Electronically Filed

9/5/2019 3:23 PM
Steven D. Grierson
CLERK OF THE COURT

CASE NO: A-19-801414-B

Department 16

Case Number: A-19-801414-B

EXHIBIT A
 August 27, 2019

VIA HAND DELIVERY AND

US MAIL

Sam Aldabbagh dba Can Can Room

3155 S Sammy Davis Jr Dr.
Las Vegas, NV 89109

RE: 3 DAY NOTICE TO SURRENDER

3149 – 3151 AND 3153 - 3155 S SAMMY DAVIS JR DR. (THE “PREMISES”)

Dear Mr. Aldabbagh:

As you know, The Siegel Group Nevada, Inc. is the manager of Siegel Plaza West LLC,
owner of the property described above (“Landlord”). Please be advised that on August 1, 2019,
we received a letter from the Las Vegas Metropolitan Police Department, Detective Eliott Ludtke
and Lieutenant Nathan Chio, stating two employees at the Can Can Room were arrested for
solicitation of prostitution and you were cited for several violations of Clark County Code. The
citations include responsibility for the acts of employees related to the solicitation charge, serving
alcohol without a license, employees not having the proper work cards or authorizations, and not
keeping the required records for employees. Additionally, there is currently a recommendation to
revoke your business license that will be going before Clark County Business Licensing.

Since that time, we have done our own investigation and obtained additional information
aside from the arrests and citations. Discussed below are the various illegal and criminal activities
at the Can Can Room. It is a violation of the Lease, as well as Nevada law, to operate an unlawful
business at the Premises.

As a result, you are unlawfully possessing the Premises by carrying on an unlawful

business. Specifically, the Can Can Room is used to commit criminal acts such as prostitution.
NRS 40.2514 states:

A tenant of real property or a mobile home for a term less than life is guilty of an
unlawful detainer when the tenant: . . . (3) Sets up or carries on therein or thereon
any unlawful business . . . and remains in possession after service upon the tenant
of 3 days’ notice to surrender.
As such, you have three (3) days to surrender the Premises or you will be in unlawful detainer of
the Premises. Failure to surrender will result in legal action against you to have you removed from
the Premises.

By way of background, shortly after Owner purchased the Property, it began having its
security team monitor the center where the Premises is located. Over time we have learned many
facts about the Can Can operation. This includes:

1. Can Can employs a “Madam.” The Madam screens girls for their interview with
the Owner. Many of the girls are responding to an ad seeking hostesses and servers
when, in reality, the Madam tries to talk them into dancing.
2. Can Can takes dancers’ sheriff’s cards and refuses to return them so dancers cannot
work somewhere else.
3. Females applying for a job at Can Can are required to have sex with the Owner as
part of their “interview” and are told if they have sex with “Sammy” he will buy
them outfits and they will make more money. When meeting with the Owner, the
prospective employee is provided a toothbrush, toothpaste, and douche and told to
“get ready for the interview.”
4. Dancers that are hired are required to have sex with the Owner.
5. Dancers that are hired are required to have sex with patrons.
6. The Madam collects the money for the sex acts. The Owner gets a cut of everything
– which includes the money paid by patrons to have sex at the Can Can.
7. The Owner is well aware of everything that goes on at the Can Can, watching via
camera. This includes the sex acts that go on in the “VIP Rooms.”
8. The VIP Rooms have beds where sex acts occur.
9. The Can Can has hired dancers that are under the age of 18.
10. Underage girls are required to have sex with the Owner as well as patrons at the
Can Can.
11. One of the Madam’s jobs is to obtain liquor from next door and serve patrons inside
the Can Can.
12. The Owner makes the girls sign non-disclosure agreements, so they are not allowed
to talk about what goes on inside the Can Can. The Owner bullies and scares the
dancers into not speaking with others about what goes on.
13. The Can Can robs tourists by getting tourists to agree to have sex with the dancers,
then records them undressed while the girls act surprised they are in the “VIP
Room” for sex.

You as the Owner are running an illegal sex operation in the Can Can Room – an operation
that you run, watch from a camera in your “office,” and from which you profit personally. In
short, you are running an illegal brothel.
 The arrests and citations, along with the information we have obtained, our inspections of
the Premises, and the various “reviews” on social media, verify all of the above. As you are
running an illegal / unlawful business, you are violation of the Lease as well as Nevada law.
Moreover, there is no question that as the Owner of the Can Can Room, you run and are involved
in all aspects of the illegal operation – nothing happens at the Can Can Room without your
knowledge and you watch everything on camera.

As there is no dispute you are running an illegal / unlawful business, you must vacate the
Premises. Pursuant to NRS 40.2514, you have three (3) days to vacate the Premises. Failure
to vacate will result in an unlawful detainer action being filed against you. The Landlord
cannot and will not tolerate this type of illegal activity in the center. Moreover, should you refuse
to vacate as required, we will have no option but to file an unlawful detainer action against you
and seek removal on an expedited basis.

Govern your conduct accordingly.

Sincerely,

Sean D. Thueson, Esq.

Executive Vice President & General Counsel
THE SIEGEL GROUP NEVADA, INC.

cc: Keith E. Galliher, Esq.

THE GALLIHER LAW FIRM
1850 E. Sahara Avenue Suite 107
Las Vegas, Nevada 89104
EXHIBIT B