http://media.myrecordjournal.com/system/files/2041

DOCKET NO. CV09­

STATE OF CONNECTICUT

SUPERIOR COURT

v.

NEW HAVEN AT MERIDEN

REAL PROPERTY & PREMISES LOCATED AT 2041 NORTH BROAD STREET, MERIDEN, CONNECTICUT [DAVID J. HENDERSON; CITYSCAPE REAL ESTATE HOLDING, INC.]

July 13, 2009

COMPLAINT COUNT ONE: GENERAL STATUTES § S4-33g - IN REM ACTION FOR ADJUDICATION AS NUISANCE 1.

The State of Connecticut brings this in rem action pursuant to General Statutes § 54­

2.

Christopher Malanyis a Supervisory Assistant State's Attorney with the Office ofthe

33g.

Chief State's Attorney, and as such, is authorized to bring this action pursuant to Connecticut General Statutes § 54-33g.

3.

The subjects of this action are the real property and premises located at 2041 North

Broad Street, in the City of Meriden, State of Connecticut, a.k.a. "2041 Club."

4.

Cityscape Real Estate Holding, Inc., is the last recorded owner of the real property

according to a Quit Claim Deed dated November 14, 2002 from David J. Henderson, and recorded in Volume 2938, page 203 of the City of Meriden Land Records.

5.

Upon information and belief, David J. Henderson, owns the real property and

premises, and operates a commercial business at that location known as the "2041 Club."

6.

The defendant real property and premises have been used to commit or facilitate

violations ofstate criminal law, including Prostitution, in violation ofGeneral Statutes § 53a-S2, and Promoting Prostitution, in violation of General Statutes 53a-SS. 7.

In 2003, David J. Henderson was arrested for promoting prostitution, permitting

prostitution, and violation of the Corrupt Organization and Racketeering Act arising out of prostitution at the real property and premises located at 2041 North Broad Street, Meriden, Connecticut, a.k.a. "2041 Club." David J. Henderson was convicted in November 2005 in docket number N07M-CR03-0216243S in 2003, and sentenced to ten years imprisonment, execution suspended after forty-five months, and five years probation. Henderson remained involved with business operations at the "2041 Club" while incarcerated, and upon his release on parole in the fall 200S. S.

The "2041 Club" is an adult-oriented business featuring exotic "dancers." At the

time ofthe incidents, the premises featured a large open area with a dance floor surrounded byplexi­ glass in the middle of the room. To the right of this main area were open booths with dividers and a padded bench in each. To the left of the main area towards the front door were four private rooms with doors.

9.

Based on a citizen complaint, the Meriden police and Statewide Narcotics Task Force

investigated the "2041 Club" in December 200S and January 2009. Initially, Meriden detectives stopped customers leaving the club and interviewed them. Five different customers admitted that

there was prostitution taking place inside the "2041 Club."

10.

On January 13, 2009, an undercover police officer ["DC"] went to the "2041 Club,"

and was admitted after paying $20.00 to the doorman. The doorman explained that the girls didn't dance on the stage. Instead, they performed for customers in private rooms or semi-private booths.

The DC paid a dancer named "Mialisa," later identified as Olga Ortiz, another $40.00. Ortiz brought the DC to a private room, where she undressed completely and began to masturbate the DC. After five minutes, the doorman banged on the door, stating that the time was up.

11.

Later that day, the DC paid for a similar session with another female named

"Cebello," later identified as Lorena Castro. David J. Henderson came out of a back room and took the money. During the "dance," Castro offered the DC sex for money.

12.

Still later on January 13, 2009, the DC paid the doorman for another five minute

"dance" with Olga Ortiz in a private room. Ortiz again masturbated the DC, and discussed with him engaging in other types of sex for more money.

13.

On January 15, 2009, the DC was briefed regarding Laura Kuhl, who was known to

police from previous investigations at 2041 Broad Street, Meriden. Kuhl had run the club while David 1. Henderson had been incarcerated. The DC went to the "2041 Club," paying the doorman $20.00 for admission. The DC spoke with Laura Kuhl, who used the alias "Adrianna. II The DC paid Kuhl $40.00 dollars for the house, and she led him to a private room. Inside, the DC paid Kuhl another $40.00. Kuhl undressed completely and masturbated the DC. During this, Kuhl offered to have any kind of sex with the DC for more money.

14.

Based on the investigation, police obtained arrest warrants for David 1. Henderson

for violations of Promoting prostitution in the 1st degree, Gen. Stat. Sec. 53a-86; Permitting prostitution, Gen. Stat. Sec. 53a-89; Conspiracy to promote prostitution, Gen. Stat. Secs. 53a-48 & 53a-86; and Conspiracy to permit prostitution, Gen. Stat. Sec.53a-48 & 53a-89. Carlton Dawkins, a doorman at the club, was arrested and charged with Promoting prostitution in the 1st degree, Gen. Stat. Sec. 53a-86; Permitting prostitution, Gen. Stat. Sec. 53a-89; Conspiracy to promote prostitution, Gen. Stat. Secs. 53a-48/ & 53a-86; and Conspiracy to permit prostitution, Gen. Stat.

