Mark Ford "sickened" by Gillis' actions

[Harness Racing Revolution]

GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
By: TOMOKO ONOZAWA
Assistant United States Attorney
86 Chambers Street, 3rd Floor
New York, New York 10007
Telephone: (212) 637-2721
Facsimile: (212) 637-2686
E-mail: tomoko.onozawa@usdoj.gov
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------------- x
UNITED STATES OF AMERICA,
Plaintiff,
 -againstMARK FORD, MARK FORD STABLES, INC.,
MARK FORD STAGE ROAD PROPERTY, INC.,
and FORD EQUINE, LTD.,
Defendants.
:
:
:
:
:
:
:
:
:
:
:
COMPLAINT
19 Civ. 9600
----------------------------------------------------------------- x
1. The United States of America, by its attorney, Geoffrey S. Berman, United States
Attorney for the Southern District of New York, acting on behalf of the Administrator of the
United States Environmental Protection Agency (“EPA”), alleges for its complaint as follows:
NATURE OF THE ACTION
2. Defendants Mark Ford (“Ford”) and Mark Ford Stables, Inc., Mark Ford Stage
Road Property, Inc., and Ford Equine Ltd. (collectively, the “Ford Companies”) bulldozed over
two dozen acres of wetlands and rerouted streams while on notice that doing so was prohibited
by the Clean Water Act (the “CWA”), 33 U.S.C. §§ 1251 et seq. Ford and the Ford Companies
did this to build a dedicated horse racing training center with associated pastures on two
properties in Orange County, New York. As Ford has put it, “you like to have the [horse] track
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 1 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 1 of 24
2
the way you want it, you want a barn the way you want it and you want some pavement to drive
on.” To make things “the way [they] want[ed] it,” Ford and the Ford Companies illegally filled
waters of the United States. They also violated a CWA stormwater construction general permit.
3. Ford and the Ford Companies have repeatedly violated section 301(a) of the
CWA, 33 U.S.C. §§ 1311(a), by running a concentrated animal feeding operation without a
permit, allowing wastewater to contaminate waters of the United States. These violations—
which include piping manure-laden wastewater directly from wash bays/stalls and a horse
swimming pool to a nearby stream—continue to the present day.
4. The United States brings this civil action under Sections 309(b) and (d) of the
CWA, 33 U.S.C. §§ 1319(b), (d), to obtain injunctive relief compelling Ford and the Ford
Companies to remove the unauthorized fill material from waters of the United States, to restore
the watercourses, and to cease their unpermitted discharges, and for civil penalties.
JURISDICTION AND VENUE
5. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1331, 1345,
and 1355, and Section 309(b) and (d) of the CWA, 33 U.S.C. § 1319(b) and (d).
6. Venue is proper in this District pursuant to Section 309(b) and (d) of the CWA,
33 U.S.C. §§ 1319(b) and (d) and 1395, because the events giving rise to the claims herein arose
in this District.
7. The United States has provided notice of the commencement of this action to the
State of New York pursuant to Section 309(b) of the CWA, 33 U.S.C. § 1319(b).
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 2 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 2 of 24
3
PARTIES
8. Plaintiff is the United States of America on behalf of EPA.
9. Defendant Mark Ford (“Ford”) is an individual who owns property and regularly
conducts business in Orange County, New York. Ford is the president and sole shareholder of,
and controls, the Ford Companies.
10. Defendant Mark Ford Stables, Inc., is a corporation organized under the laws of
the State of New York, with its principal executive offices located at 410 Jericho Turnpike,
Jericho, New York 11753.
11. Defendant Ford Equine, Ltd., is a corporation organized under the laws of the
State of New York, with its principal executive offices located at 125 Stony Ford Road,
Campbell Hall, New York 10916.
12. Defendant Mark Ford Stage Road Property, Inc., is a corporation organized under
the laws of the State of New York, with its principal executive offices located at 125 Stony Ford
Road, Campbell Hall, New York 10916.
13. Defendants Ford, Mark Ford Stables, Inc., Ford Equine, Ltd., and Mark Ford
Stage Road Property, Inc., are each “persons” within the meaning of Section 502(5) of the CWA,
33 U.S.C. § 1362(5).
STATUTORY AND REGULATORY BACKGROUND
I. The Wetlands Permitting Program Under CWA Section 404
14. The CWA was enacted “to restore and maintain the chemical, physical, and
biological integrity of the Nation’s waters.” 33 U.S.C. 1251(a).
15. Section 301(a) of the CWA, 33 U.S.C. § 1311(a), furthers this goal by prohibiting
the “discharge of any pollutant by any person” to waters of the United States, “[e]xcept in
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 3 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 3 of 24
4
compliance with,” among other things, permits issued under Sections 402 and 404 of the CWA.
33 U.S.C. §§ 1342, 1344. The “discharge of a pollutant” includes “any addition of any pollutant
to navigable waters from any point source.” 33 U.S.C. § 1362(12).
16. Navigable waters are “the waters of the United States, including the territorial
seas.” 33 U.S.C. § 1362(7). In turn, “waters of the United States” has been defined to include,
inter alia, all waters which are currently used, were used in the past, or may be susceptible to use
in interstate or foreign commerce; tributaries to such waters; and wetlands adjacent to the
foregoing waters. See, e.g., 33 C.F.R. § 328.3(a) (1993); 40 C.F.R. §§ 122.2 (1993).
17. A “point source” is defined as “any discernible, confined and discrete
conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete
fissure, container . . . [or] concentrated animal feeding operation . . . from which pollutants may
be discharged.” 33 U.S.C. § 1362(14).
18. As defined by Section 502(6) of the CWA, a “pollutant” includes, among other
things, dredged spoil, solid waste, sewage, biological materials, rock, sand, cellar dirt, and
industrial, municipal, and agricultural waste discharged into water. 33 U.S.C. § 1362(6).
19. Wetlands are “those areas that are inundated or saturated by surface or ground
water at a frequency and duration sufficient to support, and that under normal circumstances do
support, a prevalence of vegetation typically adapted for life in saturated soil conditions.”
33 C.F.R. § 328.3(b) (1993).
20. Under the Clean Water Act, no person may discharge fill into wetlands that are
waters of the United States (also known as “jurisdictional wetlands”) without a permit—typically
issued by the United States Army Corps of Engineers (the “Corps of Engineers” or “Corps”)—
under Section 404(a) of the CWA, 33 U.S.C. § 1344(a). The Section 404 permitting program,
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 4 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 4 of 24
5
consistent with the purposes of the CWA, is intended to authorize the discharge of dredged or fill
material into wetlands only when, among other things, “it can be demonstrated that such a
discharge will not have an unacceptable adverse impact either individually or in combination
with known and/or probable impacts . . . .” 40 C.F.R. § 230.1.
II. The NPDES Permitting Program Under CWA Section 402
21. Similarly, the Clean Water Act prohibits any person from discharging pollutants
other than fill or dredged material to waters of the United States without a permit under Section
402 of the CWA, 33 U.S.C. § 1342(a). Section 402 authorizes EPA, under certain
circumstances, to issue a National Pollutant Discharge Elimination System (“NPDES”) permit
authorizing a person to discharge pollutants into waters of the United States. The CWA also
authorizes states to establish their own permitting programs. 33 U.S.C. § 1342(b). After a
state’s permitting program is approved by EPA, and subject to certain limitations, states may
issue their own NPDES permits pursuant to such a program.
22. New York State, through its Department of Environmental Conservation
(“NYSDEC”), administers such an approved permitting program, referred to as the State
Pollutant Discharge Elimination System (“SPDES”) permit program. Under Sections 309 and
402(i) of the CWA, the United States retains concurrent authority to enforce SPDES permit
violations. 33 U.S.C. §§ 1319, 1342(i).
A. Construction General Permits
23. Construction activity is one type of industrial activity for which associated
stormwater discharges require a permit under Section 402 of the CWA. Construction activity
includes “clearing, grading and excavation.” 40 C.F.R. § 122.26(b)(14)(x).
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 5 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 5 of 24
6
24. The CWA regulates stormwater discharges from construction activities because
when there is precipitation, stormwater or snowmelt can wash over or flow through loose soil on
a construction site and pick up pollutants that are then discharged to rivers, streams, lakes, or
coastal waters.

