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96-75Council File # 9 G _ �(5 Green Sheet #� S� 3 1 Presented By RESOLUTION CITY OF SAINT PAUL, MINNESOTA a� � . _,_._._. �.. .U---, ..___._.__ ._.._.__�_ �— z. . ....___ . _._.,._ .. .. __ . _ -�`��-�� Referred fio �� Committee: Date 1 2 RESOLVED, that a fine in the amount of $1000.00 be imposed against the licensee, 3 Josha Corporation, d/b/a AAbe's Family Discount Center/Aabe's Music Shoppe, 1933 4 University Avenue, West, St. Paul, Minnesota for the violafion of St. Paul Legislative Code § 5 355.04 (h). On or about April 19-22, 1995 and subsequently, the license holder was 6 operating as a second hand dealer at 1933 University Avenue, West without the appropriate 7 licensure. This fine shall be paid witkrin 30 days from the date of adoption of this Resolution 8 by the City Council, and be it 9 10 FURTHER RESOLVED that Josha Corporation, is required to pay a portion of the i l admnristrative law judge costs incurred by the City of St. Paul in connection with the hearing 12 in this matter, in the amount of $400.00 within 30 days from the date of the adoption of this 13 Resolufion by the City Council, and be it 14 15 FURTHER RESOLVED, that the findings of fact, conclusions of law and 16 memoranduxn contained in the ALJ Report in this case, dated December 5, 1995, are 17 expressly ra6fied adopted as the written fmdings and conclusions of the Council in this 18 matter, and the recommendations of the ALJ is hereby adopted. 19 20 This resolution is based upon the record of the proceedings before the ALJ, including 21 the heazings held on September 21, 1995, November 9, 1995 and November 15, 1995, the 22 documents and exhibits introduced therein, the testimony of witnesses heard, and the 23 deliberations of the Council in open session on January 3, 1996. 24 25 A copy of this Resolution, as adopted, shall be sent by first class mail to the 26 Administrative Law Judge and to the attorney for the license holder, Timothy Poixier. Requested by Department of: By: Approved by yor: Date °'/ � gy; L.�?��X/° .�- l/ By: Form Approved by City Attorney By: o ` Approved by Ma r for Submission to Council sy: Adopted by COUnCil: Date �. ` Adoption Certified by Counci Secretary City Council :ONTACT PEfl50N 8 PMONE Nancy Anderson AUST BE ON CAUNCIL AGENDA BV (DAT� January 17, 1996 TOTAL # OF SIGNATURE PAGES 1/8/96 � GREEN SHEET a OEPARTMENT OIRECTOE Q Cf1YATiOflNEY O BUDGET DIRECfOR � MAVOR (OR ASSISTAN7� (CLIP ALL LOCATIONS FOR SIGNATUHE) q�-�s N_ 3563� iNmawa'rE — O CRY CAUNCiI � cm c�aK O FIN. & MGT. SERVICES pIR. 0 --. . . ----�-- �-- _.. .--_._ .— �--- ------ �-------- - - Finaiiziug City Eouncii action taicen January 3; i956; concerniug adverse action against licenses held by Josha Corp., dba Aabe's Music Shoppe, 1933 University Avenue. HECAMMENDATfONS: Apqove (A) or Rejeet (R) _PLANNMGCOMMISSION _qVILSEFiVICECAMMISSiON _ CIB COMMITTEE _ _ STAFF _ _ DISTpICTCOURT _ SUPPOFTS WHIGN COUNCIL O&IECTIVE? What. TOTAL AMOUNT OF TRANSACTION S PERSONAL SERVICE CONTFiACTS MUST ANSWER TXE FOLLOWINCa QUESTIONS: t. Has this personlfirm ever worked under a contract for this depar6nerrt? - YES NO 2. Has this person/firm eve� been a ciry employee? YES NO 3. Does this person/firm possess a skill not nortnally possessed by any current city employee? VES NO Explain a�l yea answero on seperate sheet antl attech to green sheet COST/REVENUE BUDGETED (CIHCLE ON� YE5 NO FUNDIHG SOURCE ACTIVITY NUMBER FINANCIAL INFORMATION: (EXPLAIN) OFFICE OF THE CITY ATTORNEY TimoUry E. Marx, Ciry Attorney �� (�� CITY OF SAINT PAiJL Civi! Division Nonrs Coleman, Mayor 400 Ciry Hall TeZephone: 6I2 266�770 I S West Kellogg Blvd. Facsimile: 672 298-5619 Saint Pau� �nnesota 55102 ___.._._ .. . __. __ .. . . _ ___ _' " „"' ." ...___.___ .._._.___...____.�..._.'__.—..._._.___�__.__�. =_ �__ ._.arrt...,_._ .' _......,.... _ _ _ _ _. _ _ January 5, 1996 �'° - � � m... .. - .�� Nancy Anderson 310 City Hall 0 RE: Wednesday, January 17, 1996 Council Hearing Item for Consent Agenda: Aabe's Music Shoppe Nancy: Attached is the signed resolution identifyinq the penalties imposed by the City Council on Aabe's Music Shoppe. Please schedule this item for the Consent Agenda for the Council Hearing on Wednesday, January 17, 1995. Thank you. Paralegal �tc-�s LOWSY HILb LAW OFFIGES ANASSOCIATICN. NQlAPqHL4ERSHlP WILLIAN J. HANLEY TIMOTHY B. POIRIER MARKV.LQFSTROM � '".'__ " - _ __"'. ° '- "_ _.. _. _. .. ."".'" .,_. _. _.. _... _ ._ " -__ _'. __ r . . __ _ _ _ _ OFGOUNSEb � JOHN W. HARRIG/+N i900 HENNEPIN AVENUE SOUTN M W NEAPOL15. MINNESOTA SSCO3-3i98 <6i2) 872-0222 LEGAL ASSISTANTS: _ _____. __ "_iFPcPHY�KA2IPP{'°.—__"'�.._�"__.._......��""__' _ "' CYNDY KOEPP-MALHEREK LUANY SKRIVSETH December 19, 1995 Nancy .�.^dersa� Council Secretary Room 310 City Hall St. Paul, MN 55102 Re: In the Matter of All Licenses Held by Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe with Premises Located at 1933 University Avenue West and 1730 University Avenue West, Saint Paul OAH File No. 91-2101-9995-3 Dear Ms. Anderson: The undersigned attomey represents Josha Corporation. My client would like an opponunity to be heard before any adverse action is taken by the City Council. Please advise me when this matter will come up for consideration. Sincerely, LVC� 1TL1LL L�`V1� V�i1LLU � ) � � � Tnnothy B. Peix`ier TBP:kk � \� � V (1 - ---_.. cc: Mr. Shawn Sweeney STATE OF MINNESOTA OFFICE OF ADMINI5TRATIVE HEAItINGS 100 Washington Square, Suite 1700 100 Washington Avenue South Minneapolis, Minnesota 55401-2138 ��-2S December 5, 1945 Gail L. Langfield Assistant City Attorney 40Q City Hall 15 West Kellogg Boulevard Saint Pau1, Minnesota 55102 Timothy B. Poirier Attomey at Law Lowry Hill Law Offices 1900 Hennepin Avenue South Atinneapolis, Atinnesota 55403-3198 Nancy Anderson Council Secretary Room 310 City Hall and Courthouse Saint Paul, Minnes�ta 55102 RE: In the Matter of All Licenses Held by Josha Corporation d/b/a Aabe's Family I3iscount Center/Aabe's Music Shoppe svith Premises Located at 1933 L'niversih� Avenue West and 1730 Unn�ersity West, Saint Paul; p�YI File No. 91-21U1-9495-3 Dear Counsel and Ms. Anderson: Bnclosed please find the unde�si�ed's Report in the above referenced matter. Yaurs ?ruly, x/�,uy �'• ��'Lfi��i�L / \" ` 3aiw' A. McPeak Administrative Law 7udge Providing Impartal Hearings for Govemment and Citizens An Equal Oppo rtunity Employ Administrative Law Section & AdministraUve Services (612) 341-7600 s TDD No. (612) 341-7346 � Fax No. (612) 349-2665 91-2101-9995-3 --------._. �.,,.__.. __.._ .-- -_ _-__ = OF 1VIIIQNESOTA OFFICE OF AD�S'TRATIVE HEARINGS FOR TI� CI'I'Y OF SAINT PAUL In the Malter of All Licenses Held by Josha Corporation d!b/a Aabe's Fam�Ty L�,�e^�.r: : C�±er,�P.ah�'s ivinsic Shoppe with Premises Located at 1933 Uiuversity Avenue West and 1730 University Avenue West, Saint PauJ I�'INDINGS OF FACT, CONCLUSIONS AND RECQI�IME\TIJRTION °� �- - '�S The above-entitled matter came on for hearing before Adminisirative I,aw 3ucige 7ane A. McPeak, acting as Hearing Officer for the City of Saint Paul, on November 9, 1995 in Conference Room B, in Room 220 of the Razttsey County Board of Comnussioners and on November 15, 1995 in Room 42 of the Saint Paui City Ha]URamsey Counry Courthouse, Saint Paul,lblimiesota. Gail L. Lang&etd, Assistant City Attomey, dffice of the City Attorney, 400 City Hall and Coucthouse, 15 West Kellogg Boulevard, Saint Paul, Minnesota 55142, appeared on behaL° of the City of Saint Paul Office of Licenses, Inspections and Environmental Protection (City). Timothy B. Poirier, Attorney at Law, Lowr_y Hill Lat�� Offices 190d Hennepin Avenue South, Minneapolis, Mirniesota 55403-3r48, appeared on behaif of Josha Corporation d/b/a Aabe's Family Discount CenterJAabe's Musie Shoppe (Licensee}. T1ie record in thss matter was closed on November 15, 1945. Tlvs Report is a recommendation, not a finai decision. After a retiiew ofthe record, the Council of the City of Saint Paut will make the final decision wluch may adopt, reject or modify the Findings of Fact, Conclusions and Recommendafion contained herein. Pursuant to Saint Paul Legisiative code aecTion 314.03 (c-1), after receipt of this Report, the city Councit shall provide an opporCUnity to present oral or written ugument alleging error in this Report and to present argument re3ated to any recornmended adverse action. The parties should contact Nancy Anderson, Council Secretary, Room 310, City Hall and Courthouse, Saint Pau1,lVTinnesota SS 1Q2, to ascartain the procedure for filing such ugmnent or appearing befoze the city council. STATEMENT dF ISSUE The issues in tlris case are as follows: 1_ Whether on or about April 19-22, 1995, employees or managers of the Licensee sold properry witiain ten days of hauing purchased such property in violarion of section 355.04 (c} of the Saint Paul I.egislative Code. q �� Z. W#tether on or about April 19-22, 1995, employees or managers of the Licensee failed to keep an accurate and comprehensive record of ut ' ' ' ---- ----- --_-- --- - - ---- : -- p - ci�ases,-.in - — - __._ - _ _ __ � —_. _ _.- - 35504 (bj o�tfie Sautt�anl Legislative Code. 3. �iJhether prior to Apn1 19-22, 1995, the Licensee transferred the location of ttte license in violafion of section 355.04(h) of the Saint Paui LegislaTive Code. 4. Whether on or about Apr� 19-22, 1445, employees or nunagers of the Licensee failed to comply with record keeping requirements in violation of section 344.04(a} of the Saint Paul Legjslative. 5. Whether Licensee's motion for attomey's fees shouid granted. Based upon the record herein, the Admiiustrative Law Judge makes the following FINDINGS OF FACT 1. 3osha CorporaCion operates a second hand store, wiuch aiso sells new goods, at 1933 University Avenue West in Saint Pau1. Shawn Sweeney is the owner and Erik Swenson the manager of the store. 2. t7n or about April 19-22, 1995 Josha Corporarion was licensed as a second hand dealer-single at 1730 University Avenue W est in Saint Paut but did not have any licenses ta conduct a second hand dealer business at 1933 University Avenue West in Saint Paul. 3. Qn or about Apri119, 1995 the Licensee transferred opera#ion of the 1'I3Q Urriversity Avenue West store to 1933 Universiiy Avenue West. Licensee did not notify the Ciry of this transfer or receive peiniission from the City to do so. 4. On Apri116, I995 there was a burglaay at the home, specifically iu the garage, af Gearge and Donna Moschkau, 836 Mound Street, Saint Paul, Minnesota 55106. Taken in that burgtary was musical equipment 5. After the bur�llary, George and Donna Moschkau created a list of items stolen {City's E�ibil 1}, gave it to the Saint Paul Police Department, and masled or took it to second hand stores and pawn shops throughout the city of Saint Paul. 6. On Apr� 22, 1945, wtiile delivering the fist of stolen property to stores, ihe Moschkau stopped at Aabe's Famify Discount Center at 1933 Uiuversity Avenue West in Saint Paul, which was lsaving its grand opening. While George Moschkau s[ayed 'm the car, Donna Mosch�au went into Aabe's. She spoke with a clerk who said that ha thought that one of the items on the list, a Sunn Light Console, was in the store. He took Donna Moschkau to see the item and she confirmed that it was theirs because there were piciutes on the back which belonged to them. At this point she left the store to get her husband. q c� - �s 7. The Moschkaus entered fhe store and spoke with owner Shawn SweeneY� whom George ivloschkau had known previousfy through Sweene�'s_bo_okinQ..�a��_far-Uazuls.--._.-_---------_ - --- - --- -� - `" �S�iacvn S`weene}� pernufted tfielvfosclikaus to look around the store for additonai items which tkey recovered and carried from the sales floor to a part of the basement ta insure that they woutd not be sold. Itetns recognized by the Moschkaus included diamier packs, tnike caUles for lights , canis'ters, fIaod Iights, one TD 40 stand, a Boss monitor, speaker cords, and a littte box which contained a headphone extension cords, and other items with Creorge Moschkau's initials on them. Not all of the items taken in the burgSary were faund at Aabe's. S. 'The iviascnkaus and Shawn Sweeney discussed what should be done. Sweeney did not want to call the police ax that time. Initially, the A�oschkaus ag�eed with this approach; however, after they left the store they changed their minds due to some feelittgs of uneasiness as to how forthcoming Sweeney had been and as to what might happen to their gootls which they had found anfl to any others Rrhich may have been there but as yet undiscoverd. 9. The Moschkaus called the Saint Pau1 Police Department which instructed them to retum to the store u>here an officer would be dispatched. Joining thsm at the store was Ofiicer Therese Moyer (now L.earmont). Before entering the store Officer Learmont spoke cvith the "dioschkaus wha briefed her about the burglary. 14. Once inside Aabe's Officer I,earmont spoke with owner Shawn Sweeney and mat�ager Eritc Swenson who produced the name of Ronald Kies as the seller from the Pawn Bu=.� frnn (City's F�hr�biY 3 and 16). 11. RonaSd Kies and two unidentified men came into Aabe's at 1933 I3niversity Avenue West on Apri119, 1995 to sell musicat equipinent. To ensure tliat the t�vo uttidentified men were trtily the owners of the equipment Swenson asked them to set it ug which ihey did. Swneson then offered them a lump sum of $135.00 for the equipment listed on the Pawn Buy fomn and told thezn that he was not 'snterested in miscellaneous other items wiuch the men left in the store. 12. Ronald Itiies had met the two unicientified men at At1as Temporary Service. These men, who in conversation with Kies had learned flf hss musicai background, had some mvsicat equipment for sale and asked Iues if he could help them. Iiies accomganied them to Aabe's where the eqiupment was unloaded, set up by the two unidentified men, and soid. Kies used his license for the Pawn Buv fotm because neither of tha other two men liad identification {City's E�ibit 10). 13. On Apri12�, 1995 Roanld Kies returned to Aabe's with Jahn Foster, a friend, and attempted to buy back the musical equipment for $135.Q0. Erik Swenson refused to sell it for less than $500.00. Kies told Swenson t1�at he believed that the items were stolen. Swenson still refused to sell the items for $135.00. q 6 - �S 14. Officer Leazmont found Sweeney and 5wenson to be fairly uncooperative and felt that they were not forthcomin� with inforniation. She did note fhat_� stor�,�as �a- --- � ___ -= - = - —. .- -_ -- _- .:--==��'ape�tg�c�fomeis were preseat Slie observed the items taken to the basemenx ' She wrote a report (Cify's E�iiUit 14} and took tivith her the completed Pawn Buy frnm, wiuch did not contain all of the items found in Aabe's. Officer I.eannont and the Moschkaus ihen leit Aabe's. 15. On Apri125, 1995 George Moschkau returned to Aabe's where he met Saint Police Sergeant Michael Garvey who wrote a report (City's E�ibit I3} listing the items recovered and helped Moscl�kau cazry the items from the store to his caz. One of the items, �iF31�I � 4C Lighi Tree, listed on the Pawn Buy Form was not recoverd Neittzer Sergeant C'rarvey nor OfficerLearmont's reports were accurate as to the items recovered. City's E�ibit 9 sets forth a compresensive list af the property recovered from the Licensee. 16. The Moschkaus estimated the replacement value of the equipment recovered at $1200.00. They produced receipts for many of those items, some of wluch were samewhat old. 17. Manager Swenson paid $I35.00 for a total ofnine items, none of which he valued individvall}r as oti�er $50.Q0 and did not provlde any additional eonsideration for the items recovered but not listed on the Pawn Buy form. Some of those items, like the Ibanez foot conh�oller, lig�t cables and extension cords, were not wanted b}� Swenson but le8 at the store by the two unidentified men. Other items, like the li�t gel frames, the floodli�ts, and gel palsa: �he�ts, �vere in.e�ai t arts af d��e items liste� ��7 the P�mn Bt!c fottr a;�d were considered to be part of ihose systems so that no additional consideration was gven for them 18. Tha Licensee's policy regarding the purchase of second hand goods is to pay no more than 10% of the list vatue as set forth in Orion a blue book of musical equipment. 13. Over the last year the Licensee sustained considerable losses amibuted to shaplifting at the 1730 University Avenue West location. 20. Qn or about the first iveek of 7une 1995 Saint Paul Police Officer Paui Polyak, acting pursuant to a complaint filed by Domia Moschkau, spoke with Shawn Sweeney about his licensure and informed him thaY the license could not be transferred and that applicarion must be made to.the City for a license at the 1933 University Avenue West localion. Sweeney seemed unsure of the recarding requirements and the ten day holding period for goods purctiased for $Sd.00 ar over. Officer Polyak asked Sweeney to send the Pawn Buy forms to him in the future. Previously, second hand dealer licensees had been instructad not to send the Pavm Buy form to the pofice department. 21. In August or September 1995 Chr'sstine Schwzinler, senior license it�pector for the City's Office of Licenses, Inspections, and Bnvironmental Protection, sent a written notice qc�-�1s to 3osha Coiporafion that titere were no licenses issued to 1933 Unnretsity Avenue West and that application must be made fon c�en.5ur.e. at,tfiatlocaiio�.--- _------ _--- .--- 22. Qn August 31, 1995 the Office of the City Attornep sent Licensee a Notice of Hearing stating that a he arin9 would be held an Thursda}=, September 21, 1995 on all ficenses for the premises at 1933 and 1'730 Umversify Avenue Wes� The Nofice set forth infonnation about the autharity of the Cit}� to hoid hearings wluch may result in adverse acfion against a licensee; that the bases for the adverse aciion hearing ag,ainst the licensee were violations of Saint Paut L,egislative Code section 355.04 - in the selling properiy witl�in ten days of ha�ing purchased or received it, in the falure ?e keep � a;,c•�:rate an.�'z comprehensive record of the properry purchased or received, and in the transfer of the location of the licensed premises; about the hearing procedures; about consequences for not attending a heatin�; and about the fact that a settlement would cause the heazing to be cancelled. 23. On 5eptember 26, 1995 the Office of the City Attorney, pursuant to an Order of the Aclinuristrafive Law Judge, sent the Licensee additionai inforxnation as to the allegations in the August 31, 1995 Notice and notified the Liaensee that the City intended to present evidence alleging tttat the Licensee had violated Saint Paul I,egisiative Code sectian 344.04(b} by failing to comply with record kaeping requirements and to promptly provide the police with copies of the Pawn Buy Form. 24. Nn adverse action has previously been taken against the Licensee for any violatians of the Saint Paul L,egislatn�e Code. CONCLUSIONS 1. Tl�e Saint Paul Ciry Councii and the Administ�•ative Law Judge have jurisdiction in this matter pursuant to MiFm, Stat. section 14.55 and Saint Paul Legisiative Code sections 310.05 and 310.06. The Nofices issued by tlxe City were proper and all applicable substantiva and procedurai requirements have been fiilfilled. 2. Saint Paut Legislazive Code section 310.Ob allows for adverse action to be talcen against a licensee for, among other grounds, any violation of airy provisions of the Saint Paui I,egislative Code or of any statute, ordinance or regulation reasonabh� related to the licensed activity. 3. Saint Paul Legislative �Code secrion 355.44(h} grovides that no second hand dealer license may be transferred to a different location. For a first violation of operating as a second hand dealer at an uniicensed locarion the City recommends a$i,d00.d0 fine. This recommendation is based on the City's liquor license matriY and represents a base fine. The City has a matriY onty for fiquor ficense violations and for none other. 4. C3n or about Aprii 19-22, 1995 aszd subsequentty the Licensee viotated Saint Paui Legislative Code section 355.04(h) by operating as a second hand dealer at 1933 Universiiy Avenue West without the appropriate licensure. q�-�s 5. Saint Paul ' lative Code section 355.Q4 r wres that-atShe_Yimie-a� ' ' _---- — - - _ -- -.-_ . �—_ - � -_ � _._ --- - ==°a�itemfor=wl'ucTi�e"seeonifiiand goods dealer has paid $50.00 or mare, t�at dealer keep � a record which clearly and legibly sets forth an accurate account or descriprion, in Bnglistr, of the goods purchased $:e amount of money paid the date and time of the receipt of the gaods, the name and address verified by a vatid Minnesota tiriver's license ar ideutification card of the person selling the goods, and the serial numbers and brand names of the gootls. 6. The Licensee did not vioiate Saint Paui L�gislative Code section 3SS.Q4(h} because the City failed to produce any evidence s22owing that the Licensee pad g50.�Q ar anore Ye: item iisted on li Pawn Buy fozm or that the Licensee paid $54A0 or more for each item recovered but not Sisted on the Pawn Buy form. Testimony as to the purchase price or replacement value of goods is insu.�f'icient to establish that certain amounts were paid for second hand goods. The City alle�ed that this section applied also to goods received by a second hand dealer. Nowhere in section 355.04(h} is the plvase purchased or received ased 7. Saint Paul L,e�slative Code section 355.04{c) provides that second hand properky purchased may not be sold or be pernutted to be removed from the premises for a period of ten days after acquisirion. S. The Licensee did not violate Saint Pau1 Legislative Code section 355.04{c) because the City faited to present anp evidence that the licensee sold or otherwise gernvtted removal from the premises any of the property bought from Ronald Iiies and the iwo unidentified men k: companyin� hizn. �1ere abser.ce of an SYem p�arch�s,d bist not recovered does not establish by a preponderance of the evidence fliat the licensee sold or otherswise pern�itted the removal of that item. 'The City alleged that this section applied also to goods received by a second hand dealer. Nowhere in section 355.d4(c} is the ghrase purchased or received used. 3. Saint Paui i,egislative Coda section 344.04 (a) sets YorCfi the record keeping requirements required for a pawnbraker and secfion 344.04(U} requires the gawnbroker to file a copy of those records with the police department. 10. The Licensee did not violate Saint Paul I.egisiative Code section 344.05{a} and (b) because there �>as no e�ddence produced at the hearing ta prove, nor did the City allege, that the licensee was engaged in the acti��ity of opexating as a pawnbraker, Section 344.05(a) and (b} tloes not hy its terms apply ta second hand dealers. 11. In the absence of a specific statutvey or ordinance provision or an agreeznent or stiptilation to pay them, flte general rule is that attomey's fees, or a part}�'s costs and disbursements, may not be awarded in as adminiatrative proceeding. The Conncil of the City of Saint Paui did not provide for the award of attorney's fees in Legislatzve Code adverse actions hearings. Q � � 1 •� Based upon the foregoing Conclusions, the Adminisirative Law Judge makes tha foIlowing: — __ � RECOtiIIvIENDATION TT IS RESPECTFUI,LY RECdIvIIvIEI3DED that the Council for the Ciiy of Saint Pau1 take adverse acfion against 3osha Corporation for the violation of operating as a second hand dealer without a license as established in the Findings herein. Dated this 3� day of December, 1995. �- �Q-• 7�te-Pe<�� a. McP�Euc Admittirtrative Law Judge NOTICE Pursuant to Minn. Stat. Section 14.62, subd. 1, the Cin� Council is requested Co serve its fin�l decision upon each �±arn� and Ehe Administratzne Tan� ?ti�we b f��t c?F�C s?�ail. Reported: Tape recorded. 7 � � -�s STATE OF MINNESOTA IIISTRICT COURT _-, _ == ,—_v_ _ ._ . _-.� . - ,-= - .#:��3F��G7SEY` - SECOND JIJDICIALDIS`IRICT AFFIDAVTI' dF JANE A. MCPEAK State of ivlinn.esota County of Ramsey ) j ss. ) 7ane A. McPeak, being first duly sworn, deposes and states: That in compliance with Mum. Stat Section 14.50 and Muuiesota Code of Agency Rules Sectian 1400.8100, I have prepared a Report Itt the Matter of A11 Licenses He1d b_y Josha Coiporation dibfa Aabe's Family Discount Centar/rlabe's Music Shoppe with Premises Located at 1933 University Avenue West and 1730 Univeisity Avenue Wes:, Saint Paul and have served by first class mail upon a11 parties a copy of said Raport. ,�� Su�ssari�ed and swom t� before me U�is G� day of December, 1995. .-��-i�.'�� o ry Pubfic Abr�ARCENE L- �sor� RAAhSEY COUNTy Mr�� in.�,�eao Jane A. McPeak CITY OF SAINT PAUL Norm Caleman, Mayor __ ____ ,.--'_' . -_.___-.-_._ _ _. _ Dece�ber 20, 1995 Timothy B. Poirier Lowry Hill Law Offices 1900 Hennepin Avenue South Minneapolis, Minnesota 55403-3198 OFFICE OF TF� CITY ATTORNEY Timotiry E. Marx, Ciry ABOmey �/ ��S v Civi1 DPvision 40Q City Ha11 Telephone: 6L2 266-8710 IS West Kellogg Blvd Facsimile: 612 298-5619 Saint PauZ Mmnesom 55702 NOTICE OF COUNCIL HEARING � 3 :"��i>` _.. ._. _.: _.; ,._,. �� 1� � �� RE: All Licenses Held by Josha Corporation d/b/a Aabe's Music Shoppe, License ID No.s: 86161 & 44670 Dear Mr. Poirier: Please take notice that a hearing on the report of the Administrative Law Judge concerning the above-mentioned license has been scheduled for 3:30 p.m., Wednesday, January 3, 1996, 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 argument 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 L,aw 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 Secretary Robert Kessler, Director, LIEP Gary Pechmann, Deputy Director, LIEP Nancy Thomas, Office of Administrative Hearings, 100 Washington Square, Mpls, MN 55401 Ed Bower, Community Organizer, Merriam Park Community Council 2000 St. Anthony Ave., St. Paul, MN 55104 George and Donna Moschkau, 836 Mound St., St. Paul, MN 55106 STATE OF MINNESOTA OFFICE OF ADMINISTRATIVE HEARINGS 100 Washington Square, Suite 1700 i�� Washington Avenue South Mi�neapolis, Minnesota 55401-2138 December 1$, 1995 Fred Jwus�: City Clerk 170 City Hall 15 W. Keilogg Bivd. St. Paul, MN 55102 REGEI�E� ��c �. 4 �gg5 �ETY �LE�� 9�—�� , RECElVEL� � Es 13 1996 �Il'Y GLER� Re: In the MattPr of All Licenses Held by Josha Corporation d/a!a Aabe's Famify Discount Center/Aabe's Music Shoppe, et A.L..; OAH Docket No. 91-2101-9995-3 Dear Mr. Owusu: Enclosed please r'ind the duplicated tapes for the above-entitled matter. I apologize for an inconvienence the delay may have caused. The file was mailed to you on December 12, 1995. � N7 Enc. Very truly yours, ��, �� PVancy M. Thomas Docket Clerk Telephone: 612/341-7615 Providing Impartial Hearings for Government and Citizens An Eq Opportunity Employer Administrative Law Section & Administrative Services (612) 341-7600 � TDD No. (612) 341-7346 � Fax No. (612) 349-2665 q�,_�5 STATE OF MINNESOTA OFFICE OF ADMINISTRATIVE HEARING5 100 Washington Square, Suite 1700 100 Washington Avenue South Minneapofis, Minnesota 55401-2�38 _- - - _. _—�_ _�_ — - — -- — �i� _ ° �F� cF s� .�� .2 �� February 22, 1996 Fred Owasu City Cierk 170 City Hall 15 West Kellogg Boulevard St. Paul, Minnesota 55102 �� '� F '� , .<- Re: In the Matter of All Licenses Held by Josha Corporation, d/b/a Aabe's Family Discount CentedAabe's Music Shoppe OAH Docket No. 91-2101-9995-3 Dear Mr. Owasu: Enclosed is a transcript from the prehearing conference which was held on September 21, 1995 in the above-referenced matter. This transcript was recentfy requested by the attorney for Josha Corporation. Please include it as part of the record which was returned to you in December 1995. Sincerely, -��, �� sh Enc. SANDRA A. HAVEN Administrator of O�ce Services Te le p h o n e: 612l341-7642 Prowding Impartial Hearings for Government and Citizens An Equal Oppo Emp l o yer Administrative Law Section & Admin�strative Services (612) 341-7600 � TDD No. (612) 341-7346 � Fax No. (6�2) 349-2665 � 1 2 -_- -- � 3 4 � � 5 ` 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ORiGlNA�. STATE OF MINNESOTA OFFICE OF ADMINIS_TB&T,ISLE_--��LR� FOR THE CITY OF SAINT PAUL Fi1e No. 91-21�1-9995-3 ��_� �fiB �� y 'rr� ' �� In the Matter of A11 Licenses Held by Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe with Premises Located at 1933 University Avenue West and 1730 university Avenue West, Saint Paul BEFORE: Jane A. McPeak Administrative Law Judge PLACE: Saint Paul, Minnesota DATE: 5eptember ?l, 1995 Electronically Recorded Hearing Mary Ann Hintz, Court Reporter 13364 Gladiola Street NW Andover, MN 55304 (612) 767-0601 �b- 2 • . � 1 The aforesaid matter came on £or 2 hearing at__Saint__ PauL,-M��t�-esata _- 3 21, 1995, be£ore the Honorable Jane A. McPeak, 4 Administrative Law Judge of the Office of 5 Administrative xearings. 9 10 11 12 13 14 15 A P P E A R A N C E S GAIL L. L,ANGFIELD, ESQ., Office of the City Attorney, 400 City Hall and Courthouse, 15 West Kellogg Boulevard, Saint Paul, Minnesota 55102, appeared on behalf of the City of Saint Paul Office of Licenses, Inspections and Environmental Protection. 16 TIMO'PHY B. POTRIER, ESQ., Lowry Hill 17 Law Offices, 1900 Hennepin Avenue, Minneapo- 18 lis, Minnesota 55403-3198, appeared on behalf 19 of Josha Corporation d/b/a Aabe's Family 20 Discount Center/Aabe's Music Shoppe. 21 22 23 24 25 * � * * (Whereupon, the follow- ing proceedings were had} Mary Ann Hintz, Court Reporter • 1 2 _,_ __._,__�...__�,_.-_: _, _ — 3 4 � r 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ��. 3 THE JUDGE: In the matter of all licenses held_b "-� �_�I_o_s-l�a-Eo=rgora=tion 3oirig business as Aabe's Family Discount Center, Aabe's Music Shoppe, et cetera, all O.A.H. file number 91-2101-9995-3, September 21, 1995. (Whereupon, an off-the- record discussion was had) THE JUDGE: I've already listed the title of the case and the date. Good morning. My name is Jane McPeak. I'm an Administrative Law Judge with the State of Minnesota. And this morning, the petitioner in this case has requested a pre- hearing conference, which i think is cert -- certainly appropriate. So why don't we begin riqht now. We're on the record. Let's talk a little bit about the -- the issues, the petitioner's motion in this case, anything else that we need to talk about so that once we finish, we can move this as quickly as possible. Okay? Miss Lang -- is it Langfield? Mary Ann Hintz, Court Reporter S � ��.-� 4 � 1 2 ---_ - _ � _ °- 3 4 5 � . 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. LANGFIELD: Lanqfield. THE JUDGE_,__,__k�h=1z--,don-'=t- MS. LANGFIELD: Okay. The offices -- License Of£ice has brought an adverse action against Aabe�s Music Shoppe. And that is a license held by the Josha Corporation. And I understand they're represented today by Mr. Poirier, and I think that's Mr. Sweeney sitting (inaudible; not at microphonel. MR. POSRIER: Yes. MS. LANGFIELD: The adverse action we're bringing involves a failure on the part of Josha Corporation to keep adequate records as required by the city ordinances Section 355 -- 355.04. The ri -- 355.04 requires that the licensee shall be required to keep accurate accounts of purchases made from private interests. That accurate account shall include descriptions, who purchased it, who it was purchased £rom, when it was pur- chased, the time it was purchased, the date it was purchased, the serial numbers on the equipment if it -- if they contain serial numbers should be on that record, and that Mary Ann Hintz, Court Reporter � �'�� E � � . 1� record shall be kept at the premises in which 2 the - the__e_gui�men�--�s-_-5��d-:= - � 3 4 S 6 7 S 9 10 11 12 13 14 15 16 17 1$ 19 20 21 22 23 24 25 It is the city's conten- tion that the licensing -- the license depart- ment's contention that mechandise was pur- chased by the Aabe's Music 5tore, but a com- plete record was not kept. Further, some mechandise was sold from that lot that was purchased prior to ten days, which is also required by Section 355.04 (c), which requires the -- the licensee to hold secondhand mechandise for ten days. And that was sold before ten days. There is also an inade- quate record of the sale. It doesn�t identify who it was sold to. This mechandise was -- there's some mechandise that was logged in for example, but the -- there is no evidence that it still remains at the store, and it was not found during a recovery process. Further, the licensee was opecating his business at a different address than what was on his license, which is a violation of Section 355, and also that the licensee and his employees were fairly un- Mary Ann Hintz, Court Reporter � �•' � � 1 2 _ - 3 4 • � cooperative with the police in trying to tecover__s,ome__p.£-tY�i-s �e=e�ia�txYise`: ---`` _. — That is -- those are the 5 city's allegations. THE JUDGE: Okdy. witnesses does the city have? And how many THE JUDGE: And who are they? MS. LANGFIELD: Five; I'm sorry; MS. LANGFIELD: We have four : five. 9 10 11 THE JUDGE: Who are they? 12 MS. LANGFIELD: Sergeant Garvey, 13 Officer Learmont -- she was Officer Moyer 14 before. THE JUDGE: Okay. MS. LANGFIELD: -- Chris Schweinler were the licensing inspection department -- section department, and George and Donna Moschkau. 15 16 17 THE JUDGE: How do you spell their last name? MS. LANGFIELD: M-o-s-c-h-k-a-u. THE JUDGE: Okay. Miss Langfield, would you spell your last name for purposes of the record, too, just so we have that correct? 18 19 20 21 22 23 24 25 Mary Ann Hintz, Court Reporter ��-�s � � � � . MS. LANGFIELD: Certainly. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 � Langfield is_s_gelle;d---�-a--�=q=f=i=e-I-d: THE JUDGE: Thank you. A11 right. Mr. Poirier -- is that correct, Poirier? MR. POZRIER: Poirier. THE JUDGE: Poirier. MR. POIRIER: Right. THE JUDGE: Okay. MR. POIRIER: Thank you, Your Honor. Your Honor, 2 have filled out a motion to dismiss today. And my basis of the motion to dismiss is an inadequate notice of what we are here £or today. You see from my memorandum that this matter originates back in July. And I drew a letter to the city attorney's office asking them, "What is the specific allegations you're making against my client?" He runs a music shop. He's in the business of having numerous sales. And what the charging infor- mation is is the same as the information that was on the July 7-- 7 letter from the City of Saint Paul. Looking at the charging information, Your Honor, it does not state Mary Ann Hintz, Court Reporter q�.�,� � � • � � 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 a� 25 what item or items we're here today to say --- were not_inven.t:o,r-ier�--o-r—ware=n`o� £or �a proper period or were sold without proper recording. I have to come into court today and guess what items we're going to talk about. I've been trying since the seventh of July to find out what these items are. This morning out in the hallway, now I�m getting some idea of what they're talking about. I did the discovery. And I guess i'm supposed to look at the discovery end decide, "Well, after I look through this list of items and this list of items and compare these, let's see what's le£t over here." Your Honor, if -- if -- if this were a criminal matter, this would be tantamount to sayi.ng, "Well, between april 19 and the 22nd you did something wrong, but you have to guess what it is." We've got a store that's up and running. He's got a grand opening going on at the time of this alleged incident where hundreds of items are being sold. This Mary Ann Hintz, Court Reporter � � � . i 3 4 5 6 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ��- E isn't a situation where the the charging - ---- - - ---=-i3tstca�en°t sold a guitai that belonged to George Jones on 'X' date without proper records." This just says, "YOU sold property" -- what property? -- "within ten days of having purchased or received such property." And you say, "An adequate record of the property" -- what property? -- "was not kept when it was purchased and a comprehensive record of all transactions was not kept." Well, what transactions are we talking about here? The name George Moschkau isn't mentioned here once. The item that is supposedly sold is not mentioned here once. I'm coming into court, and I�m at extreme disadvantage when I have to guess what charge 2'm going to be defending on. I have received the discovery from the City of Saint Paul. And there's numerous items of property that were stolen, some of which are alleged to have been purchased by Aabe's Best Music but not a11 of them, some of which are alleged to have been sold by Aabe's Best Music but not all of them. Mary Ann Hintz, Cpurt Reporter � ��.� � �o ! 1 — _ —�—� 3 4 5 6 7 8 9 C � � 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I've got to create in my a7&&- - �-r�Ya-�wtFT�C - ii _rt m s W e r e s t o 1 e n. I t' s n o t stated in any of the discovery information I have rece -- received. There has been no correspondence back to me telling me which items we're talking about. And there�s just been an absence of any specific charging information. 2 believe the rules from the O.A.H. state pursuant to Section 5600 that I am supposed to get proper notice of what is being charged with so that 2 can come in here and defend on the action. I'm at an extreme disadvantage when i can't come into court and be prepared to defend on an action. I'm in a situation where I've had to do this, Your Honor: I've had to sit down and say, "If I were the prosecuting attorney for the City of Saint Paul, what would 2 charge out on this case?" That's how I've had to prepare to come into court. I'm not prepared coming into court thinking about, "Well, they say this." They haven't said anything. All they've given me is some nebulous charging Mary Ann Hintz, Court Reporter � �� i � . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 information from which i have to make guesses. . .. ,. __-, �'o-E_--�ki-a�--F ovr - - Honor, I think this matter should be dis- missed. And I'm askinq that it be dismissed with prejudice because I've asked repeatedly for this information, and I've never got it. And it's extremely prejudicial for me to have to come in here and defend on that basis. I will admit to one thing in their charging statement, and that's that the information reqarding the transfers of the license is particularized enough that I can cepresent to this court that my client would admit that the license is now being used at another location and have testimony regarding whether or not there is maliciousness involved in that. But with regard to the rest of the charging information, it's completely inade- quate. Thank you, Your Honor. THE JUDGE: Thank you. Ms. Lanqfield. MS. LANGFIELD: Mr. Poirier prac- tically told our office and requested to see the file. In response to that, I sent over Mary Ann Hintz, Court Reporter ��.� �z � � � 1 2 3 � � 8 9 10 11 12 13 14 15 16 17 ia 19 20 21 22 23 24 25 every document in our file that -- that we __ __-- _ .._----:— have here todax,�sn? � F-}ea��y- police reports. It was about twenty-five pages o£ documents listinq items that were recovered, Mr. Sweeney's statement listing items that he took in, the Moschkaus' letter listing items that were stolen, the Moschkaus' explanation of what happened in the store, what they felt happened. They gave their version in a-- a detailed four-page letter. Mr. -- Mr. Poirier and Mr. Sweeney were aware that in April, on the 19th, police entered his store. George Moschkau and Donna Moschkau were with them. They were alleging that certain items were stolen from them and that they had stolen su -- stolen items in theit -- in their store. They were aware, and they returned to the Moschkaus certain items that the Moschkaus claimed to be theirs. They are aware of what items were returned. They were aware what items Moschkaus said were stolen. They also are aware through their emplayees what items the Moschkaus are still looking for. Mr. Poirier Mary Ann Hintz, Court Reporter _ l � ' �S' 13 � 1 2 -- -° -= - _- -_ _�_- 3 4 5 6 7 8 9 10 11 12 � 13 14 15 16 17 18 19 20 21 22 23 24 25 � did not report to you that he has tried to or - ----` attempted _to con�ta_c.t---Geerg-e on and obtain additional information from them, nor has he reported to you that he's tried to contact the police and obtain in -- additional inEormation from them. And also, police records are public records. He could have gotten further police reports if he felt the city was not forthcoming on what -- what items or what reports were given to him. There is notice in this case, Xour Honor. There was notice that the heating was today. That notice was given on August 31 0£ the hearing today on September 21. So I don't know what notice he says that he's lacking. If he says that he has to take time and prepare a case going through and comparing this, we had to do the same thing_ We had to compare what was stolen with what was recovered with what the Moschkaus still say is stolen with what Mr. Sweeney said that he took into his -- his property. The notice is adequate. Mary Ann Hintz, Court Reporter a�- � 14 � 1 2 f __ __..,,-. -_�_.-_ --=-°_ __ 3 4 5 The discovery was adequate. And if he wanted additional discov_e,t�r, told - or asked the city prior to yesterday rather than serving the motion. If he wants a continuance, 6 the city is fine with that. We can -- we can 7 continue this case if he feels he needs addi- 8 tional time. 9 10 11 12 � 13 14 15 16 17 18 19 20 21 22 THE JUDGE: Thank you. MR. POIRIER: May I respond, Your Honor? THE JUDGE: Yes. MR. POIRIER: Your Honor, it -- it -- counsel�s comments to me are frankly out- rageous. What I'm hearing is that I am now supposed to go out to their witnesses to figure out what the prosecutinq attorney says that they're missing. 2 have to go to the police and fiqure out what the police are going to eome in here and say is missing. i have to make the prosecution's case. That's what they're saying. 23 I shouldn't have to make 24 the prosecution's case. I should be able to 25 look at the charge and say, "This is what i'm � Mary Ann Hintz, Court Reporter � � t � `. is 1 coming to court to defend." z shouldn't have -43 � g 2 to create the cha,c e-�----_�-t===s#FauYd"" brou ht 3 - -- _- - against us. � 5 6 7 8 9 10 11 12 13 14 15 16 ]. 7 18 19 ao 21 22 23 24 25 I did compare the list. And quite frankly, my analysis is different from what theirs is. So I'm left with the -- with -- with the final result being I have guessed. They have made some guesses. And we have a different analysis of what property is turning up missing. And I want to know when I'm being charged -- having my client being charged out what I�m cominq here to defend against. And it�s not stated in the charging document. And I'm not under any burden to go out to the police or their wit- nesses to fiqure out what their case is about. It's comgletely inadequate, Your Honor, and I shouldn't have to come into court and defend on it. THE 3UDGE: Thank you. Any response to that? All right. Let me -- let me be clear on this. What the city provided Mr. Poirier was simply copies of all the documents � Mary Ann Hintz, Court Repprter � 1 2 ='_-,.-:_-=, -_`_-'_:: -,_ — 3 4 5 6 7 8 9 10 11 � iz 13 14 15 16 17 18 19 20 21 22 in your file. MS . LANGF_IELD-1---- ports -- THE JUDGE: Okay. M5. LANGFIELD: -- letter from George and Donna Moschkau detailing their visit to the Aabe's Music Shoppe and their attempt to recover this -- this -- these stolen items. �� S 16 And letrs see. I have provided him with a notice of hearing. S have provided him with -- which he had received previously. The police report was rather extensive, Your Honor, and also licensing screeninq information that they hold as a secondhand dealer's license. I don't think -- the police reports are extensive in this matter, Your Honor. It's not one page. The facts amounted to twenty-five pages -- or twenty- four pages, and i could recreate exactly what was provided. 23 THE JUDGE: Okay. Now the police 24 reports in this instance, do they deal only 25 with Aabe's Music Shoppe, or do they deal with , Mary Ann Hintz, Court Reporter �G- � 17 � � � � 1 2 � � 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 other locations, too? Only with Aabe's -- -------.-----`°'` — - M S._._L,&�i G,F-3 E�,�-:-= ; Y t -- i t d e a 1 s with the Moschkau burglary and the subsequent recovery of equipment and mechandise from Aabe's and a photo lineup of a suspect and that the suspect was arrested and detained. THE JUDGE: Okay. MS. LANGFIELD: That's what the police reports deal with. MR. POIRIER: Your Honor, the police reports do not identify the property that's allegedly been sold by Aabe's Music without proper authority. if you want to determine what progerty they're talking about, you have to start comparing different lists. And again, that's their job, not my job. THE JUDGE: Any more respanse, Ms. Langfield? MS. LANGFIELD: The police reports contained a list of the Moschkau stolen property, a list of the items recovered by the police, a-- also contained within the police report was a list or an inventory of Mr. Sweeney�s things that he ta -- took in. This is the list that he Mary Ann Hintz, Court Reporter � �,.�s' �$ � i � ' � 2 n S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Z1 22 23 24 25 says that he has to compare. And frankly, I __ — ___--- __ -- - � see it as, he doe_su_!..�=vv��t��to rnvest the time to compare it. He wants us to compare it for him. And 2 don't see that as a city's burden in this case, Your Honor. This is a civil matter, we are not charging criminally. This is a civil administrative matter. MR. POIRIER: And -- MS. LANGFIELD: He has got every- thing. MR. POIRIER: Your Honor, they do have the burden of putting me on adequate notice. That isn't my burden; that's theirs. I'm not bringing this action. They're the ones bringing it. I'm entitled to the notice that would enable me to be informed enough to determine which praperty it is we're talking about so that I can have the people lined up so thak I can have the case prepared. And that hasn't been done. All that they�ve done is dumped twenty-tive pages of stuff on me and said, "it's in here somewhere. You have to figure it aut." Mary Ann Hintz, Court Reporter ��s � • 1 2 _-,_ -_--_-_ ' � 3 . � 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 THE JUDGE: When did you receive the `�----�_ ------ information from��he-�-i�-�==- —°°�`�' - MR. POIRSER: It was faxed to me last Friday. MS. LANGFIELD: Your Honor, it was requested on Thursday. MR. POIRIER: Well, it`s been re- quested since July 17. THE JUDGE: Was these any response, Ms. Langfield, to the letter of July 17? MS. LANGFIELD: Mr. Painborn (phonetic spelling) made a phone ca11 to Mr. Poirier regarding the items and the -- and the involved parties and what was going on. And MR. POSRIER: And Mr. Painborn was not able to identify to me the specific property that we're talking about here either, Your Honor. 20 THE JUDGE: Okay. Okay. All right. 21 I've had a 1ittle bit of time to think about 22 the motion because I was also served yesterday 23 a£ternoon at some point. I have heard your 24 arguments this morning. I-- r think that 25 there has been some disclosure, but I don't Mary Ann Hintz, Court Reporter ��. zo �� 1 think the disclosure has been adequate. I-- --- -- - --- - 2 I don't think__t!??_�.�*i��t�r�e`i�i"a`s Yiad adequate 3 notice of the specificity of the charges � 9 10 11 12 13 14 15 16 17 18 19 20 ai 22 23 24 25 against him. He knows that there's this general allegation. But in terms of being able to defend, I-- I think that Mr. Poirier is correct, that he has not been able to bring the witnesses because the city has not alleged with specificity the particular items of -- involved particular transactions and so on. I am not qoinq to dismiss the case with prejudice. I wi11 continue the case for a reasonable period of time for tlze city ta complete its discovery and to provide counsel with a specific list of the property that you are alleginq was taken in and not -- and sold prior to the -- the ten days that are required that it be held, what property spe- cifically you are talking about in terms of being purchased or received but not kept in violation of 355.04 of the Legislative Code, specificity with respect to the transactions that were not kept as required by Section 255.01 of the code. And I think that would -- Mary Ann Hintz, Court Reporter �6� ai �J C .� M 1 2 4 5 6 7 8 9 1� 11 12 13 14 15 16 17 1$ 19 20 21 22 23 24 25 i think that would be it. done now is to arrive at a reasonable date to return, reasonable for you to provide the information with specificity, reasonable time for Mr. Poirier to be able to conduct whatever further discovery he needs to conduct, what- ever witnesses he needs to bring. So can I have a proposal from one or the other? Mr. Poirier. MR. POIRIER: Could we have thirty days, Your Honor? THE JUDGE: Thirty days? MS. LANGFIELD: Thirty dayS -- THE JUDGE: Thirty days? M5. LANGFIELA: -- till the hearing? Or I-- I mean, I-- THE JUDGE: Thirty days for -- MR. POIRIER: Thirty days until the hearing. `PHE JUDGE: The hearing. Okay. Is that agreeable -- MS. LANGFIELD: That's agreeable -- THE JUDGE: -- with the city? I think -- 2 think that's reasonable, too. But Mary Ann Hintz, Court Reporter c�G, 22 � � � 1 I think that we should probably at this time 2 have a date „specif_i._c�-_-A�d-=s�'-d--as� city 3 to make arrangements again for the room. 4 Thirty days from today S would be -- well, it would be Friday, October 6 the 20th. I have another administrative 7 hearing that day, so we need to go into the 8 next week, I think. We're looking at the week E 1Q 11 12 13 14 15 16 17 E�:3 19 20 21 22 23 24 25 of October the 23rd. MR. POIRIER: The 25Ch perhaps? THE JUDGE: The 25th? VOICE: What day is that? THE JUDGE; It's a Wednesday. MR. POIRIER: Wednesday. VOICE: (Inaudible; not at micro- phone). THE JUDGE: Let me ask you this: what's the 26th like? How is that? Is that any -- any worse for you, Mr. Poirier? MR. POIRIER: It's not any worse. THE JUDGE: Okay. I would gtefer the -- the 26th if at all possible. MS. LANGFIELD: Thursday, the 26th of October. THE JUDGE: Right, Thursday, the Mary Ann Hintz, Court Reporter f� � � _� 23 . � r 1 2 � 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26th of October, 9:30. I'11 ask Miss --° Langfield__t_o__mak=e--„a-��-ge�e o�m and to notify Mr. Poirier and me -- MS. LANGFIELD: Um-hum. THE JUDGE: I'm assuming that we'll probably be here -- MS. LANGFIELD: Your Honor, I was just told that one o£ our witnesses is on vacation that week (inaudible). Can we switch it a week before or a week after? THE JUDGE: I don't have any objec- tion. Do you, Mr. Poirier? I-- MR. POIRSEA: I`11 be gone a week before. THE JUDGE: Okay. How about the week -- MR. POIRIER: Erik is gone a week -- THE JUDGE: After? So we're getting what, into November? VOICE: (Inaudible; not at micro- phone). MR. POIRIER: So into no -- the week of November 6. MS. LANGFIELD: November 6. THE JUDGE: Are we in the week of Mary Ann Hintz, Court Reporter �� 24 � � 1 2 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2Q 21 22 23 24 25 November the sixth? VOICE:__� phone). cro- M5. LANGFZELD: Week of November 6. THE JUDGE: Monday, the sixth? No? MR. POIRIER: Tuesday. Tuesday is election day. THE JUDGE: Tuesday, Wednesday? MR. POIRIER: Wednesday, the eighth? THE JUDGE: How about Thursday? MR. POIRIER: That's fine with me. THE JtJDGE: Okay. Eleven eight, '95 MR. POIRIER: That's 11/9. THE JUDGE: Eleven nine; I'm sorsy. Eleven nine, '95, 9:30. I would ask £or the city to get that information to Mr. Poirier as soon as possible, well in advance of -- of the hearing date so that he'll have an adequate opportunity to prepare his case. Are there any other mat- ters that we need to discuss this morning? Mr. Poirier? MR. P�IRIER: No, there are not. THE JUDGE: Okay, thank you. Then Mery Ann Hintz, Court Reporter ��_2� 25 � 1 2 we are recessed until November the ninth, �95, at 4:30 in the �� . _ _ _ _� _ ___. _ -- - --- mo cni-r�g�=- -:.A at �"�hat t ime , we`11 either begin immediately with the hearing, or if there are any other motions, we�ll take them. � � 4 5 6 7 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Thank you. MR. POIRIER: Thank you, Your Honor. {whereupon, these proceed— ings were adjourned) � * * * Mary Ann Aintz, Court Reporter �� `✓ 26 � �� 1 1 STATE OF MINNESOTA) )SS. 2 COUNTY OF ANORA ) ___,_,_,_,,.-._---_-- 4 5 6 7 S 9 10 11 12 13 14 15 � 18 14 20 21 22 23 24 Be it known that I, Mary Ann Hintz, hereby certify that the foregoing, consisting of one volume, pages 1 through 25, is a true and correct transcription of the tape recording that was made of these proceedings, which was prepared by me to the best of my ability, Dated at Andover, Minne- sota, this 16th day of February, 1996. 4 _�1%�'� - .�� !`/kZr,� G � Mary Ann Hintz, Court Reporter City of Saint Pauf Office of the City Council 310 Ci_ -- - °_ _ �-Hai� - .__- _- v -_ -_ _ --- - - -_��Y arit�"' au{ M{V 55102 -° =` (612) 266-8560 INTERDEPARTMENTAL MEMORANDUM RECEIVEG FEB 13 7996 DATE: February 13, 1996 CITY CLERI4 TO: Fran Swanson, Deputy City Clerk FROM: Nancy Anderson � �" SUBJECT: Council File 96-75 - Josha Corporation dba Aabe's. 1 am forwarding to you our complete file (official records, audio tapes, exhibits, etc.,) for Josha Corporation, dba Aabe's, and these records should be maintained in your o�ce for permanent records storage. Thanks. If you have any questions, piease contact me at 266-8564. NA Attachments: Box of Exhibits, o�cial records and audio tapes STATE OF MINNESOTA QFFiCE OF ADMINISTRATNE AEARINGS 100 Washington Square, Sude 17Q0 100 Washington Avenue South () �_? w Minneapotis, Minnesota 55401-2138 7 " • -- - _�— �.. _._ ._ �;—=-="---_- .. _ .. December 12, 1995 Fred Owusu City Clerk 170 City Hall 15 W. Keliogg Blvd. St. Paul. MN 55102 RECE!�IEt� DEC 141g95 �,i�Y CLER� REGEIVE� FE8 13 �996 �ITY CLERG� Re: in the Matter of All Licenses Held by Josha Corporation dibla Aabe's Family Discount Center/Aabe's Music Shoppe, et A.L..; OAH Docket No. 91-2101-9995-3 Dear Mr. Owusu: On December 6, 1995, Administrative Law Judge McPeak served the Findings ofi Fact, Conciusions of Law and Recommendation in the above-entitled matter. Enclosed is the official record, with deposition and exhibits. Copies of the hearing tapes wiil be sent after duplication. Our file in this matter is now being closed. Very truly yours, � �lir�r".l�e�� , i/1'-��'''�' ancy Thomas Docket Clerk Telephone: 6121341-7615 N7 Enc. Providing Impartial Heanngs for Govemment and CRizens An Equal OppoRunity Employer Administretive Law Section & Administrative Services (612) 341-7600 � TDD No. (612) 341-7346 � Fu No. (612) 349-2665 December �, 1995 STATE OF MINNESOTA OFFICE OF ADMINISTRATIVE HEARINGS 100 Washington Square, Suite 1700 100 Washington Avenue South Minneapolis, Minnesota 55401-2138 C,ai1 L. L.angC�eld Assistant City Attarne3' �OU Citv Hall 15 West Kella� Boulevard Saint Paul, �ttinnesota 55102 Timothy B. Poirier Attorney at Law I,owry Hill I,aasm' Offices 190Q Hennepiti t�venue South \-tiruieapc,iis, 1lJIinnesota 554Q3-3148 '_`��ancy Anderson Councii Secretary Raom 310 Ciry Hat1 and Co�couse Saint Paui R7innasota 55142 [��v� D�� 141995 �!TY CLER� RE: In the Matter of All L'acenses Held by 7asha Corporation d/h!a Aabe's Family �3iscount Centzrl.4abe's \�iusic Shoppe with Premises I,ocated at 1933 tiniversityr Avenue �`est and 173t1 liniuersity West, Saint Paul; OA�I File No. 41-2101-9995-3 Dear Counsel and Ms. Anderson: Enc.losed please finci #he undersigned's Report in the above rsferenced matter. Yours mzly, � � `j/Lt�Pp,vl� 3 A. McPeak AdmivistratiNe La�t Judge 9 � �_ � Providing Impartiai Hearings for Govemment and Cit�zens An Equal Opportunity Employer Administrative Law Section & Administrative Services (612) 341-7600 � TDD No (612} 341-7346 � Fax No (612) 349-2665 � w .,� ---- a . . :��€:tr;�.. : �;�Y;°�� '_ g � � � ,:.:.._ ` ✓ :�` _' - :' y �. = ��J� _h�'y : . , l ?Y . '.sra..2=�ccco��=:+: - ��o=i=`._ .tc�;:t2 3 _ : _ - Fer.fd.:n�t2��.51:�?di; co;c ' ._ :e+�`, }: ��i EY'�isiei�."v'._ J��!CE'J=� A:n. �?�HR'I� .J ',l.'� �/4�'�Sh," �:GP $G_`ol° �Il'�I'S �'�JJ � �. _ _,,,_.,, �,� : ��zs�..� _.,,-�i-_ �.�; ._ �::. >:r _ "iS.� '.i". - �, ii` �- - c3_ . d'Y . _ � _ i:, .n . . ra;<1u..'�=. �iili��26�i RECEIVED DEC 141995 CITY CLERK C'i:!:,+?,= 31, ? �95 Tim�;'t°_} i3. i'eieier t�i?!;iI1C}' dt � 3W '.�O�vt}' �Sill I .� t✓ CSfji ,<;; i9CG g�eri�?.•r�;:� ..��c��;� S�u�;r t5inn:ap«Ii9,';[?`'. >`��3 .L� 1.�ti�>,�is i t}:i� V.:9 `_'.'�St:J�L':7.� �. i's:,:i �.. �.art;;fi�'c� A_SS3:>L:tY.if.;lf i'`iE)iltC� =Y��i �`IiV ivF�Y ; 5 �.V�;i �i£LO•r:; �iG3��VarE# Sa;t�t #�au�, k�f?�?. -5iC�2 i2�'. lai t�t: �,�dCit[� Cl� .Z�i 7.._ �ii>_. '�`:' e i: 'O"r.,, i{.. �_,' i"� (L�T'� �.=i::� �; i.?T��i! i `s, . ;r} � - ` b if i� �i��.t��r�{ i�i4� Uilli�{�ilt[Z2�.� 2G� S.i.:;� .iz2 y ;il', �_ .,.rx � ,�,.T� l',Oid3LS��; _ .r.SI7`iiji:iT' :1�;� ,�➢S_-: : P'_�. . , r .,.'� e(C. � i?fltn rS�.L, �fN;} r��'�: � _ ..i-�..°`��4�i :�i;1lCU?. ] J.,il�2' (_u'i:, � -?hp �° ' iyi �f' , :` ��_�!",x,_.. E 4'•-�;.. �. .�.'.�+a " _ _ _. .ai4" - �'"�'�- ' _._ _' . -. v _ ,-r',-1 9� �^ t� �°' i J �� rr � K�/ r\=��YP1�J �il BEFORE TfIE COUNCII, OF 1T� COUNTY OF RAA4 CTTY OF S AI�TT._,EAUT__ — In the Matter of All Licenses Held by Jasha Corporation d/b/a Aabe's Famity Discount Center! Aabe's Music Shoppe, et al. i•� • RECEIVE� pEG 141995 C1TY CLER� OAH Docket No. 91-2101-9995-3 A vIotion to Quash Discovery by the City of Saint Paul was filed by Josha Corporation on October 26, 1995. In the Memorandum uz Support of Motion to Quash, Josha Corporation alleges that the City of Saint Paul's service of Requests for Admissions, Interrogatories, and Request for Production of Documents consritutes further dascovery not pernutted by ihe Administrative Law Judge's Order for Continuance, dated September 26, 1945, and is an attempt to hazass, intimidate, and punish Josha Corporation. Further, Josha Corporation alleges that the Notice of Taking Deposition of Ronald Kies constitutes further unpernutted discovery and was not scheduled in compliance with Minn.. R. 1400.6900. The City was represented by Assistant City Attorney Gail L. Lax�'ield, 4dd City HaIL 15 West Kellogg Boulevard, Saint Paul, Minnesota 55102. Josha Corporation was represented by Timothy Poirier, Lot�vay Hill La� Offices, 194Q Hennepin Avenue South, IVSinneapolis, Minnesota 55403-3148. After hearing aral argument via telephone on October 3Q, 1995 and based on all the files and proceedings kerein, the Aclministrative Law Judge hereby enters the following: � L .� _l ORDER __ - - —° 1. The Motion to Quash is denied; 2. Josha Corparation shall respond to the Requests for Admissions and Interrogatories by close of business Friday, November 3, 1995; 3. Josha Corporation shall respond to the Request for Production of Documents by close of business Friday, November 3, 1495. Dated this 31st day of October 1995. �� "� `2�t.