December 1, 2010 Rep. Colin Simpson, Speaker P.O. Box 490 Cody, WY 82414 Fax (307) 527-7897 csimpson@iskelaw.com Rep. Edward A. Buchanan, Majority Floor Leader P.O, Box 850 Torrington, WY 82240 chuchana yor Rep. W, Patrick Gogeles, Minority Floor Leader 505 Blue Sky Hwy Ethete, WY $2520 Fax (307) 332-0230 peoggles@wvoming.com Bruce A. Salzburg ‘Atomey General's Office 123 Capitol Building 200 W. 24th Street (Cheyenne, WY 82002 ‘Subject: Official complaint and request for investigation {Lam a legal resident of Wyoming. Iam writing to ask that you initiate a formal investigation of apparent violations of Wyoming conflict of interest and disclosure laws on the part of Wyoming State Rep. Sue Wallis (R-Campbell) as well as possible violations of laws relating o feud, securities fraud, and gambling. Please consider this a complaint about Rep. Wallis’ eonduet and ‘request for a complete investigation thereof. Rep. Wallis is on a crusade to retum horse slaughter for human consumption tothe U.S. I believe she is improperly, and even fraudulently, using her positon as a Wyoming Representative to ‘promote and misrepresent the issue to her financial benefit. Not only has Rep. Wallis neglectedto recuse herself on votes on bills in which she has had a personal financfal intrest, but she has sctually sponsored them. In Devember 2008, Rep. Sue Wallis was the co-sponsor of resolution submitted to the National Conference of State Legislatures (NCSL), Agriculture and Energy Committee. Rep. Wallis was the vice chair of the committee. The NCSL is a non-governmental lobbyist organization which serves the nation’s 50 states legislator to advocate and lobby for the interest of states before ‘Congress and federal agencies. NCSL adopted the resolution which basically called for legislative and lobbying efforts to enable and promote the commercial slaughter of horses for ‘human consumption inthe U.S., a practice that has not been legal since 2007. ‘The passage of the resolution provided the authority for NCSL staff in Washington D.C. to lobby on Capitol Hil and establish the position of the States. In 2009 Rep. Walls then sponsored and voted for Wyoming HJR 8, ttp:/legissveb state. us/2009/EnrolV/HJ0008.pdi,a resolution calling forthe defeat of federal legislation, HR 503/SB 727, the Conyers-Burton Prevention of Equine Cruelty Act. The federal legislation would make it illegal to possess, sell, purchase or transport horses in interstate or foreign commerce for slaughter for human consumption. At the same time, over the past two years, Rep. Wallis and her associates have ereated a bewildering array of organizations, web pages and press releases concerning her efforts to reinstate horse slaughter. Her web sites frequently change their claims and/or simply disappear. ‘These sites have contained false and misleading statements, promoted non-existent securities, and even included a high stakes private lottery Rep. Wallis isthe paid, self-styled Executive Director of the United Organizations ofthe Horse (OED, whieh, at one point, claimed to unite The United Horsemen's Front, The United Horsemen's Alliance, and The United Horsemen's Political & Legal ction Fund. Rep. Wallis thas gone as far as promoting The United Horsemen’s Front on her legislative web ste Currently, the UOH claims to be a “nation-wide network of individuals and organizations who tare concerned about the well-being of horses, horse people, and the horse industry.” The UOH is sid to include the following: ‘United Orgunizations ofthe Horse —a mutual benefit nonprofit organized primarily to work in the political arena is registered in Wyoming.” Currently, the organization's tax status is delinquent. tps .0v/Business/FilingDetails. aspx FilingNum=2009-000577123, “United Horsemen”, formerly called “United Horsemen's Front” ~ a 501(c)(3) nonprofit ‘educational and charitable organization. Rescue, Rejuvenation, and Pasture components of the Unified Equine System reside under the non-profit from an operational standpoint. hips:/wvobiz.wy.20v/BusinessFilingDetalsspx?FilingNum=2010-000590239 Despite this selF-desctiption, UH does not appear to have done any ofthese things to date. Its director, Dave Duquette, is a Quarter Horse breeder and trainer and has provided no evidence of doing anyt for excess horses apart from creating them,“Unified Equine LLC — a Wyoming limited liability company under which all humane horse procesing and related business are operse.” hin amiednesoftshoss.org.hnS- Taafel-L webstcteslink.com?page 10-81 United Equine LLC was nt repistered with Ge ‘Wyoming Secretary of State's Office until October 2, 2010, months after Rep. Wallis represented it s a legal entity that she used, as you will see below, to solicit investments ‘The UOH lobbies directly for pro-horse slaughter interests, which means Rep. Wallis serves as a ‘Wyoming legislator at the same time she acts as a paid lobbyist. Atached as Exhibits 1 and 2 are ‘an e-mail and newsletter excerpt which Rep. Wallis and the United Horsemen's Front (UHF) \hich is now called United Horsemen, culated a if they are one, stating Sue Wallis is a ‘Wyoming state representative and calling for the defeat of the Conyers-Burton Prevention of Equine Cruelty Act ‘Aso san example ofa bstant conic of interest and abuse of her position as sate legislator, attached is Exhibit 3a nevaletr fom the former United Horsemen's Front tat sol for Rep. Wallis personally and ro-horc slaughter interest, boasting that Rep. Well member ofthe Wyoming Legislature isis “greatest resource” At his now defunct link, Rep ‘Wallis solicited and collected money tobe paid to her personally, claiming to promote horse ‘slaughter interests. htip://svww.wyoagcoalition.org/index_files/Page2084.him As you probably know, a S01(c)3) non-profit is severely restricted inthe amount of its funds it an use in any lobbying oF political activity. It does not appear that UH does anything that isnot politica, and the intimate relationship of UOH and United Horsemen adds yet another possible legality with which Rep. Wallis involved thats, eommingling of tax-exempt and nosx exempt Duquette and Rep. Wallis jointly solicit money from the publi for this lobbying and so-called “education” in suppor of laws that would enable and promote the return of commercial horse slaughter tothe U.S. and aso that would defeat a proposed ban on the export of American horses for commercial slaughter for human consumption, itp: www: snitedharsemensfiont.or8 For example, the PayPal button that was on Wallis’ web site initially went to UHF; now when the user elicks on “sign-upjoin,” a page stating “click here” appears, and the browser goes 10 UBF, now called United Horsemen. Join — Mail List lick HERE tog toa page where you can jon or suppor the wrk of the United Orgerizatons ofthe‘The donor is told he or she is donating to support both organizations, but donations to UOH. ‘would not be tax deductible, There is nothing on Wallis’ ste that tells the donor that by clicking ‘on “sign-upjoin,” he or she will be directed to the UH website. The UH site has the same design as Wallis site, and it s unlikely the user will even notice itis a different website. btpy/Avwew.untedorgsofthehorseore.ohpS-12.dfw1- In 2010, Rep. Wallis sponsored a bill, now a law, hup/legiswe state.wyus/2010/EnrolV/HBO122.pa that allows the Wyoming Livestock Board to "send for slaughter" any abandoned, estray, feral, of abused animals under the Bostd’s control. The Board could already sell these animals at auction; so including the phrase "send for slaughter” in the law didn't add tothe Board's current authority. It merely sends the message that horse slaughter is acceptable, even desirable, Note that she did not indicate “send to rescues or sanetuaries" as an option. ‘The new law also states thatthe Board "may enter into agreements with licensed meat processing plants to process meat from livestock disposed of by slaughter. The processed meat shall Be sold ‘0: () Wyoming state institutions or to nonprofit organizations for no more than the board's costfor disposal, processing and delivery or (i) For profit entities at market cost forthe processed meat.” At the same time, Rep. Walls claimed she would be opening a horse slaughtethouse under the ‘ame, Unified Equine LLC. She also announced the production of “Unified Equine Products” and stated “meat, hide, hair, byproducts will be marketed through every available legal market.” She announced inthe Same press release that “Unified Equine Programs” “will be creating new jobs and the promise of prosperity for those who make all or part of thet living with horses....Those who are interested in helping with the implementation of the Unified Equine Programs, or donating to the cause are encouraged to contact the Cheyenne office orto visit the web site. Investment opportunities are also available to those who agree with the vision of the Unified Equine Programs.” htp:/tuesdayshorse.wordpress.comy/2010/04/27/horse- slaughtersue-has-unified-plan-for-Killing-equines-in-cheyenne! ‘When Rep. Wallis announced these plans in early 2010 and even published a web page and issued a press release enticing people to invest, I found Unified Equine LLC did not exist as a corporation or LLC anywhere inthe U.S. In fat, it was not registered as an organization withthe ‘Wyoming Secretary of State until October 2, 2010, despite her representations on the web site. Rep. Wallis is either oblivious of or indifferent to the possible securities violations in her investment solicitation. Offering investment instruments ouside of established U.S. Securities and Exchange ‘Commission (SEC) rules is illegal for an existent corporation. Doing