[Stan durbread]

GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
By: TOMOKO ONOZAWA
Assistant United States Attorney
86 Chambers Street, 3rd Floor
New York, New York 10007
Telephone: (212) 637-2721
Facsimile: (212) 637-2686
E-mail: tomoko.onozawa@usdoj.gov
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------------- x
UNITED STATES OF AMERICA,
Plaintiff,
 -againstMARK FORD, MARK FORD STABLES, INC.,
MARK FORD STAGE ROAD PROPERTY, INC.,
and FORD EQUINE, LTD.,
Defendants.
:
:
:
:
:
:
:
:
:
:
:
COMPLAINT
19 Civ. 9600
----------------------------------------------------------------- x
1. The United States of America, by its attorney, Geoffrey S. Berman, United States
Attorney for the Southern District of New York, acting on behalf of the Administrator of the
United States Environmental Protection Agency (“EPA”), alleges for its complaint as follows:
NATURE OF THE ACTION
2. Defendants Mark Ford (“Ford”) and Mark Ford Stables, Inc., Mark Ford Stage
Road Property, Inc., and Ford Equine Ltd. (collectively, the “Ford Companies”) bulldozed over
two dozen acres of wetlands and rerouted streams while on notice that doing so was prohibited
by the Clean Water Act (the “CWA”), 33 U.S.C. §§ 1251 et seq. Ford and the Ford Companies
did this to build a dedicated horse racing training center with associated pastures on two
properties in Orange County, New York. As Ford has put it, “you like to have the [horse] track
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 1 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 1 of 24
2
the way you want it, you want a barn the way you want it and you want some pavement to drive
on.” To make things “the way [they] want[ed] it,” Ford and the Ford Companies illegally filled
waters of the United States. They also violated a CWA stormwater construction general permit.
3. Ford and the Ford Companies have repeatedly violated section 301(a) of the
CWA, 33 U.S.C. §§ 1311(a), by running a concentrated animal feeding operation without a
permit, allowing wastewater to contaminate waters of the United States. These violations—
which include piping manure-laden wastewater directly from wash bays/stalls and a horse
swimming pool to a nearby stream—continue to the present day.
4. The United States brings this civil action under Sections 309(b) and (d) of the
CWA, 33 U.S.C. §§ 1319(b), (d), to obtain injunctive relief compelling Ford and the Ford
Companies to remove the unauthorized fill material from waters of the United States, to restore
the watercourses, and to cease their unpermitted discharges, and for civil penalties.
JURISDICTION AND VENUE
5. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1331, 1345,
and 1355, and Section 309(b) and (d) of the CWA, 33 U.S.C. § 1319(b) and (d).
6. Venue is proper in this District pursuant to Section 309(b) and (d) of the CWA,
33 U.S.C. §§ 1319(b) and (d) and 1395, because the events giving rise to the claims herein arose
in this District.
7. The United States has provided notice of the commencement of this action to the
State of New York pursuant to Section 309(b) of the CWA, 33 U.S.C. § 1319(b).
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 2 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 2 of 24
3
PARTIES
8. Plaintiff is the United States of America on behalf of EPA.
9. Defendant Mark Ford (“Ford”) is an individual who owns property and regularly
conducts business in Orange County, New York. Ford is the president and sole shareholder of,
and controls, the Ford Companies.
10. Defendant Mark Ford Stables, Inc., is a corporation organized under the laws of
the State of New York, with its principal executive offices located at 410 Jericho Turnpike,
Jericho, New York 11753.
11. Defendant Ford Equine, Ltd., is a corporation organized under the laws of the
State of New York, with its principal executive offices located at 125 Stony Ford Road,
Campbell Hall, New York 10916.
12. Defendant Mark Ford Stage Road Property, Inc., is a corporation organized under
the laws of the State of New York, with its principal executive offices located at 125 Stony Ford
Road, Campbell Hall, New York 10916.
13. Defendants Ford, Mark Ford Stables, Inc., Ford Equine, Ltd., and Mark Ford
Stage Road Property, Inc., are each “persons” within the meaning of Section 502(5) of the CWA,
33 U.S.C. § 1362(5).
STATUTORY AND REGULATORY BACKGROUND
I. The Wetlands Permitting Program Under CWA Section 404
14. The CWA was enacted “to restore and maintain the chemical, physical, and
biological integrity of the Nation’s waters.” 33 U.S.C. 1251(a).
15. Section 301(a) of the CWA, 33 U.S.C. § 1311(a), furthers this goal by prohibiting
the “discharge of any pollutant by any person” to waters of the United States, “[e]xcept in
