95-1106QRi���!A
Presented
Referred To
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Covncil Fi1e # �' { 0 b
Green Sheet # 33R a 6
RESOLUTION
OF SAINT PAUL, MlNNESOTA
Committee: Date
�6
RESOLVED, that all licenses held by OPBM, Inc., a Minnesota corporation dba
Amelia's, for the licensed premises located at 175 Sth 5treet East, No. 140, in Saint Paul are
hereby suspended for a period of one day, �' � e�� ls1' , 1995; and, be it
FURTHER RESOLVED that OPBM, Inc., is required to pay the administrative law
judge costs incurred by the City of Saint Paul in connection with the hearing on this matter,
in the amount of $757.80, on or before September 29, 1995; and be it
FURTHER RESOLVED, that the findings of fact, conclusions of law and
memorandum contained in the ALJ Report in this case dated August 11, 1945, with the
exceptions of the first sentence of Conclusion of Law No. 6, and all of Conclusion of Law
No. 7, are expressly ratified and adopted as the written findings and conclusions of the
Council in this matter.
This Resolution is based on the record of the proceedings before the ALJ, including
the heazing on July 12, 1495, the documents and exhibits introduced therein, and the
arguments and statements of the parties on September 6, 1995, and the deliberations of the
Council in open session. To the extent that the imposition of the ALJ costs in this matter
represents an upward departure from the presumptive penalty in Section 409.26 of the
Legislative Code, that departure is justified by the follow2ng circumstances:
1. The licensee was expressly warned by an employee of the license office,
together with a Saint Paul police officer, one week before the incident in
ques6on, that complaints had been received from parents regarding liquor sales
to manors at the licensee's establishment. The licensee was advised that
licensing personnel would return to check on this, as well as other matters, in
the future.
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A copy o£ this Resolution, as adopted, shall be sent by first class mail to the Office of
Admuustrative Heazings and to the attorney for the licensee, Joseph J. Dudley.
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Adopted by Council: Date �,�, a��\9�Qrj
Adoption Certified by Covncil Secretary
sy:
Appi
By:
Requested by Department of:
By:
Form Approved by City Attorney
BY: C�.,�., � �'�`�
Approved by Mayor for Submission to
Council
By:
°�5 -����
OEPARTMENT/OFPICE/CqUNCIL DATE INRIATED ' V� 3 3 7 2 6
City Council 9/13/95 GREEN SHEE _
INITIAUDATE INRIAVOATE
COMACT PEFiSON & PHONE O DEPARTMENT OIRECTOR � ClT' CAUNCII
Nancy Anderson ���N �cmArroANer �CITVCLERK
MUST 8E ON CAUNCIL AGENW BY (DATE) p��N� O BUDGET D7AECTOA � F1N. 8 MGi SEflVICES DiB.
OflDEN � MAYOfl (OR A5SISTANn ❑
TOTAL # OF SIGNATURE PAGES (CLIP ALL LOCATIONS POR SICaNATURE)
ACTION qEQUE$TED:
Finalizing City Council action taken on September 6, 1995, concerning adverse action
against licenses held by OPBM, Inc., dba Amelia's, 175 Sth Street East.
AECOMMENDA7ION5: Approve (A) m Reject (R) pERSONAL SERVICE CONTRACTS MUST ANSWER THE FOLLOWINCa QUESTIONS:
_ PLANNING COMMISSION _ CIVILSERVICE CAMMISSION 1. Has this personlfirm ever worketl under a contrect for this department?
_ CIB COMMITfEE __ YES NO
— � AF � 2. Has this personNirm ever been a ciTy employee? _
— YES NO
_ OiS7RiC7 COUA7 � 3. Does this person/firm possess a skill not normally possessed by any current city employee?
SUPPORTS WHICH COUNCIL OBJECTIVE? YES NO
Ezplafn all yes answers on separate sheot end attach to greert sheet
INITIATMG PROBLEM, ISSUE, OPPOHTUNITY (Who, Whet, When, Where, Why):
ADVANTAGES IFAPPROVED:
D�SAOVANTAGES iF APPAOVED:
DISADVANTAGES IF NOT APPROVED:
TOTAL AMOUNT Of TRANSACTION $ COST/pEVENUE BUDGETED (CIRCLE ONE) VES NO
FUNDlHG SOURCE ACTIVITY NUMBER
FINANCIAL INFORMATION: (EXPLAIN)
OFFiCE OF THE CITY ATTORNE'Y
Trmothy E Mars, Ciry Attorney � c _`\ �`
� �
CI�' �F S'L�INT pl��.
Norm Co7eman, Mayor
September 13, 1995
Nancy Anderson
310 City Hall
Crvil Division
400 C�ty Nall
L� A'est Kellogg Blvd
Sa"rnt Paul, M"mnesota Si102
RE: Wednesday, September 20, 1995 Council Hearing
Item for Consent Agenda:
OPBM, Inc. dfb/a Amelia's
Nancy:
7'elephone. 612 266-87Z0
Facsimile: 612 Z98S619
Attached is the signed resolution identifying the penalties imposed
by the City Council on OPBM Inc. d/b/a Amelia's. Please schedule
this item for the Consent Agenda for the Council Hearing on
Wednesday, September 20, 1995.
Thank you.
Sincer
��-��
Peter P. Pangb �
Paralegal
-2�_
OFFICE OF THE CTTY ATTORNEY
Timoe7ry E. Mar.S Ciry Attomey C�5' ,� � I C G
3q
CTTY OF SAINT PAUL
Civit Division
Nomt Coleman, Mayo� 40D Ciry Hatt Telephone: 612 266871 D
ZS Wett KeQO� BHd Facsimile: 6Z2 29&5619
Sairst Paul, Minnesom 55102
i
August 23, 1995
Mr. Joseph Dudley, Jr. ��� ;��r�` '� �
Dudley & Smith, P.A.
American National Bank Building, Suite 2602 ��r° � F �^c�:
101 East Fifth Street F` �� � t�`"''
Saint Paul, Minnesota 55101
NOTICE OF COIINCIL SEARING
RE: Licenses held by OPBM, Inc. a Minnesota Corporation
d/bJa Amelia�s Nite Club & Eatery, located at 175 East 5th
5treet, #140, Saint Paul
Our File Number: G95-0166
Dear Mr. Dudley:
Please take notice that a hearing on the report of the
Administrative Law Judge concerninq the above-mentioned
establishment has been scheduled for 3:30 p.m., Wednesday,
September 6, 1995, in the City Council Chambers, Third Floor, Saint
Paul City Hall and Ramsey County Courthouse.
You have the opportunity to file exceptions to the report with the
City Clerk at any time during normal business hours. You may also
present oral or written arqument to the council at the Hearing. No
new evidence will be received or testimony taken at this hearing.
The Council will base its decision on the record of the proceedings
before the Administrative Law Judge and on the arguments made and
exceptions filed, but may depart from the recommendations of such
Judge as permitted by law in the exercise of its judgement and
discretion.
Sincerely,
Peter P. Pangborn
Paralegal
cc: Nancy Anderson, Assistant Council
Robert Kessler, Director, LIEP
Frank Staffenson, Deputy Director,
Mary Nelsan, Community Organizer,
Development Council, 445 Minnesota
St. Paul, MN 55101
Secretary
LIEP
Downtown Community
St., Suite 524,
Sgt. Per Tredal, Police Dept., Special Investigations Unit
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S7ATE OF MINNESOTA)
) ss
COUNTY OF HENNEPIN)
AFFIDAVIT OF SERVICE BY U.S. MAIL
LaVon Regan, being first duly sworn, hereby deposes and says that on the 11th
of August, 1995, at the City of Minneapolis, county and state aforementioned, she
served the attached FfNDINGS OF FACT, CONCLUSfONS, RECOMMENDATION
AND MEMORANDUM OF THE ADMINISTRATIVE LAW JUDGE; Docket No. 2-2101-
9801-6, by depositing in the United States mail at said City of Minneapolis, a true and
correct copy thereof, properly enveloped, with first class postage prepaid and
addressed to the individuals named herein.
Philip K. Miller
Assistant City Attorney
City of St. Paul
400 City Hall
15 West Kellogg Boulevard
St. Paul, MN 55102
Fred Owusu, City Clerk
170 City Hall
15 West Kellogg Boulevard
St. Paul, MN 55102
Subscribed and sworn to before me
this 11th day ofAugust, 1995.
d�u-��. C . Ca-,�
Notary Public
� LOUiSE C. COOPE�
e�taar�c-�ra
e�ry, comn. �..fu�. st.
