CCR2008045-Summons with Complaint 021208
SUMMONS
IN THE MATTER OF:
REVOCATION OR SUSPENSION OF CLASS "A”
RETAILER’S LICENSE FOR THE SALE OF
FERMENTED MALT BEVERAGES
SHUJAL GROUP INC. D/B/A CITGO AND AGENT NAVDEEP SlNGH
TO: NAVDEEP SlNGH, AGENT FOR SHUJAL GROUP INC. D/B/A CITGO
S66 W14501 Janesville Road
Muskego, WI 531 50
Upon the filing of the Complaint, a copy of which is attached hereto, the Common Council of
the City of Muskego authorized the issuance of this Summons and you are hereby
commanded to appear before the Common Council of the City of Muskego at a time and
date fixed by the Mayor pursuant to Resolution #045-2008 attached hereto at the Muskego
City Hall, W182 S8200 Racine Avenue, Muskego, Wisconsin and show cause why your
license should not be revoked or suspended based upon the Complaint attached hereto, said
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time and date being fixed as the 18day of February 2008 at 6:00 p.m.
If you do not appear as required by this Summons, the allegations of the Complaint shall be
taken as true, and if the Common Council of the City of Muskego finds the allegations
sufficient, the license shall be revoked.
If you appear as required by the Summons and deny the Complaint, both the complainant
and you, the license holder, may produce witnesses and cross-examine witnesses under
oath and be represented by counsel.
The hearing will be transcribed in writing and you have a right to a written transcript of the
hearing at your expense.
TO: Muskego Police Department: You are hereby directed to serve this Summons and
attached Complaint upon Navdeep Singh, agent for the Shujal Group Inc. D/B/A CITGO.
The Summons shall command the licensee complained of to appear before the municipal
governing body on a day and place named in the Summons, not less than 3 days and not
more than 10 days from the date of issuance. The Summons and a copy of the Complaint
shall be served on the licensee at least 3 days before the time at which the licensee is
commanded to appear. Service shall be in the manner provided under Chapter 801 for
service in civil actions in circuit court.
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This Summons issued this 12 day of February 2008.
COMMON COUNCIL
CITY OF MUSKEGO
By: ______________________________
Janice Moyer
Clerk-Treasurer
W182 S8200 Racine Avenue
Muskego, WI 53150
(262) 679-5625
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COMPLAINT TO THE CITY OF MUSKEGO, WAUKESHA COUNTY,
WISCONSIN AGAINST THE SHUJAL GROUP INC.
AND NAVDEEP SINGH, AGENT
The complainant, Captain John Z. La Tour, a police officer for the City of Muskego Police
Department (hereinafter referred to as “Complainant”), for a complaint against the Shujal
Group Inc., D/B/A CITGO, located at S66W14501 Janesville Road, Muskego, Wisconsin
53150, and Navdeep Singh as its registered agent (hereinafter referred to as “licensee”),
pursuant to Wisconsin Statutes 125.04(1) and 125.32(2) WIS. STATS, and Muskego
Ordinance 12.125.04(1), having first been duly sworn on oath alleges on information and
belief as follows:
1. Complainant is the Operations Division Commander for the City of Muskego Police
Department and a resident of the City of Muskego. The Shujal Group Inc. is a
corporation that owns and operates a gas station with a convenience store located at
S66W14501 Janesville Road, in the City of Muskego, Waukesha County, Wisconsin
and its agent is Navdeep Singh. Said corporation holds a class "A" retailers' license
for the sale of fermented malt beverages as set forth attached in Exhibit No. 1, which
is incorporated herein by reference.
2. That a Class "A" license for the convenience store located at S66W14501 Janesville
Road, Muskego, Wisconsin was issued by the City of Muskego Common Council to
Shujal Group Inc. for the year July 1, 2007 to June 30, 2008.
