PLAINTIFF’S FIRST AMENDED COMPLAINT 1

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

KATHRYN SNEED and SNEED 

EQUESTRIAN ESTATES, LLC,

Plaintiffs,

v.

JEFFREY GIBBS, CALLI ROUSE, 

GIBBS SHOW HORSES, CALLI ROUSE 

SHOW HORSES, BLACK BIRD RANCH, 

THE BONAPARTE FAMILY LIVING 

TRUST, FRANK BONAPARTE, 

PATRICIA BONAPARTE, FRANK 

BONAPARTE IN HIS CAPACITY AS 

CO-TRUSTEE OF THE BONAPARTE 

FAMILY LIVING TRUST, PATRICIA 

BONAPARTE IN HER CAPACITY AS 

CO-TRUSTEE OF THE BONAPARTE 

FAMILY LIVING TRUST, JUSTIN 

SCHMIDT, JEANNIE SCHMIDT, HAILO 

INVESTMENTS, LLC, DR. CAMERON 

STOUDT DONNELL, AND EQUINE 

SPORTS MEDICINE AND 

REHABILITATION,

Defendants.

CIVIL ACTION NO. 4:23-CV-00871-ALM

PLAINTIFF’S FIRST AMENDED COMPLAINT

Plaintiffs, Dr. Kathryn Sneed and Sneed Equestrian Estates, LLC (“Sneed” or “Plaintiffs”)

file this First Amended Complaint against the Defendants named below (collectively, 

“Defendants”), and allege as follows:

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PLAINTIFF’S FIRST AMENDED COMPLAINT 2

NATURE OF THE CASE

1. Dr. Kathryn Sneed is the owner of Sneed Equestrian Estates, LLC. She has had a passion 

for horses her entire life, riding and showing horses throughout her childhood years. Dr. 

Sneed currently owns over thirty horses, which includes over ten American Quarter Horse 

Association (AQHA), American Paint Horse Association (APHA), and National Snaffle 

Bit Association (NSBA) world champions. 

2. Sneed files this Complaint with respect to five of her horses: Bank on the Best (“Cash”), 

PartyLikeYouMeanIt (“Faith”), Avante Garde (“Ava”), Mighty Hot Gal (“Bella”), and A 

Sudden Wonder (“Sudden”) (collectively, the “Sneed Horses”), seeking relief against 

Defendants for damages stemming from negligent and abusive care of the abovementioned horses.

3. From the Summer of 2022 until August 2023 Defendants had the Sneed Horses in their 

care, custody, and control. During that time period, the Sneed Horses suffered from neglect, 

abuse, drugging, illness, injury, inadequate nutrition, and misrepresentations with respect 

to development and care. One of the horses (“Ava”) had to be euthanized. The other horses 

have suffered illness and injury, with long-term health and economic consequences.

JURISDICTION AND VENUE

4. This Court has jurisdiction, under 28 U.S.C. § 1332, because the amount in controversy, 

exclusive of costs and interest, exceeds $75,000 and there is complete diversity of

citizenship between the Parties. Defendants are subject to general and personal jurisdiction 

in Texas because Defendants are residents and citizens of the State of Texas, or have 

established the requisite minimum contacts with Texas, and have purposefully availed 

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PLAINTIFF’S FIRST AMENDED COMPLAINT 3

themselves by conducting activities in Texas, thereby establishing a substantial connection 

with the state.

5. Venue is proper, under 28 U.S.C. § 1391(b)(1) and (b)(2), because Defendants reside in 

this judicial district and because a substantial part of the events or omissions giving rise to 

the claim occurred in this judicial district.

THE PARTIES

6. Plaintiff Kathryn Sneed is an individual citizen and resident of Shelby County, Tennessee.

7. Plaintiff Sneed Equestrian Estates, LLC is a Tennessee Limited Liability Company, whose 

principal place of business is Shelby County, Tennessee.

8. Defendant Jeffrey Gibbs is a resident and citizen of Texas and can be served with process 

at: 9017 Chisholm Trail, Crossroads, Texas 76227 or wherever he may be found.

