2010-09-23_1284 San Pablo_Bingo Revocation

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For Board Action
September 23, 2010
1284 San Pablo – Bingo Facility
Public Hearing to Consider Recommendation to City Council as to Whether the
Bingo Facility at 1284 San Pablo Avenue is in Violation of Use Permit #A954
(Resolution No. 53,501-N.S.) Under BMC Section 23B.60.020 and, if so, the
appropriate remedy.
RECOMMENDATION
That the Board consider the testimony presented at the public hearing and recommend to the City
Council that it find that the Bingo Facility at 1284 San Pablo is in violation of Use Permit #A954 under
Berkeley Municipal Code Chapter 23B.60, and order that Use Permit #A954 be revoked.
BACKGROUND AND SUMMARY
Berkeley Municipal Code Provisions for This ZAB Hearing
The Zoning Adjustments Board (ZAB) is conducting this hearing pursuant to Berkeley Municipal
Code (BMC) Chapter 23B.060. For the purposes of this Chapter, the ZAB is an advisory body to the
Council. BMC Section 23B.60.020A provides that the Council may revoke or modify a Permit if it
finds that “[t]he holder of the permit has failed to comply with at least one or more of the conditions
set forth therein.”
The ZAB’s duties in this proceeding are:
to conduct a public hearing, and
to “make a written recommendation to the Council whether to revoke or modify the Permit on
the grounds specified in Section 23B.60.020, based on the evidence, testimony, and facts
presented to the Board at the hearing. Such recommendation shall include written findings in
support thereof and shall be issued within thirty-five (35) days after the conclusion of the
hearing.”
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The Council will conduct its hearing within 60 days of the issuance of the ZAB recommendation
(Section 23B.60.050). According to Section 23B.60.060, upon making any of the required findings,
“the Council may impose any remedy available at law or in equity which shall include, but is not
limited to, any of the following or combination thereof: enjoining the use in whole or in part;
imposing reasonable conditions upon any continued operation of the use, including those uses which
constitute non-conforming uses; requiring continued compliance with any conditions so imposed;
requiring the use to guarantee that such conditions shall in all respects be complied with; and, upon a
failure of the user to comply with any conditions so imposed, imposing additional conditions or
enjoining the use in whole or in part.”
Exhibit Address Errors
The correct address for the Bingo Facility is 1284 San Pablo Avenue. However, Exhibits 6, 9, 10, and
14 erroneously have the address as 1284 Gilman. There is no bingo facility at 1284 Gilman.
Ownership and Operation of the Bingo Facility
The property at 1284 San Pablo is owned by the McDermott Family Limited Partnership. The
operation of the Bingo Facility at 1284 San Pablo was approved by Use Permit #A954 on October 21,
1986 (Exhibit 1). According to City records, names listed for the property are: George F. McDermott
and McDermott Family Limited Partnership.
Originally Use Permit #A954 required that all non-profit bingo operators be approved by the Zoning
Adjustments Board prior to operating non-profit bingo at 1284 San Pablo. On January 9, 2003, at the
request of the McDermott’s representative and Bingo Hall Manager Mary Parker, the Zoning
Adjustments Board approved a modification to Use Permit #A954 allowing staff level approval of
future bingo operators (Exhibit 2, 3 and 4).
Use Permit #A954
Use Permit #A954 placed forty-five (45) operating conditions on the bingo facility operator (property
owner) and non-profit organizations occupying the facility. Since 1986, both the property owner and
non-profit organizations have consistently operated in violation of the Use Permit conditions.
Use Permit #A954, Condition 43 requires all non-profit organizations to comply with Berkeley
Municipal Code (BMC) Chapter 9.18. BMC Section 9.18.060 requires all organizations to have
available a list of approved staff at all times. Conditions 29 through 32 and BMC Section 9.18.100
require that a “Bingo Manager”, who shall be a member of the organization, be appointed and
responsible for the operation of the game and that all other staff be volunteer members of the
organization.
BMC Section 9.18.070 restricts bingo prize awards to $250. Consistent with Use Permit Condition 44,
BMC Section 9.18.130 requires all organizations to use the bingo facility to perform the duties of the
non-profit organization and the bingo permit of any organization that fails to use the bingo facility to
perform the duties of the non-profit organization may be nullified.
