Family Guardian Angel #SaveAchilles with his best bud having a blessed day with his loving family German Shepherd

https://www.givesendgo.com/GHZ1R

We have declared an EMERGENCY FILING before the Seminole County Florida Circuit Courts respectfully requesting immediate relief to a matter concerning the life of Achilles, a devoted German Shepherd and family guardian who was acting in home defense to protect the young children entrusted to his care. Achilles was provoked into biting an unknown stranger who appeared at the doorway of the residence, where a 5-year-old boy had rushed to open the door under the mistaken belief that it was his nanny. In that critical moment, Achilles stepped forward prepared to sacrifice his life to shield the boy from the unknown stranger instinctively protecting the family 5-year old and an infant child present in the home. Seminole County Attorney Kate La Torre is prosecuting the case on behalf of Seminole County Animal Services (SCAS) who has issued an order for Achilles’ destruction, which could be carried out at any time following the “dangerous dog” hearing scheduled for July 25, 2025. 

DEATH is the only option being offered by Seminole County Officials. These government officials hide their racial bias toward the Hispanic owners and hide behind their discriminatory county policy against large breed dogs (which was declared unconstitutional by the Florida legislature in 2023). They offer only DEATH for incidents involving private home protection dogs, yet the government owned dogs are exempt from the same county policies. 

We have been informed by SCAS through counsel that the statutory defenses pertaining to provocation, the protection of the child and the home are not deemed persuasive to Seminole County Government Officials, rendering Achilles’ execution imminent and inevitable, absent judicial intervention from the Seminole County Circuit Courts. 

Achilles’ owners had furnished copies of a complaint to Seminole County Officials in advance of the filing and even offered a good faith settlement offer in which Achilles would be subjected to an advanced intense 4 week training program at the nation’s premiere dog training veteran owned facility BTS K9 in Fort Walton Beach, Florida. It would also include a component of home safety protocols that will be followed by the family to ensure public safety. The family of Achilles was advised that the complaint and accompanying evidence have not altered their determination to proceed with the destruction order. Judicial intervention stands as the sole means to preserve the life of this innocent and protective animal. 

Achilles Family, seeks immediate injunctive and declaratory relief to address the unlawful extended seizure and potential destruction of their beloved family dog. Without judicial intervention, the case poses a grave risk to not only to the life of Achilles but to all large – breed dogs serving as family pets and protection. Every medium to large breed family dog in every family home is at risk in Seminole County. Those at risk include retired law enforcement and former military service dogs living the end of their lives in a veteran home. Despite Seminole County’s discrimination toward German Shepherds, if Achilles had been owned by the government and had bitten an unknown stranger under the exact same circumstances, Achilles would have never ended up on death row as government owned dogs are exempted under FS 767.16( 1): 

“Any canine that is owned, or the service of which is employed, by a law enforcement agency, is exempt from this part.” 

The County Attorney, SCAS, and other pertinent government officials have been duly notified to preserve the life of Achilles for a behavioral assessment. As of this filing, Seminole County officials have failed to perform any behavioral assessments and have provided no justification for not doing so. Achilles is being held prisoner under physical and psychologically abusive conditions held in solitary confinement and forced to live in feces and urine and bloody gums. SCAS has failed to produce any records of veterinary care likely because they have targeted Achilles for death and this Seminole County government officials are not concerned about  bacterial infections, pain and suffering, and permanent psychological damage that war prisoners suffer when thrown into isolation and torture chambers. Achilles has been held by Seminole County since June 18, 2025. The end of his statutory 10-day quarantine period ended on June 28, 2025. Seminole County Animal Services government officials are subject to liability for constitutional due process, property interests, conversion and sanctions for spoliation if they move forward with the destruction of Achilles. Achilles is close to 5 years old and he grew up loyal in a loving household surrounded by a loving family with young children. Without the public’s voice to demand Achilles’ freedom he will never get to see his family again. Our office will not stop and will continue to fight through all levels of appeals and in every legal forum to preserve his life to ensure he has a chance to live with his family until God calls for him. 