■ •
Joseph J. Dudley, Jr.
Dudley and Smith
Attorneys and Counselors at Law
American National Bank Building
Suite 2602
101 East Fifth Street
St. Paul, MN 55101-1896
l_L�-Ub� ��'�->-�
LaVon Regan
9s _��o�
2-2101-9801-6
STATE OF MINNESOTA
OFFICE OF ADMINISTRATIVE HEARINGS
FOR THE CITY OF ST. PAUL
In the Matter of All Licenses Held By FINDINGS OF FACT,
OPBM, Inc., a Minnesota corporation CONCLUSIONS
d/b/a Amelia's Nite Club & Eatery, RECOMMENDATION.
for Premises Located at AND MEMORANDUM.
175 5th Street East, #140, St. Paul, Minnesota.
The above-entitled matter came on for hearing before Bruce D. Campbell,
Administrative Law Judge, on July 12,1995, in St. Paul. The hearing took one
day, and the record c{osed at the end of the hearing.
Appearing on behalf of OPBM, Inc., was Joseph J. Dudley, Jr., Dudley
and Smith.
Appearing on behalf of the City of St. Paul was Philip K. Miller, Assistant
City Attorney.
This Report is a recommendation, not a final decision. The St. Paul City
Council wil{ make the final decision after a review of the record. The Council may
accept, reject or modify the Findings of Fact, Conclusions, and
Recommendations contained herein. Pursuant to § 310.05(c-1) of the St. Paul
Legislative Code, the Council shall provide the licensee an opportunity to present
oral or written argument alleging error in this Report, and to present argument
relating to any action recommended in this Report. The licensee should contact
Philip K. Miller to ascertain the procedure for presenting argument.
STATEMENT OF ISSUE
Should any adverse action be taken against the licensee for selling an
alcoholic beverage to a minor?
Based upon ail of the proceedings herein, the Administrative Law Judge
makes the following:
FINdINGS OF FACT
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Background Facts
1. OPBM, Inc. is a Minnesota corporation doing business as Amelia's
Nite Club & Eatery at 175 5th Street East, #140, St. Paul, Minnesota 55101.
Amelia's presently hoids restaurant, entertainment, and on-sale liquor licenses
from the City of St. Paul.
2. Amelia's is located on the second floor of the Galtier Plaza
shopping center. Pursuant to the site plan filed in the licensing o�ce, Amelia's
liquor service area includes both the interior area, which has a seating capacity
of 234, as we11 as an area outside the bar along an open atrium in the building.
The night club's capacity, including both the inside and outside areas, is
approximately 300 persons.
3. Prior to March 16, 1995, the St. Paul Police Department, license
inspectors, and the Mayor's Complaint Office had received complaints that
Amelia's had sold alcoholic beverages to minors. Senior License Inspector
Kristina Schweinler of the Department of License, Inspections and Environmental
Protection personally received telephone complaints from angry parents alleging
that their minor children had been served alcoholic beverages at Amefia's and
had become intoxicated.
4. Based on these complaints, Schweinler included Amelia's in a
group of establishments that would be checked for compliance with regard to
sales made to minors.
5. Approximately two weeks before conducting this compliance
investigation, Schweinler visited Amelia's accompanied by Sgt. Per Tredal of the
St. Paul Police Department. Sgt. Tredal has been a police officer for
approximately 20 years; he has been assigned to the Special Investigations Unit
for approximately two and one-half years. The+r visit took place at about 12:30
a.m. on a Thursday night, which was promoted as "Latin NighY' at Amelia's. A
live band was playing, and they were either aware befiorehand or learned that
night that Amelia's typically charges a$6 or $7 cover charge when it provides
live entertainment. The bar was full when they arrived.
6. During this preliminary visit, Schweinler and Sgt. Tredal observed
that the band kept playing and the bartenders kept serving alcohol past the 1:00
a.m. closing time. They immediately contacted the manager, Michael Bergstrom,
and told him to close the bar and stop serving alcohol. They also informed him
that they had received complaints of alcohol sales to minors and warned him that
they would be checking Amelia's compliance in the future.
7. On March 16, 1995, Schweinler and Sgt. Tredal conducted a series
of compfiance checks on different establishments about which she had received
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complaints about serving minors. The businesses included several convenience
stoses, a video store, and two or three on-sa{e {iquor establishments.
Accompanying them were two minor decoys: a 19-year-old male named Robert
Loesch, who is Schweinler's son, and his girlfriend, a 16-year-old female named
Catherine Caturia. Loesch had acted as a decoy before; Caturia had not. That
evening the minors visited these businesses under the supervision of Schweinler
and Sgt. Tredal and attempted to purchase either cigarettes, aduft videos, or
aicoholic beverages, depending on the type of complaint previously received.
8. Schweinler and Sgt. Tredal instructed the minors to attempt to
make the purchases. If asked for age identification, they instructed the minors to
say that they did not have any. The minors were given no instructions to dress
or act any particular way in attempting to make these purchases. They were
given no instructions about what to do in the event someone asked them to pay
a cover charge.
9. The group arrived at Amelia's at approximately 10:00 p.m. They
took an elevator up to the second floor of Galtier Plaza, arriving to the west of
the main entrance to the bar. The minors were told to walk east through the
outside bar area toward the main entrance, while Schweinler and Sgt. Tredal
walked around to observe them directiy across the atrium from the main
entrance.
10. That evening, a Thursday, was again Latin Night at Amelia's. The
bar was busy. There was a tabie set up outside the main entrance, facing east,
where a cashier was collecting cover charges. The table was placed so that
people coming up an escalator to the second floor would stop before entering
the bar. There were approximately five people waiting in line to pay the cover.
Two bouncers were standing next to the table conversing with the cashier.
11. As the minor decoys approached from the west, they stopped
approximately ten feet away from the table and waited in the outside bar area,
expecting someone to approach them about paying the cover charge or showing
identification. After about 30 seconds, one of the bouncers turned and entered
the open door of the main entrance. The minor decoys entered the bar after
him. There was nothing surreptitious about the way they entered the bar; they
simply walked in from the outside bar area.
12. At no point before entering the bar did anyone ask them to pay the
cover charge or show any age identification.
13. After walking in, the minor decoys went directly to an open spot at
the bar. Robert Loesch ordered a$3 bottle of beer; Catherine Caturia did not
order anything but stood next to Loesch while he ordered. Bartender Michaef
Boho sold Loesch the beer without asking for age identification.
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13. Immediately after purchasing the beer, the minor decoys left the
bar through the main entrance, again waiked past the cashier and bouncer at the
outside table, and took a seat in the outside bar area. It took only a few minutes
total for the minors to enter the bar, purchase the beer, and return to the outside
bar area.
14. Schweinier and Sgt. Tredal observed that Loesch was holding a
bottie of beer and crossed the atrium to where the minors were seated. Sgt.
Tredal tasted the beverage and confirmed that it was beer.
15. Bar manager Michael Bergstrom recognized Sgt. Tredaf and
approached him to see why he was there. Sgt. Tredal and Schweinler told him
that a bartender had just sold beer to a minor. Bergstrom called bartender
Michael Boho over, and Boho verified that he had sold the beer to Loesch
without asking for age identification. Boho stated that when the bar is busy the
bartenders usually rely on the door people to verify the ages of customers.
Amelia's Business Practices
16. At the time of this incident Amelia's typically had three security
people (bouncers) and one cashier working on evenings when there was live
entertainment. One bouncer stood outside the main entrance with the cashier to
check age identification; one sat inside the bar near the west doors to ensure
that no one entered the bar through those doors; and one was designated as a
"walker" who walked the interior of the bar but was available to the otfiers as
needed.
17. At the cashier's table there is a sign notifying customers of the
cover charge. After paying, a stamp is placed on each customer's thumb so
customers can exit the bar and then re-enter without paying the cover charge
again. Age ide�tification was typically checked at the cashier's table.
18. On the door to the main entrance, a large sign is posted that reads
"If you are under 30 be prepared to show I.D./Dress code enforced." A smaller
sign beneath this describes Amelia's ID policy.
19. A rope hanging between two metal stands is placed befinreen the
cashier's table and the door to the main entrance. It is intended to guide traffic
from the cashier's table into the main entrance. The rope does not block the
main entrance to people approaching from the outside bar area on the west; in
other words, the main entrance is still accessible to people who do not go
through the line.
