STATE LIQUOR AUTHORITY LICENSE FRAUD

There is an old legal adage written by Carl Sandburg that is framed somewhere in almost every law office:  "(1) if the facts are against you, argue the law.   (2)  if the law is against you argue the facts.   (3) if the law and the facts are against you, pound the table and yell like hell” ....... And according to Mr. Paduano: (4) if facts, laws, and pounding don't work -- break the law and replace it with your own.

On June 18, 2014, ‘I’ received the above surprise ‘S.L.A. Deficiency Letter,’ caused by Mr. Paduano's continuing gross negligence to disclose ‘his’ finances and involvement in W&R LLC to the SLA:

MR. PADUANO WROTE THE ABOVE OBFUSCATED LETTER CONCEALING 'WHO' WAS THE MANAGEMENT AND 

'WHO' MADE THE "INJECTION" OF CASH IN ORDER TO CONTINUE TO LICENSE ME 100% ON THE LIQUOR LICENSE.

MR. PADUANO WROTE MANY EMAILS TO ME AND OTHERS THAT HE "INJECTED $70,000" IN TWO SEPARATE DEPOSITS OF:  $45,000 ON MAY 6, 2014, AND $25,000 ON JUNE 3, 2014.

The SLA approves Mr. Paduano's application for “only me" to be the only license holder per my 100% of the stock in W&R LLC. 

Instead, he should have submitted an application on behalf of himself and Mr. Weintraub, and 286 LLC to own 51% of W&R’s license and 49% for me - or he was committing the crime of ‘Availing.’

However, after Mr. Paduano’s previous frauds to date, 286 LLC would still have remained an illegal operation - that I was the 100% owner of and had 100% of the liabilities.

Mr. Paduano chose “AVAILING" the bar so he would have no liabilities and yet reap the rewards. He chose to close it and start his own.  

Why share the profits when he could keep them all for himself?   He was going to dump all the liabilities on W&R LLC and open his new 100% owned virgin 286 LLC.

On May 27, 2014, Todd explicitly told Mr. Paduano many times to not use Todd’s AOL email account because it was full of spam and he did not want to miss any important emails from him.

By August 2014, Mr. Paduano's behavior surrounding the liquor license application for our bar was not only negligent but also strategically deceptive. Despite being legally obligated to apply for his liquor license within ten days of asserting ownership on May 5, 2014, he delayed this critical task for four months because as he said on May 30, 2014, he wanted to close the bar and/or sell it to himself.

In November 2014, upon our inquiry about the status of this essential application and our full liquor license, Mr. Paduano shockingly responded that he had not filed it with the State Liquor Authority (SLA) because we had not approved the application he sent in August. This assertion was not only false but also a calculated attempt to shift blame onto us for his own failures to comply with legal requirements.

The August email that attached the application was buried in an email to ITK@AOL.COM hidden under an irrelevant subject which was his daily instructions on how to run the bar. At first read, that was the only thing that we read, signifying his daily breach of the 286 LLC Agreement.

Had Mr. Paduano been genuinely interested in legalizing the company's status under his purported ownership, he would have highlighted it. He would have called us. Why had Mr. Paduano not followed up to ensure the application was completed and submitted in a timely and clear manner. Instead, he chose complete silence, never mentioning it again until 4 months later in a shameless November 2014 explanation.

This tactic of "blaming the victim" culminated in an attempt to close the loop with the SLA by placing the onus of his non-compliance on us, effectively averting scrutiny from his Availing actions. Mr. Paduano's actions represent a clear breach of our contractual agreements and demonstrate a pattern of manipulation and evasion that aimed to leave us liable for his legal responsibilities.

Should this existential matter not have been followed up with hourly emails until it was signed?

When Mr. Paduano wanted something, he made certain to get it.  Just like everything else he relentlessly emailed me to do, such as harassing me, hourly, for a month to go to the bank against my will and sign the bank account into his name - when he did not even own a single share and was not licensed to own the bar which was a mandatory law.

MR. PADUANO EMAILED TO ITK@AOL..COM TO SHOW ALLEGED "PROOF" OF SENDING THE ATTACHED DOCUMENT - BY SHOWING THAT ON AUGUST 6, 2O14, HE SENT A LETTER AND APPLICATION "TO THE COMMUNITY BOARD." 