(��-!c, a e A. McPeak dmtcustrative Law Judge 9'3Y � :- STATE OF MINNES�TA BEFORE TI� C�UNCIL OF THE COUi�3TY OF RAMSEY CTTY OF SAiN'T PAi3L — In the Matxer of All Licenses Held by Josha Corporation d/tr/a Aabe's Famity Discount Center/ Aabe's Music Shoppe, et al. REC�� DEC 141995 OAH Docket Na. 91-2102-99953 ClTY CLERk� In its Memorandum in Support of Mocion to Quash, Josha Corporation alleges that by service of a Notice of Taking Deposition of Ronald Kies, Requesis far Admissions, Interrogatories, and Request for Production of Documents, the City of Saint Pau1 is attempting to concluct discovery not pernuttsd by the A<lministrative L,aw 3udge's Order for Continuance, dated September 26, 1995 and is using that discovery to harass, intimidate, and punish Josha Corporation. 7osha Corporaiion also argues that the Notice of Talang Deposition of Ronald Kies was not scheduled in accordance with the provisions of Minn. R. 1404.6900. The Order for Continuance, dated Septembet 26, 1995, is just that - an order for continuance. The issue of the scope of prehearing discovery was not gresented to the Administrative Law Judge for consideratian R�hen Josha Corporation's Motion to Dismiss was heard. The Order for Continuance in no way limits the ability of the parties to conduct prehearing discovery. While the above-captioned matter is not by ]aw or rule an Administrative Procedures Act case, we look to the Act and its Rules for guidance in the disposition of issues raised in the coarse of the admitilstrative hearing grocess. n�inn. R. 1400.6700 subp. 2 provides r 9 � -- t � that "(amy means of discovery auailable pursuant to the Rutas of Civil Procedure far the Aistrict Court of Minnesota is all owed." In deci ' w hether such discavetv shi�ut� } ,- �-=-� -- — — —. made ava�able, the issues of relevancy and need are of pazamount impoztance. The City has adequately demonslrated that its Notice of Taldng Deposition of Ronald Kies, Request for Production of Documents, Request for Admissions, and Interrogatories do not expand the scope of its Amended Notice of Hea�ing, dated September 26, 1995 and are relevant to and needed for the presentation of its case. Indeed, the City has demonstrated that its discovery may result in streamlining the matter and work to the benefit of both pariies rather than waiting until the last minute which would be the case if the City were to request a subpoena duces tecwn to the principals of Josha Corporation. The City's request to preserve, by deposition, the testimony of Rvnaid Kies is addressed in a separate Order. Josha Corporation has not produced any evidence supporting its contention that the City's request for discovery is motivated by the intent ta harass, intirnidate or punish 7osha Coiporation. 17i�i 9�-:'� STATE OF MII�IINESOTA BEFORE TF� COTJNCIL OF THE COUNTY OF It AMSEY CIT OF SAIN'T PAt R — In the Matter of ASl Licenses Held by Josha Corporation d/b/a Aabe's Family Discount Center/ Aabe's Music 5hoppe, et al. RECEti�� qEC 1 � 1995 �ITY CL�R� G7:7�]�;7 OAH Docket I3o. 91-2102-9995-3 By letter dated October 26, 1995, the City of Saint Paui requested an Order for the deposition of Ronald ILies, an inmate of the Mintiesota Correctional Facility in Stillwater, Minnesota. 3osh Corporation filed a Motion to Quash Biscovery by the City of Saint Paui, dated October 26, 1995. Such Motion dealt in part with the scheduled deposition of Ronald Kies. The City was rzpresented by Assistant Ciry Attorney Gail L. Lang�ield, 400 City Hall, 15 West Kello� Boulevazd, Saint Paul, Minnesota 55102. Josha Corporation was represented by Timothy Poirier, Lowry Hill Law Offices, 1900 Hennepin Avenue South, Minnaapolis, Minnesota 554033198. After hearing oxal argument via telephone on Ocwber 34, 1995 and based on all the files and proceedings herein, the Administrative Law Judge hereby enters the following: C�7,i1��,7 i. The City's request to take the deposition of Ronald Kies, an inmate of the Mumesota Correctional Facility in Stillwater is granted; and J r % � � � i 2. The deposition shall be held at the Minnesota Correctional Facility in the City of Bayport, in the C ounty of Wa shington, State of Mu mesota, on the 7th day of Ne �P**�her _._ 1995 at 12:3d o'clock p.m. and thereafter by adjoumment unt� the same shall be oampleted. Dated this 31st day of October 1995. �"-7� a A. McPeak dministrative Law Judge 9 r � y �' � V � % J 91-Z10I-9995-3 �, . - - -- _- _—_-- ------ -- - __- ---- - - F 1GIII�7�SOTA - -- - - - ��'ic� oF �vMIlVZSTR�`1�zv� HE�aRm'GS DEC 141995 FOR T`HE CTTY OF SAINT PAt,Z, dlTX CLERi� In the Matter of All Licenses Held by Josha Corporation d/b,�`a Aabe's Family Discount Center,fAabe's Mtasic 5ho�ge with Premises Located at 1933 University Avenue West and 1730 University Avenue West, SaintPaul FATDINGS OF FACT, CONCLUSIONS E1ND :tECONLT�1IEh`�JA'rrON The above-entitled matter came on for heaxing before Admiitistrative Law 7udge Jane A. McPeak, acting as Hearing Officer for tha City of Saint Paul, on November 9, 1995 in Conference Room B, in Room 220 of the R.amsey Counry Board of Comtnissioners and on November 15, 1995 in Ttoom 42 of the Saint Paul City Ha]1,Ramsey County Courthouse, Saint Paul, P�iinnesota. Gail L. Langfield, Assistant Ciry Attorney, Office of the City Attorney, 400 City Ha11 and Courthouse, 15 West Kello�,; Boulevard, Saint Paul, n�iumesota 55102, appeazed on behalf of the City of Saint Paul dffice of Licenses, Inspections and Environmental Protection (City}. Timothy B. Poirier, Attorney at Law, Lowry Hill Iaw Offices, 190d Hennepin Avenue South, i�tinneapolis, Mitmesota 55403-3198, appeared on behalf of Josha Corporation dlb/a Aabe's Fauiily Discount Center/Aabe's Music Shoppe (Licensee}. The record in this matter was clased on November 15, 1995. This Report is a recommendation, nat a final decision. After a review of the record, the Council of the City of Saint Paul will make the final decision which may adopt, reiect or modify the Findings of Fact, Conclusions and Recommendatian contassied herein. Pursuant to Saint Paul Legislative cade section 310.03 (o-l}, after receipt of this Repart, the ciiy Councii shall provide an opporhznity to gresent oral or written araument alleging error in thls Report and to present argument zelated to any recommended adverse action. The parties should contact Nancy Andersan, Councii Secretary, Room 31Q, City Hall and Courthouse, Saint Paul, Minnesota 55102, to ascertain the procedure for filixig such argument or appearing before the city council. STATEMENT OF ISSUE The issues in this case are as follows: 1. Whether on or about April 19-22, 1995, employees or managers of the Licensee sold property within ten days of having purchased such praperty in violation of section 355.04 (c} of the Saint Pau1 I,egis2atit�e Code. 9�--='= 2. Whether on or about April 19-22, 1495, emplayees or managers of the I.icensee faited to keep an accurate and comprehensn�e record of purchases in violation of sectic ----_- -- - ---- --- � •� _ - - �.... ., e- ;.�--- _ -- — - 3. Whether prior to April 19-22, 1995, the Licensee transferred the location of the license in violation of section 355.04{h} of the Saint Paul I,egislative Code. 4. Whether on or about April 19-22, 1995, employees or managers of the Licensee failed to comply with record keeping requirements in violation of section 344.d4(a) of the Saint Pau1 Leg�slative. 5. Whether Licensee's motion for attorney's fees should �anted. Based upon the record herein, the Administrative Law Judge xnalces the following FLNDINGS OF FACT 1. Josha Corporation operates a second hand store, which also sells new goods, at 1933 IJniversity �venue West in Saint Pau1. Shar�n Sweeney is the owner and Et�c Swenson the manager of the store. 2. Qn or about April 19-22, 1995 Josha Corporation was licensad as a second hand dealer-singte at 173d University Avenue West in Saint Paul but did not haVe any licensee ta conduct a second hand dealer business at 1433 University Avenue S�Iest in Saint Paul. 3. Cln or about April 19, 1995 the Licensee transferred operation of the 1'730 University Avenue West store to 1933 University Avenue West. Licensee did not notify the City of this transf�r ar raceive pertnsssian from the City to do so. 4. On Apri116, 1997 there was a burgtary at the home, specifically in the garage, of George and Donna Moschkau, 836 Mound Street, Saint Paut, Minnesota SSld6. Taken in that burglary was musical equipment. 5. Afier the burglary, George and Donna �Ioschkau created a list of items stolen {City's E�ibit 1}, gave it to the Saint Paul Police Department, and rnailed or took it to secand hand stores and pawn shops throughout the city of Sasnt Pau1. 6. On Apri122, 1995, while delivering the list of stolen property to stores, the Moschkau stopped at Aabe's Family Discount Center at 1933 University Avenue West in Saint Paul, which was hauing its �and opening. ��Uhile George Moschkau stayed in the car, Bonna ��cschkau went into Aabe's. She spoke with a clerk who said that he thought that ane of the items on the list, a Sunn Light Console, was in the store. He took Donna Rtiaschkau ta see the item and she confirmed that it was theirs because there were pictures an the hack wtuch belonged to them. At this point she left the store to get her husband. 2 � ° � .. O — .` .. 7. The Moschtcaus entered the store and spoke with owner Shawn Sweenay whom George �Soschkau had known previously through S weeney's bo oking a�cv for bands. which they recovered and carried from the sales floor to a part of the basement to insure that they would not be sold. Items recognized by the Moscliltaus included dimmer packs, mike cables for lights , canisters, flaod Iights, one '�D �0 stand, a Boss monitor, speaker cords, and a littie box which contained a hzadphone e�ension cords, and other items with George Moschkau's initials on them. :vat all of the items taken in the hurglary were found at Aabe's. 8. The Moschkaus and Sha�un Sweenep discussed what should be done. Sweeney did not want to call the palice at that time. Initaally, the Moschkaus agreed �nth this approach; however, after they left the stare they changed their minds due ta some feelings of uneasiness as to how forkhcoming Sweeney had been and as to what might hagpen to their goods which they had found and to any others which may have been there but as yet undiscoverd. 9. The Moschkaus called the Saint Paul Police Department which inshucted them to xeturn ta the stare where an o�cer would he dispatched. Jouung them at the store was Officer Therese iUIoyer (now L,earmont). Before entering the store Officer Learxnont spoke �vith the Moschkaus who briefed her about the burglary. 10. Once inside Aabe's Qfficer Leaamont spoke with owner 5hawn Sweeney and manager Erik Swenson who produced the nama of Ronald Kies as the seller from the Pawn Buy form {Ciry's Exteibit 3 and 16). i l. Ronaid Kies and two unidentified men came into Aabe's at I933 Universit�r Avenue West on Aprii 19, 1995 to sell musical equipment. To ensure that the two unidentified men were truty the owners of the equipment Swenson asked them to set it ug which they did. Sw�neson then offered them a lump sum of $135.flQ for the equipment listed on the Pawn Buy form and told ttaem titat he was not interested in miscellaneous other items which the men left in the storz. 12. Itanaid Iues had met the tsvo unidentified r.ien at Atias 'Temporary Service. These men, who in conversation with Kies had learned of his musical backgound, had some musical equipment for sale and asked Iiies if he cenld help them. Kies accompanied them to Aabe's where the equipment was unioaded, set up by the two unidentified men, and sold. Kies used his license for the Pa�m Buy form bacause neither of the other iwo men had identificarian (City's E�ibir ldj. 13. On April 20, 1995 Roanld Kies returned to Aabe's with John Foster, a friend, and attempted to buy back the musicat equipment for $135.d0. Erik Swenson refused to sell it for less than $500.00. Kies tald Swenson that he believed that the items were stolen. Swenson still refused to sell the items for $135.40. 3 G�b_ �':; 14. Officer Leamiont found Sweene}r and Swenson to he fairly uncooperative and felt that they were not forthcoming with information. She did note that the store was havin� a She wrote a raport (City's E�itrit 1&) and took with her the compteted Pawn Buy fotm, which did not contain all of the items found in Aabe's. Officer I.eazmont and the �rloschka.us then left Aabe's. 15. On Apri125, 1995 Creorge Moschkau raturned to Aabe's where he met Saint Police Sergeant Michael Garvey who wrote a report (City's E�ibit 13} listing the items recovered and helped Moschkau carr5� the items from the store to his car. One of the items, Kni�ht TD 40 Lig�t Tree, listed on the PaR+n Buy Form was not recoverd. Neitli.er Sergeant Garvey nor OfficerLearmont's reports u�ere accurate as to the items recovered. City's Exhibit 9 sets forth a compresensii�e list of the properry recovered from the Licensee. 16. The Moschkaus estimated the replacement value of the equipment recovered at $1200.Od. They produced receipts for many of those items, some of which w�ere somewhat old, 17. Manager Sweivson paid $135.00 for a total of nine items, none of cehich he valued individually as over $50.00 and did not grovide any additi�nal cansideration for tke items recovered but not listed on the Pawn Buy fortn. Some of those items, like the Ibanez foot controller, light cables and eitenszon cords, were not wanted b}� Swenson but left at the store by the two unidentified men. C7ther items, like the light gel framea, the floodligJits, and gel paper sheats, were integral parts cf the itams listed an the Pawn Buy form and were considered to be part of those systems so that no additional consideration was given for them 18. The Licensee's policy regarding the purchase of second hand goods is to pau no more than 10°,�0 of the list vaiue as set forth ix� flrion, a biue book of musicai equipment. 14. Over the last year the Licensee sustaizied considerable losses attributed io shopiifting at the 1730 University Avenue West location. 20. On or about the first week af June 1495 Saint Paul Police Officer Paul Polyak, aeting pursuant to a complaint filed by Donna Moscl�kau, spoke rvith Shawn Sweeney about 2ils licensure and infotmed him that the license could not be transfened and that applicauon must be made to the City for a license at the 1933 i3niversity Avenue West location. Sweeney seemed unsure of the recording requirements and the ten day hoiding period for joods purchased for $50.Od or over. Officer Polyak asked Sweeney to send the Fai��n Buy forms to hirn in the future. Previously, second hand dealer licensees had been instructed not to send the Pawn Buy form to the police department. 21. In August or Septeznber 1995 Christine Schweinler, senior license inspector for the City's Office of Licenses, Inspections, and En��iroxunental Protection, sent a written notice � `� J = �, to 3osha Corporation that there were no licenses issued to 1933 Uni�rersity Avenue West and that application mus be made for licensu at that loc �_ 22, On August 31, 1995 the Office of the City Attomey sent Licensee a Notice of Hearing stating that a hearing would be held on Thursday, September 21, 1995 on all licenses for the premises at 1933 and 1730 Universih% Avenue West. The �Totice set forth infotmation ahout the authority of the City to hold hearing wtrich may resuh in adverse action against a licensee; that the bases for ihe adverse action hearing against the licensee were violations of Saint Paul Legislative Code section 355.04 - in the selling property within ten days of hatiing purchased or received it, in die failure ta keep an accurate and comprehensive record of the property purchased or received, and in the transfer of the location of the licensed premises; about the hearing procedures; about consequences for not attending a hearing; and about the fact that a setttement would cause the hearing to be cancelled. 23. On September 26, 1995 the Offtce of the City Attorney, pursuant to an Order of the Administrative Law Judge, sent the Licensee additional information as to the allegatior,s in the August 31, 1995 Notice and notified the Licensee that the Cily intended to present euidence alleging that the Licensee had violated Saint Paul I,egislativa Code section 344.04(b} by failing to comply with record keeping requirements and to promptty pro�ide the police with copies of the Pawn Buy Forrn. 24. Nn adverse action has previously been taken against the Licensee for any violatians of the Sa:.nt Paul Legislative rode. CONCLUSIONS i. The Saint Paul Cify Council and the Adxninistrative Law Juclge haue jurisdiction in tivs matter pursuant to iltinn. Stat. section 14.55 and Saint Paul Legislative Code sections 310.05 and 310.06. The Notices issued by the City were proper and all applicable substantive and procedural reqcurements have been fulfilled. 2. �aint Paul I,egislari��e Code section 310.06 allows for adverse action to be taken against a licensee far, among other �ounds, axry violation af any provisions of the Saint Pau1 I.egislative Code or of any statute, ordinance or regulation reasonably related to the licensad activity. 3. Saint Paul Legislative Code secrion 355.04{h} provides that no second hand dealer lic�nse may be transferred to a different localion. For a first violation of operating as a second hand dealer at an unlicensed location the City recommends a�1,000.00 fine. Th'vs recommendation is based on the City's liquor license matriY and represents a base fane. The City has a matrix only for liquor ficense violations and for none other. 4. On or about April 19-22, 1395 and subsequentty, the Licensee violated Saint Paut Z,egislative Code section 355.04{h) by operatittg as a second hand dealer at 1933 University Avenue West without the appropriate licensure. � -, �. !� �, : =, � - 5. Saint Paut Z,egislative Code secflon 355.04(b} requires that at the time of a record wluch cleazly and legibfy sets forth an accurate account or description, in Exiglish of the goods purchased, the amount of money paid the date and time of the receipt of the �oods, the name anfl addrass ��ified by a valid Muuiesota drn%er's license or identification cazd of the person selling the goods, and the serial numbers and brand names of the goods. 6. The Licensee did not violate Saint Paui Legislatit�e Code section 355.04(h} because the City failed to produce any evidence showing that the Licensee paid $50.d0 or more per item listed on the Pa�rn Buy form or that the Licensee paid $SQ.Q� or mare for each item racovered but not listed on the PaRm Buy forni. Testitnony as to the purchase price or replacement value of goods is insu.ffcient t� asta�.ish that certain amounts �ere pail for second hand goods. The City alleged that this secrion appliad aLso to goods received by a second hand dealer. Nowhere in section 355.04(h) is the phrase purchased or received used. 7. Saint Pau1 Legislative Code section 355.d4(c) provides that second hand property purchased may not be sold or be perxnitted to be removed frnm the premises far a period of ten days a8er acquisition. S. The Licensee did not violate Saint Paul Legislatrve Cade sectian 355.04(c) because the City failed to present any evidence tkat the licensee sold or othenuise petmitted remnva2 from the premises any of the properiy bought from Ronald Kies and the tc��o unidentif ed men accompanying tum. Mere absence of an item purchased but not recovered does nat establish by a preponderance of the evidence that the licensee sold or otherswise perxnitted the removal of that item. The City alleged that this section applied also to goods received by a second hand deater. Nowherz in section 355.04(c} is th� phrase purchased or received used. 9. Saint Paui L,egislative Code section 344.04 (a} sets forth the record keepucg requirements required for a paevnbroker and section 344A4(U} requires the pawnbroker t� file a copy of those records with the police deparixnent. 1Q. The Licensee did not violate Saint Paul I,egislatiEre Code secrion 344.Q5(a) and (b} because there was no e�ridence produced at the hearing to prove, nor did the City allege, that the licensee was engaged in the activity of operaring as a gawninoker. Section 344.45(a) and (b) does not by its tetms apply to second hand dealers. 11. In the absence of a specific statutory or ordinance pravision or an agreement or stipulation to pay them, the general rule is that attorney's fees, or a party's costs and disbursements, may nat be awarded in as adtninistrative proceeding. The Council of the City of Saint Paul did not provide iar the award of attorney's fees in Legislative Code adverse actions hearings. � �'�-:''� Based upon the foregoing Conclusions, the Administrative I,aw Judge makes the following: xECO��v�ti� az7oti IT IS RES�ECTF'L'LLY RECO'VL�ZE\-DED that the Councit for tha City of Saint Paul take adverse action against Josha Corporation for the violation of operating as a second hand dealer without a license as established in the Findings herrin. Dated this 3� day of December, 1995. � �9 • ��2�.P�t�d� a. �rcp�� Adxninistrarit�e Law Judge NOTICE Pursuant to ivlinn. Stat. Section I4.62, subd. 1, the Citv Council is requested to serve its final deeision upon each party and the Administrative Law Judge by ft�st class mail. Reported: Tape recorded. 7 1��- �� STATE OF MLNNESOTA DISTRICT COURT --= — - - ��1erfSE� -- °= ____ ._. _.. - - :3FFIDAVIT OF JANE f1. MCPfiAK State of Vlinnesota County of Ramsey ) } 5s. ) Jane A. McPeak, baing first duly sworn, deposes and states: That in compliance with Iviinn. Stat. Section 14.50 and i�tinnesota Coda of Agency Rules Section 1400.8100, I have prepared a Report In the i��atter of All Licenses Held by 7osha Corporation d/bia �abe's Family Discount Center/�abe's Pi�lusic Shoppe with Premises Located at 1933 Uniuersity Avenue West and 1730 University Avenue West, Saint Pau1 and have served b}� first class mail upon aIl parties a copy of said Report. � / Subscribed and sworn to before me this �`'-� day of December, 1495. ��-�� i�o ry Public CHARtENE l. HEFFttON PIOT�� M�'C�m�sbn Fxpireskn 3i.2BBo Jane A. McPeak _ _ : � �:� 1! : -c:A', � � PaLI. POLICE LEPARTM�NT Gca�e and Donne f.S�s;t�(�u (8t2j 773 P.11 ,• sro�� RO��R�r .. Cesa �85�8$45 Pollce Pfana �{6't2} 291-47 � i , -, .- theft occutred di781tC85 C� �.. r� � ��P1f4L . z Pesvey Futl Raega Spesker Oabinets —.__� - - - - - - -- -__ __ - -- .. ----- s'F�sIt1-8YY — X � �-- �': i �-Q2B32246 & 7E-G2982247 svrsn PLCS �6 Uqht Console X 2 $wrt PS67� DFmmar P�cics x z 50� m� ca�ies X S Par 38 {ight c�antsters X$ S SAv Flood Nphts X! Lightgel ttsr.fes • K & Gel RsPerstreets {dEf(erent caiors] �� Kr+N�ht TC�-49 tiqM Treaa wtad8ptera 2 Knk,�ht TD-37 TriPQ"1s 2 L�ather Bags - tQr dtrrtmer packs • X 1 6oss MA15A Poweca�! SDOt FAOnitor $N: 851423 Y` � 1bat7BZ IF�s3p �POt COMrpiter SN; SCk7t54 2 Knight &Iide 6+►ourtts 2 z 57 s�aker cables 3 100' Extansiort car[ts 4 $' £xfenai0n cords k � Co� Tote t Fdicrophone stand wRelescop�� 8 Z3` speaker ca�{a 7 Sida music � � Fk�rrasanic easseite tape recorclsr X � Ra.pco A610o switctf 2 Sit1X7 Ft�Of fAOltitOC& � Red storage box..-�-� 1 Bnss PSA 120 Adapter 2 Gtritat&tg;td � CRUZIN' &�n x4th oase 1 Cortl Ba,� w!!�ilsce!lapeous cords and aclapters�' � Red Hassd Tsuds {2�vheate� _ S 5iMer Hand Tnrck {2.wteeel8� x � De.rvnrortd Vofume Pedat � � In Re Licenses of Josha Corporation — d/b/a Aabe's Music Shoppe � — City's Eah. No. 1 (�ct,e�.✓e� 16- �'� Case #95049845 George & Donna MoscLkan Phone 776-8507 Documentation of Events on 422 and 4 We (George and Donna) stopped az Aabe's at 11:00 am Saturday, Apri122. 1995„�r� caw a c;� — — __---- --.-m w___ TOI433TINIVERSiTYAVEI�tUE" Wewen4totlabe'snew�ocation. Domma went in 5rst to look azound and found the light system. Once George entered the building we confirmed the follocving items immediately: Sunn Light Console - PLC816 Sunn Dimmer Pack - PS610 Briefcase for Light Console 50 R Microcphone Cable 50 R Speaker Cables Orange Cord Totes Knight TD-40 Stand for Light Baz Knight TD-40 Light Bars Paz 38 Light Canisters F1oad Lights Gel Frames cvith eartra Ge1s Two I.eather Bags, one for each Sunn Dimmer Pack - PS610, were not there and an Aabe's employee said they did not see or receive them when they purchased these items. One Knight TD-40 Stand for Light Baz was missing (we thought this was unusual because the K»ight TD-40 Siand was useless without the Knight TD-�t0 Light Baz). When we commented on it we were assured by an Aabe's employee tLat it was in their store somewhere. We asked about the Krright TD-30 Speaker Tripods, trrinldng they would t�ave been sold to Aabe's with the Knight TD-40 Stands. George was explicit in his description of them, but no one claimed to ttave seen them. We were told by Eric, the store manager, and another employee on separate occasions that they never received the Krright TD-30 Speaker Tripods in the tcansac[ion. Eric said they did not see them in the vehicle driven by the people possessing our stolen items. Shawn (Jcel Shawn Sweeney, store owner) chased us out of the room that had our stolen items and told Eric we would need to go through proper procedures. We moved to another azea of the store and saw what appeared to be sonne of our stolen cords in a store box. Since Donna saw them first she pointed them out to George. Eric said the items in that box were store cords, not ours. George checked the cords and showed Eric the uritials "GI IvP' on the cord ends (GLM is George's initials and puts them on most of this property). Qur stolen items in that box were: 50 ft: Microphone Cable 6 ft Extension Cords (not grounded) 8 ft. Extension Cord (not gounded) 20 ft. Headphone e�ctension cord Miscellaneous Cables Eatra lmob for the Knight 1D-40 and Knight TD-30 Stands The 3 Miscellaneous Cables, 1 Headphone Cord and 1 Extra Knob aze items &om our stolen "Gadget Bag." T1us "Gadget Bag" also contained other fix-it plugs, computer chips, audio patch cords, cord adapters, and other small miscellaneous items. We thought it was unusual they had some � � In Re Licenses of Josha Corporation — d/b/a Aabe's Music Shoppe — City's Exh. No. 2 � ry , �, _ L � • J meaningless items from the bag and asked aboui the bag and iYs content, descnbing it in detail. Aabe's employees said they had not seen it, but that they did see a plastic red storage box tUat fit the description of our plastic Red Box They remember the people, who sold these items, wanting to keep the plastic red box and some other miscellaneous items in the velucle. Eric and other employces descnl�ed the velricle as an orange Internatioaal Scout with a white roof and the win missing. - — - -- -- - � .__ ...___.. _ — We then walked azound the store looldng for more of ow stolen properry and George found his stolen Boss MA-15A Monitor. We slarted going down the list with Eric and we asked about several items that suspiciously turned up: 1 DeArmond Volume Pedal (Eric retrieved ttus from behind the counter) 1 Ibanez IFC�O Foot Controller (Eric found this against the wall behind the counter) i Rapco AB-100 Switch (Eric removed this item from the glass showcase) We then asked if we could mwe our identified stolen items out of the shopping areas. We were directed to a place in the basement Eric was helping us move things when George asked again about the Knight TD-40 Light Stand. Eric reassured us it was probably out on rental. George questioned how they could rent the Light Stand without the nceded Light Baz (the Light Stand is useless cvithout the Light Baz). Eric gave no explanation. Once we mwed the found items to the basement SLawn told us he wanted to show us azound his st4ce. The fust place he took us to was the back wazehouse, completely off the sales flooz, and continued with casual talk. We thought tfris was unusual unless ]as intention was to stall us while his employees were trying to conceai our other stolen items on our list. He did not bring us anywhere else. After abom 10 minutes of small talk he took us back to the sales floor. We asked what the procedures aze in Uus type of situation and we were assured they would take care of it, but that they would not be calling the police yet We were told that these stolen items were sold to Aabe's "earlier in the week" and the people who sold it came back "a couple days ago and tried to buy it back." Eric and Shawn both gave this statement We again expressed our concem that the police should be called. Sl�awn said he had talked with "some other pawn shops to see how tlris situation should be handled." He said he would be calling the people who sold the stolen mefchandise to tliem and would give them the impression they could buy it back for cash. Once they arrived and turned over the cash they would be told that the items had to be held as stolen property. In this way Aabe's could retrieve the cash they paid for these items, rather than go throngh the hassle of going to court. George and Donna leR Aabe's and went to the St. Paul Police Sta6on. We were then sent to the Arlington and Rice Street Police Station. No one was at that location so we called and were directed to ffie Eas[ Side — 7th Strcet Police Station An officer was just leaving that location and could offer us no assistance. We went home and called 291-1111. After a lengthy explanation, we were told to go back to Aabe's and call for the dispatch of a police officer. We grabbed our Polazoid camera and drove to a pay phone near Aabe's Music Store. When we arrived at Prior and University we called and had a police officer sent to our location (just down the street from Aabe's}, � We could give them details of what had occuxred earlier that day. Also, we weze not sure when the people who possessed our s[olen items would be returning to Aabe's (we did not want to alert them ihat the police were coming). The officer followed us to the back parldng lot of Aabe's and then summoned another officer since he rvas getting off duty in just a few minutes. When the second officer arrived we explained the situation and gave her a list of our stolen items. We e�cpressed our suspicions about several things that took place earlier in the store and with that we went into the store. When we arrived in the store we indicated to the officer who Stiawn was. The officer suggested to Shawn we leave the sales floor with him so we could all talk in private. Shawn said we could move to L? ,� 7 � the basement, since that was were the stolen items were located Shawn did not come down the steps, but yelled to us, "1'll be right there." Donna was suspicious of this and followed Irim back up the staixs. SLawn went wer to an azea where they Lad free hoi dogs for there Grand Opening. He casually prepared himself a hot-dog. When he saw Donna on the floor waiting, he yelled out again, "I'll be right there." Donna did not move as she suspected he would be destroying evidence or mo ving stolen items from the — came up the staus and inquired about the delay, and Donna eaplained wbat she had obseived Sl�awn doing. The police officer asked with impatience, "Can we speak with you?" Shawn came over and only answered a few ques[ions and then told the officer she should reaily be speaking with the store manager, Eric, so he dismissed lumself and the officer began ques6oning Eric. The Police officer asked Eric for a description of the peaple possessing the stolen items ihat were sold to him. She also asked for the documentation of Aabe's purchase of this equipment from those people. Eric retdeved a form that was still in triplicate. This was unusual since it appeared that tfie docwnent had just been made. Tlris form showed a list of inerchandise. At tlris point Donna and George realized they l�ad been lied to earlier, since this form showed they had purchased the Knight TD-30 Speaker Stands. When the police officer asked about the Knight TD-30 Speakez Stands Eric said that they Lad been sold. The date of tlris slip was 4/19/1995 wlrich was Wednesday, clearly a violation of St. Paul City Ordinance Sec. 355.04 paragraph (c). Also, since they Lad twice denied ever baving possession of the Knight TD-30 Speaker Stands, they Lad given false representation of the purct�ase they had made. They twice violated St Paul Ciry Ordinance Sec. 355.04 paragraph @), by l�aving no docnmentation of two of the s[olen items that were in their possession: Ibanez IFC-60 Foot Controller SN: 300154 Boss MA-15A Powered Monitor SN: 551423 The ordinaz�ce requires serial numbers and brand names, which Aabe's had none on the items they bought. This was especially unusual since many items of lesser value Lad been listed on the purchase document This created more susQicion abuut other dncumenu. At this point George found a power strip, belonging to him, that they were using in an equipment set-up on their showroom floor. Eric azgued with George about how that power strip wuld not be his, so George told the officer haw he knew it to be his and proved it. As we documented eariier, Eric told us the people, that sold the stolen iteuu to him, had been back "a couple days ago" to try to get the items back. Eric told the police officer that they were in on Friday, one day before this, to buy the items back. This was just another way in which their scory kept changing. When we left Aabe's, the Police officer and George were suspicious about more items that may have been purchased and already sold, so they returned to the store and asked if the items on the one triplicate form were everything purcl�ased. Eric replied with an empl�atic, "Yes." We did not see a sales slip for the two Knight TD-30 Speaker Stands or the rentai slip for the Knight TD-40 Light Stand. These ttrings were addressed 6y George and Police Investigator Mike Gazvey when they retutned to Aabe's on Monday afternoon to reclaim the stolen property. The story cl�anged about the rental and no explanation could be given as to the whereabouts of that item The sales slip for the two Knight TD-30 Speaker Stands could not be retrieved 6ecause we were told all items sold are simply marked "merchandise" and they kept no record of people who purchased items (name and address). This was a violation of St. Paul Ciry Ordinance 355.01 paragraph (d)(4) wlrich requires a comprehensive account of all sales. The investigator asked Eric tA go back through their sales slips and find the one showing that.transaction and he would ge[ that from Eric later. Since Aabe's had also relocated during that particular week they were in violation of St. Paul City Ordinance 355.04 paragxaph (hj which states that business may be "ouly at a permanent place of business designated in the license" and tbat "No license may be transferred to a different location or a different person. Attached please find the copy of Chapter 355. Secondhand Dealers Regulations and Aabe's license. ,, . c ' � -. �" � J Clearly Aabe's had not upheld the'u agreement cvith the City Licensing Division who did not even believe Aabe's shouid t�ave been licensed as a SecondLand Dealer, since they appear to be openting more as a Pawn Shop, wlrich would require suic[er regulations. It is Donna and George's belief that all the stolen equipment was purcbased by Aabe's and tl�at the items not reclaimed were sold or moved from the properry before they were disco r • -=`-' - =_ il��`+A:'i ��7 P:a;_L POLICE LLPFIRTME!`iT .. _ .,�- , ..�...-.�.�..,u..� . ---_..__�_, �' •. �. ` ��e�. � �* _:'' : � , J �-r� $�s- �b7-sa� ��` � � � � a -- S�di6 1<A�`es ltfS; � � . ^ � � .`aS. £ fi£�,frf►;�l� _..'_ '_�_-_—�-_=•--- - ---- - -..__ _._:^ _� �x iC-Ei-EO dti s<<t i75 r..J � �� t i �i v<_: � ,�.� _ ,;�� --��.-.��1.� ` /3 I e I ry / �° ^"'�� F n Sb a .F��° � f � �Yo(l�r �1�1�ttn �D��G'a3 ' ,�:s�,�t�r� � 8'EC �c�c� :. � GKS� ..�cJ �r'`� �o! �% '�.� �/b F�l�' �� ., N �� '�� 3� � �. �G�c �� }�d� �Utf � �� V � c�' I,�k �r��au � �� ,, t � � —______ [ FINE � • ` , • � . � � � /��Oa BTOi!lOJCf � �TA P4W� � R1Y G --� I ^~ ". , " — -- - , � . .�, - - . .. . � f + . , , .• F.i4 � - n�_�'J 1 r� ��wr��uv Fo�� G -_ , In Re Licenses of Josha Corporation d/b/a Aabe's Music Shoppe , � - City's E�. No. 3 '�e.u.J r � '_ � � � . �t -_.-'____ -'_--;- . . .. _ ... . _ .. .____..___" _ �� .� _-_-'_-_-_-�',�__'___" ____ _-_ -"_,'__` ' _ '_ _ . . .. � � _ }. � � � � �� m, � ; �, i /��;� � � ��'/:,�� \: �� . _ ;,> >. r ��r i� vx �,. � W.. ��i . �s �_ �,�� Y .2 � �v� � / � � �. ��/ R \ ffi� i / �'. / � � . . .. � �. � —�'a d L a s a� � us rn� � a � iqm — uot;�.�od.io� �qsap;o sasua�i7 a� uY � � ` r ` �' �y �� i` .� ��na t.aA'T=�9W01$fl'J c��_7-; E M 1 2852 Johnson Street NE MINNEAPOLIS, MINNESOTA 55418 (612) 789•2496 SOLO BY �ATE �g NAME PHONE AODRESS CITY � CASH ❑ CHARGE � MOSE.RETD. ppEVIOUS ' Q C.O.O. � PAIDOUT ❑ PD.ONACCT. BALANCE � � 2 sU� - �s � �� RECEIVED 8V �Idil�L�011 � raw�n ssoi 0 uc cmmi � o�nt m mex e�wne rau �rz i+emsusw� �; �.� � r i �� t -: h �� =y -_ � ��,� „ � �, ��. � �, , � � 9�_ 7:=, - _ _� - -...__ _ .. _ __ __.� 2852 Johnson Street NE MINNEAPOLIS, MINNESOTA 55418 (612) 789-2496 � CASH � CHAqGE � MDSE.RETD. ❑ C.O.D. � PAIO OUi � P6. ON ACCT. � f � �� PREVIOU3 ' 6ALANCE � � > OU � I RECEIVEO BY �1 P(�ILf 6961 � ��c, Grtbh Ma¢ Oldll io prM RqNf 1%L iP[F I+POSII5630] � � /i � ., a.. . - .. . . t" .. Gnsiomer s Oroer No i Fnone No i Dace � . 9 - Soltl ta � _�_ i Atldress '_. _ . r �- � . ._. . -. .., „ " �. '. - � � ' �, ,�. • _'i'�_ 1 _ . .� •.i City ' �i � ;� 1 � � � --, i !� Sold By, Cash C,OD I Cfiar9e On Acct. I Mtlse Reta I°aiC Out I I. i � � "- - _ I % -. � _� . � . .�.� - . � J_ : �� I t_ , � � I . �i' `� ' `\ r r . I l I _ i —�- � � _ � � i � � � I ' � � ' I I ! I ! I I � I � I —' �I �: All ciaims and returned goods MUST be accompanietl by this hill. Rec tl �� B Y � � �� ' ,,f:(:Ln ' — ' 9enme^ Irem NG3P �� Wheeie� 3rew mc �980 � i i ' y � �/f.(.Lnll ��.C! � '_ � � � / � � .� � TORPS �i� ��q�2 MUSIC CENTER SALES LESSONS 528 RICE ST. ST. 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CO. � M0.5E REfD. �� B � C.OD. �ONACCT. �PA/DOUT ' -- 'fOTY ,_ . , ; ; - �DfSCRlPTION.', _ . .. _, -:,UNqPFICE � ._�.AMOUM i.s � �, r3�-___7-b ' `.� � -- --� � ! =" �iZ RECEIVED BY -� -!`' � =� � ---_ - %y � s ------- - --- ----------- - ---- -- ^ -,- _____ --- - ----------- -- ---- � �-i-- f, ___- -- --_---------- - --�- — --- 2� � a� 7AX _ - _.. _ TOTAL 7HIS SLIP MUST ACCOMPANY ANY RETUFNS OR CLAIMS ORIGINa[ T�-_r/1/ � FOflMNO.1S£3JWlLLIAMCO [ 19BJ J WILLIPM COMVANY INC L /IR�R) zai-oasa iH Ga Cn�c raoo-saso»a �; :� _ _ _ — -- - -- — - i — �, �: �, - i=:-- � ' , > ,.�- � _ .. j _ -_ 0 ' - - _ — — — -- — -- — ¢ � ¢ W ; _;' ` ¢ i'.� ` _ — E I :� - � �/�- 1 `= C a� i . _� . y O �� _ � . 1 - _ �; - �� H . � _e.. _ _c - - �i- � t- � N � *� .� r . :.a.. �� y �� g � _.. 1 a I > ¢ � Q �� F q e - O . r � . . a U N F W Z . . w = � p J ¢ _ ` � Z � � � a : W ~¢ m z - Q a _ ti (n � a � - U V 'f .. O ° _ LL .. Q � tii�:�� . _ ��C.7��r- . i� n ' " _ t , ._ . {�. 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'LS �6 A] U1 U1 TJ ¢i i N N N U k Q1 N (6 U L." -rl U ri R i], •�i N 1.7 .0 m N N N U RS N [a m m E X SC N � U d C•�+ � U H �C 1� N N J� •�-I O O iR ill Ul U] JJ !-1 JJ O O 1� C.� 1�i .ti '.� N N W O O O O � 1� F O O LL t1 E fa Q N O O O w O O O Ui O O t6 q u1 w ua w O 0 � w c6 � u N .0 E RS hc O 4-I 4-i Sa � U U 75 •ri N .Sj O O tf) O o 0 O f6 •ri -� -rl '� JJ H p] In N lf1 � CO l0 U N G4 ,� � U) (� H �k �-1 rl N cM N M � N M� rl t-i r-I .-1 rl N a I�I +-� ri{ � N N { N 1 NI N I NI NI NI N{ NI � � � t P 'CS N N N U $ X X� 7C ,C �' R S ' S m x � � � � � U O A � .S� n • ��x o -� cn x �� r., �� r�e 0 �� _ �f41�1�1�1�f�i�l�i� � � � �� N N Q 41 N 0 O E 'i3 N N 3 U L". .L: aS Id Si N �7 ri - b) � U 3 C: '� N 'a�. o S-I W J.� N U O X � U r� O N •�-i � •.� O m N� � a� N 3 .x N +� .A ?-i -� O Q u� 8 0 U .0 R� O E �a u� w E a� m N a� � � -� N w�}a N D, }i '�tl O R, tn S-i '� �+ b� 3 N �.A �-.� p, �+ m w rt -� u A U rtS N a� .R o.� S-� R� 0 tn X m "d tn c6 N H u, rn a rt�� ,� � a a o� ro zs x a� o�a m ca o x-� m �n -� -�+ �s � A � o.� z� � N.1 � N u z �a N Ul 4-1 c6 � c6.�G }-i N 4i U N ,U N H �.' N a�i � ��'� u a�.� 2S 3 �-��i � � fx � D z3 � � a� � o a -� x� o��-�+ N a� x a� •.� H t� W U �d � GI c� W V1 L.7 � Q DC O U (x c/1 � �—I c-4 rl M .-i r-1 N ol N N C +1 � .-i ri N i: �-i N (+1 d� ln l0 l� N Ol O r-i N M d+ Lf1 a M f� t'Q f� M t'q M M th d� d� d� 'cR d� d� (� r ^ � �, � _ , �� . r . 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2� 21 22 23 24 25 � � --, _ Page 1 STATE OF MINNESOTA BEFORE THE COUNCIL OF COIINTY OF RAMSEY THE CITY OF ST. PASTJ„� In Re the Matter of All Licenses held by Josha Corporation d/b/a Aabe's Family Discount CenterJAabe's Music Shoppe for the premises located at 1933 University Avenue West, St. Paul, Minnesota. ------------------------------------------------- DEPOSITION OF RONALD KIES Taken on November 7, 1995 ��Op� Nancy J. Meyer, RPR CAPTION MINNESOTA, INC. 14286 Dulcimer Way Apple Valley, Minnesota 55124-5954 (612) 322-2113 Fax: (612) 322-2110 CAPTION MINNESOTA, INC. (612) 322-2113 f � s� / 1 2 3 4 5 6 7 8 9 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 �° �:_ 1��_ Page 2 DEPOSTTION of R023ALD KIES taken pursuant to Noti of Taking Deposition taken on Novem�,er 7, 1995, commencing at approximately 12:30 p.m., taken at the Minnesota Correctional Facility, Bayport, Minnesota, bePore Nancy J. Meyer, Registered Professional Reporter, a Notary Public in and for the County of Dakota, State of Minnesota. A P P E A R A N C E S• On Behalf of Josha Corporation: Timothy B. Poirier LOWRY HILL LAW OFFICES Attorneys at Law 1900 Hennepin Avenue South Minneapolis, Minnesota 55403-3198 On Behalf of the City of St. Paul: Gail L. Langfield Assistant City Attorney 550 City Hall and Courthouse 15 West Kellogg Boulevard St. Paul, Minnesota 55102 Also Present: Peter Pangborn Leslie Tallman CAPTION MINNESOTA, INC. (612) 322-2113 0 r � �� ._� �,.� 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I N D E X TIiE WI`PNESS' RONAI�D KIES �. c , ... � � , ., Page 3 EXAMINATION BY: PAGE Ms. Langfield ...................................4 Mr. Poirier ....................................37 Ms. Langfield ..................................65 Mr. Poirier ....................................71 EXHIBITS MARKED Exhibit No. 1 ...................................8 * Pawn/Buy Form Exhibit No. 2 ..................................15 * photograph EXhibit No. 3 ..................................16 * photograph EXhibit No. 4 ...............................19-20 * photograph EXhibit No. 5 ..................................21 * photograph EXhibit No. 6 ..................................23 * photograph OBJECTTONS Ms. Langfield ...................40,41,52,55,72,72 Mr. Poirier ....................................69 CAPTION MINNESOTA, INC. (612) 322-2113 T } y ^ - � � ..� ! _ �� - E_� 1 2 3 4 5 6 7 8 9 10 11 Q. 12 13 A. 14 Q. 15 16 17 18 19 20 21 22 23 24 25 Page 4 P R O C E E D I N G S (The de osition _of RONALD KIES was____ P _ ... _ _. commenced at 12:35 p.m. as follows:) (Oath administered.) THE WITNESS: Yes. RONALD KIES, having been first duly sworn on oath, was examined and testified as £ollows: EXAMINATION BY MS. LANGFIELD: Good afternoon, sir. Could you please state your full name. Ronald James Kies. Okay. This is a deposition. I want to give you some ground rules so you don't jump on the back of my questions. She can record one person at a time, so we have to answer this in a question-answer format. So when I finish my question, start your answer, and we'll try not to talk over each other, because she can only record one person. Also, she cannot really record a nod or shake of the head accurately, so I ask that you answer in a verbal format. If you don't understand any of my questions, I ask that you tell me that you don't understand, and I'll do my best to either explain CAPTION MINNESOTA, INC. (612) 322-2113 r r � � li - -~'�� 1 2 3 4 5 6 A. 7 Q. 8 A. 9 Q. 10 11 A. 12 Q. 13 14 15 A. 16 Q. 17 A. 18 Q. 19 20 A. 21 Q. 22 A. 23 Q. 24 25 A. Page 5 what I'm asking or rephrase it in a way that might be more understandable. And that's all�can_+hiri of at this time. Can you tell me your current address here, just for the record. Okay. Still -- Box 55, Stillwater, Minnesota. Okay. And this is the Stillwater prison? Correct. Okay. Minnesota Correctional Facility in Stillwater is the full name, correct? Correct. And can you tell me about your educational background, where you went to high school and that kind of stuff. Oh, St. Paul, Minnesota. Okay. Did you go to a high school? No. The highest grade I completed was ninth. Okay. And what was your last school that you went to? I believe Maplewood. Okay. Maplewood Junior High? Yeah. Okay. And we�re here today because you have been convicted of -- is it receiving stolen property? Correct. CAPTZON MIP3NESOTA, INC. (612) 322-2113 I � �: �� 1 t� z,� -4, _� 1 Q. 2 A. 3 Q. 4 A. 5 Q. 6 A. 7 Q. 8 9 10 A. 11 Q. 12 A. 13 Q. 14 15 A. 16 Q. 17 A. 18 Q. 19 20 A. 21 Q. 22 A. 23 Q. 24 A. 25 Q. Page 6 Can you tell me when that conviction occurred. Well, I was arrested for it on May 5th. OP this year? Yes. And did you plead guilty to that ofPense? Yes. Okay. Prior to the offense for which you're incarcerated now, was there any other conviction -- convictions for crimes? In the past? In the past. Yes. Okay. Can you give me a history of your convictions. We can go backwards. You want them all? Yeah, the best that you can recall. I had another receiving stolen goods. And when was that? If you don't remember the month, would the -- if you, remember the -- �92, I believe. Okay. Or '9 -- nope, '93. And any bePore that? Attempted theft. And do you recall the year? CAPTION MINNESOTA, INC. (612) 322-2113 � � f _� Page 7 t 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 7 8 Q. 9 A. 10 Q. 11 12 A. 13 Q. 14 15 A. 16 Q. 17 A. 18 Q. 19 A. 20 Q. 21 A. 22 4• 23 A. 24 25 '92. Any be£ore that? - There was a whole bunch of them. Okay. The most you can remember. Let's see. I got attempted burglary from '92 also. Let's see. I got a terroristio threats and a possession oP cocaine, and that's '87. okay. Any before that? Yep. Aidinq escape from custody, and that's '79. What I've got here, this one, and then there was a receiving stolen goods in 1992 or 1993. Right. An attempted burglary in 1992. Was that the theft? Well, there was an attempted burglary in -- '92. I have that one. Right, and then there's attempted theft also. In '92? I got a burglary charge in '83 also. Okay. The dates are kind of getting screwed up here. Okay. I would have brought the paper if I would have known 2 would have got asked this. Conspiracy to introduce contraband, one in '79 CAPTIQN MINNESOTA, INC. (612) 322-2113 �� ,. :� 1 2 Q. 3 A. 4 Q. 5 A. 6 Q. 7 8 9 10 11 12 13 A. 14 15 Q. 16 A. 17 18 19 20 21 22 Q. 23 24 25 i� � _ f Page 8 and one in just this year. Okay. How many do we got now? This one is for receiving stolen goods. Right. Then we have receivinc3 stolen goods in '92 and '93, that's number 2, and attempted theft in '92, attempted burglary in 1992, terroristic threats and possession of cocaine in 198�, aiding escape in 1979, burglary charge in 1983, and conspiracy to introduce contraband, both in 1979 and 1995. Can you remember any others? Yeah. I'm missing two. I don't know what they are. Probably attempted felony theft. Okay. And were they in the 1980s or the 1990s? '90s. MS. LANGFIELD: Okay. Nancy, I need an exhibit marked. (Deposition Exhibit No. 1 marked for identification by the court reporter.) BY MS. LANGFIELD: Mr. Kies, can I show you what's been marked as Kies Exhibit No. 1, and that's in the blue sticker down there, and 2'm goinq to call this exhibit a Pawn/Buy Form, and I call it that because it says CAPTION MINNESOTA, INC. (612) 322-2113 ' ' r k y ! , 4 -� -� 1 2 3 A. 4 Q. 5 A. 6 Q. 7 8 A. 9 Q. 10 A. 11 Q. 12 13 A. 14 Q. 15 16 17 A. 18 Q. 19 20 A. 21 22 Q. 23 24 A. 25 Page 9 Pawn/BUy Form up here in the corner. Have you ever seen this document before? Yes. Okay. When did you £irst see this document? When I signed it. Okay. And that would be on April -- and the date is gone, but it was the month of April? It was the month of April, right. 19th, 1995; is that right? Correct. Okay. Did you -- on April 19th, 1995, did you sell this property to Aabe�s Music Shoppe? Yes. Okay. Can you explain for the record -- first of all, tell me, were you alone when you sold this property? No. Who else was with you, to the best oP your recollection? Two other folks that -- that I had met downtown at Atlas temporary service. Okay. And can you describe these two other persons. Yeah. White males. One was probably 6 feet tall, long hair, scruffy beard. The other one was CAPTION MINNESOTA, INC. (612) 322-2113 ', _ - �� -�> � 1 2 3 Q. 4 A. 5 Q. 6 7 A. 8 Q. 9 A. 10 Q. 11 12 A. 13 14 15 16 17 18 Q. 19 20 21 22 A. 23 Q. 24 25 A. Page 10 probably about the same height, long hair, clean shaven, I think. Okay.. Did you know these -- are these both males? Yeah. Did you know these two -- these two males or these two guys? Not really. I had just met them. Do you recall their names? Nope. Okay. How did they approach you at Atlas Temporaries? I had ran into them on two occasions, one where we had just talked and -- talking about music, and I had told them that I go to a lot of open jams, play drums, and the second time I met them they had come to me, asked me if I knew where they could sell some musical equipment. So the -- the second time when they asked you if you knew where they could sell the musical equipment is when you sold this equipment (indicating)? Correct. And the first time you were just talking with them about music? Right. CAPTTON MINNESOTA, INC. (612) 322-2113 � i `�� -- � �_>- 1 Q. 2 A. 3 Q. 4 5 A. 6 Q. 7 8 A. 9 Q. 1� 11 12 A. 13 14 15 16 17 18 19 20 Q. 21 A. 22 Q. 23 24 A. 25 � Q. Page 11 And where did that conversation take place? That was down at Atlas. Okay. And the second time, did that take place at Atlas too? Yes. And the second conversation, was that on April 19th, 1995? Yes. Okay. Can you tell me the most you aan about that conversation, about how they approached you and asked you about knowing where to sell. They came in and seen me in there. They came up and said they had some musical equipment and they thought that maybe I could help them sell it. I had called a friend of mine that I thought maybe would be interested in it. He was at work, so I didn't want to bother him at work, so I told him I knew of a pawnshop or a music store that bought used equipment. Okay. And so I showed them where it was. Okay. Was that pawnshop or music store that bought used equipment, was that Aabe's Music Shoppe? Yes. And when you say you showed them where it was, te11 CAPTION MINNESOTA, INC. (612) 322-2113 �� `�. � 1 2 A. 3 4 5 6 7 8 Q. 9 10 A. 11 12 Q. 13 14 A. 15 Q. 16 17 18 19 A. 20 21 22 23 24 25 Q. Page 12 me about how you showed them where it was? We drove there and pulled up front and went in and talked to Eric, and basically the -- one o£ the other guys had explained to Eric what -- what they had. He came out, looked at it. Eric told them to bring it in, set it up, show him how it worked. They did all that and ended up selling it. Okay. Did you help the -- the two other guys set up the equipment? No, I-- I helped them carry it in. I didn't know anything about setting it up. Okay. Did they have any difficulty in setting up the equipment? No. Okay. Is anybody -- who else is present besides Eric, yourself, and these two other males when you -- when the sale is occurring? Is there anybody else there? Well, there was a salesman there, Mike Sherman. He -- he was just in and out, though. He was -- didn't really have any involvement in it as far as the sale of it. Basically the two guys that set it up demonstrated it and then made negotiations to sell it, I guess, for a price. Okay. Were you at all involved in those CAPTION MINNESOTA, INC. (612) 322-2113 -,,_` Page 13 � 1 2 A. 3 Q. 4 5 A. 6 Q. 7 A. 8 9 Q. 10 A. 11 Q. 12 A. 13 Q. 14 15 A. 16 Q. 17 18 A. 19 Q. 20 A. 21 Q. 22 23 A. 24 25 negotiations? No. Okay. Do you know Mike Sherman other than that he works for Aabe's? Yeah. Okay. How do you know Mike Sherman? I used to go to a lot of open jams and would go watch the band that he used to play in. okay. That's when he was with a band named Crow. Cro, C-R-O? C-R-O-W. Prior to this sale that's here on Exhibit 1, did you ever sell equipment to Aabe�s before? No. Now, when these two unidentified males set up the equipment, they're inside the Aabe's store? Yes. Okay. What time of day is that, do you know? Probably -- in the afternoon sometime. . Okay. After they set it up and negotiated a price, what happened? Neither one of them had an I.D. on them, and so they asked if they could use my I.D., and they ofPered me $20 for doing so. CAPTTON MINNESOTA, INC. (612) 322-2113 � � - �� 1 Q. 2 A. 3 Q. 4 5 6 A. 7 Q. 8 A. 9 Q. 10 11 12 13 14 A. 15 Q. 16 17 A. 18 19 Q. 20 A. 21 Q. 22 23 A. 24 Q. 25 Page 14 And you let them use your I.D.? Yep. - — Okay. To talk a little bit about what was sold to Aabe's music store, do you recall -- do you know what any of this equipment looks like? Yeah. Okay. Do you know what a Sunn controller is? No. Okay. I might need Peter's help with identifying some of this stuff. That, I understand, is a liqht controller. Does that make any sense to you? Do you know if that was sold, a light controller of some sort? Yeah, of some sort there was. Okay. And how many of those light controllers were sold, do you know? I know they were controlling it off of one -- one board. Okay. So you recall one board being sold? (Witness nods head.) Okay. Some light dimmer packs, were they also sold? Yes. Okay. And some Par cans on bars, were they also sold? CAPTION MINNESOTA, INC. (612) 322-2113 ` �� 1 A. 2 Q. 3 4 A. 5 6 7 8 9 10 11 Q. 12 13 14 15 A. 16 Q. 17 A. 18 19 Q. 20 A. 21 Q. 22 23 24 A. 25 Q. i� � Page 15 Yeah. Okay. Do you recall what these Par cans on bars _ are? I would -- I believe they are what the -- where the bulbs were screwed in. MS. LANGFIELD: Okay. Why don't we have Nancy mark a picture here. (Deposition Exhibit No. 2 marked for identi£ication by the court reporter.) BY MS. LANGFIELD: Let me show you what's been marked as Kies Exhibit 2. Are those Par cans in this picture up here (indicating)? Is that what a Par can on bar is? Not the closest picture, but -- Yep. That's visible, then, in Exhibit 2? (Witness nods head.) This here and this here (indicating). Okay. So there�s two sets of them? Yep. Okay. Were there -- did you sell four Kniqht -- or did these two unidentified males sell four Knight tripods? Yes. Okay. I think -- let me just take a quick -- CAPTION MINNESOTA, INC. (612) 322-2113 r '� Page 16 F u � 'L:s m 1 A. 2 Q. . -. A- 4 Q. 5 6 A. 7 Q. 8 9 A. 10 Q. 11 12 13 14 15 16 17 18 19 20 Q. 21 22 23 24 A. 25 Q. It's right there (indicating). Are there four in this picture? Yep. Okay. And four of those tripods are then in Exhibit 2? Yes. Okay. And did you or the two unidentified males sell a volume pedal, the DeArmond volume pedal? Yes. Do you know if you can see that in that picture? I don't know if it's in that picture. MS. LANGFIELD: Yeah. Let me have Nancy mark another picture here. TAE WITNESS: This looks like it could be it right here. MS. LANGFIELD: Hang on one second. (Deposition Exhibit No. 3 marked for identification by the court reporter.) BY MS. LANGFIELD: Let me show you what's been marked as Kies Exhibit 3. Is this the DeArmond volume pedal? It has a glare back or something, so you might have a little trouble seeing it. Yep. Is that it? CAPTION MINNESOTA, INC. (612) 322-2113 �. .=, _ Page 17 � ,.:_� <, � 1 A. 2 Q. 3 4 A. 5 Q. 6 A. 7 Q. 8 9 10 A. 11 Q. 12 A. 13 Q. 14 15 A. 16 Q. 17 18 19 20 21 22 23 A. 24 Q. 25 Yep. And I'm showing you in this exhibit what ap��,r,s__on the right half of the picture? (Witness nods head.) Yes. And that was something that was sold? Yes. All right. Po you recall any other equipment being sold? And let me run throuqh a couple of questions here -- Whatever this is here was sold too (indicating). What appears on the left half of Exhibit 3? Yes. Okay. Do you know if that's one or two pieces of equipment? Can you -- That's one. Okay. All right. I have a list, so I'm going to run through a list and ask you and if you can recall this being sold, and you can tell me yes or no at the end of it. Were there large Peavey speakers sold? Yeah, and I have it marked in Exhibit 2. Were these things (indicating), were they sold? No. Okay. And the Peavey speakers are on top of some tripods? CAPTION MINNESOTA, INC. (612) 322-2113 _. . � _. Page 18 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 Q. 7 8 A. 9. Q. 10 A. 11 Q. 12 13 A. 14 Q. 15 A. 16 Q. 17 A. 18 Q. 19 20 A. 21 Q. 22 23 24 25 Yes. I have to do that Por my record. (Witness nods head.) You don't recail those being sold? No. Okay. In these Par canisters, light bars, were there flood lights inside? Yes. Okay. And those were sold also? Yes. And do you know what a gel frame is, sheets or something that tYxey slide in -- The lenses? The lenses. Yes. Were those solfl? Yes. And four tripods were sold. I think we went throuqh that. Yes. Do you recall any leather bags being sold? I don't have any pictures of leather bags, but they would have been large enough to hold something called dimmer packs, which appear here (indicating), these items. CAPTION MINNESOTA, INC. (612) 322-2113 , . _: Page 19 .