Memorando Sentencia Antonio Casillas Montero

Case 3:22-cr-00437-SCC Document 94 Filed 08/10/23 Page 1 of 124
UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO
UNITED STATES OF AMERICA
v. Criminal No. 22-437-SCC
ANTONIO CASILLAS-MONTERO,
Defendant.
GOVERNMENT’S SENTENCING MEMORANDUM AND MOTION FOR UPWARD

DEPARTURE PURSUANT TO U.S.S.G. §2E3.1 AND FOR UPWARD VARIANCE
PURSUANT TO FACTORS IN 18 U.S.C. § 3553(a)
The United States of America, through the undersigned attorneys, respectfully moves this
honorable Court for a sentence of ten years of imprisonment for Antonio Casillas-Montero. This
upward departure and variance are justified because this case involves animal fighting on an
exceptional scale and Casillas exhibited extraordinary cruelty. This included the following:
(1) decades of illegal dog fights practiced by Casillas, (2) during that time, a high
number/frequency of illegal dogfights practiced by Casillas, (3) the national and international
scope of Casillas’s dog fighting, (4) the greater need for general deterrence in light of an
environment conducive to dogfighting in Puerto Rico, (5) Casillas’ promotion of dog fights,
(6) Casillas’ reputation as a “Caribbean legend” of dog fights, (7) Casillas’s teaching of
dogfighting training techniques to others, (8) Casillas’ sale of dogs that were used by others in dog
fights, and (9) Casillas’s inhumane tactic of never picking up a dog from a fight” (i.e., letting the
dog die from the fight). Casillas’s conduct is on the extreme end of the spectrum of cruelty in an
already cruel form of abuse. 1
1
This memorandum incorporates by reference the Government’s filings at docket numbers 3-1,
e15, 19, and 50. It also includes a glossary of dog-fighting terms at the end.
1
These factors set Defendant apart from other dogfighting cases and weigh in favor of a
significant sentence. 2
I. LEGAL FRAMEWORK
The Animal Welfare Act makes it unlawful to “knowingly sponsor or exhibit an animal in
an animal fighting venture” – i.e., the animal fights themselves. 7 U.S.C. § 2156(a)(1). Congress
also criminalized the many predicate activities without which animal fighting would not occur. In
particular, it is also unlawful to “knowingly sell, buy, possess, train, transport, deliver, or receive
any animal for purposes of having the animal participate in an animal fighting venture.” 7 U.S.C.
§ 2156(b). Each of these violations is punishable by the same maximum penalty – five years in
prison. 18 U.S.C. § 49.
Congress first enacted the federal animal fighting prohibition in 1976. See Pub. L. No.
94-279, § 17, Apr. 22, 1976, 90 Stat. 421. It was prosecuted for the first time twenty-two years
later, and not again until the prosecution of Michael Vick in 2007. The Vick case exposed the
public for the first time to the “horrors of dog fighting,” United States v. Berry, 09-CR-30101-
MJR, 2010 WL 1882057, at *10, including the acute animal suffering that occurs before, during,
and after dog fights. In particular, the defendants in that case admitted as part of their guilty pleas
to having drowned, hung, and bludgeoned underperforming fighting dogs to death.
2
The Government respectfully moves for permission to exceed the page limit under the Local
Rules. This memorandum incorporates, for the Court’s ease of reference, numerous screenshots
and other offers of proof that might otherwise have been included as exhibits. In addition, this
case involved a lengthy investigation that encompasses extensive and long-term criminal activity
spanning decades that is difficult to summarize in a brief number of pages.
The Government also respectfully requests 5 business days to submit certified translations of
certain Spanish-language items attached as exhibits. The Spanish-language texts quoted within
this memorandum have already been translated into English by a certified translator, whose
certificate is included at the end of this memorandum.
2
Congress has strengthened the law five times over the last fourteen years, including: the
Animal Fighting Prohibition Enforcement Act of 2007, Pub. Law 110–22, 121 Stat. 88, which
increased animal fighting from a misdemeanor with a one-year statutory maximum to a felony
with a three-year statutory maximum; the 2008 Farm Bill, Pub. Law 110–234, Sec. 12407, 122
Stat. 923, which raised the statutory maximum to five years, relaxed the interstate commerce
element, and added substantive prohibitions; the 2014 Farm Bill, Pub. Law 113-79, Sec. 12308,
128 Stat. 649, which made attending animal fights a misdemeanor offense and added a felony
offense for bringing anyone 16 years or younger to an animal fight; and an amendment effective
December 20, 2019, which broadened the reach of the statute to all U.S. territories. See Pub. Law
115-334, Sec. 12616(a)-(c), 132 Stat. 5015.
Federal and local authorities (at least, local authorities outside of Puerto Rico) have
increased prosecutions in the subject matter area. But even so, only a few dozen defendants have
been prosecuted in federal dog fighting cases since the first federal prosecution in 1998. From this
relatively small body of cases, a clear pattern has emerged from the sentencing case law: a notable
trend toward above-Guidelines sentences, based largely on the cruelty of the offense. The U.S.
Sentencing Commission also increased the base offense level of the pertinent Guideline, U.S.S.G.
§2E3.1, from 10 to 16, in November, 2016. The Commission stated that the increased base offense
level “better accounts for the cruelty and violence that is characteristic of these crimes.” Sentencing
Guidelines for United States Courts, 81 Fed. Reg. 27,262, 27,265 (May 5, 2016).
When it increased the base offense level in 2016, the Commission found that “offenders
who received the base offense level of 10 under § 2E3.1” had been sentenced to above- Guidelines
sentences at a rate more than fifteen times higher than the average across all offenses. Id. (available
at https://www.ussc.gov/guidelines/amendment/800) Further, “[f]or those animal fighting
3
offenders sentenced above the range, the average extent of the upward departure was more than
twice the length of imprisonment at the high end of the guideline range.” Id.; see also id. (finding
“a high percentage of above range sentences in these cases”).
In cases involving regionally or nationally significant dog fighters, courts have often
sentenced the primary defendants to terms of imprisonment at the statutory maximum penalty of
60 months (as well as above in cases involving multiple counts of conviction), based largely on
the nature and circumstances of the offense (dog fighting). See, e.g., United States v. Anderson,
3:13-cr-100 (Dkt. No. 723) (M.D. Ala., Nov. 17, 2014) (sentencing lead defendant to 96 months
on two dog fighting counts, departing and varying up from 12-18 month Guidelines range); United
States v. Allen, 3:13-cr-100 (M.D. Ala.) (Dkt. No. 581) (same case, sentencing second most
culpable co-defendant to statutory maximum penalty of 60 months on one dog fighting count);
United States v. Hargrove, 701 F.3d 156, 159-160 (4th Cir. 2012) (affirming 60-month sentence
imposed on single dog fighting count for 78-year old defendant who had been a prolific dog fighter,
where Guidelines range was zero to six months); 3 United States v. Richardson, 7:16-cr-122, 2017
