Florida Departmentef Business) \O- 30%) Professional © @ | 0 @ Es, Regulation F sate be if PAGE 7 RE: CASE NUMBER 2009028549 4 oft mn 4}, DIVISION OF ALCOHOLIC BEVERAGES AND TOBACCO ape o0 PETITIONER, 46 Tp 0e VS. . . Nes f he CLUB PURPLE ICE INC. D/B/A CLUB PURPLE ICE/LONGSHRMEN LGE & PKG STORE LICENSE NUMBER BEV2300977 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 CLUB PURPLE ICE INC. 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: CLUB PURPLE ICE INC. D/B/A CLUB PURPLE ICE/LONGSHRMEN LGE & PKG STORE 728 NW 79TH STREET MIAMI, FL 33150 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 administrative fines, 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 52 Terrace, Suite #303 www. MyFloridaLicense.com 305.470.6763 Doral FL 33166 License Efficiently. Regulate Fairly. BusinessA ® ® @ @ Professional Regulation cna ctes Sovernt PAGE 8 RE: CASE NUMBER 2009028549 DIVISION OF ALCOHOLIC BEVERAGES AND TOBACCO VS. CLUB PURPLE ICE INC. D/B/A CLUB PURPLE ICE/LONGSHRMEN LGE & PKG STORE LICENSE NUMBER BEV2300977 You, CLUB PURPLE ICE INC., D/B/A CLUB PURPLE ICE/LONGSHRMEN LGE & PKG STORE, are charged with the following count(s): 1. On or about __05_/_01__/2007__, 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: (Darrell Keith Wilson and Norman Moodie), did unlawfully on your licensed premises or elsewhere while in the scope of employment, conspire to violate the Beverage Law, (FSS 562.12(1) and 61A- 3.017), and commited an act to effect the object of the conspiracy, to wit: (Wilson entered into an unlawful agreement with Moodie to lease the licensed premises to include the licensing which allowed Moddie the intent to sell alcoholic beverages without a license violating FSS 562.12(1)), this act being contrary to and in violation of section 562.23, within 561.29(1)(a), Florida Statutes. 2. On or about ___06_/_11__/2007__, 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: (Darreil Keith Wilson and Norman Moodie), did unlawfully on your licensed premises or elsewhere while in the scope of employment, conspire to violate the Beverage Law, (FSS 562.12(1) and 61A- 3.017), and commited an act to effect the object of the conspiracy, to wit: (Wilson entered into an unlawful agreement with Moodie to lease the licensed premises to include the licensing which allowed Moddie the intent to sell alcoholic beverages without a license violating FSS 562.12(1)), this act being contrary to and in violation of section 562.23, within 561.29(1)(a), Florida Statutes. 3. On or about ___05_/ 01_/2007__, you, the aforementioned licensee, holding a license under the Beverage Law, did fail to manage and control all business conducted on the licensed premises, to wit: (Norman Moodie -100% Control), this act being contrary to and in violation of rule 61A- 3.017(1), Florida Administrative Code, within section 561.29(1)(a), Florida Statutes. 4. On or about __03_/_11__/_1997_, you, (Club Purple Ice Inc.), d/b/a (Club Purple ice/Longshrmen Lge & Pkg Store), did fail to maintain the requirements of your licensed premises in a active manner to wit: (having a valid Miami-Dade County Zoning Certificate of Use & Occupancy) to allow or permit alcoholic beverages to be sold, consumed, served or permitted to be served or consumed contrary to and in violation of section 561.15(3), within 561.29(1)(a), Florida Statutes. 8240 NW 52 Terrace, Suite #303 www. MyFloridaLicense.com 305.470.6783 Doral FL 33166 License Efficiently. Regutate Fairly: Hlotida Departments Busines @ 86 @ @ Professi ral Regulation onan amie cath Sov 5. On or about __ 05 / 01_/ 2007_, you, the aforementioned licensee, or your agent(s), officer(s), servant(s), or employee(s), to wit: (Darrell Keith Wilson), 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. 6. On or about ___05_/ 01_/_2007_, you, the aforementioned licensee, holding a license under the Beverage Law, did unlawfully change the name of the licensed place of business, to wit: (VIP/CAT), without first giving the Division 30 days’ notice in writing of such change, this act being contrary to and in violation of section 5614.33(2), within 561.29(1)(a), Florida Statutes. Signed this October 29, 2009 Debi Pender Interim Director ! Division of Alcoholic Beverages and Tobacco Priscilla Turner ; Law Enforcement Captain Explanation of Service: Date Served Received By. Personal Service By. Certified Mail # Attach Receipt if Served by Mail. 470. 8240 NW 52 Terrace, Suite #303 www. MyFloridaLicen: com 305.470.6783 Doral FL 33166 License Efficiently. Regulate Fairly.

Docket for Case No: 10-003099