CHARLESTOWN — The U.S. Department of Agriculture has filed a formal complaint against a wildlife sanctuary in Clark County that has been under investigation for months, alleging its owner physically abused animals and failed to get others proper care.

The complaint, filed last week by Kevin Shea, administrator of the Animal and Plant Health Inspection Service, or APHIS, lists more than 20 allegations in which refuge owner Tim Stark violated the Animal Welfare Act.

At last count, according to the complaint, Wildlife in Need housed 124 animals, including 25 primates and 97 wild or exotic mammals. The allegations in the complaint include "repeated interference with the and verbal abuse of APHIS inspectors, repeated failures to handle animals carefully, including physical abuse, and repeated failures to provide adequate veterinary care to animals."

In one instance, Stark allegedly "represented" to an inspector that Stark had euthanized a juvenile female leopard "by beating her to death with a baseball bat," in 2013, according to the complaint. APHIS also alleges Stark and Wildlife in Need "have continued to fail to comply with the minimum requirements" of the Animal Welfare Act, including holding "Tiger Baby Playtime" after inspectors suspended Wildlife in Need's federal license in September 2015. The regular event, referred to as a fundraiser, allows visitors to play with baby tigers and have their photos taken.

In a news release, People for the Ethical Treatment of Animals, or PETA, condemned the sanctuary.

"PETA is urging everyone to stay away from this scofflaw animal abuser," said Brittany Peet, foundation director of Captive Animal Law Enforcement for PETA. "This operation needs to be shut down and the animals retired to reputable sanctuaries, where they won't be beaten, denied veterinary care, and passed around as selfie props."

According to PETA the complaint "is the first step in a disciplinary process that could result in a fine of up to $10,000 per violation or a suspended or revoked license."

Stark, who has denied any wrongdoing in the past, was convicted of violating the Endangered Species Act in 2008, and is the respondent in a pending license termination proceeding, according to the complaint. He could not be reached for comment Thursday afternoon.

A January inspection report was released in June with some of the allegations found in the formal complaint. At the time, Stark told the News and Tribune that the report was all dramatics. The inspection came weeks after a fire killed 41 of the refuge's birds and reptiles.

"It's all a bogus report. We appealed it, but the other side — the USDA — is on an agenda to close down private owners," he said, adding that he is "100 percent in compliance" with federal guidelines.

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