Booze News: Distilled in Room 215

A blog about the Baltimore City Liquor Board

What happened at the Liquor Board on January 14, 2016.

Written by Becky Witt

Hearings began at 1:20pm, with all three commissioners present.

I. Expedited Items (Transfers):

Applicant Chrisovalantis Minadakis
Business Name Jimmy’s Seafood, Inc.
Trading As Jimmy’s Famous Seafood
Address 6526 Holabird Avenue
Type of License Class “B” Beer, Wine & Liquor License
Reason for hearing Application to transfer ownership, request to add live entertainment, outdoor table service & off-premise catering
Hearing notes

Mr. Kodenski represented the applicant, who appeared but did not testify. Mr. Kodenski explained that his client was requesting to add live entertainment, outdoor table service, and off-premises catering. The property is zoned B-3, which allows for live entertainment as a matter of right, but the Liquor Board still has to approve it for the liquor license.

Commissioner Hafey pointed out that the applicant did not fill out page four of the application. Mr. Kodenski replied that his client is already a licensee and argued that he shouldn’t have to fill out the character witness section of the application since he is already a licensee. However, the applicant also left blank the section that requires the landlord’s signature. The docket stated that the application was for a transfer of ownership, along with the expansions of this license, which was apparently inaccurate. Executive Secretary Michelle Bailey-Hedgepeth noted for the record that the BLLC is making changes and updates to its application, in order to take into consideration the various kinds of applications that licensees and applicants can submit. In the future, once the applications are approved by the Comptroller of the state of Maryland, information that is not required will not be included on the application. In response to the missing information, Kodenski said, “we can make the addition before we come down and pick [the updated license] up.”

Commissioner Trotter asked how large the outdoor seating area is. Kodenski replied, “it’s really a misnomer, ’cause when I think they were granting it, they had an outdoor garden. That’s since not been there. So the outdoor is really a misnomer; it’s right next to the building, so it’s not a big issue here.” Trotter replied, “okay.”

Zoning B-3-1
Neighborhood Broening Manor
Area demographics 44% White, 25% Black, 2% 2 or more races; 20% Hispanic ethnicity; 32% households have children under age 18; median household income: $30,864.31; 22% households live below the poverty line
Does corp entity exist, in good standing? Yes; yes.
Location of entity’s principal office Baltimore, MD
One applicant reside in Balt for 2 yrs? Yes.
Pecuniary interest of Baltimore City resident 100%
Attorney for licensee Mr. Melvin Kodenski
# in support 1
Attorney for community None
# of protestants 0
# of inspectors/police officers 0
Result of hearing Approved
Vote tally Unanimous
Portions of state law cited in decision Art. 2B section 10-202(a)(iii).
Other reasons given for decision None
Issues raised in audit present in this case or other issues observed

Completeness: Under Article 2B section 10-202(a)(4)(iii), “[t]he Board or the Board’s designee shall examine each application for the issuance or transfer of a license within 45 days of receipt of the application to determine whether the application is complete.” Only after an application is complete may the matter be scheduled for a hearing (subsection (v)(1)). This application was not complete, because it did not have the signature of the landlord. Mr. Kodenski said that there was no space for the landlord’s signature, but the application actually does have a specific location for a landlord’s signature, at the top of page 4.

The application did not contain a floor plan, which would have been helpful to understand Mr. Kodenski’s statements about the beer garden that was not there.

A letter from Baltimore City Zoning Administrator Geoffrey Veale was included in the docket information regarding the zoning and the use and occupancy of the property. Mr. Veale states clearly in his letter that, though the addition of live entertainment and dancing is permitted in a B-3-1 zoning district, subject to obtaining an occupancy permit, “[t]o use a portion of the beer garden as live entertainment and dancing would be a change in the conditional use requiring” BMZA approval. The Board did not inquire into whether the licensee intended to expand the live entertainment use into the ephemeral beer garden/outdoor seating area or not.

Applicant Jasvir Mavi
Business Name None provided in docket
Trading As Trade Name Pending
Address 625-27 N. Glover Street
Type of License Class “BD7” Beer, Wine & Liquor License
Reason for hearing Application to transfer ownership
Hearing notes

Mr. Kodenski represented the applicant, who was present but did not testify. Kodenski explained that his client is requesting a transfer of ownership at an existing location. The applicant has prior experience working for a relative on Washington Boulevard. He’ll be the full time operator and is buying the property.

