse also makes it less likely for natural activity of the magnitude typical for these fractures to have occurred, unless they occurred during the stampede by helicopter.

10/16/18:  A 7 year old sorrel mare (BCS 3) captured 10/15/18 was humanely euthanized in accordance with IM 2015-070 due to pre-existing bilateral ruptured sesamoids in her hind legs, which caused severe lameness.” -BLM Warm Springs Wild Horse Gather, Daily Reports

The other note on this statement of BLM is that this was a mare with a Henneke Body Condition Score (BCS) of 3 which is below average, meaning the horse was below average weight. On the occasion that a horse that is not a racehorse suffers ligament or bone issues of the sesamoid structures it is likely to be a horse that is overweight, thus putting additional weight on the suspensory system and exacerbating the injury itself. If the horse was thin due to the injury itself and BLM claims they could visually diagnosis sesamoid rupture of the ligament then the horse would have showed lameness and it was intentional cruelty and extreme animal abuse to stampede her with a helicopter.

These injuries can be tricky to spot. Even with severe injury, the signs can be confusing. Bruising, infections and injuries to tendons can produce similar heat and swelling. A veterinarian cannot diagnosis this with a visual observation. It involves a hands-on exam, flexion tests and local nerve blocks. An ultrasound or MRI scan can help pin down the location and reveal the extent of damage to the ligament, and X-rays will show if bone is involved.

The sesamoid bones are maintained in position by the branches of the suspensory ligament proximally and by a number of sesamoidean ligaments distally. Because of the great stress placed on the fetlock during fast exercise, the abaxial portion of the proximal sesamoid bones is susceptible to stress-related injury. Sesamoiditis is a clinically distinctive condition; however, it is poorly characterized pathologically.

The clinical signs are similar to, but less severe than, those resulting from sesamoid fracture. Depending on the extent of the damage, there are varying degrees of lameness and swelling. Pain and heat are evident on palpation and flexion of the fetlock joint. Radiographic evidence of sesamoiditis involves periarticular osteophytes, entheseophytes, focal osteolysis, and enlarged vascular channels (or linear defects in the abaxial margin of the proximal sesamoid bones). Grading scales for sesamoiditis exist and particularly note the vascular channels on radiographs. Severity of sesamoiditis on radiographs has been linked to a decrease in racing performance in one study. In another study, when radiographic signs of significant sesamoiditis were present, horses had a 5 times greater risk of developing clinical signs of suspensory ligament branch injury with onset of training.

Sesamoid fractures occur (Fig 9) in the area of attachment of the suspensory ligament. Horses will present with lameness and synovial effusion. There is commonly thickening over the branch of the suspensory that attaches to the sesamoid fracture. The diagnosis is confirmed by radiography.

During early training of racehorses skeletal changes are seen. Previous studies (Reference 2) found a decrease in the mineral content of the third metacarpal bone during the first months after a young horse enters race training. As the intensity of training increased, in activity and speed required of the animals studied there were marked increases in bone mineral content as well as increased calcium, phosphorus and osteocalcin levels in the blood. “To explore the skeletal adaptations involved in early race training, bone density and morphometry were tracked in 15 Thoroughbred yearlings as they began training at a facility… During training, dorsopalmar radiographs of the third metacarpal bone were taken on a monthly basis and an aluminum step wedge was exposed simultaneously as a reference standard.  Plasma concentrations of calcium, phosphorus, and osteocalcin were also measured monthly.”

These injuries would be highly unlikely to occur in wild horses unless the horse has been repeatedly stampeded at high speeds, and as shown above the diagnosis cannot be made by simply observing the horse. The diagnosis must be made with a minimum of radiographs. Other methods of diagnosis are more accurate because a sesamoid fracture is often difficult to see on a radiograph..Standing MRI scans can be used to detect a sesamoid fracture soon after it occurs.

Fractures of the proximal sesamoid bones involve the apex, body or basilar portions of the bone. A radiograph in addition to showing the location of the fracture (which determines the treatment to be employed), provides additional information of value to the clinician. The extent of fragmentation and separation is an indication of the severity of soft tissue injury which may have a significant influence on prognosis. In addition to the presence or absence of new bone the appearance of the margins of the fracture is of value in estimating the interval which has elapsed since the fracture occurred. Which would determine whether the injury was in fact pre-existing or a fracturing caused by the recently completed helicopter stampede.

Radiographs taken soon after the trauma illustrate sharp edges of the fracture line with bone of uniform density on either side. In contrast a fracture 14 days old appears wider and its margins less easily identified (Figs 2a and b).

