Motion to Protect

The following are portions of the requests for discoveries submitted by the Plaintiff. Here is additional background. (An overview can also be read here in the filed affidavit.)

On May 3rd, 2021 I published/streamed a video on my social media Facebook Group Animal Training Fundamentals with Barbara Heidenreich. Called YOU be the Behavior Consultant – Inspired to Create Change. ( It is not called “It is all Happening” as referenced in the questions)

The morning of May 3rd I posted the following announcement: Today’s topic: Are you inspired to create change? Do you see things and think “that could be improved upon?” We will take a look at an interesting journey towards improving animal welfare in the animal training industry. What it takes. The up and downs and how to navigate the terrain. As well as what is possible! Every initiative starts with just one person and that person could be you.

The entire livestream lasted 1 hour and 22 minutes. Of this discussion the requests for discoveries are in reference to 2 minutes and 23 seconds of the video, much of which has been selected out of context. The context is important for proper interpretation of the statements. The context is not provided in the interrogatories.