9. Defendant Calli Rouse is a resident and citizen of Texas and can be served with process at:

9017 Chisholm Trail, Crossroads, Texas 76227 or wherever she may be found.

10. Gibbs Show Horses is a Texas business, owned by Defendant Jeffrey Gibbs, who can be 

served with process at: 9017 Chisholm Trail, Crossroads, Texas 76227.

11. Calli Rouse Show Horses is a Texas business, owned by Defendant Calli Rouse, who can 

be served with process at: 9017 Chisholm Trail, Crossroads, Texas 76227.

12. Defendant Black Bird Ranch is an equestrian facility located in Denton County, Texas and 

can be served with process by serving Frank Bonaparte or Patricia Bonaparte at: 1623 

Mockingbird Lane, Southlake, Texas 76092 or through their attorney of record, James C. 

Erdle, Jr. Glast, Phillips & Murray, P.C. 14801 Quorum Drive. Suite 500. Dallas, Texas 

75254.

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13. Defendant The Bonaparte Family Living Trust is a Texas Trust and can be served with 

process by serving Frank or Patricia Bonaparte at: 1623 Mockingbird Lane, Southlake, 

Texas 76092 or through their attorney of record, James C. Erdle, Jr. Glast, Phillips & 

Murray, P.C. 14801 Quorum Drive. Suite 500. Dallas, Texas 75254.

14. Defendant Frank Bonaparte is a resident and citizen of Texas and can be served with 

process at: 1623 Mockingbird Lane, Southlake, Texas 76092 or through his attorney of 

record, James C. Erdle, Jr. Glast, Phillips & Murray, P.C. 14801 Quorum Drive. Suite 500. 

Dallas, Texas 75254, or wherever he may be found.

15. Defendant Patricia Bonaparte is a resident and citizen of Texas and can be served with 

process at: 1623 Mockingbird Lane, Southlake, Texas 76092 or through her attorney of 

record, James C. Erdle, Jr. Glast, Phillips & Murray, P.C. 14801 Quorum Drive. Suite 500. 

Dallas, Texas 75254, or wherever she may be found.

16. Defendant Frank Bonaparte—in his capacity as co-Trustee of the Bonaparte Family Living 

Trust—is a resident and citizen of Texas and can be served with process at: 1623 

Mockingbird Lane, Southlake, Texas 76092 or through his attorney of record, James C. 

Erdle, Jr. Glast, Phillips & Murray, P.C. 14801 Quorum Drive. Suite 500. Dallas, Texas 

75254, or wherever he may be found.

17. Defendant Patricia Bonaparte—in her capacity as co-Trustee of the Bonaparte Family 

Living Trust—is a resident and citizen of Texas and can be served with process at: 1623 

Mockingbird Lane, Southlake, Texas 76092 or through her attorney of record, James C. 

Erdle, Jr. Glast, Phillips & Murray, P.C. 14801 Quorum Drive. Suite 500. Dallas, Texas 

75254, or wherever she may be found.

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18. Defendant Justin Schmidt is a citizen of Idaho and can be served with process at: 10631 

Osburn Road, Pilot Point, Texas 76258 or through his attorney of record, Jeffrey Wolf. The 

Wolf Law Firm, P.C. 1360 N. White Chapel Blvd. Suite 100, Southlake, Texas 76092, or 

wherever he may be found.

19. Defendant Jeannie Schmidt is a citizen of Idaho and can be served with process at: 10631 

Osburn Road, Pilot Point, Texas 76258 or through her attorney of record, Jeffrey Wolf. 

The Wolf Law Firm, P.C. 1360 N. White Chapel Blvd. Suite 100, Southlake, Texas 76092, 

or wherever she may be found.

20. Defendant Hailo Investments, LLC is a Wyoming LLC with its principal place of business 

in Idaho. Hailo Investments, LLC’s sole member is its Chief Executive Manager, Justin 

Schmidt, and can be served with process through its registered agent, Registered Agents 

Inc. at 30 N. Gould Street, Suite R, Sheridan, Wyoming 82801 or through its attorney of 

record, Jeffrey Wolf. The Wolf Law Firm, P.C. 1360 N. White Chapel Blvd. Suite 100, 

Southlake, Texas 76092.

21. Defendant Dr. Cameron Stoudt Donnell (aka Cameron Stoudt) is a resident and citizen of 

Texas and can be served with process at: 396 Orchard Road. Whitesboro, Texas 76273 or 

wherever she may be found.

