DECLARATION OF LAURIE SIPERSTEIN-COOK, DVM

I, Laurie Siperstein-Cook, declare:

I know the following facts of my own knowledge and if called as a witness would testify competently thereto.

1. I am an avian veterinarian. I graduated from the University of California at Davis School of Veterinary Medicine in 1989. I also have a masters degree in Zoology from the University of California at Davis.

2. In November, 2002, I was asked to examine four ducks that I was told were rescued from a foie gras producing farm. The circumstances of the rescue were not described to me.

3. On examination of the ducks, I noted the following conditions:

• Very overweight, with excess fat pads palpable on their chests and abdomens.
• Heavily soiled with fecal matter.
• Could barely stand and walked with difficulty.
• Panted excessively.
• Had severe cases of bumblefoot (pododermatitis = infected foot pads) on both feet.
• Were not eating on their own.

4. I concluded that their conditions were a result of the following:
Force-feeding excessive amounts of a high calorie food. The purpose of this process is to cause their livers to swell to an abnormal size due to storage of fat. This process produces the delicacy known as foie gras, yet the consequences are deleterious to the health and well-being of the ducks. Grossly enlarged livers are less able to perform their function of cleansing the bloodstream of waste products from the body. In fact, if the force feeding were to continue, many if not most of the birds would die from liver disease. In fact, the mortality rate of force fed ducks is higher than that of free feeding ducks being raised for meat. Pathologists who were shown livers from force fed ducks determined that the livers were pathologically engorged with fat to a degree that was much more severe than occurs naturally.

It has been shown that ducks fed ad lib do not eat as much or gain as much weight as ducks that are force fed, and if force feeding is stopped, the ducks eat less until they lose the excess weight and their livers return to normal size. Even in preparation for migration, ducks in the wild do not gain so much weight that they are sick, can't walk and have become obese. Besides, the ducks used for foie gras production are a hybrid of mallards and muscovy ducks, the latter of which do not migrate at all in the wild. They therefore don't have the need to store fat for migration.

The swollen livers also put pressure on the abdominal airsacs which impares the bird's ability to breathe. They also push the legs out laterally, making it difficult for the birds to walk properly.

Excess weight at fast growth rates causes pressure on the legs and joints, also making it difficult and painful to walk. Ducks in foie gras factories have been shown to suffer from a much higher rate of long bone fractures at the time of slaughter than ducks raised for meat and not force fed.

5. Lack of access to water for bathing. Ducks require at least shallow pools of water for immersing their heads and for bathing. They have a strong urge to clean and preen their feathers to keep them lined up and waterproof. The ducks I saw were very soiled and obviously were denied water adequate for this behavior.

6. Improper flooring . Ducks kept on hard wood or wire surfaces will develop foot sores that lead to the infection called bumblefoot. This is a painful condition that can progress into the joint of the foot causing chronic pain and difficulty walking.

7. I believe that the conditions described, under which these birds were kept and the fact that they had been force-fed to create an obese and unhealthy state constitutes unnecessary cruelty.

8. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Laurie Siperstein-Cook

Dated October 14, 2003