2041 Club

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SUPERIOR COIJRT

STATE OF CONNECTICUT

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trUDICIAL DISTRTCT OX'NEW EAVEN

vs.

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AT MERIDEN

: DAvrD J' HENDERSON; DAI{rEL HENDERSON; LAITRA KTIHL; CITYSCAPE REAL ESTATE EOLDING, INC.; THE REAL PROPERTY KNOWN AS 2041 NORTE BROAD STREET, MERIDEN, CONhIECTfCUI, akl "2041 CLUB"

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COUNT ONE: (I9a-343,et seq.- NUISANCE ABATEMENT) 1.

The State of Connecticut brings this nuisance abatement action pwsuart to

ConnecticutGeneralStatutesSectionI9a'343, et seq.

Z.

IlanaR. Cathcrt is a SeniorAssistantState'sAttomeywith fhe Office of the Chief

State's Attomey, and as such,is authorizedto bring fhis action pursuantto ConnecticutGeneral StatutesSection19a-3434asamended.

3.

as}} lNorthBroadStreet, Thepropertywhichisthesubjectofthisactionishlown

'2041Club"' in the City of Meriden,Stateof Connecticut,a.k.a4.

TheDefendant,CityscapeReaIEstateHolding, Inc., is the last recordedownerof the

subjectrealproperlyknownasaAllNorthBroadStreet,Meriden,Connecticut,a.k'a"'zA4LClub", accordingto a euit ClaimDeeddatedNovember 14,2002fromDavidJ. Henderson,andrecorded

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in Volume 2938,pa9e203 of the City of Meriden Land Records.

5.

Upon infotmation and belief the Defendant,David J. Henderson,is the owner and

operator of the conmercial businessknown as "2041 Club" located at 2041North Broad Street, Meriden, Connecticut.

6.

Defendant The Real Property Known As 2A4l Norlh Broad Street, Meriden,

Connecticut, a.k.a. *204!Club", is the subjectpremiseswhere the illegal activities complained of in this Compiaint have occu:red and continue to occur.

7.

*204L Club" is a business which purports to provide exotic dancing entertainment

The single building is made of brick and glasswith a purple colored metal roof. A stockadefence *2041 with the number "2041" is around fhe back of the building. A sign posted in front states Club". Inside the premises is a large open areawith a dance floor suror.:nded by plexi-glass in the middle of the room. To the right of this main areaareopenboothswith dividors and a paddedbench in each. To the left of the main areatowards the front door are fourprivate rooms w'ith doors. The back portion of the premises,which consistsof severalrooms, is located down a hallwaywhich is separatedfrom the main part of t}le premises by a security door.

8.

The businesspremiseslocated at2047 North Broad Sfreet, Meriden, Connecticut,

now known as the "204I Club", was forrnerly called "Club Laart' , "Appateasers", and the

'I(it Kat

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Club". Under eachname, including the curent name,the principal owners and operatorshave been David Hend.erson,and./orDaniel Hend.erson,and/or JamesF. Gili, andlor Laura Klhl.

9.

In 1993, Daniel Henderson was arrestedon prostitution-related charges and David

Henderson was arrested for violation of the Comrpt Organization and Racketeering Act. These arrestswere basedon law enforcement investigations ioto illegal activities occrrrring at their adultentertainmentbusinesses,including the business located at 2041Norttr Broad Stree! Meriden, Connecticut.

10.

In 2003, David l{enderson was arrestedfor promoting prostitution, peruritting

prostitution, and violation of the Comrpt Organizatton and Racketeering Act associated with prostitution activity at the subject location in docket number NOTM-CRO3-0216243Sin 2003. As a result ofthis alrest, in November 2005, David Hendersonwas convicted and sentencedto ten years imprisonment with forly-five months to serve and five years probation.

11.

David Hendersonremained.involved withthe businessoperationsof the club while

incarceratedand upon his releaseon parole in the fall of 2008.

12.

