AFFIDAVIT AND REQUEST FOR SEARCH WARRANT
TO ANY JUDGE OF THE DISTRICT COURT OR JUSTICE OF THE PEACE:
I, Philip A. Dugas, being first duly sworn on oath, state as follows:
That I am a duly sworn officer with the Maine Warden Service;
That I have probable cause to believe, that presently located within the residence
and upon the premises and place of business of Bob and Julie Miner, DBA DEW Animal
Kingdom; said residence, premises, and place of business being located on Rte. 41 in Mt.

Vernon, Maine, County of Kennebec; said residence and premises being more fully
described as a single family modified cape cod style residence, gray in color, with
maroon trim; and attached barn, red in color, and several outbuildings and animal cages
and enclosures; the entire property is surrounded by a chain link fence and several species
of wildlife and other animals are visible from Rte.,41; there is a sign located on a gate at
the entrance to the property that reads DEW Animal Kingdom; said residence and
premises is located adjacent to the Echo Lake boat launch facility on Rte. 41 in the Town

of Mt. Vernon; a second facility is located on Rte. 41 in the Town of Mt. Vernon, 1.1
miles in a northerly direction on the east side of Rte. 41; and is more fully described as an
enclosed area of several acres with a chain link fence and/or a wooden fence enclosing

the perimeter and containing many animal pens, exhibits, enclosures, and outbuildings; a
brown sign with gold lettering on the Rte. 41 side of the enclosure reads DEW Animal
Kingdom and sanctuary, the facility is located 'across Rte. 41 from the intersection of the

Ithiel Gordon Rdd the said residence and premises and place of business are personally
known to Warden Investigator Philip Dugas of the Maine Warden Service, who will,
prior to the execution of this Search Warrant; show the above described residences,
premises, and place of business to law enforcement officers participating in the execution
of this Search Warrant; certain property and other non-testimorlial evidence, to wit:

1. Three (3) mountain lions and a sing-tailed lemur possessed in violation of 12

M.R.S.A., tj7371-3, 12 M,R.S.A., tj7237, 12 M.R.S.A., $7235-C, and 12
M.R.S.A.,tj 7235-D;
2. Copies of all business records, financial records, and conespondence of Bob and
Julie Miner, DBA DEW Animal Kingdom relating to the importation or purchase

of wildlife;
3. Originals and, or, copies of business bank account records showing receipt, transfer,
and, or, the disposition of monies paid by Bob and Julie Miner, DBA DEW Animal
Kingdom during the year 2001, including, but not limited to, checking and savings
account statements; check stubs; check books; cancelled checks; and deposit slips
for that period of time;

 4. Safes, security boxes, and file containers which might conceal the above described
property.

The above being seizable pursuant to Rule 41(b) of the Maine Rules of Criminal

Procedure.

The facts and circumstances, which lead your affiant to believe this, are as
follows:
Your affiant states that he is a Game Warden, working for the Bureau of
Warden Service, Maine Department of Inland Fisheries and Wildlife for
the past nineteen years. Your affiant presently is a Game Warden
Investigator working for the Investigations Division and has done so for
the past seven years. Your affiant is experienced with all types of wildlife
investigations including those pertaining to the possession and importation
of captive wildlife into Maine. Your affiant's participation in these
investigations has resulted in the apprehension, arrest, and conviction of
hundreds of fish and wildlife law violators.
Your affiant has been to the premises of Bob and Julie Miner, DBA DEW

Animal Kingdom to inspect the facility and records approximately a dozen
times. Your affiant is aware that the Miners are obligated to keep records
regarding the acquisition, disposition, and possession of wildlife kept in
captivity. Your affiant knows that the Miners have kept similar records in
the past. Your affiant believes that those records, if accurately kept,
would reveal the dates that wildlife was acquired by Bob and Julie Miner,

DBA DEW Animal Kingdom.

On November 16, 2001,
came to the Sidney Regional
Headquarters of the Maine Department of Inland Fisheries and Wildlife
where she related the following to Asst. Regional Wildlife Biologist Keel
Kemper.
.old Kemper that in November of 1999 she entered
the State of Maine with a mountain lion that she obtained fiom a facility in
Pennsylvania.
stated that she did not have a permit to import
or possess the mountain lion, as she was unfamiliar with Maine laws.
said that she sought the assistance of Bob and Julie Miner, DBA

 DEW Animal Kingdom.
asked the Miner's to house and care
for her mountain lion. According to
the Miner's instructed her
to say, if asked by personnel from the Maine Department of Inland
Fisheries and Wildlife, that the mountain lion was born in captivity at the
DEW facility in Mt. Vernon. In 2001,
was prohibited by
the Miner's from having contact with her mountain lion. Your affiant will
ask
to be present at the time of execution of the search
warrant so
can identify the mountain lion that she brought to
the DEW Animal Kingdom. Asst. Regional Wildlife Biologist Kemper
related all of the above information to your affiant subsequent to his
November 16, 2001, meeting with

Your affiant is familiar with the Maine statutes regarding importation and

keeping of wildlife. A permit is required to import wildlife into Maine, 12
M.R.S.A., tJ7237, A peimit is required to possess wildlife held in
captivity, 12 M.R.S.A., tJ7235-C. A permit is required to exhibit wildlife
for the purpose of attracting trade, 12 M.R.S.A., tt 7371-3. It is unlawful to
possess any wildlife in captivity with some exceptions. The mountain lion

described in paragraph 3 is not covered by any of the exceptions. Your
affiant was involved in and aware that the Maine Depattment of Inland