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 3 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 3 of 24
4
compliance with,” among other things, permits issued under Sections 402 and 404 of the CWA.
33 U.S.C. §§ 1342, 1344. The “discharge of a pollutant” includes “any addition of any pollutant
to navigable waters from any point source.” 33 U.S.C. § 1362(12).
16. Navigable waters are “the waters of the United States, including the territorial
seas.” 33 U.S.C. § 1362(7). In turn, “waters of the United States” has been defined to include,
inter alia, all waters which are currently used, were used in the past, or may be susceptible to use
in interstate or foreign commerce; tributaries to such waters; and wetlands adjacent to the
foregoing waters. See, e.g., 33 C.F.R. § 328.3(a) (1993); 40 C.F.R. §§ 122.2 (1993).
17. A “point source” is defined as “any discernible, confined and discrete
conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete
fissure, container . . . [or] concentrated animal feeding operation . . . from which pollutants may
be discharged.” 33 U.S.C. § 1362(14).
18. As defined by Section 502(6) of the CWA, a “pollutant” includes, among other
things, dredged spoil, solid waste, sewage, biological materials, rock, sand, cellar dirt, and
industrial, municipal, and agricultural waste discharged into water. 33 U.S.C. § 1362(6).
19. Wetlands are “those areas that are inundated or saturated by surface or ground
water at a frequency and duration sufficient to support, and that under normal circumstances do
support, a prevalence of vegetation typically adapted for life in saturated soil conditions.”
33 C.F.R. § 328.3(b) (1993).
20. Under the Clean Water Act, no person may discharge fill into wetlands that are
waters of the United States (also known as “jurisdictional wetlands”) without a permit—typically
issued by the United States Army Corps of Engineers (the “Corps of Engineers” or “Corps”)—
under Section 404(a) of the CWA, 33 U.S.C. § 1344(a). The Section 404 permitting program,
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 4 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 4 of 24
5
consistent with the purposes of the CWA, is intended to authorize the discharge of dredged or fill
material into wetlands only when, among other things, “it can be demonstrated that such a
discharge will not have an unacceptable adverse impact either individually or in combination
with known and/or probable impacts . . . .” 40 C.F.R. § 230.1.
II. The NPDES Permitting Program Under CWA Section 402
21. Similarly, the Clean Water Act prohibits any person from discharging pollutants
other than fill or dredged material to waters of the United States without a permit under Section
402 of the CWA, 33 U.S.C. § 1342(a). Section 402 authorizes EPA, under certain
circumstances, to issue a National Pollutant Discharge Elimination System (“NPDES”) permit
authorizing a person to discharge pollutants into waters of the United States. The CWA also
authorizes states to establish their own permitting programs. 33 U.S.C. § 1342(b). After a
state’s permitting program is approved by EPA, and subject to certain limitations, states may
issue their own NPDES permits pursuant to such a program.
22. New York State, through its Department of Environmental Conservation
(“NYSDEC”), administers such an approved permitting program, referred to as the State
Pollutant Discharge Elimination System (“SPDES”) permit program. Under Sections 309 and
402(i) of the CWA, the United States retains concurrent authority to enforce SPDES permit
violations. 33 U.S.C. §§ 1319, 1342(i).
A. Construction General Permits
23. Construction activity is one type of industrial activity for which associated
stormwater discharges require a permit under Section 402 of the CWA. Construction activity
includes “clearing, grading and excavation.” 40 C.F.R. § 122.26(b)(14)(x).
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 5 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 5 of 24
6
24. The CWA regulates stormwater discharges from construction activities because
when there is precipitation, stormwater or snowmelt can wash over or flow through loose soil on
a construction site and pick up pollutants that are then discharged to rivers, streams, lakes, or
coastal waters.

This is exactly why people think you are a moron with an agenda against Mark. Mark was a successful horse trainer and did smart things with his money. Then bought a piece of property to turn into a top class training facility. Do you really think he did all the site work himself?  No he hired a contractor and relied on them. It came back and bit him in the ass

[Pacer 2]

GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
By: TOMOKO ONOZAWA
Assistant United States Attorney
86 Chambers Street, 3rd Floor
New York, New York 10007
Telephone: (212) 637-2721
Facsimile: (212) 637-2686
E-mail: tomoko.onozawa@usdoj.gov
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------------- x
UNITED STATES OF AMERICA,
Plaintiff,
 -againstMARK FORD, MARK FORD STABLES, INC.,
MARK FORD STAGE ROAD PROPERTY, INC.,
and FORD EQUINE, LTD.,
Defendants.
:
:
:
:
:
:
:
:
:
:
:
COMPLAINT
19 Civ. 9600
----------------------------------------------------------------- x
1. The United States of America, by its attorney, Geoffrey S. Berman, United States
Attorney for the Southern District of New York, acting on behalf of the Administrator of the
United States Environmental Protection Agency (“EPA”), alleges for its complaint as follows:
NATURE OF THE ACTION
2. Defendants Mark Ford (“Ford”) and Mark Ford Stables, Inc., Mark Ford Stage
Road Property, Inc., and Ford Equine Ltd. (collectively, the “Ford Companies”) bulldozed over
two dozen acres of wetlands and rerouted streams while on notice that doing so was prohibited
by the Clean Water Act (the “CWA”), 33 U.S.C. §§ 1251 et seq. Ford and the Ford Companies
did this to build a dedicated horse racing training center with associated pastures on two
properties in Orange County, New York. As Ford has put it, “you like to have the [horse] track
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 1 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 1 of 24
2
the way you want it, you want a barn the way you want it and you want some pavement to drive
on.” To make things “the way [they] want[ed] it,” Ford and the Ford Companies illegally filled
waters of the United States. They also violated a CWA stormwater construction general permit.
3. Ford and the Ford Companies have repeatedly violated section 301(a) of the
CWA, 33 U.S.C. §§ 1311(a), by running a concentrated animal feeding operation without a
permit, allowing wastewater to contaminate waters of the United States. These violations—
which include piping manure-laden wastewater directly from wash bays/stalls and a horse
swimming pool to a nearby stream—continue to the present day.
4. The United States brings this civil action under Sections 309(b) and (d) of the
CWA, 33 U.S.C. §§ 1319(b), (d), to obtain injunctive relief compelling Ford and the Ford
Companies to remove the unauthorized fill material from waters of the United States, to restore
the watercourses, and to cease their unpermitted discharges, and for civil penalties.
JURISDICTION AND VENUE
5. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1331, 1345,
and 1355, and Section 309(b) and (d) of the CWA, 33 U.S.C. § 1319(b) and (d).
6. Venue is proper in this District pursuant to Section 309(b) and (d) of the CWA,
33 U.S.C. §§ 1319(b) and (d) and 1395, because the events giving rise to the claims herein arose
in this District.
7. The United States has provided notice of the commencement of this action to the
State of New York pursuant to Section 309(b) of the CWA, 33 U.S.C. § 1319(b).
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 2 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 2 of 24
3
PARTIES
8. Plaintiff is the United States of America on behalf of EPA.
9. Defendant Mark Ford (“Ford”) is an individual who owns property and regularly
conducts business in Orange County, New York. Ford is the president and sole shareholder of,
and controls, the Ford Companies.
10. Defendant Mark Ford Stables, Inc., is a corporation organized under the laws of
the State of New York, with its principal executive offices located at 410 Jericho Turnpike,
Jericho, New York 11753.
11. Defendant Ford Equine, Ltd., is a corporation organized under the laws of the
State of New York, with its principal executive offices located at 125 Stony Ford Road,
Campbell Hall, New York 10916.
12. Defendant Mark Ford Stage Road Property, Inc., is a corporation organized under
the laws of the State of New York, with its principal executive offices located at 125 Stony Ford
Road, Campbell Hall, New York 10916.
13. Defendants Ford, Mark Ford Stables, Inc., Ford Equine, Ltd., and Mark Ford
Stage Road Property, Inc., are each “persons” within the meaning of Section 502(5) of the CWA,
33 U.S.C. § 1362(5).
STATUTORY AND REGULATORY BACKGROUND
I. The Wetlands Permitting Program Under CWA Section 404
14. The CWA was enacted “to restore and maintain the chemical, physical, and
biological integrity of the Nation’s waters.” 33 U.S.C. 1251(a).
15. Section 301(a) of the CWA, 33 U.S.C. § 1311(a), furthers this goal by prohibiting
the “discharge of any pollutant by any person” to waters of the United States, “[e]xcept in
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 3 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 3 of 24
4
compliance with,” among other things, permits issued under Sections 402 and 404 of the CWA.
33 U.S.C. §§ 1342, 1344. The “discharge of a pollutant” includes “any addition of any pollutant
to navigable waters from any point source.” 33 U.S.C. § 1362(12).
16. Navigable waters are “the waters of the United States, including the territorial
seas.” 33 U.S.C. § 1362(7). In turn, “waters of the United States” has been defined to include,
inter alia, all waters which are currently used, were used in the past, or may be susceptible to use
in interstate or foreign commerce; tributaries to such waters; and wetlands adjacent to the
foregoing waters. See, e.g., 33 C.F.R. § 328.3(a) (1993); 40 C.F.R. §§ 122.2 (1993).
17. A “point source” is defined as “any discernible, confined and discrete
conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete
fissure, container . . . [or] concentrated animal feeding operation . . . from which pollutants may
be discharged.” 33 U.S.C. § 1362(14).
18. As defined by Section 502(6) of the CWA, a “pollutant” includes, among other
things, dredged spoil, solid waste, sewage, biological materials, rock, sand, cellar dirt, and
industrial, municipal, and agricultural waste discharged into water. 33 U.S.C. § 1362(6).
19. Wetlands are “those areas that are inundated or saturated by surface or ground
water at a frequency and duration sufficient to support, and that under normal circumstances do
support, a prevalence of vegetation typically adapted for life in saturated soil conditions.”
33 C.F.R. § 328.3(b) (1993).
20. Under the Clean Water Act, no person may discharge fill into wetlands that are
waters of the United States (also known as “jurisdictional wetlands”) without a permit—typically
issued by the United States Army Corps of Engineers (the “Corps of Engineers” or “Corps”)—
under Section 404(a) of the CWA, 33 U.S.C. § 1344(a). The Section 404 permitting program,
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 4 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 4 of 24
5
consistent with the purposes of the CWA, is intended to authorize the discharge of dredged or fill
material into wetlands only when, among other things, “it can be demonstrated that such a
discharge will not have an unacceptable adverse impact either individually or in combination
with known and/or probable impacts . . . .” 40 C.F.R. § 230.1.
II. The NPDES Permitting Program Under CWA Section 402
21. Similarly, the Clean Water Act prohibits any person from discharging pollutants
other than fill or dredged material to waters of the United States without a permit under Section
402 of the CWA, 33 U.S.C. § 1342(a). Section 402 authorizes EPA, under certain
circumstances, to issue a National Pollutant Discharge Elimination System (“NPDES”) permit
authorizing a person to discharge pollutants into waters of the United States. The CWA also
authorizes states to establish their own permitting programs. 33 U.S.C. § 1342(b). After a
state’s permitting program is approved by EPA, and subject to certain limitations, states may
issue their own NPDES permits pursuant to such a program.
22. New York State, through its Department of Environmental Conservation
(“NYSDEC”), administers such an approved permitting program, referred to as the State
Pollutant Discharge Elimination System (“SPDES”) permit program. Under Sections 309 and
402(i) of the CWA, the United States retains concurrent authority to enforce SPDES permit
violations. 33 U.S.C. §§ 1319, 1342(i).
A. Construction General Permits
23. Construction activity is one type of industrial activity for which associated
stormwater discharges require a permit under Section 402 of the CWA. Construction activity
includes “clearing, grading and excavation.” 40 C.F.R. § 122.26(b)(14)(x).
Case 7:19-cv-09600-AEK Document 3 Filed 10/18/19 Page 5 of 24 Case 7:19-cv-09600 Document 1 Filed 10/17/19 Page 5 of 24
6
24. The CWA regulates stormwater discharges from construction activities because
when there is precipitation, stormwater or snowmelt can wash over or flow through loose soil on
a construction site and pick up pollutants that are then discharged to rivers, streams, lakes, or
coastal waters.