YOU CAN TAKE ACTION RIGHT NOW by calling:  

(407) 665-0000 Seminole County Board of Commissioners clerk@seminoleclerk.org

and 

(407) 665-7521 Kate LaTorre klatorre@seminolecountyfl.gov 

Seminole County Attorney’s Office and demand the immediate release of Achilles to his trainers at BTS K9 (btsk9.com) 

Animal Services is holding Achilles prisoner on doggie Death Row at the Seminole Animal County Services Building. Time is running out. Seminole County has handed down Achilles’ death sentence and will put him on trial for his life on:  

Friday, July 25, 2025 at 9:00 am

Appeal of the initial determination finding Sufficient Cause to classify and recommend EUTHANASIA as a dangerous dog “ACHILLES” AD #478467; File No FL SC DD 17000154

Achilles trial on 

July 25, 2025 

9 am – 1 pm

Location of the special magistrate Sherry Sutphen presiding over the hearing at

Seminole County Board of County Commissioners 

The Cavalry Group (thecavalrygroup.com) has set up a legal defense fund for the long road ahead on appeal and is monitoring the animal abuses and suffering of Achilles at the Seminole County Animal Services: 

Please give, share, pray and peacefully protest this travesty of justice for Achilles who does not deserve to die for protecting his family and his home from an unknown stranger who suddenly appeared at the family’s doorstep.

(Continued until Monday, July 28, 2025)

(Post July 1, 2025 new law known as the “Pam Rock Act”)

Opening Statement at the Dangerous Dog Hearing:

Good morning, your honor. Assistant County Attorney Lanius and the citizens of Florida present in the hearing room and observing from their homes and businesses. 

My name is Alexander Penalta, and together with co-counsel, Gabrielle Alexa Penalta, we represent the appellants, Ida Ibarra- Rodriguez and Dr. Jose Jimenez. 

The evidence will show that Achilles, a five-year-old male German Shepherd has been wrongfully accused as a dangerous dog by Seminole County Animal Services and Seminole Sounty Officials. We are here today to appeal that designation under Florida Statute 767.12 and Seminole County Code Chapter 20, and to demonstrate by a preponderance of the evidence that Achilles is not a dangerous dog, but rather a loyal family protector who acted 

defensively in a chaotic moment to safeguard a five-year-old child from a perceived imminent threat. 

Your honor, this case arises from a single, isolated incident on June 18, 2025, shortly before 9:00 am, in the appellants’ home. The security camera video will show a bustling household with a crying infant facing medical distress and a distracted mother forced to multitask multiple children prior to the arrival of their nanny. 

The five-year-old child, expecting the family’s regular nanny who had been arriving for the previous two weeks prior to the incident at 9:00 a.m. in the security footage you will hear chaos in the background including the screams of an infant child. Mom immediately went to attend to the infant who was experiencing a gastric emergency. Her baby, who had been born premature and was struggling with medication and intestinal issues. 

The 5-year-old hearing the doorbell ring politely asked his mother if that was Manuela? “The nanny”. 

Mom looks up at the clock on the wall at that moment and confirms that its 9:00 am. 

Mom tells her little boy go ahead and let Manuela in. The little boy walks down the hall several feet from where mom was triaging the baby on the ground and Achilles calmly followed behind him toward the door. This is where security video #1 in evidence picks up with the boy opening the door to greet — what the boy and Achilles believed would be Manuela. 

And you will hear and see an analysis and you will be able to witness the actual event in real time along with our experts explanation of Achilles behavior. 

Video # 2 in evidence will show that continuation of the incident. the evidence will that Achilles immediately realized that it not Manuela and maneuvered himself between the boy and the unknown adult threat at the doorway less than a few feet from the boy. The little boy has realized to his and Achilles surprise that the boy had inadvertently opened the door to an unexpected and unknown stranger: an Amazon delivery driver wearing dark sunglasses, carrying multiple large packages in both arms advancing toward the threshold of the front door without caution. 

Achilles, had positioned himself protectively behind the door, and did not charge aggressively. instead, he maneuvered quietly to shield the child, and to assess the situation. 

The delivery drivers behavior elevated the threat level causing the back of Achilles hairs to stand up. Mr. Beplay will show that there was substantial competent evidence that Achilles was exhibiting clear signs of apprehension to the unknown stranger at the doorway 

and only responded defensively when the driver’s encroaching actions escalated the perceived threat even further: 

By direct eye contact through obscured eyes (staring down is a canine signal of aggression);

exhibiting a smile that bared teeth (a canine signal of aggression); 

and a failure to retreat toward her delivery vehicle despite ample opportunity and being the most reasonable choice in this situation. 

You will hear testimony from Byron Beplay of BTSK9 Training Facility that this was clearly a provoked defense of the 5 year old boy. 

Your honor, as you know, under Florida Statute 767.12(2)(a) and (b), a dog is exempt from dangerous designation if provoked or acting in defense of itself, the owner, or a family member. Here, a vulnerable child—from assault or threat. 

