Horida Department? Busines Professi Regulation Ec Scot, Gover PAGE 7 RE: CASE NUMBER 2012040322 DIVISION OF ALCOHOLIC BEVERAGES AND TOBACCO PETITIONER, VS. LAS 3K USA LLC D/B/A KUKARAMAKARA LICENSE NUMBER BEV2325966 SERIES 4COP RESPONDENT ADMINISTRATIVE COMPLAINT Comes now, the Division of Alcoholic Beverages and Tobacco, herein after referred to as “petitioner,” and files this administrative complaint against LAS 3K USA LLC herein after referred to as “respondent,” and alleges: 1. 305.470.6783 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. 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: LAS 3K USA LLC D/B/A KUKARAMAKARA 1270 S MIAMI AVE MIAMI, FL 33130 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. 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. 8240 NW $2 Terrace, Suite #303 www.MyFloridaLicense.com Doral FL 33166 License Efficiently. Regulate Fairly. Aorida Departmentof Busines Professiorial eceun Regulation Ken Lawson Secretary PAGE 8 RE: CASE NUMBER 2012040322 DIVISION OF ALCOHOLIC BEVERAGES AND TOBACCO VS. LAS 3K USA LLC D/B/A KUKARAMAKARA LICENSE NUMBER BEV2325966 You, LAS 3K USA LLC, D/B/A KUKARAMAKARA, are charged with the following count(s): 4. On or about 05 / 31__/11__, you, the aforementioned licensee, holding a license under the Beverage Law, or your agent(s), officer(s), servant(s), or employee(s), or other person(s) to wit: (Carlos J. Hernandez, Constanza Nino and Jairo Avellaneda), did unlawfully on your licensed premises or elsewhere while in the scope of employment, conspire to violate the Beverage Law, (FS 561.42 and FS 562.12), and commited an act to effect the object of the conspiracy, to wit: (Nino and Avellaneda own Marketing Global Brands Corp. which is licensed as a Distributor of alcoholic beverages and are the owners of Universal Beverage S.A. which hold 50% ownership of d/b/a Kukaramakara, 2325966, 4COP), this act being contrary to and in violation of section 562.23, within 561.29(1)(a), Florida Statutes. 2. On or about 03 /.06_/ 12__, you, the aforementioned licensee, holding a license under the Beverage Law as a (Marketing Global Brands Corp.), or your agent(s), officer(s), servant(s), or employee(s), did unlawfully acquire or obtain a direct or indirect financial interest in the establishment or business-of (Kukamaraka — 23-25966), this act being contrary to and in violation of section 561.42(1), within 561.29(1)(a), Florida Statutes. 3. On or about __03_/ 26/42 ___, you, the aforementioned licensee, holding a license under the Beverage Law as a manufacturer, distributor, or exporter, did unlawfully obtained a license or registration as a vendor, to wit: (Kukaramakara -2325966), this act being contrary to and in violation of section 561.22(1), within 561.29(1)(a), Florida Statutes. 4, On or about _03__/ 06__/ 12_, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Jairo A. Avellaneda), failed to submit to the Division of Alcoholic Beverages and Tobacco, a sworn application, before such person who has a direct or indirect financial interest in the license, engaged in the business of manufacturing, bottling, distributing, selling, or in any way dealing in alcoholic beverages on your premises licensed under the Beverage Law, this act being contrary to and in violation of section 561.17(1), within 561.29(1)(a), Florida Statutes. 5. On or about _03__/ 06__/ 12_, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Constanza Nino), failed to submit to the Division of Alcoholic Beverages and Tobacco, a sworn application, before such person who has a direct or indirect financial interest in the license, engaged in the business of manufacturing, bottling, distributing, selling, or in any way dealing in alcoholic beverages on your premises licensed under the Beverage Law, this act being contrary to and in violation of section 561.17(1), within 561.29(1)(a), Florida Statutes. 305.470.6783 8240 NW 52 Terrace, Suite #303 www. MyFtoridaLicense.com Doral FL 33166 License Efficiently. Regulate Fairly. Florida Department? Busines Professiorial Regulation - ack Soot, Govemer 6. On or about __03_ / 06_/ 12_, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Juan Ossa), failed to submit to the Division of Alcoholic Beverages and Tobacco, a sworn application, before such person who has a direct or indirect financial interest in the license, engaged in the business of manufacturing, bottling, distributing, selling, or in any way dealing in alcoholic beverages on your premises licensed under the Beverage Law, this act being contrary to and in violation of section 561.17(1), within 561.29(1)(a), Florida Statutes. 7. On or about -03__/ 06_/ 12_, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Nina Esquivel Cheliakova), failed to submit to the Division of Alcoholic Beverages and Tobacco, a sworn application, before such person who has a direct or indirect financial interest in the license, engaged in the business of manufacturing, bottling, distributing, selling, or in any way dealing in alcoholic beverages on your premises licensed under the Beverage Law, this act being contrary to and in violation of section 561.17(1), within 561.29(1)(a), Florida Statutes. 