Ir December 2008, the Meriden Police Deparbnent's Crime Suppression Unit

(hereinafter referred to as C.S.U.), received information that prostitution activity was occr:rring inside the businessknown as"204"!.Club"located atll4LNorthBroa4

Sfueet,Meriden. Members

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of C.S.U. were farrriiiar with the iocation due to the prior investigations into illegal activitll including prostitution, which were conducted at the properfy.

13.

Specifically, in December2008, a concemedcitizen contacted the Meriden police

Departrnent regarding an incident which had occurred with his brother, who had patronized the "2447 Club" with a group ofyoung men. According to the concemed citize+the young me,nin the group paid for unprotected sex with "dancers'bf "2041c11fu",ard as a result, the complainant's brother was infected with a sexuallytansmitted disease. When members of the Meriden Folice Deparhnent conducted a check of internet sites containing comments of individuals who had knowledge ofthe *204I Club", very similar information regarding the risk of sexually kensmitted diseasewas discussed.Due to the illegat activities alleged,and the public health hazardpresented in this infonnation, an investigation into illegal activity at*2041Club'was begrm.

14.

BetweenDecember2008 andJanuary20A9,C.S.U. andtheStatewideNarcotics Task

Force SouthCe,rrtual office undertookan investigationinto iliegal activity occurringwithin '2041 Club". As a result of this investigation,six (5) individuals were arrestedfor violations which constitutea publio nuisancepursuantto C.G.S.$l9a-343(c) for activity occurringwithin '204L CIub".

15.

During the month of January 2009, members of C.S.U. performed apreliminary

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investigation into activities occr:rring at*204l Club'"by observing customers enter and exit the club and following and stopping them in their motor vehicles. Upon being stoppedby the police, fi.ve

*204'1, different customers each gave the sarneinfornration about the prostitution businessinside Club". This inforrnation confirmed that the samemethodsof operating a prostitution businesswere being used as had been used in previous investigations for which David Henderson and Daniel Henderson were arrestedand convicted.

16.

'TJC") was utilized in the On January 13,200g,an undercoverofficer (hereinafier

investigationof "2041Club". During this investigation,the UC paid twenty ($20.00) doliars to the doorman, who had been previously identified as Caxlton Dawkins. Dawkins explained to the UC that the girls do not dance on the stage, but rather in a private room or semi-private booth. The "dancer" performs for the length of time paid for. On this date, the UC paid an additional forty ($40.00) dollars to 'Mialisa", later identified as OIga Ortiz. Ms. Ortiz took the UC into a private room where shecompletelyrtrdressed.and beganto masturbatethe UC. A-ffer fi.ve minutes was over, Dawkins banged on the door stating tin-rewas up.

I7.

Thereafter on January 13,2009, the UC paid for another five minute dancewith a

female named "Cebello", who was later identified as Lorena Castro. A heavy set male named "Dave", later identified asDavid Henderson, came out of a back room and took the money. During

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fhis dance,offersof sexfor moneywerediscussed betweentheUC andMs. Castro,but nonewere completed.

18.

After theUC's five minutedancewith Ms. Castrohadfinishsd,he wentbackto the

bar. At thebar, 'Mialisa" @lgaOrtiz) senredtheUC a beerfrom arefrigeratorbehindthebar. This was donEin front of CarltonDawkins aadDavid Henderson.

19.

Thereafteron January13,2l0g,theUC paid for anotherfive minutedancein oneof

theprivate rooms with "Mialisa" @lga Ortiz). The moneywas given to Carlton Dawkjns. During this dance, Ms. Ortiz and the UC had a discussion about having otherfypes of sex in exchangefor more money. Ms. Ortiz masturbated the UC during the dance.

20.

On January L5,zXlg,the UC was briefed about Laura Kuhl, who was known to

membets ofthe C.S.U. and ConnecticutStatePolice StatewideNarcoticsTask Force fromprevious investigations a2A4tBroad Street,Meriden. Ms. Kuhl also ran the businessat the club when it was known as "Club Laura'n while David Henderson was incarcerated on prostitution-related and racketeering charges. On this datg the UC paid the doomran, Carlton Dawkins, twenty ($20.00) dollars for entance to the club. The UC spoke with the person he reco qrized to be Laura Kuhl a.k.a.

