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Club Love and Lust: SLA Letter Motion Seeking Reconsideration and Reinstatement

Love Lust establishment


New York Civil Rights Lawyer Eric Sanders, Esq., of The Sanders Firm, P.C., announces the filing of a letter motion to the New York State Liquor Authority seeking reinstatement

New York, May 30, 2018, – The Sanders Firm, P.C.; was hired to investigate the ‘selective enforcement’ policing practices under the authority of New York State Liquor Authority Investigator Charles A. Stravalle and Deputy Inspector Emmanuel Gonzalez, Commanding Officer of the 72nd Precinct and Special Operations Lieutenant William Meyer related to the KB Venture Group, LLC d/b/a Club Love & Lust 225 47th Street Brooklyn, N.Y. 11220. KB and Imran A. Jairam’s license is ‘inactive.’ KB and Jairam are seeking an immediate ‘reconsideration and reinstatement.’

Thus far, the KB and Jairam has filed a Notice of Claim with the New York City Comptroller’s Office and intends to file other legal actions to protect its rights. KB and Jairam alleges violations of The Civil Rights Act of 1866, 42 U.S.C. § 1981 (Race Discrimination), The Civil Rights Act of 1871, 42 U.S.C. § 1983 (Equal Protection – Selection Enforcement and Monell) and 42 U.S.C. § 1985 (Conspiracy).

According to the motion, during the course of the preliminary investigation, Eric Sanders Esq., claims to have noticed an alarming pattern of similar ‘selective enforcement’ policing practices within the NYPD 40, 72, 77, 79, 88, 102, 106, 110 Precincts and other patrol commands. The targets are: On Premise (OP) license holders of color, business owners of color and establishments catering to the under served target market (primarily persons of color) culturally connected to the hip-hop community with more than $500 billion in discretionary income to spend upon entertainment.

Under the New York State Liquor Authority, the ‘focal point’ standard was used by Stravalle, Gonzalez, Meyer and other actors in the ‘scheme’ to perpetuate a fraud upon the courts to ‘benefit’ themselves and others with overtime, organizational donations, gifts and other pecuniary gains, noted in the motion. Based upon the preliminary investigation, Sanders believes this matter warrants a criminal investigation into these ‘selective enforcement’ policing practices.

According to the New York State Liquor Authority’s website, there’s no data to establish the license holder’s race and/or national origin. There’s no data to evaluate ‘selective enforcement’ due to the license holder’s race and/or national origin. Nor is there data to evaluate SLA fines and other penalties due to the license holder’s race and/or national origin.

In or around October 2014, KB and Jairam opened for business. Shortly thereafter, KB and Jairam claims Meyer and Stravalle began the campaign of harassment to close the business due to their race and/or national origin. These parties including NYPD Patrol Borough Brooklyn South Assistant Chief Steven M. Powers subjected the business, its patrons and other stakeholders to unlawful ‘selective enforcement’ activities despite a previous ruling in Sulkowska v. City of New York, et al., 129 F.Supp. 2d 274 (S.D.N.Y. January 24, 2001, due to their race and/or national origin, notes the motion.

From November 2016, through this time period, several complaints about the ‘selective enforcement’ were filed with the City of New York through the Police Commissioner’s Office, Patrol Borough Brooklyn South and 72nd Precinct. According to the motion, throughout this time period, Gonzalez attempted to secure several personal ‘benefits’ from KB and Jairam including 11 ‘free’ round trip tickets on charter flights to Puerto Rico and a generator for family member or friend Dr. Oscar Caban Badillo, MD. KB and Jairam DENIED both requests.

On April 24, 2018, frustrated with the ‘selective enforcement’ KB and Jairam sought assistance from Brooklyn Community Board No.: 7, which in turn offered the following statement: “My community was very concerned when this business opened several years ago as Jaguars 3 (Red Leopard) and, at the beginning, there were community complaints about the activities of the patrons and how the business operated. However, in the past four years our office has received no complaints about the operation of the business nor the behavior of the patrons. In fact, we have record of only a few quality of life complaints in the immediate vicinity and none have identified Love and Lust as the progenitor of these complaints.”

Therefore, based upon the totality of the circumstances, KB and Jairam are seeking an immediate ‘reconsideration and reinstatement’ including a criminal investigation into the ‘selective enforcement’ policing practices of Stravalle, Gonzalez, Meyer and other actors in the ‘scheme’ to perpetuate a fraud upon the courts to ‘benefit’ themselves and other actors with overtime, organizational donations, gifts and other pecuniary gains.

“They’re trying to financially ruin KB and Jairam,” Eric Sanders said. “We will use the public and Courts as disinfectants to rid KB and Jairam of this culture of governmental corruption.”


The Sanders Firm, P.C. offers those in the New York City area legal services related and connected to civil rightscivil service rightscriminal law and discrimination. We firmly believe in everyone’s individual rights that are described and guaranteed by the Constitution of the United States of America. We understand that our freedoms and liberties are sacrosanct and that they have been won in many and various hard-fought battles. We are committed in every way to protecting your civil rights. We are your voice for justice!


Eric Sanders, Esq.
President and Owner, The Sanders Firm, P.C.
Business Phone: 212-652-2782

SLA Letter Motion

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