I DON'T KNOW HOW THIS WAS PROOF OF SENDING US ANYTHING ON AUGUST 6, 2014, BECAUSE TODD AND I WERE NOT COPIED ON THAT EMAIL TO THE COMMUNITY BOARD OR 'ANY' OF THE HALF DOZEN EMAILS TO THEM IN AUGUST 2014 TO WHICH THEY TOLD HIM HE WAS MAKING AN IMPROPER APPLICATION.

IN HIS STUPENDOUSLY ANNOYING EMAIL OF AUGUST 6, 2014 MR. PADUANO ALSO DISPLAYS THE INCREDIBLE DEPTH OF HIS VIOLATION OF HIS ALREADY ILLEGAL AGREEMENT TO NOT INTERFERE WITH MY OPERATION.

NOW, HE WAS INCREDIBLY ***TWEAKING THE SCHEDULE***

'THAT' IS WHAT WE LOOKED AT IN AWE. THAT WAS ALL MR. PADUANO WANTED US TO SEE.

WHEN WE FINALLY DID SEE HIS AUGUST 8, 2014 EMAIL AND ATTACHMENT TO 'COMMUNITY BOARD 7' THE SUBJECT LINE STATED "SUBSTANTIAL" CORPORATE CHANGE AND CONTAINED A COVER LETTER SAYING THE SAME.. 

WE SWEETLY SHOWED MR. PADUANO THAT THE SLA LAWS DESIGNATED 80% AS THE THRESHOLD FOR "SUBSTANTIAL" CORPORATE CHANGE THAT REQUIRED GETTING APPROVAL FROM THE COMMUNITY BOARD FIRST. 

WE SHOWED HIM THAT IN ALL OTHER LESSER PERCENTAGE CHANGES IT HAD TO GO TO THE SLA FIRST. HE IGNORED US AND THEN HE IGNORED THE COMMUNITY BOARD WHO TOLD HIM THE EXACT SAME THING I DID IN REJECTING HIS APPLICATION FOR A MEETING. 

WE HAD NO CLUE WHAT HE WAS DOING OR NOT DOING. 

TODD AND I HAD AN INFINITE AMOUNT OF OTHER WORK TO DO AND A FINITE TIME TO DO IT. WE WENT BACK TO OUR WORK AND ASSUMED HE WAS GOING BACK TO HIS. 

MR. PADUANO HAD THE COMMUNITY BOARD RUNNING IN CIRCLES. SHOULD I HAVE NOT KNOWN ABOUT LIQUOR APPLICATIONS AND HEARINGS BEFORE THEY ARE MADE AND HELD??? 

OUR ALLEGED SILENT INVESTOR OPERATED OUR BAR WITHOUT BOTHERING TO INCLUDE US. JUST LIKE WITH THE INSURANCE COMPANY TO WHICH HE ALSO COMMITTED FRAUD.

MR. PADUANO DID NOT WANT US TO UNDERSTAND WHETHER HE WAS COMING OR GOING DURING THE SUMMER OF 2014. AND WE DIDN'T. 

ALL THIS WAS UNFOLDING IN REAL TIME. TODD AND I THOUGHT, AS HE TAUGHT US TO THINK, THAT HE ACTUALLY HAD THE RIGHT TO BULLY US IN THE BUSINESS.

WE DID NOT EVEN KNOW THERE WAS ACTUALLY A SERIOUS LAW CALLED "AVAILING." AND NEITHER DID ANYBODY ELSE TO WHOM WE SPOKE. WE JUST THOUGHT IT WAS OUR BAD LUCK THAT WE COULD DO NOTHING ABOUT. 

EVEN IF TODD AND I THOUGHT OTHERWISE, WE "ALL" KNEW WE COULD NEVER CHALLENGE HIS POWERFUL LAW FIRM, AND SO WE NEVER EVEN THOUGHT ABOUT IT. 

In his November 12, 2014, he arrogantly informs me that because I did not immediately sign his as yet unseen document on august 8, 2014, that he never bothered to pursue the SLA liquor license, nor would he ever again.