"Adrianna". The UC paid "Adrianna" forfy ($40.00) dollars for the house and went into a private room with her. Inside the room, the UC paid anotherforfy ($40.00) dollars to Laura Kuhl a.k.a.

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"Adriaruta"who completelyundressed.

In a conversation with the UC, Ms. Kuhl offeredto have any kind of sex vrith the UC in exchangefor more money. During fhe d.ance,Laura Kuhl mashrbatedthe UC. 21.

Basedon the above-described investigations, arrestwa:rantswereissuedfor: 1)

David Hendersonfor violations of CormecticutGeneralStatutesSections 53a-86(promoting ptostitutionl't degree),53*89(permittingprostitution) promote , and.53a-48/53a-86(conspiracyto prostitution)and53a-48 /53a-89(conspiracytopermitprostitution);2) LauraKuhl for violafionsof ConnecticutGeneralStatutesSections53a-82(prostitution)and 53a-48/53a-82 (conspiracyto commitprostitution); 3) CarltonDawkins for violationsof ConnecticutGeneralStatutesSections 53a-86(promotingprostitution)t,53a-89(permittingprostitution), 53a-48/53a-86 (con.:piracyto promoteprostitution)and53a-48/53a-89 (conspiracytoperrnitprostitution);and4)ElgaOrtrzfor violationsofConnecticutGeneralStatutesSections53a-82(prostitution"2 counts)and53a-48/53a82 (conspirarcy to commitprostitution,2 counts).

22.

On January20,2009,membersof theMeridenPoliceDepartmentandConnecticut

StatePolice met to executethe arrestwarrantsand searchwarrant far 2047Norlh Broad Steet, Meriden,Connecticut.Priorto theexecutionofthewarrants,asecondundercoverofficer(UC2)was sentto the club to confirm the prostitution activity. UCZ arived at'2041 Club" andpaid fwenfy

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($20.00)dollarsto the doorman,lateridentifiedasAlexanderGranitto,to enterthe establishmen Insidetheclub,UC2recognrzedLauraKuhl a.k.a."Adrianna",paidhertwenty($20.00)dollars,and went into a privateroom with her. UC2 paid anothertwenty ($20.00)dollarsto LauraKuhl ak.a.

"Adrianna" andshecompletelyundressed.Dwing the "dance",IJcz andLauraKuhl had a sexrelated conversationin which sheofferedto haveanykind of sex with him in exchangefor more money. During the dance,LauraKuhl masturbatedIJCZ. 23.

Thereafter, membersof theMeridenPoliceDeparftnentandConnecticutStatePolice

executedfhe arrestwarrantfor LauraKuhI aftershe left"2041CIub" in her motor vehicle. Based on what occurredvdth UC2, Lawa Kuhl waschargedon-sitewith violation of C.G.S.$$53a-82 (prostitution),53a-88(promotingprostitutionI't degree),53a-48-53a-82 (conspiracyto coramit prostitution)and53-395(comrptorganizationandracketeering).

24.

During the executionofthe arest warrantsandsearchwarrant far 2047North Broad

Street Meriden, Cornecticut alsoknown as"2047 Club-, David Henderson,attemptedto evade arrestby locking himself into a heavily reinforcedback room and fleeing through a back door.

David Hendersonwas apprehended andarestedboth for the chargesin the warrantand for on-site violationsof C.G.S.$$54-33d(interferingwith a searchwarant), 30-86(servingliquor without a permit), 53-395(comrpt organizationandracketeering) and 53a-767a(interferingwith a police

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officer). Arrested on-site was AlexanderGranitto for violation of C.G.S. $$53a-48l53a-8

(conspiracytopromoteprostitution)),53a-48/53a-89 (conspiracytopermitprostitution) ,ard.53-395 (comrptorganiz4lionandracketeering).Also arrestedon-sitewas LorenaCastrofor violationsof

(conspiracytocommitprostitution)and53-395(comrptorganiZationand C.G.S.$$53a-48l53a-82 racketeering). EIga Orfiz was arrestedby warrantwith an additional on-site chargeof comrpt arrestedby (C.G.S.$53-395).CarltonDawkinswas subsequently organizationandracketeering wa:rant on January 27,2009 and chargedon-site with comrpt organizationand racketeering

(c.G.s.$s3-3e5).