so for a non-existent corporation rises the possible offense to fraud, Rep, Wallis most recently used an article in Newsweek magazine to elaborate on her devision “to license Wyoming’ first slaughterhouse o help owners who cant afford to are for their [horse]”... Rep. Walls anticipates enough local demand, from, among others, pet-food makers, 8s Soon as next year.” hip: www newsweek com/2010/10/30/wyoming- it Rep. Wallis once again used her position to pass a law that she could, in tur, use to ereate a financial opportunity for herself ep. Wallis’ misconduct goes even deeper. First, she well knows there is no market in the U.S. {or human consumption of horsemest, nor is there a market for use of horsemeat in pet food. The idea that a horse slaughterhouse could be a going concer based on selling horsemeat inside ‘Wyoming is illogical. Not only is there no market, but the entre population of Wyoming is ‘544,270. To be viable, history has shown that such a plant would have to produce and sell approximately 100,000 pounds of horsemeat per year, or 18 pounds for every man, woman and child inthe state, ‘This is nothing short of a fraud for investors ~ and the public. But it doesn’t end there. In 2010 Rep. Wallis sponsored legislation (Wyoming Food Freedom Act, House Bill 54 hitp/legiaweh state. wy.us/200/Engross/HB0054pdf ) that would eliminateall regulation and inspection of food sold directly to the consumer. The bill s expected to be re- introduced in 2011. If this bill passes, it would allow her slaughter business to sell contaminated hhorse meat directly to Wyoming consumers ‘The Food & Drug Administration (FDA) does not regulate production of horsemeat for human consumption in the U.S. because there is no market here. However, the FDA does not allow the use of a number of drugs in food animals that are given routinely to American horses. For example, Phenylbutazone (“Bute”) is a widely used non-steroidal anti-inflammatory drug, (NSAID). So ubiquitous is Bue that it is sometimes called the “aspirin of horses.” Bute isa known careinogen and causes liver failure and aplastic anemia (bone marrow suppression), “which is most often fatal. There is no withdrawal period for Bute, and since the administration of Subject: Support the horse industry & animal agriculture - a New Survey! To Date: Tuesday, April 14, 2009, 11:34 AM. Support the Rights & Options of Horse Owners! Dear Friends; Alitle over a we private pro pet ‘oppose any legisation that The response so far has been tremendous, but we still need MORE! emember thatthe proponens of animal ights and total ban an horse sla We know tha only 1% to 2% of horses inthe United Stats round up in the food chatbut now the entre Nations staring to resize the horific unintended consequences ofthe closure (OF US processing facies ‘As mare of a true measure ofthe cultural tite tavars the human cansumation of horse mest, ‘and counterpont © the argument that ne Americans woud ever consider eating hares mest. We ite you to take our short survey Take this survey “Thank you for doing your part to support our radionl use of all animals, an forthe rights and ‘options of hore owners! Please forward this to everyone you know who wil join the fight to fond off the attacks of ‘animal rights fanatics, and help us edueate the well-meaning, But misinformed horse owners {and animal lovers who still don’ understand what a oss of legal aptions wil do to the welfare of all horses. Sncerly, Sue Walls United Horsemens Front Forward sma Bssteuneuwecrneo ‘Ths al was Set by sus. walls ven com. owe {Update rofletemal Attias [instant rorval wih SefeUsubaebe™ |Privacy Po, ‘ve Walls 8 Untes Horsemen's Fron | POBox 7 | Recuse | WY | 82725< /tbody>REM Dea eo a Location: Blogs»Ag Headlines a Posted by: Northern Ag Network 6/4/2009 6:40 AM ‘Sue Wallis, serves as one of founding leadership team members for ‘the new United Organizations of the Horse. As a Wyoming legislator who has a ranch north of Gillette, Wallis became involved in the horse slaughter issue amidst others attempts to ban all use of horses for human consumption There are currently two bills in the U.S. congress called the Prevention of cruelty to equine acts which would make it a felony for anyone to transport a horse for the purposes of using it for food—something that has desimated the horse market according to Wallis. Asa state legislator, Wallis serves on the National Conference of State Legislatures as the vice chairperson of the agriculture and energy committee which has also taken efforts to put some common sense into the horse slaughter issue. Hear Wallis | explain activities of the National Conference of State Legislatures. As a follow up, Wallis contacted her colleagues on ag committees in every state legislature and asked them to do something in their state legislatures. | | Right now