Plaintiffs assert in their complaint that defendants, individuals and companies who use non-human primates in television and movie productions, engage in physical and psychological abuse of chimpanzees.  According to plaintiffs, the abuse has been going on for years and includes violent beatings with sticks and other implements.  Plaintiffs raise their first cause of action under the federal Endangered Species Act, contending that defendant's harassment, beating, and brutalization of the chimpanzees constitutes a "taking" under the ESA.  Plaintiffs also raise causes of action under California law for specific recovery of property (e.g., the primates), conversion, violations under the California Business Code, and violations under the cruelty provisions of the California Penal Code.

Complaint to U.S. District Court (11/18/2005) (pdf file - 168.72 KB)