WL 6055773, *2-3 (E.D.N.C. Dec. 1, 2017) (varying upward from 12-18 months Guidelines range
to 96-month sentence on two dog fighting counts), aff’d, 796 Fed. App’x 795, 803 (4th Cir. Dec.
12, 2019); United States v. Chadwick, 7:16-cr-122, 2017 WL 6055384, *2-3 (E.D.N.C. Dec. 1,
3
In sentencing Hargrove to the statutory maximum of 60 months on the single count of
conviction, the court made clear that it would have imposed an even greater sentence if
it could have:
It seems to me that the salient or critical event given the incredibly barbaric nature of this
case, the critical event was being able to manage a plea to one five year case. That drove
the whole outcome of this case, because if he had been charged independently and . . . if
he had been indicted for other charges, he would be facing significantly more time.
See Hargrove, Tr. of Sentencing H’g, 7:10-cr-135, Dkt. No. 42 at 45–46 (E.D.N.C. Aug 4,
2011).
4
2017) (same case, upward variance from 12-28 month Guidelines range to 60-month sentence on
single dog fighting charge; affirmed in same appeal).
In yet other dog fighting cases, courts have sentenced defendants to terms of imprisonment
that are less than the statutory maximum penalty, but that well exceed, or even multiply, the high
end of the applicable Guidelines range, generally based on the nature and circumstances of the
offense (dog fighting). See, e.g., United States v. McCoy, 4:17-cr-40009 (C.D. Ill. Sep. 26, 2017)
(sentencing defendant to double the high end of Guidelines range on dog fighting charge, 24
months); United States v. Lee, 3:11-cr-30092 (S.D. Ill. Nov. 17, 2011) (sentencing defendant to
double the high end of Guidelines range on dog fighting charge, 12 months); United States v.
Jacobs, 7:12-cr-84 (E.D.N.C. Mar. 6, 2013) (varying upward in dog fighting case to 29 months
where Guidelines range was 8-14 months); Courtland, supra, 642 F.3d at 553 (affirming upward
variance in dog fighting case that more than tripled the Guidelines range sentence); United States
v. Love, 3:17-cr-51 (D.N.J. July 8, 2019) (varying upward from 18-24 month Guidelines range
sentence and sentencing dog fighting defendant to 54 months for trafficking in and possessing
fighting dogs); United States v. Arellano, 3:17-cr-51 (D.N.J. Apr. 10, 2019) (varying upward from
Guideline range of 15-18 months to 48 month sentence for regionally significant dog fighter); 4
United States v. Cuellar, 3:17-cr-312 (D.N.J. Mar. 12, 2018) (sentencing cooperating, de minimis
defendant in dog fighting case to twice the high end of his Guidelines range, varying upward due
to nature of the offense).
After the Sentencing Commission increased the base offense level in 2016, defendants in
dog fighting cases have still received sentences well above the Guidelines range, which were
sustained on appeal. See, e.g., Richardson, supra, 2017 WL 6055773, *2-3 (varying upward from
4
The Arellano case was premised exclusively on the trafficking of fighting dogs; there were no
charges for sponsoring or exhibiting an animal in a dog fight.
5
12-18 month Guidelines range to 96 months), aff’d, 796 Fed. App’x at 803; Chadwick, supra, 2017
WL 6055384, *2-3 (same case, upward variance from 12-28 month Guidelines range to 60-month
sentence; affirmed in same appeal); United States v. Cook, 7:16-cr-122, 2017 WL 6055385, *2
(E.D.N.C. Dec. 1, 2017) (varying upward from 15-21 month Guidelines range to 45-month
sentence; affirmed in same appeal); United States v. Thompson,7:16-cr-122 (E.D.N.C. Dec. 22,
2017) (varying upward from 24-30 month Guidelines range to 48 month sentence; affirmed in
same appeal). Although not all federal defendants in dog fighting cases have received above-
Guidelines sentences, there has been a clear trend among judges in these cases to impose
significant sentences. 5
II. AN UPWWARD VARIANCE OR DEPARTURE TO 10 YEARS OF
IMPRISONMENT IS WARRANTED IN THIS UNUSUAL CASE.
A. General Background Regarding Dogfighting
“The lives of fighting dogs are not to be envied. These dogs do not lead normal
lives, but rather every aspect of the dog’s life is carefully calculated to antagonize
and thereby increase the aggression level of the dog. Many fighting dogs spend
their entire lives without basic nutrition, shelter and healthy socialization with
humans and other animals. Rather, fighting dogs spend the majority of their lives
in filthy conditions, pinned in small cages or chained up with heavy chains across
their neck….The duration of a dog fight on average is roughly about an hour, but it
is not uncommon for fights to last longer….If a dog is successful at a fight, the
handlers can receive substantial prizes and monetary rewards….The losing dogs,
however, do not fare as well. Almost always, the losing dogs are killed or
abandoned by their handlers following the match”.
United States v. Berry, 09-CR-30101-MJR, 2010 WL 1882057, at *4 (S.D. Ill. May 11, 2010),
aff'd sub nom. United States v. Courtland, 642 F.3d 545 (7th Cir. 2011). The Berry opinion,
appended as Attachment A, details the history and practices of dog fighting.
5
Page 22 of the PSR contains a chart of sentences imposed relative to the Guideline range for
defendants. This includes any defendant sentenced under Section 2E3.1 of the Guidelines, which
includes general “gambling offenses,” and is therefore not specific to animal-fighting offenses.
6
Among other things, the Court in Berry explained how pit bulls have suffered prejudice
because of dog fighters. Pit bulls “will withstand considerable abuse and neglect at the hands of
their owners and will remain loyal and non-aggressive towards humans” making them
“particularly appealing to dog fighters.” Id. at *4.
B. Favorable Environment for Dogfighting in Puerto Rico
Under 18 U.S.C. § 3553(a)(2), the Court’s sentence should “afford adequate deterrence to
criminal conduct.” At sentencing, “the need for general deterrence is a permissible factor to
consider.” United States v. Pagan-Walker, 877 F.3d 415, 417 (1st Cir. 2017). See also United
States v. Courtney, 76 F. Supp. 3d 1267, 1300–04 (D.N.M. 2014) (“The Court distinguishes
general deterrence—the effect that a sentence has on deterring people other than the defendant
from committing the crime—from specific deterrence—the effect that the sentence has on
deterring the defendant from recidivating. The weight of the research indicates that incarceration—
imposing it at all or increasing the amount imposed—either has no significant correlation to
recidivism or increases the defendant's likelihood to recidivate…. [G]eneral deterrence remains an
important consideration in cases like this one, in which the perpetrators are relatively sophisticated
and the certainty of detection relatively low—and the celerity even lower…. Those in the
community who know [defendant] might be less apt to commit [the crime] themselves when they
see [defendant] sentenced to prison rather than probation.”). Consequently, certain characteristics
of dog fighting in Puerto Rico are relevant considerations to Mr. Casillas’s sentencing, when
considered in combination with the particularities of his case.
a. Dogfighting as an open secret in Puerto Rico
“APBT La Raza de Acero y Terciopelo” (“APBT Dogs of Velvet and Steel”) was a
Facebook page (and related Instagram account with email rodzfredies56@gmail.com) run from
7
Puerto Rico that operated for years prior to Mr. Casillas-Montero’s arrest. It openly publicized