Penal Code Section 326.5(f) requires all organizations to use the bingo facility to perform the duties of
the organization. Penal Code Section 326.5(h) states that only members of the authorized organization
must staff and operate bingo games. Penal Code Section 326.5 requires that bingo profits may only be
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used for charitable purposes. Penal Code Section 326.5(k)(2)(A) mandates that no more than 20% of
bingo proceeds before the deduction of prizes or $2000 per month, whichever is less, may be used for
rental of property. Penal Code Section 326.5(n) states that no bingo prize shall exceed $500. However,
State Section 326.5 does not prohibit the City from establishing a lower bingo prize limit and,
therefore, does not preempt BMC Section 9.18.070 limit of $250.00 prizes.
Bingo Operators
Since 1986, thirty-five (35) non-profit organizations have operated non-profit bingo at 1284 San
Pablo. From 1986 to 2004, all Use Permit modification applications to approve new non-profit bingo
organizations were authorized or signed by George McDermott or the Bingo Hall Manager, Mary
Parker.
In 2007, George McDermott submitted a letter to the Code Enforcement Unit in response to a Notice
of Violation issued on February 27, 2007. The letter stated that Robert Casteel (Exhibit 5 ) was
authorized to act on behalf of the McDermott Family Limited Partnership on matters relating to the
permitting and operation of bingo at 1284 San Pablo. Since 2007, the Planning Department has
approved applications to operate non-profit bingo at 1284 San Pablo for five non-profit organizations.
Two of these five applications were submitted by Ulysses Cooperwood on behalf of Youth Actors
Company organization and William Carpenter on behalf of East Bay Charities organization. On July
13, 2010, due to ongoing and extensive violations, the bingo permits issued pursuant to Chapter 9.18
for Mr. Cooperwood and Mr. Carpenter were suspended. (Exhibits 9 and 10).
As state above, Use Permit Condition 44, BMC 9.18.130 and Penal Code Section 326.5(f) requires all
non-profit bingo operators to use the bingo facility to perform the duties for which the non-profit was
created. In 1986, five non-profit bingo operators concurrently used the bingo facility (Exhibit 25). In
1991, five non-profit bingo operators concurrently used the bingo facility. In 1994, four non-profit
bingo operators concurrently used the bingo facility. In 1997, nine non-profit bingo operators
concurrently used the bingo facility. In 2003, three non-profit bingo operators concurrently used the
bingo facility. We have found no record that any of the above non-profit bingo operators maintained
offices at the bingo facility nor have we found any record that they used the bingo facility to perform
the duties for which the non-profit was created.
Enforcement Activity
Enforcement has been an ongoing and intermittent problem at 1284 San Pablo. On March 7, 2005,
Code Enforcement Officer Gerald Love responded to complaints that an Automatic Teller Machine
had been installed in the bingo facility without an approved zoning permit. Mr. Love issued a Notice of
Violation (Exhibit 7) to the Bingo Manager Albert Medina and ordered Mr. Medina to correct the
violation within five days. Because Mr. Medina did not respond, on May 9, 2005, Mr. Love issued a
Second Notice of Violation to the property owner, George McDermott. Mr. McDermott was ordered to
correct the violation within ten days. On May 11, 2005, Ralph Evans submitted a zoning application to
legalize the unpermitted Automatic Teller Machine.
On July 7, 2006, Code Enforcement Officer Roy Phelps responded to neighbors’ complaints that bingo
games were being held as late as 1:00a.m. Mr. Phelps met with the Bingo Hall Manager, Mr. Albert
Medina, and informed him that the permitted hours for bingo games were 6:00pm to 10:30pm. In
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addition, Mr. Phelps issued a Notice of Violation to the property owner, George McDermott (Exhibit
6).
On December 8, 2006, in response to a bingo advertisement in the Berkeley Daily Planet that
advertised Saturday bingo events from 5:00pm to 11:00pm, Zoning Officer Mark Rhoades issued a
formal warning letter to Bingo Hall Manager Ralph Evans. The letter informed Mr. Evans that
continued violations of the Use Permit may result in revocation. (Exhibit 8).
On June 18, 2008, Code Enforcement Officer Gerald Love responded to neighbors’ complaints
regarding operating hour violations. Mr. Love conducted a site inspection at 1:00pm and confirmed
that bingo games were being played in violation of Condition 13. Mr. Love instructed the Bingo Hall
Manager, Mr. Cooperwood, that he must terminate all bingo games and that no bingo games may be
played before 6:00pm.