Mr. Paduano had already 'created' what he wanted: a fake excuse to blame me for his AVAILING. It was his responsibility to perform legal duties, and particularly to get licensed. I had no idea what he was doing or not doing. If he wanted something he would want it immediately, or he would remind me repeatedly.

Todd and I were warm and cooperative in every email with Mr. Paduano until 2015. How exactly did Mr. Paduano's sudden claim of my "disobedience" in 2014 fit into any semblance of reality? Where are all the hostile emails insisting, I sign his misdirected application? 

Later, in 2015, Mr. Paduano attempted to blame and frame me to the SLA in his three failed fraudulent attempts to illegally return my 100% share liquor license...by himself. 

However, the SLA would not let him return it because he was not on any records at all: not the lease. Not the license. Not the stock. 

****At this point, I could not inform the SLA of Mr. Paduano's negligence because his frauds would just fall down on me for not alerting them of the AVAILING after ten days of signing his 286 LLC agreement on May 5, 2014.

? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? ? 

I am not a lawyer. Mr. Paduano is. Todd and I are in the 'hospitality' business. This was his dirty business, not ours. Mr. Paduano was clearly setting us up as an excuse for all his frauds. 

I had my hands full reopening the bar under the paralyzing conditions that Mr. Paduano had set. I did not look over his shoulder...and I did not have to look over mine. He was already on me like a backpack. I felt like arresting him for kidnapping.

I trusted him to be professional and properly perform his legal and fiduciary responsibilities making sure everything was done legally. 

SLA TIMELINE:

May 5, 2014: Before the court settlement, Mr. Paduano coerces me to sign his surprise illegal 286 LLC agreement. 

Mr. Paduano, as my attorney, opens a W&R LLC bank account naming me as the 100% shareholder of W&R LLC

May 6, 2014: An important understanding with Ruth (see email).  Mr. Paduano files SLA application making me the 100% W&R LLC shareholder on the license. 

May 30, 2014: Mr. Paduano tells me he wants out of ownership or any association with W&R LLC He writes he wants a third-party investor to buy him out for $150,000 immediately. 

June 18, 2014: the SLA sends a deficiency letter rejecting Mr. Paduano's May 7, 2014, application because he did not provide the proper financial information.

June 26, 2014: Mr. Paduano replies to the June 18, 2014, SLA deficiency letter with another fraudulent letter providing the SLA fraudulent information for me to be 100% shareholder and sole license holder. 

July 23, 2014: SLA approves my 100% of shares of W&R LLC on the liquor license that Mr. Paduano first filed for on May 6, 2014, and perpetuated for the next 18 months.

August 8, 2014: Mr. Paduano intentionally provided fake proof that he sent Todd a timely copy of his 'misguided letters to the community board." in fact, his further emails only prove that he did not copy us, at all, before or after august 8, 2014.

November 12, 2014:  Mr. Paduano informs us for the first time, that he lied and had 'never' applied for the all-important change to the sla for a full liquor license. In fact, he insanely informs me that Iprevented him from filing the application for corporate change for his 51% stock to the sla. He was supposed have sent it within 10 days of May 5, 2014, as is required by law.

December 2014:  Mr. Paduano frames me for his frauds in writing to the SLA again, telling them "I" prevented him registering for an entire 18 months.

If he really wanted to get this done, again, where are all his emails reminding me about such an important existential crisis?

Why did he not send me reminders every hour, every day?

August 8, 2014?  Mr. Paduano stated in writing that he had decided to sell out or close the bar on May 30, 2014. That is why he would not submit any document that legally associated him with W&R LLC, period.

Mr. Paduan0 relentlessly used his bully pulpit to lie and take advantage of me. He ominously misstates laws, threatens to sue me, and solicits me to commit crimes on his behalf - and against myself!

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Janke v. Janke, 1975:

"it has been held that one who has failed to register his name with the state liquor authority in obtaining a license, thereby violating the alcoholic beverage control law, cannot invoke the power of the equity court to impose a constructive trust on his share of the proceeds of that business being conducted in violation of statute."

* * * * * * * * * * * 

Mr. Paduano tells me he has the right to do whatever he wanted with both me, Todd, and W&R LLC. He threatens me to illegally give him my 100% of the shares he procured for me, acknowledging that as my lawyer and fiduciary partner he did not transfer 51% to himself, 286 LLC, P&W LLP, or anyone else for a year and a half. 