25.

As part of the mostrecentinvestigationby C.S.U.into the illegal activitiesoccurring

at204l North BroadStreet,Meriden,numeroussearchwarrantswereissuedfor variousbanksafe

depositboxesbelougingtotheDefendants,LauraKutrlandDavidHenderson.

Searchwa:rantswere alsoissuedfor Mr. Henderson's As a resultofthesewarrants,a total of andMs. Kuhl's residences. in cashwasseized $267,835.02 26.

On all of the occasionsduringtheinvestigationinto illegal activity at*ZA LClub",

standardlaw enforcementprotocol andprocedurewerefollowed.

27.

Duringtheinvestigations within'2041 Club-,theindividualswho participatedin the

prostitutionenterprise within "2041Club" did sowithout fearof reprisalfrom patrons,employees

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or managemenr.

28.

The illegal activities wifhin *204I Club" have been allowed to exist despite

investigations andarestsby theStatePoliceandtheMeridenPoliceDepartnent,includingarrests which ultimatelyresultedin a lengthyprisonterm for the ownerof the club,David Henderson. No actionwas takenby thoseresponsiblefor thebusiness,or thepremises,to abatethe illegal activity occurring there, as evidencedby the illegal activity and resulting arests connectedto the investigationin January2009.

29.

ConnecticutGeneral Statutes. $19a-343ft)specifiesthattheStatemaybringanaction

to abateapublic nuisanceonrealproperfywherethree(3) ormore arrestshavebeenmade,or arest warrantsissued for enumoratedoffenseswithin thethreehundredsixty-five daysprecediagthe date ofthe State'saction. The State'sComplaintrecitessix (6) eligible a:restsfor offensesenumerated in C.G.S.g19a-343(c).

30.

Therehrve beentbree or more arrâ‚Źstsindicating a pattem of criminal activity for

conducton the subjectproperfydocumentedby alaw enforcementofficer for offensesspecifiedin C.G.S.$19a-343(c).

3L.

Basedon the prostitutionactivitiesandresultingarrestsdescribedherein,the real

properfylocatedat204l Norfh BroadStreet,MeridenConnecticuta.k.a."2041 Club" constitutes 10

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a public nuisancewithin the meaningof C.G.S'$19a-343,et seq.

32.

TheDefendantsto this actionareguilty of creatingor maintaininga public nuisance

in that they havemaintained,used,ownedor leasedthe premises,at 2041 North Broad Street, Meriden, Connecticut,a.k.a. *2041CIub" for illegal activities,as describedherein,within the et seq. meaningof C.G.S.$19a-343, 33.

hereincreatea clearandpresentdengerandrisk of The i]|egal activitiesd.escribed

irreparable hann to the public health, safety and welfare, including that of employees and pabons frequenting the subject premises, and to residents and visitors of the City of Meriden, for reasons including, but not limited to: a.

Prostifution tends to be a contiauing criminal enterprise;

b.

Prostitutionis closelyassociatedwithillegaldruguse andoflercrimibal andnuisance

creating activity; c.

Prostitutionposesahighriskof spread.ofcommunicablediseasesforprostitutes and

those who pakonize them, including sexually transmitted diseasessuoh asHepatitis B and the AIDS virus. d.

Areas in which prostihrtion occursprovide an inoreasedrisk that blood, semen,urine

or other bodily secretionwill be d.epositedon the floors and /or walls of such areas,which deposits 11

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could prove detrimental to the health and safety of otherpersons who may come info contact with such deposits.

COIINT TWO: (l9a-345, et seq. - HOUSES OI'ASSIGNATIOI$ 1.

The State of Connecticut brings this action pursuant to Connecticut General Statutes

Section L9a-345,et seq.

2.

Ilana R. Cathcart, a Senior Assistant State's Attomey, and designeeof the state's

attomey for the judicial distict of New Haven, is authorized to bring this action pursuant to Connecticut General StatutesSection 19a-346.

3.