Sec.53a-48 & 53a-89. Elga Ortiz was arrested and charged with two counts of Prostitution, Gen. Stat. Sec. 53a-82, and two counts of Conspiracy to commit prostitution, Gen. Stat. Secs. 53a-48 & 53a-82. Lorena Castro was arrested and charged with Conspiracy to commit prostitution, Gen. Stat.

Secs. 53a-48 & 53a-82; and violation ofConnecticut's Corrupt Organizations and Racketeering Act, Gen. Stat. Sec. 53-395. Laura Kuhl was arrested and charged with Prostitution, Gen. Stat. Sec. 53a-82, and Conspiracy to commit prostitution, Gen. Stat. Secs. 53a-48 & 53a-82.

15.

On January 20, 2009, officers ofthe Meriden Police Department and the Connecticut

State Police coordinated execution of the arrest warrants and a search and seizure warrant at the "2041 Club." Before executing the warrants, another undercover officer ["DC2"] went to the "2041 Club." DC2 paid the doorman, later identified as Alexander Granitto, $20.00 for admission.

Inside, DC2 recognized Laura Kuhl; he paid Kuhl another $20.00. Kuhlled DC2 into a private room. There, Kulh removed all ofher clothing and masturbated DC2 for $20.00 more. Kuh10ffered to engage in any sex act for more money.

16.

Based on this incident, Kuhl was also charged with additional counts ofProstitution,

Gen. Stat. Sec. 53a-82, Promoting

prostitution in the first degree, Gen. Stat. Sec. 53a-88),

Conspiracy to commit prostitution, Gen. Stat. Secs. 53a-48 & 53a-82, and violation ofConnecticut's Corrupt Organizations and Racketeering Act, Gen. Stat. Sec. 53-395.

17.

When the Meriden Police and the Connecticut State Police executed their warrants

on the "2041 Club," David J. Henderson locked himself in the heavily-reinforced back room, and fled out the back door. Henderson was arrested on both the arrest warrants and for on-site violations of Interfering with a search warrant, Gen. Stat. Sec. 54-33d; Interfering with a police officer, Gen. Stat. Sec. 53a-167a; and violation of Connecticut's Corrupt Organizations and Racketeering Act, Gen. Stat. Sec. 53-395.

18.

Doorman Alexander Granitto was arrested and charged with Conspiracy to promote

prostitution, Gen. Stat. Secs. 53a-48 & 53a-86; and Conspiracy to permit prostitution, Gen. Stat.

Sec.53a-48 & 53a-89. Lorena Castro was also arrested at the "2041 Club," and charged with Conspiracy to commit prostitution, Gen. Stat. Secs. 53a-48 & 53a-82; and violation ofConnecticut's Corrupt Organizations and Racketeering Act, Gen. Stat. Sec. 53-395. Olga Ortiz was arrested, with an additional on-site charge for violation of Connecticut's Corrupt Organizations and Racketeering Act, Gen. Stat. Sec. 53-395. Doorman Carlton Dawkins was arrested by warrant on January 21, 2009; he was likewise charged with violation of Connecticut's Corrupt Organizations and Racketeering Act, Gen. Stat. Sec. 53-395.

19.

The real property and premises located at 2041 North Broad Street, Meriden,

Connecticut, a.k.a. "2041 Club," was used to commit or facilitate Prostitution, in violation of General Statutes ยง 53a-82, and Promoting Prostitution, in violation of General Statutes 53a-88.

Accordingly, this property should be adjudicated a nuisance, pursuant to General Statutes ยง 54-33 g,

and condemned.

WHEREFORE, the plaintiff State of Connecticut requests that the Court enter a judgment condemning the real property and premises, and respectfully requests the following relief:

AS TO COUNT ONE: 1. That the real property and premises located at 2041 North Broad Street, Meriden, Connecticut, a.k.a. "2041 Club," are judged a nuisance within the meaning ofGeneral Statutes § 54­ 33g and condemned.

2. That, pursuant to General Statutes § 54-33g (c), the real property and premises located at 2041 North Broad Street, Meriden, Connecticut, a.k.a. "2041 Club," are awarded to the City of Meriden to use or dispose of, as they see fit.

Respectfully submitted,

STATE OF CONNECTICUT

c..~~ By: __________________

CHRISTOPHER MALANY Supervisory Assistant State's Attorney Asset Forfeiture Bureau tel. (860) 258-5810

MICHAEL GIGANTE Law Student Intern