STATE OF SOUTH CAROLINA DEPARTMENT OF REVENUE OFFICE OF THE GENERAL COUNSEL 300A Outlet Pointe Blvd. Columbia, SC 29210 ‘Main Line: 803.898.5130 Facsimile: 803.896.0171 June 27,2023 VIA US MAIL AND EMAIL -~ sha; @ net ‘The Honorable Shirley C. Robinson Administrative Judge Edgar A. Brown Building 1205 Pendleton Street, Suite 224 Columbia, SC 29201 Re: Ulster Hams, d/b/a Social Bar & Lounge vs. South Carolina Department of Revenue Docket No. 23-ALJ-17-0148-CC DOR File No.: 220347 Dear Judge Robinson: Enclosed please find the SCDOR's Notice of Motion and Motion for an Emergency Suspension and Expedited Hearing in connection with the above-referenced matter. Please do not hesitate to contact me at 803-898-5110 or Dare,bailey@dor.sc.gov if you should have any questions, Sincerely, OFFICE OF GENERAL COUNSEL i P. Batley, Esquire Associate Counsel DPB/hch Enclosures c: Kenneth E, Allen, Esquire ‘Amanda M. Scott, EsquireSTATE OF SOUTH CAROLINA ADMINISTRATIVE LAW COURT Ulster Hams, d/b/a Social Bar & Lounge, DOCKET 23-AL}-17-0148-CC Petitiones, | SCDOR’S NOTICE OF MOTION AND MOTION FOR AN EMERGENCY vs. SUSPENSION AND AN EXPEDITED HEARING South Carolina Department of Revenue, Respond TO: AMANDA M. SCOTT, ESQUIRE, AND KEN ALLEN, ESQUIRE, ATTORNEYS FOR PETITIONER ULSTER HAMS, D/B/A SOCIAL BAR & LOUNGE (SOCIAL): (EMERGENCY MOTION) PLEASE TAKE NOTICE that pursuant to Rule 65, SCRCP, SCALC Rule 68, and sections 1.23-370(€), 12-60-1310, and 12-60-1340 of the South Carolina Code of Laws, Respondent, South, Carolina Department of Revenue (SCDOR), will move before the South Carolina Administrative Law Coutt (ALC) for an Emergency Order suspending the on-premises beer, wine, and alcoholic liquor licenses (100022565-PBW/PLB) held by Petitioner Ulster Hams, d/b/a Social Bar & Lounge (Social) for the premises located at 918 Gervais Street in Columbia, South Carolina (Licensed Premises).! SCDOR seeks the immediate suspension of Social’s licenses in this case pending the hearing on the merits for renewal of Social’s licenses. Based on the information provided by the Columbia Police Department (CPD) detailed below, SCDOR believes the “public health, safety or welfare imperatively requires emergency action” and respectfully requests an expedited hearing on this Motion. See S.C. Code Ann. § 1-23-370(0) é Social’s licenses are “issued or granted in the exercise of the police power of the State to do what otherwise would be unlawful to do.” Wall ». S.C. Aleobol Beverage Control Comma, 269 8.C. 13, 15, 235 S.B.2d 806, 807 (1977). tSCASE HISTORY Social has held a beer, wine, and alcoholic liquor license at the Licensed Premises since on or before December 18, 2020. This renewal matter” is before this Court pursuant to Social’s request for a contested case hearing challenging SCDOR’s March 27, 2023 Department Determination denying Social’s renewal application based on (1) receiving a valid protest’ from Inspector Michael J. Crowley with the Columbia Police Department (CPD); (2) Social’s failure to disclose all principals on its application in violation of sections 61-2-90 and 61-2-100 of the South Carolina Code of laws; and (3) Social’s failure to comply with South Carolina tax laws in violation of section 61-2-160 of the South Carolina Code of Laws. Inspector Crowley's protest of Social’s renewal application details CPD's response to “an enormous amount of calls for service, which has resulted in an immense amount of police resources” being consumed for this Licensed Premises. ‘The protest states: “CPD has responded to this location in reference to gun crimes, individuals shot, intoxication, larcenies, domestic violence, fighting and drug possession.” Inspector Crowley also describes the entrance to the Licensed Premises as “not well illuminated” with a “bottle neck of people” and indicates that on at least eleven occasions, CPD has documented Social’s “security” indiscriminately using pepper-spray to disperse patrons at closing time. Finally, Inspector Crowley’s protest states: Itis in the opinion of the Columbia Police Department that Social Bar and Lounge has failed to operate in a responsible manner, therefore adversely affecting the Put Health and Safety within our community. In our opinion, they have not taken necessaty steps to ensure the safety of patrons while selling alcohol. ‘They have had ample time to implement new strategies to [alleviate] the need for constant police resources, Therefore, we protest the reissuance of an Alcohol License to ULSTER HAMS, LLC, d/b/a Social Bar and Lounge. 