It has not been the standard procedure of BLM to have radiographs done, and never to my knowledge a standing MRI, on a horse exhibiting any level of lameness, therefore, I question the statement made on the BLM daily gather (death) report of a bilateral rupture of the sesamoids. And it is my opinion that absent the minimal diagnostic radiographs there is no possible authenticity to a claim that determines this as a pre-existing injury, if in fact there is a bilateral ruptured sesamoid injury. Therefore again, if this was pre-existing, this horse should not have been in a helicopter round up. 


From one gather alone, the Warm Springs Herd Management Area (HMA) in Oregon, on one day alone (Friday, October 5, 2018) the BLM listed 11 horses as euthanized due to ALD. (Per Daily Gather Report)

The following animals were humanely euthanized  in accordance with IM 2015-070 due to angular limb deformities (ALD) in one or multiple limbs and feet.  Because these angular limb deformities appear to have a genetic component and because the severity of these deformities were causing severe lameness, these animals were not suited to return to the range or placement in off-range holding or adoption. These conditions were indicated by club feet, severely overgrown hoof walls, collapsed heals, limb deformity, arthritic joints, toes pointed out at the fetlock, and lameness:

A 3 year old pinto mare (BCS 3): Bi-lateral ALD
A 3 year old appaloosa mare (BCS 3):  Severe club foot, left front
A 5 year old appaloosa stud (BCS 5):  Bi-lateral ALD
A 7 year old bay stud (BCS 4):  Bi-lateral ALD
A 2 year old bay stud (BCS 3):  Bi-lateral ALD
A 5 year old appaloosa stud (BCS 5):  Bi-lateral ALD
A 3 year old sorrel mare (BCS 3): Left front ALD and severe knee arthritis
A 7 year old bay mare (BCS 5):  Severe club foot, right front
A 2 year old palomino mare (BCS 3): Bi-lateral ALD
A 3 year old dun stud (BCS 3.5):  Left front ALD
An 11 year old pinto stud (BCS 4):  Bi-lateral ALD

BLM states ALD is indicative of “genetics” There needs to be a complete genetic analysis done, and every horse chosen for removal should be chosen because of the genetics they would not want to continue in the herd. If this level of congenital anomaly is being seen then one must question the overall genetic health of the herd. Are they inbreeding, is this why there is this extremely high incidence of what BLM considers a “genetic component”? 

ALD is common in foals for domestic horses, however there are no studies on the survivability or pain levels of an adult with ALD because it is corrected when the foal is young and abled to be molded. I question the statement that a horse with clubfoot, overgrown hoof walls, and many other foot issues,is not a good candidate for an adoption program (per BLM above statement). These are all conditions that can be, and regularly are, treated in domestic horses often with the aid of a good farrier.

Performance Equine Veterinary Services stated the importance an exam for a proper diagnosis. “There are genetic reasons for the development of this condition of the digit joints (clubfeet) (photo below). Other factors involved are diet and exercise. Clubfoot also can be associated to pain in other region of the limb therefore is very important a complete lameness exam in order to discard a lesion elsewhere in the limb. Clinical signs of a clubfoot are a prominent bulge at the coronary band, increase in length of the heel relative to the toe, and failure of the heel to touch the ground after trimming. As the hoof growths it develops a boxy shape and a dish shape at the level of the toe.”

Equine club foot is defined as a hoof angle greater than 60 degrees. What we see externally as the equine clubbed foot is actually caused by a flexural deformity of the distal interphalangeal joint (coffin joint). Causes include nutritional issues, heredity, position in the uterus or injury. The condition is most often encountered in young animals and can be either congenital (they are born with it) or acquired. Often one front foot is worse than the other. Cases can be very mild or quite severe. A foal with coffin joint flexural deformity that is left untreated or treated unsuccessfully often suffers from lameness, chronic hoof abscesses, and laminitis. In the very young foal medical treatment may include oxytetracycline to relax the tendons on the back of the leg, splinting, and corrective trimming with toe extensions. When these medical therapies do not work or in severe cases surgical therapy involves cutting the accessory ligament (inferior check ligament) of the deep digital flexor tendon to allow manual manipulation of the joint and hoof capsule as well as allow the soft tissue structures to lengthen and assume a more normal orientation. Horses with more mild cases may be managed throughout their life with attentive trimming and shoeing.” – Weitz Equine Veterinary Services