Video #2 will also show the driver’s behavior constituted and escalated the provocation. She stared down at the child and dog causing an additional defensive response, when she ran into the home, through the door’s threshold, after the initial defensive bite to disarm the unknown package, she trespassed even further into the home where the infant crying and visibly distressing Achilles even further rather than retreating toward her nearby vehicle parked at the curb. 

Achilles’ response was proportionate and defensive. The bites were to the arm and buttocks, not to the predatory targets like the face or throat and he immediately obeyed commands from Ms. Ibarra- Rodriguez, the mother, ceasing all action and allowing the safe resolution. the evidence will show that we will prove through competent, substantial evidence that this incident stems from human error and contextual chaos, not inherent aggressive viciousness. The video evidence “best evidence” will show Achilles actions were purely defensive in nature: raised with love and professional training from puppyhood. 

Over 15 affidavits from neighbors, caregivers, and friends— including Manuela the nanny and Kaitlin Kjellmann attest to Achilles calm, gentle nature, especially around children. The security footage in evidence, injury photos, and expert analysis will show the injuries do not meet the “severe injury” from punctures during a single engagement. 

Today, you will hear from the appellants, who will describe Achilles’ upbringing and the incident’s chaos. Our expert, Byron Beplay, a 15-year veteran in canine behavior, owner of BTS K9 dog training facility, former U.S. Army Ranger and kennel master, and twice-qualified in court as an expert witness will analyze the footage and explain canine communication cues, and affirm that handler error and provocation were the root causes. Mr. Beplay, who volunteers with veteran suicide awareness and trains law enforcement canines, has offered to assess and care for Achilles at his facility during the court proceedings at no cost to the county highlighting his belief in Achilles’ redeemable, non- dangerous temperament. 

your honor, the evidence will show that Seminole County’s premature designation and destruction order, issued without a pre- deprivation hearing or behavioral assessment, violated Florida 

constitutional due process and ignores the statutory defenses in FS 767.12 (2a and b). 

Not only that, the evidence will show that it sets a dangerous Florida precedent and specifically for the citizens of Seminole County that are subject to the arbitrary and capricious whims of Seminole County Government Officials. 

The evidence will show that Achilles is the victim of overzealous and sloppy investigations by Seminole County Animal Services – and is being falsely accused not once but twice. all family pets, especially large breeds, retired military and retired police dogs not exempted under FS 767.16(1) are living in Seminole County under grave risk of death. By the end of this hearing, the evidence will show, that the scales of justice will tip far beyond 51% in favor of Achilles who deserves to return home as the cherished guardian he is rather than becoming another statistical victim of Seminole County   animal services. Thank you, your honor. We are ready to proceed. 

YOU CAN TAKE STILL MAKE YOUR VOICE HEARD RIGHT NOW BY COMMUNICATING #SAVEACHILLES  

(407) 665-0000 Seminole County Board of Commissioners clerk@seminoleclerk.org

and 

(407) 665-7521 Kate LaTorre klatorre@seminolecountyfl.gov  Seminole County Attorney’s Office and demand the immediate release of Achilles to his trainers at BTS K9 (btsk9.com) 

Animal Services is wrongfully holding Achilles prisoner on Death Row at the Seminole Animal County Services Building. Time is running out. Seminole County has handed down Achilles’ death sentence and he is on trial for his life.   

Closing Argument at the Dangerous Dog Hearing

Your Honor, as we conclude this evidentiary hearing on July 28, 2025, under Florida Statute 767.12 and Seminole County Code Chapter 20, I ask you to reflect on the overwhelming preponderance of evidence presented today evidence that tips far beyond the 51% threshold required to reverse Seminole County’s arbitrary and capricious designation of Achilles as a dangerous dog and its unwarranted order for his destruction.

Achilles is not a menace to society; he is a devoted family guardian who, in a split-second of chaos, acted instinctively to protect a vulnerable five-year-old child from what he perceived as an imminent threat. To label him dangerous and sentence him to death would not only ignore the clear statutory defenses but also undermine the very purpose of these laws: to balance public safety with fairness, compassion, and due process. Moreover, it would perpetuate a culture of covert discrimination within Seminole County’s Animal Services Division, disproportionately targeting Hispanic and minority pet owners like the Ibarra-Rodriguez family—a Puerto Rican-born registered dietitian mother and Chief Orthopedic Surgeon father—while unfairly penalizing working breeds such as German Shepherds through flawed tools, biased enforcement, and the attempted misapplication of laws like the July 1, 2025 dangerous dog law PAM ROCK Act SB572 which utilizes the DUNBAR BITE SCALE to assess bite severity, potentially setting a Trojan horse precedent with statewide implications for families with protection or retired working dogs. 