2 Currently, Social has three matters pending at the ALC ~ two administrative violations and this matter reparding renewal of its licenses. 5 Inspector Crowley's public protest is attached as Exhibit 1. eSCurrent/Pending Violation Matters Social’s two administrative violation matters currently before this Court ate pending with Judge Kimpson. Judge Kimpson held a merits heating for the first administration violation (unlawfully selling liquor by the bottle) on January 26, 2023 (22-ALJ-17-0109-CC). As of the date of this Motion, the ALC has not issued its final decision regarding Social’s this administrative violation. SCDOR issued a Department Determination on May 18, 2023, addressing Social’s second administrative violation (selling alcoholic liquor on Sunday without a license). Social filed a request for a contested case heating with the ALC on June 16, 2023. ‘This matter has also been assigned to Judge Kimpson with docket number 23-ALJ-17-0221-CC, June 25, 2023 Shooting Incident (On June 26, 2023, Inspector Crowley informed SCDOR that another shooting at the Licensed Premises occurred in the early morning hours of June 25, 2023. Inspector Crowley indicated at least one individual was hospitalized with a gunshot wound to the lower extremity and a stray bullet damaged property actoss the street at a furniture store. Additionally, Chief Skip Holbrook of CPD also spoke of CPD’s continued concern with the escalation of gun violence stemming from Social on WIS News Channel 10.' On June 27, 2023, Inspector Crowley forwarded an email from Social’s neighbor expressing concetn with the repetitive gun violence originating from Social’s patrons.’ ‘The email alleged Social was advertising a large event on social media for July 3, 2023,' which causes the neighboring establishment to feat for the safety of its staff, customers, and the general public: 5 ‘The WIS News Channel 10 article is attached as Exhibit 3, ! ‘The email from Eddie Wales, the owner of an establishment that shares a driveway with Social is attached as Exhibit 4. © A copy of Social’s social media post advertising theis July 3, 2023 event is attached as Exhibit 5, An article from WLTX News Station documenting the July 5, 2022, is attached as Exhibie 2. i 3066(On Instagram Social is advertising a huge July 3rd inflatable bikini party that runs ftom the afternoon through the evening. It is at these big promoted events that most of [the] trouble has occurted. WIS and WLTX both reported [on] the shooting Friday night, I fear the next time it will be a gun death in the Vista. I fear for the safety of our staff and customers and the general public all because of a club... Inspector Crowley also provided an affidavit’ stating: He reviewed video surveillance footage following the June 25, 2023 shooting and observed two individuals exchanging gunfire outside of Social and one of the shootets fled on foot and ran towards Social’s back entrance. Social’s continued operation threatens the health, safety, and welfare of all individuals visiting the Vista, located in Richland County. ‘The public’s health, safety, and welfare imperatively requires emezgency action in this ease to prevent additional gun violence by suspending Social’s beer, wine, and alcoholic liquor licenses until the Administrative Law Court can review SCDOR's denial of Social’s renewal application. Social routinely permits acts which tend to create « public nuisance and/or constitutes a cxime at and around its establishment. ‘The violent criminal activity originating from Social and its patrons creates a risk to the public’s health, safety, and welfare. Since July 7, 2022, (the day he filed the protest of Social’s renewal application), CPD has received more than 50 calls for service at Social, including a fite code violation, numerous automobile break-ins, civil disturbances, assaults, physical altercations, as well as gun violence. On June 27, 2023, CPD installed a surveillance camera in front of Social’s driveway to allow real-time monitoring of Social and its patrons in response