Thepropedywhichisthezubjectofthisactionisknown as204lNorthBroadStreet,

in the City of Meriden, Stateof Connecticut,a.k.a."2041Club".

4.

The Defendant, CityscapeReal EstateHolding, Itrc., is the last recorded owner of the

*204L Club", subjectrealproperfyknown as2041 NorthBroadSkeet, Meriden, Connecticut,a.k.a.

2ss61dingto a Quit Claim Deed datedNovember 14,2002 from David J. Henderson"and recorded in Volnme 2gg8, page 2A3of the City of Meriden Land Records.

5.

Upon information and beiief the Defendant,David J. I{enderso+ is the owner and

operator of the cosrmercial business hrown as "2A41 CIub" located at 2A4L North Broad Street,

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Merideru Connecticut.

6.

Defendant, The Real Property Known As 2041 North Broad Steet, Meriden'

Connecticut, a.k.a.

*2A41.Club", is the subjectpremiseswhere the illegal activities complained of

in this Complaint have occurred and continue to occur.

7.

*2A41Club" is a busiuesswhich purports to provide exotic dancing entertainment

The single building is made of brick and glasswith a purple colored metal roof. A stockadefence *2041 with tho number "204L" is around the back of the building. A sign posted in front states Club", Inside the premises is a large open areawith a dance floor surrounded by plexi-glass in the middle of the room. To the right ofthis main areaare open booths with dividers and a padded bsnch in each. To the Ieft ofthe main areatowards the front door are fourprivate rooms with doors. The back portion of the premises,which consistsof severalrooms, is located down a hallway which is separatedfrom the main part of the premisesby a security door.

8.

The businesspremises located at 2041North Broad Street, Meriden, Connecticut,

now known as the *2041Club", was formerly called "Club LatJTau,"Appateasers",and the "Kit Kat Club". Under eachname, including the current natne, the principal owners and operators have been DavidHenderson, and/orDanielHenderson, and/orJamesF. Gill, andlor LauraKuhl. g.

In 1993, Daniel Hendersonwas arrestedon prostitution-related chargesand David

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and Racketeering Act' These Henderson was a:rested for violation of the Comrpt Orgarization occutring at their adultarrestswere based on law enforcement investigations into illegal activities Broad Sheet, Meriden, entertainrnent businesses, including the business located at 2a4L North Connecticut.

10.

permitting In 2003,David Hendersonwas a:restedfor promoting prostitution,

associated with prostitution, ffid violation of the Comrpt Qrgantzatton and Racketeering Act in 2003 ' As prostifution activity at the subject location in docket oumber N07M-CR03- 02162435 sentencedtotenyears aresult ofthis alTest,inNovemb et}}a',DavidHendersonwas convicted and imprisonment with forfy-five months to serve and five years probation' 11.

club while David Henderson remained involved with the business operatioas of the

incarcerated,and upon his releaseon parole in the fall of 200812.

Unit In December 2008, the Meriden Police Deparbnent's Crime Suppression

(hereinafter referred to as C.S.U.), received information that prostitution activity was occurring Meriden. Menrbers inside the businessl(]lown as"Z!4lClub" located at2l4lNorth Broad, Street, into illegal activity, of C.S.U. were familiar with the location due to the prior investigations including prostitution, whichwere conductedat the properby' 73.

police Specifically, in December2008, a concernedcitizen cordactedthe Meriden

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Deparhnent regarding an incident which had occured with his brother, who had patronizedthe ,,204! Club" with a group ofyoungmen. According to the concerned ciltzen, the young men in the group paid for unprotected sex with

'odancers"of"2041C1ub", and as a result, the complainant's

brother was infected with a sexually tansmitted disease. When members of the Meriden Police Deparbnent conducted a check of internet sites containing comments of individuals who had *2141Club", very similar information regarding the risk of sexually kansmitted knowledge of the diseasewas discussed. Due to the illegal activities aileged,and the public health hazardpresented in this information, an investigation into illegal activity at"204l Club" was begun.

74.

BetrveenDecember2008andJaauary2009,C.S.U.andthe StatewideNarcoticsTask

Force South Cenkal office undertook an investigation into illegal activity occurring within

'2041

Club',. As a result of this investigation, six (6) individuals were airested for prostitution-related crimes.