The record clearly shows that the county knowingly tried to covertly proper account submit the entire notebook which in it was the Dunbar bite scale and SCAS activity notes which refers to a prior bite from 2022. The record clearly shows that the county’s two witnesses Investigator Fraher and Animal Services Division Chief Stronko  and even the Asst County Attorney admitted in open hearing today that they could use either law pre July 1and post July 1 2025 used the Dunbar bite scale in assessing a level 5 against Achilles and that they admittedly took into account into a 2022 frivolous incident to arrive at the LEVEL 5 conclusion in the dangerous dog designation. It was that finding that formed the basis of the appeal and is why we are here today in this room challenging the underlying basis of their findings.  

This case exemplifies broader principles of discrimination against German Shepherd breeds and their human owner who in this case are Hispanic. German Shepherds, historically bred for herding and protection, have been stigmatized as inherently aggressive due to stereotypes rooted in their use in military, police, and imperial contexts often as symbols of repression and racism. 

Breed-specific discrimination was so pervasive throughout FL’s history that the FL legislature finally banned it in 2023 and found it to be unconstitutional. Yet, German Shepherds face systemic bias through breed-specific legislation (BSL), insurance exclusions, and housing restrictions, forcing owners to choose between their beloved pets and necessities like homes or coverage. And now the discriminatory policies of breed specific legislation has reared its ugly head again in July 1, 2025 by the attempted use of a defective tool called the Dunbar Bite scale that was slipped back into Florida law under the Pam Rock act and has made its way into the July 9, 2025 dangerous dog designation and made its way into the activity card with the #A25-214546-1 as a priority level 5 card which was noted on 6/20/25. It’s clear from the facts and the history of this case that the County Attorney was using the Dunbar bite scale as the basis for holding Achilles in solitary confinement rather than letting him quarantine at home. Furthermore, on page 106 at the bottom of the activity card previously referenced it reads: “on 6/19/25 at 1425 that 3639 Arbordale loop arrived on scene and met with the owner of the bite dog Ida Ibarra P274073 and provided her with a statement to fill out an aggressive dog packet and a written warning for 20.51 that is due and by July 19, 2025. I also had her sign the home quarantine agreement regarding Achilles a 478467 which is up on June 28 2025 sign R Duddy DUDY”. Then you will see another entry card on June 20 2025 at 11:54: “we received photos of victims injuries and due to the severity and extent of their injuries the dog will need to be held for a dangerous dog investigation let owner know that we are required to impound and hold the dog by state law if they have further questions they can contact me James or Lauren signed M Fraher FRAHER”. 

This is clear proof of the discrimination that was applied and has been applied to Achilles. SCAS did not provide any competent substantial evidence by a medical doctor or by any document proving that the injury was severe. Springboarding off the Special Magistrate’s question to Byron Beply and Dr. Jose Jimenez regarding whether they saw the delivery drivers injuries in person at the time of the incident, neither side saw the injuries in person at any point in this investigation. Both of our witnesses stated that they did not need to see the injuries in person but that based on their training and experience, they could arrive at an opinion as to the severity of the injury and how the injury is going to heal in the future based on the photographs alone. Both Byron Beply and Dr. Jose Jimenez, qualified experts, stated this was NOT a severe injury.

SCAS’s witnesses are not qualified experts in the severity of the injury and whether the incident was provoked. Furthermore, because of SCAS’s discriminatory acts in using the July 1, 2025, standard, which is evidenced in SCAS’s own notes, Achilles has been thrown into solitary confinement, made to suffer, and forced to live on a bed of his own feces and urine. Achilles was not even given a towel, a blanket, or the toys that SCAS markets to the public, which you see when you walk into the door of SCAS. This is what is happening in the backroom where they hold alleged dangerous dogs during their investigations in solitary confinement, This is in stark contrast to the marketing that Seminole County government portrays to the general public on all of their social media platforms. When you walk into SCAS’s facility, it looks like you are checking into a hotel with toys in the front. 

The July 1, 2025 standard that SCAS used against Achilles is costing an innocent family guardian his life at the hands of an overzealous government County Attorney and Animal Services division. 

