Jamison St. Clair Affidavit PDF

1 AFFIDAVIT OF JAMISON ST. CLAIR 2 3 My name is Jamison St. Clair. For the past nine years I have been the President and CEO of the 4 American Accredited Breed Dog Show. I personally oversee the annual competition held each year in Metropolitan 5 as...

1 AFFIDAVIT OF JAMISON ST. CLAIR 2 3 My name is Jamison St. Clair. For the past nine years I have been the President and CEO of the 4 American Accredited Breed Dog Show. I personally oversee the annual competition held each year in Metropolitan 5 as well as affiliated dog shows throughout the year. I am well respected in the dog show community, and am at the 6 forefront of the whole dog show world. Companies come to me to launch new products…I probably turn away 80% of 7 the companies who come to me. I probably couldn’t count on two hands how many companies have gone under simply 8 because I wouldn’t allow their products to “sniff” one of my shows. I am fully accredited with the USA Kennel Club, as 9 well as the Metropolitan Feline Club (connected to the Feline Fancier’s Association,) and have become a leading figure 10 in the monetary valuation of dog and cat breeds. I have testified as an expert in over 10 civil trials, in nine different 11 states, in this capacity. 12 The American Accredited Breed Dog Show has been running for the past 36 years. The previous CEO, Gerry 13 Fleck, founded AABDS as the Mayflower Kennel Dog Show in Philadelphia back in the early 1970’s. Unfortunately, 14 Gerry ran the show without much vision; some people used to say that Gerry had two left feet when it came to the show. 15 What really ran the show were the owners and the dogs. The show started to become popular just as all of the designer 16 breeds became popular. It seemed like people couldn’t get enough of all of the different combinations that could be 17 made. In the dog show world, we were oblivious to the outside pressures to cross breeds. We were all about the pure 18 breeds! Also, this was when 24-hour television was becoming popular as well. I bet the young people today have no 19 concept of what used to be ESPN back in the 80’s! 20 I used to compete in the old Mayflower back in the late 80’s and early 90’s. I had a Pointer named Casey that 21 was quite successful. He had the most beautiful gait. I was never a hunter, and to be quite honest, I was a little skeptical 22 about having a hunting dog. But when I took him out for walks, his natural instincts would kick in. When he saw a 23 rabbit, look out! When I first heard of the Mayflower, I wasn’t sure what to think. But as soon as I showed Casey for the 24 first time, he seemed to thrive in the spotlight. He couldn’t get enough of the attention. I showed Casey six times in the 25 show. He never won Best in Show. One year we made it to the final three, losing out to Wink, a Norwich Terrier. 26 For most of this time, I was working as a chemical engineer. I had gotten my degree from Metropolitan 27 University in 1982. My first job out of college was for a pharmaceutical company, MPharm, right along the Route 1 28 corridor near Princeton. I was doing okay financially, but I wasn’t really happy. At night, I went back for my M.B.A. at 29 Met U. They had just started a night program. It took me two years, going three times a week. They didn’t have online 30 classes back then. I had to trudge myself to the classes after working all day. I graduated at the top of my class and 31 wasn’t afraid to let people know! 32 When someone at work asked me if I wanted a puppy, I took him up on it. Enter my life: Casey! He was the world to 33 me. And because of the shows, I found a whole new world that I enjoyed. In 1990, I left MPharm to go to work for 34 Petzicon, at the time the leading manufacturer of pet-related products. Because of my background, I was put in charge of 35 developing dog shampoos. It took about 12 years in development to come up with a new waterless shampoo, one that 36 owners would just spray on the dogs and wipe off with a chamois. It had to be the specific chamois that came with the 37 product. It said it explicitly on the bottle. 38 The chemicals interacted with the chamois and would leave the dog’s coat shiny and clean. Unfortunately, even 39 though we spent another three years in testing and marketing research, the product didn’t test too well. Too many owners 40 were using a terrycloth towel to dry the dog. If too much of the chemical was left on the dog, the skin would become 41 irritated and dry. It was my first product line and it didn’t go too well. 42 By the early 2000’s, Gerry Fleck had taken the Mayflower as far as he was going to take it. Some of the owners 43 started to spread rumors that the show was going to go bankrupt or fold. I was approached by these owners to see if I 44 would be interested in taking control of the show. It was my understanding at the time that Gerry was looking to sell. It 45 wasn’t until the process had started that I realized that Gerry was being forced out. I had only a small monetary stake in 46 the buyout, but because of my experience, as well as my M.B.A., I was put in charge of the show. Because Gerry had 47 control of the name Mayflower Dog Show, for legal reasons, I changed the name to American Accredited Breed Dog 48 Show. After the first year of the show, I also made the decision to bring the competition to Metropolitan. It opened up a 49 whole new market for us. It brought more exposure. I also made the decision to have yearlong competitions, conducted 50 in all the major cities, leading up to the AABDS in Metropolitan. By way of numbers, a champion dog can bring a 51 six-figure income to the owner. When I first started, it cost us more to show a dog than what we won! I personally feel 52 responsible for this change in livelihood among my dog owners. 