   

     Who hurt you?

[Harness Racing Revolution]

49. In May and June of 2007, the Site was evaluated by defendant Ford’s
environmental consultants, Robert Torgerson and Peter Torgerson (collectively, “Torgerson”).
Torgerson acted as Ford’s agent for the purpose of this evaluation.
50. At the time that it performed its evaluation, Torgerson had a copy of the 1995
Jurisdictional Determination.
51. Torgerson documented the conclusions of its evaluation in a July 30, 2007 report
titled “Habitat Site Investigation and Report—Horse Training Facility—Mark S. Ford Stables,
Inc.” (“2007 Torgerson Report”).
52. According to the 2007 Torgerson Report, the Slaughter Road Site had 19.6 acres
of wetlands and a 1.188-acre pond in the center of the site.
53. Crystal Run Creek and the four wetland areas within the Slaughter Road Site, as
identified in the 1995 Jurisdictional Determination, are “waters of the United States” within the
meaning of Section 502(7) of the CWA, 33 U.S.C. § 1362(7).
iii. Ford Fills in Jurisdictional Wetlands Identified by His Contractors
54. Despite being on notice of jurisdictional wetlands at the Slaughter Road Site, as
described in both the 1995 Jurisdictional Determination (which at a minimum Ford’s agent
Torgerson had in hand) and the 2007 Torgerson Report, and without first obtaining a permit,
defendant Ford conducted, contracted for, supervised and/or otherwise controlled extensive
construction work at the Slaughter Road Site, and used mechanized land clearing and filling
equipment to fill in approximately 24 acres of the jurisdictional wetlands in or around 2007.
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55. Defendant Ford also conducted, contracted for, supervised and/or otherwise
controlled the straightening of significant portions of Crystal Run Creek on the northern half of
the Slaughter Road Site without first obtaining a federal permit. Specifically, in 2007, Ford
caused roughly 310 linear feet of creek bed along Crystal Run Creek to be straightened using
mechanized filling equipment. Also, in 2007, defendant Ford discharged approximately
150 linear feet of loose stone associated with the construction of the track bridges along Crystal
Run Creek below the ordinary high water mark.
56. In 2008, defendant Ford opened the Mark Ford Training Center as a 76-acre
facility for harness racing horses.
57. In a 2010 magazine interview, defendant Ford asserted that he moved “hundreds
of thousands of yards of dirt” to build his horse training center at the Slaughter Road Site, and
boasted that “[t]here’s not been a square inch of that acreage that a bulldozer hasn’t been across.”
58. Construction work at the Slaughter Road Site continued from 2011 through 2013.
During that time, defendant Ford caused roughly an additional 1,460 linear feet of creek bed
along Crystal Run Creek to be straightened without first obtaining a federal permit.
59. Aerial imagery of the Slaughter Road Site shows that in 2013, the original
channel of Crystal Run Creek was completely backfilled. On information and belief, the original
channel was filled with imported dirt and rocks and other waste material from a local highway
project.
60. Defendant Ford and the Ford Companies never sought or obtained authorization
from the Corps of Engineers for the filling of these jurisdictional wetlands and the rerouting and
filling of Crystal Run Creek.
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B. Defendants Filled Jurisdictional Wetlands and Straightened Streams at the
Ford Equine Site
61. The Ford Equine Site covers approximately 86.4 acres, and is located at 482/484
Stony Ford Road in the Town of Wallkill in Orange County, New York.
62. In September 2014, defendant Ford Equine, Ltd. purchased the Ford Equine Site
for the purpose of expanding the horse training facility. At all times relevant to this complaint
thereafter, defendant Ford controlled the Ford Equine Site and all activities relevant to this
complaint that occurred on the Ford Equine Site.
63. When defendant Ford Equine, Ltd. acquired the Ford Equine Site, a stream (the
“Ford Equine Site Stream”) flowed southward through the eastern portion of the site.
64. The Ford Equine Site Stream is a perennial tributary of the Wallkill River that has
physical indicators of an ordinary high water mark, including bed and banks. In 2016, after the
construction activities described in paragraphs 67 through 69, EPA confirmed that the portions of
the Ford Equine Site Stream that were upstream of the disturbed site had perennial flow, an
ordinary high water mark, including defined bed and banks, substrate sorting, and fish, benthic
algae, and macroinvertebrate s associated with perennial flow conditions. The Ford Equine Site
Stream flows southward from the site approximately 3,300 feet to the Wallkill River.
65. When defendant Ford Equine, Ltd. acquired the Ford Equine Site, the site had
four wetland areas, one of which (“Wetland A,” a jurisdictional wetland) abutted the Ford
Equine Site Stream. In 2016, after the construction activities described in paragraphs 67 through
69, NYSDEC excavated and sampled 21 pits in the eastern portion of the site in order to
characterize the soils beneath the fill material that has been placed there. NYSDEC determined
that in some of the test pits, the soils beneath the fill material were saturated with groundwater,
indicating that potential wetland hydrology was present in those locations before the construction
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activities. Based on evidence that included NYSDEC’s findings and pre-2016 satellite imagery,
Wetland A comprised approximately 2.27 acres before defendant Ford’s construction activities.
66. The Ford Equine Site Stream and Wetland A at the Ford Equine Site are “waters
of the United States” within the meaning of Section 502(7) of the CWA, 33 U.S.C. § 1362(7).
67. Beginning in spring 2015 and through February 2016, Ford began extensive
construction work on the Ford Equine Site using mechanized land clearing and filling equipment.
68. Defendant Ford caused approximately 900 linear feet of the Ford Equine Site
Stream to be filled and he rerouted the steam around the eastern corner of the Ford Equine Site.
As a result of defendant Ford’s construction activities, the Ford Equine Site Stream now flows
southeast and then southwest along the perimeter of the Ford Equine Site before returning to its
original path to the Wallkill River.
69. Defendant Ford’s construction work on the Ford Equine Site caused fill material
to be discharged into most of Wetland A at the site. The fill consisted of, among other things,
construction and demolition material, brick, concrete, asphalt, dirt, stone, glass, wood, and
gravel.
70. Defendant Ford and the Ford Companies never sought or obtained authorization
from the Corps of Engineers for the filling of the Ford Equine Site Stream and for Wetland A at
the Ford Equine Site.
II. Mark Ford Stage Road Property Violated Its Construction General Permit at the
Slaughter Road Site
71. Defendants Ford and Mark Ford Stage Road Property, Inc., sought coverage
under the Construction General Permit, and on or about January 19, 2016, they were authorized
by NYSDEC, in accordance with SPDES Permit number NYR11A294, to discharge stormwater
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from the ongoing construction activities at the Slaughter Road Site in compliance with the terms
of the permit.
72. Therefore, as of January 19, 2016, defendants Ford and Mark Ford Stage Road
Property, Inc., were required to comply with the Construction General Permit—specifically,
Permit No. GP-0-15-002—until all construction activities at the Slaughter Road Site were
completed and NYSDEC had approved a request to terminate coverage.
73. On November 29, 2016, EPA conducted an inspection at the Slaughter Road Site
to determine whether defendants Ford and Mark Ford Stage Road Property, Inc., were in
compliance with the Construction General Permit. EPA identified several areas of
noncompliance.
74. First, EPA observed unstabilized stockpiles of soil and mulch in the southwest
portion of the Slaughter Road Site that lacked the erosion and sediment controls required by Part
I.B.1.a of the Construction General Permit, thereby causing runoff from the piles and other
unstabilized areas of the construction site to flow into Crystal Run Creek.
75. Second, EPA observed several areas of the Slaughter Road Site where a lack of
erosion or sediment controls caused turbid stormwater to flow into a catch basin and ditch/stream
tributaries in the southwest portion of the site that, in turn, flowed into Crystal Run Creek,
causing deposition or impairing the waters’ best uses, in violation of Parts I.B.1, I.D.1, and I.D.2
of the Construction General Permit.