to the recent and escalated violence. No other nightlife establishment in CPD’s jurisdiction currently consumes as many CPD. resources as Social CPD will have to engage even more resources to patrol the area in the immediate future based. on the recent activities at Social. No other night-life establishment in CPD's jurisdiction in recent memory has experienced as much violent crime, Meetings with Social’s owners and landlord following the July 7, 2022 protest have not yielded any improvements in the location to alleviate the strain on CPD resources and mitigate the propensity for violence from Social’s patrons Inspector Crowley’s affidavit is attached as Exhibit 6. osARGUMENT South Carolina courts have affirmed SCDOR’s right to seek - and the ALC’s authority to grant - emergency suspension of that permit or license because such emergency action “protect[s} the public's future health, safety, or welfare.” S.C, Dep't of Revenue 2. Club Rio, 392 S.C. 636, 646-47, 709 S.E.2d 690, 696, (Ct. App. 2011). Additionally, section 1 .370(6) of the South Carolina Code of Laws provides, in pertinent part Ifthe agency finds that public health, safety or welfare imperatively requires emergency action, and incorporates a finding to that effect in its order, summary suspension of a license may be ordered pending proceedings for revocation or other action, ‘These proceedings shall be promptly instituted and determined. Based on Inspector Crowley's protest of Social’s renewal application, Socials violation history, information provided from CPD and Social’s neighbors, and the most recent shooting in Social’s parking lot on June 25, 2023, the public’s health, safety, and welfare imperatively requires emergency action in this case, As the attached Exhibits demonstrate, Social routinely permits acts which tend to create a public nuisance and/or constitutes a crime at and around its Licensed Premises. CPD has been working with Social for over two years to find a solution to the inordinate amount of law enforcement resources being consumed by this Licensed Premises. During this timeframe, CPD has responded to multiple incidents involving gun violence. The most recent incident on June 25, 2023, resulted in the hospitalization of at least one individual for treatment of a gunshot wound. ‘The continued operation of this location, pending the hearing on the merits of this case, threatens public safety. ‘The information provided by CPD indicates violence will continue to occur at the Licensed Premises unless this Court takes emergency action. As this violent criminal activity cacates a risk to the public’s health, safety, and welfare, emergency suspension of Social’s licenses is appropriate and authorized by law. S.C. Code Ann. § 1-23-370(¢); S.C. Ann. § 12-60-1310; S.C. Code Ann. § 12-60-1340, i 50f6INCLUSION Accordingly, SCDOR respectfully requests this Court issue an Order finding the public's health, safety, or welfare imperatively requires emergency action in this case and a summary suspension of Social’s licenses until this renewal matter is finally resolved or until Social’s licenses are otherwise surrendered or revoked, Columbia, South Carolina June 27, 2023 Respectfully submitted, Allen Myriék (Bar No. 1471 Patrick A. McCabe (Bar No. 81264) Associate General Counsel 300A Outlet Pointe Boulevard Columbia, SC 29210 Dare Bailey@dorsc.gov Court. Orders@dor.se.gov Attorneys for SCDOR Page 6 of 6[STATE OF SOUTH CAROLINA 1350 DEPARTMENT OF REVENUE ABL-~10 a NOTICE OF APPLICATION/ one dorsegov | “Q) LAW ENFORCEMENT PROTEST a Mail to: South Carolina Department of Revenue, ABL Protest, P.O. Box 125, Columbia, SC 29214-0907 Email: ABL@dor.sc.gov seee-acent Trsspoctoc. thiihoed T. Cateolry DATE 1-7- gora SKEB-AGENT CONTACT INFORMATION _ 03-19 - base This form MUST be completed and returned to DOR by oa It you fail to complete and retum this form to the Depariment of Revenue, we will assume there are no objections to the below location being licensed. hg person or entity named below has applied for a license to: Sell beer and wine for on-premises consumption [Sel beer and wine to go only no on-premises consumption allowed) Sal liquor by the dink for on-premises consumption 1 Operate a retail liquor store (no on-premises consumption allowed) [1 Sell beer, wine andior