dog fighting on the island, where dog fighting is not commonly targeted by law enforcement.
The Facebook name “Dogs of Velvet and Steel” was a reference to a well-known
dogfighting book by the same name authored by Robert J. Stevens, as well as to a business by the
same name owned by Robert J. Stevens “through which he sold videos of pit bulls engaging in
dogfights and attacking other animals,” including “a ‘gruesome’ scene of a pit bull attacking a
domestic farm pig.” United States v. Stevens, 559 U.S. 460, 466 (2010) (overturning, under First
Amendment, conviction for portrayal of animal cruelty). A screenshot of the Facebook page for
the Puerto Rican site “APBT La Raza de Acero y Terciopelo” is below, with the banner “American
Pit Bull Terrier.”
8
According to the Facebook page, it had around 5,000 followers:
A screenshot of the Instagram account is below:
9
The Facebook and Instagram accounts focused on dogfights in Puerto Rico or involving
Puerto Rican dogfighting kennels. Some examples are below, all of which were publicly available
online:
(Ex. 1 at p. 4) 6
The title reads: “Work for Face to Face Kennel. Thank you for the support,” with Puerto
Rican flags in the background.
6
Most of the exhibits have been filed electronically with this motion, with dividers (“Exhibit
____”) separating one exhibit from the next. But exhibits 4, 12, 16, 17, 23, 25, 29 and 30 contain
video and audio files that could not be submitted via PACER. These eight exhibits have been
filed on a DVD with the clerk’s office and copies of these files were provided to defense counsel.
The video files are best opened using VLC Media Player.
10
(Ex. 1 at p. 5) The comment reads “Trane Stop’s Puerto Rico (1xw)”. As explained in the glossary
at the end of this memorandum, “1xw” refers to a dog that has won one, pre-arranged fight. A
review of the publicly available website for dog-fighting pedigrees, “apbt.online-pedigrees.com,”
indicates that “Trane Stop” is an owner of fighting dogs that have bred with the dogs of Stone City
Kennels:
11
(https://www.apbt.online-
pedigrees.com/modules.php?name=Public&file=printPedigree&dog_id=250067)
Additional screenshots from the Puerto Rican Facebook page “APBT La Raza de Acero y
Terciopelo” are below, all of which demonstrate how public the promotion of dogfighting has been
in Puerto Rico. Although Casillas was not involved in this Facebook page, many of the posts on
APBT La Raza de Acero y Terciopelo have related to Casillas’ famous Stone City Kennels.
12
(Ex. 1 at p. 6) The comment reads “THE LAST WARRIOR KNL [KENNEL] EL GORDO. Those
from the west” with a Puerto Rican flag.
13
(Ex. 1 at p. 6) The post reads: “Face to Face Gr Ch ‘Titere’ 8xW ROM 3xDOY -Puerto Rico-
Awarded/certified by Sporting Dog Journal: Dog of the Decade 2016. Sporting Dog Journal: Dog
of the year 2013. Scratchback Magazine and Pitbull Bible: Dog of the Year 2014. Dogmen’s
Magazine: Dog of the Year 2015. Inducted into the Hall of Fame for Sporting Dog Journal. RIP.”
14
15
(Ex. 1 at pp. 1, 2) As indicated in the glossary at the end of this memorandum, “POR” refers to a
dog included on a list created by an underground dog-fighting magazine called “Your Friend and
Mine.” The list records the number of wins for offspring of a sire and dam and assigns a point
system to the number of wins.
(Ex. 1 at p. 8) The comment reads: “P.R. [Puerto Rican flag] Fugitive’s Gr Ch Destroyer 5XW
BIS.GIS.DOY.ROM. An excellent grand champion in the hands of the best dogs in Puerto Rico,
the perfect combination.” As indicated in the glossary below, “5XW” refers to a dog who has
won five fights. “Gr Ch” refers to a grand champion of dog fights. “BIS” refers to “best in
16
show;” “ROM” refers to a “register of merit,” which is a dog that has bred a certain number of
champions.
(Ex. 1 at p. 9) (comparing a pit bull-like dog to renowned Puerto Rican athletes Roberto Clement
and Felix “Tito” Trinidad).
17
(Ex. 1 at p. 10) The title reads “Gr Ch Siega. Photo taken in Puerto Rico,” with a Puerto Rican
flag. As indicated in the glossary to this memorandum, “Gr Ch” refers to a “grand champion,”
which is a dog who has won five pre-arranged dog-fighting matches without a loss.
18
The Puerto Rico Facebook page also openly publicized scarred “grand champion” dogs:
19
(Ex. 1 at p. 12) The caption indicates that this dog had won seven fights (“7xw”). The obvious
and numerous injuries to this dog are consistent with dog fights. See N. Intarapanich et al,
Characterization and comparison of injuries caused by spontaneous versus organized dogfighting,
JOURNAL OF THE AMERICAN VETERINARY MEDICAL ASSOCIATION (Vol. 251 No. 12) (Dec. 15,
2017) (attached as Exhibit 2) (“[D]ogs that were used in organized fighting most commonly had
injuries to the thoracic limbs (60/62 [96.8%]), the dorsal and lateral aspects of the head (58
[93.5%]) and muzzle or oral mucosa (55 [88.7%]), the dorsal and lateral aspects of the neck (45
[72.6%]), and the ventral neck and thoracic region (36 [58.1%]).”) Similar injuries can be seen
below:
(Ex. 1 at p. 13) The title indicates that this dog had won six fights.
20
(Ex. 1 at p. 3)
Dog fighting in Puerto Rico is connected to other islands in the Caribbean. As further
explained below, the Dominican Republic is a popular location for dog fights. Moreover, “Game
Dog Caribbean” (available at
https://www.youtube.com/channel/UCs0GhTNCr6xOhbUuNd3aHZQ ) is a YouTube channel—
whose owner runs it from Anguilla and St. Kitts and Nevis—that regularly publicizes dog fights
throughout the Caribbean, including fights by Stone City Kennel. (Ex. 4)
21
b. Certain veterinarian support for dogfighting in Puerto Rico
Given Puerto Rico’s geography as an island, there are limited ways for fighting dogs to
enter or leave. Health certificates from veterinarians are generally required. See, e.g., State
Regulations of Puerto Rico (https://www.aphis.usda.gov/animal_health/downloads/import/state-
regulations-for-puerto-rico.pdf) (discussing the requirement, if transporting dogs, for “[a]n official
certificate veterinary inspection signed by an accredited veterinarian in the state or territory of
origin”). This is also true if dog fighters, such as Casillas, transport their fighting dogs from/to
Puerto Rico to/from the Dominican Republic. See Pet travel from the U.S. to the Dominican
Republic, U.S. Department of Agriculture, Animal and Plant Health Inspection Service
(https://www.aphis.usda.gov/aphis/pet-travel/by-country/pettravel-dominican-republic)
(requiring Veterinary Health Certificate signed by “Accredited Veterinarian”).
The import and export of fighting dogs to and from Puerto Rico therefore requires the
participation (whether knowing or unknowing) of certain veterinarians in Puerto Rico.
Veterinarians are also a source of prescription drugs for training dogs and for treating their wounds
after fights.
Casillas’ Facebook account included the following messages with “Edwin Serrano”.
“Edwin Vet” appeared in Casillas’s contacts. Public record searches indicated that a veterinarian
with that number works at Humacao Animal Hospital/Shelter. 7 The following messages were
found in Casillas’ Facebook account:
7
A federal search warrant executed on the Humacao Animal Hospital revealed numerous records
for dogs associated with Casillas.
22
The individual was training dogs “to tear each

