CAS FOIA Request


Please note a typo in the request.
It was stated the rabbits were taken on a 334-mile to Floridanot 344.


Linda Sue

February 8, 2016

Joe Elmore
Chief Executive Officer
Charleston Animal Society
2455 Remount Road
North Charleston, SC 29406

Dear Joe Elmore:

Under the South Carolina Freedom of Information Act, §30-4-10 et seq., I am requesting an opportunity to inspect or obtain copies of public records related to “rabbits seized” in a hoarding case in SC, Sunday Dec. 27, 2015 and transferred to Charleston Animal Society, SC. Then, transported Friday Jan. 1, 2016 from Charleston Animal Society (CAS) Charleston, SC to Halifax Humane Society (HHS) Daytona Beach, FL. On arrival at HHS, handed over to HHS Transfer agent, Jason Hoffman of Critter Encounters, who distributed to undisclosed locations (according to Jason Hoffman 3 “Farms”… and, according to CAS and HHS “Rescues” immediately adopted 85% of the rabbits) in Osceola County (run by two police officers), Lake County and Seminole County Florida.

I am requesting a waiver of all fees in that the disclosure of the requested information is in the public interest and will contribute significantly to the public’s understanding of the transfer and disposition of the 70 rabbits transported from Charleston Animal Society, SC to undisclosed locations in three (3) counties in Florida. This information is not being sought for commercial purposes.

I am requesting the following public records:

  1. “Intake Records” for all rabbits “seized” and transported to Charleston Animal Society.
  2. Rabbits tagged – tagging procedures, identification procedures, and all records identifying tags for all seized rabbits and photos.
  3. Medical records, exams, treatments, assessments, continuing medication schedule of all rabbits while at CAS facility, and during 344 mile transport to Daytona Beach, FL.
  4. Medical records for all animals that died as a result of the seizure, or in CAS custody.
  5. “Transfer/Out-Take Records” for all rabbits transported to Halifax Humane Society, Daytona Beach, FL.
  6. Disposition, Out-Take records for all rabbits not transported to Halifax Humane Society.
  7. Health Certificates for all rabbits transported to Florida.
  8. Medical, vet records, medications and dosing instructions for all rabbits requiring continued medical treatment in Florida – to Florida Rescues for continued medical care.
  9. Records signed by Halifax Humane Society acknowledging receiving rabbits transferred to their facility for 70 rabbits.
  1. Agreement signed between Charleston Animal Society, SC and Halifax Humane Society, FL as to the disposition arrangement of the transported rabbits.
  1. Records, email, written communication, agreements, transfer arrangements between Charleston Animal Society and Halifax Humane Society relative to the transfer of the 70 rabbits including any financial or other arrangements. Including all communication between CAS personnel and Miguel Abi-hassan (CEO), Michelle Pari (COO), and/or other HHS employees.
  1. All emails, agreements, transfer arrangements, including financial arrangements between Charleston Animal Society, Halifax Humane Society and Jason Hoffman of Critter Encounters and/or transfer partners in Osceola County, Lake County and Seminole County Florida, related to the transfer of the 70 rabbits.
  1. All emails, written communication between Halifax Humane Society and Charleston Animal Society subsequent to delivery of the 70 Rabbits to Florida, Jan. 1, 2016 to date, including any interoffice memorandums.
  1. All emails, communications related to CAS follow-up investigation to identify locations in the (3) Florida counties rabbits distributed to by Jason Hoffman of Critter Encounters.
  1. Charleston Animal Society contract to provide Animal Services to North Charleston, SC. Including financial arrangement, bills submitted for the seized animals. And, donations collected by CAS.
  1. Related to “Rabbit Rescue Update” posted on CAS website, January 4, 2016 Charleston Animal Society.  Pressroom:
    1. “Charleston Animal Society reached out to Halifax Humane Society in Daytona Beach, Florida upon the recommendation of Pet Health, Inc., which is the largest shelter/rescue software management company”
  1. Copy of record(s), email communication used to determine to select

Halifax Humane Society, Daytona Beach, FL to transfer the  70 rabbits.

  1. “Halifax Humane Society has 61 pre-qualified transport rescue partners. All of these rescues agree to spay/neuter animals before adoption.”
  1. Records identifying the 61 pre-qualified transport rescue partners CAS used as basis for statement, including spay/neuter agreements.
  1. “In the case of the rabbits, three rescue partners in Osceola County (run by two police officers), Lake County and Seminole County Florida stepped in to help. Again, all agreed to have rabbits spayed/neutered before adoptions. Halifax Humane is in Volusia County.”
  1. Records identifying the Rescue Partners used to transfer the 70 rabbits, including spay/neuter agreements.
  2. Records of all rabbits in adoptive homes, not on farms.
  • Records of rabbits adopted, dates, locations, etc.
  1. Vet spay/neuter records, medical records, continuing medication schedules.
  2. Procedures followed to separate unsterilized rabbits.
  3. Records for any new babies and their care,disposition.
  • Transfer/Out-Take/Intake records after Halifax transferred the rabbits.
  1. “Rabbits will NOT be used as food.” — Records indicating rabbits will NOT be used as food for animals or humans.
  1. “Charleston Animal Society spent a considerable amount of money on medical exams, food and treatment when the rabbits were first brought in”Records of food, medical exams, medical treatment including financial cost.
  1. “We led an unprecedented rescue operation during the fall floods throughout the Lowcountry, saving numerous animals and depended on our transfer partners for that operation.” — Records including Intake, medical, evaluation, transfer/Out-Take records for animals taken in by CAS and transferred to other Shelters, including records where transferred, financial and other agreements.

The South Carolina Freedom of Information Act requires a response time within 15 business days.  If access to the records I am requesting will take longer than this amount of time, please contact me at with information about when I might expect copies or the ability to inspect the requested records.

If you deny any or this entire request, please cite each specific exemption you feel justifies the refusal to release the information and notify me of the appeal procedures available to me under the law.


Thank you for considering my request.

Linda Sue
Rabbit Community/Rabbit Rescue



Mayor R. Keith Summey

North Charleston, SC

CAS Government Vendor Contract
CAS. Government Funding

South Carolina FOIA Law

 Who or what is covered by the FOIA?

A “public body” is any entity supported by public funds, even in part, or that expends public funds. Public bodies include state and local agencies, school boards and city councils. Committee and subcommittee meetings are included. Even non-profit agencies and chambers of commerce that receive public funds are subject to the FOIA. Federal agencies are not covered by state law and have their own FOIA. South Carolina’s FOIA starts with the presumption that all public body records and meetings are open and available to the public. A record cannot be withheld and a meeting cannot be closed unless a specific exemption or some other state law applies. Just because an exemption could apply, however, doesn’t mean it must. A public body may claim an exemption, but is not required to do so. If claimed, an exemption must be interpreted narrowly to increase awareness of all citizens of public activities.

When the public body gets your FOI request, it has 15 working days to respond as to whether it will comply or claim an exemption. You should usually get your records within 15 working days, but the agency has a reasonable time after its response to collect and provide your data if needed. If any part of the record is to be withheld, the agency must tell you exactly which FOIA exemption justifies the denial. If the public body does not respond at all within the allotted 15 days, the FOI request is considered granted.

Charleston County has a “50” year contract with the “Society” starting in 1979.