< 1 A. 2 Q. 3 _. _._ 4 A. 5 Q. 6 7 8 A. 9 Q. 10 A. 11 Q. 12 13 A. 14 Q. 15 16 17 18 19 20 A. 21 Q. 22 23 24 25 I can't remember. Okay. A Boss powered spot monitor? And I have a picture of that too somewhere. I think that's this right here (indicating). Okay. Okay. I do believe you're right, and that appears on Exhibit 2 below one of those Peavey speakers -- Yes. -- on the lePt-hand side of the picture? Yes. Okay. And was that piece of equipment sold, that Boss powered spot monitor? I believe so. Okay. Do you know if something called a Rapco AB 100 switch was sold? It's a small box, and I'm holding my hands out in front of ine, and it's approximately 6 inches by 6 inches, and it has two buttons on it, one A, one B, and it can be switched back and forth, and it's black. I'm not sure. Okay. Do you know if some Sunn floor monitors were sold? And those are wedge monitors. MS. LANGFIELD: And I'll have Nancy mark another picture here and show you something. (Deposition Exhibit No. 4 marked for CAPTION MINNESOTA, INC. (612) 322-2113 Page 20 zz� 1 2 3 Q. 4 5 6 7 8 A. 9 Q. 10 A. 11 Q. 12 13 14 15 A. 16 Q. 17 18 19 A. 20 21 Q. 22 23 A. 24 Q. 25 identification by the court reporter.) BY MS. LANGFIELD: Let me show you what's been marked as Kies Exhibit 4, and in the foreground of this picture on the right-hand side is a wedge monitor I'm told. Do you recall if -- iP that was sold, two of those were sold? No. Okay. They were not sold? No. Okay. Now, I'm told on Kies Exhibit 3, what appears on the left side of this picture, what we identified before, is the Ibanez foot controller, and you recall that being sold? Yes. Okay. Do you recall if a Boss 120 adapter was sold? I don't know what that is, the equipment looks like. I-- I don't know by the name of it exactly what it is. Okay. Do you know what -- do you have an idea what an adapter is, a Boss adapter? Np. Okay. Were speaker cables sold to Aabe's Music Shoppe on April 19th? CAPTION MINNESOTA, INC. (612) 322-2113 Page 21 ^C 1 A. 2 Q. 3 A 4 5 6 7 8 9 Q- 10 11 12 A. 13 Q. 14 15 A. 16 Q. 17 18 A. 19 Q. 20 21 A. 22 23 Q. 24 A. 25 Yes. Okay. Do you recall how many speaker cables? All that right there (indicating). MS. LANGFIELD: Okay. Let me mark this picture then too. (Deposition Exhibit No. 5 marked for identification by the court reporter.) BY MS. LANGFIELD: And I'll show you what's been marked as Kies Exhibit 5, and you said all these cables and cords were sold also? Yes. Okay. And these -- they were sold on these reels as they appear in the picture? Yes. Yes. Is that more than speaker cables? Is that also electrical cords and extension cords? Yes. Okay. Do you recall or know how many speaker cables and cords are there? All I know is this -- the spools that are shown here (indicating). Okay. Exactly how many numbers or whatever, no, I don't recall that. CAPTION MINNESOTA� INC. (612) 322-2113 _.a � � , 1 Q. 2 3 A. 4 Q. 5 A. 6 Q. 7 A. 8 Q. 9 A. 10 11 Q. 12 13 14 15 16 A. 17 Q. 18 A. 19 Q. 20 A. 21 22 Q. 23 A. 24 25 Page 22 Okay. Do you know if a Panasonic cassette tape recorder was sold? I don't believe so. Any microphone stands? No. Okay. Any music stands? No. Okay. Any guitar stands? No. Did we cover this right here, that little brie£case (indicating)? I'm getting there. Do you recall -- I'll ask you -- let me ask you about this briefcase then, since you brought it up. In Kies Exhibit 5, there appears a briefcase on the right-hand side of a picture -- of the picture. Yes. Was that sold? Yes. Okay. And what is in that briefcase? It had all kinds oP slides to control them lights (indicating). okay. Looked like a little synthesizer. What it was, I don't know what it was. I just know they controlled the lights. CAPTION MINI3ESOTA, INC, (612) 322-2113 ^ 1 � 1 W ` Page 23 _� l� <<:� 1 Q. 2 A. 3 Q. 4 5 6 7 8 9 Q. 10 li 12 13 A. 14 Q. 15 A. 16 Q. 17 18 A. 19 Q. 20 A. 21 Q. 22 23 24 A. 25 A red storage box, a large red tote box? I don't believe so. was -- MS. LANGFIELD: Let's see. Mark one more picture. (Deposition Exhibit No. 6 marked for identification by the court reporter.) BY MS. LAI3GFIELD: Let me show you what's been marked as Kies Exhibit 6, and in the foreground of this picture on a floor there appears some bags with cords laying around them. Were those also sold? I recall this one (indicating). And you're pointing to a black striped bag? Yes. Do you recall if a red -- the red striped bag was sold? I don't recall, no. But you recall the black striped bag? Yes. Okay. It's kind o£ far away, but can you pick out anything else in this picture, anywhere in this picture, that was sold to Aabe's, any equipment? I think most of those cords were, and this little box, I think we've already gone over that. CAPTION MINNESOTA, INC. (612) 322-2113 �'� ; � � Page 24 ,-°.. ',�� 1 Q. 2 A. 3 Q. 4 5 6 7 A. 8 Q. 9 10 A. 11 Q. 12 A. 13 Q. 14 15 16 A. 17 18 Q. 19 20 21 22 A. 23 Q. 24 25 A. And the little box that you're pointing -- Which is this right here (indicating�_ _ _.__._. Okay. For the record, I'm going to identify this the best I can. Above the red bag there appears to be a small black box, and you said you recall that being sold to Aabe's? Yes. And it appears also in Kies Exhibit 2 on a stand next to one of these speakers? Yes. And that was sold to Aabe's? Yes. okay. Did you ever get a chance to look in this little black bag or anythinq? Do you know what was in it? No, I don�t really know what was in it. I didn't see for sure. Okay. Do you know -- some of this is going to be small, so you might not have seen it and might have been there and might not have been there. But do you recall seeing any drumsticks being sold? No. Any power strips? I suppose those are long strips with many outlets, electrical outlets. I think that's what was in that bag. CAPTION MINNESOTA, INC. (612J 322-2113 �' 1 � - , I �-•. > � 1 Q. 2 3 A. 4 Q. 5 6 A. 7 Q. 8 9 10 A. 11 Q. 12 13 14 A. 15 Q. 16 A. 17 Q. 18 19 A. 20 Q. 21 A. 22 Q. 23 A. 24 Q. 25 Page 25 okay. So you think that's the power strip, okay. Do you know about any XLR transformers? �. I don't know what those are. Okay. Do you recall seeing any large cases with silk banners in it? No. Okay. Did you at any time see this sign which is in Kies Exhibit 2 saying Cruzin'? Did you see that? No. okay. Did you ever sell to Aabe's on that date a red hand truck, and that's a two-wheeler dolly-type thing. No. Or a silver hand truck of the same sort? No. After -- how -- how was payment made for the equipment that was bought and sold? Eric had wrote out a check. okay. And that's an Aabe's Music Shoppe check? I'm not sure. I would imagine it was. Okay. And what was the amount of the check? $135. Okay. And is that the same amount that appears here on this Pawn/Buy Form -- CAPTION MINNESOTA, INC. (612) 322-2113 �-. ; _" _ Page 26 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 Q. 7 8 9 A. 10 Q. 11 A. 12 13 Q. 14 A. 15 Q. 16 17 A. 18 19 20 21 22 Q. 23 A. 24 25 Yes. -- which is Exhibit No. 1? Yes. And the check was made out in whose name? My name. Okay. And what happened after the -- after the check was made out, did you and the two other gentlemen leave the store? Yes. Okay. And then what happened? Then they drove me to Cub Foods where there was a bank inside there where I cashed the check. And who got the money? They did. I got $20 for using my I.D. Okay. What happened then? Can you kind of -- did you part ways, or did they take you back downtown? No, they took me back downtown, and they were talking amongst themselves. I don't know if they were joking or what, but one of them had made a statement about his brother was going to be mad that they took this stufY without his knowledge. Okay. And from the conversation they had, I had gathered -- I got bad feelings about it, and I had suspected that the stuff was stolen, and so then -- CAPTION MINNESOTA, INC. (612) 322-2113 � �q � �� ' � �. � 1 2 3 4 Q. 5 6 A. 7 8 Q. 9 10 A. 11 Q. 12 13 A. 14 15 16 17 18 Q. 19 20 A. 21 Q. 22 A. 23 Q. 24 25 A. Page 27 I think it was the very next morning I had called a friend of mine and borrowed $135 and went back to Aabe�s and spoke with Eric. Okay. And -- now, this was early in the morning of the day followinq? Yeah. It was early in the morning. I was there before the store was even open. Okay. And the day Pollowing would be April 2oth, 1995? Yes. And is it only Eric that is there at the store at that time? Let's see. I was there and then Mike Sherman showed up. And everybody was -- there was a couple customers -- I believe that they were customers -- waiting for Eric to get there and open the doors. Then Eric showed up, and then we all went in. Did your friend that you borrowed the money from also go with you? Yes. . Okay. And that person's name is? Johnny Foster. Can you give me an address or some way to contact Mr. Foster. I'm not sure of his address. I know his phone CAPTION MINNESOTA, INC. (612) 322-217.3 � ., _ . � ;� '�`=° 1 2 3 4 Q. 5 A. 6 Q. 7 8 A. 9 Q. 10 11 12 13 14 A. 15 Q. 16 17 A. 18 Q. 19 A. 20 Q. 21 22 23 24 A. 25 Q. Page 28 number, but I don't know if -- if he -- you know, I'm not really in a position to give it without hi; permission. I could have him contact you. Okay. I would prefer to do it that way. Would you be able to contact him within the next day or so? Yes. I'll give you my -- I'm going to give you now a piece o£ paper with my telephone number on it, and this is my office telephone number, and I'll be in the office tomorrow all day, so if you'll a�k Mr. Foster to call me -- okay. -- that will be helpful. I'll give you my name, and my phone number is 266-8748. When would be the best time to call? I'm in the ofPice from 8:30 until 4:30. Okay. Maybe if I make that 8 better, because sometimes I write too fast. Translated on the bottom. Ask Mr. Foster to call me, if you would, please. Yes. I'll call him today -- tonight sometime. All right. Now, when you went -- returned to the CAPTION MINNESOTA, INC. (612) 322-2113 r Page 29 �� 1 2 3 4 A. 5 Q. 6 A. 7 8 Q. 9 A. 10 Q. 11 A. 12 13 Q. 14 A. 15 16 17 Q. 18 19 A. 20 Q. 21 22 A. 23 24 Q. 25 store and Eric was there and Mike Sherman, Mr. Foster and yourself and a couple other customers, you went into the store? Yes. Okay. And tell me what happened. I had explained to Eric that I believe that the merchandise that he purchased was stolen. Were those the words that you used? Yes. Okay. And what was Eric's response? Well, I had told him that I wanted to buy the stuff back -- Uh-huh. -- just so there would be no problem and then, you know, I could deal with the matter myselP. And his response was that he'd sell it back to me for $500. Okay. And you wanted to buy it back for the $135 that was paid? Yes. Okay. Now, when Eric said that he would sell it back to you for $500, did he say anything else? No, other than that if -- i£ I didn°t buy it £or $500 that he wasn't letting it go. Okay. Did he at all tell you that there would be a waiting period to buy that merchandise back? CAPTION MINNESOTA, INC. (612) 322-2113 n ' , � _ Page 30 �. � ` :� 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 Q. 7 8 A. 9 10 11 12 13 14 15 Q. 16 17 A. 18 19 20 21 22 23 24 Q. 25 No. Okay. No. He did not say that? Nope. And what was your response to Eric when he said I'll sell it to you for $500? 2 just told him that the law was going to get involved with the -- this merchandise and that if they did that I didn't want him coming down on me being that the stuff was under my name, and he said, well, if the law gets involved that he would be my witness that Z didn't sell it to him, that these two other guys did and they just used my I.D. Okay. Any other parts o£ the conversation that you recall? No, other than I just pressed him a little bit tryinq to explain to him that he paid $135 for it just the day before that and that I just wanted to give him his money back and take the merchandise out of there. Everything he had bought was displayed around the store with price tags on it already. All right. Where is Aabe's music store? Can you kind of -- I know it's on University Avenue, but CAPTION MINNESOTA, INC. (612) 322-2113 A l r Page 31 1 2 3 A. 4 Q. 5 A. 6 7 Q. 8 9 A. 10 Q. 11 12 A. 13 14 15 16 Q. 17 18 19 A. 20 Q. 21 A. 22 23 24 Q. 25 can you give me a block, between which two streets. It's up by 280, I believe. Okay. It would be on your right-hand side heading into Minneapolis. Okay. To your knowledge, had they moved since when you were -- They were moving that day. Okay. Do you know if you went to the new store or their old -- I went to their new store, because I stopped at the old location first. There was a couple guys doing -- taking things apart and told us to go down to the new store. And when you were told at the old location, it was the day before, on April 19th, 1995? Was that when you stopped at the old place? Yep. Okay. This was all within 15 minutes. We stopped at the old place and were told where the new location was, and we went straiqht there. okay. Mr. Kies, do you hold any ill will or bad feelings to Aabe's? CAPTION MINNESOTA, INC. (612) 322-2113 � r �� ,.:� -;.,: � 1 A. 2 Q. 3 4 A. 5 Q. 6 7 A. 8 Q. 9 A. 10 Q. 11 12 A. 13 Q. 14 A. 15 16 Q. 17 18 A. 19 Q. 20 A. 21 Q. 22 A. 23 Q. 24 A. 25 Q. Page 32 Nope. Okay. Do you currently -- do you have a girlfriend? Yep. Okay. Did -- is -- did you have a girlfriend back in April o£ '95? Yes. And she's the same person? Yes. Okay. Do you know if she contacted Aabe's or anythinq regarding this case? I'm not sure if she did or not. She ever tell you about it? She might have mentioned something. I believe she did, yeah. Okay. What's -- what's the girl�s name or your girlfriend's name? Joanna. And her last name? Rodriquez. And do you have a phone number and address on her? Yeah. I'll give you the phone number. 772-3481. 3481. Okay. And does she have a job? Yes. So when would be the best time to contact her? CAPTION MINNESOTA, INC. (612) 322-2113 ^ p �. Page 33 �.; u ,y 1 A. 2 Q. 3 4 A. 5 Q. 6 A. 7 8 9 io il 12 13 14 Q. 15 16 A. 17 Q. 18 19 A. 20 21 22 Q. 23 24 A. 25 Evenings, sometime a£ter 5:00. Okay. And you kind of recall her mentioninq something about contacting Aabe's Music store? (Witness nods head.) Do you recall what she said? I believe she called there to talk to Eric about saying that if the police got involved with this that he would be my witness as to the fact that I'm not the one that sold this product to him and that -- because when the police did get involved, that basically Eric didn�t say anything about it. He just basically said, yeah, here's the guy that sold the stuff to us. So she -- she talked to Eria or wanted to talk to Eric? Yes. Did she relate any of that conversation to you whatsoever? Yeah, just what I just said. She talked to Eric and wanted to talk to him about going back on his word, basically. Okay. Did you ask her to contact Aabe's music on your behalf? No. No. I had spoke with the manager too the day that I went back with the $135 -- or the owner, I CAPTION MINNESOTA, INC. (612) 322-2113 Page 34 ,:.� - =a 1 2 Q. 3 A. 4 5 6 Q. 7 A. 8 Q. 9 A. 10 11 Q. 12 13 A. 14 15 16 Q. 17 A. 18 19 20 Q. 21 A. 22 Q. 23 24 A. 25 Q. should say. Okay. He came in probably -- I was -- had been there a ha1P hour, maybe, and he came in, and I told him the same story. And do you know the owner's name? No, not right offhand. How do you know he�s the owner? Because Johnny Faster told me he was the owner and to go talk to him. And can you describe this gentleman for me, physically, this owner person. older guy, glasses, big belly, good eater or beer drinker, one of the two. I can't remember if he was balding or not, but -- Remember a hair color? Kind of brownish, amber maybe. I believe he had a mustache. I'm not sure on that. That was the first and only time I had spoke with him. And you don't recall this gentleman's name? No. Okay. And what did you tell the owner, the person who you are identifying as the owner? You don't have a picture of him? I don't have a picture. CAPTION MINNESOTA, INC. (612) 322-2113 1 A. 2 3 4 5 Q. 6 7 A. 8 Q. 9 A. 10 11 12 Q. 13 14 A. 15 16 17 Q. 18 19 A. 20 Q. 21 22 A. 23 Q. 24 25 A. y -� t r .` Page 35 I explained the situation to him about -- that the stuf£ had been sold there Por 135 ancl I_bQ��_P�ed it was stolen merchandise and because it was under my name I wanted to buy it back. And did you use the word stolen when you talked to him? Yes, I did. okay. And what was the owner's response? Basically what he wanted me to do is find the guys that came in with me and sold the stuff and bring them into the store and that they'd work it out. Okay. And did you tell him or -- tell him anything about that or say anything back to him? I just let him know that I really didn't know them people and that locating them might be a little difficult. And anything else between -- conversation between you and the person identified as the owner? Nope. okay. Mr. Kies, did you.-- were you involved in the burglary regarding this property? Nope. okay. So the first time you ever saw the property was the day you sold it? Yes. CAPTION MINNESOTA, INC. (612) 322-2113 � t � i� 1 Q. 2 — _. 4 A. 5 6 Q. 7 A. 8 9 l0 Q. 11 A. 12 Q. 13 14 15 16 17 Q. 18 19 20 21 A. 22 23 24 25 Page 36 Okay. And what vehicle or how did that property -- how did they get there, what kind of a truck or car or things like that? I forget what kind of vehicle it was. It was like a Bronco, orange. And that wasn't your car? No. I don't even own a car. 2 don't -- I haven't had a vehicle since my car accident in April of �92. Okay. Or -- yeah, '92. I have to consult with Peter, and then -- (REPORTER'S NOTE: Ms. Langfield and Mr. Pangborn con£erring out of the hearing of the court reporter.) BY MS. LANGFIELD: Mr. Kies, did Aabe's say how long they had been in that new store, the -- where you went to the old location, then you went to the new place? Did they say how long -- how long they had been there? I can't remember specifically. I believe he said they were just getting in there, because I know they were still setting things up. MS. LANGFIELD: Okay. Okay. Mr. Kies, I don't have any questions for you, but Mr. Poirier CAPTION MINNESOTA, INC. (612) 322-2113 a � �. ., R �7 - .' ,. Page 37 1 2 3 4 Q. 5 6 7 8 9 A. 10 Q. 11 A. 12 Q. 13 A. 14 Q. 15 A. 16 Q. 17 A. 18 Q. 19 A. 20 Q. 21 A. 22 Q. 23 A. 24 Q. 25 A. may, so we'll continue. EXAMINATION BY MR. POIRIER: Mr. Kies, I'd like to go over your past criminal history, and you tell me if this is wrong or right. We show that you�ve had an attempted burglary in the second degree in 1992. Yep. And an attempted felony theft in 1991? Yep. Domestic assault in 1989? Yep. Criminal damage to property, 1989? Yep. Felony escape from custody, 1979? That's an aiding and abetting. Two 1979 convictions of defrauding an innkeeper? Yep. Possession of a controlled substance, 1980? Yeah, I believe so. Burglary, 1982? Attempted. Terroristic threats in 1985? Yep. CAPTION MINNESOTA, INC. (612) 322-2113 . , �' • _ Page 38 1 Q. Possession of a controlled substance, 1987? 2 A. 19 what? 4 A. 5 Q. 6 A. 7 Q. 8 A. 9 Q. 10 A. 11 Q. 12 13 A. 14 Q. 15 16 A. 17 Q. 18 19 20 A. 21 Q. 22 23 24 A. 25 Q. Yep. Felony thef't, 1991? Yep. � Receiving stolen property, 1994? Yep. Carrying a concealed weapon, 1979? Yep. Is there something that you're hiding regarding this offense, Mr. Kies? No, sir. Aave you ever had reason to hide anything regarding this offense? No. So that if an officer came and wanted to talk to you about this case, you would willinqly discuss it with him? Sure. Absolutely. Did you have the occasion to meet with Officer Peterson of the St. Paul Police Depar�ment on May 5th, 1995? Yes, sir. And isn't it true that at that time you were in CAPTION MINNESOTA, INC. (612) 322-2113 � , _._ .. Paqe 39 1 2 A. 3 Q. 4 5 6 A. 7 Q. 8 9 A. 10 11 12 Q. 13 14 A. 15 16 17 Q. 18 A. 19 20 21 Q. 22 23 A. 24 25 lockup in Ramsey County? Yes. --- ---------- - - And when Officer Peterson came to interview you, isn't it a Pact that you declined to discuss any aspect of this case with him? Yes. And what aspect of the case were you hiding at that time that you're continuing to hide? Nothing. I didn't have a lawyer representing me, and they had me charged with another case at that time. Was there anything stopping you from talking to Officer Peterson regarding this case? Yeah, there was. The fact that they -- there was a burglary that they had charged me for for the May 5th incident. I'm talking about this incident. They were trying to run these incidences together, and at that point in time I wanted to consult with a lawyer before I talked to anybody. So that there was something you were trying to hide regardinq this incident? No. I was not hiding nothinq regarding this incident. I was just not willing to talk about this incident without my lawyer. CAPTION MI23NESOTA� INC. (612) 322-2113 � �, , �_ Page 40 1 I Q. 2 A. 4 5 6 A. 7 8 9 Q. 10 il A. 12 Q. 13 A. 14 Q. 15 16 17 18 19 20 21 22 23 24 25 Because you had something to hide? Absolutely not. ------- -- - - - i ---- - - - �— - - --- Okay. Isn't it a fact that you're one of the people that were at George Moschkau's garage on April 16th and helped rob it? Absolutely not. Absolutely not. I wasn't charged with no burglary on no garage for no April incident. Mr. Kies, weren't you charged -- weren't you charged in this matter? For receiving stolen property. And wasn't bail set at $5,000 in this matter? Yes. Okay. Mr. Kies, I'm going to ask you about some equipment, and you tell me how much money was paid for each. Two Peavy full range speaker cabinets, Model 1150, International Series III BW, serial numbers 7E-02992246 and 7E-02992247. MS. I,ANGFIELD: I'll object. For the record, he said he did not sell that equipment. MR. POIRIER: He can answer the question. Your objection is note. THE WITNESS: Yeah, I've never seen the equipment. CAPTION MINNESOTA, INC. (612) 322-2113 Page 41 1 2 Q 4 5 Q. 6 7 A. 8 9 Q. 10 11 A. 12 Q. 13 A. 14 Q. 15 A. 16 Q. 17 A. 18 Q. 19 20 21 22 23 24 25 BY MR. POIRIER: How much was the two 50-foot mike cables? -� -- _ ___ . _ _ _. _.------ ---- - -- If it's the cabies here on the orange spools, it was included with the $135. Was there any separate consideration paid for the two 50-foot mike cables? There was no consideration accepted for any of that equipment. Was more than $5o paid for eight 150-watt flood lights? Again, everything was sold for $135. Was more than $50 paid for 14 light gel frames? It was all included in the $135. Was more than $50 paid for eight gel paper sheets? Same price, $135. Was more than $50 paid for two leather bags? I don't recall two leather bags. Was more than $50 paid for one Boss MA15A powered spot monitor, serial number 551423? MS. LANGFIELD: Do you know which -- I'll object. I think it's vague, and I don't think he knows which piece you�re talking about. Perhaps you can point it out. MR. POIRIER: It's identi£ied pursuant to your discovery as that item, so I'm going to leave CAPTION MINNESOTA, INC. (612) 322-2113 ��,� _ Page 42 1 2 4 5 A. 6 Q. 7 8 9 10 11 Q. 12 A. 13 14 Q. 15 A. 16 Q. 17 18 A. 19 Q. 20 21 A. 22 Q. 23 A. 24 Q. 25 A. the description as that. BY MR. POIRIER: ,� --- -- ------------__---- -- ----- -- Do you know what I'm talking about or not talking about? No. Do you know if you even sold such a thing? MS. LANGFIELD: And, for the record, you're talking about a Boss powered spot monitor? THE WITNESS: Yes. BY MR. POIRIER: MA15A. Yes, that's -- that's the little box. Yeah, that was sold. That's the little box. And was more than $50 paid for that item? It was included in the $135. Was more than $5o paid for one Ibanez IFC foot controller, serial number 300154? What is it? One Ibanez IFC £oot controller, serial number 300154. Yeah, that was $135. What amount o£ money was paid for that item? That was included in the $135. Was there anything separately paid for that item? There was no items separately paid for. CAPfiZON MINNESOTA, INC. (612) 322-2113 1 I Q . okay . 2 mounts? 4 Q. 5 6 A. 7 Q. 8 9 A. 10 Q. il 12 A. 13 Q. 14 15 A. 16 Q. 17 18 A. 19 Q. 20 21 A. 22 Q. 23 A. 24 Q. 25 A. n i, _ Page 43 Was more than $50 paid for two Knight slide What are thep? Two Knight slide mounts. Do you even know what two Knight slide mounts are? No. Was more than $50 paid for two 50-foot speaker cables? It's included in the price, $135. Was any separate consideration paid for those items? No. Was more than $50 paid for three 100-foot extension cords? That was all in the price, $135. Was any separate consideration paid for those items? No. Was more than $50 paid for four 8-foot extension cords? All included in the price, $135. Was any separate consideration paid for that? No. Was more than $50 paid for three cord totes? Same price, 135 bucks. CAPTION MINNESOTA, INC. (612) 322-2113 � � �' . Page 44 1 Q. Was there any separate consideration paid for that? 2 A. No. 4 A. 5 Q. 6 A. 7 Q. 8 9 A. 10 Q. 11 12 A. 13 Q. 14 A. 15 Q. 16 17 A. 18 Q. 19 20 A. 21 Q. 22 A. 23 Q. 24 25 A. -- - - ----- — ---=- -- - Do yon admit or deny selling one microphone stand? What was the question? Do you admit or deny selling one microphone stand? Deny it. Do you admit or deny selling one microphone stand with telescopic boom? Deny. Do you admit or deny selling four 25-foot speaker cables? Deny it. Do you admit or deny selling one side music stand? Deny. Do you admit or deny selling one Panasonic cassette tape recorder? Deny. Do you admit or deny selling one Rapco AB 100 switch? What was it? One Rapco AB switch. Not sure. Do you admit or deny selling two Sunn floor monitors? Deny. CAPTION MINNESOTA, INC. (612) 322-2113 1 I Q. I 2 { A. 4 5 A. 6 Q. 7 A. 8 Q. 9 A. 10 Q. 11 A. 12 Q. 13 A. 14 15 16 Q. 17 A. 18 Q. 19 20 A. 21 Q. 22 23 A. 24 Q. 25 A. n � _ - � - �. Page 45 Do you admit or deny selling one red storage box? Deny. -- --- ---- -- - -- ---- —_-- - - — -- -� -- - Do you admit or deny selling one Boss PSA 120 adapter? What is it? One Boss PSA 120 adapter? I don't remember. I don't think so. Is that a yes or a no? No. Did you see it there? I-- I don't know. I don't know what it is. Would you know one if you saw one? Put it this way, if I was showed what you were talking about, I would recall it. I would know if it was there or not. You got a picture of it? Do you admit or deny selling two guitar stands? Deny. Do you admit or deny selling one Cruzin' sign with case? Deny. Do you admit or deny selling one cord bag with 47 miscellaneous cords and adapters? I believe that was there, yep. And how many adapters were in the bag? I'm not sure. . CAPTION MINNESOTA, INC. (612) 322-2113 � J „ 1 � � . Paqe 46 1 � Q. 2 A. 4 A. 5 Q. 6 A. 7 Q. 8 A. 9 4. 1� A. il 12 13 Q. 14 A. 15 Q. 16 A. 17 Q. 18 A. 19 Q. 20 A. 21 Q. 22 A. 23 Q. 24 A. 25 Q. Did you count them? No. ---------------�—..�---- ---- --- Do you know if there were 47? I can't say. Do you know if there were 25? No. I can't say how many were in there. Do you know if there were 11? I do not have an exact number. What does a miscellaneous cord look like? Oh, a miscellaneous cord, I suppose it could be anything from extension cords to outlets. I don't know if -- Do you know if any are called miscellaneous? Could be. You don't know? 2 Teally don't know. Do you admit or deny selling two surge suppressors? Surge what? Surge suppressors. i I'm not sure what those are. Do you admit or deny selling nine guitar cords? Deny. Do you admit or deny selling two mike clips? Deny. Do you admit or deny selling drumsticks? CAPTION MINNESOTA, INC. (612) 322-2113 ^ / � � � � ' Page 47 1 A. 2 4. 4 A. 5 Q. 6 A. 7 Q. 8 9 A. 10 Q. 11 12 A. 13 Q. 14 A. 15 Q. 16 A. 17 Q. 18 19 A. 20 Q. 21 A. 22 Q. 23 24 A. 25 Q. Deny. Do you admit or deny selling Pour XLR ' ------.— --- -- - -----_- _ . - -- - --- �ransformers? I'm not sure what those are. Do you admit or deny selling one outlet adapter? Admit. Was more than $50 given in consideration of that item? There was no consideration given for no items. Was there any separate consideration given for the outlet adapter? No. Do you admit or deny selling one red hand truck? Deny. Do you admit or deny selling one silver hand truck? Deny. Was more than $50 given in consideration for one briefcase with -- for light consoles? No consideration was given. Was any separate consideration given? No. Do you admit or deny selling two 6-foot extension cords? That could have been in the miscellaneous. You don't know? CAPTI013 MINNESO`PA, II3C. (612) 322-2113 1 � �1 / . � � r 1 2 _ -- � - - -3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 48 A. Not specifically on no 6-foot cords, no. I really didn't take time to measure each and every cord ----- — ---- _ -- - --- --- - - — -- - - _. . �Tiat oame with this. Q. Do you admit or deny selling one 20-foot headphone extension cord? A. I-- I really don't even know. Q. Do you admit or deny selling three miscellaneous cables? A. What kind of cables? How long were these? Q. That would be a very qood question. I don't have the answer for you. The item is described as three miscellaneous cables. Do you have any specific knowledge of three miscellaneous cables? A. I-- I guess I don't -- I don't know. I mean, I know there was cables there. Q. Do you recall having any separate consideration paid for three miscellaneous cables? A. No. Q. Do you admit or deny selling one extra knob for Knight TD-40 and Knight TD-30 stands? A. No. Q. No. Do you deny that you sold that? A. Yeah. I don't recall them. Q. So you're denying it? A. Yes. CAPTION MINNESOTA, INC. (612) 322-2113 1 2 _ _- __ 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 > � . � � Page 49 Q. Okay. Do you admit or deny selling one power strip? - -- -- ;, .- _ --__ _ - ___ __, _----- _ — - -- ------�.. �A: " S Q. Was more than $50 paid for that item? A. It was included in the $135. Q. Was there any separate consideration given for that item? A. No. Q. With reference to one black striped bag, is that the same bag as you previously described as containing some but maybe not 47 miscellaneous cords and adapters? A. Yes. Q. Was the only money exchanqed here for the purchase of the items you've admitted to a check for $135? A. Yes. Q. And that check came from Aabe's Music? A. Yes. Q. There was no cash taken out of the till to pay for any additional items? A. No. Q. You've made reference to the two gentlemen who were with you on April 19th when you went to the store. For purposes of identifying these gentlemen, let me reference them as unidentified male with beard and CAPTION MINNESOTA, INC. (612) 322-2113 , �^ � " _ Page 50 1 unidentified male without beard. Would that be 2 fairly accurate? --- - ---_------ ------ — :- - _, _ , - -- _,_, _ _-_- . — =-- - - = _ 3 A. Sure. 4 Q. Okay. Who drove the vehicle? 5 A. The one with the beard. 6 Q. Had you had any contact on any jab with 7 unidentified male with a beard from your employment 8 - at Atlas Temporaries? 9 A. No. 10 Q. How long were you employed at Atlas Temporaries? 11 A. I worked there one time. 12 Q. And what was the date of that employment? 13 A. I'm not even sure. 14 Q. What month was that employment? 15 A. Would have been April. 16 Q. You worked one day during the month of April of 17 1995? 18 A. Yep. , 19 Q. And in that one day you met unidentified male with 20 beard and unidentified male without beard? 21 A. Yes. 22 Q. And your circumstances of ineeting them on that one 23 day were on the job or in the lobby? 24 A. In the lobby. 25 Q. When you're in the lobby, is that prior to going to CAPTION MIIdI3ESOTA, INC. (612) 322-2113 ��,_� Page 51 1 2 - -3 = 4 5 6 7 8 9 10 li 12 13 14 15 16 17 18 19 20 21 22 23 24 25 work or upon returning? A. It was prior to. ---_ _. __ . _ _- - ---,.__ . --- _�-__ ----- - -- Q. What time did yoti arrive? A. It was in the evening sometime. Q. And how much time did you spend with unidentified male with beard and the one without? A. Twenty minutes, maybe. Q. And the next time you ran into these two gentlemen was when? A. On the 19th of April. Q. How did they find you? A. I don't know if they were specifically looking for me. Q. How did they -- how did you meet up with them on the 19th? A. I was sitting at Atlas waiting to see if any jobs turned up, and they pulled up and came in. Q. You hadn't been to Atlas Temporaries since sometime in April of 1995; is that correct? A. Correct. Q. You met those two men at Atlas Temporaries at -- in the evening of whatever day it was in Apri1 of 1995? A. Yep. Q. And you hadn't been back there; then you go CAPTION MINNESOTA, INC. (612) 322-2113 � v _ e � ` -� _ Page 52 1 2 _ .._ __ ' 3 4 5 6 7 8 9 10 il 12 ' 13 14 15 16 17 18 19 20 21 22 23 24 25 back there on April 19th and just coincidentally unidentified male with the beard - - ... : _.. __, . _ _ _ , ..-_-- ..__ ._.._ _ . ... . _ ___ .. .---- -----.. - - - - - � - - � - - --- - ---- � --- -- - - and unidentified male without the beard coincidentally show up at the same time; is that your story? A. That's it. Q. Is Joanna Rodriguez still your girlfriend? A. Yep. Q. At first you weren't sure whether or not she had contacted anyone at Aabe's regarding this incident, and slowly you came around and said that you do believe that she contacted Eric at Aabe's, and not only that, you also know that she wanted to talk to Eric about his identi£ication o£ you. Is that pretty much your story? MS. LANGFIELD: I'll object as misstating prior testimony. And you go ahead and answer pending what the judge says. THE WITNESS: She wanted to talk to Eric about him backing out of his word, what his word was to -- that if the police were to get involved in this matter with him -- with the stolen merchandise at his store, that I did not se11 the stuff to him, that these people that sold it used my I.D. �a CAPTION MINNESOTA, INC. (612) 322-2113 ; d r_, ._ -� , _ Page 53 1 2 — � - — 3 4 5 6 7 8 9 10 il 12 � 13 14 15 16 17 18 19 20 21 22 23 24 25 Q• A. 4• A. Q• A. Q• A. Q• A. Q• A. Q• A. Q- I� Q A BY MR. POIRIER: Did you instruct Joanna Rodriguez to call? _ __.. _.__._ � -- "�._._ I don't instruct my girl to do anything. Did she ever tell you that she called Eric at the store and said to Eric that they�re going to bring Aabe's down if they ever fingered you? Excuse me? Could you repeat that. Did she ever tell you that she called Eric at the store and threatened that Aabe's would be harmed if any testimony was given against you in this matter? I don't recall that. You don't recall or it didn't happen? No, she never told me nothing like that. She never told you that. What's her address? I'm not going to give that address out. Do you know what it is? Yes, absolutely. I live there. Did you live there in April of 1995? No, I did not. When was the last time that you resided at that address? I've never resided at her address. I will be residing at that address when I get out of here. Is she in the phone book? Nope. CAPTION MINNESOTA, INC. (612) 322-2113 1 2 _ _ 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 r ' " .. � ` Page 54 Q. Are you saying that this number is unlisted? A. Yes, I am saying that. -_,.._ _ _ _ _-:,___. _,._._. . .._-__ - - - - -__ -- Q. Do you have some problem with me contacting Joanna Rodriguez? A. I really don't want to involve my fiancee in this matter. This is not her matter. Q. Is there some problem? A. Yeah. Q. And that problem is what? A. That I don't want you to contact my fiancee and involve her in this matter. She is not a part of this matter. No where in these complaints, these police forms, these records or so on and so Porth is her -- does she have any involvement. She wasn't arrested for anything on this, She has no knowledge of this, other than the fact that I was in jail and -- and Eric pulled a bogus move. That's a11. Q. Eric pulled a bogus move? A. Absolutely. He tried to, as far as 2'm concerned, extort me out of $500. Q. T'll get to that in a minute, Mr. Kies. Would Joanna Rodriguez support or not support your story that she called Aabe's Music to tell Eric about -- that he should back you up on this? CAPTION MINNESOTA, INC. (612) 322-2113 , ,� . � _ Page 55 1 MS. LANGFIELD: I'll object as 2 speculation, but answer to the best of your -- 3 ability. ----- --- 4 5 6 7 8 9 Q. 10 11 A. 12 13 14 15 16 Q. 17 18 A. 19 Q. 20 21 A. 22 Q. 23 A. 24 Q. 25 A. THE WITNESS: I don't believe it's about backing up. I think it was that she had called him to not back me up but to keep his word on something that he said. BY MR. POIRIER: What's the problem contacting her if that's the story she's going to give? Like I said, there's no problem. I just -- I'm not going to involve my -- this is my family I'm talking about. This is my fiancee-to-be family, and I'm not going to involve my family in this type oP stufE, period. Did she tell you that she had a tape of that conversation? No. She didn't tell you or there is no tape, to your knowledge? She di@n't tell me. Is Joanna Rodriguez your only girlfriend? Absolutely. Has she ever been in Aabe's be£ore? No. CAPTION MINNESOTA, INC. (612) 322-2113 r� r 1 2 3 4 5 6 7 8 9 10 11 12 " 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 56 Q. Did you identify Eric Swenson to her as the person who you dealt with? - - - - -- - - — - -- - - A. I don't know if I did or not. Q. You may not have? A. I may not have. Q. Do you have a guess as to how she would come to know to call Eric Swenson and tell him to back you up? A. Probably because Eric was calling my residence at that time, which was with my 9o-year-old grandmother, and left three messages with my grandmother with his name and his teZephone number at Aabe's stressing my grandmother to have me call. Q. Why did Eric want to talk to you? A. So he could get his $135 back. Q. What $135 back? A. The $135 that he said he lost out on because the police took the stuff out of his store. Q. Eric lost $135? A. That's what he claimed. q. And when were these calls made? A. They were made somewhere towards the very end of April. Q. What's your grandmother's name? A. I'm not going to involve my grandmother in this. CAPTION MINNESOTA, INC. (612) 322-2113 ♦ � d i � � � Page 57 1 My grandmother is 91 years old and in a wheelchair, 2 and we ain't even getting into that. --- - - - --- ---_ -- °_ _ - 3 Q. Was she at the address that you were picked up at? 4 A. I wasn't picked up at an address. 5 Q. Is your grandmother's last name Kies? 6 A. No, it is not. 7 Q. Is there some reason you would hide information 8 about your grandmother? 9 A. My grandmother is 91 years old. I'm -- is isn't a 10 matter of hiding. My grandmother is 91 years old. 11 Let's get something straight here. My 12 grandmother is 91 years old, in a wheelchair, and 13 ill, and ain't nobody going to go there and stress 14 my grandmother and question her. I mean, hey, 15 that -- you might not even want to deal with my 16 grandmother personally. My grandmother is, you 17 know, not somethinq that -- that somebody needs to 18 go and bother with something that's not her 19 business. 20 I lived there at the time. That's the phone 21 number she had. You want the address? Here's the 22 address right there (indicating). 23 Q. Mr. Kies, let me finish. As £ar as we can 24 determine so far -- 25 A. I don't want anybody going and bugging my CAPTION MINNESOTA, INC. (612) 322-2113 ; � ". Page 58 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 grandmother. Q. Mr. Kies, the court reporter can only take one of - - - --- - - - - =-- -- — -_ - --- us at a time. A. So maybe you should listen to what I'm saying. Q. I'm here to ask the questions. A. I'm asking my concerns of my grandmother that you don't ask her. Q. Your answer is nonresponsive, in tny mind. As £ar as I'm able to determine, Mr. Kies, and tell me if you think I'm wrong, we've got unidentified male with a beard, that you don't know who he is, who would support you if we could find him. You have an unidentiPied male without a beard who would support you if we could find him. You have a girlfriend who would back you up, but we can't contact her because she can't be involved, and you've got your grandmother who we can't contact because you don't want her involved. Is that correct, Mr. Kies? A. Sure. That's correct. Yeah, if I could £ind them people, I wouldn't be here today. Q. Now, Mr. Kies, you went back to the store -- I believe your testimony is the day after you sold the items to Aabe's Music, correct? A. Yep. CAPTION MINNESOTA, INC. (612) 322-2113 " .� - Page 59 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Early in the morning? A. Yep. ,_ „_ _.. . . , ...: -- �-= - --------- - — ---_ ---- — Q. Okay. You went in the store, you tried to get the equipment back, right? A. Yep. Q. Aow much equipment did you carry back out of the store? A. None. Q. No sale was made? A. When I went back to try to buy it back? Q. The second time. A. No sale was made. Q. No sale was made. When you went in the second time and you told Eric that the equipment was stolen, did you furnish Eric with any proof that the equipment was stolen? A. No. Q. Did you tell him that you had been personally involved in any theft of those goods? A. No. Q. When you spoke to the owner of the store, did you tell him that you had been personally involved in the theft of any items? A. No. Q. Did you tell either Eric or the owner of the store CAPTION MINNESOTA, INC. (612) 322-2113 �� , 1 2 3 4 5 6 7 8 9 10 il 12 13 14 15 16 17 18 19 20 21 � 2 2 I I, i 23 ' 24 25 Page 60 that you had personal knowledge regarding how a theft occurred of those items? A. No. ----- - - Q. Mr. Kies, have you ever played in a band before? A. Not with a steady band, no. Q. You play drums? A. Yes. Q. When did you first begin playing drums? A. About 4 years old. Q. How did you acquire the £irst set of drums? A. My mother. Q. Did you play it through your high school years? A. Yep. Q. Did you ever play with any bands? A. Just a few that we had put together ourselves. Q. Did you ever play after high school? A. Oh, off and on. Q. Did you play for bands, or was this just something you did on your own? A. Oh, pretty much just -- just on iay own. Q. Were you ever a£ill-in musician for any band? A. I've sat in with all kinds of bands. Q. Did you ever do any recording? A. Recording? Q. Uh-huh. CAPTION MINNESOTA, INC. (612) 322-2113 � i ' C �� Page 61 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No. Q. Or was it more weddings and special-occasions-type - - —,_ things? — — — I I A. Bars. Q. Bars. Did you ever do any setting up of equipment � with the bands? A. Nope. Q. Did you ever set up your own drums? A. Yes. Q. But you would never do anything else with other equipment? A. Never. Q. Did you ever acquire any special knowledge regarding band equipment other than drums? A. No, sir. Q. So that when you tell me you're not sure what something is, is that because you don't have that expertise in band equipment? A. Absolutely, yes. Q. How many bands would you say you filled in with? A. Oh, filled in with or just played with, sat in with, what? Q. How many have you filled in with on an occasion where you're playing in a bar? A. Oh, 50. CAPTION MINNESOTA, INC. (612) 322-2113 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 I i � I 18 I ' 19 20 21 22 23 24 25 c;�_ � " Page 62 Q. How would that work? Somebody would call you up and say come on down, we need a drummer? - °-------_��--- -- -- --- - - -- - _---- A. Most of these were open jams. All musicians from alI over come together. They happen a21 over the Twin Cities. You got one at Whiskey Junction on Monday nights, one in St. Paul on Payne Avenue on Wednesday nights, one at Garrity's Sunday nights. Q. Let's say that you played for 50 different engagements. Out oP those 50, how many times would you walk in the door and the equipment would be all set up Por the band? A. Always. Q. You would never come until the equipment was set up? A. Right. Q. Who would -- who would set up any microphone equipment for your drums? A. Small places like that, you don't need microphones for the drums. If you used any at all it would be maybe one microphone in the base, laaybe one for the high hat. Other than that, you don't need any -- Q. Who set that up? A. Usually whoever owned the set, whose ever drums they were. Q. You didn't have your own set of drums? CAPTION MINNESOTA, INC. (622] 322-2123 ��-_ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 29 2F Page 63 A. I've had sets of£ and on, but I've never carried my set to a-- to a bar or to a gig other than when I --- --- --- ------ had my own drums and was playing in my own little band. Q. Mr. Kies, what happened to the charge that the Ramsey County attorney's office had against you for receiving stolen property in this matter? A. What happened to the charge of what? Q. Well, I assume you're in here Por receiving stolen property, but you're not admitting to the offense. What happened to it? A. Listen. I'm in here for receiving stolen property. That right there is -- is admitting to the offense. Receiving is possessing, buying, selling, having contact with. Q. Are you serving one day in jail because of this offense? A. Because o£ this offense? Q. That's correct. A. I'm serving 28 months. Q. Because of this o£fense? A. Absolutely. Q. Does that make you angry? A. No, it really didn't make me angry, you know, because I got myself in this jam. I guess what CAPTION MINNESOTA, INC. (612) 322-2113 ^ r ` �, �� z -- -- -� 3 4 5 6 7 8 9 10 11 I 12 i 13 II 14 I 15 16 17 18 19 20 21 22 23 24 25 Page 64 � makes me angry is that -- that I was, you know, s.tu�id...,enough to use my I.D. Por some crap like - -- -----�- --- - — - - --- - -- this again. That's -- Q. Did you -- were you finished? A. Yeah. Q. Did you plead guilty to this offense? A. Yes. Q. Who was your attorney? A. Joy Bartscher. Q. Joe or Joy? A. Yes. Joy, J-O-Y. Q. And that last name is Bartscher, B-A-R-C-H-E-R [sic]? A. Sounds good. Q. Is she private or with the public -- A. She's with the Neighborhood Justice. Q. Mr. Kies, I don't practice much criminal law, but as I understand it that when someone enters a p2ea of guilty they have to admit a factual basis for the offense. A. What is it that you're getting at? Q. Did you stand in front of the court and tell the court that you took stolen property that you knew ' to be stolen? � Did I stand in front of the court and tell them CAPTION MINNESOTA, INC. (612) 322-2113 , _, �, � _ Page 65 1 2 3 4 5 6 7 8 9 lo 11 �' 12 ', 13 14 is 16 17 18 19 20 21 22 23 24 25 that? Yeah. --- - -_-- Q. And were�nfr sa_h,en_ told the court that? - --- ---=__- _—__�_._�� A. No. Q. You weren't truthful; you lied to put yourself in prison? Is that what you're saying here? A. Yeah, right. Right. Q. Are you saying that you�re serving 28 months in Stillwater because yau lied to put yourself in here? A. I'm sayinq this: They came to me with a plea bargain of 28 months. I had a choice. Accept the 28 months, take it to a trial. With a record like you just read off, me at a trial, I'm going to get probably convicted. Convicted of a trial I'm looking at 60 months, maybe up to 120 months. I'il take the 28 months and do my time. Q. At the time you admitted that you had received stolen property, did you make any claim that you were i.nnocent? A. No. � MR. POIRIER: No further questions. FURTHER EXAMINATION BY MS. LANGFIELD: Mr. Kies, I just have a couple of follow-up. In the canversations that you had with the t*.� CAPTION MINNESOTA, INC. (612) 322-2113 �- � _ _.. 1 3 4 5 6 7 8 9 10 zr 12 13 14 l 15 I ' 16 i� 18 19 20 21 22 23 24 25 Page 66 unidentiPied gentlemen that sold the property with _ yo`u`"nr �ny- ea�-uez._sat_ions that you overheard them have, did it become apparent to you that they were musicians or involved with music in any way? A. No. What I was under the assumption, that one of them had a brother that was a musician. Q. Okay. And what lead you to that assumption? A. The -- the -- the fact that they were laughinq and carrying on about takinq this equipment from their brother. Q. okay. But to your knowledge -- and you don't recall any conversations that these two -- either one of these two gentlemen were musicians? A. No. Q. Okay. On a lot of questions about these cords that appear in exhibit -- Kies Exhibit 5, if you take a look at that, was that -- are those that appear in Exhibit 5, are those the cords that you sold? A. Yeah. Q. Okay. Do you know if there were any more cords or -- that look like it or -- A. Yeah, 2-- I mean, it's hard to say. I mean, that looks pretty good right there. Q. Okay. A. I mean, you got a-- a whole bundle right -- I CAPTION MINNESOTA, INC. (612) 322-2113 ;� 1 2 3 4 5 6 7 8 i 9 �� 10 ' 11 12 ' 13 14 15 26 z� 18 19 20 21 22 23 24 25 Page 67 mean, it's hard to tell what's even in that clump _- .. __ _ righ� _�Tr�re f i-��-cating) ---- _ --_ - _- -------_ _-_ Q. Okay. Wheri -- when you -- A. -- you know. Q. okay. When you and the unidentified -- the other two guys were in the store, how long did the sale of all this equipment take? How long was that in time? A. Forty minutes, maybe forty-five. Q. Okay. So in that 45 minutes, that's the time that you had to see this equipment? A. Right. Q. Okay. And a couple of questions about being convicted Por this offense. When you were convicted for this offense, how -- or why did you plead guiZty to receiving stolen property? Was it ever in your possession, or how does it -- how does it work there? A. That's what I was charged with. Q. Okay. A. They -- they didn't want to negotiate with nothing else. Just charge me with receiving. That's it. They didn't want to come down off of that. They � didn't want to make it a lesser charge. They � ! couldn't make it a greater charge. That was it. CAPTION MINNESOTA, INC. (612) 322-2113 � ; �. ' Page 68 1 — - --- - 2- 3 4 5 6 7 S 9 10 11 i a �� is I I 14 ��' 15 16 17 18 19 20 21 22 23 24 25 That's what they charged me with. _ _. Q_ '-i�F�s-t�__p�opext_y. ever in your possession? I mean, - -------- ----- — did you ever have -- did you ever call it yours, or was it your property? A. No. I-- these people had it already loaded in the truck when they approached me. I jumped in their truck. I showed them where Aabe's was. We got out. We ali three went in. Dude without the beard talked to Eric. We all four went out. He looked at it, told them to bring it in. The only possession I had was to help carry some of this stuff in there. That was it. Q. Okay. A. They set it up, they showed him how it worked. It never got carried back out. Z touched it -- a few things, not all of it, just a few things, just to carry it in the door. That was it. Q. A couple of questions about Atlas Temporaries. Is that at all located near a pawnbroker store, nearby, or is it near a pawnbrokers? A. I wonld imagine there's some pawnshop. It's right downtown St. Paul. Q. Okay. Do you know if it's located right next door to National Pawnbrokers? A. No, I don't know. CAPTION MINNESOTA, INC. (612) 322-2113 _ -� Page 69 1 3 4 5 6 7 I 8 I 9 �, 10 ' 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. Did -- �. 3 it�o-yr,.-th_ere',s pawnshops downtown. --- -- ----- Q. Okay. Did these two unidentified gentlemen or guys that you sold the equipment with, did they ever say or ever mention that they had tried to sell it somewhere else? A. Yes. Yes. Q. Okay. Do you remember -- can you tell me more about that conversation. MR. POIRIER: I'm going to object to this as hearsay. THE WITNESS: They -- they said they ha@ tried to sell it at other pawnshops. The pawnshops were telling them that -- that they couldn't sell items like that fast enough and that something like that would -- would be left in their store for too long of a period of time and take up too much space. BY MS. LANGFIELD: Q. Okay. A. We stopped at another pawnshop. Q. Okay. Do you recall which one? A. No, I don't. It's just -- it's on the same side on University as Aabe's, and it's -- it's not too far. CAPTION MINNESOTA, INC. (612) 322-2113 Page 70 1 _- __. . _ ... . _ -- 2 _ 3 4 5 6 7 8 9 10 11 12 13 14 ; 15 I �� 16 17 28 19 20 21 22 23 24 25 Q A 4 A 4 P C F C F S Closer to St. Paul? ....___ Yeatr:- - _ _ - ,,... ._,,.__,__. - - --_= -- ------- _._ Okay. Talking a little bit about your qirlfriend - � i Joanna Rodriguez, you qave us a telephone number. Do you at all object to the City of St. Paul, that being me or Mr. Pangborn here, contacting her to ask her to come in an@ testify regarding her conversation with Eric? . I-- I don't want my family -- my £iancee, my grandmother, my people involved. I don't want to involve my people in this. Can we relate a little bit more about Eric -- you said in your -- Mr. Poirier's examination, you said that Eric had left some calls or messages at your grandmother's residence, and your grandmother told you what regarding those calls? . My grandmother just basically told me that this guy keeps calling. Call him so that he stops calling. Okay. And did she tell you about what Eric said to her or -- . No, she did not. Did you call Eric back after you got the messaqes from your grandmother? . Yes, I did. . Okay. And what was that conversation about? CAPTION MINNESOTA, INC. (612) 322-2113 , . � .� Page 71 1 A. That conversation was that Eric wanted his $135 3 4 5 6 7 8 9 10 11 I 12 � 13 I ! i 14 ' 15 16 17 18 19 20 21 22 23 24 25 - ba�3�-- �hat,,,.he,_ga_ye out for the property, otherwise -_,_ i _.__. _,____ �___________ he was going to take charqes against me. --- '1 Q. Okay. So Eric demanded $135 from you or he was ' going to charge you with something or -- A. Yeah. He was going to take me to court on it is what I gathered. Q. Okay. Do you recall his specific words or -- A. I'm trying to think. I believe he said to avoid us filing charges against you. Q. Okay. Your grandmother, her address appears on the Pawn/BUy Form? A. Yes. Q. And that's your grandmother's address on Geranium Street? A. Yes. Q. Is that also her phone number that appears there? A. 9712, yep. MS. LANGFZELD: Okay. Those are all the questions I have for you. FURTHER EXAMINATION BY MR. POIRIER: Q. Mr. Kies, do you know if the Ramsey County attorney's office has charged out anyone else regarding the theft of this property or the receip� CAPTION MINNESOTA, INC. (612) 322-2213 l '\ �. Page 72 of stolen property for it? A. No. _, _.. ,.. - - Q. Do you know a Mr. George Moschkau? A. No. Q. Do you know a Donna Moschkau? A. No. S2. Are you serving any time here today as a result of a burglary over at 1799 East Minnehaha? A. No. 1 2 '3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2� 21 22 23 24 25 Q• A. Q• Q• A. M5. LANGFIELD: I'll object as asked and answered. Go ahead and answer again. THE WITNESS: No, sir. BY MR. POIRIER: You're not? No, sir. Mr. Kies, is the only reason you're serving time out here today is because of Eric Swenson? M5. LANGFIELD: I�11 object as speculation. You can go ahead and answer, the best of your ability. THE WITNESS: Y�m serving time out here today for receiving stolen goods. BY MR. PQIRIER: And you're guilty of that offense? (Witness nods head.) CAPTIOI3 MINI3ESOTA, INC. (612) 322-2113 . � -� _ ` _ Page 73 4 5 6 7 8 9 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. You have to answer verbally. A. Yes. _ -- — -�_ - �°- __ � - -- � _ _ ____ .._- — - MR. POIRIER: I have no further questions. MS. LANGFIELD: Mr. Kies, I have no questions for you, but I have -- I need to advise you that you have a right to read this transcript once it's been transcribed into a booklet form, and I'm going to ask Nancy expeditiously to prepare this because we have a hearing in this matter on Thursday. You can tell the court reporter at this time that you want to read or not -- that you�re not going to read, but you need to advise her, and if you want to read, we will make arrangements for that reading. So what -- what it is is you just read the transcript and say, yes, that�s what I said or, no, that's not what I said. You have to tell her. THE WITNESS: Yeah. MS. LANGFIELD: So would you want to read it or not read it? THE WITNESS: Yes. MS. LANGFIELD: Yes, read it. (REPORTER'S NOTE: Deposition Exhibits 2 through 6 were kept in the possession of Gail CAPTION MINNESOTA, INC. (612) 322-2113 CAPTION MSNNESOTA, INC. (612) 322-2113 � - �. Page 75 � r 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 STATE OF MINNESOTA ) COIINTY OF ) ___ -- - - =_ _ -- - =- __ -._ _ 2, RONALD KIES, certify that I have read and examined the typewritten transcript taken of ine in the case of the matter of all licenses held by Josha Corporation on November 7, 1995, consisting of the preceding 74 pages, and find the same to be true and correct. (Except as follows): P aae Line Correction Reason Dated this day of , 1995 RONALD KIES CAPTION FIINPiE50TA, INC. (612) 322-2113 . . -, _. Paqe 76 1 2 __ _ - - ° 3 4 5 6 7 8 9 lo 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 STATE OF MINNESOTA ) . SS CERTIFICATE COUNTY OF DAKOTA ) ____ _ __-_- I, Nancy J. Meyer, Registered Professional Reporter, a Notary Public in and Por the County of Dakota, State of Minnesota, certify that the foregoing is a true record of the deposition of RONALD KIES, who was first duly sworn by me; having been taken on November 7, 1995, at the Minnesota Correctional Facility, Bayport, Minnesota, in my presence and reduced to writing in accordanoe with my stenograph notes made at said time and place; I further certify that I am not a relative or employee or attorney or counsel of any of the parties or a relative or employee of such attorney or counsel; That I am not financially interested in the action and have no contract with the parties, attornays, or persons with an interest in the action that affects or has a substantial tendency to affect my impartiality; That all parties who ordered copies have been charged at the same rate for such copies; That the right to read and sign the deposition by the witness was not waived; IN WITNESS WHEREOF, I have hereunto set my hand and affixed my seal of ofPice at Apple Valley, Minnesota, this 7th day of November, 1995. ----------------------------- NANCY J. MEYER Registered Professional Reporter Notary Public Dakota County, Minnesota CAPTION MINNESOTA, INC. (612) 322-2113 •. n <-?G� ]�a- 'b1 •8�? €b � i€� � � Qedi� 1�Atrs tiLS�.�, -�-� +�: : b9: £ 43fp;fttt f}¢ � . ' �fl.t �•7 • � _ -_-__ : _'"'___ - _ '.-.- _ _ - _ - —�= t�'f9+EG dFi x-� E75 h ,�;21111K � YZ � � � ( - .. f • ��- -- -- _ . , � . . .� - - - . .. . , f a . :. -",� F. ia " i �+°�"��,�,�+s,� ---..�.. PAWNJgilY �ORM z� X•H;, T ,. _ � y �,�,��, �ri� �`�� 'V ., R. � . _�' - = _ i1�.=_•H:•i ':T PAi_L PCILICE l�PHP.TMEN7 . � � _. E �, _ _ _ ._.____- . __- __„ _ _-. _.. # ' ___ -- ---' 1 � y 5 � — � 3 � 1 • _ !" '`\ i' ...+ . � �� ; 6• �� • + _. 9 .�.'_ � � ^ 3 � � a � — : � !, r �?,� -- � � � _ „ = S � � � g � �— I� : 7 � 7 a W ' ' " � _ t— . � E _ ; _. � �� i, � r* = u —. — :t: : a • _c � i � � � 5 + _ f � r� � 1 � i a � Y � 1 u F. . \ 9 n- _" a �� . " k W __ L0, �.. s i + _ � �- � .v � �C b # l r u � • � f e" � p _ 3 . P + � .� E ' � 1 :1J { ••. t � i ' � � J tr _ � '. c- � 3� _' J+ S i�' �'Y i+ + + .z .. + � ' + I ti � � :; _ t� � � � T . !L � �l S i 9 i ; � s � i a 4 3 3 E � � � a � 3 0 � 1 a P } � _i � � � ,� J� i� , � i ' � ' ! ; :C 9 �.. � � i r. � �A e W Y � - 1 z L � .. � : i � d -�- � _ e� LL D 4 •- z ° 1 �: � :c f "' e - y � ' � _ q �� S .. { r. ' 4— � r • ' � v � � _ � i . _' S —' OFFICE OF THE CITY ATTORNEY TimoBsy E. Mmx, Ciry Attorney SAINS PAUL . • � � Civil Division Norm Co7em<m, Mayor 400 Ciry Hall Telephone: 612 266-8770 IS West Xellogg Blvd Facsimile: 6I2 298-5619 Samt Paul, ilTmnesota 55102 _ _ ,�--------" _ ..__--=.�__ -_ __�,.'".- `' __.--_— __. __- �r+� . _'.�'_" __ October 26, 1995 The Honorable Jane Administrative Law Hamline University 1536 Hewitt Avenue Drew 66 St. Paul MN 55104 McPeak .7udge Graduate School � � ti; � � Re: In the Matter of All Licenses Held by Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe. Dear Judge McPeak: The purpose of this letter is to request an Order under Rule 1400.6900 for the deposition of Ronald Kies, an inmate at the Minnesota Correctional Facility in Stillwater, Minnesota. The key issues in this action are what property was purchased by Aabe's Music Shoppe from Ronald Kies, what property, if any, was sold within the next ten days, and what records were kept by Aabe's Music Shoppe regarding the alleged purchases and sales. Mr. Kies has testimony which is relevant to the matter before you. Kies was convicted of selling the stolen property to Aabes which forms the basis for the present action against Aabe's Music Shoppe. The City wi11 elicit testimony from Kies regarding the items sold to Aabes, the circumstances of the sale, the circumstances and conversations Mr. Ki_es ]2?� �rrinc �h�r..n �,yr�°l;°z• arG �YiC S•rT2ri80i1 after the sale when Mr. Kies returned and tried to buy the property back. The City is requesting you issue an Order for this testimon� by deposition for November 7, 1995 at 12:30 p.m. While the original notice stated the deposition should take place at 9:30 a.m., officials at Stillwater have requested an afternoon setting. I am requesting an Order after serving the Notice of Deposition in the interests of ease of scheduling with the Minnesota Correctional Facility. The Hanorable Jane McPeak Page 2 � > � ,�� Thank you for your time and consideration of this matte _ � , --. > - � ,=_, �.