other to pieces”
First federal dogfighting conviction in Puerto
Rico
Damn and they never caught him fighting
That’s right
Get out of that shit!!! You don’t need that mess!!!
We don’t do that anymore
They caught in his house dogs and training equipment
It was a video in where he used one dog to motivate

the other and there they went with that
It’s not illegal to train it but it is to confront it
Ok
(Ex. 3) 8
Serrano then sent the following message to Casillas the next week:
23
(Ex. 3)
24
Casillas also used another veterinarian in Puerto Rico who was identified in his accounts
as “Alverio vet.” On certificates required by the U.S. Department of Agriculture for transporting
the dogs, the veterinarians would not identify the dogs’ breed as pit bulls. Below is one
screenshot of a USDA form for accredited veterinarians
(https://www.aphis.usda.gov/library/forms/pdf/APHIS7001.pdf) from Mr. Casillas’ accounts
with one of his dogs identified as a “Labrador mixed”:
(Ex. 5 at p. 21)
25
WhatsApp messages with “Alverio vet” from Mr. Casillas’ phone include the following:
26
27
28
29
(Ex. 5 at pp. 5-10) 9
The following is a conversation with the same “Alverio Vet”:
9
A federal search warrant executed on this veterinarian’s clinic, Servicios Veterinarios de San
Lorenzo, in San Lorenzo, Puerto Rico revealed records for dogs associated with Casillas.
30
31
32
(Ex. 5 at pp. 15-17)
A willingness on the part of certain veterinarians in Puerto Rico to aid Casillas facilitated
his years of dog fighting. For example, in 2018, Casillas was discussing the training regime for
his fighting dogs. He explained:
33
(Ex. 6 at p. 4)
In 2021, Casillas was discussing injuries to dogs with someone via Facebook messenger in
the following exchange:
34
(Ex. 6 at p. 3)
In July 2020, Casillas was negotiating the sale of a dog to a potential buyer in California
via Facebook messenger. Casillas explained that shipping costs were “[l]ike 2 hundred ticket plus
vet and Kennels.” (Ex. 6 at p. 1)
In March 2021, there was the following exchange:
35
***
36
(Ex. 6 at p. 1)
In short, the complicity or blind eye turned by certain veterinarians in Puerto Rico to
dogfighting creates an environment in which significant general deterrence is required for this kind
of criminal activity in Puerto Rico.
c. Casillas’s Reputation Among Dog Fighters
Given Mr. Casillas’ fame in the dogfighting community—based on his years-long streak
of criminal conduct—a sentence in this case has a greater-than-normal potential for general
deterrence. Numerous messages indicate that Casillas (as the result of his long-term, specific
criminal actions) was a well-known and respected dogfighter, indicating that his sentence has the
potential for general deterrence. For example, below is a Facebook message from a man in Puerto
Rico:
37
38
39
40
41
42
43
(Ex. 7)
44
The following photo, which was recovered from an account associated with Antonio
Casillas pursuant to a federal search warrant, shows Antonio Casillas (in a blue shirt) with an
admirer:
Below is an enlarged image of the stick:
45
The signed object in the hands of the fan in the black shirt reads “SCK,” an abbreviation used for
“Stone City Kennel.” It is signed “Tony.” The object resembles a “break stick.” During a dog
fight, a break stick is used at pre-determined intervals (like rounds in boxing) to break the bite of
the dogs, take them back to their corners, and then turn them loose to fight again. Break sticks
autographed by famous dog fighters are sought after by their fans.
46
Below is another Facebook message from 2022, describing Casillas as a “Caribbean
legend.”
(Ex. 8)
Because of the reputation of Casillas and his Stoney City Kennels, dogs bred from his
fighting dogs perpetuated dog fighting elsewhere. For example, in May 2002, “Akeem Carter”
from Charlotte Amalie, U.S. Virgin Islands sent Casillas the following images via Facebook:
47
48
(Ex. 9)
Carter then wrote:
49
(Ex. 9) A screenshot of the publicly available link (http://www.apbt.online-
pedigrees.com/modules.php?name=Public&file=printPedigree&dog_id=732090) is below,
which indicates the pedigree with Casillas’s Stone City Kennels (some of which are circled in
red).
50
51
52
(Ex. 9)
As indicated above, Casillas’s customers would obtain pedigrees for their fighting dogs,
indicating the prized connection with Stone City Kennel. Below is one example sent via Facebook
that indicates a dog’s ties to Stone City Kennel and other kennels:
53
(Ex. 10)
In addition, Casillas’s “Stone City Kennel” was famous enough to sell merchandise, as
depicted in the photos below from Casillas’s email and Facebook accounts:
54
55
56
57
(Ex. 11)
Mr. Casillas’s cellphone extraction 10 indicated that he was part of an international group
of dogfighters, who would share videos of dogfights, a screenshot of one of which is below:
(Ex. 12 (video beginning with file name c462f58a ))
The comments from the group in reaction to the video included the following:
10
As indicated in the Device Report for the iPhone from which these messages were extracted,
all of the accounts on the phone, from iTunes to Yahoo to Expedia to Facebook to Uber to
WhatsApp are associated with “Antonio Casillas,” “Tony Casillas,” and
“prsckmastert@yahoo.com.” (Ex. 33) As indicated in Exhibit 32, prsckmastert@yahoo.com is
registered to Antonio Casillas from Las Piedras, Puerto Rico. Moreover, as indicated in the
WhatsApp messages excerpted in this memorandum, the “owner” is listed in the messages as
“Antonio Casillas.”
58
(Ex. 12)
The group also shared videos of other kennels for fighting dogs, such as this one identified
as being in China:
59
(Ex. 12 at video with file name beginning 42385e4b )
Also, one member of the group named “Alpha” shared with Casillas and the group a video
from Miami in 1993 of one of Casillas’ own dogfights (involving dogs names “Black Face” and
“Nico”) (with Casillas’ responses in green). This indicates the legendary status of Casillas in the
dogfighting community—decades after one of his fights, videos of his him and his dogs (in this
case, “Nico”) were still circulating. Alpha’s messages are in blue, while Casillas’ responses are
60
in green:
61
(Ex. 12)
A screenshot of the video is below:
62
(Ex. 12 (video beginning with file name 3880595c ))
After the video is sent, Casillas responds:
63
(Ex. 12) As noted in the glossary at the end of this memorandum, “ch” refers to a “champion,” that
is: a dog who has won three, pre-arranged dog fighting matches.
Given Mr. Casillas’ experience and reputation, he often provided advice to up-and-coming
dogfighters, as demonstrated in the examples below:
64
Facebook message no. 1:
65
(Ex. 13)
66
Facebook Message No. 2
67
***
(Ex. 14)
68
An upward departure and/or upward variant sentence is warranted in light of Mr. Casillas’
leadership in instructing others in dogfighting.
C. Background on Stone City Kennels: History and Characteristics of the Defendant
In a recorded phone call with federal agents in 2022, Casillas admitted to over 150 dog
fights throughout the world, including Mexico, Ecuador, Peru, New Jersey, New York, and the
Dominican Republic. According to his statement, he fought dogs throughout his adult life, for 30-
35 years. A transcript of an excerpt from that phone call is below (with the audios contained in
exhibits 16 and 17), with “Toñito” being Mr. Casillas and “SA Plaza” being the federal agent.
69
70
***
71
(Exs. 16 & 17)