[Harness Racing Revolution]

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[Detective Bonilla]

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[Harness Racing Revolution]

76. Third, EPA determined that from February 2016—when defendants Ford and
Mark Stage Road Property, Inc., notified the Town of Wallkill that it would commence
conducting monthly inspections of the construction site—to February 2017, defendants Ford and
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Mark Stage Road Property, Inc., failed to conduct the monthly inspections required by Part
IV.C.2.c of the Construction General Permit.
77. On or around January 26, 2018, defendants Ford and Mark Ford Stage Road
Property, Inc., through their consultant, submitted a Notice of Termination of the Construction
General Permit to NYSDEC, which NYSDEC approved on or about January 30, 2018.
Accordingly, while defendants Ford and Mark Ford Stage Road Property, Inc. are no longer
required to abide by the Construction General Permit, they are liable for civil penalties for their
violations of that permit through January 30, 2018.
III. Ford Discharged Animal Waste and Cleaning Agents Into Waters of the United
States
78. The Slaughter Road Site contains an operating horse training facility and stables,
and has six horse barns, three manure barns, a shop, a storage barn, and a training oval.
79. The Slaughter Road Site can house up to 330 horses at any one time.
80. Barns 1, 2, 3, 4, and 6 at the Slaughter Road Site each have four wash bays used
for daily horse cleaning that are clustered in the center of each barn. Barn 5 has two wash bays,
one on each side in the barn, as well as a swimming pool for horses in the center of the barn.
The wash water from the wash bays and the swimming pool water are discharged to a green pipe
behind and to the northeast of Barn 5. This pipe discharges to a 625-foot long ditch, which
connects to Crystal Run Creek.
81. The three manure barns at the Slaughter Road Site are used to store manure and
bedding from the barns, and to store clean sawdust from the Slaughter Road Site. Catch basins
in close proximity to the three manure barns discharge to a black corrugated pipe, which in turn
discharges to a ditch in the northeastern portion of the Slaughter Road Site. The ditch discharges
to Crystal Run Creek.
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82. The Slaughter Road Site composts some of the manure from the three manure
barns for future use as topsoil, and has a compost pile on the premises. The compost pile is on a
sloped hillside to the east of the storage barn, which is on the southeast side of the Slaughter
Road Site, and up-gradient of a catch basin that discharges to the southern portion of the
Slaughter Road Site.
83. The Slaughter Road Site also has approximately 25 paddocks where horses are
kept or exercised. Catch basins in the paddocks and in the adjoining areas on the northern
portion of the Slaughter Road Site discharge to the same black corrugated pipe near the three
manure barns. The pipe discharges to the ditch in the northeastern portion of the Slaughter Road
Site which, in turn, discharges to Crystal Run Creek.
84. The adjacent Ford Equine Site has a dirt track, some small barns, and parking
areas south of the dirt track.
85. The Ford Equine Site also has a compost pile. The majority of the composted
manure occurs on the Slaughter Road Site, while any excess manure is taken to the Ford Equine
Site. The sites use a common system for the disposal of waste.
86. The Ford Equine Site has a barn (the “Stony Ford Barn”) with one wash stall that
discharges wash water to an adjacent field to the east of the Stony Ford Barn. The Ford Equine
Site Stream runs behind and parallel to the tree line adjacent to the field.
87. On December 12, 2016, EPA conducted a CAFO inspection (“CAFO Inspection”)
at the Slaughter Road Site and the Ford Equine Site.
88. At the time of the CAFO Inspection, approximately 257 horses were stabled and
fed or maintained at the Slaughter Road Site, and seven horses were stabled at the Ford Equine
Site. In addition, the Ford Equine Site had a cow barn that housed approximately 18 cows.
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89. At the Slaughter Road Site, the horse wash water from the wash bays and/or stalls
at Barns 1, 2, 3, 4, 5, and 6, as well as the water discharged from the horse swimming pool in
Barn 5, flow through a pipe that discharges to a man-made ditch that discharges, in turn, to
Crystal Run Creek.
90. The EPA inspector observed that the wash bay area of Barn 5 had a white
container labeled “ORVUS WA Paste,” which is a shampoo used to wash horses. ORVUS is a
synthetic surfactant and wetting agent.
91. The EPA inspector further observed a considerable amount of manure stored in
uncovered areas outside each of the three manure barns at the Slaughter Road Site. The manure
was exposed to precipitation and had not been removed from those areas for five weeks before
the CAFO Inspection.
92. The EPA inspector observed catch basins located close to each of the three
manure barns at the Slaughter Road Site. The catch basins discharge to a black corrugated pipe,
which, in turn, discharges to a ditch in the northeast portion of the Site. The ditch flows into
Crystal Run Creek.
93. The EPA inspector also observed turbid flow entering the catch basin close to the
second manure barn at the Slaughter Road Site. Inside the catch basin near the third manure barn
at the Slaughter Road Site, the EPA inspector observed built-up sediments, hay, and foaming in
the top portion of the catch basin.
94. The Slaughter Road Site and the Ford Equine Site together constitute a “medium”
CAFO, as that term is defined under 40 C.F.R. §§ 122.23(b)(2) and 122.23(b)(6), because (1) at
the time of the CAFO Inspection, approximately 257 horses were stabled and fed or maintained
at both sites; (2) manure from the Slaughter Road Site and the Ford Equine Site use a common
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area or system for the disposal of wastes; and (3) wash water from horse wash bays and stalls in
Barns 1-6 and from the horse swimming pool in Barn 5 at the Slaughter Road Site is discharged
to waters of the United States through a man-made ditch that discharges into Crystal Run Creek.
95. On June 8, 2017, EPA sent defendant Ford an inspection report and directed Ford
and the Ford Companies to stop the discharge of wash water and swimming pool water from the
Slaughter Road Site; ensure that runoff from the manure barns is contained and does not flow
into waters of the United States; cover any piles of manure being temporarily stored outside of
barns; and obtain a CAFO permit from NYSDEC. To date, Ford and the Ford Companies have
not ceased these activities and have not obtained coverage under a CAFO Individual Permit or a
CAFO General Permi