there is just one organization that promotes itself as being the unified voice of horse owners in Washington DC and that fs the American Horse Council, but ‘Sue Wallis, a Wyoming legislator who also has a ranch north of Gillettetakes issue with that | asa result, the United Organizations ofthe Hrse was formed just a couple months | ago totake a stand on these critica sues | Some exiting things are coming to the forefront, including legislation that wil be introduced In both the House and Senate of Congress called the Horse Act of 2009. ‘The The United Organizations of the Horse will be meeting in Washington DC, June 16th which is strategically planned to be the Sunday right before three days of ‘American Horse Council Meetings. Learn more about the United Organziations of the HorsUnited Horsemen's Front PO Box 454 Hermiston, OR 97838 541-571-7588 Donate via PayPal ‘You may click on the link below to make » donation to the UHF via PayPal, Please use Info@UnitedHorsemensfront.ora when sending your contribution. Thank you! “The United Horsemen's Front is a SO1e3 organization, Mission Statement: The United Horsemen's Front promotes horse welfare and the health ofthe horse industry by providing accurete, timely information about the unintended consequences of the ban on equine processing in the United States. The United Horsemen's Front seeks to unify our country's horsemen and -women in our cammon goals achieving humene ana reailstic solutions to the unwanted horse problem from the Perspective of experienced horse people wha have the best interest of the horse at heart.HELP US PUT ONE OF OUR GREATEST RESOURCES WHERE SHE CAN DO THE ‘Most coop! ‘By now, you are probably well aware thet the United Horsemen's Front, 2 relatively small organization, is batting the Humane Society of the United States (HSUS) and People for the Ethical Treatment of Animals (PETA). These are immense, wealthy animal rights special-interest groups trying to Impose their laws and their agenda on the horse Industry and animal agriculture as a whole. “Together, HSUS/PETA raises nearly $150 milion a year, most of which goes toward political lobbying and placing their messages before the public. HSUS boasts more than 10.5 milion mambars, 438 paid stat, and $5.4 milian in anlina donations. DETA war proud to use more then $1 milion worth of free advertising space in 2008. ‘The United Horsemen's Front budget and range of influence is a tiny fraction of the animal rights groups’. Still, we have managed to assemble a coalition of experts from across the country to help make our voice heard on Capitol Hill and in state legislatures. We have established a web site, e-mall database of more than 25,000 subscribers, and sent out well-timed legislative action alerts that have had a true Impact on lawmakers, But we need to do more—right now. At this time, your financial support is urgently needed to achleve this important priority: ‘Assemble a politcal ‘war chest” to fund the basic travel expenses for one of our greatest resources, Rep. Sue Wallis, who serves in the Wyoming Legisiature, Rep. Wellis has been instrumental in disseminating logical, articulate and reasonable messages about why we need to restore horse processing in our country. Not only has she helped inform and {educate the voting public, she has also been a’ significant resource for legislators In other States, and has been Invited to speak before large and influential horse groups this year. ‘We want to send her to places where our Issue Is actively debated right now: Washington, DC and Tlineis, to name just two. Rep. Walls is wiling to donate her time to lobby on behalf of our issues, but she needs financial help to get there. In adltion, we would like to organize public seminars featuring Rep. Walls and several of our other key experts. If every like-minded horse person sent just $50, we could truly begin to make & difference. If you can, please visit our site and donate vis PayPal--a link can be found st the bottom of this message, Or send a contribution to:United Horsemen's Front. PO Box 454, Hermiston, OR 97838 541-571-7588 {nfo@unitedhorsemensfront.ora Donate via PayPal ‘You may click on the link below to make a donation to the UHF via PayPal. Please use when sending your contribution. Thank you! “The United Horsemen's Front Is a 501c3 organization. Mission Statement: The United Horsemen's Front promotes horse welfere and the health of the horse industry by providing accurate, timely information about the unintended consequences of the ban on equine processing in the United States. The United Horsemen's Front seeks to unify our country's horsemen and -women in our common {oal: achieving humane and realistic solutions to the unwanted horse problem fram the Perspective of experienced horse people who have the best Interest ofthe horse at heart.