20. Because there are no restrooms inside the nightclub, it is common
for people to leave the bar thraugh either the main entrance or the doors on the
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west side so they can use restrooms on another floor. Customers are not
allowed to re-enter through the west doors, but are directed to re-enter only
through the main entrance.
21. At the time of this incident, the same bouncer who was posted at
the cashier's table was responsible for checking age identification for people
coming through the line, as well as for checking everyone approaching from the
west.
22. The "rule of thumb" followed by Amelia's personnel is that people
inside the bar are not generally asked for age identification if their hands are
stamped; people sitting in the outside bar area are supposed to be carded,
because they do not have to pay a cover charge to sit there and their hands are
not stamped.
23. These security measures were not adequate to prevent the decoy
minors from entering the bar or to prevent the sale of an alcoholic beverage to
one ofi them inside the bar. The bouncer at the cashier's table paid no attention
to them and allowed them to enter the bar unchallenged; and once inside, one of
them was served alcohol even though his hand was not stamped.
24. In an incident report that he prepared some time afterward, bar
manager Michael Bergstrom stated his theory that the minors "sneaked" into the
bar by mingling with a group of customers that had gone through the line and
paid the cover charge. In his testimony he described this theory as his "best
guess" as to what had happened. No facts support this theory. Bergstrom did
not personally observe the minors entering the bar, nor did any other witness
testify to this vers+on of the facts.
25. In the same incident report, Bergstrom stated that since this
incident occurred, on "busier nights such as Latin nighY' either he or another
security guard checks identification right outside the main entrance, in addition to
having someone posted at the cashier's table. Bergstrom did not testify about
any such remedial actions, and it is not clear from the record whether this
change has been implemented or not.
Notice of Possible Adverse Action
26. By letter dated April 20, 1995, the St. Paul City Attorney's Office
notified the owner of Amelia's of possible adverse action against the licenses
based on the above-described sale on March 16, 1995.
27. On June 13, 1995, the City Attorney's Office served counsel for
Amelia's with a Notice of Hearing, scheduled for July 6, 1995. At the request of
counsel for Amelia's, the hearing was rescheduled to July 12, 1995.
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28. At the hearing, the Department of Licensing, Inspections and
Environmental Protection recommended that adverse action be taken against
Amelia's on-sale liquor license pursuant to the matrix contained in § 409.26 of
the St. Paul Legislative Code. The Department has also requested that Amelia's
be assessed the costs of the hearing in this matter.
Based upon the foregoing Findings, the Administsative Law Judge makes
the following:
CONCLUSIONS
The St. Paul City Council has jurisdiction of the subject matter of
this hearing.
2. Proper notice of the hearing was timely given, and all relevant
substantive and procedural requirements of law or rule have been fulfiiled and,
therefore, the matter is properly before the Administrative Law Judge.
3. The licensee violated § 409.08(2) of the St. Paul Legisiative Code
and Minn. Stat. § 340A.503, subd. 2(1) by serving an intoxicating beverage to a
minor on March 16, 1995.
4. Based on these violations the St. Paul City Council is authorized to
take adverse action against Amelia's licenses pursuant to § 310.06(b)(6) of the
St. Paul Legislative Code.
5. It appears from the record that this is the licensee's first
appearance for selling alcoholic beverages to an under-age person; the
presumptive penalty pursuant to § 409.26(b) of the St. Paul Legislative Code is
suspension of its liquor license for one day. In the alternative, the City Council
may in its discretion impose a fine in the amount of $2,000.00 in lieu of a
suspension.
6. There exist no substantial or compelling reasons for the City
Council to deviate from the presumptive penalty. The licensee's past business
practices were not adequate to prevent a minor from easily purchasing an
intoxicating beverage.
7. The costs of the hearing should not be assessed against the
licensee.
Based upon the foregoing conclusions, the Administrative Law Judge
makes the following:
0
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RECOMMEIVDATfON
That the St. Paul City Council impose against the licensee the
presumptive penalty contained in § 409.26(b) of the St. Paul Legislative Code.
Dated this 1 l�day ofAugust, 1995
�t-1 �?, ���
BRUCE D. CAMPBELL L,__ �
Administrative Law Judge � �
NOTICE
The City is respectfully requested to provide a copy of its final decision to
the Administrative Law Judge by first class mail.
Reported: Tape Recorded.
MEMORANDUM
There is no real dispute about the underlying facts. The minor decoys
easily entered the bar, and within minutes one of them purchased an intoxicating
beverage. Although several employees of Amelia's were in a position to do so,
none of them personally observed the minors entering the bar, and consequently
the bar is in no position to contradict the facts as described by Sgt. Tredal, Ms.
Schweinler, or the minor decoys.
The main defense raised by Amelia's is that the violation would not have
occurred if the minors had followed the bar's procedures for collecting a cover
charge and checking age identification. This argument is misplaced. !t is the
licensee's responsibi{ity to prevent an illegal sa1e. The licensee cannot
reasonably rely on minors to honor the security system the bar has chosen to
use, particularly when the system is so easy to circumvent.
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OFFICE OF ADMINISTRATIVE HEARINGS
FOR THE COBNCIL OF
THS CITY OF SAINT PAIIL
OAH Dooket No. 8-2101-9790-6
In re the Licenses of OPBM, INC.
dba Amelia's Nite Glub & Eatery
175 5th Street East, #140
CITY�S PROPOSED
EXHIBITS
July 12, 1995
�
TO: Judge Bruce Campbell, Administrative Law Judge, Office of
Administrative hearings, 100 Washington Square, Suite 1700,
Minneapolis, Minnesota 55401-2138
The following constitutes the proposed Hearing Exhibits o£ the
City's Department of License, Inspections and Environmental
Protection. �
Exhibit No.
Exh. No. 1
Exh. No. 2
Exh. No. 3
EXh. No. 4
EXh. No. 5
E�. No. 6
Exh. No. 7
Description
Police Report CN 95-034-171, dated March 16,
1995 (1 p.).
Investigation Report prepared by Kris Van Horn,
dated April 3, 1995 (1 p.).
License information re OPBM, INC dba Amelia's
Nite Club & Eatery, certified May 19, 1995
( P•)•
Letter of violation, dated April 20, 1995
�Z PP•)•
Fax letter from Amelia's to Phil Byrne, dated
April 25, (3 pp.).
Notice of Hearing with Affidavit of Service;
dated June 13, 1995 (4 pp.).
Notice of Rescheduled Hearing with Affidavit of
5ervice, dated June 14, 1995 (2 pp.).
�
Exh. No. 8
E�. No. 9
Exh. No. 10
� s _ ��d c.
City's Discovery Response with Affidavit of
ServiCe, dated June 27, 1995 (4 pp.).
Letter forwardinq copy of police report to
Joseph Dudley, Jr..
8 photoqraphs o£ Amelia's, taken Monday, July
10, 1995 (3 pp.).
Respectfully submitted this 12th day oP July, 1995.
f�c i � - P�
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C �� � r�i -�,.
Philip K. Miller
Assistant City Attorney
Office of the City Attorney
400 City Hall
15 West Kellogg Boulevard
Saint Paul, Minnesota 55102
(612)266-8731
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Emp. No.:
� [] Hom ❑ Rob ❑Juv ❑ Coord ❑ ID ❑ Lab
D/C ❑ Burg ❑ Theft � Prop Q CAU ❑ F&F [] Auto
. OT.: T�
�Yes � No
Ree ❑ Team [��
oao ❑ co C dba
� Nite Club & Eatf
City's E�ibit No.
CONTINUE NARRATIYE HEFiE
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CITY OF SAIIvT PALZ
L\TERDEPART�g:�'TAL 1��MORA.*�DU'M
April 3, 1995
TO: Robert Ressler
?hil Byrne
ied SCoeppl
iROH: �SS V�'1 tiOr:l
R"^.: Compliance Checks
The following is a reacrt ea the cempliance checks of several coavenience
stores, on sale liq�cr esteblis? aad�
Accoripanying Sergeznt 2er Trecal ��d me xas a sixteen year old fernale }mown as
CAC and a nineteen ea_ old male �_oh� as ��L. Ol:r first stc� was the�
CAC was sold a pack of
N,arlboro cicarettes. S�e �zs act as.e for identification. All o£ this was
monitored by Sergea.nt irecal aad -�e frcm a vehicle outside. Ye eatered the
store atter the minor returaed to t'r_e vehicle, icentified the clezk and
in£or:ned him of the orocedcze.
He then proceeded to . The
sixteea year old £e:nale uas sold a�ack of Marlbozo cic�rettes.