Mr. Casillas wrote via Facebook messages that, in 2020, Stone City consisted of “me n my
partner in Florida.”
(Ex. 18 at p. 4)
In another conversation in 2021, Casillas states that there are a “[f]ew guy[s] in Sck…I’m
Tony my partner Jessie and Purulo”. (Ex. 18 at p.3) Casillas also stated that he partnered with his
brother on another dog with a fighting pedigree. (Ex. 18 at pp. 1-2)
72
In the PSR, Mr. Casillas acknowledged that “[b]efore 2017, he spent approximately 5 to
6 hours caring for dogs. He explained that he mostly trained them in April or October and at some
points he had approximately 40 dogs.” (Dkt. No. 88 at p. 13 ¶ 64)
D. Dog Fights
a. Casillas Publicized Dogfights and Casillas Spread Dog Fighting Nationally and
Internationally
In addition to fighting dogs and instructing others in how to fight dogs, Casillas promoted
dog fights, as indicated in the example below from 2019:
Facebook Message #1:
73
(Ex. 19)
Facebook message #2:
(Ex. 20)
74
(Ex. 14)
Below is a photo of Mr. Casillas on the left with two other men that was recovered from
his accounts:
75
The man in the middle of the above photo ran a dog-fighting operation known as Cane
Valley Kennels and was sentenced in January 2022 to the statutory maximum of five years in
prison in the Middle District of Georgia for a multi-state dogfighting operation that included
Alabama, Florida and Georgia. See Cane Valley Kennels Dog-Fighting Trainer and Breeder
Sentenced to Five Years Imprisonment (available at https://www.justice.gov/usao-mdga/pr/cane-
valley-kennels-dog-fighting-trainer-and-breeder-sentenced-five-years-imprisonment) The man
on the right side of the photo is identified in Casillas’ account as “Amin” from “Bahrain.”
Below is another photo from Casillas’ account from a dogfighting trip to Mexico (with
Casillas in the white shirt):
Casillas fought dogs and supported dog fighting within and beyond Puerto Rico, as
indicated in the Facebook messages below:
76
[screenshot of video]
(Ex. 21)
77
78
79
(Ex. 22)
b. Example of Casillas’ method
Significant, specific deterrence is necessary in the case of Mr. Casillas because he has been
willing to defy the law and expend considerable resources to pursue dog fighting. Below is one
example:
In April 2021, Casillas contacted a veterinarian, Alverio, in Puerto Rico for travel
certificates for two dogs, as depicted below:
80
(Ex. 5 at p. 2)
Approximately one week later, Casillas messaged the same veterinarian, Alverio, the
following regarding a dog named “Enano”:
81
(Ex. 5 at pp.5-6)
Later that month (April 2021), Casillas exchanged the following messages with someone
identified on his phone as “BBK” with a phone number beginning in 809. “809” is the country
code for the Dominican Republic. See https://countrycode.org/dominicanrepublic.
In February of 2021, “BBK” had sent the following message to Casillas:
82
(Ex. 23 at p. 1)
A ferry runs daily between the Dominican Republic and Puerto Rico. See, e.g,.
https://www.rome2rio.com/map/Puerto-Rico/Santo-Domingo#r/Car-ferry/s/0. Ferry service in
much of 2020 between the islands had been suspended during the pandemic. See, e.g., “Ferries
del Caribe resumes operations between the Dominican Republic and Puerto Rico,” Dominican
Today (Nov. 9, 2020) (available at https://dominicantoday.com/dr/tourism/2020/11/09/ferries-del-
caribe-resumes-operations-between-the-dominican-republic-and-puerto-rico/)
In April 2021, the following conversation occurred between Casillas and BBK:
83
(Ex. 23 at p. 3) (As indicated in the glossary, fighting dogs can be “matched” by their weights,
such as 37.8 pounds)
***
84
(Ex. 23 at pp. 4-5)
85
(Ex. 23 at p. 6)
86
In July 2021, Casillas contacted the same veterinarian in Puerto Rico for another certificate
for a female dog. Below is an excerpt from a WhatsApp conversation extracted from Casillas’
phone:
87
88
(Ex. 5 at p. 18) July 15, 2021 fell on a Thursday. The following Monday would have been July
19. Casillas’s conversations with the Puerto Rican veterinarian then continued:
89
90
91
92
93
94
(Ex. 5 at pp. 19-23)
Then, on July 19, Casillas contacted “BBK” in the Dominican Republic again in the
following exchange to pick up the dog:
95
(Ex. 23 at pp. 38-39)
96
After arranging the papers to send the various dogs to the Dominican Republic, Casillas
exchanged the following messages on July 20, 2021:
(Ex. 24)
July 24, 2021 was a Saturday.
According to HSI/CBP records, Casillas took the following trips in July 2021 to Santo
Domingo:
Then, on July 25, 2021, Casillas had the following exchange on WhatsApp with “Sunny
Pit”, which was recovered from Casillas’ cellphone extraction:
97
(Ex. 26)
Also, on July 24 and 25, 2021, Casillas had the following instant message exchange with
his wife, which was recovered from his cellphone extraction:
98
99
(Ex. 27)
On July 27, 2021, Casillas sent a video (screenshots below) and messages via WhatsApp
to a contact named in the contact list as “German Pit Ecuador”:
100
101
(Ex. 25 with video beginning with file name 67a6b641 )
102
(Ex. 25 (PDF))
In addition, he and “German Pit Ecuador” exchanged messages of a video, a screenshot of
which is below, where people stand around and discuss the dog whom they call “Enano”:
103
104
(Ex. 25 with video beginning with file name b370c3fb ( ))
Mr. Casillas’s dog, Enano, can still be seen breathing in the video as the people around insult the
dying animal for losing.
In a subsequent audio message with “German Pit Ecuador” recovered from Mr. Casillas’s
cellphone, he explains that he leaves dogs in the fights until “the end,” “until they definitely will
not be able to leave.” (Ex. 25 at file beginning 2e7e7938 (
) at minute 1:15)
Enano’s trip therefore began with Casillas in Puerto Rico where Enano was bred and
trained; a Puerto Rican vet and a trafficker then facilitated his passage to the Dominican Republic
on the ferry; “BBK” then prepared Enano in the Dominican Republic for the fight; and finally
Casillas travelled from Puerto Rico to the Dominican Republic to watch Enano fight until he died.
A significant upward variance or departure is necessary to deter such determination by Casillas to
fight dogs.
In his interview with Probation, Mr. Casillas “stated that the dogs that lost fights were given
away.” (Dkt. No. 88 ¶ 34) As this video demonstrates, that is false.
In United States v. Gaines, the court varied upward, finding that:
this offense embodies such cruelty, just the enterprise of training dogs to
fight, of staging dogs to fight, of keeping dogs in boxes in the basement, of
medicating them by people who are not trained in medicine, clearly not
professionals, all of the materials that were seized showed how these dogs
were treated by these amateurs with all kinds of medications that were for
cattle and for other kinds of animals, the very concept of this enterprise of
staging dogs to fight each other and kill each other is so despicable and so
uncivilized that I think the nature of the offense warrants a variance.
United States v. Gaines, 3:17-cr-309, Tr. of Sentencing H’g at 17 (D.N.J. Mar. 5, 2018), aff’d, 765
Fed. Appx 730, 733 (3d Cir. Apr. 3, 2019) (affirming above-Guidelines sentence and remarking
105
that the case was “a sad reminder that man’s best friend is susceptible to man’s worst impulses”);
see also id. at 19 (“I don’t know that there’s any way we can quantify really how harmful this
crime is”).
As indicated above, the facts of this case show why such strong condemnation is warranted.