Studies show Breed Specific Legislation and breed bans disproportionately affect minority communities, where breeds like German Shepherds are more common among working-class or ethnic families for protection. Here, the Ibarra-Rodriguez family’s experience dismissal of their Hispanic surgeon’s testimony, ad hoc policies burdening their schedules, and rushed condemnation without assessment mirrors this pattern, raising civil rights concerns and highlighting how breed discrimination serves as a proxy for owner profiling.

At the heart of this injustice lies covert discrimination—subtle, indirect, and often insidious forms of bias that evade overt scrutiny but perpetuate inequality through patterns of seemingly neutral actions, policies, and institutional practices. 

Unlike blatant discrimination, which civil rights laws like the Fair Housing Act, Americans with Disabilities Act (ADA), and Title VII have largely curtailed since the 1960s, covert discrimination operates under the radar: it manifests in disparate treatment disguised as routine enforcement, selective application of rules, or reliance on biased tools that disproportionately harm protected groups, such as racial minorities or owners of certain breeds. As noted in civil rights analyses, including those from the U.S. Department of Justice and scholarly works on systemic racism, covert bias thrives in areas like housing, lending, and animal control, where enforcement disparities persist despite legal prohibitions often through inadequate oversight, cultural stereotypes, or “neutral” policies with discriminatory impacts. In the instant case before you, the July 1, 2025, legislation, which uses the Dunbar Bite Scale, reproduces the discriminatory policies that were deemed unconstitutional by the 2023 Florida legislature. The Pam rock act and Dunbar Bite scale was a BAIT AND SWITCH by the same forces that were destroying dogs through breed specific legislation in the past.

In animal services, this includes discriminatory assistance animal policies or breed-specific enforcement that parallels racial profiling, targeting minorities via proxy biases against “aggressive” breeds commonly owned by Hispanic, Black, or low-income families. Here, the principles are clear: covert discrimination violates equal protection under the Fourteenth Amendment and the Constitution of the State of Florida by creating unequal outcomes without explicit intent, eroding trust in institutions, and requiring courts to scrutinize patterns of conduct for cumulative evidence of bias.

In Achilles dangerous dog appeal, covert discrimination is evident not in a single overt act but in a pervasive pattern of subtle, cumulative behaviors by Seminole County officials, as detailed throughout the evidence and testimony. These include: 

(1) Leadership under County Attorney Kate La Torre demanding accountability yet failing to correct subordinates’ actions and pushing a malicious prosecution influenced by animal rights advocates to lead the charge in bringing back the unconstitutional breed specific legislative policies; 

(2) Attempted misuse of the Dunbar bite scale (level 5) against Achilles, implemented post-incident on July 1, 2025, only halted by Your Honor’s intervention; 

(3) Premature placement of “dangerous dog” signage on Achilles’ kennel; 

(4) Failure to produce the delivery driver as a live witness to testify, show injuries, and confirm the truth of her affidavit in English from a person who only speaks Spanish (might be written by PI lawyers); 

(5) Reliance on no substantial competent medical evidence, presenting only hearsay photos and records without expert counter-testimony; 

(6) Creation of post-incident signage to restrict access and prevent fair evaluation; 

(7) Falsely documenting a “prior bite” in kennel notes to influence the determination; 

(8) Ignoring the live testimony of Dr. Jimenez, a Hispanic chief orthopedic surgeon with expertise in bite injuries; 

(9) Dismissing the analysis of Mr. Beplay, a military veteran and nationally recognized dog behavior expert, and refusing to allow him to complete a temperament assessment of Achilles; 

(10) the July 9 dangerous dog designation which is the basis of this appeal, dismisses the testimony of Ida Ibarra Rodriguez who stated that Achilles was trained multiple times with multiple trainers being deemed as not dangerous, which was raised at the attorney conference, and which division chief Stronko knows (Achilles has been assessed multiple times and the trainers said he wasn’t aggressive as testified by Ms. Rodriguez) 

(11) Investigator Fraher’s internally inconsistent testimony, claiming reliance on videos not obtained until July 17, 2025, after his initial decision; 

(12)  Implementation of ad hoc, unwritten policies—such as limiting family visits to 20 minutes, three times weekly, between 9:00 a.m. and 5:00 p.m.—specifically burdensome for a surgeon’s schedule, with no existing manual and old ones discarded by predecessor Adam Leath; and 

(13) Fostering a broader “culture of death” propagated by Adam Leath, whose biased social media posts contaminated staff, spread statewide via NGOs like HSUS and ASPCA training local governments, and led to disproportionate targeting of minority-owned working breeds.