�;e attemoted to make �ischases at
- . No sales were made at
these locations.
he thea went to , and our sixteen year
old fe. was sold �z adu t vi eo. e o owe the same procedure at this
locztion except Serae�nt Tredal i�diceted that he would be issuing a criminal
tag for this-
We then proceeded to F�elia's at i75 E. Sth Street, �140, where Sergeant
Tredal a*�d I watched from across tae atrium while the two minoss went to the
bar. They walked into the bar without being carded er paying the cover.
t�Thile in the bar, R?L purchased a*3iller Lite and walked out to the tables in
the hall. Sergeant Tredal and 2 went over and talked to the mariager on duty
and in£orned him what hzd happened and identi£ied the bartender.
Sergeant Tredal and I then went to
observe the activity.
Zt xas considezably quieteY then previous nigr
we had monatore . we checked� on Snelling Avenue which was very busy,
but the bovncers had control o t e doors and were very dilicent about
checking identificatica. ke asked aaout the procedure for checking
identification and, we feel that Lhey have a good system.
We t};en went
at that time.
KVH/lk
to th N�e saw no violations
� .
dba Amelia's Nite Club & EaCe '
City's E�ehibit No. �
�( 5 1.Lo�
LiC ID ...................
STAT .....................
Business Name............
Doing Business As........
Address ..................
Zip......................
Exp Date .................
License Name .............
NOTE AREA ................
Bond Policy Number.......
Bond Company .............
Bond Effective Date......
Bond Expiration Date_._..
Insurance Carrier........
Ins. Policy Number.......
Insurance Effective Date.
Ins. Expiration Date.....
Associated Stock Holder..
Dealer No ................
TaxId ...................
Worker Comp Exp Date.....
Telephone ................
5/19(95
43264
AC
OPBM INC A MN CORP
AMELIA'S NITE CLUB & EATERY
175 5TH ST E 140
55101
10/31/95
RESTAURANT (B)-MORE fiHAN 12
SEATS
ENTERTAINMENT-CLASS B
SUNDAY ON SALE LIQUOR
LIQ-ON SALE-OVER 100 SEATS
12610
110592 APPN FOR NEW ON SALE LIQ(B), SUNDAY ON
ENfi-ISS, & REST(D) APP'D C.F. #92-1703
9/20/94 SENT OUT LETTER FOR SELLING TO MINORS
110794 - LICENSE RENEWAL HELD PER DAVE THUNE'S
ICE PENDING POSSIBLE PLACEMENT OF RESTRICTIONS
THE LICENSE CAR/LIC
12/23/94 GSR TO CR--LAP-LIC
LLOYDS OF LONDON
TAM01026
O1/03/95
10/31/95
FREDERICK W THORNE, III
1879159
04/O1/94
291-1480
I hereby certify that this is a true and exact copy of the records of the
LIEP Office of the City of St. Paul For OPBM Inc_ a MN Corp DBA
Amelia's Nite Club 5 Eatery at ll5 E. Sth Street, #140.
��.�, �� ��
Christine Rozek
License Manager
SALE
OFF
ON
. �
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No ry blic
■
■
LINDA KAYKORAN
�� NOYARYPUBLU%•MhlN��TA
'�, �` Mr Canmissbn Exqrei Jw. st, 2000
r ��MVwMUwen^*.^."su""^n^"nMnnMMMi ■
■ ■ �-�I-oa
dba Amelia's Nite Club & Eatery �
— City's E�tibit No. 3 —
SALNr
PAUL
�
AAAA
�
CITY OF SAINT PAUL
Nome Coleman, Mayar
April 20, 1995
Richard Thorne
Amelia's I3ite Club & Eatery
175 East 5th Street, #140
Saint Paul, Minnesota 55101
OFFI�F THE CITY ATTORnEI'
Tmrorh� 4nr.r, Cr�p�tuornn� � � � `�
YV f�
Civi[ Division
400 Ciry Ha1!
IS Wes+ Keffogg lJlyd.
Saini Pau(, Minnesota 55102
Telcpl�onc: 61? ?66.?710
Focsrnriic. 61? 39E-5619
Re: Licenses oP Richard Thorne dba Amelia's Nite Club & Eatery
Our File Number: G95-0166
Dear Mr. Thorne:
I am in receipt of inPormation that could lead to adverse action
against all your licenses. The basis for adverse action is:
On March 16, 1995, at approximately 10:00 p.m., a minor
purchased beer on the licensed premises without being asked
for any identification as to age. The minor was accompanied
to the establishment by an employee of the license office and
a plain clothes police officer. The sale to the minor was a
violation o£ Section 409.08 of the Saint Paul Legislative
Code, as well as of state law, Minn. Stat. § 340A.503 (1994).
If you do not dispute that the above sale took place, this matter
will be scheduled before the City Council for a nearing on what
penalty, if any, to impose. You will be allowed to speak on your
behalf at that hearing. I will need to have a letter from you
saying that you do not dispute the facts if we are going to follow
that path.
On the other hand, if you dispute the above facts, S will schedule
the evidentiary hearinq on the facts before an Administrative Law
Judge. In that event, you will receive a notice of hearing so you
will know when and where to appear, and what the basis for the
hearing will be.
In either case, you should contact me within ten days from the date
o£ this letter. If I do not hear from you, I will schedule the
� �
dba Amelia's Nite Club & Eatery ' �
City's Exhibit No. 4 �
_� �
! `�S-11o6
hearing, and you may be responsible for the costs of the hearing if
you do not then appear and contest the facts. Please call me or
have your attorney call me at 266-8710.
Very truly yours,
Philip B. Byrne
Assistant City Attorney
cc: Richard Thorne, 3 N. Griggs St., St. Paul, MN 55104
Robert Kessler, Director, LIEP
Kris Van Horn, LIEP
04-25-1995 14:59
�- ;., v� � ;
TO:
FR�M: � � �ls4 �
DATE: L ��! � Z S
T
THIS F14X I�iCLUL1ES THYS COiT�R SHEET APiD a3► AD�T'i'IONAL PAGES.
i
IF ANY PA�'s�'S AR$` MZSSXNCi� PLEASE CON�'ACT tT5 Afi 297-6734.
MESSAG$;
612 297 fi287
MINNESOTA DEVELEPMEM1IT, INC. �� P.01
. o � � ���
q5-\\��
. o o , �
MANAGEMEDt'� OFFICE '
� 175 E. FTFTH S2'.
� S� .� . C'. �I �f ��"'�aC ,u E+� SL�IfiE 3 i 5. $ox z7
ST. PATTL MI� 55101
E'A3C #: I {612) 29?-6734
FAXs 297-6287
� .
dba Amelia's Nite Club & Eater
� City's Earhibit No. � —
04-25-1995 15:00 612 297 6287 MIN[UES�TA DEVELEP T, INC.
- � i,yi� �7`.J
1�" �dr
y
INCIbJ�FiT REPORT
I;1CzYJ
qs -\\o�
On Thuraday May 16� 1995 we opened the nitealub tor businea�
�t 8:3p p.m. I was t3fe Matsmger 4n Duty that evertim� and Phi1 va�
h�ad af aecurity. L➢e were clsecking iden4lfioatiot� csarC� and
callecting Ghe $7 caeer eharge +sdjaces�t ta th� Qsaalntar on our
carpet 3ust outeide af tkie club doaFg. Miahsel eaho and Troy
vasquez vere Ct�e tvo riartendara at the Proat bar in the club. Tori
Sahan seas tk�e vashier working the ti�l arid Phil wa� cllecking
I.ti.'e. The bsnd far tne evmning was the T�atin svunds orcheatra
that typically plays t11e resam on Thu�s�ay niqhts. Th� arovrd size
was in the q+uer�ge range of betwaen 2D0 ta 300 people. T riad ona
senurity glaaed iust 3.nside the doora oa the wnst �id8 ot the alub
tcr ensure na ane ovuld �nCer the club aithout groceeding t�rough
the proper line were cov�er charge and 1.D.'� were laeinq proae�sed.