Surrender of Bingo Permit
An investigation into the ongoing violations of the bingo operation at 1284 San Pablo was conducted
from October 2009 until July 2010. As a result of the investigation, on July 8, 2010, the Code
Enforcement Unit issued two Notices of Suspension of Bingo Permit (Exhibits 9 and 10) to Mr.
Ulysses Cooperwood, Youth Actors Company and Mr. William Carpenter, East Bay Charities. Both
non-profits were informed that their respective bingo permits would be suspended effective July 13,
2010. On July 12, 2010, both Mr. Cooperwood and Mr. Carpenter surrendered their respective bingo
permits through their attorney, Mr. Woidtke. (Exhibits 11 and 12).
Bingo Permit Suspension – William Carpenter – East Bay Charities
On January 28, 2010, Mr. Cooperwood contact Code Enforcement Supervisor Gregory Daniel
regarding the bingo permit application for Mr. William Carpenter. Mr. Cooperwood stated that he and
Mr. Carpenter would be operating bingo at 1284 San Pablo. On January 28, 2010, Mr. Carpenter
submitted Use Permit Transfer Application #10-90000066 (Exhibit 13) to assume responsibility for
Use Permit #A954, which authorizes the use of the building at 1284 San Pablo for purposes of nonprofit bingo. The effect of the transfer was to authorize East Bay Charities, a non-profit company as a
bingo operator. According to the Transfer Application, East Bay Charities was to operate bingo on
Monday through Sunday from 6:00 pm until 10:00 pm. On March 5, 2010, Mr. Cooperwood stated that
Mr. Carpenter operates bingo on Tuesday and Wednesday.
In connection with the on-going investigation of the bingo operations at 1284 San Pablo Avenue, Code
Enforcement Supervisor Gregory Daniel and Code Enforcement Officer Gerald Love met with Mr.
Carpenter on March 9, 2010. Mr. Carpenter was informed that Code Enforcement had received two
complaints regarding bingo payout exceeding $250 and that Code Enforcement would continue to
investigate bingo complaints. Mr. Carpenter was also advised that he would receive the same
enforcement letter (Exhibit 14) sent to Mr. Cooperwood regarding East Bay Charities non-profit
records.
According to documents provided by Mr. William Carpenter, East Bay Charities is a public charity
created to raise funds for battered woman and abused children. The address for East Bay Charities is a
two bedroom single family house at 20635 Maria Court, Castro Valley, California. Documents
provided to the Code Enforcement Unit do not identify any other location that is being used for the
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non-profit purpose for which East Bay Charities was created. On July 7, 2010, Mr. Carpenter stated
that he only uses 1284 San Pablo for bingo.
In February 2010, Code Enforcement received complaints from two bingo patrons that Mr. Carpenter
was paying out bingo prize awards that exceeded the $250 limit. Another bingo patron complained that
Mr. Carpenter forced her to surrender a $1000 bingo prize award claiming an error was made by the
bingo caller. Mr. Cooperwood confirmed that Mr. Carpenter did in fact require a bingo patron to
surrender the $1000 bingo prize award.
A bingo patron was contacted by Code Enforcement Officer Gerald Love on June 7, 2010, stated that
he plays bingo at least twenty times each month and that Mr. Carpenter routinely pays $1000 bingo
prize awards and that the most recent was on June 1, 2010 (Exhibit 15).
A bingo patron called Code Enforcement Supervisor Gregory Daniel and complained that on Tuesday,
June 22, 2010, bingo prize money was paid to four bingo patrons even though the bingo caller, Peter,
only announced three winners. This happened again on June 24, 2010, when Kevin was the bingo
caller. The bingo patron stated that both incidents were reported to Ulysses Cooperwood.
On July 2, 2010 a bingo patron called Code Enforcement Supervisor Gregory Daniel and complained
that on Tuesday, June 29, 2010, Mr. Carpenter paid out three $1000 bingo prize awards.
As a result of this investigation, it has become apparent that the East Bay Charities bingo operation at
1284 San Pablo Street is in violation of the applicable land use entitlements, specifically Use Permit
#A954 and Use Permit Transfer Application #09-10000063, as well as being conducted in violation of
BMC Chapter 9.18 and California law.