Commissioner Trotter asked how Kodenski’s client is financing the transfer. Kodenski responded that there will be seller financing involved.

Chairman Neil noted that there was an email in the file regarding an issue of citizenship. Kodenski joked, “I’m a citizen; I was born here.” He elaborated that requiring citizenship of a licensee shouldn’t be considered, under the Yim case, and under the new rules, citizenship is no longer required for a sole proprietorship with no business entity.

Zoning R-8
Neighborhood McElderry Park
Area demographics 3% White, 90% Black, 1% Asian. 4% Hispanic ethnicity. 51% households have children under age 18. Median household income: $33,352.
Does corp entity exist, in good standing? N/A
Location of entity’s principal office N/A
One applicant reside in Balt for 2 yrs? No
Pecuniary interest of Baltimore City resident 0%
Attorney for licensee Mr. Melvin Kodenski
# in support 1
Attorney for community None
# of protestants 0
# of inspectors/police officers 0
Result of hearing Approved
Vote tally Unanimous
Portions of state law cited in decision None
Other reasons given for decision None
Issues raised in audit present in this case or other issues observed

Constitutionality of the citizenship and registered voter requirement: The Board of Liquor License Commissioners for Baltimore City is in a difficult situation with respect to non-citizen applicants for liquor licenses. In general, laws are presumed to be constitutional. Therefore, normally, a law must be declared unconstitutional before an agency of the executive branch may decide not to enforce it. A 2004 California State Supreme Court case held that a “local executive official does not possess … authority” “to disregard the terms of the statute in the absence of a judicial determination that it is unconstitutional[.]” In the case that Mr. Kodenski cites, Yim v. Tuzeer, because the Maryland state legislature changed the law in such a way that it no longer applied to Mr. Yim, the court declined to rule on the constitutionality issue. In addition, the court rejected the constitutional argument, because it was not raised at the administrative hearing. In the opinion, the justices cited, however, a letter from the Attorney General’s office to the Baltimore City Liquor Board, stating the AG’s opinion that the law was unconstitutional. None of the above was discussed during the hearing, except for Mr. Kodenski’s conclusory email and statement.

Regarding the “new rules” and their lack of a citizenship and registered voter requirement: these requirements are in Article 2B section 10-103; the fact that they are missing from the new rules does not mean that the Board is not still required to enforce state law.

City Resident requirement: Article 2B section 10-103(b)(4) says that the applicant must have been for the two years preceding the filing of the application a resident of the City of Baltimore. Mr. Mavi gives a Dundalk address as his home address on the application; this address is outside of the boundaries of Baltimore City, rendering him ineligible to be a sole applicant for a Baltimore City liquor license.

Applicant Habtegebriel Sibhatu
Business Name None provided in docket
Trading As Dasmir Liquor & Grocery
Address 2331 E. Federal Street
Type of License Class “A” Beer, Wine & Liquor License
Reason for hearing Application to transfer of ownership
Hearing notes

Mr. Kodenski, on behalf of his client, proffered that the business is currently open and operating. The applicant has had prior experience, at a Class A licensed establishment on N. Eutaw Street for the past two or three years. Previously, he also owned a grocery business on Bayard Street. When Commissioner Trotter asked about the source of the funds for the business, Mr. Kodenski responded that his client is using his own personal funds from his grocery business.

Commissioner Hafey asked Kodenski whether he has contacted the community; Kodenski responded that he was waiting to do so until after the transfer, adding “it’s a small store, very small.”

Zoning R-8
Neighborhood Broadway East
Area demographics 1% White, 96% Black, 0% Asian, 1% 2 or more races; 1% Hispanic ethnicity; 35% of households have children under age 18; Median Household Income: $26,431.68; 21% households live below poverty line.
Does corp entity exist, in good standing? N/A
Location of entity’s principal office N/A
One applicant reside in Balt for 2 yrs? The period of residency for the applicant was not filled out, but he is a city resident.
Pecuniary interest of Baltimore City resident 100%
Attorney for licensee Mr. Melvin Kodenski
# in support 1
Attorney for community None
# of protestants 0
# of inspectors/police officers 0
Result of hearing Approved
Vote tally Unanimous
Portions of state law cited in decision Art. 2B section 10-202
Other reasons given for decision None
Issues raised in audit present in this case or other issues observed

Completeness: The applicant did not state on the application how long he has resided in Baltimore City. He is also not a registered voter, which is required by law and is further discussed above in the constitutionality paragraph. This applicant did not submit any information to show that he is a Baltimore City taxpayer, as required by Article 2B, and he does not own the building in which he resides in Baltimore City. For all three of these reasons, this applicant does not seem to qualify to hold a liquor license in Baltimore City.

