of Sate emcee, DA #17-13644 WCAC Ai7-207847 nicks FILED e South Sierra Street AUG 2:8 2019 10, NY 89501 JACQUELINE BRYANT, CLERK 5} 328-3200 By: DEPUTY OLE IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF N IN AND FOR THE COUNTY OF WASHOE THE STAINS OF NEVADA, intife, Case No.: cRIQ-i821 & . Dept. No.: G MICEAEL DURAND SCENETDER(A) iBtuawr tav-scanetoer,(B) Defendants. — INDICTHENT The defendants, MICHAEL DURAND SCHNEIDER, and LETLANT TAU SCHNETD ) are accused by the Grand Jury of Washoe County, State of Nevada, of the following: COUN BRACLICTNG VE ERTNARY MEDICINE WITHOUT A LICENSE, $ 638.090, NRS 638.170(2), and NRS 195.020, a Sale (ies) in the manner following, to wit a violation D fe go! RN SCHNEIDER and That the said defendants, MICHA LEILANI TAU-SCHNEIDER, ai ng individually and/or in joint participation and/or as abettors with one another, between May and October, 2017, at Reno Township, within the County of Washoe, Stateof Nevada, did willfully and unlawfully practice veterinary medicine without a license at "PUPPIES PLUS, INC", located at 6405 South Virginia Street, said defendants being responsible under one or more of the following theories of the offense: (1] the defendants did directly commit the said act; and/or (2) the defendants did aid or fh the intent that the abet another in-the commission. of the crime wi crime be committed by directly or indirectly counseling, encouraging, ther to commit the commanding, inducing, ox otherwise procuring an suant to a conspiracy te commit this crime, with erime; and/or (3) pu the intent that this crime be committed, the defendants conspired to commit the crime, to wit: nid underneath the skins of the defendants injected various dogs at “PUPPIES PLUS, INC", located at 6405 South Virginia Street, which conduct constituted the practice of veterinary medicine; AND/OR That the said defendants did, acting individually and/or in joint participation, aid, abet, counsel, encourage, hire, command, induce or otherwise procure an associate, agent, or employee of "PUBPTE! forementioned act, to wit: the PLUS, INC" © commit the IES PLUS, INC”, trained and defendants, as co-owners instructed their employees to routinely inject fluid under the skins for real exceived illnesses, of dogs as course of treatme: without having instruction from @ licensed veterinarian, and provided tions the equipment and refills of fluid needed to perform said in a10 1 12 13 1g 1s 16 18 19 20 21 22 23 24 COUNT IT. PRACTICING VETERINARY MEDICINE WITHOUT A LICENSE, @ violation of NRS 638.090, NRS 638.170(2), and NRS 195.020, 17 . a category D felony, ( } in the manner following, to’ wit: That the said defendants, MICHAEL DURAND SCHNEIDER and LEILANI TAU-SCHNEIDER, acting individually and/or in joint participation and/or as abettors with one ancther, between May and October, 2017, at Reno Township, within the County of Washoe, Stat of Nevada, did willfully and unlawfully practice veterinary medicine without a license at "PUPPIES PLUS, INC", located at 6405 South Virginia Street, said defendants being responsible under one or more of the following theories of the offense: (1) the defendants did directly commit the said act; and/or (2) the defendants did aid oz abet another in the commission of the crime with the intent that the crime be committed by directly or indirectly counseling, encouraging, commanding, inducing, or otherwise procuring another to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, the defendants conspired to commit the crime, to wit: the defendants administered Doxycycline, AND/OR Tetracycline, AND/OR Clavamox, AND/OR other antimicrobial drugs via atomization and inhalation in sealed storage containers te various dogs at "PUPSTES PLUS, INC", located at 6405 South Virginia Street, which conduct constituted the practice of veterinary medicine: AND/OR That the said defendants did, acting individually and/or in joint participation, aid, abet, counsel, encourage, hire, command,20 at 12 induce or otherwise procure an associate, agent, or employee of “PUPPIES PLUS, INC” to commit the aforementioned act, to wit defendants, as co-owners of “PUPPIES PLUS, INC”, trained and instructed their employees to routinely place dogs in sealed storage containers which were then filled with atomized medication which was designed to be inhaled by the dogs as course of treatment for real or perceived illnesses, without having instruction from a licensed veterinarian, and provided the ecuipment and refills of medication needed to perform said procedure. IIT. PRACT