Department of Agriculture Commissioner Shawn Jasper said his agency stripped a prominent Chichester animal rescue of its pet vendor license because it repeatedly failed to comply with veterinary record requirements related to the health and vaccination histories of dogs and cats entering New Hampshire.

Jasper’s defense of the enforcement action came a week after Teresa Paradis, the owner of Live and Let Live Farm, publicly accused the department of engaging in a five-year campaign of retaliation against her. Paradis has already sued the department over another license dispute and her lawyer, Rick Lehmann, plans to file an injunction opposing this one, which went into effect July 1.

Inspection reports and correspondence with Paradis from 2009 to 2024 shared by Jasper show that the department began taking issue in 2019 with the completeness of Live and Let Live’s certifications for veterinary inspection, which are required to transport animals across state lines. Live and Let Live is the largest interstate importer of dogs and cats in New Hampshire, according to Jasper.

Paradis has argued that the department’s requirements are ever-changing and impossible to follow. She maintains that the denial is the latest escalation of a feud that began in late 2019 after she refused an inspector’s demand that she take in horses that had been seized elsewhere. Since then, the department has levied thousands of dollars in fines against the non-profit, which takes in animals ranging from cats and dogs to horses and geese.

Jasper “is dinging her for paperwork problems, but there isn’t a single complaint that has anything to do with actually protecting people or keeping animals safe,” said Lehmann, Paradis’s lawyer.

In a wide-ranging two-hour interview last week, Jasper – the former Speaker of the House in New Hampshire – pushed back against the notion that the certification forms are immaterial to animal welfare, arguing that the inspections are an important aspect of keeping diseases out of New Hampshire. He denied Paradis’s retaliation accusation and said that an investigation found that no inspector requested horses to be placed there. Amid increased enforcement department-wide, Jasper painted his department as accommodating of Live and Let Live Farm, rather than vindictive, and characterized the license denial as a measure of last resort taken only after all other options were exhausted.

“What are we supposed to do?” Jasper asked. “I can’t make somebody understand something that’s right there and been spelled out forever.”

A shift in enforcement

When Jasper was appointed commissioner of the Department of Agriculture in 2017, he took over a department that he described as understaffed and over-extended. The department’s division of animal industry, which among other responsibilities oversees the state’s 140 pet vendors, had no assistant state veterinarian and only three veterinary technicians. Over the succeeding eight years, the division has nearly doubled in size to eight employees.

The increased manpower has made it possible for the department to step up enforcement, ramping up the number of inspections conducted, Jasper said. Early in his tenure as commissioner, the department relied heavily on warnings, but they didn’t meaningfully increase compliance, so they shifted to issuing fines.

Last year, the department took in approximately $125,000 in fines, the bulk of which came from its weights and measures and pesticides divisions. A portion of that money pays the salary of a department hearing officer, who rules on appeals of fines and license denials.

“Over the last five years, we have picked up on what we’re doing,” Jasper said. “We’re holding people more accountable. We’re following the law, but everybody has ample warning.”

The department’s increased enforcement, which has also extended to the animal industry division, has coincided with a shift in Live and Let Live’s operations. Founded in 1997 on a sprawling 67-acre crop of land, the farm was primarily a horse rescue for its first two decades. Around 2014, after a new building was erected on the property, the rescue began to increase the number of dogs and cats it took in, Paradis said.

Over the last decade, the organization has carved out a niche taking in animals from the south, particularly from Georgia and Texas. Federal law requires that any animal from out-of-state must come with a certificate of veterinary inspection, or CVI, completed by a veterinarian in the animal’s state of origin.

“My job is to make sure that those animals that come in are healthy and that’s why the CVIs are so important,” Jasper said. “There are animals coming into this state on a regular basis that have diseases.”

A review of 12 inspection reports and a series of department letters from 2009 to May 2024 shared by Jasper with the permission of Paradis showed that the department first expressed concerns about the state of the pet rescue operation in 2018, a year before Paradis said the interaction that caused the retaliation occurred.

In a letter dated August 21, 2018, Assistant State Veterinarian Steve Harvey wrote that “a number of animal health concerns were observed” during an inspection earlier that month. Three cats receiving treatment for an illness were “not being properly quarantined,” and some animals did not have their vaccination history listed on their New Hampshire health certificate.

The letter ordered Paradis to schedule a meeting with Harvey to “continue discussing the issues we discussed during our visit . . . namely, dog and cat numbers and available space, quarantine, treatment records, and the use of foster homes.”

Nine months later, in June 2019, inspector Alicia Rosa – employee who allegedly demanded Paradis take in the horses months later – the raised issues with Live and Let Live’s certificates of veterinary inspection for the first time.

In a handwritten note on the back of an inspection report dated June 28, 2019, Rosa wrote that she “couldn’t locate CVIs” for two animals and that the 30-day certificates for litters of dogs and cats had expired two days before the animals had arrived at Live and Let Live.