22. Defendant Equine Sports Medicine and Rehabilitation is a Texas business and can be 

served with process at: 396 Orchard Road. Whitesboro, Texas 76273.

BACKGROUND FACTS

23. Beginning in approximately June 2022, Sneed entered into agreements with Jeffrey Gibbs 

(“Gibbs”), Calli Rouse (“Rouse”), Gibbs Show Horses, and Calli Rouse Show Horses

(collectively, “the Gibbs Defendants”) for the care and training of the Sneed Horses in 

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PLAINTIFF’S FIRST AMENDED COMPLAINT 6

Texas. On social media, Gibbs Show Horses states that “Jeffrey & Calli train, develop & 

show yearlings to finished horses.”

24. Sneed was promised, and was charged for board, grain, care, training, showing, and turnout 

on a regular basis. Sneed paid the Gibbs Defendants $1,650 per horse, per month ($900 for 

board and grain; $750 for training). The Gibbs Defendants consistently represented to 

Sneed that they would care for and train the Horses in a manner consistent with the highest 

industry standards. The Gibbs Defendants initially boarded the Sneed Horses on property 

owned by Hailo Investments, LLC (“Hailo”) and managed by Justin and Jeannie Schmidt 

(“the Schmidt Defendants”).

25. Upon information and belief, the Schmidt Defendants, and vicariously, Hailo, permitted a 

strangles-infected horse onto their property without taking proper and necessary 

precautions against the spread of the highly infectious disease.1

26. The standard of care to prevent a strangles outbreak is to minimize the exposure risks to 

other horses. According to UC Davis’ Veterinary Medicine Center for Equine Health, 

horses that are newly introduced onto a farm or boarding facility should be observed and 

their temperature monitored twice a day for at least two weeks before being housed with 

1 “Strangles is a highly contagious disease of the equine upper respiratory tract caused by the bacterium Streptococcus 

equi subspecies equi (S. equi). The bacteria cross mucous membranes in the nose and mouth to infect lymph nodes 

where they cause abscesses that can eventually rupture. The infected lymph nodes become swollen, which can 

compress the upper respiratory tract (hence, the name strangles). The disease occurs worldwide and is the most 

common infectious agent identified in horses 6 to 10 years of age. Horses become infected through inhalation or 

ingestion of the bacterium. This can occur through horse-to-horse contact, drinking contaminated water, or making 

contact with infected material or equipment. . . . The best strategy to prevent strangles is to minimize exposure risks. 

Horses that are newly introduced onto a farm should be observed and temperature monitored twice a day for at least 

two weeks before being housed with resident horses. Horses with temperatures over 101.5 F should be isolated. 

Vaccination is recommended on farms where strangles is a persistent problem or there is a high risk of exposure.

When cases of strangles occur, any organic material that infected horses came into contact with should be removed 

from the property. Contaminated equipment and facilities should be properly cleaned and disinfected. Handlers should 

wash and sanitize hands before contact with individual horses and should work with sick horses after work with 

healthy horses has been completed for the day. Pastures and stables that contained infected horses should be rested 

for 4 to 6 weeks.” UC Davis Veterinary Medicine Center for Equine Health.

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resident horses. Horses with temperatures over 101.5 Fahrenheit should be isolated. When 

cases of strangles occur, any organic material that infected horses came into contact with 

should be removed from the property. Contaminated equipment and facilities should be 

properly cleaned and disinfected. Handlers should wash and sanitize hands before contact 

with individual horses and should work with sick horses after work with healthy horses has 

been completed for the day. Pastures and stables that contained infected horses should be 

rested for 4 to 6 weeks.

27. The Schmidt Defendants and Hailo failed to exercise the above-mentioned standard of 

care.