�. - ----- - -- ° °I�ery= � =yo , _ G 1� ld Assistant City Attorney enc. C ' r � .,. . _` , STATE OF MINNESOTA COUNTY OF RAMSEY BEFORE THE COUNCIL OF TE� CITY OF ST. PAUL In Re the Matter of All Licenses held by 7osha Corporaflon d/b/a Aabe' Family Discount CenterlAabe's Music Shoppe for AMENDED NOTICE the premises located at 1933 University OF TAKII�iG DEPOSITION Avenue West, St. Paul, Minnesota -------------------------------------------- Tc: 7osha i c�pozatio�, aad i�s at�o:r.ey, Tu-no�y Po;rier, L,owrey HiIi Law �ffices, I90� Aennepin Avenue South, Minneapolis, Minnesota 55403-3198 PLEASE TAKE NOTICE, that the deposition of RONALD KIES by oral examination will be taken before CAPTION NIINNESOTA, INC., Court Reporters, or any qualafied notary public at the MINNESOTA COI2RECTIONAL FACILITY in the City of Bayport, in the County of Washington, State of Minnesota, on the 7th day of November, at 12:30 dclock p.m., and thereafter by adjournment until the same shall be completed. Dated: C��, /`1�1,5� TIMOTHY E. MARX City Attorney k �� Gail gfield, #1 172 Assistant Ciry Attomey Attorneys for City of Saint Paul 550 City Hall and Court House 15 West Kellogg Boulevazd Saint Paul, Minnesota 55102 (bl2) 266-8770 ��T 1 i - _ ; c �.-. _ � . , ' �ti�-._� , ._ � CZTY" O� S:�I=tiT PAliL :.c,r.:l'viem� :IaJr�r �;v�:i�:..°I ., . -- _ � Thc zoncrabie �a:ie N:cPeax Hdmin:-stra��ve _�cv �udg� t?3i?l:l.^.F' T.iY:2TT°7'S''��V '�.�3CU.�;�2 _'c;d ��' _.�e ��w'_.-' T�.., 5C. �81_, i=liV ..�_:.� r�i2 �'Sc �c_� r.7i Trmry.Hl' . _ ..-z . :r; 9P,ir:^;'�. c�.r:.�+.��, s00 Ge ta%i 1; :J.st:iaCing_�13::d c. �: rn::; ....,.,��.,._ .-.,� � � '-- _,�� - t efa .,. _ _ . . Fac�:m�k' c. -_srn f __' / _ 2 ___ �c'��. � � :a��r'�SX "5i`3I"::ia� .�or.:- %ci' i�.tna5es • �'lJ.� �� ± {�L �/9 [ tc.' , 4-- -- - i--� . C.• Q " . �s a � . �—_ .�"_'_ _"_��--1 ° r`—�' iGept. '�Fhoc� F , �_ �___ _ �.� " _� =a' ` y�-' - �� I � ...,::uU 1 .�`t2: rY `_t'a t1<xC:.�'_' CJ� 8� - �l^6=tSB3 '_i'i?i4' �+V �::.i�f.ct .yCYj542�.'-1'.;ii� (� . T 5i 3�Pg F2,P."=_'_y J1S.u"i::,L �?;f��?Tr R-;:�' a L�.!ll51�. �1:G �:2c.Y .-'�i� jri_i�o_1r_ 'iI7P. CUY'�OSF ^T �R1S �e�'t.a_Y w� tu 1`�5�. �U �ICoP.a ..OT'r �'-'-� 5 MO}1C71: %C' X::.cji, �i ��l$CGV°'�� 311a LVCL=:�u� _.� L'B3`�i:�=.....- - E�3YVev. tU.`1 OC�Cik3�-� _�., ��y�. �'�!"1? �=?-�• SETVflC� �15C�JE,'?.`V �It %a_i 2fi�v2". LQ 1_,._l'� � 2'_i:',a2�3�6 u:-� fr�/�tiJ.3=�1S3U25 �.0 i.hP_ �i@c3Y�12'i��. L'17 Fj7��_ e 1y�3� 'u°O dTl�' �..^.:iJ b;CS.;,`1ko_u iv�l"E' V1CLii�!5 c+T' ��iiig'_a5:j' ir v.:1C+ �tC�Z2 '�Ilat 4U ].�=:-.:_ __ "�us_Ca3 ea�ia�en� has suo�er�. '_''r�e u� ecuverY �s�� url =fior� _.. _ . � down or e� �mi_.ate thosP - ,.tem� as v.; wl�ich �ne , S r_c dis�t._-. n., effor-t ta str.eaT.��t�e �=,- '_neYrirg p�n�ess. T?^_e __ ��i 'r,ac reci.r.:is t� tha NGSC."�'r,au` s zegard`:.: ; :_e _Le,^s s:��ie�. The �itv .��so ?has records fro�<< �':�e N`vli�e r�garu'_ .,..z� `, ens �;=r� r�co4�er�LL fYv�r. � al��' s`!ue�.. w: �p�� . �=^ai�, �� "?c a nr c'?.W?1i�� - 7ti� . � i"^ ... G"_rr'. 1T1QiC3t`.E° Wt`:v _�2?^S :�aN�`� c___ - -:._.4 =C ��'CJ"' FC_`_�i':. .-iv5 uPG �4rG t:;3id?3=�'�-'�c: �L '_ -` � 'r c ,:� - :.f r e .r� �e`�ci1 L? =-, _ ,_..l _� > o'1�d L�e nCr.. -.._... _.._ .� 4hese 1.�'4J�c<<.. Yia ._ .a•:5i_a 'i.`C:�' ...'?-,.� _. Tl-..E• ri � t' _ c _-, _'' " St?'_ :�� .c OY t:�Sti�'�1Gi:.31 �@C4�Yuc^. '`'t a +'-L- � �- v- -" hd",sce, _rtj !%i '_t-�:iP_1 J�S:1� COIJOf?w4=u_i. !:ri"_c-, - -:7:_ �i`![? �.i;�M'SS'�_..::a Ta�;�.+�3t i0Y �:P'�u.:[i�ni-S _�:�<� "�GS1T -_ �_ ..._�_._� - �-: "L ?P `v �iu]" '_� - .i�ti.e a 4vi: �- r.ii� iC .�C-.-.__��.. _., _ .-� .i�aYe. .. ,�:`.`c.:t^v_ _ , -�Ju- � . u. �4 ..e�� .�1�� ^ ~• . '�'��1� �.�lll� 7�. _-v�i�i�l - -' _�.._� .l. rrivl.'�.��?';Ri�^._.�_ �"t c�rL'?... :..nC f<_c�..il.i�� _•-- �F=C.._�.._�- _ �f ;Pi":'lU`...1-I,. �-. E31T,�11� ai7Q C��'�1p� r�?�� _�Sll°5"_. 8� .1 F�f.3.� DI y 'v.'og b01.'.'�'!?t'�. 2?:'_, ,_ .`"-,f_`.if� �y .�,.c17}E`S ii6:S1� _ i_"�@Y� ��?E 1�1� DCT-��-:=9.� ll:�c t��P L .;''1�yc .°:C�'°a:. �T FHU� '" ' ; H7TUKfd�'( 01� _"�o S5.'�2 P. r u/2 � ��" � �t rE:"aes`5 LCr ��mi�� s- R�q�1�5� r: � C� 3� aSY L.�=" 3_. - ----� -. _s-.- -'---- � �-_�--.._ .- �- - --- ��- -- --- - .3Q:!11SS1G?? 8a �.G 'wP_d:. C.�OL`i:PEf`i'G8� �� 211.y '�ai�l�d-'��= JLr � '_r�!T.S '�::�. L'i`v �3� ai1@CEv 31dte5 U'.lr::_na$°C. ��Mi�'�o,.. -1i.�:L��B �S .,�. i :1 �- .'F. ��°.k d: .�.^'•T:1^aS=D. _ G�_ r iLlYCL11oEd 4��"12 Sa^:4 't5 ..c.�.�. �°!YU2Sr �iL,i""U.`?rS 7 `7 tC �� J7. SE2� i.i_�P2'IIt%c��.Qr! �^ G� 1�.F`fi8 Or �G�tllr�('l2:'-� W'P.�Cf: '�'t7? CCIi.V diiEQES �'i&'l�23 g!J1fX ''J�riV@e7: ?�p1'=� �7. 1`��.�. 3I?� .`�iZ✓:1- 'J4, � 9�5. ��uF'�'^ P.li..^L.l7c'Yc 1:'3 �.7 12c S^� 1C1� lY_iC�71dt30i. Y'cC`j.�.�Cl:ly" the reco°ds kept for �he alleged saics. T�`=�� - -s i�u b�s=:.� questiars ir �hes? _28 arrai��ior:s, J.; whd� w2:� pux'chased, 2% vr��w records t+=ere kG�t regard-^g `he pLrchase, 3) wr.a� was so=d aricz, =� i whac recosds war2 kepr_ rEgarding *_he sa1e. T_�� :_u.::r;�r ;�:: aCC;llssiOnB was nFCessaY'y �ec of �n� amOUY:c ot �C[ui�pmc"..L ? 1?V�]iV"zC. :�EC,UE9� ^.1]ii:�2Y'S � G9 �O _'�� a°JLE . rG VEi1t�' Wi1Z.� 2�111F+S:Et1L 'JTdS recoverec ar�d identifi�d as be�onging to 4h� t�loschkau's. r'inaliy number.s 145 !�0 15G ask for _nformation as 4o L'ne con=acts i=�a�e's pe��onn�i had wir_h �re seii°x, YZ�tiaid fies. T�"2� �:e.°CC:TBYS.' tV35 .Ot 1rit�IlCi?C Josna �orporatior, ra�her ?t a� strea;r,� ine th� i]�ar'_ng p3o;2�5. tc t]arass, ':�ncimid�:�e � rii:ais i �h€ City`s eL�crt �o ncspef::iwy ice�uest�ior__rc^uction o==��c "_'?:e Caty has re4iiested receipte, �ta*_em?r_tw, or ot :wr �iocu.;nex,�s evicien�ing rhe p'irchase or sale of the a5 or so i*_�ms o� eauipm2r� �t nas aJ_leae3 Aabe'� fai.3�� to mair.�a�n c�mpx��t�ensiv� records �oz`. Ru a.ee*er da�ed Segtem�er 26, 1995, and pursuant ce ycuy Orcizr vf `h2 same date, �he City gav� uosna ^orp�rat'.cr_ natice ot c<1� 3'�?C2t=C 1C2?RS i� 111?C�'E: TGtiilS �`_Y`iE }JdS1S OZ �:� ?QVH?"S� 3Ci.iOT'�- lT."'X111�]1C [i� �?-��Z" Of Sepr.ember �� 1�/�:�% - [�� i.iti� t11`tz i.Y7� � rE�PgL'E uOS�"3 �'CY,,l')OT�t };]TC�U�"C dt,y a.il�� dii Y"�CGYC'S.v �Mi-i:IZ Bi1�SDOYr i.Pe?iT CaBil ai13C d'G T�GGTi�S itiC�'X'2 �.�cYi:l°di_iC�. i�_c__AOSii-�iUR �L NCr!��_t�-ES °'3� Z�!Q��44� 1?7 my iPL'EY' ".jdLC'a Q.".•CG�'�r L1, ]. ��Jllcil� =�iZE w�5 .`.+.0 ' �VYlO SOiC1 ��1� 1t�RlE lIl �125tiCi:1 CG �.c�iiiE" 6 i�'1i.1,S1.L: �.170�r.�. '."-��.' `N^S i_�E.._7_L�°Ca CP_ LI:P_ �c�FVTi(�iiy �OYlT._ iilc �C'S�ii.^.G.1% 15 1_1�'C:�SSc2 t:cC.=.:i�2 r2 }';dS , e.nfOY^'^v10t_ TEy3TGlII� Ll'i� C1r`4.L'?.T.SC�iCCB .._ Lil2 Sea_� aric "?1� �rte:n��5 tp �._t?V �'J3C,K 'Ci1e p�O�or�y `Y'Qit� %�ariE3 -n 1r.tE 1�;jS fOi.l:JW1?^_'? t._'1� 5312 O^ �,v�GT'1'�_ 19� i�95. R,`7i:.diC� KZY� �{zS CG:!V'�"vL-°: '__ S�:�ii._:S -_ -'.?�: ' e13C1 1E 7,ii'�cT��Yu�'.i-°C1 1R �riP 1�117I:�S�L_- C.�rre�_-_- - °_ _ _..�.�i�y ir_ S�i�iwarer, :�i�r�r.esata- �T_C,i' i3 �E4T..iE'S�ii j•`:i:.5 �2pOS:.> S.:t Z78'_"�� YJ�C.3?�.SE �'��i =I1S�iR:'c:'�_ 2"ECE1V�� YYOttI - OSi"7?. �OTAOT�LJ,Gri i.Yl� U21+ }J�f�71F t�� =:�� .... =;7� or:gi .a1 he�rir_n. rExribi� s, Letter ��arn S. �-�G�ney �� "=1r_; 2oiri�r) . Fpparen*_Iy, �e_rscr_s ��om aa�es m.ay �es��ev -n�: =,ar��. rne e�u�pner_�: s�as sole, Aahes °�riPd *c �sa__�fY �he se;.r�� oi "e.^_� OCT 11 �'S �T .rf'F+LI_ �ITI' PT i^uFI1E'•( 012 ^98 5532 F'. �.?� ?w:;� � Ja�o� _.�_ �a'.-: �j v - e�uipm.ewL--:�.a}e��?y �_^en assem'_^,_e ti^e *.«a�cr piecES �o 'n_e su=e 4-^.°Y . _ . __ __ __.. . _ __._ _ . ___._— _ _____ __ _ ____- _ ___ . -__ __ _ - ..I..c{ET5*"CO� F70�.v � iL TNOrKECi. �� FUY'tYlE2 ,*r]CET7 K1BE r�ti:.IT.EC� CD AU�r b�7Ci4 tI1Q EU.L'.1LJIS127tL. 7J^�2 *YOiT� P..3.E7�3 �=.�8'J? Lri@]/ r?iuS"cCl C.O S2i! 1t t� i�_m. ',EX: �� s at [��r�e 2, p�tacrapn `G� . Tt�ank yo:1 �o�: �his c�gcr�unity �o res�ond. � cv�ii i�e aeJaii�b�e -c'_ tn� ne«ring a� �._= p.m. Loda�. °very t°tu�_i �rs �� Gai1 I.a. u= e? d Ass�s*_a:�t ciLc,r _,.r_. C: '!'=^i�. =Ji::-a.E'r CCT-3�-i95°� 51:=7 �,- ��L C?''��-TT��RF,E� CtTY OF S:4II�TT FAC.�L ,Vor„r ra:<nw^+. ;i � 5"E�vc':`..�'i°'_" _ � '1>�_ '�im�t:�y �. Po�riEr Lowrey Hi:l iaw Oi=ice� 1900 Aer,nepin Avenlie Scucri Miniieapolis �:i 55403-�1u8 oi� c5',� G��2 P.Lj4 VP(:L.L' V'f 1111i 4: 1+ /Z a 1v1�..+i. � Tnrotirv E .�1u� X, ! %�' 4r:arnr�� '_�. _— � .�.. �.' � \ — C'rvf7 Prars;or, �ICCo.ryHu:! 7tleynn.:e_ ozi:G�-�ty;(+ !: We3i !:e!,'agg Bitti F�calm:i'r. Ci? L"8-56 l Scint Fcr�? :L°r:xvsota �. s: RP: Al�. licenses heel b�r Sosra Corporation ci/b!a ?�a�e�s Family biscount CenterJAabe` s�1us_c 8=�ogpe for *_ii� Nremises locatec� at 1933 I7n_versity Av�nue West and 173C U.�iversity 1�venue Wes*_, S�. Fati�- LSC2Yise Nus: 86i61 .`s �=16?0 JP.c�.� Pil:'. �G_Tie.Z : PUL'SU3=7t tQ your T.[1d�10S1 dIld ;iUd.C�,� ':fCFE�k'S `X'�1Er OL �'�L]L�LCt1�2r Gl 1995, the City furnishes the fo�low_r. n�or�ria�io�: 1} The Ci�� aiiegea tne followir�g ius�a were ��I� or ot�s�rwviss ciispesed of w�thin �e� days of k;a��ing pure:sa$ed ar rscaiv�d sueh �ra�s�:r�ye 2 Pea.vey Full Rang� Speaker Cabinets, Mec�e1 11� in�Artza�ionai Series SSI SW, Seriai Ivumbers: iE-02992246 &?E-C29922=��, i Rn1gR` TD-40 Light Tree 8tand, � tr.lg} � Tif-3D Try"ipcas, � le�tt��T ua�s, u ?�- Slide Mrunts, z-50 ��ot speaker canles, E-: �_ iac� exre:�ai�Lr co?'cis, 4-9 Lc�c� extensi�n cords, 7 micraphor.� - ., 1 r-�-c��y�i�oi:� stand .v%tei=-conic bocm, »-25 root speaker c�b�� "� aice muszc gtand, ??an�s�nic c�ssette tape �zccrd�r, L Sur�n ri��_ I�'.�-r_�zors, i Te3 St•-+ra.:e bc75:., -�O�s �SA 120 ."�.u3Ft�Y� l a ..��_7�7.s; � C`Rr.�"/�I?�T' 3i;'-- :':7Li7 Cc':Se� y i 40Tu IJ3G 44�`� • �.Ti15Cc:iidi'x�tf:.��" C�-'�6 �i.'�`�' adaptez 2 swrge svp�ressar_, � aui�ar cor:�s, 2 mic c��ps; dru�cs�9ck�', � X�2 tr�nsfo"':°�-, � cuc?et adaptc�^ - r�u Y'iar_ci cruck (�-wh�el�� ; . ana � �__�ver ..�. .��±cK �%-wa��r 2) `Z'h� �... - - �1�.�C�?8 ?�J. ��4iha.� v �ECCTe , _ _ -_ _ _. � y`�' _ f3�".`:_:88E1, o� z'eesa.tied ,:i: - . _ �sp': ��,t *_�� sa;xowmz� m__�y„ i Feav�y . ._�._ �a.^_qe x � S�2axa= Ca:�---.:� . ��,a� -__�. �.nr.----� _i� _G_ .eiPA c•c �ti .. . bv�Tl�,1 1v4.137E3'_'_,. �J= -� -�7LZ4 � ._. �._ _.� TS41C ^3DZpS� " b_�hv v:3�[ fin-.^.� l� __,_, _ !1�� _ _-''.�5� ., yC1 �a;.�r s:�ee�G. � 1°_atrer �ags, _ ��:-� .�-,_��-.- -=�:��rec7. SVc� Mn� ��: � Or_�,-3r-1995 1i��1�� ST rRU� C1Tr qrTU�nE�y 61� 258 ��2 P.FJ� T ` �dC�.�',. L "j EJ _' Tir.!C-r pp;r'_°� Sex Na�r.ber: 5�19z3, 1 Ibon.ez IrC-cG :oo� Cortro'_ier; S��:a� _ �fu?r�e� : 3�U? 5� �" ?��iah� S1i�e Niou��s; Z=Sr �ccL - spea- - er�; 3- i00 foot exr�:�sien co?�a�, 4-8 =oo� ex��sacr cords, 3 cora tcr_es, i.T.1C'rOT�7=G'Il2 s�and 1 T1CiO�J1'10Y:� SLd_^.Q `r7/Le�°SC0�3C �Y'iGv^,^.t� �-G� LOfJL t3aPd�CBY Ca[J1�S, 1 S1C�2 iTt'18'_• C S�3PQ, 1 t'�'3:11Sv?11C Cd55H�LE LdpE recarder, i ka�co AB 1C0 scvi tch, 2�ur.n Flccr :KOr.itors, i r�a storage �-ex, 1 Boss FSA 12n �danter, 2 g,uicar s_a_�ds, ��nLTL=?v� saar. with case, 1 ccrct bag w/ 47 ,^„iSCE1�.2.I180LI5 COYC7.S ana a3apters, 7. surqe suppressors, 5 gui*_ar =orv's, 2 mic ciips, drumsLicks, = XL� transfor,r,ers, 1 outiet �daptor, 1 red hanu trucit t2-wheeleri ,- S11V�Y i driC1 tY'Uu^k (�-w1YEEi2Y'i , i Driefc3S� zOZ' 1iqilt Cd:?S31E� 2 b £t extersi.on cords, 1-20 foot headpccne ext�naion cora, s ma.sc. cables, i extra knob for Knigi�,t TD-4o and Kni�h� iD-3o Stands, and ' pcwcr s4wip. 3) The, Citi^y a�lege:� camprehanaive records were not kept for che Eollowiac tranaawtione: al �or_ the Saie of: 2 Peavey r^uil atar_ge s'peaxe� Cabinets, Mcdel 1_5 International S°ries IYI �P7, Serial I�TUmber.s: 7E- 025�2246 &?E-C299224?, ; Kni�ht '1`b-4G Li�ht Tree S�anci, 2 Kr.1crh4 Tb-30 TY'ipo�s, Z ledther L�ags, 2�12ic:at Siide Mourits, 2-SC foot speaker cabies, 2-1G�, soo� extension c�rds, �-8 t�,ot ext��siar cords, 1:,;icr�p:�one s�.azci, _ mi^YC�hone st�nd wfteZesco,,ic boom, ?-25 ic�t sp�aker ca�les, 1 si�e music sLand, 1 Panasonic cass�tte tape rec�raer, F Sunn rl�or Monitors, 1 r�a storage bax, 1 Bosa PSA �L�� Ada�Ler, 2 auitar stancls, 1 CRUZIN' �ign witi; case, l coru. nag w/ �7 miscallaneous corcis and adap��rs, 2 s�� suppressors, 9 auitar co�ds, 2 mi� ciips clrums*icks, 4 XLR t�ansL`ormers, 1 outl�t adap�or, 1 reu han� truck (2-wne�ier;, �r.w 1 s?iver hanG tz;:ci: (:?-k�nee" eYi . bt for che purcnase ��f: 2�eavey Ful1 R�nge �:_eak�r Caninets, :iodel 1i5 Internat�ona: Series ZI:. aw, ve° :�umi�ers: 7:- i,299224E & 7E-0299224?, 2-5� foot mic cai�ias, ts-� 5� waLi �i�eu ii�hts, 14 '-ignt gei �?ames, 8 gel r�ager sheer�, 2 Iea�nez bags, 1 Bo�s M1�15A Powered Spot Monitcr� SArial i�um�eY: 551�23, I Ibanez I:C-5G r^oot rOnLT�iier; SeYial Number: 3uu154, 2 iZn Sl�de M�unts, �-5� foot �,peaker c�3�Ies, 3-1vu fGOt extension cor �8� '!-� ��Ct �7CCCr�7.C�'-- ; C2 J COZP LGi.C-S. � mic�op::one Ct.3R'1�� '1 I7t1C10�72'ivRE St�iI1Cl W,';,�l�SC0�7.0 DOOi`l� 4 fao� speaker cdbies, 1 szde r.tusic stanu, 3?�3r,ascn_i_c cassetce tap� recorder, i papco ars iD0 swit�h, 2 Sunn Fio�r �+icnicea°s: 1 red stck�ge ��c.s, 1 rso�s FSA liG Ada��e_r, Z gu'.:yar s`�an:;�,.. � CRUZ??\�` L-.'1�:� Wi�Y! C��^� � COrC't 17d� WJ 47 P19C��i:.3I?°0118 CC2:2S dS1Q a�r'��r2TS, S;a�<�7� °`1��C'-'_'�88CWV � CJi11�d2 C09"�S, � P.11C eii_�5� �.1X'tii;�3��eiCS, 4 Iii.,R �ransicriT,eY3, ,'� putlet. a�3ptCY�, 1 rE.Ci i7dI1� L+llC7f (L^W�1�SJ.27."7 i �i g1 Yl$_^-CE LrLIC1C :� � 1 �ri�fcase r�r ' ight co�sc�le, 2 6 f� ext?nsion cor�:s, 1-20 ioct h2aciprcn� extenSion cord, 3 m_Sr_. �ab1e�, ��aMra itnc�n i�r OCT-��-1 �95 i: � 4i �' �FiuL C i T(�-l?-,JRr•lE'° F i2 �98 SS�=' P. l�]6 F� � C.' 4J � iliitCLP}' �01_:F='" - - - �night '-'�-�� anc Knigh= '��-30 S=ar.dw, and 1 pcwer s�rip. it115 iE`LEY' LV1=� c1SG TiOt-1=Y ;iCll Lt=at �i1E �=�Y iIlt.flI.AB Cb i�'_'282I'_L E'Vit��'.e,:1C@� Y^cCj1T(Y.'1iiC '.`.tl� "I1Ci3i�10I _ St. F'u:.11 L2�=613t1'�:e [.'OG'2 3 344_0? (�) "Re�cr�s ta Pciice." Tk1e �asis �or *iai3 Cnarge is vour cl'_ent's faiiure *_o ccmply witli tac Code and pYOtr�p�+y pro�-de L:�e police witn ccpies oi �^e pa�rr,/buy i�rm. Enciosea =rY the fcl�aw�ng docum�r.ts wnich may �e used :�y �n� City at the hearinq c:: I�overiher 9, 19�5 as exhibits: ke�eipts pr.avided by Georg� and Donna Nioschxau. March 18, 1992 let*er frcm Gecrge Mascnkau t� S.,awr. Sweeney. If you have any furtiner qu°stions, please Cio not hesitate to corAtae*_ c _ . �,a_rf tru�y lcurs, �31.: �.2: �'F � d �s7.s�urL ��ty Acternel: Eric - C: Ci2: Y'g° anC 1�7. G:lrid ?�iOSCtl.lta: ';,.L � ��:., � �_ ; �=?—=b-1°9� --°4�' �T ='HU� '�IT'Y RT'CFfI�'r ?..�,SE ` S ,T,;SIC" .G.�DPPE :933 i.TKI'•IEbtSZTY AVE:1iTc ST. ?�p"t=L, S??d «^.iG2 ': _"_�t POR i g� _ u��aY �?x�� w L��zc� '_�� E�NxEri� AVENUE v;r?I\�,�?�Or IS. .�,bi FtE: COfdRE��DcNCE OP r ` � t�Q��FiIf�, DEAR TIM: ` -� �� '� t. 'Ji�� G�i� SJ�� P. )� , ,�, ,.� � 9-15-95 CONC�4PSZNG G�O�GE & 'J4'?ti;tiA S FtECEIVE a .�Sy'1TD REAL' T� llOCUMENTS PAUL A.A.�: ADt]ITZON, Z 6XC}WEI1 TNE s�A�S�,G�xy�}F ST. PAT3L P.ABE'&. YOU 5E*tI' TO F'.E PROM THa ST. ALL OF THED: T� EFeIK Sv1EiiSON, 4?1TTE FRAN��Y TIM, °RIK ANB I,E1-T2E BOTH ABTC�[3NTJEH AT `PhE RIDICUL`�SU.�+" SER'4'IONS CONTRTN$➢ IN C'sE4RG�"S LETT�R. AS i 7C)LD '°'OU EARL��R,.i SFJSPECT�T) GSORGE'S WSiC�G'�.` AI'PRUACki WA�u �Rv`r�FAi'si,Y SLTME� AT G$�IidG E4cN F�R P?Y I3�CIS ttOT T� BG�sf I?.iS b'niV� YE?.FcS AGO. T�Ai�'u:'��3ITE IIRA.''L�TTC.�4.Li,Y, EMPTiASI�E� `T'HAi. TfiW RzPORTS �'FRO;". THE POLICE GrFTCER5 SEEM ACCURA�`c', w'1`PH SuME SMkLL QLFE�'P,IONAHLE COMM$Id`X'ARiES �Y TFiE FI�t-"u; Drx'ICER i'i'iluL EXFuAIiv' TizOSc AS iv"E PRCr�,'F`tF�S� . �I'IM, I 4 rITLF:'- Tk2Y TO A3dSWER EVERYTFfTNG Y� C}�+�ER C�P �R�.w�N't�iu HEF.E iT G�ES: PAi q 7� y � 5 P 1,2 ,& 3 AFc� C0�1Ek L�`"�'ER A2dL� �UR LTCETa3E rNe:1R.'tt1`Z'Ivtv— i �+�V le'�Jai��'a�hlT+.� . PAC 4 IS` ? R�pORT ��' SE.T2("aEP.AIT k'ETrR54d�E '1'F±A'P $AYS 1HE C():'YP?.e'IINAiv: S't't�i'X'.�`.IJ" T4dCJ'SP�'.ACZ$f2S. LIGHT TFtIPODS. GA�LE$ F.ND COKDS� � CCSMPCI`.l'e.n t;t�i�`i'zct3L UNI`P eIND x7IMI`�k t`�ACKS i�]ERE �TiJ4E�3 [�N Ar�RiL 1`�, i995. iIQTICE s�'O`P ONE ��tENTIGAi C�F A�Ef $c5S5 MC��iITCR, InP,N�� 'v:ri CONTR{7LL'nR flR RAPCQ A/B B4X APP�ARED i�t 'P:IIS tiR y;�`� ii�` ^t'riE SUHS�QL�NS ?�L�LICE RE°0!2'1'S iINT2L G�ORGE PiCKE� TA�, i L`- FRGM OUR ST�RE L��T ApRSL 25. I� ADDT'TI03^1, �EQRGE CLr�TI'"=S 32r' HZ� L�iT�R TO HAVE i4AF-K£ % ALL °tii8 E�UTt�I�EN`P LtITI? HIS ZI`tlTie'�i,�. C3P,Di.Y ENOU'�zi: HE ti�SPt�t �vTiIEREE7 Tfi I+1BNTtON 'PHAT i0 ��E Ft�LIC� Gai iv �it, CR, ?lr�'A.��'I�FT:.Y. I�4".' S�rn�^_ JCIS`P s�NB Nfdfc�`., 'PFiZNG flN TFTT.4" PAG�— 'I'HE COMi'L1g'INANT '�?� HOT SHOW �°�' LZNEiiP. THE (7FF:CEA I��. Z'M �aCF"HE ,iii5 I� A'iYF'G. PFiGE S& o--�RE OFFYCER MFiY�12`$ REPGRI`. Sfl:`5,�, ?\T`s.��iEaTT:ti:z F'AC"�'w ARZSE �N 'T:?i'S_ 1_ '?'FiE bI•3c'�LAINANTS 'I'ULD T?i£ v^rFICER �'HRT TH�i WERc GQiNG is`} � , s�� e _c,�<. - , ��r mca :�a : •nb, �nir tila e'�d _c �d.�C.uw , j•;nl_I 5��`.'Y - rC ��5 �; — - — - -- 553� - J I �-i :4t ,� FHJL _iT'r Ri i�Fl�E:' r,12 2'�,� �.�8 �S !�4R1�T'? Zh'I) I3ATQLw STORES ��AWN SH4P5 AS POSSIE3LS . H�i P'� :3'=t� ,�1D L1�' TT3E S':`RTEMSNT Tk1EY SAY TI�Y CAi.�LEL' OiHE� STO�S r1HL' a�`ERE ^ _CLD AABE' 8 S�LLS STGI.B�I 1"�R��Te4NDI5�.. EVE3d IF Si3CI} A T�?ING S+�R$ 1`RL`E. WHiCH IS IS ASSCsT,'JT°LY NGT- ?vC - — 5'"'JRE wOUL� S'I`tSPSi7 ENOi3GH i'Q SAY SiTC& A T'FfIPI�r Z'C7 A.�`?� -� AL'JPIE A STRANGER ON TIIE ??�QNE: AAHE' S+IAS TFiv A b€�2 E+� ACCUSEI? CF DEAL3PIG IN STGLY.?ti ME14Ct'3At3D35E IN I�Y BXCESS OF 7 Y�.�.'�S IN PUS�NESS ( 2 T_N ST. PAU?�}. 3 C;�LLEkf'rE ?�. �`.4E�CHXRli Tt} �ZVE NAi�...5 ANL' Nt,'MBERS Qit FI2�17 HI:�SS£LF D?1NG�ROliSi.Y CLt'iSE TG 8LA?i?ER. BFSSD�S. 2F AA$� `S S�LLS AkL THE �TCJLEI3 aQUZP.'�:tii W'�;'� :dASiE '"IME �TTH A:,L THOS� DT�iER STt}�Ss? IT I8 CLEAR THAT F,22ZK TRISb TO QUALIFY `PH� BELi.E.�.S OE' Ti� E�UIP#IEAIT-I�LAKIi+IG TFIES�f A55EMBL� THE �'FAJGR PiHCe 6'Pfl FE SI3KE TFiEY i7tJDER5TOOD Etdvl I'� WORKED. IN ABbITEON, OT1 4-21-95 WHE�7 TIiE THIEF KIES F2ETt1R."TET� TO RS�tTI2CIiA58 '�HE fi9UIPME2IT ERIK VGT 4NLY �H. tJSED TO SM:T_. Z-� T HIM, 8VT �XPLASNED Et7£2Q IF 1� u7�h"F`EA �0 S�LL �T TO FiIM, T°rT3�T � S k�OULA NEED `PO WAIT 10 S'ISSZNssSS �AYS ��'4ftE ��ZNG Sa. THE RE?'JR� �ATE5 TFi�T Y`L' WAS AG�iEED i0 �30VS `f`2§E ES�,TJTPP'Ic.:�iT IN ��STT4ti 'f0 �'HE HA5�MEN1. TF3.�T fS TRUE. `vIFd�T T$ NOT STA:ED IS TFr.AT G��RG� :AND T AGREED 'SQ 23Q SO $ECAUS�' t�� MCiTUALLY �ECIL�ED TiIA'i` BECAUSE;` THES WAS OUI�2 GRAND OPfiNING IT WO13LD HE 1�. 'z`f?EMENDOUS HAf2l)5F3iF QN i+tY S1'RFF AS ldELL AS GEC�RGE, DC2333t� Ar3II A� 4F�`�CER TO Z10 THrS O1P =•F�ItHAPS 'I`H� HTS5IEST DAY IN �U� HTS''iJ:cY. wHEN THE MOSC�ALS nc�x su�t� -* �n �rr�, F.ND x DID , L�'�ST IPI'V�S R�'ft3R�t�n 4VIT'EI AN :}FFICBR AF7� A a�'EW �Tc�RY I+iAS QT3T'F'E �RAiSK�,`?, ANNOYcD. Y��.+�`EVER. BDT�i ERIX T� ACCOba01lAT� b�JT�I t}UR Ct3�rGMEEr5 �'sv➢ THE �FFT_CE.�2 MA'!�R APt�'ARENT_GY W�QT�' �+`G� 4IERE UNCJOP�k�.&TIVE '1`'kEH L�4�pE!i THAT 41A5 A�IT T00 STFtONG A1�ID a�EC'aDfiB TD C'rIANG� x'= TO i A�RLY [i?1vOOPERATIVE Y,�ATE�t. FIZANK�Y. i Ti�II'rK `vlE PeTC7 Au�iTRABLY COF38YDERY'�G THE'RE G7A8 ONLY OYv`� {?'Ch�s'2 EMPLOYEE TN TH� �N':IRE S'TORE C1`r'F�'iR °PFI.�.N �TZIK ANIJ ��C,La"+ .. A?' 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PAGES ;. 6& 3 YIELA NO RE.x.EVANT INs�RMA�IOti Z Cr1id SE�• P.F�GE 10 TS TfFE Z23TTIAL POLIC� RE�ORT. qNC� A�AIN THn MOSC.xiICAUS FF,IL 'TO GIVE A 12�'P9RT Qr^ ° �`�E SO$S MuNT7'�R,SBANEZ C�NTR�LLER, t^�APC'J A/� $(77C OR E'OFZ TF?AT MAT'?'EFt, 3`iiE x'ACT `PHF,T GEOR.{'sE CLe'�I�!S TG F3AVE P`�Tf' I�SS 2NiTIALS DN EV$RY"CI?TNv h'E vShc�+'ETJ. TT 4��TJ;.D E€ A SHAME TO C�N�'USE 'I`HE PCLICE 1�IITH THE FR�PER IvF�iR1`1-�T.C�. PAGES 11 TG 1� REVEAL NQTAING F3U1 T� REYTERATE THE LS�1Z�.'E3� AC$C)L?4i OF' E�UIFMEN'� TFtE MOSCIiKAUB REt�OEt`FED AS �iSSIN�. PAf'.,� 15 5 z W� P. L.IST rJF ZTEi+IS TFiAT cSAS 4L'FtT�USI i�r`tC:k�?v iAi2G�R SI;iIC� . I�+�.Y�T? TQOR TFIE I:dTTEAL REP'-7.'�T AT x�.�5�'S. 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TI�i. � ARE A14D CGNTIM'U� ?O B� A�FtOi�»nG `�5��.�•-`^; Hx.ifiIAIE�S Pa'�€Pa i10'S C�Li' �.R� r7E' tdOT SidTSr srT ��LI3vf S!� STO��h �'R�P�RT4' ( C[JFt $Ai.$S k.R�' 7 ��k+7 I'"�M5} �Z1'I` k'tE ��3�`T 'zIAVE Z'II'L� TO k'OpL GiT?[? "f'HIS TYPE C3F R't3lvSa:dSH. GE�R TS S'.MPLY ACiY;vG OP+ A CYt�C.�GE Ha5 XF1a^ 'tvKC?:FGcLiL'.,Y Cr".,=c1�iEH y'JR YF'�RS. I P?2 itQi THE` FIP,$T �EC�PiEi3T OF XIS �ISS�E�T'�EN fi..NGx'R �`dR SFtAF:�, T. A�' 'P�?F' :.k�=' ! C�'�.L *� I° i r'�.'� AI.'i} �-�.�s'�f°iS: ,.:�sF. � �i�vEs`'ck , r / � 1 �� , �G�� t �� -_ vy` `^ J . v�''�YciY -"- �+�E � s�. �i'4� n':, �s�`�: ��J �� ' - �. 7 ' t � '^�' i , r a ; � ' ; � .. �—= i_n <�� ; � � J!, �Y �%�-�r�'_.-'..W r f � . � 5 � /�Z �Jr" „�; l `' `i -r; F;�- � �+ J., r:�.. � j 1 , � '_'..�ye�'y^� � v �a.Y�'''n'' r � ` ,r, ' ; a -� , � --� r -°` .� �.� "� J i � --.' .-{-J :✓ -- !!`t 'C -"`. ' R,l,}�-'�-'�3`�''�'� .r'L',r✓'�.. ,� ^J-�1� :� - r y f `�} ; ' , i +� y . y y ( ( � r. %� ��✓v. ��, [� ! a� ' ? - v � � .� l.�"• "'L1 1}-�v' , i . ,. ; � � �,y r -n f, i` ,� `�a 1 ',�, c ! ,,�' �.r�.,c-y ��'.'�� y� , ��-��°. ..�:=!r i ��.,--r�; -�' � x � `r' . :.'" �, ry �� • r r �, f 9 � ,�L \J+l' �/1..�'`r `.v�}--t� `_"h� i- J A.''r—s e . � t a � �. f �° J:` � ',�;�.�. C` .� . [� _ VY. .f - � . ^ - `-�-..� -� � � . 4 1 y � ;�«i (s,�°Ur �`" i �:.;2 .�� I" � vl �'.'� 'y''��'''�`'`'� � � 1 u \ li � � f' `�'�}-x?`�J ; � � t � i� t } � �\ � I;1� � � . .Lf� i � r. 1 � � y, 1'v� "I �Ft..-jC„ , 1 k/`+� � �1�.�..�G: v „+-�.��3-`Z ;°t i7^-°;y'` ° ; � �� , h �, � , v.,f�-�-N'�- ��t" _' . � �„�� > j G` �,�': �, �,. �!\ � 1 k'� ._ , �� . � � . r._ . A _ STATE OF MINNESOTA OFFICE OF ADMINISTRATIVE HEARINGS � ` 10� Washington Square, Suite 1700 100 Washington Avenue South Minneapolis, Minnesota 55401-2138 October 26, 1995 Timothy B. Pairier Gail L. Langfield Attomey at Law Assistattt City Attorney Lowry Hill Law Offices 400 City fiall 1900 Hennepin Avenue South 15 West Kellogg Boulevard Minneapolis, MN. 55403-319& Saint Paul, UIN. 55142 TRANS'�IIT'TED VIA FACSIMII,E RE: In the Matter of All Licenses Held by Josha Corporation dJbia Aabe's Family Discount CentertAabe's Music Shoppe, et al.; OAH file no. 91-2101-9995-3 Dear Counsei: Today I have received, by courier, Josha Corporation's Mofiion to Quash and Memorandum in Support of Motion Quash. Atthou� the above-referenoed matter 'ss not, by law or rute, an Admhvstratrve Procedures Act case, the Act and the Rules pramulgated pursuant to it are nevertheless retevant. Minn. R. 1400.6900 provides, in relevant part, that "(t)the written motion shall advise the other parties that shauid they wish to contest the motion they must file a written response with the judge and serve cogies on all parties, within ten working days after it is received." Given the fact that ten working days from October 27 is November 9, the date of the hearing, I wouid like to discuss with you how we might mut�ially resolve this issue because I would prefer not to further continue the hearing. Unfortunately, neither my office nor my home Yelephone is equipped to place a conference call. Since tt»s is your motion, Mr. Poirier, I ask that you arrange a conference call for us as soon as possible. October 27 and 30 I can be reached at 645-0588 from 8:15 AM until 2:00 P1�1 and at 641-2799 from 2:3Q PM nntit 5:30 PM. dctober 31 I can be reached at 645-4588 from noon until 2:4� PM and at 641-2799 from 2:30 PM unti15:3d PM. Thank you for your anticipated caoperation. Yours truly, 7 A.�McPeak� A ministrat�ae Law ludge Providing Impartial Hearings for Government and Citizens An Equ Opp Emp Administrative Law Section & Administrative Services (612) 341-7600 � TDD No. (612) 341-7346 � Fax No. (612) 349-2665 1 _. LOWRX HILL LAW OFFIGES AN FSSOGA7/ON, NOT A P4qJNEFSHIP WILLIAM J_ HAN�EY TIMOTHY B. POIRIER MARK V. LOFSTROM ._._—____.""' _.. OF COUNSELc JOHN W. HARRIGAN October 26, 1995 VIA COURIER The Honorable Jane A. McPeak Administrative Law 7udge Hamline University Graduate School 1536 Hewitt Avenue, Drew 66 St. Paul, MN 55104 1900 HENNEPIN AVENVE SOUTM MINNEAPOLIS. MINNESOTA 55403-3198 16121 872-0222 LEGAL ASSIS .�' .� KAUPPI CYNDY }COEPP-MALNEF2EK �UANN SKRIVSETH Re: In the Matter oF All Licenses Held by Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe, et al. OAH k�le No.: 91-2101-9995-3 Dear 7udge McPeak: Enclosed please find a Motion to Quash Discovery by the City of St. Paul in the above- referenced matter. The hearing on the case in chief is scheduled for November 9, 1995. The City has noted a deposition for November 7, 1995 and served Requests for Admissions which will be deemed admitted if not answered by October 31, 1995. For these reasons I am requesting an expedited review of my Motion to Quash. I wili make myself available by telephone or in person in order to hear this Motion. Please advise me how you wouid like to hear and resolve the Motion. Sincerely, LOWRY HILL LAW OFFICES TBP:cIk Enc. =� , !N�'� O Timothy B. � e r� ► \�� cc: Gail L. Langfield, Assistant Ciry Attorney � h � � BEFORE THE COUNCIL OF THE STATE OF MINNESOTA COTJNTY OF RAMSEY In the Matter of All Licenses Held by Josha Corporation d/b/a Aabe's Family Discount Centerl Aabe's Music Shoppe, et al. OAH Docket No.: 91-2102-9995-3 CITY OF ST. PAUL MOTION TO QUASH DISCOVERY BY THE CTTY OF SAINT PAUL Josha Corporation hereby moves the Office of Administrative Hearings to Quash the discovery sought by the Ciry of St. Paul. Ti�is Motion is based upon the Memorandum and E�ibits herein and the argument of counsel. LOWRY HILL LAW OFFICES Dated: / � a � S �� . � � � , Timothy B. Poi er Attorney for Josha Corporation 1904 Hennepin Avenue South Minneapolis, Minnesota 55403 Telephone:(612)872-0222 Atty. Reg. No. 121617 ' g6-�75 ' � STATE OF NIINNESOTA BEFO� THE �OIii�ICI�.-9�-�'��---- — -- - - � COUNTX OF 12AMSEY CITY OF ST. PAiJL In the Matter of All Licenses Held by Josha Corporation d/U(a MEMORANDUM IN SUPPORT Aabe's Family Discount Centerf OF MOTION TO QUASH Aabe's Music Shoppe, et al. OAH Docket No.: 91-2102-9995-3 On September 21, 1995 the Josha Corporation brought a Motion to Aismiss against the City of St. PauL The basis of the Mo6on was that the City had failed to adequately advise Josha of the charges being brought against it. The OAH denied the Motion to dismiss but agreed that the charges against Josha were not adequately stated. The matter was continued until November 9, 1995. In the OAH Order dated September 26, 1995 the OAH states that the City is directed to provide Josha with timely and adequate notice of the charges against it. The OAH further states in its Memorandum which accompanies the Order that "The interests of justice will allow the City adequate time to make the appropriate disclosure and Josha Corporation adequate time to prepare its defense". By letter post-marked October 19, 1995 the City has served: 1. A Notice of Taking Deposition of Ronald Kies at the Minnesota Conectionat Facility in Stillwater. 2. One Hundred Fifty Requests for Admissions. 1 Interrogatories. 4. Request for Production of Documents. -------�seavery�isattac�sed�as�X1 _ -- 96- 75 On September 21, 1995 the City was required to be ready for hearing. It now appears that it was not prepared. The purpose of the continuance was not to aliow the City an opportunity to make a case it never had. The purpose of the continuance was to provide Josha time to be informed of charges and assemble a defense, The City is using the continuance to conduct discovery it should have done prior to September 21, 1995. The City had six months to pursue this discovery. The Order dated September 26, 1995 did not provide that the City would be free to go on a fishing expedition for new information. Further, there is nothing in the documents supplied by the City to indicate it complied with OAH Rule 1400.6900 before setting up the deposition of Ronald Kies. The City gives every appearance that it is now using discovery to hazass, intimidate, and punish Josha Corporation The City's attempt at further discovery should be quashed and the City should be ordered to proceed on the information in its file as of September 21, 1995. Respectfully submitted, Aated: /� a� S LOWRY HILL LAW OFFICES f � 1� `��J-u' , . Timothy B. P riex Attorney for The Josha Corp. 1900 Hennepin Avenue South Minneapolis, Minnesota 55403 Telephone: (612) 872-0222 Atty. Reg. No. 121617 2 1STATE OF MIlVNESQTA COI31�iTY OF RAD4SEY 96- 75 BEFORE THE COUNCII. OF 'THE CTI'Y OF ST. PAUL In Re the Matter of All Licenses held by 7osha Corporation d1b/a Aabe' Family Discount Center/Aabe's Music Shoppe for NOTiCE OF TAKING DEFOSTTION the premises located at 1933 University Avenue West, St. Paui, Minnesota To: Josha Corporation, and its attomey, Timothy Poirier, Lowrey Hill Law O�ces, 1900 Hennepin Avenue South, Minneapolis, Minnesota 55403-3198 PLEASE TAKE NOTTCE, that the deposition of RONALD KIES by orai examination will be taken before CAPTIOIV MIlVNESOTA, INC., Court Reporters, or any qualified notary public at the MINNESOTA CORRECTIONAI. FACILTI`I' in the City of Bayport, in the County of Washington, State of Minnesota, on the 7th day of November, at 9:30 o'clock a.m., and thereafter by adjournment untii the same shall be completed. Dated: j j /�' ,� TIMOTHY E. MARX Ciry Atto y , l's-rl � Gai I.an�eld, #184172 Assistant Ciry Attomey Attomeys for City of Saint Paul 550 City Hall and Court House 15 West Keliogg Boulevazd Saint Paul, Minnesota 55102 (612) 266-8770 EXHiBIT / STATE OF MIlVNFSOTA COUNTI' OF RAibISEY gb-75 � BEFORE fiHE COUNCII. OF THE CITX OF ST. PAUL In Re the Matter of All Licenses held by Iosha Corporation d/b/a Aabe' Famiiy Discount Center/Aabe's Music Shoppe for REOUEST FOR PRODUCTION the premises located at 1933 University OF DOCLA�IENTS Avenue West, St. Paui, Minnesota � To: Josha Corporation, and its attorney, Timothy Poirier, I.owrey Hili Law O�ces, 1900 Hennepin Avenue South, Minneapolis, Minnesota 55403-3198 Pursuant to Rule 1400.6700, the City of St. Paul request Josha Corporation provide the following: 1. All receipts, statements or other documehts evidencing the purchase of the following items: 2 Peavey Full Range Speaker Cabinets, Model ll5 International Sezies III BW, Serial Numbers: 7E-02992246 & 7E-02992247, 2-50 foot mic cables, 5-150 watC flood lights, 14 light gei frames, $ gel paper sheets, 2 leather bags, 1 Boss MA15A Powered Spot Monitor; Serial Number: 551423, 1 Ibanez IFC-60 Foot Controller; Serial Number: 300154, 2 Knight Slide Mounts, 2-50 foot speaker cables, 3-1Q0 foot extension cords, 4-8 foot extension cords, 3 cord totes, 1 microphone stand, 1 microphone stand w/telescopic boom, 4-25 foot speaker cables, 1 side music stand, i Panasonic cassette tape recorder, 1 Rapco AB 100 switch, 2 Sunn Fioor Monitors, i red storage box, 1 Bass PSA 120 Adapter, 2 guitar stands, 1 CRUZTN' sign with case, 1 cord bag w! 47 miscellaneous cords and adapters, 2 surge suppressors, 9 guitar cords, 2 mic clips, dnunsticks, 4 XLR transformers, i outlet adaptor, 1 red hand truck (2-wheeler), 1 silver hand truck (2-wheeler), I briefcase for light console, 2 6 ft extension cords, 1-20 foot headphone extension cord, 3 misc. cables, 1 ex�a knob for Knight TD-40 and Knight TD-30 Stands, and i power strip. 2. All receipts, statements or other documents evidencing the sale of the foIlowing items: 2 Peavey Full Range Speaker Cabinets, Model 115 Internationai Series III BW, Serial Numbers: 7E-02992246 & 7E-02992247, 1 Knight TD-40 Light Tree Stand, 2 Knight TD-30 Tripods, 2 leather bags, 2 Knight Slide Mounis, 2-50 foot speaker cables, 2-100 foot extension cords, 4-8 foot extension cords, 1 microphone stand, 1 microphone stand witelescopic boom, 4-25 foot speaker cables, 1 side music stand, 1 Panasonic cassette . 96-75 ' tape recarder, 2 Sunn Floor Monitors, 1 red storage box, 1 Boss PSA 120 Adapter, 2 guitar stands, 1 CRUZIlV' sign with case, 1 cord bag wl 47 miscellaneous cords and adapters, 2 surge suppressors, 9 guitar cords, 2 mic clips, drumsticks, 4 XI,R --- transformers, 1 ouflei adaptor, l red,_hand tcuck.(2-wheeleF},-a�-is�verl�ad�tru�(2= -- -_____ ._- - --- _ 3. Statements, lists, or other documents evidencing the items turned over to George Moschkau and Officer Garvey on Apri125, 1945. 4. tlny and all computer records which evidence the purchase or sale of the following items prior to April 22, 1995: 2 Peavey Full Range Speaker Cabinets, Model 115 Internatio_nal Series TII BW, Serial Numbers: 7E-02992246 & 7E-02992247, 2-50 foot mic cables, 8-150 watt flood lights, 14 light gel frames, 8 gel paper sheets, 2 leather bags, i Boss MA 15A Powered Spot Monitor; Serial Number: 551423, 1 Ibanez IFC-b0 Foot Controlier; Serial Number: 3�0154, 2 Knight Slide Mounts, 2-SQ foot speaker cables, 3-1Q0 foot extension cords, 4-S foot extension cords, 3 cord totes, 1 microphone stand, 1 microphone stand wltelescopic boom, 425 foot speaker cables, 1 side music stand, 1 Panasonic cassette tape recorder, 1 Rapco AB 100 switch, 2 Sunn F1oor Monitors, 1 red storage box, 1 $oss PSA 120 Adapter, 2 guitar stands, 1 CRUZYN' sign with case, 1 cord bag w1 47 miscellaneous cords and adapters, 2 surge suppressors, 9 guitar cords, 2 mic clips, dzumsticks, 4 XLR transformers, 1 outlet adaptor, 1 red hand truck (2-wheeler), i silver hand truck (2-wheeler), 1 briefcase for light console, 2 6 ft extension cords, 1-20 foot headphone extension cord, 3 misc. cables, 1 extra knob for Knight TD-40 and Knight TD-3Q Stands, and 1 power strip. 5. All receipts, statements or other documents which evidence sales of used musical equipment from Aprii 19, 1995 to Aprii 25, 1995. Dated: ��/g �y�! J� TIMOTHY E. MARX City Atto y � � r G ' gfie , # 2 Assistant City Attomey Attorneys for Ciry of Saint Paul 550 Ciry Hall and Court House 15 West Kellogg Boulevard Saint Paul, Minnesota 55102 (612) 266-8770 7 � �. � � q6_75 _ STATE OF iVI�TNESOTA BEFORE THE COUNCIL OF COUNTY OF RAMSEY T� CIT'Y OF S PAU In Re the Matter of All Licenses held by Josha Corporaaon d!b/a Aabe' Family Biscount CenterfAabe's Music Shoppe for REOUEST FOR ADMISSIONS the premises located at 1933 University Ai�TD IIVTERROGATORY Avenue West, St. Paul, Minnesota To: Josha Corporation, and iis attomey, Timothy Poirier, Lowrey Hill Iaw O�ces, 1900 Hennepin Avenue Sauth, Minneapolis, Minnesota 55403-3198 Pursuant to Rule 1400.6800, the City of St. Paul, Office of License, Inspection and Environmental Protection requesu Josfia Corporation admit the following within ten days: 1. That Josha Corporation, d(b/a Aabe's Family Discount CenterJAabe's Music Shoppe does not have any documents evidencing the purchase of two Peavey Full Range Speaker Cabinets, Mode1115 International Series III BW, Serial Nurubers: 7E-02992246 & 7E-02992247 on April 19, 1995. 2. That 7osha Corporation, d/bia Aabe's Fawily Discount Center/Aabe's Music Shoppe does not_ have any documenu evidencing the purchase of two 50 foot microphone cables prior to Aprii 22, 1995. 3. That 3osha Corporation, dJb/a Aabe's Family Discount CenteriAabe's Music Shoppe does not have any documents evidencang the purchase of eight 150 watt flood lights on April 19, 1995. 4. That Josha Corporation, d/bla Aabe's Family Discount CenterlAabe's Music Shoppe does not have any documents evidencing the purchase of fourteen light gel frames on April 19, 1995. 5. That Josha Corporation, dlbia Aabe's Pamily Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of eight gel paper sheeu on April 19, 1995. 6. That Josha Corporation, d/b/a Aabe's Fanuly Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two leather bags on April 19, 1995. 7. That Josha Corporation, d/bla Aabe's Family Discount Center/Aabe's Music , ". g6-75 , Shoppe does not have any documents evidencing the purchase of one Boss MA15A Powered Spot Monitor, Serial Number: 551423 prior to April 22, 1995. 8. That 3osha _ Corporar_on,. -dJhfa Aabe's �amily �Bisco�trn�Aabe's Music --- ---- - - Sfioppe does not have any documents evidencing the purchase of one Ibanez IFC-60 Foot Controller, Serial Number: 300154 prior to Apri122, 1995. 9. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two Knight Slide Mounts on April 19, 1995. 1o. That Josha Corporation, d/b(a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two 50 foot speaker cables on April 19, 1995. 11. That 7osha Corporation, dJbla Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of three 100 foot extension cords prior to Apri122, 1995. 12. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purcflase of four 8 foot extension corfls on April 19, 1995. 13. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of three cord totes prior to April 22, 1995. 14. That 7osha Corporation, dlb/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one microphone stand on April 19, 1995. 15. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one microphone stand with telescopic boom on April 19, 1995. 16. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purcbase of four 2S foot speaker cables on April 19, 1995. 17. That Josha Corporation, d/b/a Aabe's Faznily Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one side music stand on Aprii 19, 1995. 18. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music 2 96- 75 Shoppe does not have any documents evidencing the purchase of one Panasonic cassette tape recorder on Aprii 19, 1995. — __— ----- 19. 'That 7osha CorQoration�_dlb/a Aate's--�a�i�y-33iscouut �--- ----- -�happz does riot�ave any documents evidencing the purchase of one Rapco AB 100 switch prior to April 22, 1995. 20. That Josfia Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two- Sunn Fioor Monitors on April 19, 1995. 21. That Josha Coiporation, d/b/a Aabe's Faznily Discount Center/Aabe's Music Sfioppe does not have any documents evidencing the purchase of one_ red stonge box on April 19, 1995. 22. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one Boss PSA 120 Adapter on April 19 1995. 23. That 7osha Corporation, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documenu evidencing the purchase of two guitar siands on April 19, 1995. 24. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one CRUZIN' sign with case on Aprii 19, 1995. 25. That Josha Corporation, dlbfa Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one cord bag with 47 misceIlaneous cords and adapters on April 19, 1995. 26. That 3osha Corporation, dlbla Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two surge suppressors on April 19, 1995. 27. That Josha Corporation, d(b1a Aabe's Family Discount CenterlAabe's Music Shoppe does not have any documents evidencing the purchase of nine guitar cords on April 19, 1995. 28. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two "mic clips" on April 19, 1995. 29. That 3osha Corporation, d/b!a Aabe's Family Discount Center/Aabe's Music 3 _ � � 96-75 , Shoppe does not have any documents evidencing the purchase of four XLR transformers on Apri119, 1995. . t 7osha Corporauon,_ d/b/a. Aahe's_Fam�g-- ic "� ""- - _ -- ---- -- - - 5'iioppe does not have any documents evidencing the purchase of one ouflet adaptor on April 19, 1995. 31. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one red hand huck (2-wheeler) on April 19, 1995. 32. Tfiat 7asha Corporation, d/b/a Aabe's Faznily Discount CenterlAabe's Music Shoppe does not have any documents evidencing the purchase of one silver hand uuck {2- wheeler) on April 19, 1995. 33. That Josha Corporation, d/b/a Aabe's FamIly Discount Center/Aabe's Music Shoppe does not have any documents evidencing the gurchase of one briefcase for light console prior to Apri122, 1995. 34. Thai 7osha Cozporation, dlbla Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two 6 foot extension cords prior to April 22, 1995. 35. That Josha Corporation, dJb/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one 20 foot headphone extension cord prior to April 22, 1995. 36. That 7osha Corporation, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of three miscellaneous cables prior to April 22, 1995. 37. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one extra knob for Knight TD- 40 and Knight TD-30 Stands prior to Apri122, 1995. 38. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one power strip prior to April 22, 1995. 39. That Josha Corporation, d/bla Aabe's Family Discount Center/Aabe's Music Shoppe purchased two Peavey Full Range Speaker Cabinets, Model 115 International Series DI BW, Serial Numbers: 7E-Q2992246 & 7E-02992247 on April 19, 1995. 40. That Josha Corporation, d!b/a Aabe's Family Discount Center/Aabe's Music 0 Shoppe purchased two 50 foot mic cables on April 19, 1495. qb-75 _ 41. That Josha Corporation, d/b/a Aabe's Family Aiscount Cenier/Aabe's Music Shoppe purchased eight 150 watt flood lights on Agri1.19 _1995-_- — - 42. That 7osha Corporation, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe purchased fourteen light gel frames on April 19, 1995. 43. That 7osha CorQoration, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased eight ge1 paper sheets on Aprii 19, 1995. 44. That 7osha Corporation, d/bla Aabe's Family Discount Center/Aabe's Music Shoppe purchased two leather bags on April 19, 1995. 45. Tfiat Josha Corpontion, d(b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one Boss MA15A Powered Spot Monitor, Serial I3umber: 551423 on April 19, 1995. 46. That Josha Corporation, d!b!a Aabe's Family Discount Center(Aabe's Music Shoppe purchased one Ibanez IFC-60 Foot Controller, Serial Number: 300154 on Aprii 19, 1995. � 47. That Josha CorQoration, d/b/a Aabe's Family Discount CenterlAabe's Music Shoppe purchased two Knight Slide Mounts on April 19, 1995. 48. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased two 50 foot speaker cables on April 19, 1995. 49. That 3osha Corporation, d(b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased three 100 foot extension cords on April 19, 1995. SQ. That Josha CorQoration, d(b/a Aa6e's Family Discount CenterlAabe's Music Shoppe purchased four 8 foot extension cords on April 19, 1995. 51. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shappe purchased three cord totes on April 19, 1995. 52. That Josha Corporadon, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one microphone stand on Aprii 19, 1995. 53. That Josha Corporation, d/b/a Aabe's Family Discount CenterlAabe's Music Shoppe purchased one microphone stand with telescopic boom on April 19, 1995. 54. That Josha Corporation, d/b/a Aabe's Family Discount CenterlAabe's Music 5 q6-75 Shoppe purchased four 25 foot speaker cabies on April 19, 1995. 55. 'That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe Mu sic Shoppe purchased one side �3 �99-5. - ------- — � 56. 'That 7ostia Corporation, d/b(a Aabe's Family Discount CenterlAabe's Music Shoppe purchased one Panasonic cassette tape recorder on Aprii 19, 1995. 57. That Josha Corporauon, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one Rapco AB 100 switch on April 19, 1995. 58. That 7osha Corporation, d/b/a Aabe's Family Aiscount Center/Aabe's Music Shoppe purchased two Sunn Floor Monitors on April 19, 1995. _ 59. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one red storage box on Aprii 14, 1995. 60. That 3osha Corporation, d/bla Aabe's Family Discount Center/Aabe's Music Shoppe purchased one Boss PSA 120 Adapter on April 19, 1995. 61. That Josha Corporauon, d!b!a Aabe's Fa�ilp Discount CenterlAabe's Music Shoppe purchased two guitar stands on April 19, 1995. 62. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one CRUZIN' sign with case on April 19, 1995. 63. That Josha Corporation, dlbfa Aabe's Family Discount Center/Aabe's Music Shoppe purchased one cord bag with 47 miscellaneous cords and adapters on April 19, 1995. 64. That Josha Corporation, d/b/a Aabe's Panuly Discount Center/Aabe's Music Shoppe purchased two surge suppressors on April 19, 1995. 65. That 7osha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased nine guitar cords on Aprii 19, 1995. 66. That Josha Cozporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased two "mic ciips" on April 19, 1995. 67. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased four XLR transformers on April 19, 1995. 68. That 7osha Corporation, dJbla Aabe's Fauuly Discount Center/Aabe's Music Shoppe purchased one outlet adaptor on April 19, 1995. � . ____________.. _.._ _._._.. _;._......__ . ,.. 96-75 ' 69. That Josha Corporauon, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one red hand truck (2-wheeler) on Aprii 19, 1995. 70. Trsat 3osha Cor�orarion,__dlbla-Aab�s�a�arly-Diseotmt s usic � - - —� Sfioppe purchased one silver hand iruck (2-wheeler) on April 19, 1995. 71. Tfiat Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one briefcase for lig�t console on April 19, 1995. 72. That Josha Corporation, d/b!a Aabe's Family Discount CenterlAabe's Music Shoppe purchased two 6 foot extension cords on April 19, 1995. � 73. That Josha Corporation, d/b/a Aabe's Fanuly Discount Center/Aabe's Music Shoppe purchased one 20 foot headphone extension cord on April 19, 1995. 74. That Josha Corporation, d/b!a Aabe's Family Discount Centez/Aabe's Music Shoppe purchased three miscellaneous cabies on ApriJ 19, 1995. 75. That Josha Corporation, d!b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one extra knob for Knight TD-40 and Knight TD-30 Stands on April 19, 1995. " 76. That Josha Corporation, dlb/a Aabe's Family Discoum CenterfAabe's Music Shoppe purchased one power strip on April 19, 1995. 77. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Aprii 24, 1995, two Peavey Full Range Speaker Cabinets, Mode1115 Inteznational Series III BW, Serial Numbers: 7E-02992246 & 7E-02992247 which were purcnased on April 19, 1995. 78. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, one Knight TD�O Light Tree Stand which was purchased on April 19, 1995. 79. That Josha Corporation, d/b/a Aabe's Family Discount CenterlAabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, two Knight TD-30 Tripods which were purchased on April 19, 1995. 80. That Josha Corporation, d!b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, two leather bags which were purchased on April 19, 1995. 81. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe soid, between April 19, 1995 and Apri124, 1995, two Knight Slide Mounts which were � purcfiased on April 19, 1995. 96-75 82. That Josha Corporauon, d/b/a Aabe's Family Discount Center/Aabe's Music -- - Shoppe soid, between Apri1 i9,_ 1995_and Ap�il--24,. 1993 SE}-fovt wfiicfi" -�� - -- -- were purcfiased on Apri1 19, 1995. 83. That 3osha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, two 100 foot extension cords which were purchased on Aprii 19, 1995. 84. That dosha Corporation, d!b(a Aabe's Family Discount Center(Aabe's Music Shoppe sold, between April 19, 1995 and Aprii 24, 1995, four 8 foot extension cords wluch were purchased on April 19, 1995. 85. That Josha Corporarion, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe so1d, between April 19, 1995 and April 24, 1995, one microphone stand which was purchased on April 19, 1995. 86. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one microphone siand with telescopic boom wiuch was purchased on April 19, 1945. " 87. That 3osha Corporauon, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between Apzil 19, 1995 and April 24, 1995, four 25 foot speaker cabies which were purchased on April 19, 1995. 88. That 7osha Corporation, d/b/a Aabe's Family Discount CenterlAahe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, one side music stand which was purchased on Apzil 19, 1995. 89. That 7osha Corporation, d/b(a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one Panasonic cassette tape recorder which was purchased on Aprii 19, 1995. 90. That Josha Corporation, d/b/a Aabe's Faznily Discount Center/Aabe's Music Shoppe so1d, between April 19, 1995 and Apri124, 1995, two Sunn Floor Monitors which were purchased on April 19, 1995. 91. That Josha Corporation, dJb/a Aabe's Faznily Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, one red storage box which was purchased on April 19, 1995. 92. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between Apri119, 1995 and Apri124, 1995, one Boss PSA 120 Adapter which was � purchased on April 19, 1995. 96-75 93. That Josha Corpontion, d!b/a Aabe's Family Discount Center/Aabe's Music Sho e so1d, between A nl 14 1995_and- J � PP --------- P_._ _.-. _ t�g� 24 199-5;-Eevs guitarstatrds w�'i"cfi were -- - --- _ . ___ - puicbased on April 19, 1995. 94. That Josha Corporation, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one CRUZIN' sign with case which was purchased on Apr91 19, 1995. 95. That 7osha Corporation, d/bla Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one cord bag with 47 miscelianeous cords and adapters which was purchased on April 19, 1995. 96. That Josha Corporation, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, two surge suppressors wtuch were purchased on April 19, 1995. 97. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe soid, between April 19, 1995 and April 24, 1995, nine guitar cords which were purchased on April 19, 1995. 98. That Josha Corporation, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Aprii 24, 1995, two "mic clips" which were purchased on April 19, 1995. 99. That Josha Corporation, d/bJa Aabe's Family Discount CenterlAabe's Music Shoppe sold, beiween April 19, 1995 and April 24, 1995, four XLR transformers which were purchased on April 19, 1995. 100. That 7osha Coiporation, d!b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apral 24, 1995, one oudet adaptor which was purchased on April 19, 1995. 101. That Iosha Corporation, d/b/a Aabe's Family Discount Csnter/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one red hand truck (2-wheeler) which was purchased on April 19, 1995. 102. That Josha Corporation, d/b!a Aabe's Family Discount CenterlAabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, one silver hand truck (2-wheeler) which was purchased on Aprii 19, 1995. 103. That 7osha Corporation, d/b!a Aabe's Fatnily Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of two Peavey Full Range Speaker Cabinets, Model 115 International Series III BW, Serial E _ }�. ._..___. .__ _�._W � _ _ .... . . ._ .. ._ - - _ _ ._ . _ qb-75 ` Numbers: 7E-02992246 & 7E-02992247 which were purchased an April 19, 1995. 104. That 7osha Corporation, d/bJa Aabe's Family Discaunt CenterJAabe's Music Shoppe does not have any_ documents_evidencing-t�e-s�le-be�ueerr�prii 19�5�and � 24, � ___.- ------ - _ _— IggS of one Knight TD-40 Light Tree Stand which was purchased on Aprii 19, 1995. 105. That Josha Corpontion, d/b!a Aabe's Pamily Discount CenterlAabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of two Knight TD-30 Tripods which were purchased on April 19, 1995. 106. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of two leather bags wtuch were purchased on April 19, 1995. 107. That 3osha Corporation, dib/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documenu evidencing the sale between April 19, 1995 and Apri124, 1995 of two Knight SIide Mounts which were purchased on April 19, 1995. 108. Ttiat Josha Corporarion, dlbla Aabe's Family Aiscount CenterlAabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Aprii 24, 1995 of two 50 foot speaker cabies which were purchased'�on April 19, 1995. 109. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and April 24, 1995 of two 100 foot extension cords which were purchased on April 19, 1995. ll0. That Josha Corporation, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and April 24, 1995 of four 8 foot extension cords which were purcY�ased on April 19, 1995. 111. That Josha Corporation, dPo/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of one microphone siand which was purchased on April 19, 1995, 112. That Josha Corpozation, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale benveen April 19, 1995 and Apri124, 1995 of one microphone stand with telescopic boom which was purchased on April 19, 1995. 113. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of four 25 foot speaker cabies which were purchased on April 19, 1995. 114. That Josha Corpora6on, d/b/a Aabe's Funily Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1495 and Apri124, 10 96_75. - 1995 of one side music stand which was purchased on April 19, 1995. 115. That Josha Corporarion, d/b/a Aabe's Family Discount Center/Aabe's Music PP Y _ — _ ing- �-r�Pri3-i4, �riT2-4; ��_...--- Sho e does not have an documents evidenc' Zhe sale be�vree ---_ — 1915 of one Panasonic cassette tape recorder which was purchased on April 19, 1995. 116. That 7osha Corporation, d/bla Aabe's Family Discount Center/Aabe's Music 5hoppe does not have any documenis evidencing the sale between April 19, 1995 and April 24, 1995 of two Sunn Floor Monitors which were purchased on Aprii 19, 1995. 117. That Josha Corporation, dib/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of one red storage box which was purchased on April 19, 1995._ 118. That Josha Coiporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between Aprii 19, 1995 and Aprii 24, 1995 of one Boss PSA 120 Adapter which was purchased on April 19, 1995. 119. That Josha Corpontion, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of two guitar stands which were puzchased on Aprii"19, 1995. 12Q. That Josha Corporation, d!b/a Aabe's Family Discount CenterfAabe's Music Shoppe does not have any documents evidencin; the sale between Aprii 19, 1995 and Apri124, 1995 of one CRUZIN' sign with case wluch was purchased on April 19, 1995. 121. That 7osha Corporarion, d!b/a Aabe's Fanuly Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of one cord bag with 47 miscellaneous cords and adapters which was purehased on April 19, 1995. 122. That Josha Corporation, d/bfa Aabe's Family Discount CenterlAabe's Music Shoppe does not have any document� evidencing the sale between April 19, 1995 and April 24, 1995 of two surge suppressors which were purchased on April 19, 1995. 123. That Josha Corporation, d/b!a Aabe's Family Discount CenterlAabe's Music Shoppe does not have any documenis evidencing the sale between April 19, 1995 and April 24, 1995 of nine guitar cords which were purchased on April 19, 1995. 124. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between Aprii 19, i995 and Apri124, 1995 of two "mic clips" which were purchased on April 19, 1995. 125. That Josha Corgoration, d/b/a Aabe's Family Discount CenterlAabe's Music 11 ��- � Shappe does not have any documents evidencing the sale between Aprii 19, 5 and pril �4, 1995 of four XLR transformers which were purchased on April 19, 1995. 126. That Josha Corporation, dJbla Aabe's _ FamiLy_.D� �^ t^t-�°�fr�abe'�iVfusic "�� _._ ____ _ _..__ .- Shepge dfles-ave have any documeaCS evidencina the sale between April 19, 1995 and Apri124, 1995 of one outlet adaptor which was purchased on April 19, 1995. 127. T'hat Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and April 24, 1995 of one red hand iruck (2-wheeler) which was purchased on April 19, 1995. 128. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documenu evidencing the sale between Aprii 19, 1995 and Apri124, 1995 of one silver hand truck (2-wheeler) wYrich was purchased on Aprii 19, 1995. 129. That on Apri125, 1995 police officer M. Garvey and Geor;e Moschkau removed one Sunn PLC 816 Light Console from Aabe's Music Shoppe. 130. That on Apri125, 1995 police officer M. Garvey and George Moschkau removed two Sunn PS610 Dimmer Packs from Aabe's Music Shoppe. 131. That on Apri125, 1995 police officer M. Garvey and George Moschkau removed two 50 foot microphone cables from Aabe's Music Shoppe. 132. That on April 25, 1995 police officer M. Garvey and George Moschkau removed eight Par 38 light canisters from Aabe's Music Shoppe. 133. That on Apri125, 1995 police o�cer M. Garvey and George Moschkau removed eight 150 watt flood lights fzom Aabe's Music Shoppe. 134. That on April 25, 1495 police o�cer M. Garvey and George Moschkau removed fourteen light gel frames from Aabe's Music Shoppe. 135. That on Apri125, 1495 police officer M. Carvey and Ceorge Moschkau removed eight gel paper sheets from Aabe's Music Shoppe. 136. That on Apri125, 1995 police officer M. Garvey and George Moschkau removed one Knight TD-40 light tree with adaptor from Aabe's Music Shoppe. 131. That on Agri125, 1495 police o�cer M. Garvey and George Moschkau removed one Boss MA15A Powered Spot Monitor Serial Number 551423 from Aabe's Music Shoppe. 138. That on Agri125, 1995 police officer M. Garvey and George Moschkau removed one Ibanez IFC-60 Foot Controller Serial Number 300154 from Aabe's Music Shoppe. 12 - - qb-75 139. That on Apri125, 1995 police officer M. Garvey and George Moschkau removed one 100 foot extension cord from Aabe's Music Shoppe. 140. That on Apri125, 1995�olice officer_D�L_(3a.rueyaad-Cee ae-A4asetikaur�muvec� "" - --- - thres cor8 tofes from Aabe's Music Shoppe. 141. That on Apri125, 1995 police officer M. Garvey and George Moschkau removed one Rapco AB 100 switch from Aabe's Music Shoppe. 142. That on Apri125, 1995 police officer M. Garvey and George Moschkau removed one DeArmond VoIume Pedal from Aabe's Music Shoppe. 143. That other than the items listed in request for admission numbers 124 to 142, above, no further items were removed from Aabe's Music Shoppe. 144. That the items listed in request for admission numbers 129 to 142 above are the properry of George Moschkau. 145. That the items listed in request for admission numbers 129 to 142 above were sold to Aabe's Music Shoppe by Ronald Kies and two unidentified males on April 19, 1995. , 146. That on Apri120 or 21, 1995, Ronald Kies rehuned to Aabe's Music Shoppe and told store personnel that the items sold by him and two unideniified males on April 19, 1995 were stolen. 147. That on April 20 or 21, 1995, Ronald Kies toid store personnei that he wanted to buy back ihe items sold to Aabe's Music Shoppe on April 19, 1995 for the price of $135.00. 148. That on Apri120 or 21, 1995, store personnei from Aabe's Music Shoppe offered to sell the items purchased the previous day to Ronald Kies for $500.00. 149. That at no tune prior to April 22, 1995 did store personnel from Aabe's Music Shoppe inform the St. Paul Police Department that Aa6es was is possession of stolen merchandise. 150. That Aabe's Music Shoppe employees failed to pzovide the St. Paul Police Depar�nent with copies of the Pawn/Buy form evidencing the purchases made from Ronaid Kies before April 22, 1995. INTERROGATORIES 1. Tf you deny Request for Admission No. 1 to 150 above, please: a. state each and every fact upon which your denial is based, 13 96-75 ' b. state the name, age, address, occupation of each and every individual wfio will testify in support of your denial, and ------- __-- - c_. ----_ ideat� eaeir anct every docnmem which supports your denial. �, -. , ; �, i TIMOTHY E. MARX City Attomey � �� Gail gfield, #1 7 Assistant Ciry Attorney Attorneys for City of Saint Paul 550 City Hall and Court House 15 West Kellogg Boulevard Saint Paul, Minnesota 55102 (612) 266-8770 14 g6 �� 5 ' 1 �°� � � �� 96-75 � C� �`1 �+,,� j, r z vape SEP 29 ' 95 11 ��RM 5T PRIL POLICE I7EPqRTMENT n��o�� t..�.�.. __.___ �, sr. P�au�. pauc ___.s�nre- a�t4l�933-FT I_ mvt _ the__ui��-tar--qg �his - DurglerY, — . Univers.fty Av., AAbea, Th� purpase a , Ba�iet ttte victim fn recaveTing some p£ his praper$Y th�s burglarY. that h� and his vfte had loaat�d 4 Tha ��Yloring it�ma sa�re recoverad anr# turned aver f Sunxs i'LC816 Light Con�aZe 2 5e�nn P$�30 Dimmer Paek$ 2 50' mi� aab2ae 8 Far 98 light canisters 8 1541M Flapo lighta !4 L�ght gel frpmtrg 1 Knight '1`D-4g P.15 �� _ '" �t e second haad � aur meet, was to repnrfed takan j�� at this atore �� tn the qxnera I Ba�ee TIA15A Paaered Spa�gSfQnitartSN� 5�1423 i Ibc�n�z IFC-fr� Foct ConLral.ies 5Ma 30�t154 3 Corx1 Totse i 8�pca AB 10B eritich 1 De�rnrand Volum� P�d�l x�rpoke xi�h atare manag�r Sr.ensan. Er1k, mnd 4e tald m� ttaat he �ae $he persan vhn atcepted theae it�me #or aele. 3v�neon told m� t.laat he aaa id the p�r�an ar8�a he baught th� 1te�m� Srom 3.