Weitz Equine Veterinary Services © 2018

BLM has not done the proper tests to determine the cause of these ALD type issues to know if they are genetic or congenital. They are merely guessing. A guess is not good enough when they are the agency tasked with the health of the not only the individual horse, but also the herd as a whole, self-sustaining and thriving unit. If there are genetic problems at this level of occurrence then BLM needs to be addressing that issue, and not planning to go willy nilly into removing them to satisfy AMLs that have been proven to be arbitrary. (national Academy of Sciences, A Way Forward)

These 11 deaths and 2 additional listed as ALD, 2 additional listed as clubfoot (not ALD), 1 bilateral stifle injury (knee), and 3 additional limb fractures (from one gather) prove not only that the herd health is insignificant to BLM, but it also proves that there is NO mechanism in place to observe the herd for these lameness issues before the gather happens and as such these horses that are so lame that BLM claims the need to euthanize them, are brutally and cruelly chased at stampede speeds with a helicopter. Then after that torture they are simply shot. This is not management, it is government sanctioned, illegal and sadistic torture of animals.


Is there any clinical examination of spinal cord function to make this determination? I do not believe it would be possible with wild horses as most of the tests (listed below) routinely done to diagnose spinal injury are done with hands on testing

  • General Examination of the Neck, Trunk, and Limbs
  • Slap Test
  • Cervicofacial Reflex
  • Cutaneous Trunci Reflex (“Panniculus”)
  • Back Reflexes
  • Tests for Limb Strength – hopping test, tail-pull test, 

Wild and excited, anxious horses cannot be accurately examined, and even weak horses may test as normal if not relaxed, this is a problem for domestic horse diagnostics which would make it even more difficult to accurately perform testing of wild animals.

Additional to these initial hands on tests there of course are radiographs and myelography that would show these injuries, but as I mentioned above those are not tests used to determine issues of lameness, injury etc of wild horses. Absent these tests BLM is again guessing at the diagnosis, and therefore could be euthanizing a horse that could be treated with steroids or anti-inflammatory medications that would correct the what is an appearance of paralysis or lack of control caused by a cervical injury..

Again I must reiterate my feelings of how utterly irresponsible, illegal and inhumane it is to have chased one such horse with “loss of control of rear legs” with a helicopter. This loss of control of the limbs again would be something that is easily observed. The horse should have been noted before gather operations began, and should not have been cruelly chased down with a helicopter. If pre-gather observation does not happen then this is normal behavior of the BLM, and it is willful, and knowingly committing extreme animal abuse and cruelty. Obviously the BLM has the capability for observation of horses pre-gather because the same gather on the same day, BLM posts daily:

10/4/18: A 5 year roan stud (BCS 4) was humanely euthanized in accordance with IM 2015-070 due to a pre-existing cervical spinal injury that had resulted in severe lameness and lack of control of rear legs.

10/4/18: A 4 year old black stud was humanely euthanized in accordance with IM 2015-070 in the field due to a pre-existing cervical spinal injury that had resulted in severe lameness and lack of control of all legs.  This stud had been observed the previous 2 days showing complete loss of body control.

One horse, the first listed was apparently gathered after being chased with loss of control of rear limbs, while the other was euthanized in the field. However, BLM doesn’t necessarily say that the field doesn’t mean at the trap site, but because “at the trap site” is terminology they use elsewhere in these gather/death reports I feel it is fair to infer that this second horse was euthanized before being gathered into the trap site.


Vaginal or rectal prolapse is a dire emergency situation. It can not be called a pre-existing condition. 

Uterine or rectal prolapse is not common in equines, however if happens within days, if not immediately after foaling. This diagnosis is a huge red flag that either this mare delivered her foal, or aborted it while being chased by helicopter. Recent gather’s have been video recorded of a mare being chased as she was delivering a fetus, it is unknown if she aborted or delivered a full term fetus, or if that fetus was ever located. Was this foal located? If, as BLM claims it was a tear from foaling then where is the foal that cannot be more than days old, if not just hours old when this report was made. Again…helicopter gathered are not safe and result in incidents like this where a mare that either aborted, or needed immediate medical attention if she was to care for her foal was simply ignored. A rectal or uterine (vaginal) prolapse is visible, it is an organ hanging out of the mare, and no helicopter pilot should EVER be chasing an animal such as this.

This is the post from BLM Warm Springs Daily Gather Reports on this mare:

10/4/18: A 16 year old palomino mare (BCS 2.5) was humanely euthanized in accordance with IM 2015-070 due to a pre-existing vaginal/rectal tear from foaling, resulting in a chronic partial rectal prolapse with a poor prognosis for recovery.