28. On or about December 9, 2022, Jeffrey Gibbs and Calli Rouse transported the stallion,

Cash,

2 as well as the other Sneed Horses to the Black Bird Ranch (“the Ranch”), a facility

owned and operated by The Bonaparte Family Living Trust, and under the control of coTrustees Frank Bonaparte and Patricia Bonaparte (collectively, “the Bonaparte

Defendants”). Around one month later, on or aboutJanuary 16, 2023, Cash wasthen moved

to EE Ranch (“EE”) in Whitesboro, Texas. Almost immediately the staff at EE noticed the

symptoms of strangles and contacted a veterinarian. On or about January 21, 2023, EE

notified Sneed that Cash was in isolation. On or about January 24, 2023, Cash was taken

to a veterinarian, where the stallion remained under treatment until about February 21,

2023.

29. When the Ranch took possession of Cash, a duty of care was created on the part of the 

Trust, and by extension, its co-trustees, Frank and Patricia Bonaparte. The Bonaparte 

2 Cash is an 8-time World/Reserve World Champion, 2016 AQHA/APHA Stallion sired by Lopin My Best. 

Showcased at the 2029/2020 APHA World Show, Cash was named World Champion Green Western Pleasure, World 

Champion Amateur Performance Stallion, and World Champion Open Performance Stallion.

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Defendants’ breach of that duty proximately caused injury to Sneed’s stallion, Cash, and 

by extension her commercial interests in the stallion. In addition, the Bonaparte Defendants

failed to communicate with Sneed and did not inform her of the strangles outbreak.

30. Damages with respect to Cash include, but are not limited to the following:

• Medical Care (hospitalization, vet care, exams, bloodwork, and ongoing 

medications).

• Rise in insurance premium (which now contains a strangles exclusion).

• Loss of breeding due to absence of cooled semen. Cash produced no cooled semen 

all season.

• Potential total loss of fertility.

• Additional boarding costs.

• Sneed has 11 personal mares open due to no available semen, and she has had to 

pay stud fees for stallions due to not having her own stallion to collect on.

31. From August 10 – August 20, 2023, the Gibbs Defendants attended the National Snaffle 

Bit Association World Championship Show and Breeders Championship Futurity in 

Tulsa, Oklahoma (“NSBA”).

32. Early on the morning of August 10, 2023, Sneed sent a text message to Calli Rouse, 

checking on her horse Faith and inquired about the Gibbs Defendants arrival at NSBA. 

Rouse stated they would start showing the next day, assuring Sneed that all was well with 

the Horses. Then, shortly thereafter, at approximately 7:25 a.m., Rouse sent a text message 

to Sneed stating they had called a veterinarian, Dr. Cameron Stoudt (“Dr. Stoudt”), coowner of Equine Sports Medicine and Rehabilitation (“ESMR”) (collectively, the “Stoudt 

Defendants”) to go to the Ranch and check on the horse, Ava. Apparently, the mare “wasn’t 

eating well, and was lethargic.” Shortly thereafter, Rouse informed Sneed that they were 

starting fluids on Ava.

33. At approximately 9:30 a.m. on August 10 (a full 2 hours later), Dr. Stoudt and Sneed spoke 

via telephone. Dr. Stoudt informed Sneed that Gibbs had called around 7 a.m., stating it 

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was an emergency. Dr. Stoudt stated that Ava was “down in her stall,” and had been that 

way when she arrived. Ava was not getting up, and Dr. Stoudt took an x-ray of the horse’s 

neck. Dr. Stoudt then informed Sneed that the mare had a fractured vertebrae at the area 

where the neck and chest meet. She informed Sneed that the prognosis was poor and 

advised euthanasia. Dr. Stoudt stated she had sent the x-ray to a neck surgeon who also 

advised against trying to save the mare.

34. Sneed then contacted Dr. Eric Johnson, a veterinary surgeon in Kentucky, for a second 

opinion. The x-rays were sent to Dr. Johnson via email for his review. Dr. Johnson called 

Sneed and stated that while he did not see a fracture, the disc was dislocated severely. Dr. 

Johnson asked for a ventral-dorsal view of the spine. Dr. Stoudt stated that view would be 

difficult to get, but that she would try. Dr. Stoudt then sent a poor-quality x-ray to Sneed, 

who forwarded it to Dr. Johnson. After consulting with colleagues, Dr. Johnson called 

Sneed, noting several times that this type of injury (in his opinion and in the opinion of his 

two colleagues) would have occurred only through extreme trauma. Dr. Johnson stated that 

the horse looked “wrecked” when he first saw the image.