[Pacer 2]

GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
By: TOMOKO ONOZAWA
Assistant United States Attorney
86 Chambers Street, 3rd Floor
New York, New York 10007
Telephone: (212) 637-2721
Facsimile: (212) 637-2686
E-mail: tomoko.onozawa@usdoj.gov
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------------- x
UNITED STATES OF AMERICA,
Plaintiff,
 -againstMARK FORD, MARK FORD STABLES, INC.,
MARK FORD STAGE ROAD PROPERTY, INC.,
and FORD EQUINE, LTD.,
Defendants.
:
:
:
:
:
:
:
:
:
:
:
COMPLAINT
19 Civ. 9600
----------------------------------------------------------------- x
1. The United States of America, by its attorney, Geoffrey S. Berman, United States
Attorney for the Southern District of New York, acting on behalf of the Administrator of the
United States Environmental Protection Agency (“EPA”), alleges for its complaint as follows:
NATURE OF THE ACTION
2. Defendants Mark Ford (“Ford”) and Mark Ford Stables, Inc., Mark Ford Stage
Road Property, Inc., and Ford Equine Ltd. (collectively, the “Ford Companies”) bulldozed over
two dozen acres of wetlands and rerouted streams while on notice that doing so was prohibited
by the Clean Water Act (the “CWA”), 33 U.S.C. §§ 1251 et seq. Ford and the Ford Companies
did this to build a dedicated horse racing training center with associated pastures on two
properties in Orange County, New York. As Ford has put it, “you like to have the [horse] track
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the way you want it, you want a barn the way you want it and you want some pavement to drive
on.” To make things “the way [they] want[ed] it,” Ford and the Ford Companies illegally filled
waters of the United States. They also violated a CWA stormwater construction general permit.
3. Ford and the Ford Companies have repeatedly violated section 301(a) of the
CWA, 33 U.S.C. §§ 1311(a), by running a concentrated animal feeding operation without a
permit, allowing wastewater to contaminate waters of the United States. These violations—
which include piping manure-laden wastewater directly from wash bays/stalls and a horse
swimming pool to a nearby stream—continue to the present day.
4. The United States brings this civil action under Sections 309(b) and (d) of the
CWA, 33 U.S.C. §§ 1319(b), (d), to obtain injunctive relief compelling Ford and the Ford
Companies to remove the unauthorized fill material from waters of the United States, to restore
the watercourses, and to cease their unpermitted discharges, and for civil penalties.
JURISDICTION AND VENUE
5. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1331, 1345,
and 1355, and Section 309(b) and (d) of the CWA, 33 U.S.C. § 1319(b) and (d).
6. Venue is proper in this District pursuant to Section 309(b) and (d) of the CWA,
33 U.S.C. §§ 1319(b) and (d) and 1395, because the events giving rise to the claims herein arose
in this District.
7. The United States has provided notice of the commencement of this action to the
State of New York pursuant to Section 309(b) of the CWA, 33 U.S.C. § 1319(b).
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PARTIES
8. Plaintiff is the United States of America on behalf of EPA.
9. Defendant Mark Ford (“Ford”) is an individual who owns property and regularly
conducts business in Orange County, New York. Ford is the president and sole shareholder of,
and controls, the Ford Companies.
10. Defendant Mark Ford Stables, Inc., is a corporation organized under the laws of
the State of New York, with its principal executive offices located at 410 Jericho Turnpike,
Jericho, New York 11753.
11. Defendant Ford Equine, Ltd., is a corporation organized under the laws of the
State of New York, with its principal executive offices located at 125 Stony Ford Road,
Campbell Hall, New York 10916.
12. Defendant Mark Ford Stage Road Property, Inc., is a corporation organized under
the laws of the State of New York, with its principal executive offices located at 125 Stony Ford
Road, Campbell Hall, New York 10916.
13. Defendants Ford, Mark Ford Stables, Inc., Ford Equine, Ltd., and Mark Ford
Stage Road Property, Inc., are each “persons” within the meaning of Section 502(5) of the CWA,
33 U.S.C. § 1362(5).
STATUTORY AND REGULATORY BACKGROUND
I. The Wetlands Permitting Program Under CWA Section 404
14. The CWA was enacted “to restore and maintain the chemical, physical, and
biological integrity of the Nation’s waters.” 33 U.S.C. 1251(a).
15. Section 301(a) of the CWA, 33 U.S.C. § 1311(a), furthers this goal by prohibiting
the “discharge of any pollutant by any person” to waters of the United States, “[e]xcept in
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compliance with,” among other things, permits issued under Sections 402 and 404 of the CWA.
33 U.S.C. §§ 1342, 1344. The “discharge of a pollutant” includes “any addition of any pollutant
to navigable waters from any point source.” 33 U.S.C. § 1362(12).
16. Navigable waters are “the waters of the United States, including the territorial
seas.” 33 U.S.C. § 1362(7). In turn, “waters of the United States” has been defined to include,