15.

Connecticlt Generalstatutes $19a-346specifiesthat the Statemay bring an action

"fhe to perpetually eqioin anynuisance as defined in Connecticut General Statutes$19a-345 and person or persons conducting or maintaining the same from continuing the same and the owner or agent of the building or ground upon which such rnrisanceexists from pe,r:rritting such buiiding or ground or both to be so used."

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Dgring the month of lanuary 2OAg,members of C.S.U' perbrmed apreliminary

the club investigation into activities occurring at*204l Club'by observing customers enter and exit police, five and folloraring and stopping them in their motor vehicles. Upon being stopped by the different customers each gave ihe same information about the prostitution business inside

*2041

Club',. Thisinformationconfimredthatthesamemethodsofoperatingaprostitutiogbusinesswere berrg used as had been used in the previous investigations for which David Henderson and Daniel Henderson were arrested and convicted.

17.

On fanuary 13,2009, an rmdercoverofficer (hereinafter'o[JC") was utilized in the

investigationof"214l Club". During this investigation the UC paid twenfy ($20.00) dollars to the doorman, who had beenpreviouslyidentifi.ed as Carlton Dawkins. Dawkins explained to the UC that the girls do not dance on the stage,but rather in a private room or semi-private booth. The ..da1cer" performs for the length of fime paid for. On this date, the UC paid an additional fody ($40.00) dollars to "Mialisa" ,lzter identified as Olga Mz.

Ms. Ortiz took the UC into a private

Afterfiveminuteswasover, roomwhereshecompletelyundressedandbegantomasturbatetheUC. Dawkins ba::gedon the door stating time was up' 18.

Thereafter on January 73,2009, the UC paid for anofher five minute dancewith a

female named "Cebe1lo", who was later identified as Lorena Castro. A heavy set male nanied

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'Dave", latsr identified asDavid Henderson,cameout of a back room and took the money. During tbis dance,offers of sex for moneywere discussedbetweenthe UC and Ms. Castro,but none were completed.

19.

After the UC's five minute dancewith Ms. Castrohad finished, he went back to the

bar. At the bar,

'Mialisa'' (Elga Ortiz)served tbe UC a beer from a refrigerator behind the bar. This

was donE in front of Carlton Dawkins and David Henderson.

20.

Thereafteron January 73,20}g,the UC paid for anotherfive minute dancein one of

the private roorns udth

'Mialisa" (Elga Ortiz). The money was given to Carlton Dawkins. During

this dance, Ms. Ortiz and the UC had a discussion about having other types of sex in exchange for more mon€y. Ms. Ortiz masturbated the UC during the dance.

21.

On January 15,2A09, the UC was briefed about Lawa Kuhl, who was known to

membersofthe C.S.U. and Con:recticutStatePolice StatewideNarcotics Task Force fromprevious investigatio ns at}}4lBroad

Street,Meriden. Ms. Kull also ran the business at the club when it was

known as "Club Laura" wtrile David Henderson was incarcerated on prostitution-related and racketeering charges. On this date, the UC paid the doorman, Carlton Dawkins, twenty ($20.00) dollars for entranceto the club. The UC spoke with the person he recoErized to be Laura Kr-rhla.k-a' 'oAdriaflLa" forly ($40.00) dollars for the house and welrt into a private "Adrianna". The UC paid

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room with her. Insidethe room,the UC paid anotherfor{y ($40.00)dollarsto LauraKuhl a.k.a.

