Alortda Department: puis rofessi Regulation Fie Sot, Gaver PAGE 7 RE: CASE NUMBER 2013001497 DIVISION OF ALCOHOLIC BEVERAGES AND TOBACCO PETITIONER, VS. PARADISE DINER INC. D/B/A PARADISE DINER LICENSE NUMBER BEV1615077 SERIES 2COP RESPONDENT ADMINISTRATIVE COMPLAINT Comes now, the Division of Alcoholic Beverages and Tobacco, herein after referred to as "patitioner,” and files this administrative complaint against PARADISE DINER 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 ficense/permit, issued in the State of Florida, by the Division of Alcoholic Beverages and Tobacco. Respondent's last known mailing address is as follows: PARADISE DINER INC. D/B/A PARADISE DINER 560 S DIXIE HWY POMPANO BEACH, FL 33060 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. Tel: 954.917.1346 5080 Coconut Creek Pkwy. www. MyFigridaLicanse.com Fax: 954.917.1957 ui License Efficiently. -Regulate Fairly. Margate FL 33062-3042 debra.nicoletti@myfioridalicanse.com Florida Depart Business) Professigrral sok sean Govene Regulation Ken Lawson, Secretary PAGE 8 RE: CASE NUMBER 2013001497 DIVISION OF ALCOHOLIC BEVERAGES AND TOBACCO VS. PARADISE DINER INC. D/B/A PARADISE DINER LICENSE NUMBER BEV1615077 You, PARADISE DINER INC., D/B/A PARADISE DINER, are charged with the following count(s): 1. On or about February 15, 2013 through February 18, 2013, you, the aforementioned licensee, holding a license under the Beverage Law, did unlawfully on your licensed premises, allow or permit your agent(s), officer(s), servant(s), or employee(s), to wit: Gloria Maidanado (employee), to beg or solicit a patron, customer, or visitor, te wit: Agent Juan Torres, to purchase a beverage, to wit: Corona Beer, for such agent, servant, or employee, this act being contrary to and in violation of section 562.131(1), within 561.29(1}(a), Florida Statutes. 2. On or about February 15, 2013 through February 16, 2013, you, the aforementioned licensee, holding a license under the Beverage Law, did unlawfully on your licensed premises, allow or permit your agent(s), officer(s), servant(s), or employee(s), to wit: Nancy Martinez (employee), to beg or solicit a patron, customer, or visitor, to wit: Agent Juan Torres, to purchase a beverage, to wit: Gorona Beer, for such agent, servant, or employee, this act being contrary to and in violation of section 562.131(1), within 561.29(1)(a), Florida Statutes. 3. On or about February 15, 2013 through February 16, 2013, you, the aforementioned licensee, holding a license under the Beverage Law, did unlawfully on your licensed premises, allow or permit your agent(s), officer(s), servant(s), or employee(s), to wit: Delmy Vaieriano-Valladares (employee), to beg or solicit a patron, customer, or visitor, to wit: Agent Juan Torres, to purchase a beverage, to wit: Corona Beer, for such agent, servant, or employee, this act being contrary to and in violation of section 562.131(1), within 561.29(1)(a), Florida Statutes. 4. On or about February 15, 2013 through February 16,2013, you, the aforementioned licensee, holding a license under the Beverage Law, or your agent(s), officer(s), servant(s), or employee(s), to wit: Elvia Castellon and/or Resa Castellon (licensees), did unlawfully on your licensed premises, alfow or permit the sale, possession, or consumption of an illegal controlled substance, to wit: cocaine, mdma (molly pills) and marijuana, this act being contrary to and in violation of section 893.13(1)(a), within 561.29(1)(a), Florida Statutes. §. On or about February 15, 2013 through February 16, 2013, you, the aforementioned licensee, holding a license under the Beverage Law, did untawfull allow or permit or maintain a nuisance, to wit: Solicitation of Beveragés, allowing gang members to congregate (Nortena Bloods), carrying concealed weapons (gun), and possession/sale of controlled substances, on your licensed premises (cocaine, marijuana, mdma (molly pills), this act being contrary to and in violation of section 561.29(1)(c), within 561.29(1){a), Florida Statutes. Tel: 954.917.1346 5080 Coconut Creak Pkwy. yaww.MyFloridaLicense.com Fax: 854.917.1357 Suite C License Efficiently. Reguiate Fairly. ul Margate FL 33063-3942 debra. nicoleti@myforkdalicense.com Florida Department: Busines: Professishal Regulation tt Seat, Sovran PAGE 9 RE: CASE NUMBER 2013001497 DIVISION OF ALCOHOLIC BEVERAGES AND TOBACCO VS. PARADISE DINER INC. D/B/A PARADISE DINER LICENSE NUMBER BEV1615077 Signed this June 3, 2013 Robert A. Douglas, Director Division of Alcoholic Beverages and Tobacco Carmen Puentes-Croye Law Enforcernent Captai EXPLANATION OF SERVICE: DATE SERVED RECEIVED BY PERSONAL SERVICE BY CERTIFIED MAIL # 7009 2820 0002 0663 2128 ATTACH RECEIPT IF SERVED BY MAIL CEaIMEED Madks 7 PARADISE DINER IN nee 2420 O00 ObL3S 2128 Tel: 954.917.1346 5080 Cocenut Creek Pkwy. www.MyFloridalicense.com Suite G License Efficiently. Regulate Fairly. Fax: 954.917.1357 Margate FL 3063-2042 debra .nicoletti@myfloridalicense.com

Docket for Case No: 16-004176