Applicant Amy Bonitz
Business Name North Avenue Arts, LLC
Trading As Motor House
Address 120 W. North Avenue
Type of License Class “D” Beer and Wine
Reason for hearing Transfer of ownership and location; requests for Live Entertainment, outdoor table service and off premises catering.
Hearing notes

Ms. Caroline Hecker and Mr. Justin Williams, of Rosenberg Martin Greenberg, LLP, represented the applicant and proferred the case on her behalf. Hecker explained that she was withdrawing the request to convert the license from a 6-day beer, wine, and liquor license to a 7-day beer and wine license. Hecker described the 25,000 square foot building at 120 W. North Avenue, which was built as an automotive showroom and has recently been operated by artist entrepreneurs under the name “Load of Fun.” The project will be renamed the Motor House and will be renovated at a cost of $6.5 million to include a performance theater, public gallery, artist studios, and office space. As part of that renovation, the developers plan to open a 100-seat cafe, which will open in September 2016. The developers’ request is for sales of alcohol to take place on the first floor, with outdoor seating and live entertainment, which has already been approved by BMZA. Hecker submitted a letter of support and Memorandum of Understanding between her client and the Charles North Community Association.

Chairman Neil told Hecker and her client that it’s wonderful that they are doing this project, because “this neighborhood needed help.” He commended them for “taking the risk to do what other people won’t do.”

Zoning B-2-3
Neighborhood Charles North
Area demographics 53% White, 32% Black, 8% Asian, 3% 2 or more races; 4% Hispanic ethnicity; 6% households have children under age 18; median household income: $38,331; 5.5% households live below poverty line
Does corp entity exist, in good standing? Yes; yes.
Location of entity’s principal office Towson, MD
One applicant reside in Balt for 2 yrs? Yes
Pecuniary interest of Baltimore City resident 0%
Attorney for licensee Ms. Caroline Hecker and Mr. Justin Williams, Rosenberg Martin Greenberg LLP
# in support 3
Attorney for community None
# of protestants 0
# of inspectors/police officers 0
Result of hearing Approved
Vote tally Unanimous
Portions of state law cited in decision None
Other reasons given for decision None
Issues raised in audit present in this case or other issues observed

Pecuniary Interest: The applicant has no pecuniary interest in the business, according to the application on the Liquor Board docket, and there is no evidence that she is an authorized person of the LLC under Article 2B section 9-101. The application states that the applicant attached a list of the names and addresses of outstanding stockholders who own more than 5% of the stock of the corporation; there was no such attachment provided in the docket materials from the BLLC.

II. Regular Docket (New applications and Amendments):

Applicants John Stein & Ronald Burr, Jr
Business Name Stay Thirsty, LLC
Trading As World of Beer
Address 1724 Whetstone Way
Type of License Class “B” Beer, Wine & Liquor License
Reason for hearing Application for a new Class “B” Beer, Wine & Liquor restaurant license under the provisions of Article 2B Section 6-201(d) (vii) $500,000 in capital investment in restaurant fixtures and facilities and seating capacity for a minimum of 75 people; request for live entertainment and outdoor seating.
Hearing notes

Mr. Justin Williams, of Rosenberg Martin Greenberg, LLP, represented the applicants and proffered the case on their behalf. His clients are investing over $700,000 in the building, which currently operates in McHenry Row under a Class D tavern license; this Class D license will transfer to Piaza, which would be heard during the same day’s docket. They’ve been in business since 2013 and have no history of violations. Currently the average daily food receipts for this location must be greater than 65% of the total. Williams stated that Senator Ferguson has promised to introduce legislation during this legislative session that would lower that requirement to 51%. They will have live entertainment, including live bands and trivia. There are “high class” apartments above the restaurant, which will motivate the owners to keep the volume low. The applicants have received support from the Locust Point Civic Association.