liquor at wholesale ‘Applicant's namo or PermitiLicense Holder: ULSTER Hams LLC /dJbla Sowal By el Loans Proprand bucinaes shires SUC CVI SE lect eee acres Has yoy jurisdiction had any problems with public intoxication at or near the proposed location? es [[INo _Ifyes, attach explanation and any supporting documentation. Have police been summoned to this location on prior occasions? (ves [No Ifyes, altach explanation and any supporting documentation. Is the prpposed location or nearby other locations been @ constant source of law enforcement problems? [CINo tyes, attach explanation and any supporting documentation. ‘Does the location have people congregating and loitering? [aes No Ifyes, attach explanation and eny supporting documentation, Does the corporation, association, or applicant have a reputation for peace and good order in the community? [ves [30 tno, attach explanation and any supporting documentation, Do you yish to protest this location? taves [No tyes, you MUST complete page 2. d= 7-32 Date $o3- 714 -3300 Department and Phone Number yauynOL4Will you tend a contested case hearing before the Administrative Law Court and offer testimony as to why you believe the propbsed location listed inthis protest should not be issued a new beer and wine peril andor iquor keense? ves. [No Your protest must bo postmarked and received by the Department of Revenue NO LATER than 4 days from the date the proposed location was posted by SLED; or the last date to protest as sworn in the Notice of ‘Advertisement in the newspaper, whichever occurs latest. Under penalties of perjury, the information contained in this protest form is true and correct to the best of my knowledge. PS. y= ge ‘Signature of [By Enforcement Offical Dale NOTE: THE INFORMATION COLLECTED ON THIS FORM IS SUBJECT TO PUBLIC SCRUTINY AND RELEASE, Please note the following: 4. If your protest states that the protestant does not wish to attend a contested case hearing before the Administrative Law Court, then the protest Is Invalid and the Department, by law, must continue to process the application and must issue the permit or license if all other statutory requirements are met. 2. If the protest is valid and states that the protestant wishes to attend a contested case hearing before the Administrative Law Court, then the Department must determine, via letter, emall, fax, or some othor ‘method, that the protestant does intend to attend the contested case hearing and offer testimony before the Administrative Law Gourt. 3. If the protestant advised the Department of his or her intention to attend the contested case hearing before the Administrative Law Court, but does not attend the hearing, then such protestant may, by law, be assessed a fine or penalty to include court costs. REQUIRED: ;pecific reasons why the application should be denied. (Attach additional pages If needed.) SEE AMMA HIMENT yauueoneMEMORANDUM Date: July 7,202 To: South Carolina Department of Revenue £ Licensing Bureau y From Michael J. Crowley Inspector Columbia Police Department Subject ULSTER HAMS, LLC. d’b/a Social Bar and Lounge 918 Gervais St., Columbia SC LAW ENFORCEMENT ABL-10 PROTEST ‘The following supporting documentation is in response to the “Law Enforcement Protest” by the Columbia Police Department against the reissuance of alcohol permits for ULSTER HAMS, LLC, d’b’a Social Bar and Lounge located at 918 Gervais Street, Columbia S Since January 2021 to July 5, 2022 alone, the Columbia Police Department (CPD) responded t0 an enormous amount of calls for service, which has resulted in an immense amount of police resources at this location. Because of the large amount of police resources being used at this one location, it is in our opinion that other areas of the city are certainly being under served. ‘On numerous occasions, incidents have required other Law Enforcement agencies such as USC Police and Benedict College Police to respond to this location to provide assistance. CPD has responded to this location in reference to gun crimes, individuals shot, intoxication, larcenics, domestic violence, fighting and drug possession, Officers have also observed consumption of alcohol on the premise after hours. On several occasions, CPD Officers have been on scene because of the large crowd exiting