Florida Departments Busines Professiorial wack Regulation Ken Lawson, Secretory PAGE 7 RE: CASE NUMBER 2014017963 DIVISION OF ALCOHOLIC BEVERAGES AND TOBACCO PETITIONER, VS, LIQUOR GROUP FLORIDA LLC D/B/A LIQUOR GROUP FLORIDA LLC LICENSE NUMBER WSL2608174 SERIES KLD RESPONDENT ADMINISTRATIVE COMPLAINT Comes now, the Division of Alcoholic Beverages and Tobacco, herein after referred to as “petitioner,” and files this administrative complaint against tQUOR GROUP FLORIDA LLC herein after referred to as “respondent,” and alleges: 1. Petitioner is the state agency charged with supervising businesses licensed under the Florida beverage, tobacco and tax, and tobacco products permit laws pursuant to sections 559.061, 561.07, 561.15, 561.19, 561.29, 561.501, 210.15, 210.16, 210.45, 210.50, 569.003, and 569.006, Florida Statutes. 2. Respondent Is, and has been at all times material hereto, the holder of a valid license/permit, issued in the State of Florida, by the Division of Alcoholic Beverages and Tobacco, Respondent's last known mailing address is as follows: LIQUOR GROUP FLORIDA LLC D/B/A LIQUOR GROUP FLORIDA LLC 4600 TOUCHTON RD #1150 JACKSONVILLE, FL 32246 | | | And the division has not been notified of any other designated person or address for the service of process and notices authorized by Rule 61A-2.012, Florida Administrative Code. 3. Petitioner intends to revoke; suspend; annul; impose civil penalties, investigative costs, and late penalties; or any combination of these authorized penalties. This intended action is based on the below described facts or conduct. 904.727.5550 4161 Carmichael Avenue www.MyFloridaLicense.com 3300 Bidg., Suite 200A License Efficiently. Regulate Fairy. Jacksonville FL 32207 Florida Departmente , Office of the General Counsel i P Michael Ross, Chief Attomey Busi n es Division of Alcoholic Beverages and Tobacco Professi ral 1940 North Monroe Street, Suite 42 f] Tallahassee, FL 32399-2202 Regulation Phone: 850.717.1245+ Fax: 850,488.5074 Ken Lawson, Secretary Rick Scott, Governor PAGE 8 RE: CASE NUMBER DIVISION OF ALCOHOLIC BEVERAGES AND TOBACCO Vs. LIQUOR GROUP FLORIDA LLC D/B/A LIQUOR GROUP FLORIDA LLC LICENSE NUMBER WSL2608174 SERIES KLD You, LIQUOR GROUP FLORIDA LLC, D/B/A LIQUOR GROUP FLORIDA LLC, are charged with the following count(s): 1. On or about June 1, 2012 to August 1, 2014, the aforementioned licensee holding a license as an alcohol distributor or exporter, maintained a nuisance on the licensed premises, that exposed AB&T, Liquor group, City employees in the furtherance of their duties, employees, business invitees and other visitors to dangerous and unhealthy conditions at the primary warehouse location at 1431 W 16" Street, Jacksonville, Florida, this act being contrary to and in violation of Section. 561.29(1)(c), Florida Statutes. . On or about October 1, 2013 to August 1, 2014, the aforementioned licensee holding a license as an alcohol distributor or exporter, maintained licensed premises that were unsanitary or net approved as sanitary by the City of Jacksonville, Municipal Code Enforcement, at the primary warehouse location at 1431 W 16" Street, Jacksonville, Florida, this act being contrary to and in violation of Section 561,29(1)(d), Florida Statutes. On June 1, 2042, the aforementioned licensee holding a license as an alcohol distributor or exporter, refused to admit alcoho! enforcement officers to inspect the alcohol located in rooms adjacent to the licensed premises by having walls of trash or debris erected to impede their efforts, at the primary warehouse location at 1431 W 16" Street, Jacksonville, Florida, this act being contrary to and in violation of 562.41(3), Florida Statutes. On or about June 1, 2012, November 20, 2012, May 31, 2013, September 27, 2013, November 27, 2013, May 31, 2014, and June 10, 2014, the aforementioned licensee holding a license as an alcohol distributor or exporter within this state, failed to maintain required records, this act being contrary to and in violation of Section 561.55, Florida Statutes. On or about November 30, 2012, May 31, 2013, September 27, 2013, November 27, 2013, May 31, 2014, and June 10, 2014, the aforementioned licensee holding a license as an alcoho! distributor or exporter within this state, failed to provide access to the records at the primary warehouse location at 1431 W 16" Street, Jacksonville, Florida, this act being contrary to and in violation of Section 561.41, Florida Statutes. On or about June 1, 2012, November 30, 2012, May 31, 2013, September 27, 2013, November 27, 2013, May 31, 2014, and June 10, 2014, the aforementioned licensee holding a license as an alcohol distributor or exporter within this state, failed to provide access to its alternate offices located within the state (address unknown), by establishing them as virtual offices without staffing, records, or hours of operation, this act being contrary to and in violation of Section 561.41, Florida Statutes. LICENSE EFFICIENTLY. REGULATE FAIRLY. WWW.MYELORIDALICENSE.COM { H ] i i i | 7. 