That would be true. As a kid, on a dairy farm, some of the cows could be milked in the paddock, anywhere, others needed a good "kick rope" firmly attached.
Never tried goats, sheep, or the latest one over here, Deer.
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We had mostly a good experience with milking our beautiful Belle, only if the flies/mosquitoes were bad did we have to worry about her kicking, but her tail had to be tied each time, that thing is dangerous when she flicks it. :D LOL. :D
I'm looking forward to seeing how our mom-to-be Princess does when we try to milk her, she's a good gal, but this will be her first baby and you never know how they'll react to being milked until you try. :D
Especially with little dried lumps in the fury ends.
If she is skittery I can see some bails being made over there soon.
That is so true. :D We try to clean their tails as well as their bellies and teats. :D