this location when gunshots rang out. The entrance to this location is not well illuminated and a bottleneck of people usually occurs in the parking lot because all patrons are being searched for weapons before entering. CPD has eleven (11) documented events to where “Security” at Social Bar and Lounge has deployed OC Spray on patrons at closing time, These patrons were very upset On June 24, 2021, [and other CPD command staff met with Mr. Meyer Moore (principal owner) at the Metro Region headquarters to discuss our concerns with prior incidents at Social Bar and Lounge. We advised Mr. Moore that we were concemed with the large amount of police Bla.resources being deployed to his business. We also conveyed to him that our greatest concern was for the Public Safety and Health of individuals inside and outside of his business. We advised Mr, Moore that CPD got very little cooperation from his security team during critical incidents Before the meeting concluded, Mr. Moore advised that he would do what was necessary and make changes where needed to solve this problem. Since June 24, 2021, CPD has continued to respond to calls for service at this location CPD has also received complaints from members of the busi around the Social Bar and Lounge about incidents that have occurred. Many of these complainants are concemed with the public safety of individuals visiting this near and is in the opinion of the Columbia Police Department that Social Bar and Lounge has failed to operate in a responsible manner, therefore adversely affecting the Publie Health anc Safety within our community. [n our opinion, they have not taken the necessary steps to ensure the safety of patrons while selling alcohol. They have had ample time to implement new strategies to elevate the need for constant police resources. Therefore, we protest the reissua ‘of an Alcohol License to UL ER HAMS, LLC, d/b/a Social Bar and Lounge. Wy6727123, 12.00 PM Man shot outside Social inthe Viste in Columbia | witccom Man shot outside club in Columbia's Vista Police say the injuries appears to be non life-threatening. Reece ese eo pst 543 PA EDT ty 2022 ‘COLUMBIA, $.C. — Columbia Police are searching for the person who they say shot = man ‘outside a bar in Columbia's Vista, ‘The incident happened at Social Bar & Lounge in the 900 block of Gervals Street around 1am, Tuesday. Officers say they were called there after getting emergency cals From the public about a shooting in that location. When they got there they found a 21-year-old man who'd been shot in the arm, Officers applied tourniquet to his injuty to stop the bleeding, The victim was then ‘token to the hospital for further treatment. Officers say the injuries are non ife-hreetening. No one else was reported injured. Officers say theyre looking to see If survellance cameras can help identily the suspect Anyone with information about the incident to cantact CRIMESTOPPERS in any of the following ways: hus: convartce/noweyerimeshooting vista columble-sauth-carolinalt01-b3e7ab/2-509d-4165-a5e"-deta152atb> 12127123, 1200 PM ‘Man shot outside Social inthe Vista in Columbia | wix.com CAL tol-te0, 888-CRIME-SC. LOG onto: www.midiandscrimestoppers.com, and click on the red “Submit a tip” tab, DOWNLOAD the new P3 Tips App for Apple or Android devices. ‘Sumter Police search for woman accused of shoating 2 on Saturday night Death investigation underway in West Columbia ‘LOADING NEXT ARTICLE... tips. conlartclelbows/ximeYshooting-vistacclunbie-south-carolina/101-be7abf2-S084-4185-a5e!-do4d152a@b NIN 2aNews Live Fits Alert Weather Sports WIS Investigates Columbia Police Chief wants a Vista nightclub shut down after multiple shootings in area CHIEF SKIP HOLBROOK [eT Tae =o WES Dat 1 pm Monday tough Fe By 7) Wilson and Marcus Flowers Pablished: un. 27, 2029 at S40 AM EDT | Updated 6 hours ogo ouven COLUMBIA, SC. (WS) - The City of Columbia's police chiefs oking action to ensure people have fun while going outa popular sree ofthe ity without fearing for thei ives ‘Two shootings in the past two months at The Vista have lft multiple people injure, and aftr the latest incidant that happened this past weekend Plce Chit Wiliam “Skip” Holbrook ofthe Columbia Police Departments taking ation whe sure never happens again, We hve a lub in the Vista Socil