10. 1 = 42. 13. On or about November 20, 2012, May 31, 2013, September 27, 2013, November 27, 2013, May 31, 2014, and June 10, 2014, the aforementioned licensee holding a license as an alcohol distributor or exporter within this state, failed to provide officers access to inspect inventory located at either the primary warehouse location at 1431 W 16" Street, Jacksonville, Florida or satellite offices located within the state, this act being contrary to and in violation of Section 561.41, Florida Statutes. On or about January 1, 2012 to August 1, 2014, the aforementioned licensee, holding a license as an alcohol distributor, failed to meet and maintain the qualifications of a licensed distributor by attempting to operate out of a condemned warehouse, failing to provide access to the alcohol transferred in and out of the warehouse, failing to maintain operating hours, and failing to provide access to records and inventory, these acts being contrary to and in violation of Section 561.411, Florida Statutes. On or about June 17, 2012, the aforementioned licensee, holding a license as an alcohol distributor, failed to maintain the records required to substantiate the claim that 403.92 gallons of wine were stolen from the primary warehouse location at 1431 W 16" Street, Jacksonville, Florida, this act being contrary to and in violation of Section 561.55, Florida Statutes. On or about September 30, 2012, the aforementioned licensee, holding a license as an alcahol distributor, failed to maintain the records required to substantiate the claim that 475.20 gallons of liquor and 118.80 gallons of wine were stolen from the primary warehouse location at 1431 W 16" Street, Jacksonville, Florida, this act being contrary to and in violation of Section 561.55, Florida Statutes. . On or about July 31, 2013, the aforementioned licensee, holding a license as an alcohol distributor, while operating without a bond and prohibited from making sales, failed to maintain the records required to substantiate the claim that 1235.52 gallons of liquor were stolen from the primary warehouse location at 1431 W 16” Street, Jacksonville, Florida, this act being contrary to and in violation of Section 561.55, Florida Statutes. On or about May 1, 2010, to August 1, 2014, the aforementioned licensees, or persons, corporate officers, stockholders or individuals with an interest in this license under the Beverage Law, to wit: Christopher John Eiras and Jason Bandy, conspired to violate the beverage code, this act being contrary to and in violation of Section 562.23, Florida Statutes. On or about June 2, 2012, to August 1, 2014, the aforementioned licensee, holding a license under the Beverage Law, or your agent(s), officer(s), servant(s), or employee(s), did, on the licensed premises or elsewhere while in the scope of employment, willfully and knowing made false entries into records required under the Beverage Law, to wit: you reported the total gallons of alcohol stolen from the primary warehouse location at 1431 W 16" Street, Jacksonville, Florida, exceeded both the reported total sales and the reported total inventory, the Monthly Liquor and Wine Reports, the responses to official requests for records and the responses to subpoenas issued on or about June 1, 2012 and on or about July 7, 2014, these acts being contrary to and in violation of section 562.45(1), Florida Statutes. i t | { | 14. On or about March 21, 2012 to August 1, 2012, the aforementioned licensee halding a license as an alcohol distributor or exporter, violated the provisions of the consignment sale provisions of the Federal Alcohol Administration Act, by failing to segregate the bailment alcohol in suitable enclosures, failing to allow ready access to the producer without consent of the distributor, failing to maintain adequate commercial records, and failing to transfer the alcohol by bona fide sale, these acts being contrary to and in violation of 27 U.S.C. § 205, United States Code. Signed this August 18, 2014 Explanation of Service: Date Served Received By. Personal Service By. Personal Service By. Service Location Certified Mail # *Attach Receipt if Served by Mail. William Spicola, Director Division of Alcoholic Beverages and Tobacco Lawrence Hayes Law Enforcement Captain (sign) (print).

Docket for Case No: 14-005295