(Go into further about amazon driver not being here. Can’t testify that it’s her affidavit is correct, especially in English. Can’t discuss her injuries, her treatment, her current condition, or whether she wants him killed too)

These acts, when viewed collectively, reveal a systemic bias that disadvantages this Hispanic family, echoing broader civil rights violations in animal control where minorities face higher rates of pet seizures and euthanasia due to covert enforcement disparities.

Let us revisit the uncontroverted facts established through testimony, affidavits, video evidence, expert analysis, and the broader context of systemic issues revealed in this hearing:

On June 18, 2025, at approximately 8:00 a.m., the Ibarra-Rodriguez home was a whirlwind of typical family turmoil: an infant crying in distress due to medical issues, a mother multitasking to soothe the baby, and a five-year-old boy excitedly opening the door, expecting the family’s trusted nanny, Manuela, who arrives like clockwork at 9:00 a.m. Instead, an unfamiliar Amazon delivery driver appeared: a stranger in dark sunglasses obscuring her eyes, clutching multiple packages like foreign objects, towering, and staring down with a smile that, in canine language, is a sign of aggression.

Achilles did not lunge unprovoked as our expert Byron Beply so aptly described a truly aggressive dog might. No, Achilles did not fly out the door the frame-by-frame security footage shows him calmly positioning himself as a shield between the boy and this intruder, with raised hackles (piloerection) signaling apprehension, not malice. Only when the driver encroached further locking eyes and invading the threshold did Achilles respond with defensive bites: first to the arm to disarm the perceived threat, then to the buttocks as she trespassed deeper into the home instead of retreating to her truck mere steps away. As Achilles expert testified, Achilles actions were defensive, not predatory targeting non-lethal areas like the arm and buttocks, rather than the face or throat and stemmed from clear provocation cues, including direct eye contact and forward movement, which dogs interpret as threats.

This response aligns with standard delivery policies across services like FedEx, UPS, and the Postal Service, which instruct personnel not to exit vehicles or attempt delivery if a dog is present unless safety is confirmed by the owner. If no response is received, deliveries are rescheduled to minimize risk. Historically, drivers carried protective sprays, but modern practices emphasize disengagement—precisely what this driver failed to do, escalating the situation through her disregard for canine boundaries, akin to encroaching on a bear with cubs. (if Judge objects, say that’s the point, no amazon depo)

Florida Statute 767.12(2) explicitly shields dogs like Achilles from dangerous designation in precisely these circumstances. Subsection (a) states: “A dog may not be declared dangerous if the threat, injury, or damage was sustained by a person who, at the time, was unlawfully on the property or who, while lawfully on the property, was tormenting, abusing, or assaulting the dog or its owner or a family member.” Subsection (b) reinforces: “No dog may be declared dangerous if the dog was protecting or defending a human being within the immediate vicinity of the dog from an unjustified attack or assault.”

The driver’s actions were neither peaceful nor lawful under Seminole County Code Chapter 20’s definition of “unprovoked”—an attack on someone “acting peacefully and lawfully.” By advancing without caution, failing to disengage despite clear warning cues, and committing trespass into the home post-initial contact, the delivery driver provoked a protective response. As Mr. Beply testified, drawing from 15 years of bite analysis, seven and a half years operating BTS K9 (the largest facility of its kind on the Eastern Seaboard), and over 300 behavior modifications (40% involving German Shepherds, including severe aggression and animal reactivity cases), 90% of incidents stem from human or handler error. Here, the unexpected door-opening amid chaos and the driver’s societal-conditioned disregard for canine boundaries constituted such error. Mr. Beply’s expertise is unimpeachable: a twice-qualified Florida expert (never stricken), former U.S. Army Veteran and Kennel Master with 14 combat tours, including work with special forces and medics in Ukraine; certifications as STS K9 Master Trainer, Tarheel graduate in police decoy and bite work, APPO instructor; experience with DHS, TSA, police, military, and high-profile clients like Tucker Carlson and Jon Jones; and leadership as former Commander of the Florida State Guard Special Missions unit overseeing special operations canines statewide for Governor Desantis.

