DOCKET NO. ______: SUPERIOR COURT : In the matter of a Petition for a Common : JUDICIAL DISTRICT OF Law Writ of Habeas Corpus, : LITCHFIELD : NONHUMAN RIGHTS PROJECT, INC., : AT TORRINGTON on behalf of BEULAH, MINNIE, and : KAREN, : Petitioner, : v. : : R.W. COMMERFORD & SONS, INC. : a/k/a COMMERFORD ZOO, and : WILLIAM R. COMMERFORD, as : President of R.W. COMMERFORD & : SONS, INC., : Respondents. : November 13, 2017

VERIFIED PETITION FOR A COMMON LAW WRIT OF HABEAS CORPUS

PARTIES

1. Petitioner the Nonhuman Rights Project, Inc. (“NhRP” or “Petitioner”) is a not- for-profit corporation organized pursuant to the laws of the State of Massachusetts with a principal address at 5195 NW 112th Terrace, Coral Springs, FL 33076. Its mission is “to change the common law status of at least some nonhuman animals from mere ‘things,’ which lack the capacity to possess any legal rights, to ‘persons,’ who possess such fundamental rights as bodily integrity and bodily liberty, and those other legal rights to which evolving standards of morality, scientific discovery, and human experience entitle them.” The NhRP does not seek to reform animal welfare legislation.

2. Respondent R.W. Commerford & Sons, Inc., also known as the Commerford Zoo, is a Connecticut corporation with a business address at 48 Torrington Road, Goshen, CT 06756.

3. Respondent William R. Commerford is the President of R.W. Commerford & Sons, Inc., with a residential address at 64 Crossman Road, Goshen, CT 06752. 4. Karen is a female African elephant in her mid-thirties. She was captured in the wild around 1983. Respondents have owned Karen since 1984. Her last known address is 48 Torrington Rd, Goshen, CT 06756.

5. Beulah is a female Asian elephant in her mid-forties. She was captured in the wild in 1967 in Myanmar. Upon information and belief, Respondents have owned Beulah since 1973. Her last known address is 48 Torrington Rd, Goshen, CT 06756.

6. Minnie is a female Asian elephant. Respondents have owned Minnie since at least 1989. Her last known address is 48 Torrington Rd, Goshen, CT 06756.

INTRODUCTION 7. On behalf of Beulah, Minnie, and Karen, the NhRP submits this Verified Petition for a Common Law Writ of Habeas Corpus (the “Petition”) and states: This Petition is filed pursuant to Connecticut Practice Book (“Practice Book”) § 23-21 et seq. as well as Conn. Gen. Stat. § 52-466 et seq., and requests that this Court: (a) issue the requested writ of habeas corpus and require Respondents to file a return to the Petition pursuant to Connecticut Practice Book § 23-21 et seq. including, inter alia, setting forth the facts claimed to justify the denial of liberty, detention and imprisonment of Beulah, Minnie, and Karen, three illegally confined elephants in Respondents’ custody; and (b) order the immediate release of Beulah, Minnie, and Karen from such illegal confinement.

8. This Petition is brought under the common law of Connecticut, which is broad, flexible, and adaptable. State v. Brocuglio, 264 Conn. 778, 793 (2003); State v. Guess, 244 Conn. 761, 778 (1998); Jolly, Inc. v. Zoning Board of Appeals, 237 Conn. 184, 196 (1996); Dacey v. Connecticut Bar Association, 184 Conn. 21, 25-26 (1981).

9. Connecticut courts have long recognized the common law writ of habeas corpus. Hudson v. Groothoff, 10 Conn. Supp. 275, 278 (Conn. C.P. 1942). This Petition is filed as an application in good faith for an extension of the Connecticut common law of habeas corpus to Beulah, Minnie, and Karen, who are being imprisoned solely because they are legal things rather than the legal persons they should be for the purpose of common law habeas corpus.

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10. The Expert Affidavits attached to this Petition set forth the facts that demonstrate that elephants such as Beulah, Minnie, and Karen are autonomous beings who live extraordinarily complex emotional, social, and intellectual lives and who possess those complex cognitive abilities sufficient for common law personhood a