Specific violations of Use Permit #A954 since February 2, 2010, include, but are not limited to, the
following:
Lease of Facility Condition 12 requires that all leases for the use of the facility must include office
space for each non-profit. Such office space must be used exclusively for the performance of the
purposes for which the non-profit was created. Since February 2010, East Bay Charities has not
operated a separate office space for the activities of East Bay Charities based on visual inspections and
Mr. Carpenter’s July 7, 2010 statement.
Prize Limit Condition 36 and BMC section 9.18.070 established a prize limit of $250 per bingo
game. Since February 2010, Mr. Carpenter has repeatedly advertised and paid bingo prize awards
exceeding $250 (Exhibit 16).
Special Games
Condition 39 requires East Bay Charities to notify the Zoning (Current Planning)
Division in writing of any special games the organization conducts. Since February 2010, East Bay
Charities has advertised and paid bingo prize awards for special bingo games. However, there are no
records that East Bay Charities has provided written notification to the Zoning Division regarding
these special bingo games (Exhibit 16).
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Failure to file Quarterly Bingo Report Condition 41 requires each organization that has been issued
a bingo permit to file a detailed City of Berkeley Quarterly Bingo Report with the Finance Department.
For the period, February 2010 through June 2010, East Bay Charities has failed to file the Quarterly
Bingo Report.
Failure to provide Winner Signatures List Condition 42 requires each non-profit organization to file,
with the Quarterly Bingo Report, a list of names and signatures of all bingo winners. East Bay
Charities has failed to provide the City with the names and signatures of all bingo winners from
February 2010 through June 2010.
Failure to perform activities/office space Condition 44 requires that East Bay Charities must have an
office at 1284 San Pablo that is exclusively used for the purposes for which East Bay Charities was
created. Since February 2010, East Bay Charities has failed to perform activities at 1284 San Pablo for
which East Bay Charities was created. All space rented by East Bay Charities has been used solely for
the purposes of their bingo operations as described above.
Bingo Permit Suspension – Ulysses Cooperwood – Youth Actors Company
On July 29, 2009, Mr. Cooperwood submitted Use Permit Transfer Application #09-10000063 to
assume responsibility for Use Permit #A954, which authorizes the use of the building at 1284 San
Pablo for purposes of non-profit bingo. The effect of the transfer was to authorize Youth Actors
Company, a non-profit company, as a bingo operator. According to the Transfer Application, Youth
Actors Company is to operate bingo on Monday through Friday from 6:00 pm until 11:00 pm and on
Saturday and Sunday from 4:00 pm until 11:00 pm.
According to documents provided by Mr. Ulysses Cooperwood, Youth Actors Company is a youth
oriented theater company. The class schedule and performances are Wednesday and Thursday 3:30 pm
to 5:00 pm and Saturday 10:00 am to 12:00 pm. However, there have been no classes or performances
held at 1284 San Pablo since July 29, 2009 when Mr. Cooperwood began his non-profit bingo
operation based upon Mr. Cooperwood admission, and the Code Enforcement Unit has not been able
to verify that classes or performances have been held at any other locations.
The address for Youth Actors Company is a four bedroom single family house at 1994 Galbreth Road,
Pinole, California. Based on the City of Pinole zoning district regulations, a theater company is not an
approved use at that location. In addition, the City of Pinole has no record of an approved zoning
permit or home occupation permit, or any other permit or application therefore that would authorize
the use of 1994 Galbreth Road for theater purposes. Additionally, documents provided by Mr.
Cooperwood and his accountant, Dr. Jesse M. Wyatt, CEO of Wyatt and Associates, (Exhibit 17) show
that no other location is being used for the non-profit purpose for which Youth Actors Company was
created.
On October 19, 2009, Code Enforcement Officer Gerald Love and Code Enforcement Assistant
Planner Nathan Dahl were scheduled to meet Mr. Cooperwood to inspect the bingo operation at 1284
San Pablo. Mr. Cooperwood was not available for the inspection. Nonetheless, City staff determined
that the prize awards being paid by Mr. Cooperwood exceeded the $250 limit established by Berkeley
Municipal Code (BMC) section 9.18.070 (“Maximum Amount of Prize”), based on multiple colored
flyers attached to the wall of the bingo hall that advertised 25 bingo games paying $1000 prizes and 20
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bingo games paying $500 prizes, and the October web page (Exhibits 18 and 19) for Gilman Street
Bingo at 1284 San Pablo which advertised three $500 games and two $1000 games.