Mr. Beply clarified that Achilles’ actions were a single defensive engagement misinterpreted as “multiple bites,” with multiple puncture wounds from one bite due to the dog’s teeth, not separate attacks. The injuries do not rise to “severe injury” under Chapter 20: no broken bones, no disfiguring lacerations, just punctures and a laceration requiring treatment but not meeting the threshold of “severe” (e.g., broken bones, multiple bites, or disfigurement). Dr. Jimenez, a Hispanic chief orthopedic surgeon with personal knowledge of dog bites and extensive experience in bite-related injuries, corroborated this: the hospital did not call an orthopedic specialist, perform advanced procedures, or detain the driver long-term, all indicators of non-severe wounds that will heal without visible scarring. Seminole County presented no live medical testimony, relying solely on hearsay photos and records from non-experts (an investigator and manager lacking medical or wound analysis expertise), admitting their lack of qualifications, and failing to personally inspect the wounds or produce a doctor, thus falling far short of their burden of proof.

Achilles’ immediate obedience to Ms. Ibarra-Rodriguez’s commands—dropping to the ground and allowing resolution—underscores his trained, non-predatory nature. His history further demolishes any notion of inherent danger. Raised from puppyhood with intentional breeding for calm temperament, he underwent rigorous professional training at Central Florida K-9, graduating as a “star student” in socialization and obedience, with ongoing advanced off-leash enrollment. Prior to this incident, Achilles was evaluated in Seminole County and found not dangerous, yet the county inconsistently rushed to condemn him without conducting their own behavioral assessment despite multiple demands. Over 15 affidavits—from neighbors like Evonne Marcano-Nelson and Daniel Vazquez Henao, caregivers Manuela and Kaitlin Kjellmann, to friends Jayris Rivera Saldana and Yanira Ruiz paint a unanimous portrait: a gentle, obedient “Velcro dog” who thrives with children, never aggressive in crowds, walks, or visits. No prior bites, no complaints, only love and loyalty.

The mother, as handler, bears partial responsibility for control, but this was a unique, chaotic situation, not negligence. She has since taken every step to prevent recurrence: hiring Mr. Beplay for post-incident assessment and behavioral modification to address any concerns, demonstrating responsible ownership and remediation efforts that minimize future risk.

As Mr. Beplay affirmed: “Achilles is not a dangerous dog; he’s a devoted protector, and killing him would be an overreach.” Yet Seminole County rushed to condemn him without due process: no pre-deprivation hearing, no behavioral assessment despite multiple demands, and abusive post-quarantine conditions, solitary confinement on feces-strewn cement, bloody gums untreated, denied veterinarian care, and substandard diet risking gastric torsion—that violate Florida’s animal cruelty laws and basic husbandry.

Dr. Jimenez testified to feeling discriminated against, echoing his wife’s statement in evidence: special policies created barriers, knowing his hospital duties, while non-minorities often receive warnings or fair hearings. Mindy, our legislative expert and lobbyist at congressional and state levels, detailed the history of breed-specific legislation (BSL) deemed unconstitutional in Florida via SB 942 in 2023 as biased tools historically targeted breeds associated with Black and Hispanic communities (e.g., German Shepherds, pit bulls, Rottweilers) to marginalize minorities. Yet enforcement disparities persist, as in this case, where opinions from Hispanic professionals (Dr. Jimenez) and a veteran expert (Mr. Beplay) were neglected by SCAS in favor of unqualified personnel, suggesting this as a “test case” against a Hispanic family.

Designating Achilles as dangerous ignores the law’s intent: to target truly vicious animals, not family guardians reacting to provocation. Florida Statute 767 allows (“may”) euthanasia for dangerous dogs, taking precedence over Seminole County’s mandatory (“must”) under Chapter 20 where discrepancies exist. Exemptions under FS 767.16(1) for law enforcement and hunting dogs expose hypocrisy a hunting dog can maul without consequence during lawful hunts, yet Achilles faces death for defending a child.

Destruction under the false pretenses of Achilles being killed because he was falsely accused would devastate this family robbing children of their guardian, eroding public trust, and setting a chilling precedent for large-breed pets, reviving ideologically driven discrimination against working dogs. SCAS’s stated purpose of public safety disregards the emotional trauma to this young Hispanic boy, who may grow up believing he caused his best friend’s death. Instead, heed Mr. Beply’s offer: transfer Achilles without the dangerous dog designation to BTS K9 for assessment and care at the owners’ expense, ensuring safety without death. 

The preponderance weighs heavily in Achilles favor: provocation, defense, no severe injury, impeccable history especially with children and expert consensus. The undisputed evidence proves this WAS a provoked attack. Under Florida Statute 767.12(2)(a) and (b), Achilles is exempt.

Fraher – Destroyed his own credibility by making an internally inconsistent statement claiming that the two videos played a role in his final determination to issue the July 9 report of dangerous dog. 