I also had tsvo more seou�ity wcrk3ng #he ins3,de of the c1uD walkinq
trie Eloor. �
� �,�.�',�>s r
At aprcaeimately _I� Cj �""`� _ T was itlformm8 by ��"' j ��'
_ that they had gent t�ro minorg inta our niteciub to
atten�gt to purcriase alcohol. Tk�ey ��ated that the tara tninor� had
baen in the caver charqe\IA �.3,ne but h�.d stege�d nut of th� 13ne end
entered the a.Yub with n qroup of customnrs that had already paid
�he ccrrsr charge. mhey did not prdcead tl3rough tl�e iine but rather
snuck into the club o�ithout paylag the at�ver charqe. t7nce in Cita
club tha minors ardsr�d a M�.1&er Lite lron Michael goho �� �
front bax� on the esst side nP the ba�. Whan I wng tol� by �'�
tkaat ttt+a mtnors had been ner�ree ai�ohal I ro�as infcrmed that
thay had reaieved ccmp�ainCs abou�. Ameli.a's and that e�as why '�eY
were at the club. Tt]ey did state th�t if the minors hed gone
throuyh the line properly th�t would no£ have got�en in the cltab.
�
sinca tkxat fnaident ate have alaartgefl our procea&tra� ot
colleating cover charge and idec�tif3catian campietly. �g ncter haes
tha iiae�a farmed out�ide tha cluh on all of oux euen�s in tlts aluA.
�te al�ays have ane as�urity per�on chackirx; identifics�ian end onra
cashier aallseting tY�e Covar �harqe. Or� the busier niqhta such ce�
a.atin Night vg have ane mQCUri.ty or mpeal! checking In`e riqht
cutside the club dacsr� to ensure that eka�olute].y noo� witriaut .
praper identi�icaticro stap� foet inside aas satn]sliuhment, on a
typicel Latits Night wc wi17. turn nway ia to 2o peaple because they
Pail to have ID�s cr they riave unaceep�ehle IL1's. iQe cbllaCt pn
avarage at l�ss� 1 Pake I17 a xtiqh�. �i8 �ansult witTt tYi� Bt.Paul
�0
,t
04-25-1995 15=00 612 297 6287 HINMES�TA DEVElEPt4ENT, INC_ P.03
9S� \\��
� lioe departmeat frequsntly duri� l3ie caurse of a eveniaq to
nEOrm them of ittdividual� seho are att�mptS�ng to en�er th� ciu�
wit� inv�qlid IA'�. oPe have alrrtays taken procedures at the doar
srery �erfou�Yg an� 9re do eo even savre since the ii►ciderrt on Kay
�6tt�, we malce every e�foxt ta enaura that every single persob �C1saC
entsr� our olub ia over the age �Y 21. i�a naa Hsve takan moXe
ffierioua measnres ta easura that iadividuals cannct aneak inta aur
a�kab2lshment �rithout flrst following the pr0aed�rres Y.txnt ws
enfarCe.
�
�
STATE OF MINNESOTA 9 5 -\\��
OFFICE OF ADMINISTRATIVE HEARINGS
100 Washington Square, SuBe 1700
100 Washington Avenue South
Minneapolis, Minnesota 554�1-2138
June 20, 1995
Peter Pangborn, Paralegal
Office of the City Attorney
400 City Hall
15 West Kellogg Boulevard
St. Paul, Minnesota 55102
RE: Licenses of OPBM Inc, d/bla Amelia's Nite Club & Eatery;
OAH Docket No. 2-2101-9801-6
Your File No.: G95-0166
Dear Mr. Pangborn:
As requested in your letter of June 16, 1995, enclosed are subpoenas requiring
the attendance of certain witnesses at the hearing on July 12, 1995, in the above-
referenced matter.
Yours very truly,
``���� J � ��-Yt}�LC�2-�-�
t, p �
BRUCE D. CAMPBEL�
Administrative Law Judge
Telephone: 612/341-7602
sh
Enc.
Providing Impartal Hearings for Government and Citizens
An Equal Opportur}�ty Employer
Administrative Law Section 8. Administrative Services (612) 341-7600 � TDp No. (612) 341-7346 � Fax No. (612) 349-2665
�ts-����
r �:� STATE OF MINNESOTA
�� � OFFICE OF ADMII�TISTRATIVE HEARINGS
.ti ... �-�
HEARING SUBPOENA
TO: Sergeant Per Tredal, St. Paul Police Department, 100 East
11th Street, St. Paul, Minnesota 55101
GREETINGS:
YOU ARE HEREBY COMMANDED to lay aside all your business
and excuses and to appear before Bruce D. Campbell, Administrative Law
Judge, of the Office of Administrative Hearings of the State of Minnesota,
at St. Paul City Hall, Room 42, 15 West Kellogg Soulevard, in the City of
St. Paul, Ramsey County, Minnesota, on the 12th day of July, 1995 at
9:30 o'clock in the forenoon, to appear as a witness in the matter of All
Licenses Held OPBM lnc a Minnesota Corporation d/b/a Amelia's Nite
Club & Eatery for Premises Located at 17 5th Stre t East #140 St
Pauf Minnesota.
YOU ARE FURTHER COMMANDED to bring and have with you, to
be used as evidence in the hearing, if required, the fof{owing:
Pursuant to the authority granted at Minn. Stat. § 14.51, Witness, the
Honorabfe Kevin E. Johnson, Chief Administrative Law Judge, at
Minneapolis, Minnesota this 20th of Sune, 1995
�•
KEVIN E. JO SON �
Chief Administrative Law Judge
612/341-7600
Subpoena requested by: Janet Reiter, Office of the City Attorney,
Telephone: 266-8710
qs_ ���,�
�: -
� "�a�� �_
'� -�.�- s.
,, -
STATE OF MINNESOTA
OFFICE OF ADMII�IISTRATIVE HEARINGS
HEARING S[3BPOENA
TO: Catherine A. Caturia, St. Paul Police Department, 100 East
11th Street, St. Paul, Minnesota 55101
GREETINGS:
YOU ARE HEREBY COMMANDED to lay aside all your business
and excuses and to appear before Bruce D. Campbel{, Administrative Law
Judge, of the Office of Administrative Hearings of the State of Minnesota,
at St. Paul City Hall, Room 42, 15 West KeAogg Boulevard, in the City of
St. Paul, Ramsey County, Minnesota, on the 12th day of July, 1995 at
9:30 o'clock in the forenoon, to appear as a witness in the matter of All
Lic�n�es Heid OPBM Inc a Minnesota Corporation d/b/a Amelia's Nite
Club & Eatery. for Premises Located at 175 5th Str et Ea t#140 Gt
Paul. Minnesota.
YOU ARE FURTHER COMMANDED to bring and have with you, to
be used as evidence in the hearing, if required, the following:
Pursuant to the authority granted at Minn. Stat. § 14.51, Witness, the
Honorable Kevin E. Johnson, Chief Administrative Law Judge, at
Minneapolis, Minnesota this 20th of June, 1995
1? _ �
KEVIN E. JOH ON '
Chief Administrative Law Judge
612/341-7600
Subpoena requested by: Janet Reiter, Office of the City Attorney,
Telephone: 266-8710
as� 1 � O �
, - - • i •
�� :�;,,.--�� '$ • • � � � . � .
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r � � �� 1`^ � � � � � � �
.f
..'n.'......''�
TO: Richard P, Loesch, St. Paul Police Department, 100 East
11th Street, St. Paul, Minnesota 55101
GREETINGS:
YOU ARE HEREBY COMMANDED to lay aside all your business
and excuses and to appear before Bruce D. Campbell, Administrative Law
Judge, of the Office of Administrative Nearings of the State of Minnesota,
at St. Paul City Hall, Room 42, 15 West Kellogg Boulevard, in the City of
St. Paul, Ramsey County, Minnesota, on the 12th day of July, 1995 at
9:30 o'clock in the forenoon, to appear as a witness in the matter of AI!
Licenses Heid OPBM inc.. a Minnesota Cor�oration d/b/a Amelia's Nite
Glub & Eatery for Premises Located at 175 5th Stre t East #140 St
Paul Minnesota.
YOU ARE FURTHER COMMANDED to bring and have with you, to
be used as evidence in the hearing, if required, the following:
Pursuant to the authority granted at Minn. Siat. § 14.51, Witness, the
Honorabie Kevin E. Johnson, Chief Administrative Law Judge, at
Minneapolis, Minnesota this Oth of J�, 1995
r
L
� � �
KEVI E. JOH SON
Chief Administrative Law Judge
612/341-760Q
Subpoena requested by: Janet Reiter, Office of the City Attorney,
Telephone: 266-8710
f � �
' • � � � OFFT�F THE CITY ATTORNEY
- - � ���� q _��
CITY OF SAIN'T PAUL c;�r a,�»
Norm Cokman. Mayor 400 Ciry Hall
IS War7GAvgg Bivd
Sa'vu Pau{ M'vuiesota 55102
June 13, 1995
NOTICB OF HEARZNG
Joseph J. Dudley, Jr.