On December 9, 2009, Code Enforcement Supervisor Gregory Daniel and Code Enforcement Officer
Gerald Love inspected the bingo operation of Youth Actors Company after receiving a complaint that
Mr. Cooperwood was continuing to pay prize awards exceeding $250 in violation of BMC section
9.18.070. Mr. Love issued a Notice of Violation (Exhibit 20) to Mr. Cooperwood for violating BMC
section 9.18.070, BMC sections 23A.12.010 and 23B.56.040, which require that all uses permitted
under the Zoning Ordinance and subject to Use Permits must comply with the Zoning Ordinance
(BMC Title 23) and all other applicable local and other laws and regulations. In addition, Mr.
Cooperwood was directed to provide the Code Enforcement Unit with a list of all officers and
members of Youth Actors Company and to cease all prize payouts exceeding $250. Mr. Cooperwood
was also warned that he would be cited $2000 per day per violation. Mr. Cooperwood failed to comply
with the Notice of Violation. He has not provided the Code Enforcement Unit with a list of Youth
Actors Company members and, as described below, has continued to pay bingo prize awards
exceeding $250.
On January 14, 2010, Mr. Cooperwood submitted a written request to the City Manager asking that
enforcement be stayed until the City determines whether the prize limit in BMC 9.18.070 is consistent
with State law. Specifically, Mr. Cooperwood claimed that AB 1369 supersedes BMC section 9.18.070
and allowed bingo halls to pay bingo awards up to $500 as a matter of right (Exhibit 21).
On February 3, 2010, Deputy City Manager Christine Daniel, issued a letter (Exhibit 22) to Mr.
Cooperwood stating that SB 1369 (not AB 1369) gives cities the authority to enact bingo ordinances
and the authority to limit bingo prize awards. The Deputy City Manager’s letter further stated that
BMC section 9.18 is consistent with State law and that bingo prize awards paid by Youth Actors
Company are limited to $250.
In connection with the on-going investigation of the Youth Actors Company bingo operation, Mr.
Love contacted bingo players listed on the petition submitted by Mr. Cooperwood with his January 14,
2010 letter to the City Manager. Twelve of those bingo players have confirmed that Mr. Cooperwood
has continued to pay bingo prize awards exceeding $250. Three confirmed that Mr. Cooperwood has
paid at least four bingo prize awards exceeding $1000 since April 2010 (Exhibit 15).
Ms. Joyce Thibodeaux contacted Code Enforcement Supervisor Gregory Daniel and complained that
on New Year’s Day, January 1, 2010, Mr. Cooperwood held twenty-five (25) $1000 bingo games.
According to the complaint, Mr. Cooperwood’s wife won three (3) $1000 bingo games, Mr.
Cooperwood’s son won two (2) $1000 bingo games and two of Mr. Cooperwood’s bingo facility
employees won $1000 bingo games each. In addition, the complainant stated that on Friday June 25,
2010, Mr. Cooperwood’s wife won a $1000 bingo game and Mr. Cooperwood’s son (Peter) won a
$1000 bingo game.
On July 2, 2010, Code Enforcement Supervisor Gregory Daniel inspected the bingo operations at 1284
San Pablo. At 5:30pm volunteer workers (Exhibit 23) were selling bingo flash cards. A volunteer
worker named Ron stated that he sells approximately 1200 Instant Hits flash cards per night. The
winning payout for the Instant Hits flash card is $500. A volunteer worker named Kevin, identified as
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a volunteer floor worker and a bingo caller, stated that he sells approximately 600 Blockbuster flash
cards per night. The winning payout for the Blockbuster flash card is $100, $300 or $400. A volunteer
worker named Michael stated that he sells approximately 2400 Triple Score flash cards per night. The
winning payout for the Triple Score flash card is $300 minimum and $750 maximum.
As a result of this investigation, it has also become apparent that the Youth Actors Company’s bingo
operation at 1284 San Pablo Street is in violation of the applicable land use entitlements, specifically
Use Permit #A954 and Use Permit Transfer Application #09-10000063, as well as being conducted in
violation of BMC Chapter 9.18 and California law.