Seminole County’s premature designation and destruction order on July 9, 2025, issued without due process or assessment, violates rights and ignores defenses. It sets a dangerous precedent for all family pets, especially large breeds like retired military dogs not exempted under FS 767.16(1). Competent substantial evidence has tipped the scales far beyond 51% in Achilles’ favor.

Achilles deserves to return home as the cherished guardian he is—not face an unjust death. On behalf of the family and all who defended him, we ask that you reverse the designation, vacate the order, and allow Achilles to rehabilitate with Byron Beplay at BTS K9 in Fort Walton Beach after enduring inhumane conditions under Seminole County custody.

Mindy Patterson of The Cavalry Group (TCG), an animal welfare stakeholder testified that under state law TCG has oversight concerns in the manner SCAS is applying the new legislation in this incident and all others beginning July 1, 2025 (and our clients demands for equal ad fair treatment runs concurrent)

Fraher – Destroyed his own credibility by making an internally inconsistent statement claiming that the two videos played a role in his final determination to issue the July 9 report of dangerous dog. Yet, the County did not receive the videos until well after the July 9 report.

In conclusion, we ask that you Honor consider reversing the July 9, 2025 dangerous dog designation and return Achilles to his family. 

Achilles is home again with his family for a brief time and will be spending time receiving additional training under the direction of expert k9 trainer Byron Beplay of BTS K9 where he will be recovering from the abuse and trauma of solitary confinement that Achilles had endured at the hands of the SCAS staff and Seminole County Attorney Kate LaTorre.

The Penalta Law Firm and The Cavalry Group thank all who prayed for Achilles, supported the family, shared Achilles story and voiced their concerns for Achilles welfare. Your prayers, your care and concern and your voice all contributed to Achilles finally being reunited with his family.

Subject: Achilles Comes Home – A Victory for Justice and Compassion September 26, 2025

Dear Friends and Supporters,

We are proud to share that Achilles was rescued from the animal abusers at the Seminole County Animal Services in Sanford, Florida and has returned home safely to his loving family. After a long and difficult legal battle, Achille’s owners have chosen to conclude this case with a Voluntary Dismissal Without Prejudice. The Seminole County appointed Special Magistrate declined to amend her prior order even after obtaining evidence of an intense 4 week behavioral assessment and graduation certificate of completion demonstrating that Achilles is not a dangerous dog. We will be concluding the companion Seminole County Circuit Court case  the outcome we fought for together has been realized: Achilles is alive, successfully graduating from behavioral  training proving he is not a public safety threat, and he has reunited with those who love him.

This victory is more than the story of one dog. It is a testament to the power of teamwork, dedication, and courage in the face of adversity. When others coward away fearing government and media retaliation, Achilles’ owners, the family and the entire legal team stepped forward into the line of fire. Their courage and dedication ensured that Achilles was given the chance to prove Achilles was acting in self defense and defense of the family and home and Achilles did so with distinction — successfully completing an intensive training program and demonstrating the loving temperament his family and friends always knew he had.

This case highlights the harsh reality of recent legislative changes that encourage aggressive enforcement of “dangerous dog” laws, Florida Statute 767 which will result in statewide genocide for dogs that have been involved in protecting their family and the home. Yet it also demonstrates the power of perseverance and advocacy. Achilles’ survival and return are a direct result of the combined efforts of his devoted family, our legal team comprising of Decorated Army Ranger Veteran Byron Beplay and the world-class trainers at BTSK9 (www.BTSk9.com), and the tireless legislative advocacy of Mindy Patterson and The Cavalry Group (www.thecavalrygroup.com).

Because of this extraordinary team effort, Achilles is home. This case reminds us that with perseverance and compassion, even against the toughest odds, life can triumph.

Congratulations and heartfelt thanks to everyone who stood in the gap for Achilles and fought hard to save an innocent home protector from canine prison and out of the hands of his executioners. Mission accomplished.

With gratitude,
Alexander Penalta and the Legal Team

The Cavalry Group (www,thecavalrygroup.com) and The Penalta Law Firm will lead the fight to amend the legislation to strike troubling parts of the July 1, 2025 law which includes the defective Dunbar Bite Scale and the vague and ambiguous language that will lead to the systemic, mass killing of dogs throughout Florida. It will place your family dog at risk of mandatory death at the hands of indoctrinated government bureaucrats carrying out animal rights extremist policies to eliminate private dog ownership, Visit The Cavalry Group today and join us in this fight to preserve the constitutional right of Floridians to raise and keep working breed dogs and family protection dogs,