Dudley and Smith
Attorneys and Counselors at Law
American National Bank Building
Suite 2602
101 East Fifth Street
Saint Paul, Minnesota 55101-1896
Telepfio.� 612 266-5710
Facdmile 612 298-5619
RE: All licenses held by OPBM Inc. a Minnesota Corporation dba
Amelia�s Nite Club 5 Eatery, for premises located at 175 5th
Street Bast, � 140, St. Paul
Our File Number: G95-0166
Dear Mr. Dudley:
Please take notice that a hearing will be held at the following
time, date and place concerning all licenses for the premises
stated above:
Date: Thursday July 6, 1995
Time: 9:30 a.m.
P18Ce: Room 41
st. Paul City Hall
15 W. Rellogg Bivd.
Saiat Paul, MN. 55102
The hearing will be presided over by an Administrative Law Judge
from the State of Minnesota Office of Administrative Hearings:
Name: Allea Giles
Office of Administrative Hearings
100 Washinqton Square, Suite 1700
Minneapolis, l�i. 55401
Telephone: 349-2543
The Council of the City of Saint Paul has the authority to provide
for hearings concerning licensed premises and for adverse action
. ■
dba Amelia's Nite Club & Eatery �
— City's Exhibit No. 6
� • • �s-��n�
against such licenses, under Chapter 310, including sections 310.05
and 310.06, of the Saint Paul Legislative Code. In the case of
licenses for intoxicating and non-intoxicating liquor, authority is
also conveyed by Minnesota Statutes section 340A.415. Adverse
action may include revocation, suspension, fines and other
penalties or conditions,
Evidence will be presented to the judge which may lead to adverse
action against all the licenses held at the above premises as
follows:
��That on March 16, 1995, at approSimatelp 10:00 p.m., a
minor purchased beer on the licensed premises without
being aske8 for any identification as to age. The minor
was accompanied to the establishment by an employee of
the license office and a plain clothes police officer.
The sale to the miaor was a violation of Section 409.08
of the Saint Paul Legislative Code, as well as of state
1dW, Minn. Stdt. § 340.503 (1994).'�
The hearing will be conducted in accordance with the requirements
of Minnesota Statutes sections 14.57 to 14.62 and such parts of the
procedures under section 310.05 of the Saint Paul Legislative Code
as may be applicable.
At the hearing, the Administrative Law Judge will have all parties
identify themselves for the record. The City will then present its
witnesses and evidence, each of whom you may cross-examine. You
will then have an opportunity to offer in rebuttal any witnesses or
evidence you may wish to present, each of whom the City's attorney
may cross-examine. The Administrative Law Judge may in addition
hear relevant and material testimony from persons not presented as
witnesses by either party who have a substantial interest in the
outcome of the proceeding; for example, the owners or occupants of
property located in close proximity to the licensed premises may
have substantial interest in the outcome of the proceeding.
Concluding argwaents may be made by the parties. Following the
hearing, the Judge will prepare Findings of Fact, Conclusions of
Law, and a specific recommendation for action to be taken by the
City Council.
You should bring to the hearing all documents, records and
witnesses you will or may need to support your position. Subpoenas
may be available to compel the attendance of witnesses or the
production of documents in conformity with Minnesota Rules, part
1400.7000.
If you think that this matter can be resolved or settled without a
formal hearing, please contact the undersigned. If a stipulation
or agreement can be reached as to the facts, that stipulation will
be presented to the Administrative Law Judge for incorporation into
his or her recommendation for Council action.
Hearing Notice - Page 2
�
�
q5- 1l0 �
If no one appears at the hearing on behalf of OPBM, Inc., then the
allegations against OPBM, Inc. which have been stated earlier in
this notice may be taken as true and OPBM, Inc.'s ability to
challenge them forfeited. Zf non-public data is received into
evidence at the hearing, it may become public unless objection is
made and relief requested under Minnesota Statutes, Section 14.60,
subdivision 2.
Very truly yours,
Janet Reiter
Office of the City Attorney
cc: Nancy Anderson, Assistant Council Secretary
Robert Kessler, Director, LIEP
Frank 5taffenson, Deputy Director, LIEP
Nancy Thomas, Office of Administrative Hearings, l00
Washington Square, Mpls, MN 55401
Mary Nelson, Community Organizer, Downto
Development Council, 445 Minnesota St.,
St. Paul, MN 55101
wn Community
Suite 524
Hearing Notice - Page 3
1
�
STATE OF MINNESOTA )
) ss.
COUNTY OF RAMSEY )
� �5- 1`O�
AFFIDAVZT OF SERVICE BY MAIL
JOANNE G. CLEMENTS, being first duly sworn, deposes and says
that on June 13, 1995, she served the attached NOTICE OF HEARING on
the followinq named attorney by placinq a true and correct copy
thereof in an envelope addressed as follows:
Joseph J. Dudley, Jr.
Dudley and Smith
Attorneys at Law
2602 American National Bank Bldg.
101 E. Fifth Street
St. Paul, MN. 55101
(which is the last known address
the same, with postage prepaid,
Paul, Minnesota.
G.
o£ said attorney) and depositing
in the United States mails at St.
Subscribed and sworn to before me
this 13th day of June, 1995.
.�"�'�- �-�.� �
Notary�Public
� BEGYA J FLOYD �
�►ARI�PIIBLIC'MMYFSOTA �
. �� �
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covER ;
CHARGE i
S7.°O I
�i
CITY OF SAIN'T PAUL
Norm Co7oiwn, Maynr
June 14, 1995
OFFICE� THE CIT'1' ATTORNEY
r,m«h c„rar� e� _ \ \OCo
c;�;r �
400 Ciry HaII
ZS West KeAogg Blvd
Saint Paul, M'yuiesota 55102
Telep7ene� 612 2668710
Facdnrile 612 298-56Z9
NOTICE 08 RE3CHEDIILED HEARING
Joseph J. Dudley, Jr.
Dudley and Smi�h
Attorneys and Counselors at Law
American National Bank Building, Suite 2602
101 East Fifth Street
Saint Paul, Minnesota 55101-1896
RE: All licenses held by OPBM Inc. a Mianesota Corporation dba
Amelia•s Nite Club 8 Eatery, for premises located at 175 5th
Stieet East, # 140, St. Paul
Our File Number: G95-0166
Dear Mr. Dudley:
As you requested, the Administrative Hearing scheduled for Thursday
July 6, 1995 regarding the City�s adverse action against the
licenses of Amelia�s Nite Club & Eatery has now been re-scheduled.
The hearing is now scheduled for 9:3o a.m. on Wednesday, July 12,
1995. The hearing has been moved to room 42 of the St. Paul City
Hall/Ramsey County Courthouse and will be presided over by Judge
Bruce Campbell. Judge Campbell can be reached at the Office of
Administrative Aearings, 100 Washington Square, Suite 1700; phone:
341-7602.
very truly yours,
/��(K/ "`—
anet Reiter
Office of the City Attorney
cc: Nancy Anderson, Assistant CounCil Secretary
Robert Kessler, Director, LIEP
Frank Staffenson, Deputy Director, LIEP
Nancy Thomas, Of£ice of Administrative Hearings, 100
Washington Square, Mpls, MN 55401
Mary Nelson, Community organizer, Downtown Community
Development Council, 445 Minnesota St., Suite 524
St. Paul, MN 55101
Sgt. Per Tredal, Police Dept., Special Investigations Unit
■ �
dba Amelia's Nite Club & Eatery
� City's Exhibit No. 7 —
•
�
�S-1�n�
STATE OF MINNESOTA
COUNTY OF RAMSEY
ss. AFFIDAVIT OF SERVICE BY MAIL
JOANNE G. CLEMENTS, being first duly sworn, deposes and says
that on June 14, 1995, she served the attached NOTICE OF
RESCHEDULED HEARING on the following named attorney by placing a
true and correct copy thereof in an envelope addressed as follows:
Joseph J. Dudley, Jr.
Dudley and Smith
Attorneys at Law
Suite 2602 American National Bank Bldg.
lol East Fifth Street
St. Paul, MN. 55101
(which is the last known address of said attorney) and depositing
the same, with postage prepaid, in the Un�.t�d States mails at St.
Paul, Minnesota. / �
Subscribed and sworn to before me
this 14th day of June, 1995.
��--�.� �- ���.