8. On or about __03__/ 06 _/ 12__, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Ghyska Avila), did fail to notify the division ofa transfer of 10 percent or more of any financial interest, a change of executive officers or directors, or a divestiture or resignation of such interest or position, in your business licensed under the Beverage Law, this act being contrary to and in violation of section 561.17(3), within 561.29(1)(a), Florida Statutes. 9. On or about __03__/ 06 _/ 12__, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Constanza Nino), did fail to notify the division of a transfer of 10 percent or more of any financial interest, a change of executive officers or directors, or a divestiture or resignation of such interest or position, in your business licensed under the Beverage Law, this act being contrary to and in violation of section 561.17(3), within 561.29(1)(a), Florida Statutes. 40. On or about __03_ / 06__/ 12__, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Jairo A. Avellaneda), did fail to notify the division of a transfer of 10 percent or more of any financial interest, a change of executive officers or directors, or a divestiture or resignation of such interest or position, in your business licensed under the Beverage Law, this act being contrary to and in violation of section 561.17(3), within 561.29(1)(a), Florida Statutes. 41, Onor about __03__/ 06_/ 12__, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Juan Ossa), did fail to notify the division of a transfer of 10 percent or more of any financial interest, a change of executive officers or directors, or a divestiture or resignation of such interest or position, in your business licensed under the Beverage Law, this act being contrary to and in violation of section 561.17(3), within 561.29(1)(a), Florida Statutes. 305.470.6783 8240 NW 52 Terrace, Suite #303 www. MyFioridaLicense.com Doral FL 33166 License Efficiently. Regulate Fairly. Horida Deparment? Busines Professional Regulation . at SE, Governor 12. On or about _03__/ 06__/ 12__, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Nina Esquivel Cheliakova), did fail to notify the division of a transfer of 10 percent or more of any financial interest, a change of executive officers or directors, or a divestiture or resignation of such interest or position, in your business licensed under the Beverage Law, this act being contrary to and in violation of section 561.17(3), within 561.29(1)(a), Florida Statutes. 13. On or about __03__/ 06__/ 12__, you, the aforementioned licensee, hoiding a license under the Beverage Law, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Carlos Hernandez) unlawfully keeps and maintains a licensed premises where alcoholic beverages are sold unlawfully, this act being contrary to and in violation of section 562,12(1), within 561.29(1)(a), Florida Statutes. 14. On or about __05_/ 31__/ 11__, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Ghyska Avila), did unlawfully sign under oath or affirmation, and falsely swore to or affirmed a material statement, to wit: (the 100% share holder of Universal Beverage S.A.), on your application for a license, this act being contrary to and in violation of section 559.791, within 561.29(1}(a), Florida Statutes. 15. On or about __03__/ 14__/ 13__, you, the aforementioned licensee, holding a distributor's license under the Beverage Law, or your agent(s), officer(s), servant(s), or employee(s), to wit: (any verbal and/or written agreement with MAG Miami for any derived revenues), to wit: (any derived revenues from Thursday night promotions at the licensed premises on 3/14/13), this act being contrary to and in violation of rule 61A-3.017(5), Florida Administrative Code, within section 561.29(1)(a), Florida Statutes. 46. On or about __02__/ 28 _/ 13__, you, the aforementioned licensee, holding a distributor's license under the Beverage Law, or your agent(s), officer(s), servant(s), or employee(s), to wit: (any verbal and/or written agreement with MAG Miami for any derived revenues), to wit: (any derived revenues from Thursday night promotions at the licensed premises on 2/28/13), this act being contrary to and in violation of rule 61A-3.017(5), Florida Administrative Code, within section 561.29(1)(a), Florida Statutes. 305.470.6783 8240 NW 52 Terrace, Suite #303 www. MyFioridaLicense.com Doral FL 33166 License Efficiently. Regulate Fairly. Florida Department? Busines Professiéral Regulation Kato Seat, Govemer Signed this April 18, 2014 Robert A. Douglas, Director Division of Alcoholic Beverages and Tobacco acl Law Enforcement Captain Explanation of Service: Date Served Received By Personal Service By. Certified Mail # Attach Receipt if Served by Mail. US, Postal Sarvicdmn 2) GERVIFIED D DA Rte RECEIPT i (Rameste Grell Cue Ro it a | Recieyiihiriin ior aiemaCmS | al OFFICIAL US E a Postage a+ o Cortfied Fee a Postmark S (Enaaroene meet Fee Here fi & Rastrcted Delivery Fea | ‘ (Endorsement Required) i | 4} Ri 4? m oO Oo 8240 NW 52 Terrace, Suite #303 www. MyFloridaLicense.com 305.470.6783 Doral FL 33166 License Efficiently. Regulate Fairly.

Docket for Case No: 16-005769