http://voiceforthemurphytexasbobcat.yolasite.com/
This is the website for the organization - Voice for the Murphy, Texas bobcat

We are going to unite all animal lovers in Texas to get Murphy, Texas Chief of Police G.M. Cox fired or force him to resign ...... for authorizing a police officer to shoot and kill the bobcat, while it was locked in a cage. We will be at the San Antonio City Hall steps every Saturday at noon, to gather signatures and also get contributions to help pay the filing fees on the lawsuit which has been filed against Police Chief G.M. Cox.

The Murphy, Texas police officer who shot a bobcat while it was in a cage, was acting under the direction of Murphy Chief of Police G.M. Cox. The Texas Parks and Wildlife Dept. does not consider what Chief Cox did as a crime. Texas Penal Code and Parks and Wildlife Code does consider it a crime. So I have filed a lawsuit against Chief Cox, because he must be held accountable for this. The bobcat was totally defenseless.

Not one law enforcement agency in Texas will do anything about this matter ......... according to the Parks and Wildlife State Statute, all wild animals are the property of the people of the state of Texas. And the law covers every county and city.

I am contacting every radio and television station in the state to get public support for this defenseless animal. We don't shoot and kill murderers and rapists, while they are in their cells.

http://www.gofundme.com/respectanimals

is my website where I am accepting contributions to help with the filing fee.

BEXAR COUNTY DISTRICT COURT
224TH CIVIL DISTRICT COURT
100 DOLOROSA STREET, ROOM 120
SAN ANTONIO, TEXAS 78205-3411
Patrick Greene (Pro se)

Plaintiff
vs. CAUSE NUMBER 2011CI15632
G.M. Cox, Chief of Police of Murphy, Texas
Defendant

REVISED COMPLAINT

1. Patrick Greene
5335 Glen Ridge Drive #2504
San Antonio, Tx 78229

2. G.M. Cox/Chief of Police of City of Murphy, Texas
206 N. Murphy Rd.
Murphy, Texas 75094

3. Plaintiff is resident of San Antonio, Bexar County.

4. This court has jurisdiction per Subchapter B, Section 1.011(a), also Parks and Wildlife State Statute Subchapter A, Section 61.003 and 61.005(1) (Exhibit #1)

5. This court is the proper venue per Section 15.002(a)(4) Texas Civil Practice and Remedies Code.

6. Plaintiff must file complaint in this court, due to his financial incapacity to travel to county of defendant's actions. Plaintiff must take this action because no law enforcement agency in Texas will take action against defendant.

7. Plaintiff has standing in this court, per Section 1.011(a) Texas Parks and Wildlife Statutes. Plaintiff is part of the 'people' in this section. Also Section 61.003(1) of Texas Parks and Wildlife Statutes. (Exhibit #2)

8. On or about August 17, 2011 defendant dispatched a Murphy police officer to the residence of Andrew and Christine Smith. Mr. and Mrs. Smith are residents of Murphy, Texas. (Exhibit #3)

9. Mr. and Mrs. Smith granted the officer permission to enter their property, to relocate a bobcat, which they had previously humanely trapped in a cage. The officer took possession of the caged bobcat. The officer was with an animal control officer, who was an employee of the city of Murphy, Texas. This officer was acting under the authority of the defendant. (Exhibit #3 page 3)

10. Mr. and Mrs. Smith went into their house, with the understanding that the officer would take the caged bobcat and relocate it to a safer location and free the animal. Defendant failed to properly train the this officer to comply with Mr. and Mrs. Smith's request.

11. Mr. and Mrs. Smith watched the animal control officer on the left of the cage, trying to sedate the bobcat.

12. Mr. and Mrs. Smith witnessed officer kicking the cage, yelling at the bobcat. The officer also repeatedly was stomping the ground.

13. At that point the bobcat became aggressive inside the cage.

14. Mr. and Mrs. Smith watched the officer repeatedly remove his service revolver out of his holster and put it back in the holster.

15. Then the officer removed his service revolver, put it near the cage and pull the trigger.

16. Mr. and Mrs. Smith then witnessed the officer kill the bobcat, with shooting a bullet to the bobcats head, while the animal was still in the cage.