Chairman Neil noted that the BMZA had required a security plan from the applicants; Caroline Hecker replied that her clients had submitted the security plan to the BMZA already.

Zoning B-2-2
Neighborhood Locust Point Industrial Area
Area demographics 90% White, 3% Black, 3% Asian. 3% Hispanic ethnicity. 15% households have children under age 18. Median household income: $73,342. 8% households live below poverty line.
Does corp entity exist, in good standing? Yes; yes.
Location of entity’s principal office Edgewater, MD
One applicant reside in Balt for 2 yrs? Yes
Pecuniary interest of Baltimore City resident 1%
Attorney for licensee Mr. Justin Williams and Ms. Caroline Hecker, Rosenberg Martin Greenberg LLP
# in support 3
Attorney for community None
# of protestants 0
# of inspectors/police officers 0
Result of hearing Approved
Vote tally Unanimous
Portions of state law cited in decision None
Other reasons given for decision None
Issues raised in audit present in this case or other issues observed None
Applicants David Crocetti and Jennifer Gounaris
Business Name McHenry Row, LLC
Trading As Piaza
Address 1602 Whetstone Way
Type of License Class “D” Beer and Wine
Reason for hearing Application to transfer ownership and location from 1724 Whetstone Way, outdoor seating and off premises catering.
Hearing notes

Mr. Justin Williams and Ms. Caroline Hecker, of Rosenberg Martin Greenberg LLP, represented the applicants, one of whom was present. The attorneys proffered that their clients are requesting a transfer of the Class D license from the World of Beer, which was the immediately preceding hearing. Ms. Gounaris is the Baltimore City resident on the application but is a Baltimore County school principal; Executive Secretary Michelle Bailey-Hedgepeth had excused her from being required to attend the hearing. Piaza opened as a fast casual eatery serving oven-fired pizzas in the summer of 2015. The applicants had met with the Locust Point Civic Association the night before the hearing, and the attorneys submitted a letter of support from that organization.

Zoning B-2-2
Neighborhood Locust Point Industrial Area
Area demographics 90% White, 3% Black, 3% Asian. 3% Hispanic ethnicity. 15% households have children under age 18. Median household income: $73,342. 8% households live below poverty line.
Does corp entity exist, in good standing? Yes; yes. But the name of the entity is “Piaza McHenry Row, LLC.”
Location of entity’s principal office Ellicott City, MD
One applicant reside in Balt for 2 yrs? Yes.
Pecuniary interest of Baltimore City resident 0%
Attorney for licensee Mr. Justin Williams and Ms. Caroline Hecker, Rosenberg Martin Greenberg, LLP
# in support 1
Attorney for community None
# of protestants 0
# of inspectors/police officers 0
Result of hearing Approved
Vote tally Unanimous
Portions of state law cited in decision None
Other reasons given for decision None
Issues raised in audit present in this case or other issues observed

Pecuniary Interest: The Baltimore City resident applicant did not have any pecuniary interest in the business, in violation of Article 2B section 10-103.

Applicant Kenneth Plante
Business Name Dead End Bar & Grill, LLC
Trading As Dead End
Address 933-35 Fell Street
Type of License Class “B” Beer, Wine & Liquor License
Reason for hearing Application for a new Class “B” Beer, Wine & Liquor restaurant license under the provisions of Rule 2.08 requiring $200,000 in capital investment in restaurant fixtures and facilities and seating capacity for a minimum of 75 people
Hearing notes

Mr. Melvin Kodenski represented the three applicants, all present. Kodenski explained that his clients had reached an agreement with the neighbors, who had had an issue with the proposed application. The applicants have agreed to only use the first floor, among other restrictions. A letter from the Fells Point Residents Association was in the file, and a neighbor testified briefly that he was in agreement with the new application, under the conditions they agreed to. Kodenski submitted a floor plan, capital investment breakdown, menu, and petition in support of the application.

Commissioner Hafey noted that this applicants were already licensees on a liquor license. Kodenski replied that there was originally a Class D license at this location, but that it had been closed. The commissioner asked, “that license is dead?” After a long pause, Kodenski replied, “yes.”