Notar Public �—
� �.va,� �s.oYn '
R�Et� _COUHrY� �
Mr�m.6,ywes�,. s,.2aoo
.
�
• � S - ��06
Catherine A. Caturia, police decoy, St. Paul Police
Dept., 100 East llth Street, St. Paul, MN 55102
2. DOCUMENTS
Attached please find the following documents which the
City intends to offer into evidence at the time of the
hearing:
* Police Repoit CN 95-034-171, dated March 16, 1995;
* Znvestigation Report from Kris Van Horn dated April 3,
1995;
+ OPBM, Inc. license information, certified May 19, 1995;
* The City�s letter of complaint, dated April 20, 1995;
* A 3-page fax from Amelia�s to Mr. Philip Byrne of the
City Attorney's Office, dated April 25;
* The Notice of Hearing, dated June 13, 1995;
* The Notice of Rescheduled Hearinq, dated June 14, 1995.
3. The City is not in possession of any written or other
recordings of statements, summaries of statements, or
other reports made by witnesses or OPBM representatives,
beyond those written statements contained in attached
reports.
Please note that portions of the investigation report
prepared by Ms.Kris Van Horn have been blacked out, Those
deleted sections relate to compliance checks at various
other establishments and, therefor, are not relevant to
the City's adverse action against OPBM, Inc.
With regards to the City's discovery requests, at this time,
pursuant to the Rules of Administrative Hearings, specifically
Minnesota Rules §1400.6700, the City request the following:
1. The names and addresses of all witnesses OPBM, Inc.
intends to call at the hearing, along with a brief
statement of each witness' testimony.
2. Copies of any and all written and/or recorded statements
Discovery - Paqe 2
.y .
•
•
�,$- ��b�
made by any of the witnesses oPBM, Inc. intends to call,
and all written and/or recorded statements made by other
parties or witnesses.
3. Copies of any other document or thing OPBM, Inc. may
introduce at the hearing including any books, papers,
correspondence, documents, photographs, notes or other
tangible or relevant evidence, not privileged, that OPBM,
Inc., has obtained, whether or not intended to be used at
the hearing on this matter.
We would appreciate your prompt attention to these request. If you
have any questions, or have additional requests, please do not
hesitate to contact me.
Sincerely,
Janet A. Reiter
Office of the City Attorney
��• �..���_
Discovery - Page 3
^ • . �
°�S-1\e�
STATE OF MINNESOTA )
) ss.
COUNTY OF RAMSEY )
AFFIDAVIT OF SERVICE BY MAIL
JOANNE G. CLEMENTS, beinq first duly sworn, deposes and says
that on June 27, 1995, she served the attached LETTER on the
following named attorney by placing a true and correct copy thereof
in an envelope addressed as follows:
Joseph J. Dudley, Jr.
Dudley and Smith, P.A.
Attorneys at Law
2602 American National Bank Bldq.
101 E. Fifth 5treet
St. Paul, MN. 55101
(which is the last known address of said attorney) and depositing
the same, with postage prepaid, in the United States mails at St.
Paul, Minnesota.
Subscribed and sworn to before me
this 27th day of June, 1995.
�, � � �
: � �
. . .
■ .
� BELVA J. FL.OYD �
1q�NSY PI�UC - MItlNE50TA
RAMSEY CQUNTY
�Mtxnm, E»rces.ren. ai. z000
' • OFFICE �HE CITY ATTORNEY
Timothy E. Ciry Attarney
�S-\�O�
CTTY OF SAINT PAUL
Norm Co7entax, Mayor
Civil Divuion
400 Ciry Hall
IS PJett Keitogg Blvd
Saint Pau1 Minncsom SSIO2
Te7epfione: 612 266-871Q
Facsimile: 612 298-5619
July 3, 1995
3oseph J. Dudley, Jr.
Dudley and Smith, P.A.
Attorneys and Counselors at Law
1�1 East Fifth Street
Saint Paul, Minnesota 55101-1896
RE: All Licenses Held by OPBM, INC., a Minnesota Corperation
dba Amelia's Nite Club & Eatery
OAH Docket No.: 2-2101-9801-6
Your File No.: 3000.1
Our File No.: G95-0166
IIear Mr. Dudley:
Enclosed please find a copy of the St. Paul police report CN 95-
034-171, the last page of which was inadvertently left out of our
document package of June 27, 1995.
Sincerely,
Peter P. Pangborn
Paralegal
. �
dba Amelia's Nite Ciub & Eatery
— City's E�ibit No. 9 —
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TL�L-11�-1':'=+ 1�� 11 FF'i il t C 1 T l iiTTOPI IE �`;, i iFF I CE
CITY OF SAIi�IT PAUL
Na>q Caltmcn, hfmW
Ju{y 10, i995
FAX TRANSMtSSION
DATE:
TO:
RE:
Judge Bruce Campbell FAX No.: 349-2665
Ofilce of Adminlstrative Hearings
7-i �� 1•� „ i _ .
OFf OF'I'F{F CCC1' A"1"P(1RNFy
Timorky E. Meu.c, C.'�ry,#arv„eN \ � j' � /
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Amelia's Nite Club & Eatery - Notice of Hearing (incfudes charges)
NUMBER OF PAGES (induding cover page): 5
FROM: Peter Pangborr.
Paralegal
St. Paui City Attomey's Office
400 City Hail
FAX No.:298-56t9
!f ycw Uo not rece� a(1 pages ot thfs trartsmission, please cprttact:
Peter Pdngbotn Telephane No. 266-8776
Tt IL-1� �-195� i=' � ll FPOhI C 1 T\ t1TTOF9 IE� =. OFF I CE TD
'�--1?_r.e.�_ F, i i_
OFFIC �F 7'FI� CITY f+'ITORNEY
` r� cuy,,�,,»e
`�S 1�0�
CTTY QP SAINT PAUL
Norm Co�ema+� 1Sayer
June 13, I995
� ��n
� Gn NaU
IS W�sr KeAOgR $iwL
Saiu Pau{ Mi�viecn:�t 5510"1.
DTOT;CE OF HEARINC3
Joseph J. Dudley, 3z.
Dudley and Smith
Attozneys and Counselors at Law
American National Bank Building
Su�,te 2602
101 East Fifth StYee.�
Saint Paul, Minne:,ota 55101-1896
RE: All licenses held bp ORSM ZnC
Aateiia�s xite Club & Eatery,
Strest East, } 1d0 St. Paul
Our Flle Nu�ber: G95-0166
lrlephon�' bl: ?R(r�7; 0
Fn(s.ntv r;i: ?A+t-cr:,'O
. a Minnesota Corporation dba
Por premises located at 175 sth
Dear Mr. Dudley:
Please take notice that a hearing will be held at the followinq
time, date and place concerning a11 licenses for the premises
stated above:
Date: Thursdap July 6 1995
T�mQ: 9:30 a.m,
P�ace: Room 41
5t. Paul City Ha$I
15 W. Rellogq Blvd.
3aint Paul, MN. 55102
The hearing will be presided over by an Administrative �w Judgc
from the State of Minnesata Office of Aduiinistrative Hearings:
Name: 7111en Gil�s
office of Administsative Hearings
10o Washxnqton Square, Suzte 1700
Minneapolis, MN. 554D2
TelephOne: 349-25�43
The Council of the City of Sair�t Paul has the authoxity to provide
For hearings concerning licensed premises and £o; adverse action
7UL-l�i-i'=''?5 1�:1_ FF'iihl CIT� NT1iiF1VE,'�. iiFF1�-E Tii
'J:.-P.,��.r;
__ �5- 1\��
against such licenses, under Chapter 310, including sections 310.05
and 310.06, of the Saint Paul LegislativP Code. In the case of
licenses for intoxicating and non liquor, avthority i;
also conveyed by M�nnesota Statutes section 340A.415. Adverse
action may include revocation, suspension, fines and other
penaltias or conditions.
Evzdence will be presented to the judge which may lead to adverse
action against all the licenses held at the above Prenises a�;
follows:
"That on Hnrch 16, 1995, at approsimatelp l0:0o p,m., a
minor purchased beer on the licensed premises witbout
being asked foz any identification as to age. The minor
xas accompanied to tEe estabiishment by nn employee og
the iicense office aad � plain clothes policQ officer.
Tha sale to the minoZ° vas a violation of Section d09.08
o£ the Saint Paul Leqislative Code, as well as of state
ldw� Miriti. StaSt. § 340.503 (1994) ,e�
The hearing wi11 be conducted in accordance with the requirements
of Minnesota Statutes sections 14.57 to 14.62 and such parts of the
procedures under Section 310.05 of the Saint Paul L Code
as may be applicabie.