17. This court can view the news report from WFAA.com, a Dallas television station. It can be viewed at this address:
http://www.wfaa.com/news/entertainment/pets/Caged-Bobcat-Shot-by-Officer-127980323.html

18. The bobcat is classified as a 'depredating animal', per Texas Parks and Wildlife State Statute Section 43.103(2). (Exhibit #4)

19. All 'depredating' animals are classified as 'Wildlife' per Texas Parks and Wildlife State Statute Section 43.103(6). (Exhibit #4)

20. Texas Parks and Wildlife State Statute Section 61.005(1) classifies all wild animals as 'Wildlife resources'. (Exhibit #1)

21. When defendant authorized this police officer to shoot and kill this caged bobcat, he violated Section 61.022(a) of the Texas Parks and Wildlife State Statute. (Exhibit #5)

22. When Mr. and Mrs. Smith captured this bobcat, they effectively took possession of this animal. Their responsibility toward this animal was to treat it humanely.

23. When Mr. and Mrs. Smith allowed defendants' officer to enter on to their property, he was mandated by law to obey the wishes of the owners.

24. When defendant was interviewed by Karen Chaney, a reporter for the Murphy Messenger newspaper, he stated; 'A good tip about calming a trapped bobcat: put a blanket over the cage, if possible--if a cat thinks it is in the dark and can't be seen, it will calm down. Nice to know.' Defendant went on to say; 'Until I can finalize the procedures that we will follow in future situations, we will not utilize a firearm to euthanize a caged animal unless there are serious, obvious, justifications for it and then only after at least one member of the command staff has been consulted.' (Exhibit #6)

25. With that quote defendant admitted ignorance of existing state Texas State Statutes, which have been in effect since 2005. Plus the City of Murphy city ordinance effective 2-16-2009. The City of Murphy Charter states that City ordinances must comply with State Statutes. (Exhibit #8)

26. When defendant's officer proceeded to torment this animal, he violated the City of Murphy ordinance Article 1, Section 14-7(d) by 'ill-treating and tormenting' the bobcat. (Exhibit #7)

27. Defendant also admitted ignorance of Murphy city ordinance. Article 1, Section 14-2(e) violates existing State Statute. 'No person may possess any wildlife resource, unless the owner consents.' Texas Parks and Wildlife Statute Section 61.022(a)

28. Defendants' police officer, acting in compliance with defendants' departmental policy, willfully mislead Mr. and Mrs. Smith into believing he intended on complying with their wishes to relocate the bobcat.

29. Defendants' police officer, in purposely misleading Mr. and Mrs. Smith, entered their private property, and took possession of caged bobcat, illegally. He killed the bobcat without their permission.

30. This illegal possession took the bobcat out of the possession of the defendant, and placed it back into the property of Mr. and Mrs. Smith. They decided to take no action in this matter. They thereby relinquished their responsibilities to the bobcat.

31. It was at this point the bobcat became the property of the Plaintiff, as a representative of the 'people' per aforementioned state statute.

32. Defendant, being the Chief of Police of Murphy, Texas, has the written responsibility of 'Enforcement of state laws as well as city ordinances. (Exhibit #9)

33. Defendant is culpable, being the Chief of Police of the City of Murphy, per the City's website. Defendant is ultimately responsible for enforcing all city ordinances and state laws. 'It is the duty of any police officer to be obedient to him' Per Murphy City Charter, Article II, Section 42-23 (Exhibit #10)

34. Defendant has extensive background in law enforcement. His background goes back almost 30 years. This includes 'the full spectrum of policing, managerial, and leadership experience.' (Exhibit #11)

35. What makes this matter all the more grievous, is that defendant came to Murphy, from being the Chief of Police of Corsicana, Texas for many years. Corsicana has had a policy of relocating wild animals to the county area away
from people, going back to at least 2008. This information came from the current Chief of Police, Randy Bratton. (Exhibit # 13)

36. Defendant authorized his officer to commit an act of possession, where he knowingly received the bobcat, and was aware of his control of the bobcat for a sufficient time to permit him to terminate his control. Thereby violating Texas Penal Code Chapter 6, Section 6.01(a)(b) (Exhibit #12 page 1)

37. Defendant meets the requirement of culpability where he 'intentionally, knowingly, recklessly authorized his officer to engaged in this conduct. (Exhibit #12 page 1)

38. Defendant is responsible because he knew, when his officer committed this act, that the result would not have occurred but for his conduct. (Exhibit #12 page 3)

39. Defendant also violated The Texas Penal Code when he; 'acting as a public servant, misused government property, personnel and wildlife resources, by ordering a sworn police officer to use a government vehicle, and kill a bobcat temporarily in his possession. This violated Section 39.01(1)(A)(B)(2)(A)(B) and Section 39.02(a)(1)(2)(Exhibit #13)

I pray the court rules defendant legally responsible for his officer's actions, and penalizes defendant appropriately, according to the powers delegated to it by the Texas Constitution.

Patrick Greene (Pro se)
53335 Glen Ridge Dr. #2504
San Antonio, Tx 78229
210-391-2537