c. Examples of other dog fights
The above (letting a dog die after a loss) was not atypical for Mr. Casillas’s criminal
conduct. For example, in March 2018, Mr. Casillas described:
106
***
(Ex. 28) (emphasis added)
Mr. Casillas was clear: “I don’t pick up.” In other words, he does not remove losing dogs
from a fight, prefering to let them die.
107
What Mr. Casillas did to his dogs before the fights was also cruel.
A video of one of Casillas’ dogs chained to a treadmill is attached as Exhibit 29, a
screenshot of which is below:
(Ex. 29)
Below is a 2020 conversation from Facebook in which Mr. Casillas was offering a two-
time dog-fighting champion to a potential customer for $4,500. The dog was “ready for box” (i.e.,
ready to fight).
108
109
(Ex. 34)
Mr. Casillas sent these additional photos to the same contact:
110
111
(Ex. 34)
Below are photos from Casillas’ property where federal agents rescued several dogs
wearing heavy collars chained to the ground nearby dirty water bowls and only a plastic,
overturned blue barrel to provide shelter from the sun and rain.
112
113
114
115
III. THE COURT SHOULD IMPOSE SPECIAL CONDITIONS OF SUPERVISED
RELEASE.
The Court should include special conditions of supervised release that prohibit Casillas
from possessing or owning any dogs, including through a third party (e.g., his wife or other family
members who reside with him). This is common in dog fighting cases. See, e.g., Andrews, supra,
Dkt. No. 358 (Judgment) at 6; Love, supra, Dkt. No. 295 (Judgment) at 3. The maximum period
of supervised release – three years – is warranted to help ensure Casillas does not return to his
lengthy pattern of cruelty.
116
IV. CONCLUSION
Over the last decade, there has been increased public awareness of the serious, violent
nature of animal fighting, as reflected by Congress’s repeated strengthening of the Animal Welfare
Act. Given the extensive networks that are needed to solicit opponents as well as to locate, buy
and sell dogs of particular coveted bloodlines, dog fighting is organized crime in the traditional
sense of that term. Defendant Casillas has been a full participant in national and international
dogfighting networks, and he has shown a decades-long lack of respect for the law as he built his
reputation as a “Caribbean legend” of dogfighting. He warrants a significant sentence in order to
promote respect for the law and the functions of this Court. The Government has not found a
comparable case of someone with as many dog fights for as many years as Mr. Casillas. The facts
of his case are far beyond the norm.
Furthermore, dog fighting is difficult for law enforcement and investigative professionals
to infiltrate. As this case demonstrates, it is often partially practiced abroad. A dog fighting
investigation requires many of the same skills and resources employed in major undercover
narcotics investigations, thus challenging the resources of any agency that seeks to respond to it.
While local Puerto Rican law criminalizes dog fights at 5 L.P.R.A. § 1671, a search on Westlaw
in the database of Puerto Rico caselaw failed to uncover a single judicial decision involving this
statute…ever. The undersigned is aware of none.
As the above pages indicate, Mr. Casillas used a broad network of transporters,
veterinarians, and other dog fighters to conduct his decades-long criminal streak. Yet, the
veterinarians who facilitated Mr. Casillas’ dogfighting conduct have suffered no repercussions;
while “Sunny Pit” with whom Mr. Casillas shared dogfighting experiences was stopped a couple
of months ago trying to send multiple pit bulls on the ferry from Puerto Rico to the Dominican
117
Republic.
Given the limited law enforcement resources available for cases such as this, and the strain
it places upon animal shelters called upon to care for the large numbers of dogs seized in these
investigations, it is imperative that the sentences imposed in the few cases that are able to be
brought send a strong message of deterrence. Those who choose to brutalize animals for
entertainment and profit must know that their criminal conduct will be severely punished. See
Gaines, supra, Tr. of Sentencing H’g at 18 (“animal cruelty is a horrible offense, uncivilized, and
warrants punishment and deterrence. It’s important for society to know that this is a serious
offense, that it’s a grievous offense, that the animals deserve something better than this”).
Consequently, a strong sentence is needed to “afford adequate deterrence to criminal conduct,”
both to Defendant and to other potential offenders. 18 U.S.C. § 3553(a)(2)(B).
In addition, Application Note 2 to U.S.S.G. §2E3.1 provides that an “upward departure
may be warranted if (A) the offense involved extraordinary cruelty to an animal beyond the
violence inherent in an animal fighting venture (such as by killing an animal in a way that prolongs
the suffering of the animal); or (B) the offense involved animal fighting on an exceptional scale
(such as an offense involving an unusually large number of animals).” Although animal fights
generally result in maiming or death to an animal, courts often look for evidence of cruelty beyond
than that which is intrinsic in the fighting pit before departing upward on this basis. See United
States v. Hackman, 630 F.3d 1080, 1084 (8th Cir. 2011). Examples of conduct that courts have
found to comprise “extraordinary cruelty” (and departed upwards on that basis) include inhumane
killing of dogs outside the fighting ring, see, e.g., id. (attempting to electrocute a losing dog in
front of spectators using jumper cables; dog suffered and convulsed for several minutes before
dying), and severe neglect of dogs culminating in untreated veterinary problems. See Anderson,
118
supra, 3:13-cr-100 (M.D. Ala., sentenced Nov. 7, 2014).
Mr. Casillas bragged that he never picked up a dog from a fight—and there are video and
written evidence of that submitted with this sentencing memorandum. Mr. Casillas brags in an
audio recording that he leaves dogs in the fights until “the end,” “until they definitely will not be
able to leave.” (Ex. 25 at file beginning 2e7e7938 at minute 1:15) Moreover, the extreme number
of dog fights and length of time indicate that Mr. Casillas was remorseless in his cruelty.
In addition, the PSR describes the poor conditions of the dogs found on Mr. Casillas’
property (Dkt. No. 88 at p.7), and a video of their recovery is included as Exhibit 30. The medical
report on the dogs notes “pustules,” “fungus,” “emaciated,” “intestinal parasites,” “high bacterial
infection,” “lameness,” and “jaw clamping,” (Ex. 31) And these were the lucky ones, in contrast
to the numerous dogs that fought and died in Casillas’ 150+ matches of animal cruelty.
Jeremy Bentham wrote with respect to animals: “[t]he question is not, ‘can they reason?’
nor, ‘can they talk?’ but ‘can they suffer?’” Via the Animal Welfare Act and with respect to
animals such as dogs, Congress has responded in the affirmative.
119
Mr. Casillas’ decades of criminal, cruel conduct warrant a significant upward departure
pursuant to U.S.S.G. § 2E2.1 or an upward variance pursuant to 18 U.S.C. § 3553(a).
Considering all of the 18 U.S.C. § 3553 factors, the relevant Guideline provisions, the case law
discussed above, and the applicable departure, ten years of imprisonment is warranted.
RESPECTFULLY SUBMITTED.
In San Juan, Puerto Rico, this 10th day of August 2023.

