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NhRP Re-Files Habeas Corpus Case on Behalf of Tommy in New York

The Nonhuman Rights Project filed a new lawsuit on December 2, 2015 in the New York State Supreme Court, New York County (Manhattan) in which we again demand that Tommy the chimpanzee be released from captivity pursuant to a common law writ of habeas corpus. The case is captioned Nonhuman Rights Project, on behalf of Tommy v. Lavery, et al., (162358/2015).

You can read our press release here.

For more information, please email us at media@nonhumanrights.org.

Below are the documents we have filed with the court to date, including motions, memoranda of law, exhibits, and affidavits from the world’s leading primatologists, including NhRP board member Dr. Jane Goodall:

Order to Show Cause and Writ of Habeas Corpus

Verified Petition Table of Contents

Verified Petition dated December 2, 2015

Exhibits Annexed to the Verified Petition dated December 2, 2015

  1. Order dated December 17, 2013 of Honorable Joseph M. Sise, and Transcript of Oral Argument dated December 2, 2013
  2. Letter dated May 1, 2014 from Arthur Carl Spring, Esq., Attorney for Respondents, to Appellate Division, Third Department
  3. Appellate Division, Third Department Order dated July 9,2014 Granting Petitioner’s Motion for Preliminary Injunction
  4. Appellate Division, Third Department Order dated January 30, 2015 Denying Motion for Permission to Appeal to Court of Appeals
  5. Court of Appeals Order dated September 1, 2015 Denying Motion for Leave to Appeal to the Court of Appeals
  6. Letter Brief of Amicus Curiae Laurence H. Tribe dated May 8, 2015 In Support of Motion for Leave to Appeal to the Court of Appeals
  7. Letter Brief of Amicus Curiae Justin Marceau dated April 14, 2015 In Support of Motion for Leave to Appeal to the Court of Appeals
  8. Appellate Division, Second Department Order dated April 3, 2014 Dismissing Appeal
  9. The Nonhuman Rights Project, Inc. Trust for Tommy, Kiko, Hercules, and Leo dated November 15, 2013

Affidavits Annexed to the Verified Petition dated December 2, 2015

Affidavit of Molly Polidoroff sworn to December 5, 2014

Exhibit A: Photographs of “STC” Sanctuary

Exhibit B: Standards for Great Ape Sanctuaries

Affidavit of Steven M. Wise sworn to January 21, 2015

Exhibit A: Announcement of Agency Decision: Recommendations on the Use of Chimpanzees in NIH-Supports Research” dated June 26, 2013

Exhibit B: Portuguese Decision dated September 28, 2005 In favor of Suica, a Chimpanzee

Exhibit C: English Translation of Decision dated September 28, 2005 In favor of Suica, a Chimpanzee

Exhibit D: Excerpts from brief

Exhibit E: Excerpts of Oral Argument of Steven M. Wise

Exhibit F: Excerpts of Memorandum of Law

Exhibit G: Verified Petition dated December 2, 2013

Affidavit of Steven M. Wise, dated December 2, 2013

Exhibit A: Video of Tommy

Exhibit B: Photographs of Tommy

Affidavit of James R. Anderson sworn to November 20, 2013

Affidavit of Christophe Boesch sworn to November 19, 2013

Affidavit of Jennifer M.B. Fugate sworn to November 22, 2013

Affidavit of Mary Lee Jensvold sworn to November 21, 2013

Affidavit of James King sworn to November 21, 2013

Affidavit of Tetsuro Matsuzawa sworn to July 7, 2014

Affidavit of William C. McGrew sworn to November 21, 2013

Affidavit of Mathias Osvath sworn to November 19, 2013

Affidavit of Emily Sue Savage-Rumbaugh sworn to November 22, 2013

Original Affidavits Annexed to the Verified Petition dated December 2, 2015

Supplement Affidavit of James R. Anderson sworn to November 18, 2015

Supplemental Affidavit of Christophe Boesch sworn to November 14, 2015

Affidavit of Jane Goodall sworn to September 21, 2015

Supplemental Affidavit of Mary Lee Jensvold sworn to September 29, 2015

Supplemental Affidavit of William C. McGrew sworn to October 9, 2015

Supplemental Affidavit of Emily Sue Savage-Rumbaugh sworn to December 1, 2015

Motion to Admit Steven M. Wise Pro Hac Vice

Notice of motion

Affirmation of Elizabeth Stein

Proposed Order

Affidavit of Steven M. Wise

Certificate of Good Standing

Request for Judicial Intervention

Memorandum of Law, dated December 2, 2015

Comments
6 Responses to “NhRP Re-Files Habeas Corpus Case on Behalf of Tommy in New York”
  1. Lydia says:

    thank you NhRP for your persistence and incredible work.

  2. ELIZABETH says:

    what is wrong with Judge barbara jaffe? She has no compassion in her soul. What’s the big deal about setting them free to a sanctuary? It just doesn’t make sense. there must be some payoffs involved!!

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  1. […] Perhaps unsurprisingly, the Nonhuman Rights Project (NhRP) filed another petition for a writ of habeas corpus (available of NhRP’s website) to: […]

  2. […] Jaffe declined to issue the order to show cause requested in the Nonhuman Rights Project’s second habeas corpus petition on behalf of Tommy the chimpanzee “to the extent that the courts in the Third Dept. [already] […]

  3. […] both in chimpanzee communities and in human/chimpanzee communities. We then filed Tommy’s second habeas corpus petition in Manhattan in early December, 2015 and again were assigned Justice […]

  4. […] was only after the NhRP filed a second case on Tommy’s behalf in December of 2015 that we learned of Lavery’s claim to have sent Tommy to the DeYoung Family […]



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