Zoning B-2-2
Neighborhood Fells Point
Area demographics 53% White, 32% Black, 8% Asian, 3% 2 or more races; 4% Hispanic ethnicity; 6% households have children under age 18; Median Household Income: $38,331; 5.5 % households live below poverty line.
Does corp entity exist, in good standing? Yes; yes.
Location of entity’s principal office Baltimore, MD
One applicant reside in Balt for 2 yrs? Yes.
Pecuniary interest of Baltimore City resident 1%
Attorney for licensee Mr. Melvin Kodenski
# in support 3
Attorney for community None
# of protestants 0
# of inspectors/police officers 0
Result of hearing Approved
Vote tally Unanimous
Portions of state law cited in decision None
Other reasons given for decision None
Issues raised in audit present in this case or other issues observed None

III. Violations:

Licensees Mustafa Jackson & Brittnay Moore
Business Name Four One Four, LLC
Trading As Kings and Diamonds
Address 414-16 E.Baltimore Street
Type of License Class “BD7” Beer, Wine & Liquor/Adult Entertainment
Reason for hearing

Violation of Rule 4.17(a): Sexual Practices and Obscenity – August 8, 2015 – Starting at approximately 9:30PM, members of the Baltimore City Police Department’s Vice Squad conducted an undercover investigation at the establishment. At approximately 11:30 PM, Det. Gatto, of the Vice Squad, made contact with an individual later identified as Ms. Shadyrra Jacobs who was a dancer at the establishment. Det. Gatto initiated a conversation with Ms. Jacobs who stated that she would have sexual intercourse with Det. Gatto for $600 outside of the establishment or for $300 if he preferred to have sexual intercourse inside of the establishment.

Violation of Adult Entertainment Rule 9: Codes Compliance – August 8, 2015 – Starting at approximately 9:30PM, members of the Baltimore City Police Department’s Vice Squad conducted an undercover investigation at the establishment At approximately 11:30 PM, Det Gatto, of the Vice Squad, made contact with an individual later identified as Ms. Shadyrra Jacobs who was a dancer at the establishment. Det. Gatto initiated a conversation with Ms. Jacobs who stated that she would have sexual intercourse with Det. Gatto for $600 outside of the establishment or for $300 if he preferred to have sexual intercourse inside of the establishment.

Violation of Rule 4.17(a): Sexual Practices and Obscenity – August 8, 2015 – Starting at approximately 9:30PM, members of the Baltimore City Police Department’s Vice Squad conducted an undercover investigation at the establishment At approximately 11:30 PM, Det. Garrett, of the Vice Squad, entered the establishment and later made contact with an individual later identified as Ms. Cabrina Robinson who was a dancer at the establishment. Det. Garrett initiated a conversation with Ms. Jacobs who stated that she would have sexual intercourse with Det. Garrett in the stage area for $200.

Violation of Adult Entertainment Rule 9: Codes Compliance – August 8, 2015 – Starting at approximately 9:30PM, members of the Baltimore City Police Department’s Vice Squad conducted an undercover investigation at the establishment. At approximately 11:30 PM, Det. Garrett, of the Vice Squad, entered the establishment and later made contact with an individual later identified as Ms. Cabrina Robinson who was a dancer at the establishment. Det. Garrett initiated a conversation with Ms. Jacobs who stated that she would have sexual intercourse with Det. Garrett in the stage area for $200.

Hearing notes

Former Liquor Board Chairman Stephan Fogleman represented the licensees in the matter and submitted a not guilty “plea.”

Baltimore City Police Detective Garrett testified that, on August 8, he entered the bar in plainclothes with Detective Gatto. A young woman approached him and began to dance on him; afterward, she sat next to him and they talked. During the conversation, she told him that they could have sex at the bar for $200. When Garrett said that he didn’t want to have sex at the bar, she suggested that they go to a private room for $50 more. Under cross-examination from Fogleman, there was some discussion of the time of evening that the two entered the bar. Garrett’s report said they entered at 9:30, but Gatto’s said 11:30. Garrett and Gatto both testified that they entered the club together. Under further questioning, Garrett said that there wasn’t anyone else in the bar and that he had ordered a Corona.

After Garrett and Gatto left the club, Detective LC Greenhill testified that he went in and identified the two dancers, based on what Gatto and Garrett told him about their stage names and the clothes they were wearing. Greenhill did not arrest the women in order to protect the ongoing investigations that the police were doing on the Block.

