Accusation Against Woodley Enterprises Inc

Accusation Under Alcoholic Beverage Control Act and State Constitution

In the Matter of the Accusation Against:

Licensee:

Woodley Enterprises Inc

DBA:

Club 7557

Premises:

7557-59 Woodley Ave, Van Nuys, CA 91406

License(s):

On-Sale General Eating Place

File:

47-419125

Reg:

180868345

Stamp 1:

Filed, Alcoholic Beverage Control, January 18, 2018

I hereby complain and accuse the above respondent(s), holding the above license(s), based on the following statement of facts:

Count 1

By reason of the following facts, there is cause for suspension or revocation of the license(s), in accordance with Section 24200 and Sections 24200(a) and (b) of the Business and Professions Code. It is further alleged that the continuance of the license would be contrary to public welfare and/or morals as set forth in Article XX, Section 22 of the California State Constitution and Sections 24200(a) and (b) of the Business and Professions Code. The facts which constitute the basis for the suspension or revocation by the Department are as follows:

On or about June 22, 2017, respondent-licensee’s agent or employee, “Vanessa,” encouraged or permitted John Doe #1, on the licensed premises, to touch, caress or fondle her breasts, buttocks, anus, or genitals, in violation of California Code of Regulations, Title 4, Division 1, Section 143.2(3).

Count 2

By reason of the following facts, there is cause for suspension or revocation of the license(s), in accordance with Section 24200 and Sections 24200(a) and (b) of the Business and Professions Code. It is further alleged that the continuance of the license would be contrary to public welfare and/or morals as set forth in Article XX, Section 22 of the California State Constitution and Sections 24200( a) and (b) of the Business and Professions Code. The facts which constitute the basis for the suspension or revocation by the Department are as follows:

On or about June 22, 2017, respondent-licensee’s agent or employee, “Vanessa,” encouraged or permitted John Doe #2, on the licensed premises, to touch, caress or fondle her breasts, buttocks, anus, or genitals, in violation of California Code of Regulations, Title 4, Division 1, Section 143.2(3).

Count 3

By reason of the following facts, there is cause for suspension or revocation of the license(s), in accordance with Section 24200 and Sections 24200(a) and (b) of the Business and Professions Code. It is further alleged that the continuance of the license would be contrary to public welfare and/or morals as set forth in Article XX, Section 22 of the California State Constitution and Sections 24200(a) and (b) of the Business and Professions Code. The facts which constitute the basis for the suspension or revocation by the Department are as follows:

On or about June 22, 2017, respondent-licensees permitted “Anna” to perform or simulate an act of sexual intercourse, masturbation, sodomy, bestiality, oral copulation flagellation or other sexual act upon the premises, prohibited by law, in violation of California Code of Regulations, Title 4, Division 1, Section 143.3(1)(a).

Count 4

By reason of the following facts, there is cause for suspension or revocation of the license(s), in accordance with Section 24200 and Sections 24200(a) and (b) of the Business and Professions Code. It is further alleged that the continuance of the license would be contrary to public welfare arid/or ~orals as set forth in Article XX, Section 22 of the California State Constitution and Sections 24200(a) and (b) of the Business and Professions Code. The facts which constitute the basis for the suspension or revocation by the Department are as follows:

On or about June 22, 2017, respondent-licensees permitted “Anna” to perform or simulate an act of touching, caressing or fondling her breasts, buttocks, anus or genitals, upon the premises, in violation of California Code of Regulations, Title 4, Division 1, Section 143.3(1)(b).

Count 5

By reason of the following facts, there is cause for suspension or revocation of the license(s), in accordance with Section 24200 and Sections 24200(a) and (b) of the Business and Professions Code. It is further alleged that the continuance of the license would be contrary to public welfare and/or morals as set forth in Article XX, Section 22 of the California State Constitution and Sections 24200(a) and (b) of the Business and Professions Code. The facts which constitute the basis for the suspension or revocation by the Department are as follows:

On or about June 22, 2017, respondent-licensee’s agent or employee, “Lala,” encouraged or permitted John Doe #3, on the licensed premises, to touch, caress or fondle her breasts, buttocks, anus, or genitals, in violation of California Code of Regulations, Title 4, Division 1, Section 143.2(3).

For purposes of imposition of penalty, if any arising from this accusation, it is further alleged the respondent-licensee(s) has/have suffered the following disciplinary history:

Licensee(s) Previous Record: Licensed as above since December 27, 2004.

WHEREFORE, I recommend that a hearing be held on this accusation.

Dated this 4th day of January, 2018.

Attorney
Department of Alcoholic Beverage Control