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Judgment.
Animal Care Program received a complaint from the Humane Society of the
Defendants to:
Electronically Filed - Sullivan - May 23, 2017 - 12:16 PM
a. Comply with the Animal Care Facilities Act (ACFA) and its
Consent Judgment;
Judgment;
Electronically Filed - Sullivan - May 23, 2017 - 12:16 PM
g. Allow the Department to enter Defendants place of business
h. Attain total compliance with the rules and standards set forth
ACFA-covered activity.
Defendants property.
more than three intact female dogs, a violation of the ACFA, and the terms of
the Amended Consent Judgment. See 273.342. 1 RSMo.; see also Amended
she occasionally bred her dogs and sold puppies, which, given the number of
Judgment and a violation of the ACFA. See 273.342.1 RSMo.; see also
that the puppy was a French Bulldog sired by Hill Top Pirate Johnny and
a minimum: (1) failing to comply with the ACFA and its implementing
more intact females during the time they were prohibited from doing so
under the Amended Consent Judgment; (3) failing to allow the Department to
take photographs during the site visit for the purpose of documenting care,
conditions, and compliance with the Amended Consent Judgment; and (4)
failing to attain total compliance with the rules and standards set forth in the
Consent Judgment and yet continued to willfully disobey this Courts orders.
Judgment is calculated to defeat the rights of the State of Missouri and the
Electronically Filed - Sullivan - May 23, 2017 - 12:16 PM
authority of this Court.
WHEREFORE, the State requests that this Court issue its Order that
Defendants appear and Show Cause why they should not be adjudged in
contempt of court.
appropriate per diem fines against Defendants, and enter such Judgment of
Judgment. The State also asks that if this Court chooses to enter a
Judgment of Contempt against Defendants, that the Court order the parties
Respectfully submitted,
Joshua D. Hawley
Attorney General
/s/Shawna M. Bligh
Shawna M. Bligh
Assistant Attorney General
Missouri Bar #56079
P.O. Box 861
St. Louis, Missouri 63188
Phone: 314-340-7834
Email: Shawna.Bligh@ago.mo.gov
I hereby certify that a copy of the foregoing was served via Federal
Charles Stephenson
Diana Stephenson
26185 Cheynne Drive
Milan, Missouri 63556
/s/Shawna M. Bligh
Electronically Filed - Sullivan - May 23, 2017 - 12:16 PM
Electronically Filed - Sullivan - May 23, 2017 - 12:16 PM