W. STEPHEN MULDROW
UNITED STATES ATTORNEY
s/ Jonathan Gottfried
Jonathan Gottfried, U.S.D.C.-PR G02510
Assistant United States Attorney
United States Attorney’s Office
Torre Chardon, Suite 1201
350 Carlos Chardon Ave.
San Juan, PR 00918
120
GLOSSARY OF DOG-FIGHTING TERMS
(1) Best in Show (B.I.S.): A title or award given to the fighting dog that was deemed the “best”
across a series of matches (e.g., provided the most entertainment to the spectators). May be
interchangeable with “Gamest in Show.”
(2) Breeding stand (a/k/a “rape rack” or “rape stand”): method for breeding in which the
female dog is trapped on a metal or wooden devices that elevates her off the ground and
immobilizes her neck and legs.
(3) Chain Weight: The dog’s “normal” weight when not being actively conditioned for a
dog fight (so called because the dog is often kept on a chain in a dog fighter’s “yard.”
(4) Champion (“CH” or “Ch”): A dog who has won three, pre-arranged dog fighting
matches
(5) Conditioned Weight: The weight that the dog fighter deems to be a dog’s optimal
fighting weight, following a conditioning program leading up to a dog fight. This is
usually the weight at which the dog fighter will agree to fight the dog. The “conditioned
weight” of a pit bull-type dog is generally between 35 and 50 pounds.
(6) Culling: The act of killing an undesirable dog. Culling is done to avoid including
undesirable traits in a dog fighter’s breeding program, and so that a dog fighter will not
have to expend resources, space, and time caring for such dogs.
(7) Cur: A dog that does not display the sought-after temperament, physical traits, or
fighting ability
(8) Dog of the Year (D.O.Y.): A title given by a dog-fighting journal to the best fighting dog
of the year
(9) Gameness: A desired trait in a dog in which he/she will continue to fight even though
mortally wounded. A dog that does not have “game” is considered a “cur” and will likely
be “culled” from the yard.
(10) Gamest in Show (G.I.S.): A title or trophy given to a fighting dog that demonstrated
the most “heart” or “gameness” during a set of matches
(11) Grand Champion (“GR CH” or “Gr. Ch.”): A dog who has won five pre-
arranged dog-fighting matches without a loss.
(12) Hooking a match: Setting up a dog fight in which parties agree upon the terms
(13) Keep: Conditioning period for dog fight that generally occurs eight weeks prior to
pre-arranged fight
(14) Leaving a dog down: the practice of a handler leaving a losing dog to die in the
pit, rather than “picking up” the dog
(15) Off the Chain (“OTC”): If a dog wins a fight without first having gone through
the traditional conditioning program, it is said that the dog has won “Off the Chain,”
which is notated as “OTC
(16) Pedigree: A record of a fighting dog’s lineage or bloodline. These can be
maintained in hard copy or electronic format.
(17) Pick up: When a dog fighter removes his dog from the pit and forfeits the match
(18) Pit: A walled-in square space, approximately 10-20 feet per side, in which a dog
fight takes place. The length and width of the pit can depend on the rules agreed to by
the parties or by the materials available to the participants.
(19) Producer of Record (“POR”): a list created by an underground dog-fighting
magazine called “Your Friend and Mine.” The list records the number of wins for
121
offspring of a sire and dam and assigns a point system to the number of wins. The points
are increased for offspring that become Champions or Grand Champions.
(20) Register of Merit (“ROM”): A listed created and maintained by the Sporting
Dog Journal, an underground dog fighting magazine. The list records the number of
Champion and Grand Champion offspring that the dog produces. A male dog must sire at
least four Champion dogs and a female dog must be the dam of at least three Champion
dogs to be accepted onto the list
(21) Roll: A fight that is staged between two dogs not for gambling purposes, but to
ascertain fighting temperament and ability. It is typically of shorter duration than a
contracted match but can still result in injury.
(22) Schooling: When an inexperienced dog is pitted against an experienced dog in a
short fight. The owner is hoping that the inexperienced dog will learn fighting methods
from the experienced dog. This is also done so that the owner can determine how a
particular dog fights (for example, whether the dog primarily attacks the head or the legs
of its opponent).
(23) Scratch: when the dogs are separated and taken back to their corners as in the
beginning, held for a moment, and released to see if one or both will cross the “scratch
line” or “scratch” to attack the other.
(24) Scratch line: The line in a pit (see above) behind which dogs are placed
(25) Yard: Dog fighters frequently refer to the property or properties on which they
maintain such animals as their “yard.” Dogs are often placed in close proximity to one
another on a yard, but just beyond reach. This is done so that each dog can see each other
but they are unable to socialize. Over time, this builds aggression between the dogs
towards each other. When they are later pitted against each other, they will fight.
(26) “xW”: The number of times that a dog has won a match is often referred to by the
notion “#xW”, where the number (“#”) indicates the number of dog-fighting wins. For
example, “3xW” indicates that the dog has won three fights.
122
TRANSLATION CERTIFICATE
I, Cristina D. López Acevedo, certified translator under Local Rule 5 (c)(2) and (3) of the U.S.
District Court, District of Puerto; with 6 years of experience translating for the U.S. Attorney’s
Office, District of Puerto; and with a Master’s Degree in Translations from the University of Puerto
Rico; CERTIFY that the English translation on the Government’s Sentencing Memorandum for
case 22‐437‐SCC is a true and accurate rendition of the original Spanish text to the best of my
abilities.
Given, today, August 10, 2023, in San Juan, Puerto Rico.
Cristina D. López‐Acevedo, M.A.