AC the hearinq, the Administrative I,aw 3udge w�ll have all parties
identify Lhemselves for the record. The City r��ll then present its
vitnesses and evi.dence, each of whotn you may cross You
wil.l then have an opportunity �o of£er in rebuttal any witnesses or
evidence you may wish to present, each of whom the City's attorney
may cross-examine. The Administrative i,aw Judge may in addition
hear relevant and material testimony from persons not presented as
wit�esses by either party who have a substantial interest in Che
outcome of the proceeding; for example, the owners or occupants of
property located in close proximity to the licensed premiUes may
hav�. subsCantiai interesC in the outcome of the proceeding.
Concluding arguinents may be made by the parties. Fallowzng the
hearinq, the 3udge wjll prepare Fir.dings of Fact, Conclusions of
�w, and a specific recommeridation for action to be taken by the
City Counci7.,
You should bring to the hearing all documents, records and
witnesses you will or may need to support your position. Subpoenas
may be available to compe2 the attendance of witnesses or the
production of documents in conformity witla Minnesota Rules, part
14o0.7poo,
If you think that this matter can be resolved or settled without a
�ormal nearing, please contact the undersigned. if a stipulation
or agTeement can be reached as to the Pacts, that stipulation w311
be presented to the Adzninistzative Law Judge for incorporation into
his or her recommendation for Council action,
,
xearing Notice - Page 2
TI iL-1U-19'?S 1_ � 1_ FF•i il y �: [ T � HTTi IF•I lE'� =. i iFF I CE 1 D ',�.��.:�-� �. ,
'- -- q 5 .1 `O �
Zf no one appears at the hearing on behalf of OPBM, Inc., then the
allegations against OP$M, Sne. c�hich have been stated earlier ir.
this notice may be taken as true and OPgM, Inc_�s ability to
challenge them forfeited. IP non-pubzic data is received 9hto
evidence at the hearing, it may become public unle;,s objection i�
made and Telief Yequested under Minnesota Statutes, Seciion 1c.50,
subdivision 2.
Very tru3y yours,
Janet Reiter
Office of the City Attorney
cc: Nancy Ariderson, Assistant Council Secretary
Robert Kessler, Director, LIEP
Frank Sta£fenson, Deputy Director, LIEP
Nancy Thomas, ofPice of Admi.nistrative Hearings, 100
Washington Square, Mpls, MN 55401
Mary Ne2son, community Organi2er, powntown Community
Development Council, 445 Minnesota St., Suite S29
St. Paul, MTI 551o1
Hearing Notice - Paqe 3
'yl� "_:�
-;. �-x' '( f � �i'7i7F`t IE i'S tJFF 1 CE
Ti��
=�1.1�a: ,, r
°� 5- \1 O�
STATE OF MINNESOTA )
) s�.
COUNTY OF RAMSEY )
AF'pIDAVIT op_SERVICE BY MA7L
JOANNF. G_ .^.LEMENTS, being first di�ly sworn, deposes and say:;
that on Jun� 13, 1995, she served the attached NOTiCE UI' HF.ARTNG on
the following named attorney by placing a true and correct copy
thereof in an envelope addressed as fo2lous:
Joseph J, Dudley, Jr.
Dudley and Smith
At.torneys at L.aw
2602 American National 13ank Rldc�.
101 E. Fifth StreeY_
5t. Paul, MN. 55107
(which is the last known address of said attorney) and depo.ritinq
the same, with postage px�epaid, in th�n\ ted States mails at :;t_
Pdul, Minnesvta. / �
. � CLEM�N'i'S
SubsCY'ibed and sworn to before me
this 13th day of June, 1995.
� �
`=�0�f ��tzs�.-t/
Notary Public�
����-YA J. E1.�YD
� C%Ol�'i'Y
� �M.1m. 31. 20�0 �
T�iirtl f='.(i�-.
�( S- iloG
< TRANSACTION REPORT >
C REC�IVE ]
( ��.?(�
NO. DATE TIME DESTINATION STATION
a702 7-1� 12:17 612 298 5619
PG. DURATION !tODE RESUL
5 O`02'03' NORr�.E Ok
5 J° 02 03'
CITY OF SAINT 1'AUL _: `= : _ .
NamCdeman,Ma}m `.+: .,�:'� i �j F:; L ' . .
^t. _
June 16, 1995
Judge Bruce Campbell
Office of Administrative Hearings
100 Washington Square, Suite 1700
Minneapolis, Minnesota 55401-2138
OFFICE OF'PHE CITY ATTORNEY
TmoUry E. Ma+i Clry Attor^e}' Q S �, O Ce
i
CFvrl Divivon
400 Ciry HaR Telephone 612 266�8710
15 Wec Ke!!o� Bivd Facdnule 612 �R5619
Saint PauT Mv+newta SSIO2
VIA FAX AND U.S. MAIL
RE: In re The Licenses of OPBM Inc. a Minnesota Corporauon dba Amelia's Nite Club
& Eatery
License ID No. 43264
Our File Number: G95-0166
Dear Judge Campbell:
The purpose of this letter is to request subpoenas pursuant to Minnesota Rules, part
1400.7000 relating to the above-mentioned contested case hearing that is scheduled to be
heard hefore you on Wednesday, July 12, 1995. This request is made of behalf of Ms. 3anet
Reiter, the attorney assigned to this matter. The City of St. Paul License Division will be
calling these witnesses to testify regarding the incident which serves as a basis for the action
against the licenses of OPBM Inc. a Minnesota Corporauon dba Amelia's Nite Club &
Eatery.
In order to ensure these individuals will be in attendance to testify, the City of St. Paul
requests from the State Office of Administrative Hearings suhpoenas for the following
individuals:
1.) Sergeant Per Tredal
St. Paul Police Department
100 E. llth Street
St. Paul, MN 55101
3.) Catherine A. Caturia
St. Paul Police Depaztment
100 E. llth Street
St. Paul, MN 55101
2.) Richard P. Loesch
5t. Paul Police Department
100 E. llth Street
St. Paul, MN 55101
If you need additional information or ha�e any questions regarding this request, please do
not hesitate to contact me at 266-8776. Thank you far your consideration in this matter.
_ »� .,�,-�-
OFFlCE OF THE CITY ATTORNEY
r,.�y �. arm� c;ry wrr�,� d' S��� Q(�
t
CTTY OF SAII�IT PAUI; =- =: �- :_- - cMr D;,�,
Nomt Coleman, Mayor , : 400 Ciry Hall
�� .��.. i �.�', �.,. , . 15WeuKr.77oggBlvd
Saint Pa�{ Mtnnesora 55102
June 14, 1995 "" �"°
NOTICB OF RESCHEDIILED HEARING
3oseph J. Dudley, Jr.
Dudley and Smith
Attorneys and Counselors at Law
American National Bank Building, Suite 2602
101 East Fifth Street
Saint Paul, Minnesota 55101-1896
Te7ephone 6I2 266E710
Facsimile 6I2 2985619
�: Aii l�ceases �ei3 by aPBM Zac. a Mia�es�ta Co=pn==taa� dba
Amelia�s Nite Club 8 Eatery, for premises located at 175 Sth
Street East, � 140, St. Paul
Our File Number: G95-0166
Dear Mr. Dudley:
As you requested, the Administrative Hearinq scheduled for Thursday
July 6, 1995 regarding the City's adverse action against the
licenses of Amelia's Nite Club & Eatery has now been re-scheduled.
The hearing is now scheduled for 9:30 a.m. on WeBnesday, Suly 12,
1995. The hearing has been moved to room 42 of the St. Paul City
Hall/Ramsey County Courthouse and will be presided over by Judge
Bruce Campbell. Judge Campbell can be reached at the Office of
Administrative Hearings, 100 Washington Square, Suite 1700; phone:
341-7602.
Very truly yours,
i�,�/-�-
anet Reiter
Office of the City Attorney
cc: Nancy Anderson, Assistant Council Secretary
Robert Kessler, Director, LTEP
Frank Staffenson, Deputy Director, LIEP
Nancy Thomas, Office o£ Administrative iiearings, 100
Washington Square, Mpls, MN 55401
Mary Nelson, Community organizer, Downtown community
Development Council, 445 Minnesota St., Suite 524
St. Paul, MN 55101
Sgt. Per Tredal, Police Dept., Special Investigations Unit