35. Sneed then called Dr. Claunch, another veterinarian in Texas, hoping to get another 

opinion, and enquired about the possibility of an on-site inspection prior to euthanizing the 

mare. Dr. Claunch, after reviewing the x-rays, called Sneed and stated that this type of 

injury could only occur in one of three ways: 1) by running into a fixed object with the 

head down, 2) a rotational fall, or 3) by flipping over. Dr. Claunch determined there was a 

collapsed disc/fractured vertebral body that was collapsed into the spinal cord, thereby 

paralyzing the horse. Only then did Sneed then give Dr. Stoudt permission to euthanize the 

mare.

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36. Sneed’s husband, Darrell Sneed, then contacted Frank Bonaparte, the owner (by virtue of 

being co-Trustee of the Trust) of the barn where Ava was stabled, asking for video footage 

of the mare’s stall. Darrell Sneed specifically asked when Ava had last been out of her stall. 

Bonaparte stated his “IT guy” would have to get back to him. Bonaparte called Darrell 

Sneed back within a few minutes and sent one photograph, claiming it was the night before, 

at 9:50 p.m. Bonaparte stated he could not send any more video footage, could not send

anything with a date stamped on the footage, and only had footage going “back 72 hours.” 

Bonaparte claimed the mare had “eaten all of her food the night before” and was acting 

“normal.” But blood lab work, taken from the mare at 8:05 a.m. on August 10, 2023, shows 

elevated WBC and lymphocytes, as well as dehydration. The photo sent by Dr. Stout also 

showed swelling in the legs of the mare.

37. Multiple witnesses have provided a description of the training methods used on Ava and 

other horses by Jeffrey Gibbs and Calli Rouse while the horses were on the Schmidt’s, 

Hailo’s, and Bonaparte’s property. Upon information and belief, one witness who had been 

an intern with Gibbs Show Horses, stated that the Gibbs defendants had tied Ava up several 

times in her stall with her head tied up, and had also tied her head down to her chest with 

reins drawn under her legs and tied to the saddle. The witness stated that Gibbs had also 

done this by hobbling Ava’s legs together and forcing the mare to run. The witness saw the 

mare flip over, fall, and run into things multiple times. The witness stated that if the mare 

did not run, Gibbs would use blunt traumatic force on her. Upon information and belief, 

Gibbs beat all the Horses with bats, whips, boards, and other objects found throughout the 

barn. The witness stated that Gibbs scolded her for not being “mean enough to the babies.” 

In addition, the witness reported hearing Gibbs screaming foul statements at the Horses 

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PLAINTIFF’S FIRST AMENDED COMPLAINT 11

and yelling at them after hitting them multiple times and would kick them if they did not 

get up when hobbled. The witness stated that she observed Gibbs put Ava up into her stall 

after one of these “training days” with a swollen and bloody mouth from the force of the 

bit in her mouth after being tied down. The mare was then left there for days.

38. Damages with respect to Ava include but are not limited to: Loss of the horse, loss of 

potential offspring value, training costs, hauling costs, and veterinarian fees and expenses.

39. Upon information and belief, all the Horses were exposed to Strangles after the Schmidt 

and Hailo Defendants permitted a trainer to bring a strangles-infected horse onto their 

property and remain in close proximity to Sneed’s Horses. The strangles infection almost 

cost Cash his life, and he had no semen for the entire 2023 breeding season due to fever 

and illness.

40. Upon information and belief, the Stoudt Defendants were aware of the Strangles infection 

and did not take proper care or precautions to protect the Sneed Horses; neither did the 

Stoudt Defendants give notice to Sneed of the outbreak and illness.

41. Faith: In addition to the strangles that was kept secret from Sneed, upon information and 

belief, Faith was medicated with illegal levels of NSAID’s at the NSBA show in 2023. 

This would have caused Sneed to have been put on a three-year probation. One of the 

medications found in the mare’s blood is a known cause of bone rotation. The mare has 

also had campo phenique poured in her ears, which has damaged the soft tissue lining of 

her ears. This technique is illegal and is known to cause neurological problems and 

potentially long-term hearing loss.

42. Ava: As described above, the mare suffered from a dislocated cervical spinal vertebra in 

two dimensions, compression into the spinal column by tying her head around to the side 

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of her saddle and leaving her that way for hours and letting her lay down in the round pen.