Rosa left the department in the spring of 2024 and has declined to comment.

The June 2019 inspection was followed by another one three months later. A day after that inspection, and at around the same time Paradis said she was told to take in the horses, the department issued its first fine – for $1,000.

In a letter communicating the fine, Harvey wrote that the CVIs for 11 animals had expired two days before they arrived at Live and Let Live and that certain records “were incomplete or did not exist.”

In a note paying the fine a month later, Paradis responded that “much of what took place in this situation was wrong, with the law having a lot of gray area’s.”

In subsequent inspections, the violations continued. “CVI isn’t dated + doesn’t include viral vax info,” Rosa wrote in June 2020. “One CVI missing the date,” she wrote in April 2021. Records must say “see attached” when there are multiple pages, she wrote in June and December 2022. They must include the veterinarian’s accreditation number, she wrote in April 2023.

Along the way, the fines continued to rack up. Live and Let Live paid a total of at least $5,400 from 2019 to 2023, according to the documents provided, which were only a selection of the department’s file on the organization.

At times, Rosa wrote the organization up for other violations besides issues with the CVIs, including that the “facility must be lighted enough to allow for inspection” and that the facility’s license must be appropriately displayed on its building

But the records were clearly the department’s focus.

“There were other things, but this was the biggest issue,” Jasper said. “This was the one that really couldn’t be ignored anymore.”

Paradis has responded that the issues with the CVIs were nitpicky and ever-changing. CVIs with illegible veterinarian signatures or with the county box left blank have been found to be incomplete, she said.

Jasper “has been imposing obligations on her that have not been adopted as a matter of law by administrative rule,” said Lehmann, Paradis’s lawyer. “He can’t just make up these requirements that people have to comply with because that’s what you feel like doing as a government official.”

The final straw

Last July, Jasper wrote Paradis a “letter of understanding” which set out four conditions under which the department would issue Live and Let Live a license for the coming year. The farm would have to pay a fine of $2,400, agree to a reduced limit on the number of cats and dogs it takes in, resolve its “paperwork issues”, and send all CVIs to the department prior to animals’ trips to the state.

“The department has afforded LLLF significant latitude to continue to operate with a license while attempting to maintain the facility and records in compliance with minimum required standards,” Jasper wrote to Paradis in the letter of understanding. “While LLLF has incorporated some improvements required to meet New Hampshire pet vending regulations over the past several years, there has been a pattern of unsatisfactory inspections and re-inspections.”

Jasper considered the agreement to be an olive branch and a final warning. Paradis considered it coercion.

“They put me in a corner because we had animals here and a whole bunch in the south,” Paradis said. “That’s the only way they would let us keep functioning.”

The agreement was in place for only four months before another dispute broke out. Paradis’s partners in the south were sending the CVIs directly to the department. Jasper ordered them to go through Live and Let Live first.

“You simply don’t feel that you should have to comply with the letter of the law or regulations. Doing ‘good work’ does not give anyone a free pass,” Jasper wrote to Paradis in an email last November regarding the dispute.

He then issued a final warning: “CVIs that are not correct can lead to fines and ultimately license revocation, which is something none of us want to see happen.”

Live and Let Live’s final inspection came this May. Rosa had left the department by this point, and so it was conducted by Harvey, the assistant state veterinarian.

In a handwritten report flooded with information, Harvey found that “most CVIs” were “incomplete, inaccurate, not viewable” or “missing information”.

A month later, Harvey wrote to Paradis that he was denying her pet vendor application, which meant she could not take in or adopt out any dogs, cats, or other small animals. The denial letter was scant on details, saying only that Paradis had failed to comply with minimum standards in the categories of lighting, visible signs of insects, shelter from sunlight, sanitation, classification and separation, protection from disease, and origin and medical history.

Out of the approximately 140 pet vendors that applied for licenses for the coming year, five of them, including Live and Let Live, were denied, according to Jasper.

Paradis has pointed out that the most recent inspection report found she was actually in compliance for two of the categories – lighting and visible signs of insects – for which the inspection denial letter claimed she was out of compliance. She also said the department has not clarified what she must do to get back into compliance, an assertion that Jasper dismissed.

“The information is all there for them,” Jasper said, speaking generally. “If somebody is telling you they don’t know why [they failed an inspection], I’m going to suggest to you they’re not being honest with you.”

What happens now is not clear. Jasper said he has reached out to Paradis through her lawyer, Rick Lehmann, to encourage her to reapply for her license. Lehmann in turn has requested an adjudicatory hearing and has indicated he plans to file a request for an injunction in Merrimack County Superior Court to get her pet vendor license reinstated.

“We want her to be licensed,” Jasper said.

It’s a sentiment Paradis doesn’t buy.

“If he wants us to have our license – if he really means that – he could simply make it happen, and he’s not,” she said.

Jeremy Margolis can be  contacted at jmargolis@cmonitor.com.