� iar �aw hYm aga3n. Ths� srict3,m atated thet tha rep,tacement oelnae ot the iteme recavere�+ et tRS3s time �s approseitte�tely B120fD. �•._•• r,._0 ou+g U rnett � Pmp [J CAU � ■ In Re Licenses of Josha Corporation d/b/a Aabe's Music Shop�e — lteee.e�•�EQ City's Exh. No. i "I � � �Sul6 u � onm � �� F�+h �} (rhBi � � � L� �4've � pra �aS3R m SF�' 26 'O5 i_� �RI9 - _ 'LiC= ;:_='�t^T'; ' fC � r ' F.9 — ' _ � oUPPLEF�6E►F'!'kf. 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SR., Lc�,a 6�3 r�.�lm�,�.� �.kA, 5 � , �*�., Sr. k��s� a'��$� Ps�t� 3� Q� '� cv"�C a �� C�n r 1�- o.n � �, y� �1:�.�a.t�-�. � � \I a-s� ��c��: -�j-n,;, . �ac3 � ; �1k.dG�.4-, � - ibo� , a. a.�.� o ,�cAr4..c. �CnC� CIYV JtiA.B�..Q1J , J i ,> �c1'1� ..� � � z -�� pW(�s-� , v � z 5�'ti^,;.. , � -1 ti -S$ , � "3YS�A Q� , 5 i� .��a < < '��3-fi438 • � �� , t� r�e.t , ��, t � � � 3�c� � � . 'ct � S�x� c�.� , �:r� ik r�as. 1'�nn► s�uv-�,-��► -5543 1 t-►1, 6-g t��it�st.'1C3CM � 9 .�iut�� - �1^�.."� cn-� l-t-t�-GS 3 ti"� 1'� � =.s��.z. i.,,rc�o -�, �� r I �L� :c.t�. �.s , � t , t�.71 rn � , 3vy��t s• 3�, �-�S. . � �. 't � O � • � A � o y b � w�� s�{ �' 1,�..� g ti4il�M r L'y � L.i GtU ❑ FdF � /tu6� J .� .�ti Vt� � � H�unSe a RPt+ ❑ Otlqr _ •� Q'+Yve �µ ezzsaR • In Re Licenses of J Corp • d(bfa Aabe's Music Sho_p�e —, /�¢�¢�,Q City's E�►. No. j _°EP 2u ' 95 11 � �:,HPI ST PALt POL:CE LEPRP,7T1�NT .. - .... �,nv� NqqAA71YE HERE w L 7 5 yo � b1 c�.c.� 4�0�,,,� c�-.x� - _. 4�V ��+�Cl�� t U�+\� tVC\ iY`' ��^,, rt�t�1�o� ��5� �' K�r � � bcu�� 41„•.,.,, ri-. ��:.� C� hva b0.t� ��k 3 � �r�,li1) �'Qc,r�G.�`� �LUmst�. 10 - t=,, �U , � b � t � _ ,:?�sso,r tv� , `� 3 G - �-� � � t...:s 1 r.. 5 - � �� -- ------ ---t _----_•_ ��--��---� — - - - - *-:3a:�r��c� __ts:]��= _ _ v�'�s �c'?st t,.�l �.e� 3 �v .� ; , �hQ.� �d - b.� Aa.t\ , Zhr,,.� �,.:A,� w, t,. Lc,.� �� f .Ac�r.lv� $C� � i '� .t,�,�� Olc�.,v,t�� S�T��trcc�lc°sr•c„� JCL,z3't" , a • �az.n i..J� t'�tU .r�s..c�r� t...sv�cs�..� . - l�a.. �c� �t .��-a� �- ,QL � G�Iso '1'1,� - tr�i.�c.`�. ti^�O..,e� G. \.�.1'�,'�-,.� "�i� fi1, � �`.-�t^=n'"`1� C^" �'JGv�� `ti'�'e'`� , 4`"Las-"� �� .w.� c,'� ��'�'1`� �`a"� �+�.t�s. C�.9.t.��.n�� 1..1� .� k.� W C�Q :�..L.1_ �¢x.x-w�tc_�Q Y`�v.d��cSr �� `�- �39..x�(1CRr\ 1J't"'��-z_ c�s — Cr.z,xr A� r�. v� �CS1 Y - t,.3 / o a; b � - �r..�,Y. tN� �-t ��. �- S 5 �,ti� c.�.3� . � CC�n�.�- �43 t�.n�� ..��rut. c�51�.w�c� i�.+ ..�v.-�P 1C1C:�t-k_ k h�,.. .��d cs��,� u �"s�. c��.,.,t . � �� 1.,�j c'�"y�_ Y\tD �Mv'1��tn� . �� kfM. C,,. iCV.v"�tr ltil o�Ac� � l��'C ` �-.cx�, � r �,v�b wc�a � -� cn.s. l�.�ti�w,� �--� �� . � '�C. 'CSSC�L�lf.tt/Y� CCfW{�,(3 a �C5'C1�._ � � St,�aefv�AC,vt t� '-j� {�e-_ �N. �a.n ,`�'�' "�h� n �, t� �M G vs.ts�l Cn.� �-� �a b�.D�r� v,�r��o.A L+��.�s�; c..��e,�'" bo ,�cy.n.-t�s.a. �c�P -��- ¢�cs�� G� '�t,�n -.e,�� d`CYti �]s.u1,p Wt c� L �p 4 ; .,,'i `T W` �� -..�� 1 �'\CS�CJ�hG�"�S'tt�Q ct. �nw� - 3v � u.i vxn U � � � � c�-� tnn�scnr�;,�` �t tt�, � � � � w�� W c.tl� C i.l„� ��. t��-.21� s. c.b �,,'Z..,,ti Ccrv�v�.nl3cr.."rta+n * '�ts�d C�t� �.�z,s..'^�cs.Et�: 1� t,��.A,� "Ihc�u�r... �..k�� 'x'�-� - `m�lc3 rn� . C ct�^P� A - �r�c.� - t r_r,_1�.c� 1�e.�.u.n�.� �-,s�i .�s;}�s �u'� � -�"' �,.�,�� .�.r� r��.- -� �t Ja �- �� -b'�tltist. ��a.n_pCnr�,S� - #t„-�c�`,. • ��C�.r�cu� "'� �nc� ^�v r`�-...1�a.ts ��C.Ct�;'`�-� �M1�.. Cl' .3-t..�� ,Tv� �)1.2,kr1 U Gc� a.� � tj 1�.� •. r�<_vtic,,,r,c�.�.Q i 0 LiC ID ................... 86161 qb-75 , STAT ..................... AC Business Name..,......... JOSHA CORPORATION Address .................. 1933 UNIVERSITY AVE W 2ip..... .............. 55104 ... Doing Business As........ AABE'S FAMILY DISCOUNT_CENTER/_AAHFv-'-3- �'5---- --- -- -- --- -- -- -- - -- -- - _ -- - - ---- I� - - License Name ............. SECOND HAND DEALER-SINGLE LOCATION Esp Date..,.. ......... 09/26/95 ... Insurance Carrier........ Ins. Policy Number....... Insurance Effective Date. Ins. Expiration Date..... AIOTE AREA ................ Tax Id ............. ..... SVorker Comp Exp Date..... Telephone ................ SFIAW23 SWEE23EY - OWNER ERIK SWENSON - MANAGER 2346544 645-1550 Press �C� to continue, 'P' to print, or 'R� to redisplay... Alt-Z FOR HELP� VT102 July 19, 1995 � FDX � 9600 E71 � LOG CLOSED � PRINT OFF � 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 Josha Corporation DBA Aabe's Family Discount CenterjAabe's Music Shoppe at 1933 W. University Avenue. � ,n �f�� ci� d7 ' Kri�`Schweinler, Chief License Inspector tar Public 1-3i—d� • M��n�.,�„�,s � 3.INDA K�Y �CERA� ' HOTAflYPUBLIC-MINNESQTA s . ..a ' Mq C9mmlasbn Eap�res,t�n. 3;.2�C0 Y fl}J1p�R(V�RM/y% . -_ � In Re Licenses of Josha Corporation � d/bJa Aabe's Music Shoppe — (�,�, City's Exh. No. � 96-75 Lic ID ................... 44670 STAT ..... ............... TR Business Name............ JOSHA CORPORATION Address .................. 1730 UNIVERSITY AVE W Zip ...... .............. 55104 Doing Business As........ AABE'S MUSIC SHOPPE__________�—___ �---------- - ----------- - -�;ieens� 3ia�e:�:.......... SECOND HAND DEALER-SINGLE IACATION E� Date..... ......... 09/26/95 ... Insurance Carrier........ Ins. Policy Number.... .. Insurance Effective Date. Ins. Expiration Date..... NOTE AREA ................ Tax Id ........... ....... 2346544 Worker Comp Exp Date..... 09f21/93 Telephone ................ 645-1550 Press 'C' to continue, 'P' to print, or 'R' to redisplay... Alt-Z FOR HELP4 VT102 �uly i9, 1995 � FDX � 96�0 E71 � LOG CLOSED � PRINT OEF � 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 Josha Corporation DBA Aabe's Music Shoppe at 1730 W. University Avenue. � nA � � 4 � / J�tu�,/� / 1 � ��'l�� Kri Schweinler, Chief License Inspector tN7i a�fy Public` /'� / `-(3 � $�3'AA.h.^O.�.NP.�:t�.A. i.. . . �:K\l�.'.� s::'= e:'ti'1 ; � ..`'Fu,�.f±.`viti �' '" � N07ARVPU0L3C-M'R0.ESOT.3 _:. A4y C�mlasion Ezpirsa J_2. 39, 2C�00 � S � • J x .�� 0 LL �� J � � a �•,= -� r _._ •�U�2�� i� � � � �:f �' ? �� . �, ��e��i � , ,� ;<; � ,. . ��. M°. ..�� . � . .� . � �� . �� Y� � �� _ � �� . �� `�„*�,� � � �� .� � ° 4 *,��, o �,>. �. � � � v r� � � m � � � � � � � �� .� � � � � � � �:.: ��t �. � � � � � � � _ �� °� � � ,� �- -� � � a� :� —`�.� � fl � 4 ��, � � � � a � s o� �� ,�, �� ""' � �°� �s � � � � � Lf" � �-�._ � � r- �i ri.. �n o S 5 C� �� ' J� ��J l� � v `� 3 U G� � vQ �1 � �� EX� IT . t_� � AABE'S MUSIC SAOPPE 1933 UNIVERSITY AVENUE ST. PAUL, MN 55102 _ --- — -- - -- ---- — ----- - - - - -- -- --- _ TIM PORIER I,OWERY HILL LAW OFrZCE 1900 H�'N1VgpIN AVENUE M.INNEAPOLZS, MN 96-?5 �: CORRESP023II£I3CE OF 9-15-95 CflNCERNIAIG GnORGE & DO?ZNA MOSCIs.KAU IIEAR TZM: I RECEIVED AND READ THE D4CL'�?ENTS YOU S£.*IT TO ME FROM TH� ST. PAUL D.A.. IN ADDITZON, Z SHOWED ALL Or THEM. TO ERIK SWENSON, THE MAISAGSR OF ST. PAUL AA3E'S. QUTTE FRANKLY TIM, ERIK AND T ARE HOTH ASTOUNDED PT T�E RIDICULOUS ASSERTIONS CONTAFNED TN GEORGE'S LETTE3. AS I TCLD YOU EARLIER,I SiJSFECTED GEaRGE'S WiiOLE AFPROACFI WAS PROBA3LY ATM.ED AT GETTIbIG EVEN POR MY DECTSTON NOT TO HOOK HIS BA�`ID YEARS AGO. TAIS, QUITE DRAMP.TICALLY, EMPHASIZES THAT. THE REPORTS FROM T2iE PObICE �FFICERS SEEM ACCliRATE WITH SGME SMALL QUESTIONAHLE COMMENTARIES BY THE FZRST OFsICER. I WILL EXPLAIN T'HOSE AS WE PROGRESS. TIM, I WTLL TRY TO A135WER EVERYTHING IN �RDER OF PRESENTAION, HERE IT GOES: PAGES 1,2 & 3 ARE CflVER LETTER AYD pUR LICENSE INFORf4ATSON- NO ADJUSTMENTS. PAGE 9 I$ A REPORT BY SERGEANT PETERSCN THAT SAYS THE COMPLAI23ANT STATEII" TWO 5PEAKERS, LIGHT TAI?ODS, CABLES AND CORDS, A COMPIITER CONTROL U,IIT AND DIi�R1ER PACKS" WERE S10LEN ON APRZL 16, 1995. 2�IOTICE NOT ONE MENTTON OF ANY BOSS YONITOR, IBANEZ FOOT CONTROLLER OR RAPCO A/H BOX APPEA.°,�D Iti THIS OR ANY OF ^tAb SUB5EQLJENT POLICE REPQRTS UNTIL GEOR�E PICKED THEM LIP FROM OUR STORE ON APRZL 25. IN ADDITION, G�ORuE CL•AIMS ZN HIS LETTER TO HAVE MARKED ALL FiIS aQUSPMENT WZTI: HSS IATITIALS. ODDLY ENOUGA, AE NEVER BOTHERED TO MEAFTION Tri?T ='� RHE POLICE OR TO l+� OR, APPARENTLY, MY STAFF. 3UST OAIE MORE THING ON THIS PAGE- THE COMPLAINANT DID I�IOT SHOW THE LINEUP, TIiE OFFICER DID. I'M SURB THIS IS A'PYPO. PAGE 5& 6 ARE OFFICER MAYER'S RE?ORT. SOME INTERESTING FACTS ARSSE IN THIS- 1. THE COMPLAINANTS TOLD THE OeE'ICE32 THAT THE�WERE GOING TO � � In Re Licenses of Josha Corporation ��d/b/a Aabe's Music Shop e — City's Exh. No. I� 96-75 AS MAbiy 2ND EiAbtD STQRES& PAWDt SxOPS A5 POSSIHL£. HOWEVER, AT THE E'�D OF T:iE S2'ATEMEPIT TFiEY SAY THEY CALLED OTHER STORES AND WERE TOLD AABE'S SELLS STOLEN MERCHANDISE. EVE:1 IF SUCA A THING WER£ TRUE, Wfi2CH IS ZS ABSOLUTLLY NOT- NO STORE WOIILD_ _$$_STUP�_EDL4LIGFi -TO -SAY--.SISGH--A--��F�76 �@- Pd�FYOlvir-bE-� - ------- 3-- - — AL4NE A SfiFtANGEI2 ON 'PHE PHONE? AAHE' S HAS NEVER BEEN EVE*T � ACCUSEI7 OF DEALZIIG Z1Q STOL£N MERCHA.*dDZSE IN AN EXCESS OF 7 YEARS IN BUSINESS ( 2 IN ST. PAUL). i CHALLENGE MR. MOSCF�CAU TO GIVE � NA.�S AND NUMBERS OR FINB HIMSELF DANGEROUSLY CLOSE TO SLA23DER. s BESIDES, IF AAgE`S SELLS ALL TAE STOLEN nQIIIPMEAFT WH`f WASTE fiIME WZTH ALL THOSE OTIiET2 5TORES? IT IS CLEAR 'PFIAT ERIK TRZED fi0 QUALIFY THE SELLERS OF THE EQI7IPME�IT-MAKIbIG THEM ASS$MBLE THE MAJOR PIECES TO SE SURE THEY tJNDERSTOOD HOW IT WORKED. IN t�.IIDITION, ON 4-21-95 WHEN THE THIEr, K2ES RETL3RNEB TO REPURCHASE THE EQUIPMENT ERIK_NOT ONLY REFUSED RO SBLL IT TO HIM, Bi1T EXPLAINnD EVEN IF HE WANTEII TO SELL IT TO HIM, THAT KIES WOIILD N'nED TO WAIT 10 BUSTNESS DAYS BEFORE DOIIQG SO. THE REPOE2T STATES THAT IT WAS AGREED TO MOVE THE bQIJIPMEPiT FN QETESTION TO THE BAS£MENT. THAT TS TRUE. WHAT IS NOT STATED IS THAT GEOi2GE AND I AGREED TO DO SO BECAtTSE WE ML)TUALLY AECIDED THAT BECAtJSE THIS WAS OUR GRAI3D OPENING IT WOULD BE A TREMENDOUS IiARDSHIP ON MY STAFF AS VIELL AS GEQRGE, DONVA AND A,IY OFFICER TQ DO THIS ON PERIi�PS 'THH BUSIEST DAY IN OUR HISTORY. WIIEN THE MOSCFixAL?S RETU?2NED WITH A23 OFFZCER AND A NEU1 STORY I WAS BOTA SURPRISED P.bTD, QUITE FRA.RCLY, ANNOYED. HOWfi'VER, BQTH ERIR AND T DID pIJR HnST TO ACCOMODATE HOfiFi OUR CUSTOMERS AND THE INVESTIGATOR. OFFICSR MAYER APPAREYTLY WROTE WE tdERE UNCOOPERATIVE 2HEN DECZDED THAT WAS A HZT 3'QO STRONG AND DECSDED TO CHANGE ZT TO FAIRLY UNCOOPERATZVE LATER. FRANKLY, I THINK WE DID ADMIRABLY CONSIDERIi�IG THERE WAS ONLY 02� OT':iER EMPLQYEE IN THE ENTIRE STORE QTHER THAN ERIK AND MYSELF. Afi THE fiIME WE PROBABLY HAD 40 CUSTOMERS SAOPPZNG, REGZSTERFNG r'aR PRIZES, GETTiNG FOOD, POUR TELEPHQNE LINES CONSTANTLY RIDFGTNCs, A CHARICATiJRE ARTIBT DRAWZ23G THE GUESTS ( BY THE WAY, THE MDSCHKAUS AVATLED THEMSELVE5 OF TkE ARTISTS 5ERVICES NO LESS THAN 4 TIMES.) AND DEALING WITH THE MOSCHKAU MATTER AS 41ELL. 2 WQND�R iF OFFICER MAYER HAD TAKEN STATfiMENTS FRaM 40 DZFFERENT INDIVFDUALS AT THE SAME TIME IF SOME OF THOSE PEOPLE MIGHT HAVE FELT SXE WAS " FAIRLY UNCOOPERATIVE ONE OTI3ER SIDELINE TO TFiIS IS THAT OFFICER PETERSON, WHO SAOWED ERTK THE LINEUP APPARENTLY FBLT GOOD EI30UGH ABOUT US THAT HE SUBSEQUENTLY RETURNfiD AND SOLD SOME EQUIPMENT TO US AND IS NOW A CliSTOMER. 0?dE FINAL ITEM OF NQTE IH Q�'FICER MAYER'S REPORT IS THAT AFTER GEORGE AND ERFK MOVED EVERYTHING THE M�SCHKAU'S CLAIMED WERE g6-75 THEIRS SHE LZSTED TF� SUNN C4hTecOL:.�R, 2 DII�R�'iEFt FACKS• P� C� LIGHTS ON A BAR, 4 KNIGAT TRIPOD STA.*7DS AND A DE.�RMOND PEDAL. THESE ARE ALL ThG TAINGS GEOF2GE PUT IN OIJR BASEMEI3T ANB VERIFZEII WZTH 2EiE pFPICER WERE AZS. THIS STANDS IN STARK CONTRAST TO HIS LETTER 5TATING THAT E� AI4D DON.FA VALIANTLY FOtTGHT BACK OUR — -- ATTEMPTS TO COT7EF2_UP_F:I$ _Di_SCQVEBY._OF__TI�- QTHEB-_ITF.�S-�e cmamt�n -- Fi£ FOLStiD TF.AT DAY &EFORE OFF2CER "IA`!Eg ARRIVED. OF COtJRSE, DNCE AGAIN, THE COMPLAZNANTS FAILcD TO ME?ITION ANYTI3ING ABOUT ANY OF THEIR ITEMS HEING t'SA.RKr.D WITH GSORGE'S Z21I2'IALS. OFFICER MAYER DiII S'PATF, T'dAT 4u'E TOLD HER A DIFFEREIFT STORY THAN GEORGE AND DONNA SAID WE TOLD THEM. OHVZOUSLY, IT 5EEMS LIKE TLiE DIFF'EF2ENCE IS NOT IN ERIR'S AND MY STORY BUT IN GEORGE A13D DON23A'S RENDITTOI3 WITH OFr'IC�R iIAYER. PAGES 7, 9& 9 YIELD NO RELEVANT INFORMATION I CAN SEE. PAG£ 10 I$ THE INITIAL POLZCE RSPORT. �NCE AGAIN TA'n MOSCAKAUS FAIL TO GIVE A 12BPORT OF THE BOSS MONITOR,ZBANEZ CONTROLLER, RAPCO A/B BOX OR FOR :HAT MATTER, T?IE FACT THA2 GEORGE CLAFMS TO HAVE PUT AIS IIVITIALS ON EVERY'SF?ING HE OWNED. 2T WOULII BE A SHA�'�lE T� CONFIISE THE POLICE WITH THE PROPE'-2 INFORM-�TION. PAGES 11 ?'U 14 REVEAL NOTHING BiTT TO REITERAT£ TIiE LIMITE� AMOUNT OF EQUZPMENT TSE MOSCh"XAi3S F2EPORTEII AS MISSING. PAGE 15 SHOWS A LTST OF ITEMS TT HAS CUR?OUSLY GR0�•4N LARGER SINCE OFFICER �Y�R TCOK TFiE INTTIAL REPORT AT A.�1BE'S. TAE EXPLAIdATI03J FOR THSS IS SIMPLE_ GEORGE CAM� ZN TO AA3E'S SSVERAL MORE TI?�IES DURING TFiE WEEK AND BEGAN TO DEMA2ID ADDIfiIONAL EQUIPMEF3T BE TURISED OVER TO HIM• FlE BECAME PROGRF,3SIVELY M�RE FiOSTILE. SnOULD ERIK EVEN DARE TO ASFC GEORGE TO ZDENTIrY ANY PIECE OF EQUFPMENT HERETOFORE UNNOTICED GEORGE'S REPLY WAS SIMPLX "ARE XOU CALLING M� A LTAR"? sm'£ N1ERE xa�r . UVFORTUNATELY, ERIK WAS FORCED TO DEAL WITH GEORGE'S TANTRUMS ALONE BECAUSE I idAS WORKING IN Qi3R MINNEAPOLIS STORE MO5T OF TXAT tVnEK. LECAUSE OF THSS, I ADVISSD ERIK TO MAKE THE BEST OF A BAD SITUATIO23 AND TRY TO APPEASE GEORGE'S DEMANAS EVEN IF T?iEY WERE UNREASONABLE. SOME THINGS ARE NOT WORTH THE FIGHT. IT SAOULD BE MADE CLEAR THAT TiiE HOSS MQ2vFTOR WAS PURCF�ASED NOT HY ERZK ON 4-19-95 BUT 9Y ME ON 4-18-95. ENCLOSED YOU WILL FIND MY COPY OF THE PURCHASE DONE DURZNG OUR MOVE AT TAE OLD STORE. DSD 23pT EVEN KI30W THI5 WAS PART QF THE CLAIMED MERCHANDISE UNTIL I READ THE INFORNfATION YOU SENT ME ON 9-I5-95. I THOUGIIT TT HAD HEEY SOLD. SINCE I DIAN'T WORR IN ST. PAITL DiJRING GEORGE'S SUBSEQt]ENT VTSITS, I DIDN'T DEAL WITH HIS CONTIKUIIYG DfiMA2�iDS. IF I HAD THE CONFLISION QVER SEV�RAL OF THESE ITEMS WOLJLD HAVfi' BEEN SOLVED IMMEDIATELY. � 96-15 PAGE 16 IS THE POLIC5 FORM FILLED Ot3T BY ERiK. IT CCRR?SPaNDS COMPLERELY TQ Tk'E RSPORT M.ADS TQ TtiE PQLICE HY GEORGz. TH£ CABLES WSRE NOT RFsPQRTED SEPARATELY HECAUSE THEY ARE AN ZNTEG.T2AL PART OF THE LIGHT SYSTEM AND WOULD NATURALLY GO WITH IT. THEY AAVE NO RESALE VALUE OH TIiEI� OT+7N. WSEAF YOU BIJY A CAR_YOU DO ?IOT S&PARATELY. THE S� A?PLZES I?':RE• PAGE 17 IS THE NEWLY GROWN LIST E'nOM GEORGE THAT APPEARED ' MYSTERZOUSLY IN THE D.A.'S FILS. TH25 LZST WAS N�VE`t PRESENTSD - TO US OR TO TIiE POLiCE AS FAR AS I KNOW Ifi. I ASSURE YDU, THr1T HAD THE C6MPLAINA3JfiS GIVE23 t3S THZ5 LIST I23ZTIALLY ZT @I�ULD I?A�1E SAVED EVERYONB A TEtEME2dD0US A.*IOUNT OF TROUBLE. IT WOULD SEEM THAT TI3E LAi2GER APQENDED LIST WAS COMPILED 023LY AFTER GEORGE CAME IN Ot3R STORE AND TOOK NOTBS QN THE MODELS ANB SERIAL NUMBERS OF TF� ADDITiONAL PIECES HE WISHyD TO ADD TO FiI5 COLLECTIOM. IT FS NOT MY CONTENTION THAT GaORGE TOOK ADVFNTAGE �F ADI OPPORTi3NITY TO TAKE EQIIIPMENT THAT WASN`T FIlS, I3CWEVER, ST CERTAINLY RAISE5 SOME MO5T DISTURBING QUESTIONS. TC THIS DAY WE HAVE SEEN NO DOCUMENTATION AS TO WHETHER THE uOSCIuCAUS ACTUALLY OWN ANY OF THE EQUIPMa:tT THEY HAVE CLATMED. PAGE 18 TO 20 FiAVE 3+t0 RfiLz',VP.2IT IAIrORMATION ESCEPT TO REITE:tATE THAT ERIK IDENTIFZED AND COOPEc'It1TED ZN EVERY WAY TO ALLOW THE APPREHENS20N OF RONALD KIES, THE REAL PERPETRATOFt. IT SHOULD BE NflTfiD THAT RIES' GIRL�'RIED CALLED ER�K AND THREATE23ED ALL OF US BECAUSE OF AZS CAPT(IR�. W'E WERE FiAPPY TO` COMPLY. IT WAS THE RSGHT THFNG TO DO. IT WOULD SEEM THAT THE MOSCHKAUS WOULD H� APPI2ECIATZVE. CLEARLY NOT! PAGE 20-24 ARE GEQR@E'8 ALLEG�D "DOCLMENTATTON OF EVENTS". I WILL PROCEEA THROUGH THIS WITH AS M'JCH CLARIfiY AS POSSIHLE. DQN23A MOSCHKAU CA.''4S IIS`I`O AABE' S ALONE AND SPOKE TO Qt3�i SALEPERSON, CHARLIE DOROW. SFiE GAVE HIM A COPY OF THE POLICE FORM IIESCRI$I2SG THE LIGHT SYSTEM SiiE SAID [d�S STOLEN. HE IMMEDIATELY TOOK HER BACR TO TEE E4t3iP•'"�ENT AND SHOWED IT TO HER. HE CERTAINLY DZD NOT TRY TO HZD�. AN':THING FROM HER HI3T LED HER DIRECTGY TO THE EQUIPMENT SHE DESCRiBED. THE CAHLES, 5TANDS, LIGHTS AND ALL RS:�?.:ED ITEMS WERE TOGETHER AND ACCOt3NTED FOR . DONNA LEFT APID RETt7F�N'nD f�vITH GEORGE WfiG PROCEEPED TO EXAMINE THE EQUIPMENT. FT WAS AT THIS TI:�'E CHARLIE TOLD ME 43FIAT WAS HAPPENING AND I WENT TO TALX TO GEORGE AND DOHNA, QNLY ONE TIME IIID WE IIISCLJSS A MZSSING 5TAt1D AND I ASSURED THE COUPLE THAT IF WE HAD BOUGFiT THE STA23II IT WOULD STILL BE SN THE STORE SOMEWHEF2E. WE SUBSEQUENTLY DID FIND IT A.'rD IT WAS PUT IN THE BASEMENT WITH TAE OTHER ITEMS A5 OFFICER MA`r�'S REPORT STATES. AS TO CHASING THEM OUT OF ANY PARTICULAR ROOM THE ONLY TERM I CAN USE TS ABSURD! AFTER ALL, IF N� DID HAVE STOLEN MATERIAL SN � F`�ri : HHEES PIUSIC �HOPFE ST FAUL I'il'7 FHGNE N0. � b1= 5-35 1«� gb-75 APIOTHER ROOM WIiY WOULD I"CF3�SE" THEM DZftECTLY I23T0 ST AS THEY HAVE STATED? FOTSNn-.-NQTFE nF ------ - -Hd-RE£�'�:�2A-T8-'£� Q'Fi�.E� �'£�4S-T-�"rrY--LvAZM--TO--HAVE --- THEhI WERE MARKED WITH ANY ZNITIALS AND .�T LEAS`P 3 OF TFiEM I KDtOW fiAD BEEN RENTAL CAHLES FOR PIO23TIiS . PAGE 22: GEORGE DESCRISES rINDING 2HE BOSS MA15A MOI�IITOR AAI1) CLAIMING IT AS FIIS OW23. THZS IS N4`� S0. AS I HAVE STATED EARLZ�R, I REMFu�SBER DISTINCLY BUYING THAT ITEM OPI A SEPARATE DAY ENTZ�LY. I Rai�BER VIVIDLY BECAUSr. 2 HA� USr.D fiFL EXAC'� MODEL FOR YEA.RS LIYSELF. IN ADDITIOIJ, AS STATEII EARLZER I Fi-AVE ZNCLUDED TIiB DOCL3ME23TATION FOR TI�E PURCHASE . NEITHER GEORGE OR DONNA MENTZONED TAIS ITEM &ECAUS� I WOULD FiAVE QUESTIONED 'fHEM CONCERNING IT. THE MONITOR wAS NOT TAREN TO THE BASEMENT APID DID NOT A?PEAR ON OFFICER MAYER'S REp��T THAT DAY. IN ADDITION, NE:THER TH: IBANEZ IFC60 FOOT CONTROLLER OR THE RAPCO AB Si�1ITCH GiERE DZSCUSSED ON TfiI5 DAY. AS W�,S TRLTS WITEi TEiE SOSS MONITOR, GEORGE WEVT THROUGH THE 3TORE ON ANOTHER DAY AND WROTE DOL7AI MODELS A1vD SERFAL NUMBERS ,ON TfiAT AAY. ZT SHOULD BE NOTED THE E2APC0 SGiITCFF T?�IAT ALLEGEDLY WAS GEORGE' S WAS QDIE QF QUR NEW SWITCHES. WE KEEP THESa IN S'rOCK• ONCE AGaIN, GEORGE Mr1DE ONE OF F?IS "SHOPPING TRIPS" 023 ANOTFiER AAY AND APPAe�ENTLY DECIDED TO ADD THIS ITEM WH�TxFR IT WAS HIS OR IZOT. A3 TO THE IBANEZ CONTROLLER- xFiIS WAS IrI THE BOX WZTH TFiB CABLES FROM THE LZGHTS. HO`�JEVER, I30 ONE EVEN NOTICE� IT UNTIL THE BOX WAS UAiLOADED DURING OUR MAD RUSii TO GET THI2dGS ON DTSPLAY F�R THE WEEKEND. TIiE CONTROLLER WAS PUT BcHIND THE CQUN'i'ER, IN PLAIN SFGHT. HOWEVER, IT WAS NOT TO BE PUT ON ON THE SALES FLOOR UNTIL IT WAS INVENTORIED AND PROCESSED. AT THE TIME ERIK BOUGHT fiHE � LIGHTS FROM KIES HE HAD NO IDBA, NQR APPAf2ENTLY DIIl KIES, Ti?e'1T TAE PEDAL t3AS THER&. GIVHN A NQRMAL STATE OF AFFAIRS, THERE WOULD HAVE BEEN TIME TO PROCESS THINGS ZI1 AId ORDERLY FSiiZOI�I. HOWEVER, DU� TO THE FACT THAT WE ALL WORKED NO LESS TIiAN 100 HOURS PLfJS TFiAT WEEK WE SIMPLY HAI? t30T GOTTEN AROUfI➢ TO PUTTI*7G TAIS PZECE IN ��NENT4RY. I2' WA9 SiTTING WITH Ai LEAST A DOZEN OTHER PIECES WE HAD NOT GOTTEN 20. I RECOGNIZED GEORGE WHEN IiE CAME ZN A13D t3AS AS GRACIOUS AS I COULD BE TO HE AND DONNA CONSIDERING THE CHAOS ASSOCIATED WITH A GRADID OPENING. I CHOSE TO GiVE TAEM WiiAT ?� CALL "TIiE GRAND TOiSR" OF THE WHOLE BUILDING WHICFI DID INCLUDE TFL WAREi30USE WFTEz'tE G9E ARE ADDING AN ADDITIONAL SHOWROOM. I HOPED THAT HYG�NES WQULD BE BYG023fiS AND AT TfSAT TZi�E IT SEEMEP AS THOi3GH THAT WOULD HApPEN_ , IF IT WAS PiX INTENTZON FOR `PHE EMPLOYEfiS 20 HIAE APIYTHZNG I'1' WAS COMMtJNICATED BY £SP BECALTSE IN THE MIDST OF THE MELEE I DIDN'T � 96-?5 HAtTB TII� TO TALR TO EITH£R ERIK OF2 C?3ARLIE, WI'.O. �Y THE WAY, WERE BURIED WZ�H CtT9TOMER5. GEORGE E%PRESSED CONCERN THAT HIS EQUZ°I�'fENT Bn TA-�{EN a�'�' TF=E SiiO4JROOM FLOOR AND I AGFtEED. I SXPLAZNED TFiAT WFiEN WE SUY ZTE.*3S --- --- — �i-S&T£ �Y�AGk'£3Y TO - CQNtPt3TSR AtiFY �i�P:T h=fl'PH�MG `$E SOLD B�FORE TEPI IIAYS. HOW`fiVER. � UTIDERSTOOD FiOW FT.E F'ELT. WE BOTH AGREED TO STORE THE THI:IG& EE SP.ITJ WERE HIS TN THE BASEMENT AND THAT CsIVEN Th'E FACT THAT OUR GRl�3D OP�NZNG WAS HAPPENING HE FIOULD COI".E BACK TO SETTLB EV£R'f:=�IhG DI�F �'4DNDAY I DID SUGGEST WE CAi.L R4NALD KIz5 A.KD OFFER TO EQUZPMENT WITH THE IIdfiEAITION T?3AT WH£N H'� C-AME THE POLICfi A23D HAVE AIM APPI2EHENDED. I NEVER CQURT .. AFTER ALL , GEORGE WOULD BS Tk'E ONE 'i'C US. PAGE23: SELL BACK TFTE Z,j W� WOIILB CALL SAID ANYTHI.TG ABOUT BRING CFiAi2GES NOT OH THAT I fiAD HAD TZME TO CASUALLY Pft�P�E �SELF A TiQT DOG::: TIiE ASOSGHK�US ANB TfiEIR Ciili<DRS+\' A2'E Na LESS THRN A DOZEN OF Th�M DURTNG THEIR VFST'T: ! THIS COMMWYTARY 021L'I 5AOWS HOt7 TRULY PETTY TFiESE PEOPLE ARE. � Z SPOKE TO QFFICER MAYER SRIEFLY SUT WHE:"j SHE HAD SPECiFIC QU'ESTIONS CONCERNING TAE PURCFIASE I DEFERRED THE DISCUSSION QUICKLY TO ERIK DUE TO TF� FACT THAT I WAS N�ITI�ER IN 1H5 STORE WABIi T'ri£ ES}UIPMENT WAS PURCFiASED NOR HP.D I DEALP IN ANY WAY WITFi MR. KFES A'£ THAT TZME. ERIK, HOWEVER, DID GIVE A FULL DESCRIPTI�Y AP1A PRd�IDED T`�£ POLZCE FORM HE FILLEI3 OUT THAT DAY. GEORGE CLAIMS TFie1T TFiE �'ORM WA5 STILL IN TFtIPLICATS. THAT TS TRUE. `SHEY ARE ALWAYS IN TRIPLICATE BECAUSE WE ARE REQUIRED Tfl ECEEP THE POLICE FORMS INTACT FOR OUR RECORDS. THEY ARE ISSUEA TO I3S iAi TRIPLICA2E- ONE POR US ?�ND 2 FOR THE POLiCB, SFFO'JLD THEY �V'nR REQUTRE THEM. fiHc FdRM HAS THE IMPRI]QT QF RONAL� KIES DRIS7ER' S I,ICENSE AND HIS SICsI3ATLR2E. AIQW, UNLnSS HE WAS BEING STO�.+'� ALONG WITH THE OTHER THINGS GEORGE CLAIMS WE �+1EF2S HIpING WE WOULD NOT HAVE BE�N ABLE TO REPRODUCE IT WI2HOUT HIM BESNG fiFiERE• IN ADDITION, YOt3 WiLL FIND THAT THE POLICE FORMS STATE ERIK BOtJGHT 4 KNTGE�T TRIPOTJS, NOT Ki7IGHT TE30 SPERICER STANBS' T� TB30 E BOt3GHTK4�STANDSTAND RETURNEEFOUR STANDSERE TD40'S OR AGAIN, THE BOSS MdISA AND TH5 IBANEZ CONTROLLER HAVE BEEN COVBRED. GEORGE ALSO CLAiMED THE P�T�'� 5TRIP WAS HIS BECAt3SE IT AdD TAPE ON THE BACK OF IT. BRIK REPLIED THEY ARE�ESYO D�L�ING �FACTORY THAR WAY. GEORGE REPLIED PREDICTABLY, 96-75 LZAR"? APPARE:dTLY HE FEELS TAiS IS PftOOF QF Ot�1NERSkIP. AS TO THE COIQFUSION OPI THE SdLD OR RENTBD EQtJZPMENT- GEOFtGE KEPT STATI:JG WE WERE MISSIbiG A STAND. ERIIC 3AID MAI'HE IT WAS SOLD BtiT -- _. _..- WE. �4IILD--G�--T�-�AiF'BRNNiA�F�43 fi�ZNNE�;PE?L�S �E�ERE=�:� _ — RECfiPTS ARE ECSPT. WE DID NOT HAVE BNY INFO:�MATSOP7 Bt3T GaORGE' S T.J012D Afi TFiE TIME THAT THERE WAS AZIOTHER STAAID TO BE F'OtTA+�D- AS YOiT CAN SEE BY THE POLICE �EZ'OR^sS, WE BDL3GH'f 4 STANIIS AND 4 _ STAT3DS idE� F�iTDTD QIS 4-19-95 A:ZD CO33F'ZR*iSD BY OFFFCER MAYER. AS TO THE QUESTZON 0€ THE MQVING OF TAE STO�u AND OLIft LICENSE- Tiil& TdOULD NOT A2SD SHaI1LD NQT CONCERN THE IdOSCHiCAUS UNLESS, AS THEY HAVE SHOWN, TFiEIR GOAL IS ONi,Y ONE OF VIA(DICTZVENESS. 03VIQU5LY, TIM, WE ARE AND CONTIiIUE TO BE A GROWEPFG VIBRANT BU52NESS AND NOT ONLY ARE 4VE NOT ZNTEF2ES2'ED IAF D�ALING ZN STOLEN PROpERTY ( OUR SALES ARE 75� NEW ITEMS) BUT G1E DON`T HA� TIb7E-TO FOOL WITX THIS TYPE OF NONSE*tSE. GEORGE IS 5IMPLY ACTTNG ON A GRUDGB HIS Y.AS WRONGFULLY CARRIED FOR YEARS. I A'rF230T THE FIRST REC£PIENT OF HIS MISBSGOTTEN ANGER NOR SHALL I BE xAE LAST!! CALL ME IF I CADI ADD ANYTHI.iG ELSE• S INCEi2ELY, ��`L"�' \ J . SkAGIbt SLIEBNEY AABE'S MUSIC SHOPPES ��< �� -� � �..� �� c�. i � ` �� v ��- � QM'L . �•�./� rt" "�9-�A. , �� ` "�'�. �� ,� � ' -��- a� � ��5�� , � � � ��=� � � � �� c�..., .�-�.Q. ��1 � � �� , � .-�;,� � a �..�.-� , c�� ; �s � �: s�� ! (� � �, ? r w � . STATE OF NIINNESOTA COUNTY OF RAiviSEY In Re the Matter of All Licenses held by Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe for the premises located at 1933 Universiry Avenue West, St. Paul, Minnesota OAH Docket No.: 91-2102-9995-3 g6-75 BEFORE THE COUYCIL OF THE CITY OF Sfi. PAUL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUYIENTS To: Gail Langfieid, Assistant City Attorney, Ciry of Saint Paul, 550 City Hail and Court House, 15 West Kellogg Boulevard, Saint Paul, Minnesota 55102 Josha Corporation, for its Response to the Ciry of Saint Paul's Request for Production of Documents, states and alleges as follows: 1. All receipts, statements or other documents evidencing the purchase of the following items: 2 Peavey Full Range Speaker Cabinets, Model 115 International Series III BW, Serial Numbers: 7E-02992246 & 7E-02992247, 2-50 foot mic cables, 8-150 watt flood lights, 14 light gel frames, 8 gel paper sheets, 2 leather bags, 1 Boss MA15A Powered Spot Monitor; Seriai Number: 551423, 1 Ibanez IFC-60 Foot Controller; Serial Number: 300154, 2 Kniaht Slide Mounts, 2-50 foot speaker cables, 3-100 foot extension cords, 4-8 foot extension cords, 3 cord totes, 1 microphone stand, 1 microphone stand w/telescopic boom, 4-25 foot speaker cables, 1 side music stand, 1 Panasonic cassette tape recorder, 1 Rapco AB 100 switch, 2 Sunn Floor Monitors, i red storage box, 1 Boss PSA 120 Adapter, 2 guitar stands, 1 CRUZIN' sign with case, 1 cord bag w/ 47 miscellaneous cords and adapters, 2 surge suppressors, 9 guitar cords, 2 mic clips, drumsticks, 4 XLR transformers, 1 outlet adaptor, 1 red hand truck (2-wheeler), i silver hand truck (2-wheeler), 1 briefcase for light console, 2 6 ft extension cords, 1-20 foot headphone extension cord, 3 misc. cables, 1 exua knob for Knight TD-40 and Knight TD-30 Stands, and i power strip. RESPONSE: Josha objects to furnishing any document not required by Section 355.04. The City has the Pawn/Buy form of the documents purchased. 2. All receipts, statements or other documents evidencing the sale of the following items: ■ In Re Licenses of Josha Corporation �� /b/a Aabe's Music Shopge City's Exh. No. �`� � � qb-75 2 Peavey Full Range Speaker Cabinets, Model 115 Internauonal Series III BW, Serial Numbers: 7E-02992246 & 7E-02992247, 1 Kni�ht TD-40 Light Tree Stand, 2 Knight TD-30 Tripods, 21eaffier bags, 2 Knight Slide Mounts, 2-50 foot speaker cables, 2-100 — ---- £ee{ exte4sioa-esrds 4-8 fs3e� exte�sisn ctx� 1��epkone sFaa��-taieiep�aae-- stand w/telescopic boom, 4-25 foot speaker cabies, 1 side music stand, 1 Panasonic cassette tape recorder , 2 Sunn Floor Monitors, 1 red storage box, 1 Boss PSA 120 Adapter, 2 guitar stands, i CRUZIN' sign with case, 1 cord bag w/ 47 misceilaneous cords and adapters, 2 surge suppressors, 9 guitar cords, 2 mic ciips, drumsricks, 4 XLR transformers, 1 outlet adaptor, i red hand truck (2-wheeler), and 1 silver hand truck (2-wheeler). RESPONSE: Josha has previously denied the sale of any of these items. 3. Statements, lists, or other documents evidencing the items turned over to George Moschkau and Officer Garvey on Apri125, 1995. RESPONSE: 7osha has no independent list. 4. Any and ail computer records which evidence the purchase or sale of the foliowing items prior to Apri122, 1995: 2 Peavey Full Range Speaker Cabinets, Model 115 International Series III BW, Seriai Numbers: 7E-02992246 & 7E-02992247, 2-50 foot mic cables, 8-150 watt flood lights, 14 light gel frames, 8 gel paper sheets, 2 leather bags, 1 Boss MAiSA Powered Spot Monitor; Serial Number: 551423, 1 Ibanez IFC-60 Foot Controiler; Serial Number: 300154, 2 Knight Slide Mounts, 2-50 foot speaker cables, 3-100 foot extension cords, 4-8 foot extension cords, 3 cord totes, 1 microphone stand, 1 microphone stand w/telescopic boom, 4-25 foot speaker cables, 1 side music stand, 1 Panasonic cassette tape recorder, 1 Rapco AB 100 switch, 2 Sunn Floor Monitors, 1 red storage box, 1 Boss PSA 120 Adapter, 2 guitar stands, 1 CRUZIN' sign with case, 1 cord bag w/ 47 miscellaneous cords and adapters, 2 surge suppressors, 9 guitar cords, 2 mic clips, dmmsticks, 4 XLR transformers, 1 oudet adaptor, 1 red hand truck (2-wheeler), 1 silver hand uuck (2-wheeler), i briefcase for light console, 2 6 ft extension cords, 1-2Q foot headphone extension cord, 3 misc. cables, 1 exua knob for Knight TD-40 and Knight TD-30 Stands, and 1 power strip. RESPONSE: 7osha does not admit the purchase or sale of items other than as previously identified in Response to Request for Admissions. Objection is made in that unless the properry is identified by serial number or some other unique mark, it cannot be tracked to prior sales. Computerized sales records are available for copying at counsel's office after confidentialiry arrangements are made. 5. All receipts, statements or other documents which evidence sales of used musical equipment from April 19, 1995 to Apri125, 1995. 2 96-75 R RESPONSB: Computerized sales records are available at counsel's office arrangemenu are made. - -- - ,' -�- - -. ..- -�� , -_ _ _ --- • — - - -- - � f� J. Subscribed and swom to before me th�-`� day of November, 1995. / / / t I.rr�L�(i� ` Notary Public �� ossw+�+ocor�x.aww�++�.,;.,,.. _...,..>a 5� J"� TIMO'MY B. 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TAX '� 23.80 i � TOTAL .... ;63:79 ' ii ., VISA �`,_ -i6�Si94B3162 +� i EXP.tn..=: -iO3+ 3U3.74 � . . � X_____ — -- ' ix= YUJ : . ApgE•= ::;� YOIAt t��USED 5 f�fNTAL 5TOP ,. �_ ',. ;: �r- . . . ;l.Y :ut�ta L;i . .. .,. . . . -i�::.'�T:�.�� .::..:�'�.� � . `. i .� . •:i�i : f:il�x :`i:: f r.: • � _ .. . n _ r.,....s:_e;iCix3 , -"-----"""_`' . ••- FkICE 9SY 4�': - 'TIUti ---- i. I i � 3 _ � � �.� 1:� +.f:.?^;: y ._..r . .....^.' '" Q3f1I31'�1 "�F3�,, 9SZL'- _: : _ _ y ' ..�( .M'�/ .�.KI;CiS.`��+(j. ^, � � r : y.y]r? : _ Ip �� .. T 'GL `� :T : •�lVl _'� ��=•r .s . -. : iF ,. . ':- ;'i::-: :.2::"•':�':" Xyl � °. : -, ;-��:. i � � . biZ2:. = �= . � > 1tl101;&t15 -: °: �.: =: �";.. � ,- "� t00'; , :518ifi5 1 53fltl�1 T�.' :'_ � :�•� � .'• ' : 00' � i15FPoH :�-� � ��;t00'Si, ;.'.._'= :�'7QpH.Stl9FII'1'�;>:: tl1�3H5 T-tl5 NOII�t{.T'. ` -- :" - 00'Si d'T�i , ` � +pp•I- . . S�FIIBJS �IS1.�3 �. , B 1t�1I7 00�6Q 0�ldQ t�_ r � � -: ••`-00'T � OOl6QtlQ -. i i� w r40'1. 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STOF i , �- .5'L-96 . � - - � � . . � � - j 4 2. ; y � _�, � - � � .�.._ . -� � �..� �_�..� �G, , ,_;.�_:� � � � x� -�- ._ C�TY DESCIiIF?IGN ^ F'F:Ii.f � . __,'=-=- --_=-_____= =___ , DAJ4� @ S.S� 1 Dr1DDAkIU 745 FFQ ART' � E M�iMAL ELA55ICAL 5 �..`� ;� . . - ., t ,_ `. ..,SL� TOTAL 8. %fi . . i ; • T{�V .i:3 - - - ,... :7�TAl °.6:' • � . ':.:.�s'FJ kEGEI'JLD i0.44 ; � .. '' �- : �at� . � �; � :_: - - .__ . ' iHi�9K `(f�5. . �j Ae,E�E'S I1�J5IC=YtlL�i t�USEU F�NTA�� 57CiF• � � � . ,� , ;� ., _ i _ �re . � F ..� � ._._.__�; Kb.i!.�w.�.__ <. "�.�'s. �'�.-_.;:i # _-� , t � �� . � +x`-.- � -". M1?->- c.�c..:s�w'�:�`i�r::.t>.... i t�_ �� -" ' a ' .v as'�.;:`;�' .� ::•.:" _ _ " � . _ _: " . _.,�,.. _. •�: . ' ' � . .; �: a.='s , _ _ . n•�s.:,. . `S' ' "� �k.�' _ ._ ' "� " <.:._.4i�-Y " -�" � . � �itY tfStklPi:nN �� j = __'--_=______°___----__= � • :{ �i i t � D'n2510U �? 1.� ' 2 In`FC�] DSSOQ LI�,'�IT AC • u�JSTIE 57F.Ih1�5 3.� IM,J45 C� 3.�'Y • 1 iADDARIO S�5 F'k0 �(tT - E N��AL �tA�SICAL S �.5'i* l�?i45 � �.49 - 1 C�t?5 1IF 93D SINC�LE ♦ T!t QAS:?CI�L STRIlG .'.+Sti V.n� TGTi1. 1�.+8 �� 2:C�i TOTAL 25.49 i,ASH �ECEI6'ED 2{1.U0 - CHAHC�E 4.`1 TH�';!{ Y011 . - .. . . fiAbE'S 171JSIC-YOU�' t�E{d�I15ED II R9{ii+l STOR �t :� i f i i;. ;;� , _ . . ' - = i =; _ � ! _ 1 , � i k S � i ' , ; � e . .3o�s �:sr�� a�n`�� ;-a��w s,�:,s� (IQh N'ri"t%H: „rt)T aay^�i�p} ys"a': G�'T7. �i5:3�I h.�,3n 04.'TZ • lt'l:?1 qt'T ;N1 3(i'4, t'Sii! �itl: ' ?:a0��°T�"�= w��,•Q3 :531;�3I 'F1 t�LS,'. NCSWBS Y='ih'3S t .:�'Ui � ��tl4i�3 . r ==-.-3:�I�Si --- t�I1.iS ��;I j ��; i ,7QF .•-----^' _..-'. ' ; -- - - - --�~_..��_ - - . : � ' 1� !� ` �'i. " • � . Se�� _ -• • � * ,e.ai - �• �'.L.. - ,f. ; - _.�. � . - "1_ F_^^-_ � '-�+�3�}��,� '> - _,.,, �,� ,� �„ �'�!.�' ;�MYl�iii�iwt= s -- -. - --�r : �. _ - , : �.�m��es �-° _ -°� �� / � . •'-- - ir,.�.-=�..: .� . ' �� `- _:�.._ * 4 .� �-. : _: `. �'' ; . ; -�,� ,-�`=.: "= hYS� - - - :9., � � _ ... _ .�. s - _ — .� ... . T l�~} ��. � f _ • _.__ `. . r;,2 _ � � ' • � � w�'a� -+ --� ri- . ��'_ . . � .�. ._. , � r _Y."� . [. �` 4�� d '. • i . �� • :� _ `.i-+.,% �<;u, ws , „�5c.n�*. �i �,.�cp> 4:: -./ �, � ;c n ;A -,wr,�.-' ,.. _ '- - ' �'° �:..?%`` . _ , . ��Y,;�., . - .' _..:�:. _ � - � . ..,_.-.:..�= ; � .. . R: �D. . '( fG . � _ . . .�. __`__ _ __ _ ____ ________._ _ �t _1_ ______ _ . — - ' j' - ?._ _ � ,3 0 W �j`3 '• -� .' T'."dL � - y�� - '�_ �.. ` . �•h^ S:,ai . �Rdc �3'�YC- � _as�. r .•�f ; _ __..:::i� _ . - � � �!!�y� . - - <;p �- _ � � e.��. _ . . . . � y - ; - ' _ . . ' ` "_ _ _-}i•r ,.' . ` _ - _ 96-75 � � , • �\ � ��s �a� e a3sn`�a �A=aisr� s.�� - r�� rr,n� i sti• . � i LL? "L� 43r1I373'1 HS�r'7 �'.'9i '1d10! . ' ;L'i . X4'1 00';Z � 1tl10i Hf,'� �04'S' ' aI41 lk ' �i 45�US 3`SftHS 43`Q T DO'SZ � 4GG�`i�:= _______�� ___'__—' �__ '`-'__' ---- z�I?1�1 � hauli n1�� -- i:aT'Y U��ifiIF'TIrN --- -`"- F'FcICE -. -- '?�L:i��13 E GOA�� 2 ;dE��J �'�CK STkAIGHT CY 17PA1 57nt4D G0. G0� t�'�v'1F'OI:h�)W @ 11.49 ' . i NE4! F'�QflAfiN RQCX KHO C�fEfi MiION UFC15T� 21.99* � t$fvY7T"nRKW @ 9.4? -.•�, - 1 NE41 F�i'Oi7r'NiK HIWCdi'iY : F.QGIC KFIOCKS�S WQiJD •.-.-,. 4.� : M.�ItlFIF' [ u.44 . 1 NE4! UNFVER'�AL CW#�H �I.EaTt�k &D FRD 6.9�a ; 1-CdUFUN . -10.� � f t�F,ASN t� .00 ' . . 1 AAE�ES T �HIkTS ' .00* � 511R T�TAt. . 78.97 ;. • iAX : .::a;F,';.'.S.Sa �' TOTAL r� _. ;^;;� $4:.°�0' ' '.1 G1�CK FECEIVED . .` - ,_=c •&4.50 •'": . ;; � . 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PAUL In Re the Matter of All Licenses held by Josha Corporarion d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe for the premises located at 1933 University Avenue West, St. Paui, Minnesota OAH Docket No.: 91-2102-9995-3 ANSWERS TO ADMISSIONS AND INTERROGATORY TO: Gail Langfield, Assistant Ciry Attomey, 550 City Hall and Court House, 15 West Kellogg Blvd., St. Paul, MN 55102. 1. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two Peavey Full Range Speaker Cabinets, Model 115 International Series III BW, Serial Numbers 7E-02992246 & 7E-02992247, on April 19, 1995. ANSWER: Admit. 2. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of rivo 50 foot microphone cables prior to Apri122, 1995. ANSWER: Objection is made in that the request does not sufficiendy identify the items to admit or deny same. 3. That Josha Corporation d/b/a Aabe's Fanuly Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of eight 150 watt flood lights on April 19, 1995. ANSWER: No separate consideration has been paid for this item. No records required pursuant to Section 355.04. 4. That Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of fourteen light gel frames on Agril 19, 1995. ANSWER: No separate consideration has been paid for this item. No records required pursuant to Section 355.04. � � In Re Licenses of Josha Corporation �� /a Aabe's Music Shoppe — City's Exh. No. ZZ gb-75 ' � 5. That Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of eight gel paper sheets on April 19, 199�. ----- --- — - _ _ "- AT�ISWER: No separate considerafion has been paid for this item. No records required pursuant to Section 35�.04. 6. That Josha Corporation d/b/a Aabe's Fanuly Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two leather bags on ApriI 19, 1995. I�►GY.f : _ . ��"11# 7. That Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one Boss MA15A Powered Spot vlonitor, Serial Number 551423, prior to Apri122, 1995. A1�ISWER: Consideration was less than $50.00. No record required. 8. That Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one Ibanez IFC-60 Foot Controller, Serial Number 300154, prior to April 22, 1995. ANS WER: No sepazate consideration has been paid for this item. No records required pursuant to Section 355.04. 9. That Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two Knight Slide Mounts on April 19, 1995. ANS WER: No sepazate consideration has been paid for this item. No records required pursuant to Section 355.04. 10. That Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two 50 foot speaker cables on April 19, 1995. ANS WER: No separate consideration has been paid for this item. No records required pursuant to Section 35�.04. 11. That Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of three 100 foot extension cords prior to April 22, 1995. q6-75 ANS WER: No separate consideration has been paid for this item. No records required pursuant to Section 35�_04. — — - -- ----- ----- -- - --- - -- - ------ - 12. That Josha Corporation d/bla Aabe's Family Discount Center>Aabe's Music Shoppe does not have any documents evidencing the purchase of four 8 foot estension cords on April 19, 1995. ANS WER: No sepazate consideration was paid for any 8 foot estension cords. No records required pursuant to Section 355.04. li. That 7osha Corporation d/b(a Aabe's Family Discount CenterlAabe's Music Shoppe does not have any documents evidencing the purchase of three cord totes prior to Apri122, 1995. ANS WER: No sepazate consideration has been paid for this item. No records required pursuant to Section 355.04. 14. That Josha Corporation, d!b!a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the pwch�se of one microphone stand on April 19, 1995. ANS WER: 15. Admit. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one microphone stand with telescopic boom on April 19, 1995. ANS WER: 16. Admit. That Josha Corporation, dJb/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of four 25 foot speaker cables on April 19, 1995. ANSWER: Admit. 17. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one side music stand on April 19, 1995. ANSWER: Admit. ,� 18. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one Panasonic cassette tape recorder on April 19, 1995. g6-75 ANSWER: Admit. 19. That Josha Corporation, dJbfa Aabe's Family Discount Center/Aabe's Music Shoppe does not h ave a ny documents evidencing theQurchase of one_Ra�co AB 100 sw�ich_puor___�_-__ _ � ---- — -- --- — �to Apnd 22, 1995. ANSWER: 20. Deny. Josha is a Rapco dealer for new equipment. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two Sunn Floor Monitors on April 19, 1995. ANSWER: 21. Admit. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencin� the purchase of one red stora�e box on April 19, 1995. ANS WER: 22. Admit. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one Boss PSA 120 Adapter on April 19, 1995. ANSWER: 23. Admit. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of riuo guitar stands on April 19, 1995. ANSWER: 24. Admit. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencin� the purchase of one CRUZIN' sign with case on April 19, 1995. ANSWER: 25. Admit. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one cord bag with 47 miscellaneous cords and adapters on April 19, 1995. ANSWER: Admit. 96- �� 26. That Josha Corporation, d/b/a Aabe's Fanuly Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two surge suppressors on April 19, 1995. -- ----- -- - ANSWER: No sepazate consideration has been paid far this item. No records required pursuant to Section 355.04. 27. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of nine guitar cords on April 19, 1995. ANSWER: Admit. 28. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of rivo "mic clips" on April 19, 199�. ANSWER: Admit. 29. That Josha Corporation, d/bla Aabe's Family, Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of four XLR transformers on April 19, 1995. ANSWER: Admit. 30. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one outlet adaptor on April 19, 1995. ANSWER: Admit. 31. That Josha Corporation, dlb/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one red hand truck (2-wheeler) on April 19, 1995. ANSWER: Admit. 32. That Josha Corporation, d/bla Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one silver hand truck (2-wheeler) on April 19, 1995. ANSWER: Admit. 96-75 33. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one briefcase for li�ht console prior to Apri122, 1995. ----- - — ---- -- ----- A�iTSWER: 1Vo separate consideration has been paid for this item. No records required pursuant to Section 3».04. 34. That Josha Corporation, d/b/a Aabe's Fanuly Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of two 6 foot extension cords prior to April 22, 1995. Ai�1S WER: No sepazate consideration has been paid for this item. No records required pursuant to Section 35�.04. 35. That Josha Corporation, d/bJa Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one 20 foot headphone eYtension cord prior to April 22, 1995. ANSWER: No sepazate consideration has been paid for this item. No records required pursuant to Section 35�.04. , 36. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of three miscellaneous cables prior to Apri122, 1995. ANS WER: 37 Objection is made in that the request does not sufficiently identify the properCy. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one extra knob for Knight TD- 40 and Knight TD-30 Stands prior to Apri122, 1995. ANSWER: 38. No separate consideration has been paid for this item. No records required pursuant to Section 355.04. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the purchase of one power strip prior to Apri122, 1995. ANSWER: Objection is made in that the request does not sufficiently identify the property. 39. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased two Peavey Full Range Speaker Cabinets, Model 115 Intemational Series III B W, Serial Numbers 7E-02992246 & 7E-02992247, on April 19, 1995. F'i gb-75 ANSWER: Deny. 40. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased two 50 foot mic cables on Apri119, I995. Ai�1SWER: No separate consideration has been paid for this item. No records required pursuant to Section 35�.04. 41. That Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased eight �0 watt flood lights on Apri119, 1995. AI�SWER: No separate consideration has been paid for this item. No records required pursuant to Section 355.04. 42. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased fourteen light gel frames on April 19, 1995. AlVSVJER: No separate consideration has been paid for this item. No records required pursuant to Section 355.04. 43. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased eight gel paper sheets on April 19, 1995. ANS WER: No separate consideration has been paid for this item. No records required pursuant to Section 355.04. 44. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased two leather hags on April 19, 1995. ANSWER: Deny. 45. That Josha Corporation, d/bfa Aabe's Family Discount Center(Aahe's Music Shoppe purchased one Boss MA15A Powered Spot Monitor, Serial Number 551423, on April 19, 1495. ANSWER: Deny. Property purchased 4118/95 for less than $SO.OQ. 46. That Josha Corporation, d!b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one Ibanez IFC-60 Foot Controller, Serial Number 300154, on April 19, 199�. ANS WER: No sepazate consideration has been paid for this item. No records required pursuant to Section 355.04. 96-75 �' t 47. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased two Knight Slide Mounts on Apri114, 1995. ANSVJER: No separate consideration has been paid for this item. No records . �_ ._ _ _�_ -...__ . � R � ' pursuanf to �ectron �55.04. 48. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased two 50 foot speaker cables on April 19, 1995. P,i�IS WER: No separate consideration has been paid for this item. No records required pursuant to Section 355.04. 49. That Josha Corporation, dJb/a Aabe's Family Discount CenterfAabe's Music Shoppe purchased three 100 foot extension wrds on April 19, 1995. ANSWER: No separate consideration has been paid for this item. No zecords required pursuant to Section 355.04. 50. That Josha Cotporauon, d/b(a Aabe's Family Discount CenterlAabe's Music Shoppe purchased four 8 foot extension cords on April 19, 1995. ANSWER: No separate consideration was paid for any 8 foot extension cord. No records required pursuant to Section 35�.04. 51. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased three cord totes on April 19, 1995. ANSWER: No separate consideration has been paid for this item. No records required pursuant to Section 355.04. 52. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one microphone stand on April 19, 1995. ANSWER: Deny. 53. That Josha Corporation, d!b!a Aabe's Family Discount Center(Aabe's Music Shoppe purchased one microphone stand with telescopic boom on April 19, 1995. ANSWER: Deny. 54. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased four 25 foot speaker cables on April 19, 1995. Ai�ISWER: Deny. 9b-?5 5�. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one side music stand on April 19, 1995 _ ____ - -- ----- ANSWER: Denv. _--- --------- �6. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one Panasonic cassette tape recorder on April 19, 1995. ANSWER: Deny. 57. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one Rapco AB 100 switch on April 19, 1995. ANSWER: Deny. 58, That Josha Corporauon, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased rivo Sunn Floor Monitors on April 19, 1995. ANSWER: Deny. 59. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one red storage box on April 19, 1995. ANSWER: Deny. 60. That Josha CorQoration, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one Boss PSA 120 Adapter on April 19, 1995. ANSWER: Deny. 61. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased two guitar stands on Apri1 19, 1995. ANSWER: Deny. 62. That Josha Cotporation, d(b!a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one CRUZIN' sign with case on April 19, 1995. ANSWER: Deny. 63. That Josha Cotporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one cord bag with 47 miscellaneous cords and adapters on April 19, 1995. ANS WER: Deny. � v � � � ' � � 64. That ]osha Corporntion, d/b/a Aabe's Fanuly Discount Centez/Aabe's Music Shoppe purchased tcvo surge suppressors on April 19, 199�. ANSWER: No separate consideration has been paid for this item. I�io records required pursuant to Section 35�.04. 65. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music 3hoppe purchased nine guitaz cords on Aoril 19, 1995. ANSWER: Deny. 66. That Josha Corporation, dlbla Aabe's Family Discount CenterlAabe's Music Shoppe purchased two "mic clips" on April 19, 1995. ANSWER: Deny. 67. "1'hat Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased four XI.R transformers on April 19, 1995. ANSWER: Deny. 68. That 3osha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one outlet adaptor on April 19, 1995. ANSWER: Deny. 69. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one red hand truck (2-wheeler) on April 19, 1995. ANSWER: Deny. 70. That Josha Corporation, dibia Aabe's Family Discount CenterlAabe's Music Shoppe purchased one silver hand truck (2-wheeler) on April 19, 1995. ANSWER: Deny. 71. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one briefcase for light console on April 19, 1995. ANSWER: No sepazate consideration has been paid for this item. No records required pursuant to Section 355.04. 10 96-75 72. That Josha Corporation, d/b/a Aabe's Family Discount CenterlAabe's Music Shoppe purchased two 6 foot extension cords on April 19, 1995. A�tiSWER: No sepazate consideration has been paid for this item. No records - -- ----- -- pucsuant to �echon �5�:04. --- ---- 73. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one 20 foot headphone estension cord on April 19, 1995. ANS WER: No separate consideration has been paid for this item. No records required pursuant to Section 355.04. 74. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's 1Vlusic Shoppe purchased tluee miscellaneous cables on April 19, 1995. ANSWER: Objection is made in that property is not sufficiently identified. 75. Thai Josha CorporaAOn, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe purchased one extra knob for Knight TD-40 and Knight TD-30 Stands on April 19, 194�. ANS WER: No separate consideration has been paid for t`his item. No records required pursuant to Section 355.04. 76. That Josha Corporation, dlbfa Aabe's Family Discount CenterlAabe's Music Shoppe purchased one power strip on April 19, 1995. ANSWER: No separate consideration has been paid for this item. No records required pursuant to Section 355.04. 77. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between Aprii 19, 1995 and Aprii 24, 1995, two Peavey Full Range Speaker Cabinets, Model 115 International Series III BW, Serial Numbers: 7E-02992257 & 7E- 029922G7, which were purchased on April 19, 1995. ANSWER: Deny. 78. That Josha CorQoration, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one Knight TD-40 Light Tree Stand which was purchased on April 19, 1995. ANSWER: Deny. 11 96-75 79. That 7osha Corporarion, cUb(a Aabe's Family Discount CenterlAabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, two Knight TD-30 Tripods which were purchased on April 19, 1995. -- ----- A�i7SWEK: -- Deny. --- 80. That Josha Corporation, d/b/a Aabe's Fanuly Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, two leather bags which were purchased on April 19, 1995. ANSWER: Deny. 81. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, two Knight Slide Mounts which were purchased on April 19, 1995. ANSWER: Deny. 82. That Josha Corporation, d!b!a Aabe's Family Discount CenterlAabe's Music Shoppe sold, beriveen April 19, 1995 and Apri124, 1995, two 50 foot speaker cables which were purchased on April 19, 1995. ANSWER: Deny. 83. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, two 100 foot extension cords which were purchased on April 19, 1995. ANSWER: Deny. 84. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, four 8 foot estension cords which were purchased on April 19, 1995. ANSWER: Deny. 85. That Josha Corporation, d/b/a Aabe's Family Discount CenterlAabe's Music Shoppe sold, between April 19, 199� and Apri124, 1995, one microphone stand which was purchased on April 19, 1995. ANSWER: Deny. 12 96-75 86. That 3osha Corporation, d/bia Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 199� and Apri124, 1995, one microphone stand with telescopic boom which was purchased on April 19, 1995. -_ t�NSWER: Deny. 87. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 14, 1995 and April 24, 1495, four 25 foot speaker cables which were purchased on April 19, 1995. ANSWER: Deny. 88. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, one side music stand which was purchased on April 19, 1995. ANSWER: Deny. 89. That Josha Corporation, d/b!a Aabe's Family Discount CenteriAabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one Panasonic cassette tape recorder which was purchased on April 19, 1995. ANSWER: Deny. 90. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, two Sunn Floor Monitors which were purchased on April 19, 1995. ANSWER: Deny. 91. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Ivlusic Shoppe sold, between Aprii 19, 1995 and Apri124, 1995, one red storage box which was purchased on April 19, 1995. ANSWER: Deny. 92. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Nlusic Shoppe sold, between April 19, 1995 and Apri124, 1995, one Boss PSA 120 Adapter which was purchased on April 19, 1995. ANSWER: Deny. 13 q6-75 93. That Josha Corporation, d/b(a Aabe's Family Discount Center(Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, two guitar stands which were purchased on Apri119, 1995. --- - - - --;r�vS�NEIt -- �Deny: --- - ---- ----- 94. That Josha Corporation, d/b/a Aabe's Fanvly Discount Center/Aabe's Music Shoppe sold, between Aprii 19, 1995 and April 24, i 995, one CRUZIN' sig� with case which was purchased on April 19, 1995. ANSWER: Deny. 95. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one cord ba? with 47 miscellaneous cords and adapters which was purchased on April 19, 1995. ANSWER: Deny. 96. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, two surge suppressors which were purchased on April 19, 1995. ANSWER: Deny. 97. That Josha Corporation, d/b/a Aabe's Family Discount CenterlAabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, nine guitaz cords which were purchased on April 19, 1995. ANSWER: Deny. 98. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and April 24, 1995, two "mic clips" which were purchased on April 19, 1995. ANSWER: Deny. 99. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, four XLR transformers which were purchased on April 19, 1995. ANSWER: Deny. 14 96-75 100. That Josba Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one oudet adaptor which was purchased on Aprii 19, 199�. �. ' i 101. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe sold, between April 19, 1995 and Apri124, 1995, one red hand truck (2-wheeler) which was purchased on April 19, 1995. ANSWER: Deny. 102. That Josha Cotporation, d/b/a Aabe's Family Discount CenterlAabe's Music Shoppe sold, between Aprii 19, 1995 and April 24, 1995, one silver hand truck (2-wheeler) which was purchased on April 19, 1995. ANSWER: Deny. 103. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of two Peavey Full Range Speaker Cabinets, Model 1 �5 Intemational Series III BW, Serial Numbers: 7E-02992246 & 7E-02992247, which were purchased on April 19, 1995. ANSWER: Admit. 104. That Josha Corporauon, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale beriveen April 19, 1995 and Apri124, 1995 of one Knight TD-40 Light Tree Stand which was purchased on April 19, 1995. ANSWER: Admit. 105. That Josha Corporation, d/U/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and April 24, 1995 of two Knight TD-30 Tripods which were purchased on April 19, 1995. ANSWER: Admit. 106. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale beriveen April 19, 1995 and April 24, 1995 of two leather bags which were purchased on April 19, 1995. ANSWER: Admit. 15 96-75 10�. That Josha Corporarion, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and April 24, 1995 of two Knight Slide A�iounts which were purchased on ApriI 19, 1995. —__ __ — �S�£R: - - �dnTiY: — -- - - - --- --- 108. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of two 50 foot speaker cables which were purchased on April 19, 1995. .Si�3SWER: Admit. 109. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of rivo 100 foot extension cords which were purchased on April 19, 1995. ANSWER: Admit. 110. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between Apri1 19, 1995 and Apri124, 1995 of four 8 foot estension cords which were purchased on April 19, 1995. ANSWER: Admit. 111. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale beriveen April 19, 1995 and Apri124, 1995 of one microphone stand which was purchased on April 19, 1995. ANSWER: Admit. 112. That Josha CorQoration, d!b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale beriveen April 19, 1995 and Apri124, 1995 of one microphone stand with telescopic boom which was purchased on April 19, 1995. ANSWER: Admit. 113. That Josha Corporation, d/b/a Aabe's Family Discount CenteriAabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of four 25 foot speaker cables which were purchased on April 19, 1995. I•l�G'�J71:�r,J"1ii # T� 96- �5 114. That Josha Corporarion, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale betv✓een April 19, 1995 and Apri124, 199� of one side music stand which was purchased on April 19, 1995. -- - - - A�S c%V��: t�ditiit: _ _ . - -- - - - -- --- - 115. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencina the saie betu+een April 19, 1995 and Apri124, 199� of one Panasonic cassette tape recorder which was purchased on April 19, 199�. Ai�ISWER: Admit. 116. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencin� the sale beriveen April 19, 199� and Apri124, 1995 of two Sunn Floor Monitors which were purchased on April 19, 1995. ANSWER: Admit. 117. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and April 24, 1995 of one red storage box which was purchased on April 19, 1995. ANSWER: Admit. 118. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and April 24, 1995 of one Boss PSA 120 Adapter which was purchased on April 19, 1995. ANSWER: Admit. 119. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, I 995 of two guitaz stands which were purchased on April 19, 1995. ANSWER: Admit. 120. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music 5hoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of one CRUZIN' sien with case which was purchased on April 19, 1995. ANSWER: Admit. 17 96-�5 121. That 3osha Corporation, dlbla Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of one cord ba� with 47 misceilaneous cords and adapters which was purchased on April 14, 1995. ANSWER: Admit. 122. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 14, 1995 and Apri124, 1995 of two surge suppressors which were purchased on April 19, 1995. ANSWER: Admit. 123. That Josha Corporation, d/b/a Aabe's Family Discount CenterJAabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of nine guitaz cords which were purchased on April 19, 1995. ANSWER: Admit. 124. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 199� of two "mic clips" which were purchased on April 19, 1995. ANSWER: Admit. 125. That Josha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of four XLR transformers which were purchased on April 19, 1995. ANSWER: Admit. 126. That Josha Corporation, d/b!a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, I 99� of one outlet adaptor which was purchased on April 19, 1995. ANSWER: Admit. 127. That 7osha Corporation, d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe does not have any documents evidencing the sale between April 19, 1995 and Apri124, 1995 of one red hand truck (2-wheeler) �vhich was purchased on April 14, 1445. ANSWER: Admit. �F3 96-75 128. That Josha Corporation, d/b/a Aabe's Fanuly Discount Center/Aabe's Music Shoppe does not have any docutnents evidencing the sale between April 19, 1995 and Apri124, 1995 of one silver hand truck (2-wheeIer) which was purchased on April 19, 1995. - - �S�R: Admit. _ - - - - 129. That on April 25, 1995, police officer M. Garvey and George Moschkau removed one Sunn PLC 816 Light Console from Aabe's Music Shoppe. Ai�iSWER: Other than for statements provided by the Ciry, Josha is without knowledge of ail items removed. 7osha does not have a separate inventory of the items removed. li�. That on Apri125, 1995, police officer M. Garvey and George Moschkau removed two 5unn PS610 Dimmer Packs from Aabe's Music Shoppe. ANS WER: Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a sepazate inventory of the items removed. 131. That on Apri125, 1995, police o�cer M. Garvey and George Moschkau removed two 50 foot microphone cables from Aabe's Music Shoppe. ANS WER: 132. Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a separate inventory of the items removed. That on Apri125, 1995, police officer M. Garvey and George Moschkau removed ei�ht Paz 38 light canisters from Aabe's Music Shoppe. ANSWER: Other than for statements provided by the City, Josha is without knowledge of all items removed. 7osha does not have a sepazate inventory of the items removed. 133. That on Apri125, 1995, police officer M. Garvey and Geor�e Moschkau removed eiQht 150 watt flood lights fzom Aabe's Music Shoppe. ANS WER: Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a separate inventory of the items removed. 134. That on Apri125, 1995, police o�cer M. Garvey and George Moschkau removed fourteen light �el frames from Aabe's Music Shoppe. ANSWER: 135. Other than for statements provided by the City, Josha is without knowled�e of all items removed. Josha does not have a sepazate inventory of the items removed. That on Apri125, 1995, police officer M. Garvey and George Moschkau removed eieht get paper sheets from Aabe's Music Shoppe. fL'] 46-75 ANS WER: Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a separate inventory of the items removed. 