     V.     SWAYBACK

Again looking at the Warm Springs gather BLM posted this on the Daily Gather/Death Reports:

“10/8/18: A 3 year old blue roan mare (BCS 4) was humanely euthanized in accordance with IM 2015-070 due to a severe sway back condition.”

Swayback or lordosis is weakening of a horse’s supporting ligaments along the spine. Causes of lordosis include genetics, pregnancy, age, conformation, excessive strain on the back and lack of exercise.

In this case where the horse is very young, and is not domestic, therefore not subject to excessive strain of being ridden, or not subject to a lack of exercise, the cause would likely be genetic. 

According to E. Bailey, of the Department of Veterinary Science, MH Gluck Equine
Research Center, University of Kentucky “congenital lordosis has been reported to be associated with incomplete development of the upper thoracic vertebrae in the area of T5-T10. This causes overextension of the vertebral joints in the area and leads to this conformational problem.”

Radiographs of the area could confirm the diagnosis and would help determine that this was in fact a genetic issue. Again what is going on with the genetic health of this herd is a big question with all of the listed conditions that are more commonly congenital than not.

I do not disagree that this condition is pre-existing, but I do disagree with the necessity of euthanasia due to the condition. While horses with lordosis are more prone to back pain, many domestic horses are able to be ridden, and some even compete. I have seen some horses being ridden into their 20s with significant lordosis and without pain.

     VI.     COLIC

Colic is not a pre-existing medical condition it is an urgent, immediate, call the veterinarian condition, according to the Dick Vet Equine Practice Fact Sheet: Colic, the instructions listed if you believe your horse has colic are “Call your vet immediately – colic is a true veterinary emergency and time is of the essence.” And having been around horses for all these years I could not agree more with that statement. 

Given the extreme urgency associated with colic in a horse, it stands to reason that the colic is a clinical sign of another issue that needed to be investigated. But it could not have been pre-existing because the horse would have been dead before it got to the holding facilities to be euthanized.

“Colic in horses is defined as abdominal pain, but it is a clinical sign rather than a diagnosis. … The most common forms of colic are gastrointestinal in nature and are most often related to colonic disturbance. There are a variety of different causes of colic, some of which can prove fatal without surgical intervention.” – Horse colic – Wikipedia

The biggest cause of colic is is a sudden abundance of fresh grasses, or inappropriate types of hay, things a wild horse may not be accustomed to that cause a sudden change for the digestive system. I believe if colic was present it was due to human error at the holding facilities or in the trap site.


The Warm Springs gather reports only list one horse euthanized for being blind, which is low compared to other gathers. The horse listed in this instance was a 14 year old. The horse is also listed with a BCS of 3 which is within an acceptable range for a wild horse, who is 14 and has a disability. However, he was surviving and managing out there, and there is no need to kill him just for being blind. This happens very commonly. I do not believe that BLM should be selecting what horses survive as part of a management plan. Blindness is not painful, it is not contagious, and old horses who are blind but healthy possess much knowledge the herd depends on.

Selecting horses that are allowed to live out their lives on the range based on their ability or possible desirability (which is the case with the Kiger mustangs in 2 Herd Management Areas in Oregon) to collector/breeders is not management of wildlife. It is interfering with wildlife in an unnatural way.

Other Pre existing Conditions that are questionable but that I am not going to go into in such depth as I have above are 3 horses listed as having a pre-existing condition of a broken back, (different from those previously discussed as they are not listed as cervical which was discussed above), water deprivation or toxicity, emaciation, heavy parasite load, lip tumor, pneumonia, and several that do not even list the pre-existing condition.

The statistics on euthanasia of gathered horses in gather reports I analysed from 2015 to present show that most horses euthanized are a result of previous injuries which may have subsequently resulted in ALD and lameness, or ALD that is believed to be congenital resulting in lameness. Without proper use of diagnostic tools there is no way for BLM to determine if these were in fact pre-existing in many cases.

Inspection of the daily gather reports from BLM’s wild horse gather pages daily reports (See Reference 52) which were still online, from 2015 to 2018 we found the following results:

Condition Number Euthanized
ALD, Lameness or Old injury                                                             92

    (included clubfoot)                                                                        (29)

Unlisted Pre-existing Condition                                                         28
Blindness                                                                                           25

Age Related (Tooth, Arthritis, Low BCS etc.)                                    19

Body Condition Score (BCS)

Non Age Related low BCS                                                                13

Illnesses (Colic, Pneumonia, lip tumor)                                              7

Water Deprivation or Toxicity                                                              3

The Horses that BLM admitted were euthanized due to the gather from injuries (mostly broken necks) were 37. And 3 foals that were orphaned.