Specific violations of Use Permit #A954 since July 2009, include, but are not limited to, the following:
Lease of Facility Condition 12 requires that all leases for the use of the facility must include office
space for each nonprofit. Such office space must be used exclusively for the performance of the
purposes for which the non-profit was created. Since July 2009, Youth Actors Company has not
operated a separate office space for the activities of Youth Actors Company base upon visual
inspections.
Prize Limit Condition 36 and BMC section 9.18.070 established a prize limit of $250 per bingo
game. Since October of 2009 Mr. Cooperwood has repeatedly advertised and paid bingo prize awards
exceeding $250 (Exhibits 15, 19 and 20).
Special Games
Condition 39 requires Youth Actors Company to notify the Zoning (Current
Planning) Division in writing of any special games the organization conducts. The profit and loss
statement, dated February 3, 2010, (Exhibit 24) provided by Mr. Cooperwood states that Youth Actors
Company paid out $174,379 in special bingo game prize awards. However, there are no records that
Youth Actors Company has provided written notification to the Zoning Division regarding these
special bingo games.
Excess Overhead Condition 37 requires non-profits to limit their overhead to $1000 or 20% of the net
proceeds, whichever is less. As stated in the profit and loss statement, dated February 3, 2010 (Exhibit
24), provided by Mr. Cooperwood, during the period July 2009 through December 2009 the total
overhead for Youth Actors Company was $648,934.13. This overhead amount exceeded the limits set
by Use Permit #A954, Condition 37 by $516,822.
Excess Rent Condition 11 which was modified on November 25, 1991, limits rent charged for use of
the building to $1,070 per day. The profit and loss statement dated, February 3, 2010 (Exhibit 24)
provided by Mr. Cooperwood, shows that during the period July 29, 2009 through December 2009,
Mr. Cooperwood paid $258,868 in rent for the bingo hall. Total rent paid for the 156 days should have
been $166,920. Total rent paid exceeds the limits set by Condition 11 by $91,158.
Failure to file Quarterly Bingo Report Condition 41 requires each organization that has been issued
a bingo permit to file a detailed City of Berkeley Quarterly Bingo Report with the Finance Department.
For the twelve month period, July 2009 through June 2010, Mr. Cooperwood has failed to file the
Quarterly Bingo Report.
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Failure to provide Winner Signatures List Condition 42 requires each nonprofit organization to file,
with the Quarterly Bingo Report, a list of names and signatures of all bingo winners. Mr. Cooperwood
has failed to provide the City with the names and signatures of all bingo winners from July 2009
through June 2010.
Failure to perform activities/office space Condition 44 requires that Youth Actor’s Company must
have an office at 1284 Gilman that is exclusively used for the purposes for which Youth Actors
Company was created. Since July 2009, Youth Actors Company has failed to perform activities at
1284 San Pablo for which Youth Actors Company was created. All space rented by Youth Actors
Company has been used solely for the purposes of their bingo operations.
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
Exhibit 8
Exhibit 9
Exhibit 10
Exhibit 11
Exhibit 12
Exhibit 13
Exhibit 14
Exhibit 15
Exhibit 16
Exhibit 17
Exhibit 18
Exhibit 19
Exhibit 20
Exhibit 21
Exhibit 22
Exhibit 23
Exhibit 24
Exhibit 25
UP #A954
Mary Parker 9/2002 Letter to Planning
Mary Parker 11/20/2002 Letter to Planning
ZAB 1/9/2003 Notice of Decision
Robert Casteel Letter
March 7, 2005 Notice of Violation
July 7, 2006 Notice of Violation
December 8, 2008 Zoning Officer Letter
July 8, 2010 Cooperwood Suspension Letter
July 8, 2010 Carpenter Suspension Letter
July 12, 2010 Letter from Attorney Jay Woidtke
July 12, 2010 Letter from Attorney Jay Woidtke
Use Permit Transfer Application 10-90000066
March 24, 2010 Enforcement Letter
Gilman Street Bingo Payout Investigation
June 22, 2010 Bingo Prize Web Advertisement
Documents from Accountant
October 6 2009 Bingo Prize Web Advertisement
October Gilman Street Bingo Wall Flyer
December 9, 2009 Notice of Violation
January 14, 2010 Letter from Mr. Cooperwood
Deputy City Manager letter to Cooperwood February 3, 2010
Youth Actors Company Bingo Workers
Youth Actors Company Profit and Loss Statement
Non-Profit Bingo Organizations
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