The Gibbs Defendant’s neglect and abuse killed this two-year-old horse, and cost her a 

show career, and future offspring. Upon information and belief, established by eyewitness 

accounts, the Stoudt Defendants were complicit in this through their awareness of extreme 

abuse in the barn and through providing pain medication without proper examination in 

the weeks prior to Ava’s death.

43. Bella: This mare suffered from a bone chip on the front right fetlock and another on her

second cervical vertebra (the same vertebra dislocated in Ava). The mare now has to 

have surgery and at least sixty days off after surgery. Bella has missed the entire 2023 show 

season and will not be shown this whole year, if she recovers. Upon information and belief, 

a veterinarian has stated that the cervical chip is “trauma” related.

44. Sudden: This mare now has a bone spur in her hock and arthritic changes in her 

knee/carpus. Due to the negligence of Defendants, she will have to have a minimum of 

sixty days off.

45. The illness and injuries inflicted upon Sneed’s horses while under the care and training of 

the Gibbs Defendants, and while under the veterinary care of the Stoudt Defendants from 

approximately June 2022 to approximately August 2023, took place while the Horses were 

stabled on properties belonging to the Schmidt, Hailo, and Bonaparte Defendants. 

CAUSES OF ACTION

COUNT 1: BREACH OF CONTRACT (AGAINST JEFFREY GIBBS, CALLI ROUSE, GIBBS SHOW 

HORSES, AND CALLI ROUSE SHOW HORSES)

46. Plaintiffs incorporate and re-allege the foregoing paragraphs by reference.

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47. Plaintiffs and the Gibbs Defendants entered into an agreement for the board, training, and 

showing of the Horses. Sneed paid the Gibbs Defendants $1,650 per horse, per month 

($900 for board and grain; $750 for training). Plaintiffs tendered performance on the 

agreed-upon terms.

48. Upon information and belief, Plaintiff’s Horses did not receive the agreed-upon stabling, 

feed, training, medical care, and turnout as the parties had agreed. The Gibbs Defendants’

failure to honor their obligations under the parties’ agreement represents a breach of 

contract.

49. As a direct and proximate result of Defendants’ breaches of the agreement to maintain 

Sneed’s horses in healthy body conditions, Plaintiffs have suffered and will continue to 

suffer damages, including, but not limited to, reduction in the value of the Horses, lost 

show opportunities, lost breeding opportunities, and the loss of potential sales.

COUNT 2: NEGLIGENCE: INJURY TO SNEED’S HORSES (AGAINST ALL DEFENDANTS)

50. Plaintiffs incorporate and re-allege the foregoing paragraphs by reference.

51. A bailment was created when Sneed’s horses were transferred into the care, custody, and 

control of the various Defendants at the barns/equine training and boarding facilities which 

they owned and oversee, or by virtue of their providing veterinary care.

52. At all times, while Sneed’s horses were under the care, custody, and control of the 

Defendants, and on property owned by the Bonaparte, Schmidt, and Hailo Defendants, 

Defendants had a duty of care, which required a reasonable standard of care and the 

avoidance of injury, communicable disease, and death.

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53. Defendants breached this duty of care by failing to exercise reasonable care in a way that 

is compatible with the standard of care exercised by a prudent person, with knowledge of 

the proper standard of care.

54. Defendants therefore caused the harm suffered by Plaintiffs through their breach of the 

duty of ordinary care. Defendants’ acts and omissions are the actual and proximate causes 

of Plaintiff’s harm—the spread of disease in and serious injury to the Plaintiff’s Horses, 

including euthanization.

55. Sneed has suffered actual losses, quantified by the loss of life, loss in value of her Horses, 

loss of the value of future offspring, lost potential sales, loss of future earnings, additional 

veterinary care, rehabilitative care, increased insurance premiums, and training charges.

COUNT 3: GROSS NEGLIGENCE: ANIMAL ABUSE AND INJURY TO SNEED’S HORSES (AGAINST 

JEFFREY GIBBS, CALLI ROUSE, GIBBS SHOW HORSES, AND CALLI ROUSE SHOW HORSES)

56. Plaintiffs incorporate and re-allege the foregoing paragraphs by reference.

57. A bailment was created when Sneed’s horses were transferred into the care, custody, and 

control of the Gibbs Defendants.