136. That on Apri125, 1995, police officer M. Garvey and George Mo schkau removed --- - one- K�¢-�3-49 �ig}tt tree with adaptor from Aabe's Ivltisic Shoppe: ---- — ---- ANSWER; Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a separate inventory of the items removed. 137. That on April 25, 1945, police officer M. Garvey and C�eorge Moschkau removed one Boss VIA1�A Powered Spot Monitor Serial Number 5�1423 from Aabe's Music Shoppe. ANSWER: Other than for statements provided by the City, 3osha is without knowledge of all items removed. Josha does not have a separate inventory of the items removed. 138. That on April 25, 1995, police officer M. Garvey and George Moschkau removed one Ibanez IFC-60 Foot Controller Serial Number 3�0154 from Aabe's Music Shoppe. ANS WER: Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a sepazate inventory of the items removed. 139. That on Apri125, 1995, police officer M. Garvey and George Moschkau removed one 100 foot extension cord from Aabe's Music Shoppe. ANSWER: Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a separate inventory of the items removed. 140. That on Apri125, 1995, police officer M. Garvey and George Moschkau removed three cord totes from Aabe's Music Shoppe. ANS WER: Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a separate inventory of the items removed. 141. That on Apri125, 1995, police officer M. Garvey and George Moschkau removed one Rapco AB 100 switch from Aabe's Music Shoppe. ANSWER: Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a separate inventory of the items removed. 142. That on Apri125, 1995, police o�cer M. Garvey and George Moschkau removed one DeArmond Volume Pedal from Aabe's Music Shoppe. ANSWER: Other than for statements provided by the City, Josha is without knowledge of all items removed. Josha does not have a sepazate inventory of the items removed. 20 96-75 � � 143. That other than the items listed in request for admission numbers 129 to 142, above, no further items were removed from Aabe's Music Shoppe. Ai�IS WER: Other than for statements provided by the City, Josha is without knowiedge of all -------- --- items remov�d. :tosha does not$ave a separa�e mvenfory o�tTie Ttems removed. 144. That the items listed in request for admission numbers 129 to 142 above are the property of George Moschkau. ANSWER: Deny. George Moschkau did not provide proof of ownership sufficient to identify all cords, cables, power strips, surge suppressors, Rapco pedal, Boss equipment, knobs, flood lights, TD 30 or TD 40 stands. Unless product is identified by a serial number or other unique mazk, Josha cannot detemrine ownership of the property. 145. That the items listed in request for admission numbers 129 to 142 above were sold to Aabe's Music Shoppe by Ronald Kies and two unidentified males on April 19, 1995. ANSWER: Deny. Josha only paid money for the items on the Pa4vn/Buy form. 146. That on Apri120 or 21, 1995, Ronald Kies returned to Aabe's Music Shoppe and told store personnel_ that the items sold by him and two unidentified males on April 19, 1945 were stolen. ANS WER: Deny. Kies said the property was borrowed by one of his friends. 147. That on Apri120 or 21, 1995, Ronald Kies told store personnel that he wanted to buy back the items sold to Aabe's Music Shoppe on April 19, 1995 for the price of $135.00. ANSWER: Admit. 148. That on Apri12Q or 21, 1995, store personnel from Aabe's Music Shoppe offered to sell the items purchased the previous day to Ronald Kies for $500.00. ANSWER: AdmiC. Kies was advised if he came back 10 days after the time of saie, he could purchase same. 149. That at no time prior to April 22, 1995 did store personnel from Aabe's Music Shoppe inform the St. Paul Police Department that Aabe's was in possession of stolen merchandise. ANSWER: Objection to form of the question. It assumes that at all times Josha was awaze that property was stolen. 21 150. That Aabe's Music Shogpe employees failed to ptovide the St. Paui Police Department with copies of the Pawn/Buy form evidencing the purchases made from Ronald Kies before Apri122, 1995. _-- - -- - - - - - -r�NSWER: �e�ry: ��rsuani �o St: �aut Ordia�ces, �awniBuyforms were avaii"able at store: L1'"I'ERROGATORIES If you deny Request for Admission No. 1 to 150 above, please: a. State each and every fact upon which your denial is based, b. State the name, age, address, occupation of each and every individual who will testify in support of your denial, and c. Identify each and every document which supports your denial. ANSWER: a. Answer previously disclosed in Response to Admission. b. Those individuals previously named in police reports as employees of Josha. c. Purchase form and Sale: Production of Documen Subscrib and sworn to before me this day of i�iovember, 1995. '; � � � . .�=-= �Notary Pu� _;;w.A.`�.✓..__.ra*4+.Y's-i ..��.n..,.t� '°""°d TIMOTHY 6. PCIRIER ' �:�� AqTAil4PUltA�'•Af1NNE50TA � � � �bNwYM9l�sbs.3f.2oW 2� z� � CERTIFIED MAIL RETURN RECEIPT March 18, 1992 Shawn Sweeney Best Music Agency 4450 Nicollet Avenue South Minneapolis, MN 55408 Re: Contract �l5487 — Kirk Hennen & Deena Gustafson Deaz Shawn: �- gb- 75 Enclosed please find Contract #5487'"and accepY�,our noticeE to decline performance based on a conversation our gmup representative Lad with John;`your offic.e�manager. John was contacted about seve ��ncerns we had upon this contr�act:" � a� `"�,,, a� � 1) Total contract bookmg am�ount was not disclosect:� , ,, r .=; �� *� r Per the verbal greement we have had with Best Music Agency, CRUZ/N' will ' 4 make a nvnimum of $450.00 on bookings of $600.00 or less. When bookings � "exceed $600.00, the amount mora than $600.00 would be divided equally �� be[iv�een CRUZIN' and Best Music Agency (labeled as Promo Plus by your '°� a enc �.�. � B Y)• 2) The contract stated that a portion of the compensation wouid be paid to CRUZIN' by Best Music Agency within 5 business days of the engagement's completion. Again, our agreement has always been that we would receive full payment before the performance, paid to us by the client, not Best Music Agency. 3) The contract does not include the signature of the client. 11ils is for our protection, since Best-Music Contract reads "It is herelry agreed that should said purchasers cancel engagement, BESTMUSICAGENCYwitl nos be considered liable in any way for either payment of ouutanding balance orfor collection thereof. " We understand that is this a standard clause in agency contracts because the contract has always been between the purchaser and the entertainers, however, this cannot be the case if the purchaser in not involved in the contract. Best Music Agency cannot sign the contract for the purchaser and then forego the responsibilities of fuifilling the agreement and, of course, neither agencies nor entertainers want it that way. � � In Re Licenses of Josha Corporation ��d/b/a Aabe's Music Sho� e — City's Exh. No. � Shawn Sweeney — Best Music Agency March 18, 1992 Page Two In the conversation with John all the previous items were conveyed and we made the following requests: 1) The total amount of the booking be disclosed in writing. 2) A client signature be provided on a contract. 3) Total compensation be delivered to CRUZIN' on the contracted on the date of performance, before the performance start-t�me. ' John's responded by informing us that the contract"s�had changed�and � the Promo Plus was no longer in effect. He also said that Best Music Agency now works with two contracts: 1) between the purchaser and Best Music Agency, and 2) between Best Music:Agency and the entertainers. He explained that in essence the client �i_ves them gemussion to hire us'for" We do not understand how you can take the power of signing`a,��gal document for�them and still state�U�at you are not�liable. Who is liable? The purchasers? No� without a contract bearing theii signature. John assured us�that this new contract had gone to court twice and had held up; with the �urchaseis, being liable, however, decisions as that can vary with judges and courts and we ara not willing to leave that open to interpret`a6on by either. ��r John then explained that the entertainers n�v decide their minimum amount for a booking and that this was the amount they would receive regazdless of what the client had paid the agency. At tlus point our representative interrupted 7and and informed him that if there was a change sn the contract that we have always had with Best Mtisic Agency, we would need an appointment to negotiate and agree about the bookings involving CRUZIN' . John's reply was ihat with the economy as it was, the agency has no choice but to do this and that there would be several bands who would work under these terms so we should therefore retum the contract. We appreciate the previous professional relationship we have had with Best Music Agency and would like to continue on a legitimate business level, however, the conditions of our original verbal agreement are no longer in effect. We aze further dishubed ihat our request for in£ormation about a cantract for CRUZIN's services was denied. We have never met wiih this in our twelve+ yeazs in the entertainment busutess and find it to be completely unetlucal. Sincerely, CRUZ/N` Specialty Band George L. Moschkau, Jz. Group Owner Enclosure . A � ecsr MUSIC AGENCI' P.O. Box 8657 Minneapolis, MN 55408 (672) 822-7964 CONTRACT # -�"f�7 96 r • I Agreement entered into this the 2�'�day of_�ebr�v��_19 92, by and between KirK ( (� }st��F Yt (herein Purchaser(s)) and -C'xu7iN (herein Pe rformer( s)). — - -_ - - - - --- - - - - - -- - -- - --- - -_ __--- _. TERMS OF ENGA6EIiENT: Purchaser(s) agree to engage the professional ser- vices of Performer(s), as independent contractors through BEST MUSIC AGENCY, for t specific purpose of providing �l �W�� L� }`Iq will be the date of the performance aryd the times are from PM/AM to PM/AM at /� U�' G o�_ �e�Yf��/�✓P_ />/ ��-/t�/cl COMPENSATION: For the professional services rendered, Performer(s) will be paid the sum of � h�.t/�daeC�<3nll� ��'�r/ ($g,�'-�i) for the engagement. aid payment � s to be made �s follows: The sum oP {�y h�� ($40p �) is to be paid to Performer(s) by Purchasers in CASH, MONEY ORDER OR CORPORATE CHECK. Payment will be made by the day of engaqement, prior to the performance. The remaining sum of ��T\I �p11,�r5 ($ .r'�-p�) will be paid to Performer(s) by BEST USIC AGENCY within 5 business days of the engagement's completion. SERVICES: Performer(s) agree to provide their services to Purchaser(s) during the times set forth. It is also agreed that all non-DJ performers shall be entitled to one fifteen minute break for every 45 minutes per- formance time. In addition, Performer(s) agree to exempt BEST MUSIC AGENCY from any and all claims, costs or liabilities for damage and/or injury to any person and/or property during said engagement, including time of set-up and take down. It is hereby agreed that any and all repeat or referred performances will be arranged through BEST MUSIC AGENCY exclusively. OTHER PROVISIONS: It is hereby agreed that should said purchasers cancel,engagement, BEST MUSIC AGENCY will not be considered liable in any way for either payment of outstanding balance or for collection thereof. Liability for payment is fully that of the purchaser and collection'is the full responsibility of the performers. It is also agreed that BEST MUSIC AGENCY will not be held liable in any way for the negligence of any party either known or unknown to the agency. In addition, the agency is not responsible in any way for the failure of any party due to an act of God, natural disaster or any other situation beyond the agency's control. BEST MUSIC AGENCY will not pay any costs associated with any litigation of this agreement. PURCHASER S est Music Agency NAME(S): ` }^u71TJ PERFORMER(S) BY: ADDR�SS � 50 Nicollet Avenue S. ADDRESS: /2 y( �j�iS�J;� �y2 ��(} inneapo is, __ ��7P�SUL MN 5lb2 PHONES:WK 822_'7g64 HM PHONES:WKZ-Z/-/9¢9 xrf a9z-659s AGENT• Besl Music Agency... �� "Our Name Says It — We'll Prove lt!" - ,: �a ' z �.>�':i`�r�.�?"..� .e ✓ _ a� - ±;;w J' .cr . e. ? c��.. �. . �, .forgdtlmonal,`semces- � ° � �� a�s0.`W15H t0 �0001V8 the _ & e �.. , ,,,;;„ , „� �; � �_, following �services (for an extra ss on� reverseaf Mis furtn so thxt we can fee): � �-- . � . m of'the ma'IQ�eca ° on tfre h scece• ' 7 ❑ Addressee's Address � �� r . ' . ' ' _ . - _ � , �4� s , s � ' �6 � 5 estea. onU,emaayecabewwtl,eemeieaumner 2. ❑ Restricted Delrvery�:: :�•. � pra'videyouthesignatureoftEieperso'ndeWar ,�. -= . , - . , . _ , - �;-:��r_==' < ConsuR postmaster foi fees: _:, �_- o <..r�� '� "z, � 4a- Arucle Number . ;, - �'��'��'�'�-,� '�" � P?%802:.182 061�=�� .r� a ..._ )LIS,MN° 55408;,;''..:_s';_' �, "`� �- _ - - 7. Da�� ress 8. Ad� : -�,-_ .� - " � an< 6._ Signa� PS Form 3811, No� 1990 cU.S.GPO: �� .;; =�'_=° - -- - - — " ::._ ��CODia;c._��" __-__ _ M � � Remrn Receipt for � - Mumhanriien � r; °:: � �� '� —_ _ _ _____ . —_"_ ' _ _ _�"__' i UNI7ED STA7ES POS7AL SERVICE `'�p�,^(7S z I, � P M- � � Official Business � 23 MaR �� . —�_ � —�--� ioq; � ,,,1 �-� � PENALTY FOR PRIVA7E i - . _ � , , - '. USE. 3300; :, . I � _ - � ' - " - _ ` ' - Print your name, address and ZIP Code here`- - . .�. , - � '-� � �:,.�_'-� _ ! GEORGE MOSCHKAU JR - = . � „ - 1296 PLEASANT AVE #102_' � �-� ST PAUL MN.55102__ I ' - � ' 1 X � ...�� a � ' �, _ - _ - ' 1 ��`� � i�i�1��1 t,��,Iiii_�s�..i I��il�1� ,�,1��€i��l; 3si�1 -a �Wn< <'"il !4 3. � ' �: .�� .�^.}3�--v.. at.�� wa�..e...�.+i..�+ .�.v..a.vtc��u.. ..��uv�c�--�- � ++ 9 Q� '� �� > � 0 � da`� 1 � o,= o — `° � .�6 > _ N �U� � � � � -° d�� y� = 3 � � = O �_c � V ZO �a'�t .:�,�. � � U] O � � , ) � v�i �C t�} ) E � a m i o a � U a O � H �i W z �w I o O m 'z � � �n � z m d1 N H d ma�d£� vi ¢ � p m a � � ¢ E c m — C� a 1 � m m m =3 ?m a LL E -.. � m ¢ ¢9 ¢o �m E ., . . 066t aun p�.'008£ W�� Sd � � gb-?� .C�-:.`�; : \ (5) Every licensee shall at all times keep his place of business thoroughly tteated with ---- --oil o�-ethe�-sttbstaacesss that dustwi3�nat be raised or blown about on public streets or adjoining property. (6) Every licensee shall keep posted in a con- spicuous place in or upon said premises a legible written or printed sign with letters at least three (3) inches high bearing the following words: LICENSES § 354.03 '�.� = .; 4 �"a :< £ . - ' i �.� "This Trailer Renting Business Operated Under City License No. _" and shall insert therein the num6er of the license. (Code 1956, § 348A7) Sec. 352.07. License not transferable. No license issued hereunder shall be transfer- able. (Code 1956, § 348.03) Chapter 353. Roller Rinks Sec. 353.01. License required. No person shall keep, run or maintain in Saint Paul any roller skating rink wherein such person shall permit for reward or otherwise any person to meet and practice upon roller skates, either for individual exercise, public exhibitions or amuse- ment, without a license. (Code 1956, § 419.01) Sec. 353.02. Fee. The fee required is forty-eight dollars ($48.00) for each such rink run, kept or maintained by the licensee. (Code 1956, § 419.02; Ord. No. 168H3, 2-11-82) Chapter 354. Sanitary Disposal See. 354.01. License required. (a) S¢nitary dispos¢Z. No person sha11 exercise, carry on or be engaged in the trade or business of sanitary disposal in Saint Paul without a license. "Sanitary disposal" means and inclndes the clean- Supp. No. 30 ing and removing of the contents of any septic tank, cesspool, sink, privy va or oth er private _ drairi: '___.� __ (b) Discharge into sewer system. No person shall discharge or dispose of the contents of any septic tank, cesspool, sink, privy vault or other private drain into the Minneapolis-St. Paul Sanitary In- terceptor System in Saint Paul without a license. Any person licensed under pazagraph (a) of this section is egempt from this provision. (c) [�ehicle Zicense. No licensee or permittee shall use or operate on any public street in Saint Paul any vehicle used for the purpose of conveying the contents of any septic tank, cesspool, sink, privy vault or other private drain without a vehicle li- cense. (Code 1956, §§ 241.01, 241.02, 241.04) Sec. 354.02. Fees. (a) The fee required for a trade or business li- cense under section 354.01(a) is thirty doliazs ($30.00). (b) The fee required for a discharge license un- der section 354.01(b) is thirty dollars ($30.00). (c) The fee required for a vehicle license under section 354.01(c) is one hundred fifty dollars ($150.00). (Code 1956, §§ 241.01, 241.04) Sec. 354.03. Lieense requirements. (a) Bond. Before the issuance of any license or permit as provided herein, the applicant shall ex- ecute and submit an annual bond in the sum of five thousand dollars ($5,000.00) running to the City of Saint Paul, which bond shall be approved as to form by the city attomey. Such bond shall be conditioned that the licensee or permittee shall perform the work for which he is licensed or per- mitted in an approved sanitary manner in accor- dance with the provisions of this chapter and all regulations of the division of public health and the department of public works, and that he shall pay for ail labor performed and materiais fur- nished in the performance of such work, and shall save the City of Saint Paul harmless in the prem- ises. 2099 § 354.03 LEGISLATIVE CODE - (b) License tags. There shall be issued to the owner of each and every licensed vehicle a suit- able lieense tag which shall be fastened and dis- played upon the outside of each and every vehicle so that said license tag may be plainly visible at all times. In case any vehicle licensee shall lose his license tag, he shall forthwith and before do- ing any further business procure a new license tag and shall pay for each new license tag the sum of one dollaz ($1.00). (c) Insur¢nce. Whenever a license is issued here- under, the provisions of Section 1.44, Subsections A, C, D, E, K, L, M, N, O and P of the City of Saint Paul, Minnesota, Department of Public Works Specifications for Street and Sewer Construction, as amended, shall apply. Certificate(s) of insur- ance submitted as proof of coverage shall be in a form acceptable to the city attomey and shall in- clude the "St. Paul Uniform Endorsement" as re- quired under section 7.03 of the Saint Paul Leg- islative Code (uniform license endorsement). Said certificate(s) must be submitted to the inspector prior to issuance of the license. (d) License not tr¢nsfer¢ble. At no time wiIl it be permissible to transfer licenses. No moving ve- hicle shall be sold without first removing the li- cense tag from the vehicle and destroying it. (Code 1956, §§ 241.03, 241.04; C.F. I��o. 95-475, § 1, 5-31-95) Sec. 354.04. Regulations. (a) Cleaning of t¢nks, etc. The cleaning, emp- tying and removing of the contents of any septic tank, cesspool, sink, privy vault and any other private drain shall be done in an ino$'ensive man- ner, aad aay person having begun any such san- itary disposal work shall, without any interrup- tion or delay, finish the same, and shall in every instance leave the septic tank, cesspool, sink, privy vault and private drain in as good condition upon the outside as when the work was undertaken. (b) �¢nsporting contents. Every licensee or per- mittee hereunder, in conveying upon the public streets, alleys or elsewhere in the City of Saint Paul the contents of any septic tank, cesspool, sink, privy vault or private drain, shall convey the same in a tank approved by the division of public health, and in such a manner as to avoid overloading or spilling the contents thereof, or the emissioa of an o$'ensive odor therefrom, and shall maintain the exterior of the vehicle and tank in a clean manner. If any of the contents of the tank shall be spilled or fall upon any street, walk or premises, the own- er or driver of the vehicle shall replace the same immediately and remove all traces thereo£ The tanks shall be kept and maintained clean and in- offensive when not in use. (c) Disposal. No person shall dispose or dis- chazge the contents of any septic tank, cesspooi, sink, privy vault or other private drain within the City of Saint Paul in any manner other than by disposing of or discharging the same into the Min- neapolis-Saint Paul Sanitary Interceptor 2ocated in the vicinity of East 'I'hird Street and Commer- cial Street; and said contents shall be so disposed of or dischazged in compliance with the regula- tions of the division of public health and the de- partment of public works. (d) Records. All persons licensed hereunder shall keep an accurate record of the name and address of the owner of each septic tank or cesspool which is pumped, and said licensee shall submit to the director of public works, on the first day of each month, a written report listing the name and ad- dress of the owner of the property containing the septic tank or cesspool pumped by said licensee. (Code 1956, §§ 241.05-241.08; Ord. No. 16881, 2-482) Chapter 355. Secand�an4 €3ealers* Sec. 355A1. License r�e�wire3. (a) Secondh¢nd geods. �o pe:scn shall be en- gaged in the business of b=��^n� o: selling second- hand goods of any nind in Sa�nt Paul without a license to do so. (b) Antiques. ATO ?e; son ehall be engaged in the business of buying o: sei=i�:g antiques of any kind in Saint Paul without a license to do so. *Cross references--Secondhand book dealers, Ch. 235; licensing regulations for pawn shops, Ch, 344. T �� Supp. No. 30 2100 qb-75 ,-� .e� �'� � , ,._� , • �..,i LICENSES § 355.03 (c) Exhibiiions. Any person desiring to have an eghibition,_convention,_shoSV Qr_ exgositionofsec= _ - - ondhand goods or antiques for a limited period of time, not to exceed five i5) consecutive calendar days, shall apply for a license so to do, as herein- after provided. The provisions of paragraphs (a) and (b} of this section shall not apply to persons exhibiting, showing, buying or selling secondhand goods or antiques at a duly licensed exhibition, convention, show or egposition. No more than twelve (12) exhibitions may be held at a single location in a license yeaz. (d) Multipde dealers at one tocation. The owner of a business, at which two (2) or more secondhand goods dealers are engaged in business by main- taining sepazate sales space and identifying them- seives to the public as individual dealers, may obtain a multiple secondhand goods dealer license for that location. No such license shall be issued unless the following requirements are met: (1) The business shall have a single name and address; (2) The business shall operate in a compact and contiguous space; (3) The business shall be under the unified con- trol and supervision of one (1) person, part- nership, firm or eorporation, which shall hold the license; (4) All sales shall be consummated at a central point or regieter operated by the owner of the business, and the owner shall maintain a compreher:aive sccount of all sales. The holder of a secoa�hand goods dealer license under this section, fo; a business with more than one (1) dealer at t: e sa:�ne location, shall comply with all of the :eaui*eser_ts of this chapter, in- cluding the respersibility for reporting and re- cordkeeping, in the 3z*ne manner as any other dealer licersed under �his chapter. Any dealer li- censed under this sectio.^. shall be responsible to its custame:s :br any stolen or misrepresented goods sold at its place of business, in the same manner as any other dealer licensed under this chapter. (e) Exemptions. This chapter shall not apply to the following: (1) Any person engaged in the business of dealing in secondhand motor vehicles or sec- ondhand parts for motor vehicles. Supp. No. 24 (2) Any person engaged in taking in second- - -ha�d-g�ere�andise as gart or fuH '- pay�nent for new goods and merchandise where such business is incident to and not the primary business of such person. (3) Any person licensed hy the County of Ramsey as a precious metal dealer pur- suant to Chapter 333, Laws of Minnesota for 1981. (4) The sale oF secondhand books, magazines, sound or video recordings, films or baseball cards. (5) The sale of goods at an auction held by an auetioneer licensed under Chapter 390 of the Legislative Code. (6) The sale of secondhand goods where all of the foilowing are present: a. The sale is held on property occupied as a dwelling by the seller or owned, rented or leased by a charitable or po- litical organization; b. The items offered for sale are owned by the occupant; c. That no sale exceeds a period of seventytwo (72) consecutive hours; d. That no more than three (3) sales are held in any calendar yeaz; e. That none of the items offered for sale shall have been purchased for resale or received on consignment for purpose of resale. (Code 1956, §§ 342.01, 342.12; Ord. No. 16828, 10-1•81; Ord. No. 17362, § 1, 6-5-86; C.F. No. 93- 1646, § 1, 11-23-93) Sec. 355.02. Fees. The fee required For each license under section 355.01, paragraphs (a), (b), (c) and (d), shall be established by ordinance as specified in section 310�09(b) of the Legislative Code. (Code 1956, § 342.02; Ord. No. 16883, 2-11•82; C.F. No. 93-1646, § 2, 11-23-93) Sec. 355.03. Licensing requirements. (a) Exhibitions, applic¢tion. The application for a license under section 355.01(c) shall contain the 2101 § 3"05.03 LEGISLATIVE CODE " name and address of the person or persons who vrill be responsible for the conduct and manage- ment of the exhibition, oonvention, show or expo- sition, the names and addresses of all persons ex- hibiting or showing secondhand goods or antiques at such exhibition, convention, show or exposi- tion, and the dates, time and piace during which such exhibition, convention, show or exposition will be held. tbi Exhibitions, bond. The app2icant for a fi- cense under section 355.Q1(c) shall file with the inspector a bond in the sum of five thousand dol- lazs ($5,000.00) with a surety company duly li- censed to do business in the State of Minnesota, said bond to be approved as to form by the city attorney, conditioned that the person or persons exhibiting or showing secondhand goods or an- tiques shaIl observe aIl ordinances and laws in relation to dealers of secrondhand goods and an- tiques and conduct the business in conformity therewith and shall accrount for and deliver to any person legally entitled thereto any goods, wazes or merchandise, srticie or thing wlsich may come to his or their hands through the business trans- acted at such exhibition, convention, show or es- position or, in lieu thereof, shall pay in money to such person or persons the reasonable value thereof. (e) Reserved. (d) Investig¢tion; ¢pproa¢l. A copy of the appli- cation for such license shall be delivered to the director of the departmettt of police of said city; the director or an officer duly detailed by him for such purpose shall investigate the applicant and report the result of such investigation to the in- spector together with the approval or the disap- proval of such application by said director, pro- vided, however, that no person shall be licensed under the terms hereof who may at any time prior to the issuance of said license flave been duly cron- victed in any court of competent jurisdiction of having received stolen goods or of any infraction of the terms and provisions of this chapter; pro- vided, however, that the inspector shall follow the procedures required by these chapters and Laws of Minnesota for 1974, Chapter 298 (Minnesota Statutes, Chapter 364) if the license is to be de- nied on the basis of criminal convictions. (Code 1956, §§ 342.01, 342.03, 342.05; C.F. 1Vo. 93-1646, § 3, 11-23-93) Sec. 355.04. Regulations. (a) Hours of business, minors. No person so li• censed shall keep his or her office or store open for the transaction of business on any day of the week hefore 7:00 a.m. or after 10:00 p.m., nor shall any person so licensed purchase or receive personal property of any nature from any minor. (b) Records. Every person licensed pursuant to the terms of this chapter shall, at the time of pur- chasing an item for which the secondhand goods dealer has paid fifty dollars ($50.00) or more, keep a record in which shall be clearly and legibly written an accurate account or description, in the English language, of the goods, articles, antiques or things purchaseci; the amount of rnoney paid therefor; the date and time of the receipt of the same; the name and address of the person selling tfie same, requiring identification in the form of a valid driver's license containing a picture or a valid State of Minnesota identification card con- taining a picture; and the serial numbers and brand names of such goods, articles, antiques or things. The record, as well as the items men- tioned herein that aze bought by the licensee, shall be kept at the licensee's usual place of business ana shall be open to inspection at all reasonabl� times by the license inspector or any membe_ ef the police department of the City of Saint P��±. (c) Sales af[er reporting to the license inspecicr. No property, mentioned in this chapter, Pl`SCh2 by any person licensed herennder, shall be soia'�y or be permitted to be removed from the place cf business of such licensee for a period oi ten ilul days after acquisition. (d) Orders of chief ofpolice. Whenever the chief of police or the inspector shall notify any licsasee hereunder not to seA or permit to be removed any goods or article purchased by such licensee, such goods or articles shall not be permitted to be re- moved, nor shall the same be sold until such time as may be determined by the chief of police; pra vided, that such time shall in no case exceed the sfy �� Supp. ATO. 24 � 2102 gb-75 � � LICENSES § 356.03 period of six (6) montfis from the date of such no- occupant of the dwelling where the sale is con- tif"ication.- - -------.------ ----- ------duct,ed.-IaTO-�icense--mag-be-��rs�e�-t�a-�iF - (e) Adaertised articles. If any goods, artieles or f t 1 t' diff t things shall be advertised in any public news- paper of the City of Saint Paul as having been lost or stolen and such goods, articles or things shall be in or shall thereafter come into the possession of any licensee under the terms hereof, said lic- ensee shall, upon actual notice thereof, immedi- ately thereafter give information in wtiting that certain goods, articles or things advertised aze in said licensee's possession, and shall not there- after dispose of the same except upon written au- thority so to do from the chief of police of the City of Saint Paul. (fl Inspection. Any person licensed under the provisions of this chapter shall, at all times during the term of said license, allow employees of the inspector or o�cers of the police force of the City of Saint Paul to enter the premises where said licensee is cazrying on such business for the pur- pose of inspecting such premises and inspecting the goods, wares, merchandise and reeords therein for the purpose of locating goods suspected or al- leged to have been stolen or otherwise improperly disposed of. (g) Persons cl¢iming interest. All goods, wares or merchandise coming into the possession of any licensee under the terms hereof shall at all times be open to the inspection and right oF eaamina- tion oF any person claiming to have been the owner thereof, or claiming to have had any interest therein, when such person is accompanied by a poliee officer of the City of 5aint Paul; and no licensee under the terms hereof shall hide, con- ceal or stow away any article in his or her posses- sion from any member of the police department of the City of Saint Paul. (h) Business at only one place. A license under section 355.01, pazagraphs (a), (b) or (d), shall au- thorize the licensee to carry on its business only at the permanent place of business designated in the license, escept that a licensee may conduct an estate sale at the dwelling of the owner or prior owner of the goods, provided that all goods offered for sale aze owned by or were obtained from the eren oca ion or a eren person. (Code 1956, §§ 342.04, 342.06-342.11; C.F. No. 93-1646, § 4, 11-23•93) Chapter 356. Sidewalk Contractors* Sec. 356.01. License required. (a) Sidewalk contractor. No person shall en- gage in the business of a sidewalk contractor in Saint Paul without a license. (6) Defznition. "Sidewalk contractor" means and includes building or repairing public sidewalks, curbs, driveways, trap doors, coal holes, tunnels or azeaways in, on or under any street or alley or public property of the City of Saint Paul. (c) P¢rtrzerships, corporations. Tn the event a partnership or corporation is the applicant, at least one (1) of the partners and at least one (1) of the principal managing agents or officers must apply, be examined and qualify as though for an indi- vidual license. Such partnership or corporate li- cense shall be valid only so long as at least one (1) individual is so qualified. (Code 1956, §§ 220.02, 220.12) Sec. 356.02. Fee. The fee required is sixty dollars ($60.OD). (Code 1956, § 220.07) Sec. 356.03. Licensing rE �uirements. (a) Applic¢tion. The app':catic : si:all be made to the inspector and recei�-e� :�y :ne :nsgector when completed and accompanied 'a�r such `ees and bond as may be required. The a-^l', ant shall then be referred to the directer oi the deca-tment of gublic works for exami: a't:a� a:,r': tesiing. The license shall be issued by th2 inspector enIy upon written approval of the director of the department of public works. (b) Examin¢tiorz. The applicant shall, at such time and place as said public works director may •Cross references—Provisions pertaining to building and housing, see Title �7; provisions pertaining to streets, side- walks, bridges and other pcblic ways, see Title XII. Supp. No. 26 2102.1 § 356.03 I.EGISLATIVE CODE - _ :_,, I designate, be required to submit himseif to exam- ination as to his qualifications to work at or en- gage in the business of a sidewalk contractor. The public works director or an employee of his department assigned for that purpose shall eY- amine the applicant as to his practical knowledge of the work incidental to the construction and re- pair of public sidewalks, curbs, driveways, trap doors, coal holes, tunnels or azeaways, and if sat- isfied as to the competency of such applicant, he shall recommend in writing to the inspector that the license be issued. (c) Bond. Before any license is granted here- under, the applicant shall post a bond in the sum of five thousand dollazs ($5,000.00), to be so con- ditioned that such work as the sidewalk contractor is to be permitted to perform sha11 be in accor- dance with the ordinances goveraing this class of work, and in accordance with the specifications, rules, regulations and conditions prescribed by the public works director; and further conditioned to protect and save harmless the City of Saint Paul and the interested property owner from any and all liability, damage or espense wiuch said city or said property owner may sustain by reason of the granting of such license or by reason of the viola tion of any ordinance, statute or law by such lic- ensee or any negligence by him. Said bond shall be in form acceptable to the city attorney. Should the surety on such bond become unac- ceptable, cr �hould said bond in any manner be cance'_led or �erminated, it shall be the duty of tfie Iicer.see to immediately furnish a new bond in m�,�aer and conditioned as above provided; and such Lcens�e shali perform no furtherwork until such bord is furnished and fuliy approved as to for, i by the city attomey. (d) Insurance.Wheneveralicenseisissuedhere- under, the provisions of Section 1.44, Subsections A, C, D, E, F, K, L, M, N, O and P of the City of Saint Paul, b4innesota, Department of Pubiic Works Specifications £or Street and Sewer Con- struction, as amended, shall apply. Said certifi- cate of insurance shall be in form apprwed by the city attomey and shall be filed with the commis- sioner of public works prior to issuance of the li- cense. (Cade 1956, §§ 220.03, 220.04, 220.08, 220.09) Sec. 356.04. License not transferable. A sidewalk contractor's license shall not be transferable. No person, partnership or crorpora- tion holding a license shall allow his, her, their or its name to be used by any other person for the purpose of obtaining permits, or to do any of the work for which said license is issued. (Code 1956, § 22013) Sec. 356.05. Grounds for revocation. (a) Among the grounds for revoking any license issued hereunder shall be that the licensee has willfully violated any of the provisions of this chapter, of section 310.06 of this Code, or of Chapter 121 of the Saint Paul Legislative Code, or has failed to comply with any of the specifica- tions,rules,regulationsand conditions prescribed from time to time by said public works director. (b) The failure to pay, within sixty (60) days, any legitimate claim the City of Saint Paul may have against the sidewalk contractor shall consti- tute a cause for revocation of licenses. (Code 1956, § 220.14) Sec. 356.66. Reinstatement. A revoked license shall not be reinstated in any manner for a period of sis (6) months. No license shall be reinstated without a bond being in fu11 force and effect, nor until the payment of all le- gitimate ciaims wIuch the City of Saint Paul may have against the sidewalk contractor. (Code 1956, § 220.15) Sec. 356.09. Regulations; form of license. The public works director is hereby empowered to promulgate all necessary administrative regu- lations for carrying out the several provisions of this chapter into effect and shall prepaze a form o£ license to be issued hereunder. (Code 1956, § 220.16) Sec. 356.OS. Lieensed contractor nnder other provisions of Code. Persons, partnerships or corporations licensed under this chapter shall be deemed to fall within the term of "a contractor licensed by the City of � 3 �5n"+ Supp. No. 26 21022 � � LICE?QSES � � — � � § 344.03 (C ��, s ��' -� (2) The information may be offered as evidence by the director or any other duly autho- --- -- — ---- -- rized representative in any civil action at law for the collection of inspection fees or in any administrative hearing held pur- suant to the provisions of the sections of this chapter dealing with milk inspection and milk inspection fees. ode 1956, § 286.031) Sec. 341.18. Outside sources of supply. Milk and milk products from points beyond the limits of routine inspection of the City of Saint Paul may not be sold in the city unless produced and pasteurized under requirements which aze equivalent to this chapter and which aze enforced with equal effectiveness. Such licenses as aze re- quired by this chapter must be obtained from the City o£ Saint Paul. (Code 1956, § 286.04) Sec. 341.19. Plans for construction, recon- struction, etc., to be submitted for approval. All dairies, milk plants, milk distributor's plants and receiving stations which aze bufft, rebufft or eatensively altered shall conform in their construc- tion to the requirements of this chapter. Plans for all dairies, receiving stations and milk plants shall be submitted to the director of the division of public health before work is begun. (Code 1956, § 256.05) Sec. 341.20. Enforcement. This chapter shall be enforced by the direetor of the division of public health and the inspector. (Code 1956, § 286.06) Sec. 34121. Violation; penalty. Any person violating any provision o£ this chapter may be punished as provided by the Saint Paul Legislative Code, Section 1.05. (Code 1956, § 286.07) Supp. No. 19 Chapter 342. Oil—Bulk Storage Sec. 342.01. License reguired; definition. (a) No person shall maintain bulk oil storage plants in Saint Paul without a license. (b) "Bulk oil storage plants" means and in- cludes places where lazge quantities of flammable liquids aze stored for K�holesale purposes or dis- tribution. (Code 1956, §§ 350.01, 350.02) Sec. 342.02. Fee. The fee required is two hundred dollars ($200.00) for each such plant. (Code 1956, § 350.03) Chapter 343. Reserved* Secs. 343.01-343.03. Reserved. Chapter 344. Pawn Shopst Sec. 344.01. License required. No person shall exercise, carry on or be en- gaged in the trade or business of pawnbroker in Saint Paul without a license. (Code 1956, § 366.01; Ord. No. 17929, § 1, 6•9-92) Sec. 344.02. Fee. The fee required is eight hundred ten dollazs ($510.00). (Code 1956, § 366.02; Ord. No. 17929, § 2, 6-9-92) Sec. 344.03. License requirements. (a) Applicatiorz; investig¢tion, etc. Any person desiring a pawnbroker license shall file with the license inspector an application containing such information as the license inspector shall require. *Editor's note—C.F. No. 92-1102, §§ 1, 2, adopted Aug. 18, 1992, repealed §§ 343.01-343.03, which were the substantive provisions of Ch. 343, pertaining to licenses for opticians and derived from Code 1956, §§ 374.01-374.03. It should be noted for the user that the repeal of §§ 343.01— 343.03 by C.F. No. 92-1102 is effective Jan. 1, 1993. fiCross reference—Secondhand book dealers, Ch. 235. 2091 � § 344 03 LEGISL�TIVE CODE The application shall be made under oath and fu:- nishing false information therein shall be a��io- — " Fation o��Y"iis c�iapf,ei in a��ition to axiy ot�er Ia� s or ordinances. Before such person =_hall be licensed to conduct such business in the city, a copy of the application for such license shall be delivered to the chief o£ police (hereafter, in this chapter, "chief '). The chief or an officer duly detailed b}� the chief for such purpose shall invesiigate the applicant and report the result of such investiga- tion to the inspector together �vith the approi o* the disapproval of such application by the chief: provided, however, that no person shall be li- censed under the terms hereof who, at any time prior to the issuance of such licen=e, has been dul} convicted in any court of competent jurisdiction o` having violated any law relating to theft, bu:- glary, recei��in� stolen property, sale of controlled substance, or of any infraction of the terms and provisions of this chapter or of any of the ordi- nances of the City of Saint Paul regulating the business of paw-nbroking; further pro��ided, that in denying any license based upon such convic• tion, the inspector shall follow the procedures in these chapters and in Laws of?vlinnesota for 19i4, Chapter 298 (Minnesota Statutes, Chapter 364;. The term "convicted" shall include a plea of guilty even though no judgment o£ conviction is or ha been entered or imposition of sentence has been stayed. Sec. 344.04. Regulations. 96- 75 (a_)_ Records. E��ery__person en2aged and licensed____�____ .__ in the business of pawnbroker shall record all pur- chases or pa«n transactions on a standazd three- pazt form furnished by the Sair.t Paul Police De- partment, hereafter referred to as a pa«•n or bu}� form. One copy shall be maintained at the place of busine=s. The other two (2) shzil be delivered to the Saint Paul Police Department according to Section 344.64ibi of the Legislati�•e Code. P11 pa«�n tickets shall be completed, legibly «'ritten in ink in the English language, at the time any loan or purchase is made, and will include the follo«'ing information: ;1) The date and time that all such loans andior purchases are made. !2) An accurate description of any person pa�3 selling or lea��ing any h�pe o£prop- erty on deposit as a collateral security. Such description shall include, but not be lim• ited to, the person's full name; date of birth; residence; physical description, including, but not limited to, sex, height, w�eight, color of eyes and color of hair; and the identifi- cation number from any of the follo��ing forms of identification o£ the persons pawning or selling the property: valid driv- (b) Bond. Before any person shall be licensed a a pawnbroker, such applicant shall file a bond in the amount of five thousand dollazs ($5,00O.00i with a duly licensed surety company as sureh� thereon, such surety bond to be approved as to form by the city attorney, conditioned that such licensee shall observe the ordinances of said city in relation to the business of pawnbroker and that such licensee will conduct said business in confo*- mity therewith and will account for and deliver to any person legally entitled thereto any good=_, Wares or merchandise, article or thing which mai� have come into the possession of such licensee as pa�mbroker or in lieu thereof such licensee shail pay in money to such person or persons the rea- sonable value thereof. (Code 1956, §§ 366.05, 366.03; Ord. ATO. 1i929, § 3, 4-9-92) Supp. No. 19 2092 Ar �` � LICEhSES er's license containing a picture or IvIinne- sota ident�cation card. - - -- - - -- (3) The full description of all such property pur- chased by the licensee or property received on deposit as collateral security, including the manufacturer's serial number or iden- tifying insignia, if applicable, and the amount of purchase money or the amount loaned. (4) All forms shall be signed by such person and initialed by the clerk or agent for the business. (5) Entries on such forms shall not be erased, obliterated or defaced in any manner and shall be, at all reasonable times, open to inspection by the chief of police or any member of the police department or license and permit division. (b) Reports to police. The licensee or employee of the licensee shall complete a pawn or buy form, as required and furnished by the police depazt- ment, £or each transaction. Two (2) copies of such pawn or buy form shall be delivered to the chief or duly detailed ofPicer by 4:00 p.m. on Mondays, Wednesdays and Fridays following the day of the transactions. No person shall be required to fur- nish such descriptions of any property purchased from manuFacturers and wholesale dealers having an established place of business, or of any goods pu:chased at an open sale from any bankrupt stock, or from any other person doing business and having an established place of business, but any goods in this provision referred to must be accompanied by a bill of sale or other evidence of open or legitimate purchase, and must be shown to any member of the police department upon de- mand. (c) Receipts required. The licensee or agent of the licensee shall give to the person negotiating a loan or selling property a written or printed re- ceipt for the property received for the loan or pur- chase. Such receipt shall correspond with the in- formation on the pawn or buy forms. (d) Records. The police department shall main- tain the records turned over to them by the pawn- shops for no less than one yeaz. Supp. No. 18 9b �� .' §344.04 (e) Ninety-day redemption period. Any person pledging, pawning or depositing an article for se- curityshal}�rave o€-ninety (SB}daYs--- from the date when the loan or pledge was origi- nated or renewed to redeem the same before the same becomes forfeitable. I�o personal property pawned or left on deposit with any person licensed under the terms hereof shall be permitted to be redeemed from the place of business £or a period of seventy-two (72) hours, excluding Sundays and holidays. (fl Property purchased. Property purchased by the licensee shall be recorded in the same manner as items pawned or left on deposit and such prop- erty shall not be sold within thirty (30) days foi- lowingthe date o£transaction. Motor vehicles shall be exempt from this requirement. (g) Report of stolen or lost goods. I£ any goods, articles or things shall be advertised in any public newspaper of the City of Saint Paul as having been lost or stolen, and such goods, articles or things shall then be or shall thereafter come into the possession of any licensee under the terms hereof such licensee shall, upon actual notice thereof, immediately thereafter notify the chief or duly detailed officer that certain goods, articles or things advertised aze in the licensee's possession and shall not thereafter dispose of the same ex- cept upon written authority so to do from the chief or duly detailed officer. If probable cause eausts that specific goods or materials are stolen contra- band or have been used in the commission of a crime and a representative of the police depart- ment notifies the licensee of such fact, the lic- ensee shall not sell or permit to be sold, remove or permit to be removed, such goods and materials until such time as the licensee is notified by the chief of police or his or her representative. (h) Camera surueill¢nce. Licensees shall be re- quired to video tape all transactions and main- tain a dated copy of the recording for thirty (30) days. The video recording shall include a cleaz view of the customer and shall display the date and time of the transaction. The video tape re- cordings shall be provided to the police or license inspector upon request. The foregoing require- ments shall become effective as to each licensee, and remain in full force and effect thereafter as to �z�xx: i 344.04 qb-75 LEGISLn7I�'E CODE each such licensee, when during an}• sixty-day pe- riod more than one (1) percent of a11 tran=actior.; — - -----s�a�l-��rvalue--stele� prsgerzr. -'��e-ter-zs� - _ "transaction," Ior the purposes of this section sha11 me2n the purchase or redemption of property, is- suarce of pawn tickets or other sir.ulaz receip�s. aad all other pawn transactions bet«-een the lic- ensee and any other person. Dlultiple t:ansac- tions by one member of the public. or transactioa involving more than one item of propertc by one member of the public occurrin� on the =_ame o* succes=_ive days, shall be deemed to be one trans- action. The term "stolen p*oper:��." for the pL-- poses of this section shail mean aad include an�- form of tangible property, as to ��}ich the o« or possessor of such property has made oral o: ticritten complaint to a law enforcement authori.} that euch property has been stolen: pro�•ided ho�v- ever, that there need not be proof of the crime of theft or other criminal offense nor the com•iction of any person for theft or other criminal offense ia order to establish that the propeny is stolen. The license inspector, or his or her successor, shall give notice to a licensee that the foregoing require- ment for camera surveillance has become effec- tive, and such licensee shall within thirty (30) days after the receipt of such notice begin to comply. Failure to comply after receipt of such notice shall be grounds for adverse action against such lic- ensee. The licensee may dispute in any contested case hearing before an independent heazing ex- aminer, on his or her failure to comply, the fac- tual basis for the imposition of the foregoing camera surveillance requirement. (i) Burgl¢r al¢rm. Licensees shall maintain an electronic burglar alazm system for the licensed premises. 5uch system must be duly licensed by the city and maintained in working order. (Code 1956, §§ 366.07-36615; Ord. No. 1�929, § 4, 6-9-92) Sec. 344.05. Hours; minors. No person licensed under the terms of thi; chapter shall keep his office or store open for the transaction of business on any day of the w�eek before 7:00 a.m. or after 10:00 p.m., nor shall any person licensed under the terms hereof purchase or receive personal property of any nature on de- posit or pledge from any person under the age of eighteen (1S}, any person w•ho appear= under the inffuence of alcohol or controlled substance, or �e�La1�3Lincom�etent,�r-proper±�-�rh has--the- serial numbers or other identif5-ing insignia «�hich hace been destroyed, altered co��ered or defaced. �Code 19�6, § 366.06; Ord. ?�o. 17929, § �, 6-9-921 S e c. 3 4 4. 0 6. In s p e ct i o n. (ai Stolen goods, etc. Any person licensed under the provisions of this chapter shall, at ali times during the term of'said license allo�c the inspector or o:ficers of the police force of the City of Saint Paul to enter the premises «�here said licensee is carr} on such business for the purpose of in- specting such premises and inepecting the goods, �cares and merchandise therein for the purpo=_e ot locating goods suspected or alleged to ha��e been stolen or other�+�ise improperly disposed af. (b) Inspection by elaimed owner ete. �11 goods, �3•ares or merchandise, or records of same, coming into the possession of any licensee under the terms hereof shall at all times be open to the in�pection and right of examination of any person claiming to have been the owner thereof or claiming to ha�•e had any interest therein, w�hen such person is ac- companied by a police officer of the City of Saint Paui; nor shall any licensee under the terms hereof hide, conceal or stow away any article in his pos- session from any member o£ the police depart- ment of the City of Saint Paul. (Code 1956, §§ 366.04, 366.16; Ord. No. 17929, § 6, 6•9•92) Chapter 345. Peddlers, Solicitors and Transient Merchants* Sec. 345.01. Definitions. Peddler means any person who shall sell or offer for sale goods or wares, or other articles of value, at any point or place in the City o£ Saint Paul other than upon land owned or leased by said'' person, or within any park or park�vay, building •Editor's note—Section 1 of Ord.'�'o. 17708, enacted Jan. 23, 1990, amended Ch. 345 in its entirety to read as herein set out. Chapter 345 formerly pertained only to peddlers and v.�a=_ derived from Code 1956, §§ 339.01-339.11, and fzom Ord. TTO. 16841, adopted Oct.20, 19&1; Ord.?�o. 16853, adopted Feb. 11, 1982; Ord. No. 16929, adopted T7ay 27, 1982. .,,,.. � < z s ��: �� -�� Supp. No. 18 2�94 �� _� SUBTITLE A. IN GENERAL LICENSES --_ _ -- - -- - ----- - ----- - Chapter 310. Uaiform License Procedures Sec. 310.01. Definitions. For the purposes of this chapter, any chapter of the Legislative Code pertaining to licenses as here- inafter mentioned, and subsequently enacted or- dinances establishing or relating to the require- ments for Ciass I, Class II and Class III licenses under authority of the City of Saint Paul, the terms defined in this section shall have the meanings ascribed to them: Adverse ¢ction means the revocation or suspen- sion of a license, the imposition of conditions upon a license, the denial of an application for the grant, issuance or renewal of a license, the imposition of a fine, the assessment of the costs of a contested hearing, and any other disciplinary or unfavor- able action taken with respect to a license, licens- ee or applicant for a license. Adverse action in- cludes any of the foregoing directed at one (1) or more licenses held by a licensee at any location in the City of Saint Paul. Adverse action also in- clu3es disapproval of licenses issued by the State of Minnesota under statutory provisions which per- mit the governing body to disapprove the issuance of the license. Bond means a bond meeting the requirements of section 310.07 and indemnifying the City of Saint Paul against all claims, judgments or suits caused by, resulting from or in connection with any li- censed business, activity, premises, thing, facility, occurrence or othenvise under these chapters. Building ofj'ici¢Z means the official in the office of license, inspections and environmental protec- tion chazged with the responsibility of enforce- ment of the building code. Ch¢pters and these ch¢pters shall mean this Uni- form License Qrdinance, any chapter of the Leg- islative Code pertaining to licenses as hereinafter mentioned, and subsequently enacted ordinances establishing or relating to the requirements for Class I, Class II and Ciass III licenses under au- thority of the City of Saint Paul. Supp. No. 30 2026.3 g � - � � � 3�0.0� Class I Zicerzses means those licenses which can be approved and issued or denied by the director, _sub�ect to the procedures reauired by these_chap- _.__ __ _ ters. The following licenses aze so classified, and the numbers shown opposite them correspond to the chapters in the Legislative Code pertaining to each license: Class I Licenses Automobile Repair Garage and Body Shop Animal Foods Manufacturing and Distributing Auiusement ftides Mechanical Amusement Devices Bill Posters Bituminous Contractors Boarding and Roominghouses; Dormitories Bowling Alleys; Pool Halls Christmas 'I4�ee Sales Cigarettes Close-Out Sales Building Contractors Dry Cleaniug and Dry Dyeing Plants; Laundries Electrical and Appliance Repair Fire Alarm—'I�lephone Devices; Appazatus Installers Florists Legisl¢tive Code Ch¢pter 315 316 317 318 319 " 320 321 322 323 324 325 326 327 328 329 Food License Fuel Dealers--Liquid F�el Fuel Dealers—Solid Fuel �migating—Pest Control Gasoline F�lling Stations Private Fuel Pumps Hardwaze Stores House Sewer Contractors Ice Cream Processing and Dis- tributing Mercantile Broker Milk Oil—Bulk Storage Opticians Pawn Shops Peddlers Soliciting 330 331 S32 ��3 834 335 336 337 3�8 ��o J4O 341 342 343 344 345 346 § 310.01 LEGISL.STI�'E CODE -- Class I Licenses Pet Shops Radio and Television Repairs Rentalof Clothing Rentat of Hospital Equipment Rental of Kitchenwaze Rental of �ailers RoIIer R inkc Sanitary Disposal Secondhand Dealers Sidewaik Contractors Solid Waste Sign and Billboazd Construction Sound �cks and Broadcasting Uelucles Public Swimming Pools Tow Trucks�ervice Vehicles Tree 4]�imming Vending Machines Ueterinary Hospital Window Cleaning Block Par-ties Tattoo Pazlors Wrecking of Buildings Building Trades Business Licens- es Building �ades Certificates of Competency Finishing Shop 14re Recapping Plants 1Y�ansient Merchants Therapeutic Massage Center Therapeutic Massage Fractitic- ner Legisl¢tive Code Ch¢pter 347 348 349 350 351 352 353 354 355 356 357 358 359 360 361 362 363 364 365 366 367 36S 369 370 371 372 373 412 414 Class II Licenses means tl:ose Iicenses wluch must be approved or denied by ��e director, subject to the pmcedures required by these chapters. The folIowing licenses are so cisssified, and the num- bers shown opposite them corespond to the chap- ters in the Legislative Code pertaining to each license: Class II Lieenses Auctioneers—Short Term License LegisZatiae Code Chapter 390 Legisl¢tiae Class ZI Licenses Code City Gambling Permit Section 402.06 SolicitingFunds—TagDays Chapter 391 Temporary On-Sale Beer Section 410.10 Temporary Wine and Li- Section 40925 quor Class III licenses means those licenses which can be approved or denied only by the council, subject to the procedures required by these chap- ters. The following licenses aze so classified, and the numbers shown opposite them correspond to the chapters in the Legislative Code pertaining to each license: Legzslatiue Code Class III Licenses Chapter Auctioneers 400 Motor Vehicle and Parts Dealer 401 Bingo 402 Bingo Eialls 403 Private Clubs 404 Dance Halls 405 Game Rooms 406 Hotel 407 Junk Salvage and Scrap 408 Intoxicating Liquor 409 Nonintoxicating Liquor 410 Entertainment 411 Conversation Pazlors 413 Motion Picture Theatres 415 Motion Picture Drive-In Theatres 416 Pazlung Lots 417 Taxicabs 376 Gambling License 419 Director means the director of the office of li- cense, inspections and environmental protection, unless othercvise defined in the specific chapter, section or subdivision referred to. Division means the o�ce of license, inspections and environmental protection as the successor to the former division. Fee means and includes both the license fee and application fee unless otherwise provided. � �: .: Supp. No. 30 2026.4 qb-75 --�. � . � �_ .