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Stephen M. Reilly, Jr.

Assistant City Solicitor
Law Department
36 Court Street, Room 210
Springfield, MA 01103
Office: (413) 787-6085
Direct Dial: (413) 787-6133
Fax: (413) 787-6173
Email: sreillyjr@springfieldcityhall.com


THE CITY OF SPRINGFIELD, MASSACHUSETTS


September 11, 2014


SERVED IN HAND VIA SPRINGFIELD POLICE DEPARTMENT


Timothy Babbs
d/b/a Ambrosia Lounge
143 Main St.
Springfield, MA 01105

RE: DEMAND TO CEASE AND DESIST UNLICENSED ACTIVITY
143 Main Street, Springfield, MA

Dear Mr. Babbs:

As you are aware I represent the City of Springfield in its capacity as the licensing authority
for entertainment licenses. It has come to the Citys attention that you intend to host an event titled
Who is T Swan at 143 Main Street d/b/a Ambrosia Lounge this Friday September 12, 2014 at 9
p.m. This proposed event offers a mixtape release show/celebration with a cover charge despite
the fact that you possess no entertainment license to conduct such an event. A copy of an
advertisement for the subject event is enclosed herewith.

You should be keenly aware of the need for an entertainment license to host this type of
event given that the City previously issued a cease and desist order to you for a similar event
scheduled for June 7, 2014. Additionally you currently have an application for an entertainment
license pending and no decision has been rendered on that application. Your knowing and willful
disregard of the entertainment license requirement, with an application for such a license pending,
is of particular concern. Accordingly the proposed event is a clear violation of M.G.L. c 140, the
regulations promulgated thereunder, and local law.

The Mayor of Springfield, as the entertainment license granting authority for the City of
Springfield, has instructed the Law Department to issue you a Demand to Cease and Desist from
all unlicensed activity. This includes offering entertainment to patrons without a proper
license. As such the event scheduled for September 12, 2014 cannot proceed. Failure to
comply with this letter by continuing with the scheduled event or hosting future events of this
nature shall result in further enforcement action by the City of Springfield.


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Please contact me if you have any questions regarding this matter.


Very truly yours,



Stephen M. Reilly, Jr.




cc: Mayor Domenic J. Sarno
John Barbieri, Police Commissioner
Edward Pikula, City Solicitor
Alesia H. Days, Director of Licensing