58. At all times, while Sneed’s horses were under the care, custody, and control of the Gibbs 

Defendants, Defendants had an ordinary duty of care, which required a reasonable standard 

of care and the avoidance of injury, communicable disease, and death.

59. Defendants breached this duty of care by acting in a way that, objectively, involved an 

extreme degree of risk, considering the probability and magnitude of the potential harm to

Sneed’s horses. Additionally, Defendants had actual, subjective awareness of the risks

involved in their abusive “training” methods, but nevertheless proceed in conscious 

indifference to the rights, safety, or welfare of Sneed’s Horses.

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60. Defendants therefore caused the harm suffered by Plaintiffs through their acts of gross 

negligence. Defendants’ acts and omissions are the actual and proximate causes of 

Plaintiff’s harm.

61. Sneed has suffered actual losses, quantified by the loss of life, loss in value of her Horses, 

loss of the value of future offspring, lost potential sales, loss of future earnings, veterinary 

care, rehabilitative care, increased insurance premiums, and training charges.

62. Pleading in the alternative, the Sneed Horses were injured by virtue of accident, brought 

on by careless disregard for the conditions exacerbated through abusive training methods.

COUNT 4: PROFESSIONAL (VETERINARY) MALPRACTICE (AGAINST DR. CAMERON STOUDT

DONNELL AND EQUINE SPORTS MEDICINE AND REHABILITATION)

63. Plaintiffs incorporate and re-allege the foregoing paragraphs by reference.

64. Upon information and belief, the Stoudt Defendants were frequently and routinely utilized 

by the Gibbs Defendants to care for and provide medication and drugs to the Sneed Horses.

65. Upon information and belief, the Stoudt Defendants were aware of the Strangles outbreak 

and did not properly care for the Sneed Horses nor contain its spread. The Stoudt 

Defendants failed to notify Sneed of the outbreak of a highly infectious disease, despite 

having a duty and obligation to do so.

66. Upon information and belief, the Stoudt Defendants failed to diagnose Ava’s condition 

properly and adequately on the morning of August 10, 2023. Specifically, Dr. Stoudt failed 

to perform a dorsal-ventral view of the vertebrae; an above-and-below view was necessary, 

as requested by Dr. Johnson. When the x-ray was finally provided, it was of a substandard 

quality. As a result, Dr. Stoudt failed to adequately assess surgical repair. In addition, Dr. 

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Stoudt failed to take additional x-rays in order to assess secondary sources of injury and 

paralysis; she failed to collect additional data.

67. Upon information and belief, the Stoudt Defendants were aware of the Gibbs Defendants 

abusive and dangerous training methods, but despite actual knowledge of extreme abuse in 

the barn, Dr. Stoudt continued to provide pain medication to Ava without proper 

examinations and without Sneed’s informed consent.

68. Upon information and belief, the Stoudt Defendants exacerbated the risk of injury to the 

Horses, particularly Ava, by medicating the Horse in order to cover up injuries in the weeks 

prior to August 10, 2023. Ava’s lab work showed that the Horse was dehydrated, suffered 

muscle spasms, and was medicated with pain killers. Dr. Stoudt’s knowledge of these 

conditions, combined with her inaction, exacerbated the injuries, which led to Ava’s death.

69. Upon information and belief, Dr. Stoudt provided an IV to Ava without Sneed’s informed 

consent, despite having an obligation to notify the Horse’s owner of care.

70. Upon information and belief, the Stoudt Defendants ignored the fact that Ava was “down 

in her stall” for quite some time, remarking to Sneed that the Horse may have a “genetic 

predisposition to a weak vertebra,” and stating that “it could have been congenital.” Dr. 

Stoudt make these comments despite her awareness of the Gibbs Defendants cruel, 

dangerous, and abusive training methods.

71. Upon information and belief, the standard of care when a horse is “down” is to consider 

flushing the stomach, examining the legs for fractures, performing an Equine Protozoal 

Myeloencephalitis (“EPM”) test in order to determine neurological reasons for paralysis. 