A horse so frantic that it runs into panels and breaks its neck is a terrified horse. This is unacceptable and it cannot be categorized as management, but rather planned, intentional murder.

Helicopter gathers have proven to have much higher death rates than BLM has stated to the public, many times in many places, for example Rob Sharpe, the Wild Horse and Burro Specialist for Burns District Office BLM in Oregon, stated that the death rate from helicopter gathers was less than 1%. As of October 26, 2018 (the gather has not yet been listed as completed) the gather of the Warm Springs herd, of which he is overseeing has a death toll of 3.8% or nearly 4 times what he told the public.


In summary helicopter roundups are extreme animal cruelty, running wild horses in a stampede with previous injuries and also causing serious injuries during and after this unnatural ordeal. 

These issues are specifically hidden by the BLM (Red Rock Utah Gathers) in an arbitrary and capricious manner.  The BLM is only as transparent as they choose on a case by case basis.  

Moreover, Helicopter round-ups are fraudulent. The BLM is hiding the facts that:

1. Wild horses do not need to be rounded up first, 

2. Wild horses do not need to be transported to holding for darting

3. Wild horses do not need to be branded for darting

4. Wild horses do not need to be transported back for release. 

This is because with PZP (Zona stat H) as registered by the EPA as a non-experimental vaccine, no further data is required per the registration. 


  1. Wild horses can be darted without being branded, on the range, with no holding, no handling by helicopter (over 100 meters high), by lure trap, or on foot.
  2. Hence, the BLM falsely inflates the cost of PZP darting by including the cost of round ups, transport, feeding, holding, branding, foot trimming etc However they are not transparent and instead they SAY that it is not practical because the contraceptive has to be darted yearly or every two years. Evenso, this is feasible y comparison. (See Attachment I)

 BLM is choosing to hide that these horses could be feasibly darted on the range by helicopter, or by lure trap. This is again on a case by case basis in an arbitrary and capricious manner. Here at Muddy Creek, there is no valid cost analysis.  showing that simple on range darting by helicopter in this wide open HMA could keep the population below the higher AML while BLM’s extreme bias against these sentient beings that is at issue as shown  unnecessary they are unnecessary, they are fraudulent based on fraudulent cost analysis versus using PZP without round ups, handling, and holding, and can be darted on the range and since 2012 when the EPA registered Zona Stat H (PZP) for use on wild horses as a contraceptive versus 


  1. Risk factors for proximal sesamoid bone fractures associated with exercise history and horseshoe characteristics in Thoroughbred racehorses; Lucy A. Anthenill, DVM; Susan M. Stover, DVM, PhD; Ian A. Gardner, BVSc, PhD; Ashley E. Hill, DVM, PhD
  2. Skeletal Adaptations With The Onset Of Training Thoroughbreds
    January 1, 2007; Pagan, J. D., L. A. Lawrence and D. Nash. 2007. Skeletal adaptations with the onset of training Thoroughbreds. In: Proc. 20th Equine Science Society. Hunt Valley, Md. June 5 – 8. pp. 148 – 149.
  3. Traumatic Joint Disease; C. Wayne McIlwraith BVSc, PhD, FRCVS, Diplomate ACVS
    Professor and Director, Orthopaedic Research Center, Colorado State University
  4. Axial osteitis of the proximal sesamoid bones and desmitis of the intersesamoidean ligament in the hindlimb of Friesian horses: review of 12 cases (2002-2012) and post-mortem analysis of the bone-ligament interface. Brommer H, Voermans M, Veraa S, et al.; BMC Vet Res. 2014;10:272. Published 2014 Nov 19. doi:10.1186/s12917-014-0272-x
  5. Interpreting radiographs 2 : The fetlock joint and pastern; G. B. Edwards; Department of Surgery and Obstetrics, Royal Veterinary College, Hawkshead House, Hawkshead Lane, North Mymms, Hatfield, Hertfordshire; Equine Veterinary Journal; Equine vet. J. (1984) 16 (l), 4-10
  6. Equine Sports Medicine and Surgery (Second Edition) 2014, Pages 275-296; Distal limb: Fetlock and pastern; Alicia L.Bertone
  7. An Unknown Filly Dies, and the Crowd Just Shrugs; William C. Rhoden, The New York Times 25 May 2006.
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