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BEFORE THE
DEPARTMENT OF ALCOHOLIC BEVERAGE CONTROL
C1F THE STATE OF CALIFORNIA
File: 47-471983
Reg:
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ACCUSATION UNDER
ALCOHOLIC BEVERAGE
CONTROL ACT AND
STATE CONSTITUTION
Ihereby complain and accuse the above respondents}, holding the above license(s), based on the following
statement of facts:
By reason of the following facts, there is cause for suspension or revocation of the license(s), in accordance
with Section 24200 and Sections 24200(x) and (b) of the Business and Professions Code. If is further alleged
that the continuance of the license would be contrary to public welfare and/or morals as set forth in Article XX,
Section 22 of the California State Constitution and Sections 24200(x) and (b) of the Business and Professions
Code. The facts which constitute the basis for the suspension or revocation by the Department are as follows:
From and about between the date of January 27, 2013 Co September 19, 2015, respondent-licensees) kepC or
permitted, in conjunction with a licensed premises, a disorderly hcause, or to which people resort, to the
disturbance of the neighborhood or in which people abide or resort which is injurious to the public morals,
health, convenience ar safety, in violation of Business and Professions Code Section 25601.
Without limitation to the foregoing, it is more specifically alleged that the following incidents occurred at or
near the premises:
r
# ~
-Bate
Case #
1 i 01/27/13
13-0U344
2
03/03/13
3
04/21./13
4 ~ OSJ25/13
13-00$51
13-Q1605
13-02131
5 i Q7j13/13
'~, 6
07/14/13
1
13-02868 ~
13-02$77
Incident Type
242 PC -Battery & 415 PC -Disturbing the
Peace/Fi htin & 647 PC -Drunk in Public
647( PC - Drunk. in Public
647 PC - Drunk in Public
243(4) PC -Battery with GBI & 245(x)(4) PC
Assault with Deadl Wea onlForce
242 PC Batter & 647(f PC -Drunk in Public
647(f PC -Drunk in Public
Result ~ ~fficer(s)
One Arrest
Torres #106
One Arrest
One Arrest
Five Arrests
Torres #106
Russell #103
Torres #106
One Arrest
One Arrest
Torres #106
Nash #109
47-471983
KANIT &DATE INC
Page 2
08/16/13
13-03362
Three
Arrests
09/08/13
13-03655
One Arrest
Nash #109
Renger #110
Torres #106
Nash #109
09/28/13
13-03959
One Arrest
Nash #109
10
11
12
10/03/13
ll/01/13
02/01/14
13-04020
13-04430
14-OQ377
Maore #35
Nash #109
Nash #109
13
03/02/7.4
14-00762
14
04/12/14
14-01286
15
16
17
18
04112/14
04/13/14
OS/ll/14
10/26/14
1401290
14-01313
14-01707
14-04049
One Arrest
Two Arrests
No Arrest /
Two Unk.
Sus ects
Case to DA
for Review
One Arrest
19
3/19/15
15-01192
20
04/19/15
15-01649
21
04/19/15
15-01650
22
23
24
07/31/15
08/09/1.5
09/19/15
15-03164
15-03305
15-03$09
Carlson #112
Labbe #67
Two Arrests
One Arrest
One Arrest
Case to DA
for Review
Case to DA
for Review
One Arrest
Holck #ll4
Doroshov #34
Nash #109
Meteaif #111
One Arrest
Brown #532
One Arrest
One Arrest
Two Arrests
Ren er #110
Holck #114
Torres #106
Nash #109
Woods #118
47-471983
KANIT &KATE INC
Page 3
COUNT 2
By reason of the following facts, there is cause for suspension or revocation of the license(s), in accordance
with. Section 24200 and Sections 2420Q(a) and (b) of the Business and Professions Code. It is further alleged
that the continuance of the license would be contrary to public welfare and/or morals as set forth in Article XX,
Section 22 of the California State Constitution and Sections 24200(a) and (b) of the Business and Professions
Code. The facts which constitute the basis for the suspension or revocation by the Department are as follows:
Between. the dates of January 27, 2013 to September 19, 2015, respondent-licensee(s), directly or by and
through its agents, employees, or servants, permitted or suffered the above-designated premises to be used in a
manner which did create a law enforcement problem for the law enforcement officials of the Davis Police
Department, in that such officials were required to make numerous calls, investigations, arrests, or patrols
concerning the .conduct and acts occurring in or about said premises, and which thereby created conditions then
and there contrary to public welfare and/or morals as set forth in Article XX, Section 22 of the California State
Constitution and Sections 24200(a) of the Business and Professions Code.
Without limitation to the foregoing, it is more specifically alleged that the following incidents occurred at or
near the premises, necessitating Officers of the Davis Police Department to respond to calls for service, make
arrests, and/or take police reports as follows:
The Department hereby repeats, re-alleges, and makes part hereof as fully, completely, and with the same force
and effect as though set forth herein in full, the 24 specific incidents contained in Count 1 of this Accusation