�- a > �� ? LICE`SES § 310.02 Inspector as used in these chapters means the delinquent, on any property, real or personal, sit- director of the office of license, inspections and uated within the City of Saint Paul and used in -ea�aa�aea�al �e�e£ie� o-s-bis er ��e�igBee:--- - -eoaaestien w�t,�t�e dersaid-- -- - license. License means and includes all iicences and per- mits provided for or cocered hy these chapters. License also includes licenses issued b� �he State of b'I�innesota under statutory pro«sions �;•hich per- mit the governing body to disapprove the issuance of such licenses,for the purposes of making pro- cedures in Chapter 310 of the Legislative Code applicable to the approval or disappro� of such licenses. Person means and includes any person, firm, corporation, partnership, cos�any, organization, agency, club or any group or association thereo£ It shall also include any executor, administratcr, trustee, receiver or other representative appoint- ed by law. Zoning administr¢tor means the o�cial chazged with responsibility for enforcement of the zoning code. (Code 1956, § 510.01; Ord. No. 17303, § 3, 10-29- 85; Ord. No. 17569, § 1, 6-7-88; Ord. No. 17919, § 1, 3-31-92; C.F. No. 93-1645, § 8, 12-30-93; C.F. No. 94-46, § 6, 2-2-94; C.F. No. 94-500, § 2, 7-6-94; C.F. No. 94-898, § 1, 7-13-94; C.F. No. 95-473, § 1, 5-31-95) Sec. 310.02. Application. (a) Fcrm. All applicants for licenses or permits issced ;ou: s aant to these chapters shall make both origin� ar_d renewal applications to the inspector �z s�lch forms as aze provided by the division. S�ch appIications shall not be received by the in- sp2c�cr ur_�i'_ completely filled out, accompanied bc �' f es, insurance policies, bonds, deposits, sure- tie�. a=1d indemnifications or certificates required by *hese chapters, together with the certification rec�zired i=. garagraph (b) below. (b) Taxes. No person shall be granted a license er a renewal of a license required by the Saint Paui Legislative Code unless, prior to and in ad- dition to any other requirements, rules or ordi- nances heretofore or hereafter required, the Ram- sey County Department of Property Taxation certifies that said applicant has paid any and all taxes, real or personal, before said taxes become Supp. No. 30 Notwithstanding the precious paragraph, the council, the director or the inspector may issue or renew a license if it is found that: (1) The applicant has made an agreement sat- isfactory to the Ramsey County attorney to pay delinquent taxes in periodic install- ments; (2) The applicant has properly commenced a proceeding to contest the amount of taac due or the valuation of his property, and has made all partial payments required by law in connection with such proceeding; or (3) The business property with respect to which taxes are delinquent is not owned by the applicant, but by a lessor, and it would be inequitable to require the lessee to pay such tazces. If a license is issued or renewed because of the existence of an agreement as described in subsec- tion (1) above, the license may be revoked if the licensee defaults upon such agreement. (c) Additional information. The inspector shall prescribe ihe information required to be submit- ted by each applicant in his application, in addi- tion to that required by specific sections in these chapters, as may be necessary to carry out and enforce any provision hereunder. He 5hall require in every case the applicant to submit his name; business or corporate name; names of partners, officers, directors, shareholders or trustees in- volved in the business; age; address; description or blueprint of the premises, if any, and the owner thereof, and locations and addresses of other busi- ness locations in Minnesota. (d) No reapplic¢tion within one (1) ye¢r ¢fter denial or reuoeation. No person may apply for any license within one (1) year of the denial or revo- cation of the same or similaz license by the city council, if such denial or revocation was based solely or partially upon misconduct or unfitness of the applicant, evidence of violations of law involv- ing licensed premises, evidence that the applicant had been involved in the operation of a nuisance, 2026.5 § 310.02 LEGISLATIVE CODE or fraud or deception in the license application. A license is "similaz," within the meaning of this pazagraph, if the basis upon which the revocation or denial of the original license was made would have been a relevant basis on which to deny or revoke a license of the type subsequently applied for. (e) Reapplication ¢fler deni¢Z; °interest" of ¢p- plicant irz reaoked license. An application by a per- son having an interest in, or whose shareholders or officers have an interest in, any premises or enterprise whose license has been revoked or to which a license has been denied shall be treated as an application by the person whose license was denied or revoked. The term °interest," as used in this pazagraph, includes any pecuniary interest in the ownership, operation, management or prof- its of an establishment, but does not include: bona fide loans; bona fide rental agreements; bona fide open accounts or other obligations held with or without security arising out oF the ordinary and regular course of business of selling or leasing merchandise, fixtures or supplies to such estab- Iishment; an interest in a corporation owning or operating a hotel but having at least one hundred fifty (150) or more rental units holding a license in conjunction therewith; or ten (10) percent or less interest in any other corporation holding a li- cense. (fj Prohibition on re¢pplication; uception. The prohibition on reapplication herein provided shall not apply in cases where it is othercvise expressly provided by statute or ordinance. (g) Waiting perzod ¢fter filing of petition. Any petition required to be filed with the application for any license shall not be considered as officially filed and irrevocable until seven (7) worl�ng days after a petition is received in the inspector's office. During the seven-day waiting period, any signa- tor of any petition may withdraw his name there- from by written request, and such request shall be appended to the subject petition and made a part thereof. After the seven-day waiting period, signatures may not be withdrawn unless it is shown they were obtained by fraud or duress. Sig- natures withdrawn or obtained by fraud or duress shall not be counted in determining the sufficien- cy of the petition. This subdivision shall apply in any case where the applicant for a license must gresent a statement in writing signed by a spec- ified number or percentage of persons that they have given their consent to the grant of the li- cense. (Code 1956, § 510.02; C.F. No. 95-473, § 2, 5-31- 95) Sec. 310.03. Investigation and review of new applications, etc. The inspector shall determine the sufficiency and accuracy of each new application and obtain such criminal history information as may be used under Minnesota Statutes, Chapter 364, and is othercvise avaitable by law. The inspector shall make reasonable and appropriate investigation of the premises or personal property, vehicles or fa- cilities, as may be involved in or related to the licensed activity, and shall request, where appm- priate, tfie assistance of otfier city divisions or departments in malring additional investigations for the purpose of determining whether the appli- cant is or cvill be in compliance with all applicable ordinances and statutes. The approval of such oth- er divisions or departments is not required for issuance of a license unless othercvise required by specific sections in these chapters. All new appli- cations shall be reviewed by the zoning adminis- trator or his designee for compliance with all re- quirements of the Saint Paul Zoning Code, and no new license shall be granted without full compli- ance with said requirements.: �11_ ne:c applications involving a premises, loca�ion, building or struc- ture shall be referred to the di: ector of the depart- ment of fire and safety serczces sad to the build- ing o�cial for investigation �^d : e:ommendation. (Code 1956, § 510.03; Ord. :�TO. 17361, § 1, 6-5-86) Sec. 3I0.04. LeveIs af approv2l; recommen- dations. (a) Cl¢ss I licenses. FV1 an application for the grant, issuance or renewal of a Class I license meets all the requirements of law, and there ex- ists no ground for denial, revocation or suspen- sion of, or the imposition of conditions upon, such license, the director shall grant, issue or renew said license in accordance with the application. ��.� Supp. No. 30 2026.6 q6-?5 .�'� ��. � �� < ' t�:i� LICE\SES § 310.05 (b) CI¢ss II Zicerzses. Where an application for the grant, issuance nr renewal of a Class II license meets all#,he reguirements-of lac�, aaeb #d3e�e es---- ists no ground for denial, revocation or suspen- sion of, or the imposition of conditions upon, such license, the director shall grant, issue or renew said licensein accordance with the application. (c) Class I¢nd Class II licenses, if denied by director. In the event the director, in the case of both Class I and Class II licenses, determines that the application for grant, issuance or renewal of the license does not meet all the requirements of law or that there exist grounds for denial, revo- cation, suspension or other adverse action against the license or the licensee, the director shall rec- ommend denial of the application and follow the procedures for notice and hearing as set forth in section 310.05. (d) CZ¢ss III licenses. (1) Gr¢nt, issuance or tr¢nsfer. Upon receipt of a fully compieted application and required fees for a Class III license, and after the investigation required, the director shall no- tify the council. A public hearing shall be held on the grant or issuance of all Class III licenses. In any case where the director rec- ommends denial of the grant, issuance or renewal of a Class III license, or where the council believes that there is evidence which might result in action adverse to the origi- nal or renewal app!ication, the director on his or her own :nitiative, or at the direction of the council, saa:l :ollow the procedures for notice and hearing as set forth in sec- tion 310.05. �TV�ere the application for the grant, issuarce or renewal of a Class III license mee�s all the requirements of law, and where the*e exists no ground for ad- verse acticn, the couacil shall by resolution direct that *� directo: issue such lieense ia accor3ance uith law. (2) Renew¢l. The director shall in writing no- tify the council, and the affected neighbor- hood organization(s) established for citizen participation purposes, at least siYty (60) days before the eacpiration date of all Class III licenses. A public hearing on the renew- al of any such license shall not be held ex- Supp. No. 30 cept on the request of a councilmember, which request shall be incorporated in the --#'or�-t�€ a-eeuaeil resslu�ien: Upast�e pas= — sage of such resolution, the director shall give written notice of such hearing to the affected neighborhood organizations. Such public hearing does not replace or amend any of the procedures set forth in section 310.05 of the Legislative Code. If no re- quest for a public hearing is made before the expiration of any such license, and where there exists no ground for adverse action, the council shall by resolution direct that the director issue the license in accordance with law. (e) Appe¢l; CZ¢ss I or CZ¢ss II licenses. An ap- peal to the city council may be taken by any per- son aggrieved by the grant, issuance or renewal of a Class I or Class II license; provided, however, that the appeal shall have been filed with the city clerk within thirty (3�) days after the action by the director. The only grounds for appeai shall be that there has been an error of law in the grant, issuance or renewal ofthe license. The appeal shall be in writing and shall set forth in particulaz the alleged enors of law. The council shall conduct a hearing on the appeal k-ithin thirty (30) days of the date of filing and shall notify the licensee and the appellant at least ten (10) days prior to the hearing date. The procedures set forth in section 310.05, insofaz as is practicable, shall apply to this hearing. Following the hearing, the council may affirm or remand the matter to the inspector or director, or may reverse or place conditions upon the license based on the council's determination that the decision was based on an error of law. The filing of an appeal shall not stay the issuance of the license. (fl No waiuer by renew¢l. The renewal oF any license, whether Class I, II or III, shall not be deemed to be a waiver of any past violations or of any grounds for imposition of adverse action against sueh license. (Code 1956, § 510.04; Ord. No. 17455, § 1, 5-21-87; Ord. No. 17551, § 1, 419-88; C.F. No. 94500, § 1, 7-6-94; C.F. No. 95-473, § 3, 5-31-95) Sec. 3I0.05. Hearing procedures. (a) Adaerse ¢ction; notice ¢nd hearirzg require- ments. In any case where the council may or in- 2027 § 310.05 � LEGISLATIVE CODE , tends to consider any adverse action, inciuding the revocation or suspension of a license, the im- position of conditions upon a license, or the denial of an appiication for the grant, issuance or renew- al of a license, or the disapproval of a license is- sued by the State of Minnesota, the applicant or licensee shall be given notice and an opportunity to be heazd as provided herein. The council may consider such adverse actions when recommend- ed by the inspector, by the director, by the director of any executive department established pursu- ant to Chapter 9 of the Chartzr, by the city attor- ney or on its own initiative. (b) Notice_ In each such case where adverse ac- tion is or will be considered by the couacil, the appIicant or licensee shall have been notified in writing that adverse action may be taken against the license or application, and that he or she is entitled to a hearing before action is takea by the council. The notice shall be served or mailed a reasonable time before the hearing date, and shall state the place, date and time of the hearing. The notice shall state the issues involved or grounds upon which the adverse action may be sought or based. The council may request that such cvritten notice be prepazed and served or mailed by the inspector or by the city attomey. (c) Hearing. 4Vhere there is no dispute as to the facts underlying the violation or as to the facts establishing mitigating or aggravating circum- stances, the hearing shall be held before the coun- cil. Otherwise the hearing shall be conducted be- fore a hearing examiner appointed by the council or retained by contract with the city for that pur- pose_ The applicant or the licensee shall be pro- vided an opportunity to present evidence and ar- gument as well as meet adverse testimony or evidence by reasonable cross-examination and re- buttal evidence. The hearing examiner may in its discretion permit other interested persons the op- portunity to present testimony or evidence or other- svise participate in snch hearing. (c-1) Proeedure; he¢ring ex¢miner. The hearing examiner shall heaz all evidence as may be pre- sented on behalf of the city and the applicant or licensee, and shall present to the council written findings of fact and conclusions of law, together with a recommendation for adverse action. The council shall consider the evidence con- tained in the record, the hearing examiner's rec- ommended findings of fact and conclusions, and shall not consider any factual testimony not pre- viously submitted to and considered by the hear- ing egaminer. AfEer receipt of the hearing exam- iner's findings, conclusions, and recommendations, the counciI sfiaIl provide the applicant or licensee an opportunity to present oral or written azgu- ments alleging error on the part of the examiner in the application of the law or interpretation of the facts, and to present azgument related to the recommended adverse action. Upon conclusiori of that hearing, and after considering the record, the exa?�?�?+er's findings and recommendations, togeth- er with such additional aza �ments presented at the hearing, the council shall determine what, if any, adverse action shall be taken, which action shall be by resolution. The council may accept, reject or modify the findings, conclusions and rec- ommendations of the hearing exam;ner. (o-2) Ex parte cont¢cts. If a license matter has been scheduled for an adverse hearing, council members shall not discuss the license matter with each other or with any of the parties or interested persons involved in the matter unless such dis- cussion cecurs on the record during the hearings of the matter or during the counciPs final deliber- ations of the matter. No interested person shall, with l�owledge that a license matter has been scheduled for adverse hearing, convey or attempt to convey, orally or in writing, any infozmation, argument or opinion about the matter, or any is- sue in the matter, to a council member or his or her staff until the council has taken final action on the matter; provided, however, that nothing herein shall prevent an inquiry or communica- tions regarding staLus, scheduling or procedures concerning a license matter. An interested perscn, for the purpose of this paragraph, shall mean and include a person who is an o�cer or employee of the licensee which is the subject oF the scheduIed adverse hearing, or a person who has a financiai interestin such licensee. (d) Licensee or ¢pplic¢nt m¢y be represented. The licensee or applicant may represent himself or choose to be represented by another. �� k �w__ Supp. No. 30 20�$ g6-?5 ��: x- �� ., `'�:�'. (e) Record; euidence. The hearing examiner shall receive and keep a record of such prceeedings, meTuding �stimony an3 ea�uTii�s, and s3ialI�re- ceive and give weight to evidence, including hear- say evidence, which possesses probative value com- monly accepted by reasonable and prudent persons in the conduct of their a$'airs. (fl Council ¢ction, resolution to contain /and- ings. Where the council takes adverse action with respect to a license, licensee or applicant for a license, the resolution by which such action is tak- en shall contain its findings and determination, including the imposition of conditions, if any. The council may adopt all or part of the findings, con- clusions and recommendations of the hearing ex- aminer, and incorporate the same in its resolution taking the adverse action. (g) Addition¢l procedures where required. Where the provisions of any statute or ordinance require additional notice or hearing procedures, such pro- visions shall be complied with and shall super- sede inconsistent provisions of these chapters. This shall include, without limitation by reason of this specific reference, Minnesota Statutes, Chapter 364 and Minnesota Statutes, Section 340A.415. (h) Discretion to hear notwit]zst¢nding with- draw¢l or surrender of ¢pplic¢tion or license. The council may, at its discretion, conduct a hearing or direct that a hearing be held regazding revocation or denial of a license, notwithstanding that the applicant or licensee has attempted or purported to withdraw or surrender said license or applica- tion, if the attempted withdrawal or surrender took place after the applicant or licensee had been notified of the hearing and potential adverse ac- tion. (i) Continu¢nces. Where a hearing for the pur- pose of considering revocation or suspension of a license or other disciplinary action involving a li- cense has been scheduled before the council, a continuation of the hearing may be granted by the council president or by the council at the request of the licensee, license applicant, an interested person or an attorney representing the foregoing, upon a showing of good cause by the party making the request. Supp. No. 30 LICENSES § 310.05 (j) If the council imposes an adverse action as defined in section 310.01 above, a generic notice of sucfi"ac�'ion s$alI �e prepaze3"by tfie �cense in= spector and posted by the licensee so as to be vis- ible to the public during the effective period of the adverse action. The licensee shall be responsible for tal�ng reasonable steps to make sure the no- tice remains posted on the front door of the li- censed premises, and failure to take such reason- able precautions may be grounds for furtl adverse action. (k) Imposition of costs. The councff may unpose upon any licensee or license applicant some or all of the costs of a contested hearing before an inde- pendent hearing examiner. The costs of a contest- ed hearing include, but aze not limited to, the cost of the administrative law judge or independent hearing examiner, stenographic and recording costs, copying costs, city staff and attomey time for which adequate records have been kept, rental of rooms and equipment necessary for the hear- ing, and the cost of expert witnesses. The council may impose all or part of such costs in any given case if (i) the position, claim or defense of the licensee or applicant was frivolous, arbitrary or capricious, made in bad faith, or made for the pur- pose of delay or hazassment; (ii) the nature of the violation was serious, or involved violence or the threat of violence by the licensee or employees thereof, or involved the sale of drugs by the lic- ensee or employees thereof, and/or the circum- stances under which the violatien occurred were aggravated and serious, (iii) the .2oi _tion created a serious danger to the public nealth, safety or welfare; (iv) the violaticr. 'vnvo_ced unreasonable risk of harm to vulnerable p2rsoas, o* to persons for whose safety the licensee er ap,�l:cant is or was responsible; (v) the apYi_:c� :t er licensee was su�ciently in control of the �`uation and there- fore could have reasonably avride3 ±ne violation, such as but not Hm:ted zo.. t-e nonpay of a required fee or the failure to r�new required in- surance policies; (vi) the c�iclation is covered by the matrix in section 40°.26 0; the Legislative Code; or (vii) the violation involved the sale of cigarettes to a minor. (1) Impositiorz of fznes. The council may impose a fine upon any licensee or license applicant as an adverse license action. A fine may be in such 2029 § 310.05 LEGISLATIVE CODE �=`=: amount as the couucil deems reasonable and ap- propriate, having in mind the regulatory and en- forcement purposes embodied in the partieulaz li- censing ordinance. Afine may be in addition to or in lieu of other adverse action in the sole discre- tion of the council. To the extent any other provi- sion of the I,egislative Code provides for the im- position of a fine, both provisions shaII be read together to the extent possible; provided, howev- er, that in the case of any conflict or inconsistency, the other provision shall be controlling. (Code 1956, § 510.05; Ord. No. 17551, § 2, 4-19-88; Ord. No. 17559, §§ 1, 2, 5-17-88; Ord. 2�TO. 17659, § 1, 6-13-89; Ord. No. 17911, § 1, 3-10-92; C.F. No. 94-46, § 7, 2-2-94; C.F. No. 94-898, §§ 2, 3, 7-13-94; C.F. No. 94-1340, § 2, 10-19-94; C.F I�TO. 95-473, § 4, 5-31-95) Sec. 310.06. Revocation; suspeasian; adverse actions; imposition of condi- tions. (a) Council m¢y take odverse action. The coun- cil is authorized to take adverse action, as defined in section 310.01 above, against any or all licenses or permits, licensee or applicant for a license, as provided in and by these chapters. Adverse ac- tions against entertainment licenses issued under Chapter 411 of the Legislative Code may be initi- ated for the reasons set forth in subsection (b) below, or upon any lawful grounds which are com- municated to the license holder in writing prior to the hearing before :he council. Such actions shall be initiated ��a car:ied out in accordance with the procedures outline in section 310.05; provid- ed, howecer, that the formal notice of hearing shall be used to initiate the adverse action without the use of prior n:ecedurai steps. (b) B¢sis for action. Such adverse action may be based on one (i) or more of the following rea- sons, which zre in addition to any other reason specificaily pra�>ided by law or in these chapters: (1) The license or permit was procured by mis- representation of material facts, fraud, de- ceit or bad faith. (2) The applicant or one (1) acting in his or her behalf made oral or written misstatements or misrepresentations of material facts in or accompanying the application. (3) The license was issued in violation of any of the provisions of the Zoning Code, or the premises which aze licensed or which aze to be licensed do not comply with applicable health, housing, fire, zoning and building codes and regulations. {4) The license or permit was issued in viola- tion of law, without authority, or under a material mistake of fact. (5) The licensee or applicant has failed to com- ply with any condition set forth in the li- cense, or set forth in the resolution grant- ing or renewing the license. (6) a. The licensee or applicant (or any per- son whose conduct may by law be im- puted to the licensee or applicant) has violated, or performed any act which is a violation of, any of the provisions of these chapters or of any statute, ordi- nance or regulation reasonably related to the licensed activity, regazdless of whether criminal charges have or have not been brought in connection there- with; b. The licensee or applicant has been con- victed of a crime that may disqualify said applicant from holding the license in question under the standards and procedures in VIinnesota Statutes Chapter 364; or c. The licensee or applicant (or any per- son whose conduct may by law be im- puted to the licensee or applicant) has engaged in or permitted a pattern or practice of conduct of failure to comply with laws reasonably reIated to the H- censed activity or from which an infer- ence of lack of fitness or good character may be drawn. (7) The activities of the licensee in the licensed activity created or have created a serious danger to the public health, safety or wel- faze, or the licensee performs or has per- formed his or her work or activity in an unsafe manner. (8) The licensed business, or the way in which suchbusiness is operated, maintains or per- � Supp. No. 30 2030 g6-?5 �; T: l ��.:r mits conditions that unreasonably annoy, injure or endanger the safety, health, mor- - - - - aTs, com#'ort or repose of anp considerable number of inembers of the public. (9) Failure to keep sidewalks or pedestrian ways reasonably free of snow and ice as required under Chapter 114 of the Saint Paul Leg- islative Code. (10) The licensee or applicant has shown by past misconduct or unfair acts or dealings: phys- ical abuse, assaults or violent actions done to others, including, but not limited to, ac- tions meeting the definition of criminal sex- ual conduct pursuant to Minnesota Stat- utes Sections 609.342 through 609.3451; sexual abuse, phpsicai abuse or maltreat- ment of a child as defined in Minnesota Stat- utes Section 626.556, subdivisions 2 and 10e, including, but not limited to, acts which con- stitute a violation of Minnesota Statutes Sec- tions 609.02, subdivision 10; 609.321 through 609.3451; or 617246; neglect or en- dangerment of a child as defined in Minue- sota Statutes Section 626.557, subdivision 2; the manufacture, distribution, sale, gift, delivery, transportation, exchange or baz- ter of a controlled substance as defined in Minnesota Statutes Chapter 152; the pos- session of a controlled substance as defined in Minnesota Statutes Chapter 152 in such quantities or under circumstances giving rise to a reasonable inference that the pos- session was for the purpose of sale or dis- tribution to others; or by the abuse of alco- hol or other drugs, that such licensee or applicant is not a person of the good moral character or fitness required to engage in a licensed activity, business or profession. (11) The licensee or applicant has materially changed or permitted a material change in the design, construction or configuration of the licensed premises without the prior ap- provat of the city council in the case of Class III lieenses, the director in the case of Class II licenses, and the inspector in the case of Class I licenses, or without first having ob- tained the proper building permits from the city. Supp. No. 30 LICENSES § 330.06 (12) The licensee or applicant has violated sec- tion 294.01 of the Legislative Code, or has maae or attempte3 to ma e�hibifzd eg parte contact with a council member as pro- vided in section 310A5(a2) of the Legisla- tive Code. 2031 The terms "licensee" or "applicant" for the pur- pose of this section shall mean and include any person who has any interest, whether as a holder of more than five (5) percent of the stock of a cor- poration, as a partner, or otherwise, in the prem- ises or in the business or activity which are li- censed or proposed to be licensed. With respect to any license for activities entitled to the protection of the First Amendment, notwith- stznding the foregoing provisions, neither the lack of good moral character or fitness of the licensee or applicant nor the content of the protected speech or matter shall be the basis for adverse action against the license or application. (c) Imposition of reasorzable conditions and/or restrictions. When a reasonable basis is found to impose reasonable conditions and/or restrictions upon a license issued or held under these chap- ters, any one (1) or more such reasonable condi- tions and/or restrictions may be unposed upon such license for the purpose of promoting public health, safety and welfare, of advancing the public peace and the elimination of conditions or actions that constitute a nuisance or a detriment to the peace- ful enjoyment of urban life, or promoting security and safety in nearby neighborhoods. Such reason- able conditions and/or restrictions may include c- pertain to, but aze not limited to: (1) A limitation on the hours of operation o� the licensed business or establishment, o; on particular types of activities conducted in or on said business or establishmeat; (2) Alimitation or restriction as to thz ice2tio,-, within the licensed business or estab:ish- ment whose [sic] particular type of activi- ties may be conducted; (3) A limitation as to the means of ingress or egress from the licensed establishment or its parking lot or unmediately adjacent area; (4) A requirement to provide off-street parking in excess of other requirements of law; § 310.06 LEGISLATIVE CODE (5) A limitation on the manner and means of advertising the operation or merchandise of the licensed establishment; (6) Any other reasonable condition or restric- tion limiting the operation of the licensed business or establishment to ensure that the business or establishment will harmo- nize with the chazacter of the azea in which it is located, or to prevent the development or continuation of a nuisance. The inspector may impose such conditions on Class I licenses with the consent of the license holder, or may recommend the imposition of such conditions as an adverse action against the license or licens- es; the inspector has the same power with respect to Class II licenses. The council may impose such conditions on Class III licenses with the consent of the license holder, or upon any class of license as an adverse action against the license or licens- es following notice and hearing as may be re- quired. Such conditions may be imposed on a li- cense or licenses upon issuance or renewal thereof, or upon and as part of any adverse action against a license or licenses, including suspension. Con- ditions imposed on a license or licenses shall re- main on such licenses when renewed and shall continue thereafter until removed by the council in the case of conditions on Class III licenses or conditions imposed by adverse action, and by the inspector in the case of Class I and II licenses. (d) St¢ndards for multiple Zicense determin¢- tion. In any case in which the council is autho- rized to take adverse action against less than all of the licenses held by a licensee, or appLed for by an applicant, the following standazds *aay be used: (1) The nature and gravity ofthe groun3s iound by the council to exist upoa r:.ich the ad- verse action would be base�; (2) The policy andlor regulatory gcals for the particulaz licenses invoIved, Pither as em- bodied in the Legislatice Code or as found and determined by the council; (3) The intenelationship of the licenses and their relative importance to the overall busi- ness enterprise of the licensee or applicant; (4) The management practices of the licensee or applicant cvith respect to each of such licenses; (5) The extent to which adverse action against less than all of the licenses or applications would result in di�culty in enforcing and monitoring the adverse action taken; (6) The hardship to the licensee or applicant that would be caused by applying adverse action to all licenses or applications; and (7) The hazdship and/or danger to the public, or to the public health and weifare, that would result from adverse action against less than all of the licenses or applications. (Code 1956, § 510.06; Ord. No. 17584, § 1, 8-25-88; Ord. No. 17657, § 15, 6-8-89; Ord. No. 17659, § 2, 6-13-89; Ord. I�TO. 17901, §§ 2, 3, 1-1492; Ord. No. 17917, §§ 2, 3, 3-31-92; Ord. No. 17922, § 1, 428- 92; C.F. No. 94-500, § 3, 7-6-94; C.F. No. 941340, § 3, 10-19-94; C.F. No. 95-473, § 5, 5-31-95) Sec. 310.Q7. Termination of licenses; surety bonds; insurance contracts. (a) Autom¢tic ternxirzafion, reinst¢tement; re- sponsibility of Zicensee. All licenses or permits which must, by the provisions of these chapters or other ordinances or laws, be accompanied by the filing and maintenance ofinsurance policies, deposits, guarantees, bonds or certifications shall automat- ically terminate on cancellation or withdrawal of said policies, deposits, bonds or certifications. No licensee may continue to operate or perform the licensed activity after such termination. The lic- ensee is liable and responsible for the filing and maintenance of such policies, deposits, guaran- tees, bonds or certifications as aze required in these chapters, and shall not be entitled to assert the acts or omissions of agents, brokers, employees, attomeys or any other persons as a defense or justification for failure to comply with such filing and maintenance requirements. In the event the licensee reinstates and files such policies, depos- its, bonds or certifications within thirty (30) days, the license is automatically reinstated on the same terms and conditions, and for the same period as originally issued. After thirty (30) days, the appli- cant must reapply for a renewal of his license as though it were an original application. (b) Bonds and insur¢nce requirements: (1) Surety Companies: All surety bonds run- ning to the City af Saint Paul shall be writ- � �` Supp. No. 30 2032 q6-75 f7 �� -� _ � �� LICE?�SES § aio.os ten by surety companies authorized to do business in the State of Minnesota. All in- sura$ce�e�ieie�reguir� hy #,hese ehagte�� ---- shall be written by insurance companies au- thorized to do business in the State of Min- nesota. (2) Approved as to Form: All bonds filed with the City of Saint Paul in connection with the issuance of licenses for whatever pur- pose, and all policies of insurance required to be filed with or by the City of Saint Paul in connection with the issuance of licenses for any purpose whatsoever, shall first be approved as to form by the city attomey. (3) Uniform Endorsement: Each insurance pol- icy required to be filed pursuant to these chapters shall contain the endorsement set forth in Chapter 7 of the Saint Paul Legis- lative Code. (4) Conditions: All bonds required by these chapters shall be conditioned that the lic- ensee shall observe all ordinances and laws in relation to the licensed activity, busi- ness, premises or facilities and that he shall conduct all such activities or business in conformity therecvith. Such bonds shall also indemnify the City of Saint Paul against all claims, judgments or suits caused by, re- sulting from or in connection with the li- censed business, premises, activity, thing, facility, occurrence or otherwise licensed un- derthes=:hapters. (c) Terminationofbondsandinsur¢ncerequired by city. 1e*m;nation of bonds and insurance re- quired to be filed with the city pursuant to these chapters sha1l te in accordance with the require- ments of �: hapier 8 of the Saint Paul Legislative Code. (d) Expiru!ion date to be concurrent with term of iicer.se ar permit. The expiration date of all such policies, bonds, guarantees or certifications shall be concurrent with the expiration date of the li- cease cr permit. (Code 1956, § 510.07) Sec. 310.08. Termsoflicenses;uniformdates. (a) All licenses or permits shall be valid for a period of one (1) year from the date of issuance by Supp. No. 30 the inspector, except as otherwise provided herein or in these chapters or in cases of revoeation, sus- pe�sie�er-#z��aties -ua�ea-sectiea-314.06:---- - - (b) Licensees may continue to operate their busi- ness after the expiration date of their license; pro- vided, that the licensee has filed with the inspec- tor on or before the egpiration date the appropriate license application, license fees, insurance and bonds. The inspector shall process the renewal application in the manner provided for in this Code. (c) Whenever any licensee is the holder of the two (2) or more licenses of the City of Saint Paul which expire on different dates, the inspector is authorized, at the request of the licensee, to de- termine a uniform date for the expiration of all or any number of such licenses, notwithstanding the term and expuation dates of such licenses as orig- inally issued, and notwithstanding any provision as to term of license of any ordinance of the city heretofore or hereafter enacted. The provisions hereof shall govem the issuance of any new li- cense to one already holding a license. (d) In order to conform to the foregoing grovi- sions, new licenses may be issued for a term of less than one (1) year, and the license fee therefor shali be prorated for the period of issuance. (Code 1956, § 510.08; Ord. No. 17360, § 1, 6-5-86) Sec. 310.09. Fees. (a) Exempt org¢niz¢tions. The Legislative Code exempts certain organizations from paying the cus- tomary license or permit fees or establishes a nom- inal fee of less than seven dollars ($7.00). The terms and condiiions of such exemptions aze stat- ed within the applicable chapters. Such organiza- tions shall pay a five dollars (�5.00) minimum pro- cessing fee for each and every application for a license or permit to be issued by the division man- ager, director or council of the city. (b) Fee schedule. The council may by ordinance determine and establish one (1) fee schedule for any or all licenses and permits issued pursuant to these chapters, and a separate fee schedule for applications for such licenses and permits, which may include fees to cover costs incurred by reason of the late filing. Such fees, in either schedule, shall be reasonably related to the costs of admin- 2033 § 310.09 LEGISLATIVE CODE istration incurred in connection with each such application, license or permit. Costs of adminis- tration shall mean and include, but without lim- itation by this specification, both direct and indi- rect costs and expenses, such as salaries, wages, benefits and all personnel costs including train- ing, seminars and schooling, egpenses of investi- gations and inspections, handling of inquiries and requests for assistance, telephone and communi- cations, stationery, postage, paper, reproduction, o�ce capital equipment and all o�ce supplies. Such fee schedules as adopted by ordinance and posted in the office of the inspector shall supersede in- consistent fee provisions in these chapters or in other ordinances or laws. (c) Fee for one ye¢r, may be pror¢ted. Unless otherwise specifically provided, the license fee stat- ed is for a period of one (1) year. Such fee may be prorated where a license is issued for a period of less than a yeaz. (d) I,dte fee. Unless otherwise specifically pro- vided by the particulaz licensing provisions in- volved, an applicant for the renewal of a license who makes application for such renewal after the expiration date of such license shall be chazged a late fee for each such license. The late fee shall be in addition to any other fee or payment required, and shall be ten (10) percent of the annual license fee for such license for each thirty=day period or portion thereof which has elapsed after the espi- ration date of such license. The late fee shall not exceed fifty (50) percent of the annual license fee. If any provision of these chapters imposes more stringent or additional requirements for the issu- ance of an original license than would be the case for mere renewal, those requirements must be met when the license has lapsed by reason of egpira- tion_ (Code 1956, § 51d.09; Ord. No. 16884, 2-11-82; Ord. No. 17802, § 1, 1-10-91) Sec. 310.10. Refunds of fees. (a) Refund wlzere ¢pplication withdr¢wn or de- nied; service charge. Unless otherwise specifically provided by the particulaz licensing provisions in- volved, where an application for any license is with- drawn or denied, the inspector shall refund to the applicant the license fee submitted less a service charge to recover in part the costs incused in pmcessing the application in the amount of twenty- five (25) percent of the annual license fee. (b) Limit¢tion on refurzd; other cases. In all oth- er cases as pmvided in paragraph (c), the inspec- tor may refund not to exceed one hundred dollars ($106.00) of fees received in connection with any license, permit or application therefor; provided, that he certify in writing that the amount of the refund represents a sum over and above the rea- sonable costs of administration incurred up to that time in connection with said license, permit or application. The director may refund not to ex- ceed two hundred fifty dollars ($250.00) of such fees upon a like certification by the inspector. The council may by resolution authorize all refunds upon a like certification by the inspector. (c) Bases for refunds. Refunds under pazagraph (b) may be made to the licensee or his estate: (1) Where the place of business of the licensee or his principal equipment is destroyed or so damaged by fire or any other cause that the licensee ceases for the remainder of the licensed period to engage in the licensed activity or business; (2) Where the business or licensed activity ceas- es by reason of the death or illness of the licensee or the sole employee or manager; or (3) Where it has become unl��fu2 for the lic- ensee to continue in *he business or li- censed activity other than by revocation, suspension, denial or any cri�inai activity on the part o€the licensee. (Code 1956, § 510.10) Sec. 310.11. 1�2ssfers; generai. (a) License apriailege, notproperty. All licenses or permits issued by the City of Saint Paul pur- suant to these chapters or other ordinances or laws confer a privilege on the licensee to engage in the activity or occupation so licensed, and do not constitute property or property rights or cre- ate any such rights in any licensee. No such li- cense or permit may be seized,levied upon, at- �. F � �:. �� -=„�- Supp. No. 30 2�$¢ qb-75 � 4'. � . • _ tached, egecuted upon, assessed or in any manner takea for the purpose of satisfaction of any debt or _ _ ol�tigatiaa wlfatever. -- - _ _ --- — - -_ _ LICEASES § 310.15 > � �A t . '�'�.:%:EY '< `- } `� (b) Licenses not transfer¢ble; conditions. 1TOt- withstanding any other provision of the Saint Paul Legislative Code to the contrary, no licenses is- sued by the City of Saint Paul shall be transfer- able. Sec. 310.13. R.enewal. Ecery license renew unde these chapters may - - - ------- be denied for aay licensee w& " any payment or contribution to a health and wel- fare trust or pension ttust, or similaz program, estab�ished for the benefit of his employees. (Code 1956, § 510.13) (c) �}ansfer; definition. "Transferable" means the ability to transfer a license or licenses from one (1) person to another, or from one (1) location to another. "7`ransfer," as nsed in these chapters, shall include a transfer from person to person, or from place to place, or a transfer of stock in a corporate licensee, or of shares or intesests in a partnership or other legal entity. "Ttansfer," as used in these chapters, shall not include the instance where a license is held by an individual or partnership and the transfer is by said individual or partner- ship to a corporation in which the majority of the stock is held by said individual or by the members of said partnership. (d) Deceased licensee. Notwithstanding any oth- er provision of these chapters, in any case where a liquor license is held by a person not incorpo- rated and where the license would, by reason of the death of said licensee, lapse to the city in the absence o£ this paragraph, the authorized repre- sentative of the estate of the deceased licensee may consent to and seek to reissue said license to the beneficiary to the licensed establishment. The reissuance shall be subject to all applicable re- quirements of these chapte*s and existing law. (Code 1956, § 510.21; O�d. No. 16822, 9-3-81; Ord. No. 17551, § 3, 4-19-88; C.F. ^:o. 95-473, § 6, 5-31- 95) Sec. 310.Z2. InspectioFe ai premises. The premises, faclities, piace, device or any- thing named in any licease issued pursuant to any provision of the Saint Paul Legislative Code or other law shall at all times while open to the public or while being used or oecupied for any purpose be open also to inspection and examina- tion by any police, fire, or health officer or any building inspector of the city, as well as the in- spector. (Code 1956, § 510.12) Supp. No. 30 6ec. 310.14. Savings clause. (a) If any provision in these chapters is held unconstitutional or invalid by a court of compe- tent jurisdiction, the invalidity shall extend only to the provision involved and the remainder of these chapters shall remain in force and effect to be construed as a whole. (b) 'i'he repeal of any ordinance by this ordi- nance (which enacts the Uniform License Ordi- nance) shall not a$'ect or impair any act done, any rights vested or accrued, or any suit, proceeding or prosecution had or commenced in any matter, prior to the date this o:dinance became effective. Every such act done or right vested or accnxed shall remain in full force and effect to all intents and purposes as if the repealed ordinances had themselves remained in force and effect. Every such suit, proceeding or prosecution may be con- tinued after repeal as though the repealed ordi- nances were fully in e$'ect. A suit, proceeding or prosecution which is based upon an act done, a right vested or accrued, or a violation committed prior to repeal of the repealed ordinances, but which is commenced or instituted subsequent to repeai of the repealed ordinances, shall be brought pursuant to and under the provisions of such re- pealed ordinances as though they continued to be in full force and effect. (Code 1956, § 510.14) Sec. 310.15. Penalty. Any person who violates any provision of these chapters, or other ordinances or laws relating to licensing, or who aids, advises, hires, counsels or conspires with or otherwise procures another to violate any provision of these chapters or other ordinances or laws relating to licensing is guilty of a misdemeanor and may be sentenced in accor- dance with section 1.05 of the Saint Paul Legis- lative Code. The term "person," in addition to the 2035 § 310.15 LEGISLATIVE CODE - definition in section 310.01, shall for the purpose of this section include the individual partners or members of any partnership or corporation, and as to corporations, the oScers, agents or members thereof, who shall be responsible for the violation. (Code 1956, § 510.15) Sec. 310.16. Reserved. Editor's aote�ection 310.16, pertainiag to license fees and annual increases, and derived &om Ord. No. 16885, adopt- ed Feb. 11, 1982; Ord. No. 17059, adopted Oct 20, 1983; and Ord. No. 17303, adopted Oct. 29, 1985, was repealed by Ord. No. 17884, § 1, adopted Nw. 19, 1991. Sec. 310.17. Licensee's responsibility. Any act or conduct by any clerk, employee, man- ager or agent of a licensee, or by any person pro- viding entertainment or worlang for or on behalf of a licensee, whether compensated or not, which act or conduct takes place either on the licensed premises or in any pazl�ng lot or other azea ad- jacent to (or under the lease or control o� the licensed premises, and which act or conduct vio- lates any state or federal statutes or regulations, or any city ordinance, shall be considered to be aad treated as the act or conduct of the licensee for the purpose of adverse action against all or any of the licenses held by such licensee_ To the extent this section is in conflict with seetions 409.14 and 410.09 of the Legislative Code, this section shall be controlling and prevail; but shall not other- wise amend, alter or affect such sections. (Ord. No. 17629, § 1, 1-31-89) Sec. 310.18. License fee schedule. Notwithstanding the provision of any other or- dinance or law to the contrary, the following fees are hereby provided for all the licenses listed here- in. These fees supusede all inconsistent provi- sions, including, but not limited to, graduated fee provisions, in these chapters and in other ordi- nances and laws, and include the fee for the li- cense application as part of the license fee; pro- vided, however, that this section does not amend or modify sections 310.09(a) or 310.09(d) of the Legislative Code with respect to exempt organi- zations or late fees. Pursuant to section 310.09(b) of the Legislative Code, these schedules shall be posted in the office of the director of the office of license, inspections and environmental protec- tion. These fees shall be effective for license re- newals and new license applications cecurrmg on and after January 1, 1995, or on the effective date of this section, whichever is later; provided, how- ever, that with respect to all licenses whose re- newal dates occur after the effective date of this new schedule, there shall be no increases in, nor offsets or refunds of, the e�sting fees paid, or due and Owing. (a) ENFORCEMENT LEVEL 1 Chapfer/Section No. License Description Fee 167 Commexcial Vehicle $66.00 195.04 Keeping of anima7s (Exotic Pets) 66.00 316 Animal Foods Mana & Dis- tribution 66.00 317 Amusement Rides 66.00 323 Christmas 1Yee Sales 66.00 325 Close Out Sale 66.00 327 Dr9 Cleaning Pickup Station 66.00 331 Beverage Vehicle 66.00 332 Liquid Fuel Velucle 66.00 333 Solid Fuel Vehicle 66.00 336 Private FlieI Pump 66.00 339 Ice Cream Yehicle 66.00 340 Mercantile Broker 66.00 345 Peddler (SoliciWr/TYansient) 66.00 348 Rental of Clothing & Vehicle 66.00 349 Rental of Clothes Attire Vehicle 66.Q0 350.02 Rental of Hospital Equipment 66.00 350.02 Rental of Hospital Equipmeat Ue- hicle 66.00 351 Rental of Kitchenware 66.00 353 Roller Rinks 66.00 355.01 Secoadhand Dealea (a) & (b) Single Location 66.0� 357.03 Refuse Hauler-Each Vehicle Over One 66.00 359 Sound 1Y-ucks & Broadcast Uehi- cles 66.00 371 Fiaishing Shop 66.00 361.14 1bw 1]vcklWrecker Uehicle 66.00 362 1]�ee'Ifimmer-Additional Uehicle 66.00 372 15re Recapping Plant 66.00 376.16(d) Taxicab Driver (new) 66.00 377 Lawn Fertilizer & Pesticide Ap- pIication 66.00 380 Tanning Facility 66.00 382 Pet Groo min o o 66.00 409.11 Outdoor Change in Service Area 66.00 412 Massage Center (Class B) 66.00 414 Massage Therepist 66.00 424.02 Gasoline FSlling Statioas 66.00 �a� �r`- Supp. No. 30 2036 �� . ��',- 1 �. (b) ENFORCEMENT LEVEL 2 __ ._ - - - - -- -'- �-- - -- No. L'uense Descriptiorz 320 321.03 322.02 (a) & (b) 324 326 327 332 333 334 338 342 347 352 354 355.01(c) 356 362 364 365.02 367 37S 379 401 405.02(a) 406 408 412 415.04 416 426.04 Bituminous Contractor Rooming & Boazdinghouse Bowling Center & Pool Halls Cigazettes Building Contractozs Laundry & Dry Cleaning Plants �ei Deaters-Liquid Fuel Dealers---Solid Pest Control House Sewer Contractors Oil Bulk Storage Pet Shop Rental of Trailers Sanitary Disposal Business Secoadhand Dealer-Eachibitions Sidewalk Coatractors 'hee 'himming Ueteriaary C&aic Window Cleaning Tattoo Pazlors Bed & Breakfast Residence Lock Opeaing Services Motorcycle Dealer Dance Hall Game Room Recycling Collection Ceater Massage Centez (Class A) Theaters and Movie Theaters Motion Picture Drive-in Theater Cabazet (Class A & B) (c) ENFORCEMENT LEVEL 3 Chapter/Sectiorz No. License Descri.ption 354 Sanitary Disposal Vehicle 355.01(d) SecondhaadDealer-?vlultipleDeal- ers 357.03 Refuse Hanler & Vehicle 360.03 Public Swimmiag Pools 360.03 Whirlpools 361.14 1bw'IYuck Operator 376.04 Taxicabs 401.02(a)(1) New Motor Vehicle Dealer 401.02(a) Motor Uehicle Parts Dealer 401.02(a)(5) Secondhand Dealez Motor Vehicle Parts 401A2(a)(2) Secondhand Motor Vehicle Dealer 407.03 HotelMIote1-1b 50 rooms 407.03 Hote]-Each additional room over 50 409.07.2 After Hours Food Service 412 Massage Center (Class C) 413 Conversation/Rap PazIor (A & B) Supp. No. 30 LICENSES § 310.18 ChapterlSection No. Licetrse Descriptzorz Fee - - --- - - ---- - - ____-'--�-_ . p� 415 Mini-Motion e"f`fi ' -' �- ------�---- Adult 317.00 �164.00 g17.04 Pazking Lots 164.00 164.00 164.00 164.00 164,00 264.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 264.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 164.00 Fee $317.00 317.00 317.00 317.00 317.00 317.00 317.00 317.00 317.06 317.D0 317.00 317.00 317.00 317.00 317.00 317.00 a>--cs> 422 A'Iotor Vehicle Salvage Dealer 423.02(b) Auto Body Repair Garage 423.02(a) Auto Repair Gazage 427 Health Sports Clubs (Class A& B) 428 Steam Room/Bath Aouse (A & B) (d} ENFORCEMENT LEVEL 4 Chapter/Section No. Licerzse Description 331.04 Bakery (A) Bakery (B)-Add on 331.04 Butcher (A) Butcher (B)-Add on 331.04 Cateriag (A)-Limited Catering (B)-Full Catering (C)-Add on 331.04 Day Caze Food (fU Day Care Food (B) 331.04 Food Processor/Distributor/4Vaze- house 331.04 Food Salvage 331.04 Food Vehicle 331.04 Food Veading Machine Food Vendiag Operator 331,04 Food Warehouse/Distributor Food/Boazding Facility Food/Institutional Facility 331.04 Grocery (A) Grocery (B1 Grocery (C)-To 2,000 sq. ft Grocery (D)-�fore than 2,OC^ sq. ft. 331.04 Mobile Food Ma6ile Food-Lixnited 331.04 Original Container 331.04 Restaurant (A)-0-12 seet� Restaurant (B)-More than 22 seats Restaurant (C)-Limited Restaurant(D)-92d cn Restaurant iE)-Exce^::;�: 331.04 Special Event Fco3 Salzs-I-3 days Specia] Event Food Saies-4--14 days Special Event Food Sales-Annual Special Event Food Sales-Fee Waived 339 Ice Cream Products, Process & Distribution 2037 317.00 317.00 317.00 317.00 317.00 317.00 Fee $135.00 85.00 135.00 85.00 201.00 405.00 180.00 5.00 5.00 201.00 201.00 67.00 15.00 60.00 201.00 135.00 5.00 5.00 83.00 150.00 201.00 261.00 135.00 41.00 201.00 405.00 6D.00 305.00 50.00 92.00 119.00 146.00 5.00 201.00 § 310.18 (e) ENFORCEMENT LEVEL 5 Ch¢pter/Section No. L'uerzse Descripiiorz 409 Intoxicating Liquor 409A5(b)(1) OnSale-Over 200 seats 409.05(b)(2) OnSale--0ver 100 seats 409.05(b)(3) OnSale-I00 seats or less 40925(b) Tempozary Liquor 409 On-sale C1ut�Under 200 mem- bers On-sale Club-201�500 members On-sale Ciub-501-1,000 mem- bers On�ale Club-1,001-2,000 mem- bers On-sale Club-2,001-4,000 mem- bers On-sale Club--4,001-6,000 mem- �� On-sale Club-G,000+ members 409.05(e) OffSale 409.07@X2) Sunday OnSale 409.11(a)(8) Extension of Service 409.15(b) PTme OnSale 40925 Temporary Wine 410.02 OnSale Malt (Stron� 410.02 OnSale Malt (32) 410.02 OffSale Malt 410.10(a) Temporary Malt 411.03 Entertainment-Class A 411.03 Entertainment--Class B 411.03 Entertainment-Class C 411.03 Entertainment Temporary (fl ENFORCEMEN'P LEVEL 6 Chapter/Section No. License Description 127 Courtesy Benches 167 Commercial Vehicle-Seplace- menc 225.OS Firesrms 278 Gambting Hall 318 !K.9D Opezator with up to 10 Each MAD over 10 blusic n4achiae P>musement Rides to 10 Amusement Ride over 10 TV. Units per location 331.05 Used Equipment Review Fee 341 Single Service Container 344 Pawn Shops 345 'Ltaosient Merchant 376.16 Taxicab Dtiver Renewal Taxica6 Drivu Duplicate Taxicab Duplicate Plate Taxicab Vehicle Replacement 391 Soliciting Funds-Tag Days LEGISL9TIVE CODE Chapter/Seciion No. Lirense Descri.ption Fee Fee 401 Secondhand Dealer Motor Uehicle Parts-secoad location 87.00 402 �mporary Gambling (3 types) 21.00 $5,050.00 403 Bingo Halls 179.00 4,650.00 40924(1) Gambling Manager 66.00 4,200.00 4pg.05(j) Gambliag Location-A 66.00 46.00 409.05(j) Gambling Locatioa-B 66.00 409.05(j) Gambliag Location-C 66.00 297.00 409.04(g)(5) ModificaAon of Pazking 375.40 497.00 357.03 Solid Waste TYansfer Station 1,500.06 40S Recycliag Processing Center 750.00 647.00 414 MassageTherapy-PracticalExam- ination Fee 50.00 797.00 414 Massage Therapy-Written Exam- iaation Eee 20.00 997.00 429 Infectious Wazte Processiag Facil- ity 1,500.W 1,997.00 198 KeepingofAn.imal-Renewal 25.OQ 2,997.00 2Q0.�3 Dog License 1U.00 1,000.00 Dog License-Senior Citizen 5.00 200.00 Dag License-I.ifetime (with Mi- 53.00 � 30.00 1,385.00 Dogj,icense-SeniarCitizeqLife- 46.00 time (with Microchip) 15.00 445.00 2(10.05 Dog License-Duplicate 5.00 445.00 200.08 Impounding Fee 30.00 89.00 Boazding Fee-Per Day 7.00 as.00 �C.F. No. 92-1742, § 1, 12-8-92; C.F No. 93-1650, § zi7.00 1, 12-9-93• C.F. No. 94-201 § 1, 3-16-94; C.F. No. 527.00 > > 2,500.00 941447, § 1, 12-14-94; C.F. No. 95-519, § 2, 6-7- 2zoo 95) Fee $ 20.00 is.00 317.00 354.00 583.00 42.00 44.00 301.00 28.00 28.00 42.00 445.00 z,5o0.00 65.�0 21.00 6.Q0 16.00 44.00 21.00 Sec. 310.19. Discount from on-saIe intoxicat- ing liquor license fees. A discount will be pmvided for on-sale liquor licenses and shall reduce such fees mentioned in section 310.18 by approffimately seven (7) per- cent, in the esact amounts as further provided herein, contingent upon each of the following con- ditions: (1) Driaer's Zicense guide; compilation of Z¢ws. The lieensee shall maintain on the prem- ises, in a location accessible at all times to all employees of the licensed establishment: a. A current driver's license guide, which shall include �icense specifications for both adults and minors for each state (including Canadian provinces), and shall list such,information from at least five (5) years,prior to the present date; and � ",� .. Supp. No. 30 2038 96-75 ��_. �� r 4� � ; LICENSES b. A current compilation of the laws re- lating to the sale and possession of al- coholic beyer__ages in the State, of Min- nesota as outlined in Chapter 7515 of the State of Minnesota Rules and Chap- ter 340A of the ?