3. On Monday August 18, 2007, two on-duty City of Muskego Police officers were
investigating a complaint at the CITGO gas station and convenience store located at
S66W14501 Janesville Road, at 6:16 p.m. Upon their arrival at said location, the
officers met an employee identified as Ram M Ram Patel who was the only employee
on duty at the time. Phone contact with a store manager identified as Patel Manoj
confirmed the identity of the employee and the fact that the employee was not
licensed through the City of Muskego to sell or dispense alcoholic beverages. A
search of the records maintained by the City Clerk for the City of Muskego confirms
that Ram M Ram Patel did not hold any type of license issued by the City of
Muskego.
4. On Thursday, September 6, 2007, two on-duty City of Muskego Police officers
conducted a licensed premises check of the CITGO gas station and convenience
store located at S66W14501 Janesville Road at 6:31 p.m. Upon arrival, officers
made contact with the on-duty clerk who identified himself with an Illinois I.D. as
Ramubhai Mohaanlal Patel. The employee was not licensed through the City of
Muskego to sell or dispense alcoholic beverages. The officers made phone contact
with a store manager identified as Nilam Patel, who informed the officers that he was
in the process of obtaining the proper licensing from the City. A search of the records
maintained by the City Clerk for the City of Muskego confirms that Ramubhai
Mohaanlal Patel did not hold any type of license issued by the City of Muskego.
5. On Friday October 19, 2007, two on-duty City of Muskego Police officers conducted a
licensed premises check of the CITGO gas station and convenience store located at
S66W14501 Janesville Road at 4:05 p.m. Officers made contact with the on-duty
clerk who identified herself as Alkaben S. Patel. Patel advised she did not have a
license to sell or dispense alcoholic beverages. The officers observed and noted that
the convenience store was open for business and noted that alcoholic beverages
were on display for sale to the public. A search of the records maintained by the City
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Clerk for the City of Muskego confirms that Alkaben S. Patel did not hold any type of
license issued by the City of Muskego.
6. At all times pertinent to this complaint on each of the above stated dates and times
the licensed premises located at S66W14501 Janesville Road, Muskego, Wisconsin,
was open for business. At no time during the investigation of the complaints by the
Muskego police officers was there on the premises the licensee or permittee, the
agent named in the license, or some person who had an operator license who was
permitted to sell or dispense alcoholic beverages to customers, in violation of Section
125.32(2) WIS. STATS.
7. On each occasion set forth in this complaint a municipal citation was issued to
Navdeep Singh for violation of the aforesaid state statutes and local ordinances and a
conviction for said violations resulted in each case. That the presence of employees
on the dates of violations who did not possess valid licenses issued by the City of
Muskego is a violation of Sections 125.04(1) and 125.32(2) WIS. STATS. That the
licensee is responsible for the acts of its employees and agents.
8. Complainant believes the information contained in this Complaint is reliable because
as to each violation Complainant was, as the Captain of Police, the command officer
directing the police investigation, knows the police officers who observed the
violations to be truthful and reliable, and each municipal citation issued in conjunction
with said violations was based upon the personal observation of the officers who
issued the charge. Further, Complainant has reviewed the police reports and other
records of the City of Muskego, believes them to be reliable, and has found them to
be consistently reliable in the past.
Complainant requests that a Summons issue, that a Hearing be scheduled and held before
the Common Council of the City of Muskego, and that the alcohol beverage license held by
Shujal Group Inc. D/B/A CITGO, Navdeep Singh agent, located at S66W14501 Janesville
Road, Muskego, Waukesha County, Wisconsin, be suspended or revoked, all pursuant to
Wisconsin Statutes Section 125.12 and the relevant ordinances of the City of Muskego.
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Dated in Muskego, Wisconsin, this 12 day of February 2008.
______________________________________
John Z. La Tour
Operation Division Commander
City of Muskego Police Department
Subscribed and sworn to before me
this ____ day of February 2008
_____________________________
Notary Public
Waukesha County, Wisconsin
My commission expires ___________________.
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