inter alia, all waters which are currently used, were used in the past, or may be susceptible to use
in interstate or foreign commerce; tributaries to such waters; and wetlands adjacent to the
foregoing waters. See, e.g., 33 C.F.R. § 328.3(a) (1993); 40 C.F.R. §§ 122.2 (1993).
17. A “point source” is defined as “any discernible, confined and discrete
conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete
fissure, container . . . [or] concentrated animal feeding operation . . . from which pollutants may
be discharged.” 33 U.S.C. § 1362(14).
18. As defined by Section 502(6) of the CWA, a “pollutant” includes, among other
things, dredged spoil, solid waste, sewage, biological materials, rock, sand, cellar dirt, and
industrial, municipal, and agricultural waste discharged into water. 33 U.S.C. § 1362(6).
19. Wetlands are “those areas that are inundated or saturated by surface or ground
water at a frequency and duration sufficient to support, and that under normal circumstances do
support, a prevalence of vegetation typically adapted for life in saturated soil conditions.”
33 C.F.R. § 328.3(b) (1993).
20. Under the Clean Water Act, no person may discharge fill into wetlands that are
waters of the United States (also known as “jurisdictional wetlands”) without a permit—typically
issued by the United States Army Corps of Engineers (the “Corps of Engineers” or “Corps”)—
under Section 404(a) of the CWA, 33 U.S.C. § 1344(a). The Section 404 permitting program,
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consistent with the purposes of the CWA, is intended to authorize the discharge of dredged or fill
material into wetlands only when, among other things, “it can be demonstrated that such a
discharge will not have an unacceptable adverse impact either individually or in combination
with known and/or probable impacts . . . .” 40 C.F.R. § 230.1.
II. The NPDES Permitting Program Under CWA Section 402
21. Similarly, the Clean Water Act prohibits any person from discharging pollutants
other than fill or dredged material to waters of the United States without a permit under Section
402 of the CWA, 33 U.S.C. § 1342(a). Section 402 authorizes EPA, under certain
circumstances, to issue a National Pollutant Discharge Elimination System (“NPDES”) permit
authorizing a person to discharge pollutants into waters of the United States. The CWA also
authorizes states to establish their own permitting programs. 33 U.S.C. § 1342(b). After a
state’s permitting program is approved by EPA, and subject to certain limitations, states may
issue their own NPDES permits pursuant to such a program.
22. New York State, through its Department of Environmental Conservation
(“NYSDEC”), administers such an approved permitting program, referred to as the State
Pollutant Discharge Elimination System (“SPDES”) permit program. Under Sections 309 and
402(i) of the CWA, the United States retains concurrent authority to enforce SPDES permit
violations. 33 U.S.C. §§ 1319, 1342(i).
A. Construction General Permits
23. Construction activity is one type of industrial activity for which associated
stormwater discharges require a permit under Section 402 of the CWA. Construction activity
includes “clearing, grading and excavation.” 40 C.F.R. § 122.26(b)(14)(x).
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24. The CWA regulates stormwater discharges from construction activities because
when there is precipitation, stormwater or snowmelt can wash over or flow through loose soil on
a construction site and pick up pollutants that are then discharged to rivers, streams, lakes, or
coastal waters.

       Who hurt you?   

[Zoomer]

It wasn't his family that hurt him that I could tell you........... but he has hurt his family........... A family member told me some woman Pam hurt him deeply... If that's the case he's taking his anger out on the horse people that never did anything to him... He's also not allowed on any race tracks who knows what happened there........ If only he would quit all this nonsense and get back with his family at least make an attempt.......... .

[Kirbys Ace]

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[Pacer 2]

It wasn't his family that hurt him that I could tell you........... but he has hurt his family........... A family member told me some woman Pam hurt him deeply... If that's the case he's taking his anger out on the horse people that never did anything to him... He's also not allowed on any race tracks who knows what happened there........ If only he would quit all this nonsense and get back with his family at least make an attempt.......... .

    Whoever hurt him really messed up his brain. Gotta feel sorry for him......

[firhill]

image upload site

 

[Zoomer]

    Whoever hurt him really messed up his brain. Gotta feel sorry for him......

somebody mentioned drugs……… perhaps that’s what happened to him……….. Let’s hope not.

[Harness Racing Revolution]

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