"Adrianna" who completelyundressed.Ir a conversationwith the UC, Ms. Kuhl offeredto have any kind of sex with the UC in exchangefor more money. During the dance,Laura Kuhl masturbated the UC. 22.

arrestwarrantswere issuedfor: 1) investigations, Basedon the above-described

David Hendersonfor violations of ConnecticutGeneralStahrtesSections53a-86 (promoting (conspiracytopromote prostitutionl't degree),53a-89(permittingprostitution),and53a-48/53a-86 prostitution)and53a-48/53a-89(conspiracytopermitprostitution);2) LauraKuhl for violationsof Connecticut General StatutesSections 53a-82(prostitution) and 53a-48/53a-82(conqpiracyto commit prostitution); 3) CarltonDawkins for violationsof ConnecticutGeneralStatutesSections (conspiracyto 53a-86(promotingprostitution), 53a-89(permittbg prostitution),53a-48/53a-86 promoteprostitution)and53a-48 /53u89 (conspiracyto permitprostitution);andA)Elga Orttz fot violationsofConnecticutGeneralStatutesSeefions53a-82(prostitution,2counts)and53a48/53a82 (conspiracyto cornrnitprostitution,2 counts).

23.

On Januaryz1,}A}9,membersof the MeridenPoliceDepartuientand Cormeoticut

StatePolice met to executethe arest warrantsand searchwarrant fot 204I North Broad Street, Meriden,Connecticut.Priortotheexecutionofthewarrants,a secondtmdercoverofficer(UC2)was 18

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sentto the club to confirrnthe prostitution activity. UCZ arrived at*2047 Club" andpaid twenfy

($20.00)dollarsto the doorman,lateridentifiedasAlexanderGranitto,to orter the establishment Insidetheclub,UCZrecoenizedLauraKuhl a.k.a."Adriarna'',paidhertwenty($20.00)dollars,and went into a private room with her. UC2 paid anotherfwenty ($20.00)dollars to LauraKuhl a.k.a.

"Adrianna" and shecompletelyundressed.During the "daoce",UcZ and Laura Kuhl had a sexrelatedconversationin which sheofferedto have any kind of sex with him in exchangefor more money. During the dance,LauraKuhl masturbatedUC2.

24.

Thereafter,membersofthe MeridenPoliceDepartmentandConnecticutStatePolice

executedthe arrestwarrantfor LauraKuhI after she1eft'2041,Club" in her motor vehicle. Based on what occurredv/ith UC2, LauraKuhl was chargedon-sitewith violation of C.G.S.$$53a-82 (prostitution),53a-88(promotingprostitution1 $ degree),53a-48-53a-82 (conspiracyto commit prostitution)and 53-395(comrpt organizationandracketeering).

25.

During the executionof the arest warrantsandsearchwarrant for 204I Nortir Broad

Steet, Meriden, Connecticut,alsoknown as"204l Club", David Henderson,attemptedto evade arest by locking himself into a heavily reinforcedback roonr and fleeing through a back door.

David Hendersonwasapprehended andarrestedboth forthe chargesin thewarrantandfor on-site violationsof C.G.S.$$54-33d(interferingwith a searchwarant), 30-86(senringliquor without a 19

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permit), 53-395 (comrpt organization and racketeering)and 53a-167a(interfering ** officer).

police I

Anested on-site was Alexander Granitto for violation of C.G.S. $$53a-a8l53a-86

(conspiracyto promote prostitution), 53a-48/53a-89(conspiracyto permit prostihrtion), and 53-395 (comrpt orgadzation and racketeering). Also a:rested on-site was Lorena Casto for violations of C.G.S. $$53a-a8/53a-12(conspiracytocommitprostitution) and53-395 (comrpt organizationand racketeering). Elga Ortiz was affested by wanant with an additional on-site charge of comrpt organtzationand racketeering(C.G.S. $53-395). Carlton Dawkins was subsequentiyarrested by warrant on January 21.,20A9 and charged on-site with comrpt organization and racketeering

(c.G.s.$s3-3es).

26.

arestedbywa:rantfor the crimesofVoyeurism subsequently David Hendersonwas

and (C.G.S. $53a-189a),Conqpiracyto Cornmit Voyeurism (C.G.S. $53a-48/53a-189a), acts (C.G.S.$53a-189b) foraliegedlyvideo-recordingsexual DisseminationofVoyeuristicMaterial which were occurringbetweenemployeesandcustomersat the *2047 Club".

27.

activity at*2041CIub", On all of the occasions duringfheinvestigationinlo i1lega1

standardlaw enforcementprotocol andprocedurewere followed.

28.