***He owns no shares and claims he is not my lawyer. So how does he have any legal right to even talk to me? Much less, instruct Mr. Walsh to harass me hourly?

Mr. Paduano was brazenly committing extortion. That's how invincible he thought he was against a 'nobody' like me. And being a woman to boot. Perfect prey for a bully. 

On the November 22, 2015, recording, he holds a gun to our heads to try force me to assign him 100% of the shares and SLA license - which was simply illegal and impossible to do because the SLA had to give prior approval. He was supposed to have gotten that no later than May 15, 2014.

The assignment would have been an illegal and worthless piece of paper that would only have had repercussions for me. 

What was Mr. Paduano thinking? This was a mere formality that could be brushed off. And that he could destroy me without any repercussion? The answer is "yes he could and yes he did."

According to state liquor authority agents, “AVAILING” was the equivalent of “MURDER”, and he was certainly murdering me.

I put my liquor license in jeopardy of being revoked, for him to keep his legal license. I was putting his life before mine, even while he destroyed me. I just wanted him to stop torturing me and get as far away from him as possible. 

MR. PADUANO REMOVES MY LICENSE FROM THE BAR, AND THEN LIES TO THE SLA THAT I HAVE IT AND WON'T RETURN IT.   HE WAS TRYING HAVE MY LIQUOR LICENSE REVOKED - JUST TO TIE THE KNOT ON HIS FALSE NARRATIVE BLAMING THE VICTIM:  ME.

MR. PADUANO DISINGENUOUSLY GIVES ME INSTRUCTIONS, MAKING IT LOOK LIKE "I" AM THE ONE THAT DOES NOT KNOW SLA LAWS INSIDE AND OUT. 

IS HE NOT RESPONSIBLE FOR KNOWING SLA LAWS ALSO, AND ABIDING BY THEM FROM MAY 5, 2014 SINCE OWNING A MAJORITY SHARE OF A BAR, AND BEING THE LAWYER REPRESENTING IT?

THE SLA REJECTED HIS THREE ILLEGAL ATTEMPTS TO RETURN MY LICENSE BECAUSE MR. PADUANO WOULD NOT ADMIT HE (286 LLC, P&W LLP) IS A SHAREHOLDER OR ON A SINGLE W&R LLC DOCUMENT. 

I WAS DEAMED BY THE SLA AS THE 100% STOCKHOLDER WHICH REQUIRED' ME AND ONLY ME, TO OWN 100% OF THE THE LICENSE, AND THEREBY "LEGALLY REQUIRED" ME TO HAND DELIVER' THE LICENSE BACK TO THE SLA, MYSELF.  

IN HIS COMMUNICATIONS WITH THE SLA, MR. PADUANO CLAIMED HE WAS NOT MY LAWYER, PLACING THE BLAME ON ME FOR COMPLYING WITH SLA REQUIREMENTS THAT ONLY I, AS THE PURPORTED 100% STOCKHOLDER, COULD LEGALLY EXECUTE.

"JENNIFER, THE LICENSE BELONGS TO THE CORPORATION, NOT YOU." 

MR. PADUANO!  IF THE LICENSE BELONGS TO THE "CORPORATION" - AND I OWN 100% OF THE "CORPORATION" THEN " I" OWN 100% OF THE LIQUOR LICENSE, AND THE ONLY SINGLE PERSON RESPONSIBLE FOR IT. 

WHY DID HE DANCE IN CIRCLES WITH THE SLA? WHY WOULD HE NOT REVEAL HE WAS THE (ALLEGED) MAJORITY OWNER? INSTEAD, HE DUPLICITOUSLY CLAIMED HE CONTROLLED AN UNNAMED CORPORATION THAT HE SAID CONTROLLED ME.