53 I had brought a lot of change to the AABDS. A couple of the owners, not the ones who approached me to take 15 48  54 over, were upset that I was still working at Petzicon. They said that it was a conflict of interest for me to work at a pet 55 company, while being in charge of the AABDS. To be honest, I was looking for a way out of the company for a number 56 of years anyway. I had started to butt heads with the CEO of the company, W. Pat O’Connell, over the whole shampoo 57 fiasco. Also, there had been rumors circulating that a company employee had been misappropriating funds. Because of 58 the funds lost and the failure of the shampoo line, Petzicon was forced to look elsewhere for the chemicals and supplies 59 for their products. I had been letting the higher-ups know that the product quality had been suffering. It was for this 60 reason that I left Petzicon, and later made the decision to not allow Petzicon products to be used at my competitions. 61 I am aware that there are rumors that I was forced out at Petzicon. I cannot comment on that allegation due to a 62 confidentiality agreement signed by me and the company when I left three years ago. 63 Losing a sponsor like Petzicon hurt the AABDS at first. Some of the dog owners were reluctant to switch. That’s 64 one of the faults in the dog show world - not being able to see the big picture. I was able to work out contracts with 65 some of the other companies to make up the difference. I banned all Petzicon products from the competition, both in 66 sponsorship and in use. I had developed contingency plans for this. KodaCo, Petzicon’s biggest competitor, was signed 67 on to be the official pet products of the AABDS. KodaCo then re-upped to be the title sponsor of the competition series 68 for six years…at $3.2 million a year. KodaCo is even going to run AABDS-labeled products in their next line. With this, 69 the AABDS is set to thrive for the next decade. 70 I have also worked for the past five years in cases involving pet deaths due to negligent veterinary and shelter 71 care. We have been working with the USA Kennel Club and the Feline Fancier’s Association to push for legislation to 72 protect pet owners who have sued for damages citing sentimental value of their pet to the family, as well as valuation 73 for competitive show dogs. I have testified as an expert in court at civil trials, including the two most recent: MacArthur 74 v. Crane in California, where an owner filed a lawsuit after her dog died due to negligence following an operation, and 75 Melvin v. Dallas Animal Shelter, where a family pet was wrongly euthanized by an animal shelter. In both cases, the 76 United Veterinary Medical Association worked to stop the lawsuits, claiming the high rate of malpractice insurance 77 needed to cover the costs. In the MacArthur case, the plaintiff lost her case because the court ruled that the loss of 78 companionship is not a compelling argument. In fact, over 30 states have had cases similarly decided. Other than what I 79 already mentioned, a gag order does not allow me to talk about the Melvin case any further, since it is still in litigation. 80 In regards to this case, I am aware of the allegations that Carmen Capella has made. While I am not happy that 81 Carmen Capella used a Petzicon product on their dog, I am also not surprised by the claims. I have never used the 82 product on my dogs, would never use the product on my dogs, and would shout it on the rooftops to people that no one 83 should use the product on their dogs. 84 Carmen Capella had won the 2023 Best in Show Award with their West Highland Terrier, Sally. With this, they 85 were awarded a top prize of $100,000. I have been asked to determine the value that this dog, Sally, would have 86 brought to Carmen Capella. It is my estimation, with years of experience, as well as all available research and analysis, 87 that the West Highland Terrier, Sally, would have competed in the AABDS shows for the next 4-5 years at a high level. 88 With the money that is available to successful owners, taking into account the costs of grooming, veterinary care, and 89 training, Carmen Capella would have earned, or netted, upwards of $500,000 had the dog competed at the AABDS and/ 90 or other dog shows, as well as through endorsements. This is not taking into account appearance fees, or any emotional 91 or sentimental value. If called to testify as an expert, I will affirm these numbers. I prepared a chart outlining the earnings 92 of champion show dogs in recent years. 94 95 Jamison St. Clair 96 Jamison St. Clair 97 98 99 Sworn to and subscribed before me, this 14th day of August, 2024. 100 Judy Mason Pitt 101 Judy Mason Pitt 102 Notary Public 16 49