The contents of the sealed complaint that led to last week’s raid by U.S. Marshals of Brunkow Cheese of Wisconsin Inc., located near Darlington, were made public after the cheese products were seized by the government.

The complaint details in writing and with more than a dozen photographs just how bad the rodent infestation problem was and how recently it was documented by federal inspectors (May 10).

“Rodents may transmit disease-causing strains of pathogenic microorganisms to human beings in this manner, and may spread diseases such as leptospirosis, plague, and murine typhus,” the complaint says.

Rodent excreta pellets established that cheese was being held in insanitary conditions “whereby they likely have become contaminated with filth,” the complaint added.

The last comprehensive inspection of Brunkow Cheese was conducted from Feb. 14 through Feb. 25, 2011 and it “revealed evidence of widespread rodent infestation.” Rodents were getting into the cheese facility in part because of building defects, including gaps in exterior doors and holes leading to the outside, FDA said.

FDA returned on April 22 and concluded Brunkow Cheese had taken some corrective actions, including repairs to the roof, doors, and exterior walls, but still had not resolved the rodent contamination problem.

One example cited in the complaint was that a rodent carcass first observed in Februar had not been removed in April.

Photos were provided to the U.S. District Court for Western Wisconsin that show rodent bite marks on cheese packages in the Brunkow Cheese retail store, gnawed cheese, rodent excrement on cheese packages, and pieces of old cheese, filth and apparent rodent pellets scattered on the floor.

The court ordered a “warrant of arrest for the defendant articles of food,” which included all cheese products held in the facility except those in the aging room.