*** WHEN MR. PADUANO TRIED TO RETURN THE LICENSE TO THE SLA, THEY SAID ANY PARTIAL OWNER COULD RETURN THE LICENSE. 

BUT MR. PADUANO WOULD NOT DISCLOSE TO THEM THAT HE WAS A PARTIAL OWNER. AND HE ALONE WAS ILLEGALLY CLOSING THE BAR BECAUSE HE ALONE VOTED TO DO SO AS THE "SECRET" CONTROLLING 51% PARTIAL OWNER.  OTHERWISE KNOWN AS AN AVAILER

MR. PADUANO DECIDES WHAT IS LEGAL AND WHAT IS NOT.  THEN HE GETS TO OVERRULE HIMSELF WHENEVER HE WANTS.  HE IS EVEN ABLE TO ABIDE BY TWO OF HIS CONTRADICTING DECISIONS AT THE SAME TIME.   HE NEVER HAD ANY HONEST ANSWERS FOR WHAT HE DID OR THOUGHT.   HE ONLY HAD EXCUSES AND BLAME. 

MR. PADUANO DEFAMED ME TO ADVANCE HIS WANTON AGENDA AT THE EXPENSE OF MY SOLE OCCUPATION AND CAREER.  

I FINALLY CONTACTED THE SLA TO RETURN A 'COPY' OF ‘MY LICENSE’ AND EXPLAINED THE PROBLEM TO THE AGENT THAT IT WAS ILLEGALLY TAKEN OFF THE WALL OF THE BAR AND I NO LONGER HAD ACCESS TO IT. I DID NOT MENTION MR. PADUANO's NAME OR I WOULD HAVE BEEN IN TROUBLE FOR NOT REPORTING HIM FOR THE PAST 18 MONTHS. THE SLA HAD ME IN THEIR SYSTEM AS THE 100% LICENSE HOLDER AND ONLY OWNER OF THE COMPANY. 

AS THE ONLY LEGAL 100% OF THE BAR THEY TOLD ME TO JUST FAX A COPY OF IT TO THEM IF I HAD ONE. I FAXED IT TO THEM WITHIN AN HOUR OF THE CONVERSATION WITHOUT ANY PROBLEM.

IT TOOK LESS THAN AN HOUR SOUP TO NUTS, LEGALLY.  NOT LIKE MR. PADUANO'S FAILED ATTEMPTS FOR THREE WEEKS, ILLEGALLY. 

MR. PADUANO'S UNETHICAL CONDUCT IN PLAIN SIGHT.   MR. PADUANO PUBLICLY DISPLAYS HIS 18 MONTH LONG QUEST TO TAKE FULL POSSESSION OF W&R'S LOCATION.  

UNFORTUNATELY, THE LANDLORD FOILED HIS PLAN BY NOT OFFERING HIM A LEASE BECAUSE OF WHAT MR. PADUANO WAS DOING TO ME. THE LANDLORD SAID: 

"HE IS THE WORST PERSON I HAVE EVER RUN ACROSS IN MY CAREER OF MANAGING BUILDINGS."  

"HE IS A DISGRACE TO HUMANITY, ITSELF."

I TAPED HIS 'DESPERATE' EXTORTION CALL TO ME ON THE NIGHT BEFORE HIS ILL-FATED ATTEMPT TO HAVE ME ILLEGALLY ASSIGN MY 100% SHARES OF STOCK TO HIM.

 I ALREADY GAVE HIM PERMISSION TO DO THAT AS MY LAWYER ON MAY 5, 2014. HE ALSO DEMANDED I "ILLEGALLY" TURN OVER THE BANK ACCOUNT TO HIM.

HE IS THE ONE THAT PERPETUATED BOTH FRAUDS FOR OVER A YEAR AND A HALF.

HOWEVER, ON THE NEXT DAY HE COULD NOT GO TO THE SCHEDULED MEETING.  HE DID NOT HAVE A LEASE.

SO, IN RETALIATION HE GUTTED THE BAR, THAT COST ME $500.00 TO BUILD, WITH POWER TOOLS STATING HE DID IT SO THAT I COULD "NEVER USE THE BAR AGAIN...ON HIS DIME.

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DISCLAIMER:  I am not a lawyer.  My opinions and descriptions of the emails and documents displayed on this website, and my chosen nomenclatures for them, are strictly derived from my own layperson's understanding of the definitions of the applicable statutes and torts in basic legal reference manuals and guides.  All references to "crime" are alleged and used in accordance with its colloquial definition:  A grave offense, especially against morality.  Reprehensible, foolish, or disgraceful.  Evil, shameful, or wrong.