During theinvestigationswittrin '204 LCIub", theindividualswho participatedin the

prostitutionenterprisewithin *2041 Club" did so without fear of reprisal from other pafoons, 20

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employeesor management, 29.

The illegal activities within '204t Club" have been allowed to existdespite

investigations andarrestsby theStatePoliceand/ortheMeridenPoliceDepartmentincludingarrests in 2003, which ultimately resultedin a lengthy prison term for the owner of the club, David Henderson.No actionwastakenby thoseresponsible for thebusiness,or thepremises,to abatefhe illegal activity occr::ringthere,as evidencedby the prostitution-relatedarrestswhich occurredin connectionwith the investigationin January2009.

30.

The Defendant,the Real Froperty known as 2041.North Broad Sfuee! Meriden,

Connecticuta,k.a.'2041Club"hasbeerrerected,established, maintained,used,owned.orleasedfor

the purposeof lewdness,assignationor prostifutionand is a nuisanceas definedin Connecticut GeneralStatutEs$t9a-345.

31'

The Defendants,David J. Henderson,Daniel Henderson,Laura Kuhl, and Cityscape

Real Estate Holding, Inc., are gurlfi/ of maintaining a nuisance pursuant to Connecticut General Statutes$19a-345,inthat theyhave erected,established,maintained,used owned or leased forthe purpose of lewdness,assignationor prostitution, fhe building or place Isown as 204! North Broad Sfreet,Meriden, Connecticut a.ka. "2041 Club".

32.

Based on the prostitution activities and resulting arrestsdescribedherein, and the

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generalreputationof the subjectproperty,the real properfy located at 2041 Norlb Broad Steet,

Meriden,Connecticut,a.k.a.*2047Club"constinrtes apubiicnuisancewithinthemeaningofC.G.S $I 9a-345.

WIIEREFORE, the Ptaintif[ Stateof Cornecticut,respectfirlly requeststhe following ordersof relief from tle Courtwhich arereasonably to abatettrepublic nuisance: necessary AS TO COTINTSONE AND TWO: 1.

Make a finding and enterjudgment declaringthat the Defendantsare guilty of

creatingand/ormaintaininga public nuisanceas definedby Cor:necticutGeneralStatutesSection '1,9a-343, as amended" andCornecticutGeneralStahrtes Section19a-346.

2.

brjunotiveorderswhichmayincludg but not be timited to, apermanentinjunction

against the Defendants,fheir employees,agents,assignsand all other personsfrom utilizing maintaining,owning, conducting,permitting,andcarryingon at the propertyknown as 2041North Broad Street,Meriden,Connecticuta.k a.'2041 Club- for illegal activity or anyotherpurposefor up to a oneyear period.

3.

A11other injunctive relief that the Court deemsnecessaryand proper to abatethe

public nuisancqwhichmayinclude,but not belimitedto, a permanentinjuuctionorderslesingthe buildinglocrted.atZl1{lNorthBroadStreet, Meriden,Connecticutandtbebusiness known as"204l

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Club" anddiscontinuingits usefor anypurposefor aperiodofup to oneyear.

AS TO COUNT ONE ONLY: 4.

An awardofthereasonable costsofinvestigation,prosecutionandanyexfuaordinar

expensesincurredby the Stateor the participatingmuaicipality in abatingthe public nuisance.

AS TO COT]NTTWO ONLY: 5.

An abatementorder directing the removal from the subjectbuilding or place all

conductingsuchnuisance and fixtures,fi.rnriture, andpersonalproperfyusedin musicalinskuments the saleof suchasprovidedin ConnecticutGe,neral Statutes$19a-346.

6.

A penaltyofnot morethantbreehundreddollarsirnposedupon anyperson,owner,

agentand the subjectproperly if a permanentinjunction is issuedfor maintaining a nuisance,in accordance with ConnecticutGeneralStatute$19a-351.

RESPECTFULLYSUBMITTED, STATE OF CONNECTICUI

By. Ilana R. Cathcart SeniorAssistantState'sAttorney Office ofthe Chief State'sAttomey 300 CorporatePlace RockyHill, CT 06067 Phone:(860)258-5810 JurisNo.: 475876

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