Then an injury to the neck might be considered. Dr. Stoudt never recommended an EPM 

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PLAINTIFF’S FIRST AMENDED COMPLAINT 17

test be done on Ava. Rather, Dr. Stoudt, with knowledge of Gibbs’ prior acts, knew to 

examine, via an x-ray, the exact vertebra that was injured.

72. The Stoudt Defendants were under a duty of care toward the Sneed Horses; Dr. Stoudt had 

accepted the responsibility of treating the Sneed Horses, particularly Ava. The Stoudt 

Defendants actions and nonactions did not conform to the professional standard of care and 

conduct. Such failure to conform to the professional standard of care and conduct was the 

proximate cause of the injuries and harm to the Sneed Horses. And the injuries and harm

to the Sneed Horses resulted in damages to the Plaintiffs—quantified by the loss of life, 

loss in value of the Horses, loss of the value of future offspring, lost potential sales, loss of 

future earnings, veterinary care, rehabilitative care, increased insurance premiums, and 

training charges.

COUNT 5: RES IPSA LOQUITUR (AGAINST ALL DEFENDANTS)

73. Plaintiffs incorporate and re-allege the foregoing paragraphs by reference.

74. The injuries to the Sneed Horses, Ava and Cash in particular, were of a type that does not 

generally happen without negligence.

75. The injuries were caused by an instrumentality solely in the Defendant’s control.

76. The Plaintiffs did not contribute to the cause of the injuries.

77. Sneed has suffered actual losses, quantified by the loss of life, loss in value of her Horses, 

loss of the value of future offspring, lost potential sales, loss of future earnings, additional 

veterinary care, rehabilitative care, increased insurance premiums, and training charges.

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PLAINTIFF’S FIRST AMENDED COMPLAINT 18

DAMAGES

78. As a direct and proximate result of the Defendants’ acts and omissions alleged in the 

foregoing paragraphs, Plaintiffs have suffered damages for loss and injuries in an amount 

in excess of $75,000 but less than $6 Million, including but not limited to the following 

damages:

a. Loss of life.

b. Loss in value of the Horses.

c. Loss of future offspring.

d. Loss of potential sales.

e. Loss of future earnings.

f. Veterinary and rehabilitative care.

g. Increase in insurance premiums.

h. Training charges.

EXEMPLARY DAMAGES

79. Defendants’ acts and/or omissions are of such a character to rise to the level of gross 

negligence. Further, Plaintiffs would show that the acts and/or omissions of Defendants 

were carried out with a conscious disregard for an extreme danger of risk and with actual 

awareness on the part of Defendants that their acts would, in reasonable probability, result 

in serious injury to the Horses or death. Defendants caused substantial injury to Plaintiffs

and engaged in acts or omissions that, when viewed objectively at the time of the 

occurrence, involved an extreme degree of risk, considering the probability and magnitude 

of the potential harm to the Horses. Further, Defendants, personally or through their

employees, had actual, subjective awareness of the risk involved in their acts and 

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PLAINTIFF’S FIRST AMENDED COMPLAINT 19

omissions, but nevertheless, proceeded with conscious indifference to the rights, safety, or 

welfare of others, including Plaintiff’s Horses. 

80. Plaintiffs seek the imposition of punitive or exemplary damages from Defendants without 

limitation as imposed by § 41.008 of the Texas Civil Practice and Remedies Code. 

JURY DEMAND

Plaintiffs demand a jury trial on all Causes of Action alleged in this Complaint.

PRAYER FOR RELIEF

Plaintiffs request that Defendants be cited to appear and answer, and that on final trial 

Plaintiffs recover: 

a. Judgment against Defendants for compensatory damages;

b. Judgment against Defendants for exemplary damages;

c. Pre-judgment and post-judgment interest as provided by law; 

d. Reasonable attorney fees;

e. Costs of suit; and 

f. Any further relief, at law or in equity, to which Plaintiffs may be entitled. 

Respectfully submitted,

KEARNEY, MCWILLIAMS & DAVIS, PLLC

/s/ Charles S. North

Charles S. North

SBN: 24095712

cnorth@kmd.law

1235 South Main, #280

Grapevine, Texas 76051

Tel./Fax: 817-764-3459

Attorney for Plaintiffs

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