�'Iinnesota Statutes. This compilation must also include Chap- ters 240 through 246, 409 aad 41Q of the Saint Paul Legislative Code. (2) Signage. The licensee shall maintain on the premises, in all customer azeas, current sig- nage relating to underage consumption of alcoholic beverages, and relating to driving under the influence of alcohol. One (1) sign must be located behind the baz, and one (1) sign must be present in each additional room or section within the lounge area in which the writing on the sign behind the bar is not clearly legible. The sign(s) must have dimensions of at least one (1) foot by one (1) foot with letters at least one-half (�/z) inch in height. All signs must be eomfortably readable from a distance of fifteen (15) feet. (3) Contract with security ¢gency. a. Generally. The licensee shall partici- pate in a training program with an ap- proved private security agency, firm or association (hereafter "security agen- cy") which is selected and contracts cvith the City of Saint Paul for the purpose of providing investigations and train- ing to the licensee pursuant to this sub- section. The city contract shall provide (i) that the security agency shall not be reimbursed by the city, but that it shall recover its costs and profit by fees col- lected from the licensees which choose to receive the training program and in- vestigative services, and (ii) that the security agency shall chazge the same amount to all licensees who choose to receive such services, so that all such licensees are treated equally and with- out discrimination. b. Investig¢tion. The contract with the city shall provide for and require one (1) or more investigations by the security agency each calendar yeaz into the prac- Supp. No. 30 § 310.19 tices of the licensee with respect to (i) age identification of customers in order __. _. to prevent sales of alcoholic beverages £o minors, and (ri) preventing tlie saZe -- of alcoholic beverages to persons who are obviously intofficated. 'I'he contract shall require that the security agency disclose the results oF all such investi- gations to both the licensee and, at no cost to the city, to the o�ce of license, inspections and environmental protec- tion, within ten (10) days after such investigations aze concluded. Failure to do so will be grounds for adverse action against the licensee's licenses. The con- tract shall require that all such inves- tigations shall include unannounced and random attempts by minors to pur- chase alcoholic beverages in the licensed premises, and survefflance within the licensed premises. The security agency shall employ reasonable measures to minimize or eliminate conflicts of in- terest in providing and reporting on in- vestigations of licensees. c. Tr¢ining. The contract shall also pro- vide for alcohol awazeness training by the security agency of all o�cers, em- ployees or agents of the licensee who work in the licensed premises at least once during the calendar yeaz. All new- ly hired empioyees or new officers or agents hired during the calendar year shall receive such training within four (4) weeks following their hiring, ard shall not work in the p:emises after that four-week period until they have received such training. 2039 96-75 � ' ". _�.,.,;_. .. - ,�'' a� � �� 4 � � �'; . LIC$NSES __ — - -- --.__ __.__. d. StandardsfordpprouatInad�itio�-ka_______. the requirements specified elsewhere -- in this subsection, the securit5 agency and its investigations and training must meet or exceed the following: 1. fihe alcohol awareness course shali cover all of the topics listed herein. The content of each trainiag course shall inciude, but need not be lim- ited to: (a) Pertinent laws and ordinanc- es regarding the sale of aico- hol. (b) Verification of age, forms oF identification, and forms of false ar misleading age iden- tification. (c) The effect of aIcohoI on hu- mans and the physiology of al- cohoIintoxication. {d) Recognition of the signs of in- to�tication. (e1 Strategies for intervention to prevent intoxicated persons from consuming further alca hol. (fl The licensee's policies and guidelines, and the employee's role in observing these poli- cies. (g) Liability of the person serving alcohol. (h) Effect of alcohol on pregnant women and their fetuses, and in other vulnerable situations. 2. The seeurity agency shall have a minimum of two (2) years actual experience in alcohol awareness training. The courses may be giv- en by one (1) or more instructars, but each instructor must have a formal education and/or training in each area they teach. The courses may be svpplemented by audio- visual instruction. 5upp. No. 29 3. The security agency shall have suf- ficient personnet and physical re- sources to provide an aicohol § 311.02 awareness training course to new- ty'hired-e�giayees wi_ _ t _hin four (4) weeks after their hinng by the - ensee with whom there is a con- tract. The fees after credit for the discount sha11 be on-sale liquor over two hundred seats: four thou- sand seven hundred dollars ($4,700.00); on-sale liquor over one hundred (100) seats: four thou- sand three hundred twenty-fice dollazs ($4,325.00); and on-sale liquor up to one hundred (100) seats: three thousand nine hundred doliars (�3,900.00). (C.E No. 94-1447, § 2, 12-14-94) Chapter 311. Publie Telephones; Licensed Premises Sec. 311.01. General; definitions. This chapter shall apply to any business li- censed by the City of Saint Paul where a tele- phone accessible to the public is located on the ticensed premises. The term "licensed premises" shaIl mean and include, for the purgoses of this chapter, all the property, whether in or out of a building or structure, which is (a} used for the licensed activity, (b) under the ownership, control or management of the licensee, or leased to the Iicensee, if such property is adjacent to, or in rea- sonably close proximity to, the premises in which the licensed activity occurs. The term "licensee" shaIl mean and include, for the purposes of this chapter, the ticensee and the manager of the li- censed business; and if the licensee is a corpora- tion, partnership or other entity, the term "licens- ee" shaI2 also incIude each o�cer, director, shareholder, partner, executive and manager o� such corporation, partnership or other entity. (C.F. No. 95-64, § 1, 2-8-95) Sec. 31Z.02. Responsibility of licensees. It is the responsibility af every person holding license issued by the City of Saint Paul as a co� dition of that license and its continuation to ta� adequate measures to insure that every telepho� an the licensed premises is not used for the p�r pose of distribution, sale, use or possession of co troiled substances, prostitution or other crimi� 2040.2 § 311.02 LEGISLATIVE CODE �„ '-, activity. Failure to comply with the terms and re- quirements of this chapter shali be grounds for adverse action. (C.F. No. 95-64, § 1, 2-8-95) Sec. 311.03. Designation of probiem tele- phones. The director of the office of license, inspections and environmental protection may by written or der designate one (1} or more public telephones located on the licensed premises o£any ticensee as a problem telephone. Such designation shall be based upon evidence which possesses probative value commonly accepted by reasonable prudent persons in the conduct of their affairs, which shows that one (1) or more of the following conditions exist: (a) The telephone is regularly or frequently used to further the distribution af contralled substances, prostitution or other criminal activity. (b) The worestricted use of the telephone (i} contributes to luitering or rnngregation in the area or disturbs the peace, quiet or per- sonal sa£ety of other persons in the area, or (ii) contributes to the esistence of a nui- sance as defined in section 31017(c) of tfie Saint Paul Legislative Code. (c? The telephone is detrimental to the public safety. (d) The telephone unreasonably interferes with the flow of pedestrians or vehiculaz traffic. (e) The telephone unreasonably interferes with the use of crosswalks, traffic signs or sig- nals, hydrants or mailboaes. (fl �e telephone unreasonabIy interferes with ingress or egress from any residence or place of business. (g) The telephone is deemed by the tra�'ic en- gineer to be a safety concem or hazard. h) The telephone is considered escessive giv- en the number of other public telephones in the area and that the aggregate number of public phones contribute directly to any con- ditions listed in subsections (a) through (g) above. �. No. 35-64, § 1, 2-&95) Sec. 3I1.04. Procedure for designation of a problem phone. (a) Beforeissuing an order designating a prob- lem telephone under section 311.Q3, the director or his/her designee shall conduct an informal hear- ing to determine whether a particular telephone is a problem telephone and, if so, what measures can be taken ta correct the condition. The infor- mal hearing shall be preceded by at least ten (10} days' written notice to the licensee and the owner of the public telephone at the address indicated on the subject telephone, describing the time, place and subject matter of the hearing. The director or h9slher designee may consider any evidence with prohative value commonly accepted by reasonable prudent persons in the conduct of their affairs. (h) Upon a finding of fact that the particulaz telephone is a problem telephone, the director or his(her designee may issue an order, which shall be in writing and addressed to the owner of the telephone and ta the licensee, to take and keep in force one (1) or more of the following remedial measures including, but not limited to, the follow- ing: (1? Modifications to the public telephone through use of effisting technologp to pre- vent persons from using the telephone to facilitatz criminal activity. (2) Installation of a lockup telephone in place of the existing telephone, or of devices that effectively prevent the use of the teIephone escept under the supervision of the licens- ee or law enforcement authorities. (3) Modifications to the telephone to prohibit the reception of all incoming caIIs. <4) Movement of the telephone to a di$'erent location on the Iicensed premises. (5) Modifications to the telephone through the use of existing technologg to prevent Sts use for calls to pagers and/or celluiar telephone numbers. (6) Modifications to the telephone to prevent its use by payment in coins, and/or restric- tions on the provision of coins suitahle for use in the telephone by the licensed busi- ness and its employees, manager and own- er. . ;�J` �, �� ti�' xo. zs 2040.2 46=?5 '` { ��v�.. STATE OF MINNESOTA � OFFICE OF ADMIIVISTRATIVE HEARIlVGS __��____ _-_ ' -- _- _ - ----- — - .. ' HEARING SLTBPOENA +I�s: TO: John Fosier GREETINGS: YOU ARE HEREBY COMMANDED to lay aside all your business and excuses and to appeaz before Administrative Law Judge Jane McPeak of the Office of Administrative Hearings of the State of Minnesota, at the St. Paul City Hall, Room 42, 15 West Kellogg Boulevazd, in the city of St. Paul, County of Ramsey, Minnesota, on the 15th day of November, 1995, at 1230 o'clock in the afternoon, to appeaz as a witness in Re the Licenses of Josha Corp. d/b/a Aabe's Music Shoppe; OAH Docket No. 91-2101-9995-03. Pursuant to the authority granted at Minn. Stat. § 14.51, Witness, the Honorable Kevin E. Johnson, Chief Administrative Law Judge, at Minneapolis, Minnesota this 14th day of November, 1995 Chief Administrative Law Judge 6121341-7600 Subpoena requested by Peter P. Pangborn Telephone: (612) 266-8776 SA[tii r,vc � A.,�, C3"]Y OF SAINT PAUL R�rm C'o4mnn. x1r.')-nr OFFiCE OF 7HE CITY r ' tmuWr F. :�lurs. Cin�.{rrarrre � � � ( J _ ('rvr! Dr+:man �GJ C�q� Ha71 T-t��:o�,�. G11 Ztir,�.R-ro 15 i5_ESt tiefioG�ItF i , _ =--dmrkrhY2?fi _ __ _ _ _ _ - -_ - -- - - - _- _" Su�nt P.xrrl, .il+�tnrcum SSIO2 FAX TRANSMISSlON DATE: June 15, 1995 TO: Judge Jane McPeak Office of Administrative Heari�gs Cl0 Louise Cooper NUMBER OF PAGES (including cover page): 2 FROM: Peter Pangborn F�aralegal St. Paul City AtEOmey's O�ce 40Q City Hall FAX Nb.: 349-2665 FAX No.. 298-5619 tt you do not rece�ve a7/ pages of th�s transm+ss�on. please contaCY Peter Pangborn Telephone No 266-8776 I�r'.J _t.�':�•. iil 3��i�J�� ?.13J I•lit'�� t,ft:9T SE�6L-'�i-fiGF{ ��.i I�+Ui1 . OFFICE OF THE CITY ATTOR7�iEY '!'lmWkv £. ,if.r�x, f'try .ffi(irner r t � / 7 i� CITY nF SAINT PALTI. -4"ornr Co(mm2 .41ay�or '�v.e,�,bzr 13, 1945 Crvi/ Prv�sicvi tfJp!'iry�Hn[! 72[eP�na: 6f??6f.�'!A 7i ise.0 Kellq�; Aled. Fuu'�mild: /i1T 29&5_f>_IQ-- _-_ -- - ___ _. __St�int gerux-�!'r�meaaiu�i7�P_—'__ �_ "-- - __ S�ivT vIA FAX Jud�e Janz McPeal: c�o Loiiisc C'ooper t�Stice �if ndmini,trative Hearings IQO �-cLtihmgton Square. Suite I70C> Nfuuicapolis, Nlinnesota »a01-2133 RE: In r� The Licenses of Josha Corp. d/b/a .4abe�s Music Shopge OAH f�ile Nuiuber: 91-2101-9995-0= Our Filc Numbcr G95-0259 [)car iudge McPeaF:: I ht ri.irposc of this lereer is to request a subnoena pursuant to Minnzsota Rules. part 140�.7UC1() relaiing to the above-mentioued contzsted case hearing that is seheduled to bc; heard before you at 13 >U a m. on wednesday, Noveu7ber 1�. iA9S. The City o� St. Paul License Divisiun will b� �.afling Chis uitness to tesufy regardinU the incident �vhich serves as a basis foc• tlie action ariaiust the licenses of Josha Corp. d/bfa �abe's Music �hoppe. In order to ensurr Ihis indi��idual will ix in attendance to testify, the City of St. Paid reauest�� frnm the ;it,�te nfficz of .4dm�nistrati�e Hearinn�s a suhpoena Tor: 1 ) Juhn Foster "I�his heanng is schedtiled to take place in ruom 42 of die St. Paiil City Ha11. 15 West Kellugg gh•d.. St. Paul, iviN 55102. li y„u nred addiuonal infonuation or have an�� questions re�ardin� this �-equesi, piease do not hcsiuie tv contaet me at Zti(i-877b. "111ank cou for your co��sideration in this matter. tiincrr � .----, / � � � `iL �% � � ��, . �� ' . /G!i Yc t�°r N. Pangborrf ,% Para]egal - �;'.� �_ i�1 3_�I d� t S:\3F•1:9011H .!..11 -�� LJi:i:9d F.�t:9T �5r.i-�I-i'101J U t'.I U OFFICE OF THE CITY" ATTURi.£Y T�mJthY F, ,419Y I,.'tn' ,{ttpnjer CI"i'Y Q1= SA1NT PA[IL t.�rml'el.mmi ALnoi Novetnber 13, 1995 c„,t Urvrs,�n =��C�ryFlall Tete(.hr.x• tit2ldOGi-7!/ 7 i 8'esr A:�IIO� Bh•d Facsrml�lr2�S 5614— �-- — �_.�- __'�' _ _ _ _ _ - - ti PmrE :ttinri�"so�t. ?� IO2 96- 7� NOTICE OF CONTINLTED FZEARING SENT VIA FAX AND U.S. MAIL 7'i�t�otliy B. Foiriar Lowcy Hill Law OfEices 190o Hennepin Avenue South Mi.nneapoli�, Minr.csota 5540;-3198 RE: All licenses held by Josha Corporation dJb/a Aa'r,4`s Family DiscounC Center/Aabe's Music Shpgpe License ID NO.s: 86i61 � 44670 llear Mr. Poir�e� 'i'i;r Adminisrrative xearing wnich was continu�d to 12:30 p.m., WE-di�esday, November 15, 1495, will be he7.d in: St. paul Room 42 15 Weat St. Pau2 S i ncere �� / � ��_� f „� _ E>E <°r E'anyt�ar�� F><, ra I �c�a l City Hall/Ramsey County Courthouse ilower level of City Ha21) Kellogg Boulevarfl , Minne-sqta 55102. ., r-- _-�_.__.__�_�.��_ ,-^�=�:_�- <'�:��e Jane NcPeak, H_a��ine C7niveisity Gradua�e School, Drcw '°"�� ' "� `= ` :�. =" . , St . Paul, MN 55104 Nancy Andez Assistan� Council Secretary, Raom 31C Robez�t KFSSler, Director, LIEP, 300 Lowry Sidg, Nancy Thomas, Office of Administrative Hearings, 10C Washington Square, Mpls, MN 55401 Ed Bow�r, Community Organizer, Merriam PaTk Commui?ity CGUncil Z000 St. Anthony Ave., St. Paul, MN 5510� George and Donna Moschkau, 835 yl�uad St., SY. Paul, MN 55106 (it',� � �!1 3=� 1��i i•_:' 31Jd� �11H .! i i:� l�1LC�j ,.,v : �T S55L—�T—('dJhl < TRANSACTION REPORT > C RECE I VE 7 - NO. DATE TIME DESTSNATION STATION 10257 11-13 12:30 612 224 4697 g6_75 � , 11-13-1995(MON) 12�32 PG. DURAT[ON MODE 4 0°O1'49" NORMAL 4 �°�l'49 RESULT OK < TF2ANSACT I OfJ REPORT > 9b-?5 � i1-13-1995(MOM 12:35 C RECEIVE 7 - � ---�- � N0. DATE TIME DESTINATION $TATI�N PG. DURATIQN MODE RESULT 10258 11-13 12:34 612 298 5619 1 0°FSC7'37" 1VORM,E OK 1 0° ��' 37" OFFICE OF THE CITY ATTORNEY Tunothy E. Marz, Ciry Attarney crrY oF sAnv�r PAU1. Norm CaZeman, Mayor November 13, 1995 NOTICE OF CO23TINUED AEARING SENT VIA FAX AND U.S. MAIL Timothy B. Poirier Lowry Hill Law Offices 1900 Aennepin Avenue South Minneapplis, Minnesota 554�3-3198 Zelephone: 612 266-871 D Facsuuik: 6I2 298-56I9 9b- 75 RE: A11 licenses held by Josha Corporation d/b/a Aabe's Family Discount Center/laabe's Music Shoppe License ID NO.s: 86161 & 44670 Dear Mr. Poirier: The Administrative Hearing which was continued to 12:30 p.m., Wednesday, November 15, 1995, will be held in: St. Paul City Hall/Ramsey County Courthouse Room 42 (lower level of City Hall) 15 West Kellogg Boulevard St. Paul, Minnesota 55102. Sincerely, Peter Pangborn Paralegal cc: Judge Jane McPeak, Hamline University Graduate School, Drew 66, 1536 Hewitt Ave., St. Paul, MN 55104 Nancy Anderson, Assistant Council Secretary, Room 310 Robert Kessler, Director, LIEP, 300 Lowry Bldg. Nancy Thomas, Office of Administrative Hearings, 100 Washington Square, Mpls, MN 55401 Ed Bower, Community Organizer, Merriam Park Community Council 2000 St. Anthony Ave_, St. Paul, MN 55104 George and Donna Moschkau, 836 Mound St., St. Paul, MN 55106 crv:r DNUron 400 Ciry Xall IS West Kellogg Blvd SQinf Paul, M"mnesota Si102 � g6-7� � STATE OF NIINNESOTA COUNTY OF RAMSEY ---__ - In the Matter of All Licenses Held by Josha Cozporation d/b/a Aabe's Family Discount Centerf Aabe's Music Shoppe, et al. QAH Docket No.: 9 ]-2102-9995-3 : ��] ��1�1'1�LK�lit�[��i[�]�iLM:I� CITY OF ST. PAUL MOTION FOR ATTORNEY'S FEES AND COSTS Josha Corporation moves this tribunal for attoniey fees and costs pursuant to Minnesota Statute 549.21. Dated: � � � q � LOWRY HILL LAW OFFICE5 � �.�.. c� `'�- •Qd—c.ru� ` Timothy B P •ier Attorney for Josha Corporation 1900 Hennepin Avenue South Minneapolis, Minnesota 55403 Telephone: (612) 872-0222 Atty. Reg. No. 121617 96-75 STATE OF MINNESOTA COUNTY OF RAMSEY BEFORE THE COUNCIL OF THE CNyy'L�S�. I�Zlil� In the Matter of A11 Licenses Held by Josha Corporation d/b{a Aabe's Family Discount Center/ Aabe's Music Shoppe, et al. MEMORANDUM OAH Docket No.: 91-2102-9995-3 Minnesota Statute 544.21 is applicabie to "any civil action". The license procedure now before this tribunal is a civil action within the contemplation of the statute. After taking the deposition of Ronald Kies the City is continuing to pursue its action against 7osha Corporation for a11 items in its charging letter of September 26, 1995. The City is bringing claims which it now knows are frivolous. Mr. Kies has identified numerous items of properry wlvch were not sold to 3osha but which the City contends Josha either iilegally sold ar did not maintain adequate records as required. Their own witness has not supported the Ciry's contentions. Attorneys' fees have been incurred and continue to be incurred respecung these items. Respectfully submitted, � Dated: ' � � � LOWRY HILL LAW OFFICES / � "f' / � r E --- ' --- • c _ Tunothy oiri r Attorney for Josha Corporation 1900 Hennepin Avenue South Minneapolis, Minnesota 55403 Telephone: (612) 872-0222 Ariy. Reg. No. 121617 r.....�,m..o�.,.,.�.�.�__ _ _ �4:�"S§:�I� �4$t4';ESi)7:1 i�:�1�t.F1��-�i,�} �,,. .' .o1J<dZ �U;:Fiiv� �''� ;.,�::� �':. :...� .,� �J�.. 7 5 ._� �sc,sa�:r��-z�•� �(7_ � if�, °`. .,..%�t;�r �- _".�"°i�,l�"ij ii. . �,... �?P[::T.�_ 3i. _. �,.;. ( .,. . , _ �E='l:t -' . '�- � �Ir.r iaif: Pi?i� :.,v_ .. . . ... \t'. 'i `RO l'` -iluiti _ :L�i;'.'.s iti, _t�... . . - . - i�ti: . ; 3" i t_ _ �.�.. 1;"<i,._°i : „r.t'FY�C; �t''� i�?ij ; 5:5]� i' j� �5{ t:��;?."`r '� ;t,.�'4:., . i; , .-! � � � '; ' .7`:il: .,sa. i\ ,�_ i7: Ifl,', i�:':1�': t': �� 1'., . . r _-�� _ � �_:��'.0 t �__, _. .<1, � l� �1-: t'�:,�iY_ _ . � -. r € .L ♦ 7� , �"..y '� .,�c'�.tt: �. ;,;.c�. .:-(�C J j.3:'}�jJ"�..i.11., �J�k1 L�tt ;? l�i i'�y�7'-° %-:A! �,-.�t`::'is. f f.� � . tl�n'1� 4*� .__Jl1`C - "'.E P n .:� , iX.t �.t�A ii�i `R �_� �.�l.CiG :; � 7 `:.�C S�iii`.Ci� �'1 ��l'� S,i C;�C� 1�.'�Y..._.is ^.di:>. ,'.t� �t:-.e....5i1. _ �] _,_ � .`.�LC. _,.2II `. �;�':i 5.�,.�• t: , .,.,_ _ � , [��v�i }i _ , .dii:} l, �':y') �z! t�, iMJ t. � . :;f-. ��F �:Ji� _ � _ .F',i e� �, x, ': ,; nx _� a= , v ., .+ �A� � �;i.`C ."k-s I7`.-� •fii'.�?C: �..: i'.`.: €t'ti'; ii' �_, i :�C� L� y .� °� a1;.Ui _ _i'4i �'7 �.!�':. _ � _.:<'.r; � �� irt iit( ��.53:�1, lFit� :_:Viu�(.ii., .<_ � �� . ? �. t�).1 i iFiC c. , v i.it;, .. sEC�.. �_ C,+J'.:id'..: ��:. _ G<'i'll,"�` C41 i;?�. >?:�. �.t,t-'J - �''d'�; _ _ i . � � :.. ,r.. ��... T�ij,� i h C, 3J _ .._t .��.. .. . , �:,... ;t:n,1r'...�t'.,_ '"�u.� .�-.�-, ,.,.. _,_ " _ Rn { - `..t[„ �," � _ .,c �__ �-,i .'i�:._v0....'�3cCG v �_�' ..�aL,B .�,., j� _ �-.,_.� . ,�� ..":.�i �.�iiCi �, �_ , . ., ih.�i_ _^ STATE OF MiNNESOTA OFFICE OF ADMINISTRATIVE HEARINGS 100 Washington Square, Sude 1700 100 Washington Avenue South Minneapolis, Minnesota 55401-2138 --- -- - _ - - - gb-75 � t September 29, 1995 Gail L. Langfieid Assistant City Attorney 550 St. Paul City Haii 15 W. Keliogg Bivd. St. Paul, MP1 55101 Re: In the Matter of the Licenses of ,fosfia Corporation dtb/a Aabe's Music Shoppe; OAH Docket No. 91-2101-9995-3 Dear Ms. Langfield: Enciosed please fiind the originai and one set of photocopied subpoenas per your request regarding the above-entiiled matter. Very truly yours, �� Cr�I.Lyrt%!'i; . �-8s;'-:l1rO � J Nancy M. Thomas Docket Glerk Telephone: 612/341-7615 NT Enc. Providing Impartal Hearings for Govemment and Citizens An Equal Oppo Employer Administra6ve Law Section 8 Administrative Services (612} 341-7600 � TDO No. (612) 341-7346 � Fax No. (612) 349-2665 96-75 ' t __ ___ �,�... . _ __ - - _- S'F1�� t3F MINNESOTA . _� � � OFFICE OF ADMIAIISTRATIVE HEARINGS � HEARING SUBPOENA "�� ..� TO: Donna Moschkau 836 Mound Street St. Pauf, Minnesota 55106 GREETINGS: YOU ARE HEREBY COMMANDED to fay aside afl your business and excuses and to appear before Jane McPeak of the Office of Administrative Hearings of the State of Minnesota, at Ramsey County Courthouse, Room 220, Conference Room B, 15 West Kellogg Bou{evard, in the City of St. Paul, Ramsey County, Minnesota, on the 9th day of November, 1995 at 9:�Q o'clock in the forenaon, to appear as a witness +n the matter of the Licenses of Josha Corooration d/b/a Aabe's Mucjr Shnnna, Pursuant to the authority granted at Minn. Stat. § 14.51, Witness, the Honorabie Kevin E. Johnson, Chiefi Administrative Law Judge, at Minneapolis, Minnesota this 29�h of t m r, 1995 -�. C . V 6�►'� c►'� KEVI E. JOHNSON Jo�._ q �J;, Chief A ministrative Law Jud��e 612i341-7600 Subpoena Requested by: Gail L. Langfie{d, 612l266-8710 STATE QF MINNESOTA `� OFFICE OF ADMIIVISTRATNE HEARINGS 9 6� 7� ' �,....-'' f�,ARIlVG SUBPOENA " - - - - — - - TO: Officer Therese A. Learmont St. Paul Police Department 100 E. 11th Street St. Paul, Minnesota 55101 GREETINGS: YQU ARE HEREBY COMMANDED to lay aside ali your business and excuses and to appear before Jane McPeak of the O�ce of Administrative Hearings of the State of M+nnesota, at Ramsey County Courthouse, Room 220, Conference Room B, 15 West Keflogg Boulevard, in the City of St. Paui, Ramsey County, Minnesota, on the 9th day of November, 1995 at 9�.,�Q o'clock in the forenoon, to appear as a witness in the matter of �he Licenses of Josha Corporatino d/b/a Aabe's Music Sho�ne. Pursuant to the authority granted at Minn. Stat. § 14.51, Witness, the Honorable Kevin E. Johnson, Chief Administrative Law Judge, at Minneapalis, Minnesota this 29�1 of Se�tember, 1995 r � Ly'fM��'�^t KEVI E. JOHNS N I�n.� ph,�K Chief Administrative Law Judge 612/341-7600 5ubpoena Requested by: Gail L. Langfieid, 812l266-8710 --- -- � STATE OF MINNESOTA - _-__-'__- --�.�y . �` _. OFFICE OF ADMINISTR.ATIVE HEARINGS �-.....,--'� HEARIlVG SUB20ENA TO: George Moschkau 836 Mound Street St. Paui, Minnesota 55106 GREETINGS: 9b-75 !t! YOU ARE HEREBY COMMANDED to lay aside all your business and excuses and to appear before Jane McPeak of the O�ce of Administrative Hearings of the State of Minnesota, at Ramsey County Courthouse, Room 220, Conference Room B, 15 West Ke{{ogg Bou{evard, in the City of St. Paui, Ramsey County, Minnesota, on the 9th day of November, 1995 at 9�Q o'clock in the forenoon, to appear as a witness in the matter of the �.icenses of Josha Comoration dlb/a Aabe's M�si Sho�ae. Pursuant to the authority granted at Minn. Stat. § 14.51, Witness, the Honorabie Kevin E. Johnson, Chief Administrative Law Judge, at Minneapolis, Minnesota this 29�f of te , 1995 . C �t�_{ KE IN . JOHNSON b� A�wK Chief Administrative Law Judge 612/341-7600 Subpoena Requested by: Gaii L. Langfield, 612t266-871� 9��5 "' ,:�� STATE OF MINNESOTA -� � OFFICE OF ADMINISTR.ATIVE HEARINGS _- ---_ _- ------------ - � HEARING SUBFOENA — - '. - - - .,� TO: Sergeant Michaei Garvey St. Pau4 Pol'sce Department 100 E. 11th Street St. Paui, Minnesota 55101 GREETiNGS: YOU ARE HEREBY COMMANdED to lay aside all your business and excuses and to appear before Jane McPeak of the Office of Administrative Hearings of the State of Minnesota, at Ramsey County Courthause, Room 220, Conference Room B, 15 West Kellogg Boulevard, in the City of St. Paul, Ramsey County, Minnesota, on the 9th day of November, 1995 at 9:�Q o'ciock in the forenoon, to appear as a witness in the matter of the Licenses of Josha Corporatino d/bia Aabe's Music FIODD�. Pursuant to the authority granted at Minn. Stat. § 14.51, Witness, the Honorable Kevin E. Johnson, Chie#Administrative Law Judge, at Minneapolis, Minnesota this 29�h of e ber, 1995 � . `J KEVI . JOHNSON Is�,� /�w1C Chief Administrative Law 3udge 612l341-7600 Subpoena Requested by: Gaii L. Langfield, 612l266-8710 `�EF'-::�.-�� 711E :+�oC44 Ft9 f+f9EF.:.E51q'=..L1q_._ :.I� g4_.+E�°.:;:$ F.iil OFFICB OF' THE CiTI' AT?C)RNFY T,.,,..v,�,E .1f,>.�-. C;n•AVO.ny �;.r�rY nF SaiNT PAUL h'ern� f'nl£nr.:n Af.rv.�� September 21. 1�9� Jtidge Iaue McPrak Hamli+ie University Csr�3duate �ch��c�l prctv 6fi 1536 Hewi(t .nverzue St, Paui, �Ziiu�esota 551�4 �: In re The Licenses of Josha Corporalion d/1�1a Aabe's Music 5hoppe License Tp No. �6161 & 4�+67(l ti r� C>ur File Number: G95-0?y0 �✓�' �Z�`'� (��" t ,,4rV.,� c S i: �� ` � � � j Dcar Judge McPeak: � { O 5 E3 _._-- ; Tlie guipc�se uf this letter is in request netiv stibpoenas piusttant Co r�fi��)iPSOt3 Rtiles, p�rt 1400J000 ielating fi tlle above-ment�one�l can�ested case h�.,tritig whiah has been contine�z�i to Thui•3day. Nu<<ember 9, i995 This request is ��ade nt behalf of Ms. G.�i( L. Langfielci. dic �ttturney assigtied to tliis mattr.r. The Ciry of St. Pauf Liceitse i)icieion �vi11 he caNi�ig thes� wit��esses tu CestifV regard�ag tlle incident ��hich serves �s a basis far tha action �gainst thc> licenses Of J�>sha Cor�2oration d/L At�be's Fatttily C?i�count Center(Aahe's Music Shoppe itt order to ensur'e tliese individu�ls will be in altend�atic c to trtihl:y, the Ciry of St. Paui requcsts fro+zi tlie State Ofhce nf Ad�»inistrative Heuings subpoet�a5 fa' the fnUowing ittdividu3ls: 1.) Ser�eant Michael Gar�-e� St. P9u1 PoIice Departineur 1 UU E. I I rh Street 5t. Faul, ?��N 551f)1 3.} George Moschkau 83Ei Mowvd Street St. Paul, MN 5� I 0& 2) Officer Therese A. Learmont St. Paul Pnlice TJepartme�it ] 04 E. 11 di Street St Yaul. MN 5�1(IJ 4.) Uomia Mosclil:au 33fi Moiu�cl StrtEt �t. Paul, t�1N Sti146 �,,.�: P:.,.,,.� 9 6- 7 5!' � � ,- sr)OC.n•Harl rrtrp�:a�e r,r?:co-i'1f .__ i ; ii'zv t;elln,C� FA'<I .^ --�F«-sina:i2-4*-: — Zr. 4 i! - ! 4— _ _— _- _' ___-_-___..Scir.�Pa�d..if:rt�t<er� Silfi: Post-tt" b�and taz transminat memo 767t r ot Pages ,--� r� � i....,. 1 .�//�,'1 A.l'!'!.!.- T}�E }iearinc �vilf l�e held in Confcrence Room FS, Ramsey (_r�i�rity Hoar�9 of Commisiitinrrs, Ramsey Cc�ur�ty C�urt II��usE, Room 22Q, 35 1'✓est Keilogg Boulrva�d, S(. Pnul, Mi�uiesotu 55102. �_.EF'-�r=.-':c T�IE E��o:4� F'f9 'if9E6'_E:=-N2.f1!'=" 0 P��z z :. 1_. r_. 3 �+ C� g:_ r: F. i� 96"�� -'-- TF p�u need aduitionaS infurmati�n �r hati•e any que,�iions regarding Lhis iequest, p(ease do not t�esitate to contact „�e at ?bb-�77h. Tfi<u�k y��u for cour eo��sider�t+ozi in d1�s matte�' Sinceae �/ _ _ � - / � � � < Peter P. Pangbi�r7l Faralegal < TRANSACTION REPORT > 09-26-1995CTUE) 21:4E �� C RECE I V E 7 . �� '_�-- - - � . NO. DATE TIME DESTINATION 5'fATION PG. DURATION MODE RESUL� 9646 9-26 21:44 512+645-m588 2 0°01'20" NORMAL OK 2 0°01'20" 9bc7� STATE OF MINNESOTA BEFOKE THE COUNCIL QF TI� COUN7'YOFRAMSEY _ _ . _- ---------f;Ff'Y6FSAIb1TPAUi, --------- _ - In the Matter ofAll Licenses Held by 3osha Corporation dJbla Aabe's Famfly ORDER Discount Center/Aabe's Music Shoppe, et al. OAH Docket No. 91-2102-9995-3 A Motion to Dismiss was Sled by Josha Corporation on September 20,1995. Ire the Memorandum in support of the Motion Josha Cocpomtion alleged that the City of Saicit Pau1 had not been specific in in its allegarions and had thereby grevented the licensee from preparin$ a defense in violation of its constitutionally guaranteed right to due pcocess oflaw. The City was represented by Assistant City Attomey Gail Langfield, 400 City Hall, 15 West Kellogg Boulevazd, Saint Faui, Mumesota 55102. Josha Corporatian was represented by Timothy Poniez, Lowry Law Offices,1900 Hermepin Avenue South, Minneapolis, Minnesota 55403-3198. After hearing oral argiunent at a preheaivig conference helfl on 5eptember 21, 1995 and based on all the files and proceedings herein, the Administrative Law ludge hereby enters the following: ORDER 1. The Motion to ITismiss is denied; 2. 11te hearing, originatly scheduled for September 21,1995, is continued to November 9,1995 at 4:30 A.M.; 3. In the interim the City is ordered to provide to JosYia Corporation in a tdmely matter adequate notice of the charges against it, specifically, the properLy alleged to t�ave been sold in violation of Seetion 355.64 of the Saisrt Paul Legislative Code, the psoperty whose zeceipt oi purchase it is alleged had not been accurately recatded in violation of Section 355.04 of the Legislative Code, the tansactians allegeffiy not recorded in violalion of Section 355.41 Legislative Code, and a description of the manner in wluch it is alleged that the licensee was not cooperative in assisting the 96-i� pofice and the owners of the stolen pioperty in recavering ti�eir properry. _ _ _-- ----- ---- - - . Z DaTed flvs �+ day of September, 1995. �� 7M.r.(�eadG e A. McPeak Admuilslrative Law 7udge 96- f 5 SfATE OF MII3NESOTA i "� �, ,l�T .... BEFORE THE COUNCIL OF Tf� ---------- —_ _— - - - -.- - - — - -- - - Cl`2'I' OF�SAII3T PAL3I, In the Matter of All Licenses Aeld by Sosha Corporation dl6/a Aabe's Family Discount CenterJAabe's Music Shoppe, et al OAI�i DocketNo. 91-2102-9995-3 MEMORANDUM In its Notice of Hearing in the above-captioned matter the City of Saint Paul alleged that: "On or about April 19-22,1995, etnployees or managers ofthe licensed business sold property within ten days of having purchased or received such propaty, a violation of Section 355.64 of the Saint Paul Legislative Code. An accurate record of the property puccY�ased or received was not kept, in violation of Section 355.04. A comprehensive record of all transactionr was not kept as required by Sectian 355.01. Tbis pxoperiy was determined to be stolen properiy. It appeazs that the licensee andlor his employees or managers were not cooperative in assisting the police and the owners ofthe stolen property in recovering their property. Additionally, the ficensee transfeared the locaiion of the license in violation of Section 355.04 of the Legislative Code. These riolations aze the grounds for adverse action against the above referenced licenses.°' On 3uly 17,1995 in a letter ad$ressed to Assistant City Attomey Pliilip B. Byme, counsel for Josha Corporation requested specific information as to the properly which formed the basis o£the allegations and the identity of the complainant. Some infotmation was providcd oralty. On September 15,1995 the City, pursuant ta a request made several days before, provided Josha Coipoiation with approa4mately twenty-five pages of investigatiue reports. At no time did the City ideniify with specificity the property alleged to t�ave been sold, tY�e pioperty allegedly received or purchased without proper record keeping, and the transactions which were allegedly not recorded, all of wlilch would be violations of the Saint Paul Legislative Code. Fundamental due process requires that a licensee be given adequate nofice of fhe basis for any proposed advecse action. In providing copies of all relevant imestigative regrnis, the City only partially complied with the zequirement to give adequate notice ofthe charges. More specificity is is needed to enable Josha Corporation to adequately prepare its defense. Dismissai with prejudice, as zequested 'm Josha Corporatian's motion, is not appropziate in th'ts case 9b-?5 whece there has been some disclosuce by the City. The interests of justice aze best served -- -- -----.. _ __ ____ -- -- _— -- oon5ntianee ev}riah un�i allow the City adequaYe tune to make the appropriate disclosures and Josha Corpomrion adequate fune to prepare its defense. JAM OFFICE OF THE CITY ATTORNEY Timothy E. Man, Ciry ilnomey CITY OF SAINT PAUL Nbrm Coleman, Mayor September 22, 1995 Civil Division 400 City Hal! TeTephone: 6I2166-87l0 IS West Kellagg Blvd Facsimile: 612 298-i679 Saint Pau7, Minnesota 55702 ,. __ _ � _. __ 96-75 : 3 NOTICE OF CONTIbRTED HEARING Timothy B. Poirier Lowry Hill Law Offices 1900 Hennepin Avenue South Minneapolis, Minnesota 55403-3198 RE: All licenses held by Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe License ID NO.s: 86161 & 44670 D2ar Mr. Poirier: The Administrative Hearing which was continued to 9:30 a.m., Thursday, November 9, 1995, will be held at the following location: Conference Rcom B Ramsey County Board of Commissioners Ramsey Coi;.nty Court House, Room 220 15 West Kellogg Boulevard St. Paul, Minnesota 557.02 Sinc ze�y;� � � /'G 'C � � � Peter Pang rn Paralegal cc: Judge Jane McPeak, Hamline University Graduate School, Drew 66, 1536 Hewitt Ave., St. Paul, MN 55104 Nancy Anderson, Assistant Council Secretary, Room 310 Myrtle Dennis, Ramsey County Board of Commissioners, Room 220 Robert Kessler, Director, LIEP, 300 Lowry Bldg. Frank Staffenson, Deputy Director, LIEP, 300 Lowry Bldg. Nancy Thomas, Office of Administrative Hearings, 100 Washington Square, Mpls, MN 55401 Ed Bower, Community Organizer, Merriam Park Community Council 2000 St. Anthony Ave., St. Paul, MN 55104 Sgt. Michael Garvey, St. Pau1 Police Dept. Officer Therese A. Learmont, St. Paul Police Dept. George and Donna Moschkau, 836 Mound St., St. Paul, MN 55106 LOWgY HILL LA� OFFICES AN ASSOCIATIDN, NO' R PARTHbiSHIP WILLIAM J. HANLEY TIMOTFIY B. POIRICR MARK V. LOFSTROM _-. _ __" _ _"__--_.__"_- _ _ . _ __ - � O�COUNSEL JOHN W. HARRIGAN VIA COURIER Gail L. Langfield AssistanC City Attorney 400 City Hail 15 West Kellogg Blvd. St. Pau1, MN 55102 Re: Josha Corporation License ID Nos. 86161 and 44670 Dear Ms. Langfield: i � ; Enclosed herewith and served upon you, please find a Motion to Dismiss and Memorandum in the above matter. Sincerely, TBP:cIk Enc. September 2Q 1995 9 6" _ i900 HENNEPIN AVENUE SOVTH NINNEAPOL�S, MiNNE50TA 55403-3�98 (6�2) a72-o222 '_. __-.,. __ __ l£GAL9551SCAMSS--- _____ _ KATFii KAVPPi CYNfYY Y.OEPP-MALMEREK LUANN SKRNSETH 75 ' � LOWRY HILL LAW OFFICES Timathy B. Poirier cc: The Honorable Jane McPeak CITY OP SAINT PAUL Norm Coleman, Mayor __'�+r� _ " _ _ _ _ __ _ _ _ . _ -__ __.._�_ September 21, 1995 Judge Jane McPeak Hamline University Graduate School Drew 66 1536 Hewitt Avenue St. Paul, Minnesota 55104 OFFICE OF TIIE CITY ATTORNEY Trmothy 6 M¢rx, City Attorney 96_ Civil Division 400 City Hall Telephone. 612 266-87T 0 ISWestKelloggBlvd Facsimele: 612298-�619 Saint Paul, Minnesow 55102 _ ------- - RE: In re The Licenses of Josha Corporarion d/b/a Aabe's Music Shoppe License ID No. 86161 & 44670 �/' �� ,,,9% Our File Ntunber: G95-0290 �/�� yy rf�� 1 � �� Deaz Judge McPeak: The purpose of this letter is to request new subpoenas pursuant to Minnesota Rules, part 1400.7000 relating to the above-menrioned contested case hearing which has been continued to Thursday, November 9, 1995. This request is made of behalf of Ms. Gail L. Langfield, the attorney assigned to this matter. The City of St. Pau1 License Division wi11 be calling these witnesses to testify regarding the incident which serves as a basis for the action against the licenses of Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe. Tn order to ensure these individuals will be in attendance to testify, the City of St. Paul requests from the State Office of Administraflve Hearings subpoenas for the following individuals: 1.) Sergeant Michael Garvey St. Paul Police Department 100 E. l lth Street St. Paul, MN 55101 3.) George Moschkau 836 Mound Street St. Paul, M1V 55106 2.) Officer Therese A. Leannont St. Paul Police Department 100 E. llth Street St. Paul, MN 55101 4.) Donna Moschkau 836 Mound Street St. Paul, M1V 55106 The hearing will be held in Conference Room B, Aamsey County Board of Commissioners, Ramsey County Court House, Room 220, 15 West Kellogg Boulevard, St. Paul, Minnesota 55102. If you need addit hesitate to contac� Sincere , Peter P. Pangbom Paralegal . SF .. "i} * 3 Y. { (L .. -. .. .. . i + ± � � + '– A � ^ . : �- : : _ i ° • ! ? ,. : t� � + � -j 1: � 1 � ., � ; i ; �, = 9 -- ' '�j' ' '_'�-=`--�- �_ -� � l `' _ � ' � � , � �. - - ; - ; - - - - , � _, _ - '= t ; : _ ; ' �' 1 ' �. f . . -, _ ; ; , - ; _ .- � s Y : - _ . ; .. . - � � . i _ r � � - � � .., ll � — i a � f � . �_ ; � 3 ,,. � 4 . _ � r : � ' � _ >. � . 96= ?5 this request, please do not �n in this matter. 9 September 13, 1945 Timothy B. Poirier Attomey at Law Lowry I�ill Law O�ices 1900 Hennepin Avenue Soutlt IvTinneapolis, MN. 554fl3-3198 Ga�7 L. I,angfield Assistant City Attomey 40Q City Hall 15 West Kello� Btvd. Saint Paul, MN. 55102 96- 75 RE; 7n the MaUer of All Licenses Held by Josha CorQoration dlbla Aabe's Family Discount Centet/Aabe's Music Shoppe, et aL;QAH file no. 41-2101-9995-3 Deaz Counsel: I have just received the Notice of Hearing in the above-referenced matter. To ittsure that all par4ies are adequately informed, I want to notify you that my previous empioyment, as a practicittg attomey, was in the Office af the City Aitorney in Saint Paul from October of 147$ to May of 1992. The last 2 1/2 years I served as City Attorney. It has been three years since my employment wifh the Saint Paui City Attorney's Office and I am not acquainted with the attorney representing ihe city in tiva matter nor with the licensee or the licensed premises. I believe tliat I will be a fair and impartial judge. Should either or both parties prefer to have another adminisirative law judge preside over tt�is case, please contact N�cy Thomas at 341-7615. If I am to continue with the case, please direct all ma�7ings to me at Hamline University Graduate School, Drew 66, 1536 Hewitt Avenue, Saittt Paul, MN. 55144. My telephone nuxnber is 641-2799. Very truty yours, Jane A. McPeak Administrative Law 3udge STATE OF MINNESOTA OFFICE OF ADMINISTRATIVE HEARINGS 100 Washington Square, Suite 1700 100 Washington Avenue South Minneapolis, Minnesota 55401-2138 Providing Impartial Hearings for Government and Cfizens An Equal Opportunity Employer Administrative Law Section & Administrafive Services (612) 341-7600 e TDD No. (612) 341-7346 � Fax No. (612) 349-2665 K' 9b•7� "' ��:� ;� ':vir r :;, �_ <ti " l �. .:,. °�;.. STATE OF MINNESOTA OFFICE OF ADMIIVISTRATIVE HEARINGS �___— — - - - - -- - - ---- - ---------- �� HEARING SUBPOFNA TO: Sergant Michael Garvey St. Paul Police Department 100 East l lth S�eet St. Paul, Minnesota 55101 GREETINGS: YOU ARE HEREBY COMMANDED to lay aside all your business and excuses and to appear before Administrative Law Judge Jane McPeak of the Office of Administrative Hearings of the State of Minnesota, at the City Hall Annex, Room 1503, 25 West 4th Street in the city of St. Paui, County of Ramsey, Minnesota, on the 21st day of September, 1995, or as otherwise directed by counsel, at 930 o'clock in the forenoon, to appeaz as a witness in the Licensing matter of Josha Corporation d!b(a Aabe's Family CenterlAabe's Music Shoppe. Pursuant to the authority granted at Minn. Stat. § 14.51, Witness, the Aonorable Kevin E. Johnson, Clvef Administrative Law Judge, at Minneapolis, Minnesota this 18th day of September, 1995 Subpoena requested by Peter Pangborn Telephone: (612) 266-8776 612/341-7600 �. 96-75 "! ;�::��..._ • • ' �':� ,- � i i i ' i i' , v�y -..: � � ._ J}- _ :3` _ _ ..� TO: George Moschkau 836 Mound Street St. Paul, Minnesota 55106 GREETINGS: YOU ARE HEREBY COMMANDED to lay aside all your business and excuses and to appeaz before Administrative Law Judge Jane McFeak of the Office of Administrative Hearings of the State of Minnesota, at the City Hall Annex, Room 1503, 25 West 4th Street in the city of St. Paul, County of Ramsey, Minnesota, on the 21 st day of September, 1995, or as otherwise directed by counsel, at 930 o'clock in the forenoon, to appear as a wimess in the Licensing matter of Josha Corporation d/bla Aabe's Family Cen#er/Aabe's Music Shoppe. Pursuant to the authority granted at Minn, Stat. § 14.51, Witness, the Honorable Kevin E. Johnson, Chief Admiuistrative Law Judge, at Minneapolis, Minnesota this 18th day of September, 1995 KEVIN E. JC�I3SOI3 Chief Admimstrarive Law 612l341-7600 Subpoena requested by Peter Pangborn Telephone: (612) 266-8776 9b-7� �- `" �r.. • • ;, `�':�- �� • � i i • <�e�: ,.;i� . , � TO: Officer Therese A. Moyer St. Paul Police Department 100 East I lth Street St. Paul, Minnesota 55101 GREETINGS: YOU ARE HEREBY COMMANDED to lay aside all your business and excuses and to appear before Administrative Law Judge Jane McPeak of the Office of Administrative Hearings of the State of Minnesota, at the City Hall Annex, Room 1503, 25 West 4th Street in the city of St. Paul, County of Ramsey, Minnesota, on the 21st day of September, 1445, or as otkierwise directed by counsel, at 9:30 o'clock in the forenoon, to appear as a wimess in the Licensing matter of Josha Corporation dfb/a Aabe's Family CenterlAabe's Music Shoppe. Pursuant to the authority granted at Minn. Stat. § 14.51, Witness, the Honorable Kevin E. Iohnson, Chief Administrative Law Judge, at Minneapolis, Minnesota this 18th day of September, 1995 Subpoena requested by Peter Pangborn Telephone: (612} 265-8776 612l341-7600 96-?5 � -' ��:.:. . � . :.T:.�-.._ �Y�ll'f�`i: '� � � - � , • a ` 1 � ^- � ��.`1c}'s:. �.; f " 1 • TO: Donna Moschkau 836 Mound Street St. Paul, Minnesota 55106 GREETINGS: YOU ARE HEREBY COMMANDED to lay aside all your business and excuses and to appeaz before Administrative Law Judge Jane McPeak of the Office of Administrative Hearings of the State of Minnesota, at the City Hall Annex, Room 1503, 25 West 4th Street in the city of St. Paul, County of Ramsey, Minnesota, on the 21st day of September, 1995, or as otherwise directed by counsel, at 930 o'clock in the forenoon, to appeaz as a witness in the Licensing matter of Josha Corporation d/b/a Aabe's Family Center/Aabe's Music Shoppe, Pwsuant to the authority granted at Minn. Stat. § 14.51, Witness, the Honorable Kevin E. Johnson, Chief Administrative Law Judge, at Minneapolis, Minnesota this 1%th day of September, 1995 KEV E. JO ON Chief Administrative Law Judge 612/341-7600 Subpoena requested by Peter Pangborn Telephone: (612) 266-8776 .=il �.� �i ili il CITY OF SAINT PAUL Abrrn Co(err.�rn. ife� or Srpterober 14. 799� OFFICE OF THE CITI' ATTORNEY Txnepthv F pfarx. ('ery'.lurtn�ey 9b�- �� _ cn�d Orv,r:or. .!7UCLyHo11 'fe;_p%:one 51; _66-3'/0 ; , ;/eg[ nel:Ggg "ali'd ('a:s�mitc GIl 79v_,�,Gl� __ _ ____ _ __Sau:FBau4—H"mm�so. ... _ - _-- —'___�. Ju�9�e Iane McPeak �� C1Q OYtice aY Administratice Hearings 100 Washinp on Square, Suitc; 1700 Minneapulis. DZinnesota 554�1-213R vt�, �r�� a��ll u.s. �ti1aiL RE: In re The �.icerases of Josha Corporation dlbfa Aabe�s Family Disco�mt C'.enterlAatx�s Yfu,ic Slioppe License ID No. 36161 & 44570 CJur File �tumber: G9�-0290 Dear Jud�e McPeak: The puzpose of this letter is to request subpoenas pursuanY to Miiuiesata Rules, part 1400.70�0 relatine to the above-mentioned cont�sted case hearin� that is scheduizd to be heard before you ��n "Ihursciay, September 21 1995. This request is made of` behalf of Ms. �'iail L Langfield, the attorne}� assigned to this n�atter. Z�he Liry of St. Pau1 �icense Division w�11 be calling these �c'itnesses to tcstily rrgurdi�ig tl�e i��cident whicl� s�rves as a baS�s 1or the aetion against the licenses of Josha Curporation �,'b/a Aabe�s Fanul}� Discount CenterlAabe�s Music Shoppe. [u order to ensiue these mdividuals �vill be in attendance tu testify, the City of St. Paul requests fiom t4ie State Of��ce of Administrati�-e I-learings subpoenas for tbe foilowzng indi�iduals: t ) Ser�eant A4iehae] Garver• St I'aul T'olice Departrnent l00 E. l lth Streat St Paul. MN S ti 101 -� ? GeorQe Moschl:au 836 Mou�d SCre�t St. Yaui. MN SS106 2.y Oxficer Thezese A. Moyer St. Paui Police Depariraant 100 E. Ilth Street St. Paul, D4�3 ��+10] 4.) Doiu7a Moschfi�u 836 Mound Street St. Paul, l�'IN »lOb If - ��ou need additianal information or l�ave ax�y queynions re�arding this request, please do not hesitate to contact me at 2Ei6-3776. Thani: }�ou for your consideration in tivs matter. .?0'd ��9.-r,t'��. pl �=�i��il •=,�'.3N.�ii11� .!.11=� l�lii,�� t�c:bili S=.tiT-�T-d3� . . �.,. . . . �,..��. ,.. Pazalepal OFFICE OF THE CITY ATTOP�3�EY Tmomy F, lfars. �':n� A¢nrne� C�� F SA�T Pf�.�. G� 0: 9 6 '� t� � .'�'orm Cok�r ta. Ma}�Ar 400 Grc X.:11 Teldph,ont �I? _v �/� 1 i iL:•s: r�'t(logg Rh•d. FaCSmuit 6!? 29R-56/Y Sarr,t Pcul_..11 » _iiGB-s--- _— —_ _ ___" _ __ _ _ __ __-___ ,__._ ____+r.+i.n FAX Tf2AhlSMiSSkOfV ol " ' O ��/��s DA7E: June 15, 1995 TO: Judfle .lane McPeak FAX No.: 349-2665 Offrce of Administrative Hearings f �'LL cr�i i'�G,^� ias"t t C/O touise Cooper � �t a__ '(-"[�._ ��E-t�� -'��(� , Ti-f�X�� - NUMBER OF PAGES (including cover page): 2 FROM: Peter Pangbom Paralegai St. 4'aul Ciry Attomey's Office 400 City Haii FAX No : 79R-5619 !f you do riot raceive s11 pages of !his Uansm�ssion, please contacf Petar PartgBorn Telephone No 266-877n � �5�U3 ��8�' �� $�� S�/�>.� 01 3:�I��C� =:!317rJiJ11� :.l[_� I�di�� =�:GtJ ��_.GT Tn'.J �_�' �=Gr'�'_ < TRfiNSACTION REPORT > 09-15-1995CFRI) 09:4=. - u _ _ ------ C RECE I VE 7 ____. __..---- �-'f .-- _ _-_- -- - ---- --- �'� ! J - fJO. DATE T?ME DESTINATiON STATION 9523 9-15 09�44 612 298 5519 PG. DURATION MODE RES!�LT 2 0°00'SS" NORM.E OK 2 �° 00' S8" OFFICE OF THE CITY ATTORNEY Timothy E Mars, Ciry Anorney CITY OF SAINT PAUL Norm Calemmf. Mayor _ - _....,. September 14, 1995 7udge Jane McPeak C/O O�ce of Administrative Hearings 100 Washington Square, Suite 1700 Minneapolis, Miunesota 55401-2138 Civil Divisiox 400 Ciry Hall Telephone: 612 266-8i10 I S f7est Kel(ogg Blvd. Facsimile: 612 298-5619 _ Saira P¢ul M"unesoJ¢_5,.£ZOZ--- ---------- q6-75 f VIA FAX AND U.S. MAIL RE: In re The Licenses of 3osha Corporation d/U/a Aabe's Family Discount Center/Aabe's Music 5hoppe License ID No. 86161 & 44570 Our File Nuxnber: G95-0290 Deaz Judge McPeak: 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 before you on Thursday, September 21, 1995. This request is made of behalf of Ms. Gail L. Langfield, the attomey assigned to this matter. The City of St. Paul License Division will be calling these witnesses to testify regazding the incident which serves as a basis for the action against the licenses of Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe. In order to ensure these individuals will be in attendance to testify, the City of St. Paul requests from the State Office of Administrative Heazings subpoenas for the following individuals: 1.) Sergeant Michael Garvey St. Pau1 Police Department 100 E. l lth Stree± St. Paul, MN 55101 3.) George Moschkau 836 Mound Street St. Paul, MN 55106 2.) Officer Therese A. Moyer St. Paul Police Deparhnent � DO E. ? lth Street St. Paul, MN 55101 4.) Donna Moschkau 836 Mound Street St. Paul, MN 55106 If you need additional information or have any questions regarding this request, please do not hesitate to contact me at 266-8776. Thank you for your consideration in this matter. r c�c. r . raugwii. Paralegal OFFICE OF ADiVIINISTRATIVE HEARINGS J Re: All Licenses Held by 7osha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe With a Premises Located at 1933 University Avenue West and 1730 University Avenue West, St. Paul. License I.D. No.: 8E161 and 44670 9b-75 OAH File No.: 91-2101-9995-3 MOTION TO DISMISS Josha Corporation hereby moves the Off'ice of Administrative Hearings to dismiss the hearing concerning the above matter. This Motion is based upon Memorandums and e�ibits herein and the arguments of counsel. LOWRY HILL LAW OFFICES r Dated: a a' a ;�` s /� � (�`� L � tm�o � .� , Timothy B. Poird� r Attorney for Jos a Corporation 1900 Hennepin Avenue South Minneapolis, Minnesota 55403 Telephone: (612) 872-0222 Atty. Reg. No. 121617 g6-75 � � OFF`ICE OF ADMIlVISTRATIVE HEARINGS Re: All Licenses Aeld by Josha Corporation dlbla Aabe's Family Discount CenterJAabe's Music Shoppe With a Premises Located at 1933 University Avenue West and 1730 University Avenue West, 5t. Paul. License I.D. No.: 86161 and 44670 MEMORANDUM The Notice of Hearing in this matter is dated August 31, 1995 from the City of 5t. Paul. As notification as to the specific charges against Josha Corporation, the following was stated: OAH File No.: 91-2101-9995-3 "On or about April 19-22, 1995, employees or managers of the licensed business sold property within ten days of having purchased or received such property, a violation of Section 355.04 of the Saint Paul Legislative Code. An accurate record of the property purchased or received was not kept, in violation of Section 355.04. A comprehensive record of all transactions was not kept as required by Section 355.01. This property was deternuned to be stolen property. It appears that the licensee andlor his employees or managers were not cooperative in assisting the police and the owners of the stolen property in recovering their property. Additionally, the licensee transferred the location of the license in violation of Section 355.04 of the I,egislative Code. These violations are the grounds for adverse action against the above referenced licenses." Nowhere in the aliegations made against Josha Corporation is it stated what specific piece of property was allegedly sold within ten days after having purchased same. Likewise, there is no specific allegation as to what item or items were not properly recorded within the purview of sections 355.04 and 355.01 of the St. Paul Legislative Code. From the inception of this matter the undersigned attomey has sought to have the Clty of St. Paul provide a reference to the specific item or items that are alleged to have been sold. Attached to this Memarandum is a copy of a letter dated July 17, 1995 sent to the City of St. Paul Attorney's Office Civil Division requesting the particulars of the alleged violation. To ��-� ,, date, discovery has been done and there is still no specific allegation of the item ms _ have alleged to have been sold without proper recording, inventory, or holding period. Josha Corporation is effecrivel�denie�itsdue-gra�s�rig�ts-te Heprepare�t�s��f�n -- • — -------- itself when the City of St. Paul has refused to advise of the specifics of the alle�ed offense. The Notice of Hearing is inadequate to inform Josha Corporation of the charges against it. The charges against Josha Corporation concerning nnproper uansactions should be dismissed with prejudice. LOWRY HILL LAW OFFICES Dated: � a'� �1 S i �� l � o �� Timothy B. P � er Attorney for ha Corporation 1900 Hennepin Avenue South Minneapolis, Minnesota 55403 Telephone: (612) 872-0222 Atty. Reg. No. 121617 2 � � 96-75 i900 HENNEPIN AVENUE SOV7H M1NN£APOLIS, MtNNE50TA 55<033�9B (6i2J 872-0222 KATHI KAUPPI CYNDY KOEPP-MnLHEREK LUANN SKRIVSETH 7uly 17, 1995 VTA TELECOPIER AND FIRST CLASS MAIL Philip B. Byme Assistant City Attorney Civil Division 400 City Hall 15 West Kellogg Blvd. St. Paul, MN 55102 Re: Josha Corporation d/bla Aabe's Family discount Center/Aabe's Music Shoppe License ID Nos. 86161 and 446'7Q Dear Mr. Byrne: The undersigned attorney represents 7osha Corporation and Aabe's Pamily Discount Center/Aabe's Music Shoppe. Reference is made to your letter dated July 7, 1994, directed to Shawn Sweeney. I cannot advise my client to admit to any violation without knowing the basis of the claim. Your letter does not mention which property is the basis of the claim or who is making a complaSnt. Please provide me with the particulars of the alle;ed violation. Sincerely, . � LO�YRY HSLL LAW OFFSCES AN ASSOpATlON. NOf A PAFINFRSHIP - WlllfAM .1. FtANI.EY TIMOTHY B. POIRIER MARK V. LOPSTRO_M___.. OPCOUNSEL JOHN W. HAARiGAN LOWRY HILL LAW OFFICES Timothy B. Poirier TBP:kk cc: Mr. Shawn Sweeney FP.OM : ARBES MUSIC SHOPPE ST P,��L MM Ci"I'Y OF SAINT PAUL Ncrm Calana+5 .Nayoi July 7, 1995 Shawn Sweeney Aabe's Pamily Discount Center & Muszc Shopp� 1933 University Avenue West Saint Paul, Minnesota 55104 9bp �� , : RE: All licenses held by Josha Corporation dba Aaba•s r�amisy Discount Center/Aahe�s Music Shoppe for the premises 1aCated at 1933 LlniVersity Avenue WesC and 1730 unive�sity Avenue West, Saint Paul. License ID NO.s: 86161 & 44670 Dear Mr. Sweeney: I am in receipt of information that could lead �o an action against a11 your licensas. The basis for adverse action is: ��On or about April 29-22, 1995, employesg or managers ot the liceased business sald property within ten days of havinq purchased or received such property, a violation of Section 355.04 oi the Saint Paul Leqislative Code• An acaurats record of tha groperty purchased ar received vas not kept, in violation of sectiion 355.oA. A comprehensivs recard of all transactions was not kept as required by Section 355.01. You transferrsd the location of the liaense in vioiation of saction 355.04 cf tt�e LeSi�lative Co3e. Sinallyr it mpYears tha� yau and/or'yaur empioyees or managars were not cooperative in assist3ng tha palice and the owners of the stolen property in reoovering their property, which also furnishes, as do the above violations, gTOUnds for adverse action aqainst your liCense.�f If you da not dispute tha allegations or Pacts, or aqree that a violation occurred, but want to have the opportunity to sgeak to the Council to argue for the lightest possible penalty under ai.l tha circumstances, please call Peter Fangborn at 266-8776 to work out the procedures. Tf you contest the allegations or dispute the facts, I will take JUL.13.1995 12:55NM N % PHONE N0. : 612 645 1550 pF?�� E OF THE CITY ATI'ORNEY Tima.. � E. Ma� Ciry �trtomey Civi! I?ivision >,v ,� � H� Telephonc: 6I2 266F11U IS Wai Ke6o� Bt�d Facsimile: 61? 298•56I9 . _ _g �xnr_rot¢ SSIO2 _ FP.OM � qRBES MUSIC SHOPPE ST PAUL MM (� 7UL.12.1yy5 i:esr� r a PHONE N0. : 612 645 1550 96-75 - the necessa�y steps to sche8ule a hearinq before an independent hearing examiner and provide you wiCh a proper notice of hearing so — —��--.wi.�} ��ow__-•�_aa�-w�iar�_to_�}�eaz�and what the hasis for the hearing will be. Please respond within ten days. oY u may — responsible for costs if I schedule a hearing thereafter and you do not appear and/or contest the facts. Very truly Philip . Assistant yours, �- Byrne City A torney cc: Shawn Sweeney, 407? Foss Road, St. Irvinq Schrader, 471 Hershel St., Robert Kessler, Director, LIEP firank Staffenson, Deputy Director, Anthony, MN 55421 St. Paul, MN 55104 LZEP � SA[NT PAVL • � • r� � AAAA August 31, 1995 OFFICE OF TI� CITY ATTORNEY � Timothy E. Mmx, Ciry Avaney �' ' r - ` �. �— - - Civil Division j J �- � � 4 ;`. dA9 Ciry Hall Telephone 612 266-8710 �-' � `�.; ,_= it5 Weu Kelbgq Blvd Facsinule: 612 29&5619 __--- ------------ s��a_-, 55102 .�.�_,_-.�:.;'; � n��.:,:::.... 9�-�� NOTICE OF HEARING Timothy B. Poirier Lowry Hill Law Offices 1900 Hennepin Avenue South Minneapolis, Minnesota 55403-3198 RE: All licenses held by Josha Corporation d/b/a Aabe's Family Discount Center/Aabe's Music Shoppe for the premises located at 1933 University Avenue West and 1730 University Avenue West, Saint Paul. License ID NO.s: 86161 & 44670 Dear MY. Poirier: Please take notice that a hearing will be held at the folZowing time, date and place concerning all licenses for the premises stated above: Date: Thursday september Time: 9:30 a.m. Place: Room 1503 City Hail 25 West 4th Street St. Paul, MN 55102 21� 1995 Annex The hearing will be presided over by an Administrative Law Judge from the State of Minnesota Office of Administrative Hearings: Name: Jane McPeak Office of Administrative Hearinqs 2844 Portland Avenue Saint Paul, MN. 55401 Telephone: 645-0588 The Council of the City of Saint Paul has the authority to provide for hearings concerning licensed premises and for adverse action against such licenses, under Chapter 310, including sections 310.05 and 310.06, of the Saint Paul Legislative Code. In the case of �- q6-75 ' licenses for intoxicating and non-intoxicating liquor, authority is also conveyed by Minnesota Statutes section 340A.415. Adverse —— ar,t4or�--�g._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 you hold at the above premises as £ollows: ��Oa or about April 19-22, 1995, employees or managers of the license8 business sold property withia ten days of havinq purchased or received such property, a violation of Sectfon 355.04 of the Saint Paul Leqislativa Code. An accurate record of the property purchased or received was not kept, in violation of Section 355.04. A comprehensi.ve record of all transactions was not kept as required by Sect?o� 35�.C1. This property was determined to be stolen property. It appears that the licensee and/or his employees or manaqers were not cooperative ia assistinq the police and the owners of the stolen property in recovering their property. Additionally, the licensee transferred the location of the licease in violatioa of Section 355.04 of the Legislative Code. These violatioas are the grounds for adverse action aqainst the above referenced licenses.�� 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 appZicable. 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 the licensee or attorney may cross-examine. The licensee may then offer in rebuttal any witnesses or evidence it 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 testim�ny fr�ra 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 arguments may be made by the parties. Following the hearing, the Judge will prepare Findings of Fact, Conelusions 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 attendanae of witnesses or the production of documents in conformity with Minnesota Rules, part Notice of Hearing - Page 2 .. 1400.7000. g6-75 If you think that this matter can be resolved or settled without a formal hearing, please contact the undersigned. If a stipulation �r--a.4zeement- '....:-��`'°-�ea�ee�-as t3rat�tipu a ion wi ----- be presented to the Administrative Law Judqe for incorporation into his or her recommendation for Council action. If the licensee or his representative fails to appear at the hearing, the allegations against the licensee which have been stated earlier in this notice will be taken as true and the licensee's ability to challenge them forfeited. If 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. ��ery truly yours, 4;c�// vi Gail L. Lan ield Assistant City Attorney cc: Nancy Anderson, Assistant Council Secretary Robert Kessler, Director, LIEP Frank Staffenson, Deputy Director, LIEP Nancy Thomas, Office of Administrative Hearings, 100 Washington Square, Mpls, MN 55401 Ed Bower, Community Organizer, Merriam Park Community Council 2000 St. Anthony Ave., St. Paul, MN 55104 Sgt. Leonard J. Peterson, St. Paul Police Dept. Sgt. Michael Garvey, St. Paul Police Dept. Officer Therese A. Moyer, St. Paul Police Dept. George and Donna Moschkau, 836 Mound St., St. Paul, MN 55106 Notice of Hearing - Page 3