NG VETERINARY MEDICINE WITHOUT AL LICENSE, a violation of NRS 638.090 and NRS 638.170(2), a category D Sal7e felony, (G65) in the manner following, to wit: That the said defendant, MICHAEL DURAND SCHNEIDER, between May and October, 2017, at Reno Township, within the County of Washoe, State of Nevade, did willfully and unlawfully practice veterinary medicine without a license, to wit: the defendant prescribed AND/OR provided Doxycycline pills, AND/OR other antimiccobial drugs to Ashley Perez for the treatment of her dog, which conduct constituted the practice of veterinary medicine. COUNT IV. PRACTICING VETERINARY MEDICINE WITHOUT A LICENSE, a violation of NRS 638.090, NRS 638.170(2), and WRS 195.020, a category D felony, (S89%) in the manner following, to wit: That the said defendant, MICHAEL DURAND SCHNEIDER, between May and October, 2017, at Reno Township, within the County of Washoe, State of Nevada, did willfully and unlawfully practice veterinary medicine without @ license, to wit: the defendant administeredzoonotic disease vaccinations, namely, cabies vaccinations, to various dogs at "PUPPIES P , located at 6405 South Virginia Street, which conduct constituted the practice of veterinary medicine; AND/OR at- the said defendant, MICHAEL DURAND SCHNEIDER, did aid, abet, counsel, encourage,,hize, command, induce or otherwise procure an associate, agent, or employee of "PUPPIES PLUS, INC" to commit the rementioned act, to wit: the defendant, as an owner of “PUPPIES PLUS, INC”, trained and instructed his employee, namely, Ashley ed at Perez, te administer rabies vaccinations to various dogs loca ork, all “PUPPIES PLUS, INC” and to complete the required pape: without a licensed veterinarian present. COUNT V. PRACTICING VETBRINARY MEDICINE WITHOUT A ‘LICENSE, a violation of NRS 638.090 and NRS 638.170(2) a category D galze (ieee ony, in the manner foli wing, to wit: hat the said defendant, LEILANI TAU-SCHNEIDER, between May and October, 2017, at Reno Township, within the County cf Washoe, State of Nevada, did willfully and unlawfully practice veterinary medicine without a license, to wit: the defendant recommended a course of treatment for a sick “Cocker Spaniel” breed dog to her employees at "PUPPIES PLUS, INC", located at 6405 South Virginia Street, whereby the defendant recommended that the sick “Cocker Spaniel” be given fluid injections AND/OR breathing treatments AND/OR be force-fed food, which conduct constituted the practice of veterinary me ‘ine.10 1. 12 13 14 16 7 19 20 al 22 23 24 26 COUNT VI. TORTURING AND/OR KILLING AN ANIMAL, a violation of NRS 574.100(1), NRS 574.300(6) (a) and NRS 195.020, a category D felony, (55977) in the manner following, to wit: That the said defendant, LEILANT 0. HNETDER, between the ist and 30th day of September, 2017, at Reno Township, within the County cf Washoe, State of Nevada, did willfully, unlawfully, and maliciously, torture and/or kill a “Cocker Spaniel” b: sed dog at or near "PUPPIES PLUS, INC", located at 6405 South Virginia Street, in the manner following, to wit: by tefusing and/or withholding necessary veterinary care to a sick “Cocker Spaniel" breed dog, which conduct caused said dog to experience unjustifiable physical pain and/or suffering, and/or caused the death of said dog; AND/OR That the said defendant did aid, abet, counsel, encourage, hire, command, induce or otherwise procure an associate, agent, or employes of “PUPPIES PLUS, INC" to commit the aforementioned act, all of which caused said dog unjustifiable physical pain and suffering, and/or caused the death of said dog, to wit: the defendant, as an owner of “PUPPIES PLUS, INC”, instructed her employees how to care for a seriously ill “Cocker Spaniel” breed dog in that LETLANI "AU SCHNEIDER instructed her employees not to take the sick dog to a licensed veterinarian, but to instead force-feed the sick dog and inject it with fluid, and to feed it Karo syrup, ali of which did not cure the dog, who died shortly thereafter. ws Wd10 qa 12 13 44 16 a7 18 1g au 22 23 24 AFFIRMATION PURSUANT TO NRS 239B.030 The undersigned does hereby affirm that the preceding document does not contain the social security number of any person. 28,04 CY Dated this 28th day of August? 2019. CHRISTOPHER J. HICKS District Attorney By CHRISTOPHER DEPUTY DISYRICT ATTORNEY10 at The following are the names of witnesses examined before the Grand Jury: ASHLEY SERV oF GEES BROOKS. CASANDRA SCANNELL JESSICA SLATIN, DVM JENNIFER PEDIGO “A TRUE BILL" FOREEERSON s "NO TRUE BILL" FOREPERSON