Fisheries and Wildlife cited Bob and Julie Miner, DBA DEW Animal
Kingdom, in 1998 for importing two black bears and a crested macaque

without a permit as well as for other violations of the rules for keeping
wildlife in captivity. At that time the Miner's permit to exhibit wildlife
was suspended. The Miner's were given a time certain to correct the

deficiencies and bring the DEW facility into compliance with the
regulations and statutes. The Miners made all the necessary corrections
and their permit.to exhibit wildlife was reinstated in Januaiy of 1999.
Your affiant has inspected the wildlife exhibition records of the Maine
Department of Inland Fisheries and Wildlife for Bob and Julie Miner for
the year 1999 that shows that the Miner's did not report acquiring a
mountain lion from any source. Your affiant states that during 1999 he
directly asked both Bob and Julie Miner where the new mountain lion
came from and they replied that it was born at their facility. Your affiant
now knows this statement to be false. The Maine Depattment of Inland
Fisheiies and Wildlife regulations for wildlife exhibits in 1999 required
the animals retained at a wildlife exhibit to be secured in a lawful manner
and that as evidence of such legal possession the receipted invoice, bill of
lading, or bill of sale shall be presented upon request. The Miner's had no
bill of lading or bill of sale and they gave false information to the Maine
Department of Inland Fisheries and Wildlife as to the source of a mountain
lion that was being exhibited at their DEW Animal Kingdom facility.

 Your affiant makes the following assertions: The Miner's were cited in
1998 for an illegal importation of two black bears and a macaque. Less
than a year after this citation the Miner's acquired a mountain lion that
was imported into Maine unlawfully. The Miner's knowingly and willfully
hid that fact from the Department by failing to disclose the source of the
mountain lion on a required document and made knowingly false
statements to your affiant when they were asked about the mountain lion.

On November 15, 2001, Julie'Miner applied for a permit to import two
mountain lions and a ring-tailed lemur. Mrs, Miner telephoned the main
office on State St. in Augusta and wanted the permits issued without a
prior inspection. Your affiant made contact with Mrs. Miner and stated to
Ms. Miner that I would not be able to inspect her facility for the purpose
of granting her importation permit request until December 10, 2001. Your
affiant told Mrs. Miner that all facilities are inspected before permits are
approved. Mrs. Miner told your affiant that she was going to import the
mountain lions and the lemur without first obtaining the necessary
impottation permit. Your affiant made it clear to Mrs. Miner that she
needed the importation permit before she acquired the animals. On
December 10, 2001, your affiant received telephone call from Julie Miner.
Mrs. Miner stated that she was not available at the residence that day due
to a prior engagement. Your affiant asked Mrs. Miner if she had
the two mountain lions and the ring- tailed lemur. Mrs. Miner told your
affiant that she had in fact imported the two mountain lions and the lemur.
Your affiant knows that no permit had been issued.

impo
sed

Your affiant seeks permission for personnel other than sworn law
enforcement personnel to accompany any officers executing this Search
Warrant. Your affiant states that there are no law enforcement officers of
the Maine Warden Service or any other law enforcement agency in Maine,
known to your affiant, that are qualified to handle a mountain lion an'd
transport it to another facility. Your affiant seeks permission to bring
wildlife biologists and/or wildlife technicians fiom the Maine Department
of Inland Fisheries and Wildlife to facilitate a safe acquisition of the
above-described mountain lions. Your affiant also seeks permission to
allow
to accompany law enforcement officers, also,
to facilitate safe acquisition of the above-described mountain lions. The
Maine Department of Inland Fisheries and Wildlife granted
a
permit to possess a mountain lion in captivity in April of 2002, In addition
is familiar with the specific above-described mountain lion
and is experienced in handling mountain lions, in general.
9.

Y ou r affiant has had this affidavit reviewed by Paul Rucha, Assistant
District Attorney. Mr. Rucha has been an Assistant District Attorney for
more than 12 years and has reviewed numerous search warrants.

 10.

You r affiant concludes from the above information that Bob and Julie
Miner, DBA DEW Animal Kingdom, currently possess three mountain
lions and a ring-tailed lemur that have been imported or acquired either

without proper permits or are being held in violation of fish and wildlife
regulations. Further, that on the premises there is documentation

regarding that importation which would be evidence of the illegal
acquisition.

WHEREFORE; in view of the foregoing, your affiant pray that a Search Warrant issue,
commanding your affiant and other duly sworn law enforcement officers and personnel

of the Maine Department of Inland Fisheries and Wildlife and other above named
individual to search the above described residence, premises, and place of business of

Bob and Julie Miner, DBA DEW Animal Kingdom, for the items which are listed above.

I, Philip A. Dugas, depose and state that all the information contained within this
affidavit is tmthful and accurate.

DATED' 8 D2

Phihp A. Du s
Warden Investigator
Maine Warden Service

SUBSCRIBED TO AND SWORN TO; BEFORE ME:

Judge, Maine District Court

A true copy,
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