Translation Project Coordinator & Translator
United States Attorney’s Office | District of Puerto Rico
Email: cristina.lopez@usdoj.gov
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on August 10, 2023 I electronically filed the foregoing with
the Clerk of the Court using the CM/ECF system, which will send notification of such filing to
all counsel of record.
s/ Jonathan Gottfried
Jonathan Gottfried
Assistant United States Attorney
123

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Case 3:22-cr-00437-SCC Document 94 Filed 08/10/23 Page 1 of 124

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA

v. Criminal No. 22-437-SCC

GOVERNMENT’S SENTENCING MEMORANDUM AND MOTION FOR UPWARD

already cruel form of abuse. 1

prison. 18 U.S.C. § 49.

to having drowned, hung, and bludgeoned underperforming fighting dogs to death.

115-334, Sec. 12616(a)-(c), 132 Stat. 5015.

at https://www.ussc.gov/guidelines/amendment/800) Further, “[f]or those animal fighting

“a high percentage of above range sentences in these cases”).

single dog fighting charge; affirmed in same appeal).

to nature of the offense).

II. AN UPWWARD VARIANCE OR DEPARTURE TO 10 YEARS OF

IMPRISONMENT IS WARRANTED IN THIS UNUSUAL CASE.

A. General Background Regarding Dogfighting

appended as Attachment A, details the history and practices of dog fighting.

“particularly appealing to dog fighters.” Id. at *4.

B. Favorable Environment for Dogfighting in Puerto Rico

imposing it at all or increasing the amount imposed—either has no significant correlation to

recidivism or increases the defendant's likelihood to recidivate…. [G]eneral deterrence remains an

considered in combination with the particularities of his case.

a. Dogfighting as an open secret in Puerto Rico

Pit Bull Terrier.”

According to the Facebook page, it had around 5,000 followers:

A screenshot of the Instagram account is below:

Rican flags in the background.

review of the publicly available website for dog-fighting pedigrees, “apbt.online-pedigrees.com,”

from the west” with a Puerto Rican flag.

system to the number of wins.

Characterization and comparison of injuries caused by spontaneous versus organized dogfighting,

Dog Caribbean” (available at

https://www.youtube.com/channel/UCs0GhTNCr6xOhbUuNd3aHZQ ) is a YouTube channel—

throughout the Caribbean, including fights by Stone City Kennel. (Ex. 4)

b. Certain veterinarian support for dogfighting in Puerto Rico

Regulations of Puerto Rico (https://www.aphis.usda.gov/animal_health/downloads/import/state-

regulations-for-puerto-rico.pdf) (discussing the requirement, if transporting dogs, for “[a]n official

certificate veterinary inspection signed by an accredited veterinarian in the state or territory of

(requiring Veterinary Health Certificate signed by “Accredited Veterinarian”).

participation (whether knowing or unknowing) of certain veterinarians in Puerto Rico.

found in Casillas’ Facebook account:

The individual was training dogs “to tear each

Damn and they never caught him fighting

Get out of that shit!!! You don’t need that mess!!!

We don’t do that anymore

They caught in his house dogs and training equipment

It was a video in where he used one dog to motivate

It’s not illegal to train it but it is to confront it

screenshot of a USDA form for accredited veterinarians

(https://www.aphis.usda.gov/library/forms/pdf/APHIS7001.pdf) from Mr. Casillas’ accounts

with one of his dogs identified as a “Labrador mixed”:

(Ex. 5 at pp. 5-10) 9

The following is a conversation with the same “Alverio Vet”:

(Ex. 5 at pp. 15-17)

his fighting dogs. He explained:

the following exchange:

vet and Kennels.” (Ex. 6 at p. 1)

In March 2021, there was the following exchange:

of criminal activity in Puerto Rico.