Detective Abraham Gatto then testified about his experience on the same night. Gatto said that a dancer approached him and brought him back to the seating area, where he paid her for a dance. Gatto suggested to the dancer that they have sex, but the dancer said that they would have to wait until after work, and it would cost $300. She suggested to Gatto that if they had sex right in the back room area, it would be $600. Gatto left the bar at some point after this conversation and notified Greenhill.

Fogleman then cross-examined Gatto, who testified further that the “private room” area was not really private; it was more like a lounge in the back, which was not lit in the same way that the stage was. A person could see into the room from the front if they wanted to. Fogleman asked Greenhill whether he had ever heard of an incident of prostitution with a price as high as $600. Greenhill replied that he had, for “more than $600, yes, oh yes.”

The licensees’ attorney then called Mr. William Shepherd, the manager of the club, to testify. Shepherd told the commissioners that he works at the club 50-60 hours per week, but he was not present on August 8. Though the women who were allegedly involved were not present at the hearing, Shepherd said that both of them denied the allegations to him. He said that he told both of the dancers not to come back until the issues were resolved. The manager said that the club has no back rooms where anything illegal can take place in private. He also has a “very strict hiring process” for the dancers, who are all independent contractors. He checks Maryland Judiciary Casesearch to see if the dancers have criminal records. Former Chairman Fogleman showed the commissioners photographs of the club so that they could see the floor plan. Shepherd testified that there is plenty of light inside the club. Called back to testify again, Detective Garrett said that the club was dark enough that you couldn’t see the back of it from the front. Detective Greenhill testified that he needed to use his flashlight to check IDs and employee records while he was there.

The two women’s criminal charges were both placed on the “stet docket,” which is a postponement during which the case can be reopened if the defendant does not follow certain conditions.

In closing, Former Chairman Fogleman argued that the old Adult Entertainment rules were “terrible creatures” and he applauded the new commissioners for revisiting them. He argued that the old wording of the rule talks about the licensee permitting or suffering his licensed establishment to be used for any sexual act or activity. Fogleman argued that the licensee in this case hadn’t allowed the prostitution solicitation to occur, because he hadn’t known about it. Fogleman said that he didn’t believe that Shepherd could do more to discourage illegal activity and argued that he exercised enough due diligence to not be charged with a violation.

Commissioner Trotter responded that a licensee should expect illegal activity when they operate an adult entertainment business. The entire premise of the business is on a very fine edge of legality. Commissioner Hafey asked if the licensee had terminated the employment of the dancers. The manager responded that he had asked them to take a break until the violation issue was resolved.

Mr. Fogleman jumped back in to again congratulate the Board on the new Adult Entertainment rules, which are much more comprehensive that the previous set of rules. Under Rule 4.01(c), the Board can deny, suspend, or revoke an adult entertainment license if employees or agents are enter into illegal acts on the premises and the manager reasonably should have known of the offense or failed to supervise. Fogleman said that these rules were much clearer and more comprehensive.

Zoning B-5-2
Neighborhood Downtown
Area demographics 39% White, 37% Black, 16% Asian, 3% 2 or more races; 5% Hispanic ethnicity; 9% of households have children under age 18; Median Household Income: $38,146; 18% households live below poverty line
Does corp entity exist, in good standing? Yes; yes.
Location of entity’s principal office Baltimore, MD
One applicant reside in Balt for 2 yrs? N/A
Pecuniary interest of Baltimore City resident N/A
Attorney for licensee Former Liquor Board Chairman Stephan Fogleman
# in support 1
Attorney for community None
# of protestants 0
# of inspectors/police officers 0
Result of hearing Responsible for 4 violations. $2,000 fine (total).
Vote tally Unanimous
Portions of state law cited in decision None
Other reasons given for decision

Commissioner Hafey noted that the manager wasn’t present at the time of the incident, which suggests to her that there wasn’t someone present at the bar who had oversight. Trotter agreed and said that two officers being solicited by two different dancers is a serious situation, which means that no one is watching over the business.

Former Chairman Fogleman asked whether the commissioners would consider merging the charges. Chairman Neil replied, forcefully, that Fogleman’s client had already gotten a good deal with a $2,000 fine, because Neil had been considering a suspension.

Issues raised in audit present in this case or other issues observed

The so-called “new” section of the Adult Entertainment Rules and Regulations referenced by the licensees’ attorney is borrowed word-for-word from the Baltimore City Code, Article 15 section 1-28, which has been in place for years, and which the BLLC should have already been enforcing.

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