Bar ard Lounge cli, where there hos been a numberof assaults and violent nsdents we have connected back to he dub says Hotbrook The shootings have rated business owners and patron in the ares and Holbroak belever it the Social Bar and Lounge shuts down, Holbrook believes ‘things wil changeHolbrook as “Right now we have zidtional patrols We invested in adtiona camarasin the Visa. License plate veados, but unl you eliminate what is easing the problem that clu, the type of parties thay are having, and then the lige clowe that ae gathering and the probleme we are having atervard. Until we stop that, tis going tobe hard for us to prevent situation tke ths, with certain bad actors that ae carrying guns with bad intentions to use a gun” ‘The police chiefs adding extra resources to the area to hela prevent and stop gun violence, but he isnot stopping there. "We have had several instances atthe cab eesuitng in us sending them a rusance letter and asking them to come to meet with us We have not sen any movement or any improvement with the cu, and the violence over the weekend isa great example af that We have filed whet we refer te, 35 an alcoho potest tition with the Department of Revenue to revoke thelr quot lienea” Most nightchibs generate a sizable portion of ther revenue from alcohol sls Holbrook saysif ha quer license is taken away, the Soca Bar and Lounge wil probably cose geting, id of the problem for god. Notice a speling or grammor erin this onticle? Click ar top hereto report it Please include the article's headine Sty upto dote with WIS News 1. Get the app rom the Apple App Stare or Google Ply Store. aré Stream us on Roku YouTube, Amazon Fie or Apple 1M Copyright 2023 WAS. Al rihts reserved. Most Read © ‘check your statements: Former hotel worker accused of accessing guests credit cards &: dead J overturmed In Lengton County ‘© FIRST ALERT WEATHER: Strong storms possible tonight Yq a4Dare Bailey Crowley, Michael | Tuesday, June 27, 2023 11:06 AM Dare Bailey FW: [EXTERNAL] Gun violence st Social. YL I'm working on getting this past weekend reports to you, Michael --Original Message- From: eddie wales Sent: Tuesday, June 27, 2023 9:47 AM To: Crowley, Michael Cc: Abby Naas ; Ariel Brady Subject: [EXTERNAL] Gun violence st Social [You don't often get email from ewales99@gmail.com. Learn why this is important at https://aka.ms/LearnAboutSenderidentification } CAUTION: This email originated outside of the organization. Do not click links or open attachments from unknown senders or suspicious emails. Never enter a username or password on a site that you did not knowingly access. Far suspicious emails, please report using the "Phish Alert Report" button. Hi Inspector Crowley, ‘As I'm sure you are well aware there was another shooting at Social in the Vista this past Friday night/ Sat morning. Our GM Ariel Brady supplied video to CPD of the shooting in our parking lot near the street and then the shooter running back towards Social and jumping the fence by their back left door. | worked Friday night but then left town early Saturday for vacation. Upon learning of the incident I contacted one of Social’s newer owners (who has been responsive to issues from us in the past) by text. He responded that his managers said the shooting was in the ally behind them and that USC police said the shooting “had nothing to do with Social”, which we know isa lie. | told him as much and supplied the video to him as well. His only response was that we should get together and talk about their new concept of a beach bar. Something they have been saying they're going to do for a year. July 4th weekend is coming up and last year Social had 2 gun incidents over the same weekend. This prompted CPD to protest Socials liquor license in August. Nearly a year has gone by while the appeals go through due process with SCDOR. | understand the process is out of CPO’s hands at this time but is there something else you can do in the meantime to make things safer, a temporary injunction to close them down, station a car in our parking lot on the weekend nights, put pressure on the owners? (On Instagram Social is advertising a huge July 3rd inflatable bikini party that runs from the afternoon through the evening. tis at these big promoted events that most of trouble has occurred. WIS and WLTX both reported of the shooting Friday night, | fear the next time it will be of a gun death in the Vista. | fear for the safety of our staff and customers and the general public all because of a club that has been allowed to operate for far too long.Any assistance and action from the city is needed now and is greatly appreciated. BTW here are contacets for Social’s owners Jay Floyd 803-477-8980 George Sembos 803-513-9898 Thank you, feel free to contact us anytime, Eddie Wales (Qwner- Motor Supply 802-238-4065 Ariel Brady GM- Motor Supply 803-605-2567 nr672723, 1:56 AN Facebook Social Bar and Lounge THRs tomes @28dp2"9 we like Q Search Posts About Mentions Reviews Followers Photos.» More ¥ ce Intro Columbia's Hottest Nightclub and Bar located in the Vista. Bringing you some of the biggest Electroni © Page: Bar © 918 Gerais st, Columbia, SC, United States, South Carolina & (603) 603-4313 5X info@socialcohumbiase.com ® socialcolumbiase.com DP EXHIBIT ES © closed now © Price Range-$$ hitpsuwinwfacebock.com/socialcohmbiase wnt6127/28, 1:58 AM Facebook Oe o 8 Photos See all photos Peete add aces Privacy Terms Advertising Ad Choices > Cookies - More - Meta © 2023 Posts Social Bar and Lounge 4h JULY 3c 1 Over 500+ invaded our last Slip N Slide of Inflatable Party! & We're Back even bigger this time 5 Filters FREE BACARDI SAMPLES ! provided by Bacardi Models @ July... See more - Zz https facebook.comisocialcolumbiase = m &127123, 1:56 AM Facebook Oe ee 10PM vlUitel=s4 DIIBT DIB TRUE social of) Uke © Comment 2 Share BP wite a comment 220088 Social Bar and Lounge ne 18 at 451 PM #SOCIALIZE @lexxiieebabyyy ta: Orarri_tupvizualz hups:wantfacebook.comsocialcolumbiascLents 7 Nell ; yg ae3,11:56 AM Facebook Q oe @ Pyaar ) & 2 Like © comment ® Share Q® write a comment Z£Q0080 Genin ae ox Tiss tovighthemeg/ Cone cath Viel Arado Gczcneoubisc oka he eter Pay oy 2th = Mushy fica + @thecaljlaycee @d, ve & mor. See moe ini it of SE St eM) waia r SOTO RCD sa B Caer Social Sey Wart cmon FOR SECTION DM @OFFICIALDJUB OR @SOCIALCOLUMB! 1 share G Like © Comment ® Share Iiipsw facebook comvsocialcoumblaseSTATE OF SOUTH CAROLINA ADMINISTRATIVE LAW COURT South Catolina Department of Revenue, DOCKET 23-ALJ-17-0148-CC Petitioner, v. AFFIDAVIT OF INSPECTOR MICHAEL CROWLEY, COLUMBIA Ulster Hams, LLC, d/b/a Social Bar and Lounge, POLICE DEPARTMENT Respondent. COMES NOW, INSPECTOR MICHAEL CROWLEY OF THE COLUMBIA POLICE DEPARTMENT, being duly sworn, affirms the following: 1. Tam over the age of 18 years and I provide this affidavit from my own personal knowledge. 2, Lam employed as an Inspector with the Columbia Police Department (CPD) in Richland County, South Carolina. I have been employed with CPD for approximately 2.5 years. 3. I drafted and submitted the Law Enforcement Protest dated July 7, 2022, and attached to SCDOR’s Motion for an Emergency Suspension and an Expedited Hearing (Emergency Motion) as Exhibit 1. 4, have personal knowledge of the facts alleged in the WIS News Channel 10 article attached to SCDOR’s Emergency Motion as Exhibit 3 5. Leceived an email from Eddie Wales, owner of an establishment neighboring Social Bar and Lounge expressing concern about the continued gun violence at Social on June 27, 2023. 1 provided the email to SCDOR and it is attached to SCDOR’s Emergency Motion as Exhibit 4. 6. Thave personal knowledge of the facts alleged in WLTX’s July 5, 2022 news article attached to SCDOR’s Emergency Motion as Exhibit 2 7. After the June 25, 2023 shooting in Social’s parking lot, I obtained video surveillance footage from the general manager of the establishment that neighbors Social. I reviewed the video footage and observed two individuals exchanging gunfire outside of Social. One of the individuals fled on foot, running towards Social’s back entrance. 8. Social’s continued operation threatens the health, safety, and welfare of all individuals visiting the Vista, located in Richland County. Page 10f 2 I9 The public’s health, safety, and welfare imperatively requires emergency action in this case to prevent additional gun violence by suspending Social’s bees, wine, and alcoholic liquor licenses until the Administrative Law Court can review SCDOR’s denial of Social’s renewal application, 10, Social routinely permits acts which tend to create a public nuisance and/or constitutes a crime at and around its establishment. 11. The violent criminal activity originating from Social and its patrons creates a tisk to the public's health, safety, and welfare. 12. Since July 7, 2022, (the day I filed the protest of Social’s renewal application), CPD has received more than 50 calls for setvice at Social, including a fire code violation, numerous automobile break-ins, civil disturbances, assaults, physical altercations, as well as gun violence. A copy of the Incidents Search Report is attached to my affidavit as Exhibit A. 13. Today CPD installed a surveillance camera in front of Social’s driveway to allow real-time ‘monitoring of Social and its patrons in response to the recent and escalated violence. 14, No other nightlife establishment in CPD’s jurisdiction currently consumes as many CPD resources as Social, 15. CPD will have to engage even mote resources to patrol the atea in the immediate future based on the recent activities at Social. 16, No other night-life establishment in CPD’ jurisdiction in recent memory has experienced as much violent crime. 17. Meetings with Social’s owners and landlord following the July 7, 2022 protest have not yielded any improvements in the location to alleviate the strain on CPD resources and mitigate the propensity for violence from Social’s patrons, Swom to and Subscribed before me on june 27, 2023. ley Notary Public for South My Commission Expires May 6, 2031 Page 2 0f2 my MICInform Browser : 21.102.411.15 - Search - Incidents (Advanced) Page 1 of 2 \ CAD Browser Enterprise “saat > =a te [resent z Dettveoe [rte voice [acces ce [asc or vee ¥ ULceiden mivate Progen cr asco [sera] Pon (cas [Grae torkarecion | [loro 4 ter poses! ay homer Agencies (Poke a cS Wiscso icro. an a ae Lac rre 5 1 058+ as wierd except for Unt [Siero un + ttcomplete case number isc, then (Shes ‘ther id eared ee 3 ‘ecsrssn snes cura go swcenuser cmon” sonaszor ana ‘cons, mee So teens Suma nen ena a ‘secrim teers oss 2 toons Suwa Shaseseiee conn sae ct: oo comet Sauna Sassoon copii seit Pe tote co ecm coun staan ana acne omar tenet oo tecwmnst coum Senate ssc Be tou cro tani ccunen sonar aor enous cz few cr ttn coun danas 2s8s0a sees SB. caomteeshP, toma coum aso rasiere scent SBR 2 sett eseen 0 smears coun sates tat toron enna (et 4 Ale at 20 staat ounon amano t ‘mietaie Ss 5 st ney nc > ncaa nie isos cme tout = ms ‘ena hitp://10.240.1.24/VisiNetBrowser/Search/IncidentSearch.aspx 6/27/2023Inform Browser : 21.102.411.15 - Search - Incidents (Advanced) sans et ia = a eone =. sxc Se Saou ann al iam 2} oe oat sat ° rs =. scam =: 7 Pe a = seco se s, aber side abr aa st oy tatty 8439389 9 8 aaggg hitp://10.240.1.24/VisiNetBrowser/Search/IncidentSearch.aspx Page 2 of 2 6/27/2023 Zh,Inform Browser : 21.102.411.15 - Search - Incidents (Advanced) Page | of 2 CAD Browser Enterprise ieee = ‘havenead a ay [Eeewe cate Beer 5 ncornonthr 4 = SS aan coe |__| ">" = Geacweomes 1 —— oT Eker ee elt 1 ioae igre es} J = eae 1 Use * as whcard except for Unit een casei ‘rer terme ‘| ™ [ceo une cea capaapiae: Boe mereneet em J a =a oe 7 am http://10.240.1.24/VisiNetBrowser/Search/IncidentSearch.aspx. 62772023 % |Inform Browser ; 21.102.41 1.15 - Search - Incidents (Advanced) Page 2 of 2 http:/!10.240,1.24/VisiNetBrowser/Search/IncidentSearch.aspx 6/27/2023 YhSTATE OF SOUTH CAROLINA ADMINISTRATIVE LAW COURT Ulster Hams, LLC d/b/a Social Bar& =) Docket No. 23-ALJ-17-0148-CC Lounge, ) o iN Petitioner, ) ) vs. ) PROOF OF SERVICE ) South Carolina Department of Revenue, ) ) Respondent. ) J 1, the undersigned employee of the South Carolina Department of Revenue, Office of General Counsel, do hereby certify that I have served the SCDOR’S Notice of Motion and Motion for an Emergency Suspension and an Expedited Hearing in connection with the above-captioned matter by causing a copy of the same to be deposited in the United States Mail, postage prepaid, to the following partes at their address of record: Kenneth E. Allen, Esquire Amanda M. Scott, Esquire Ken Allen & Associates, LLC Capital Center 1201 Main Street, Suite 1980 Columbia, SC 29201 Alttorneys for Petitioner Herman C. nansl A i a Office of General Counsel South Carolina Department of Revenue Columbia, South Carolina June 27, 2023