ALJDEC - Licensing

26A-351852-SLB-LIQ · Liquor Licenses and Control · 2026-05-07

IN THE OFFICE OF ADMINISTRATIVE HEARINGS

In the Matter of the Location Transfer for Liquor Store Liquor License Application No. 351852,

Maria Danielle Burgess, Agent,

Circle K Stores, Inc.

DBA: Circle K Store #9598

5502 E. Grant Street,

Tucson, AZ 85712,

Applicant.

No. 26A-351852-SLB-LIQ

ADMINISTRATIVE LAW JUDGE DECISION

HEARING: April 27, 2026

APPEARANCES: Rachael Carrico, Esq. represented Applicant Circle K Stores, Inc., doing business as Circle K Store #9598. Bradford Borman, Esq. represented the City of Tucson. Protestor Dr. Deron Davenport appeared on his own behalf.

Witnesses: Jordan Ridberg, Troy Beatty, Felix Kadiri, Dr. Adam Pershing, Elaine Hill

ADMINISTRATIVE LAW JUDGE: Sondra J. Vanella

EXHIBITS ADMITTED INTO EVIDENCE: The parties stipulated to the admission of all exhibits

FINDINGS OF FACT

Procedural History

Circle K currently owns and operates over 95 liquor-licensed convenience stores in Tucson, Arizona. As part of an optimization and revitalization plan, Circle K intends to consolidate those 95 stores into approximately 70 to 75 stores to meet current operational and demand needs.

Circle K has operated Store #1632 at 5505 E. Grant Road on the northeast corner of Grant and Craycroft in Tucson for approximately 40 years. Circle K’s current location is on a 1/3 acre parcel with a 2,680 square foot store on the northeast corner of the parcel with a 2-pump fuel canopy at the southwest corner. At its closest point, the fuel canopy is just 18 feet from the roadway on Grant. Vehicle ingress and egress is via westbound traffic on Grant before the intersection, and northbound traffic on Craycroft, just after the intersection. At its current location, traffic often causes a slow-down and back-up of vehicles through the intersection.

In May 2024, Circle K entered into a lease for the 1.7 acre parcel at 5502 E. Grant Road, at the southeast corner of the Grant/Craycroft intersection, with the intention of replacing Store #1632 with a larger, more modern convenience store and fuel station with 6 fuel pumps (“Store #9598”). The parcel of land contains building(s) that have been vacant for years.

On or about May 6, 2025, the City of Tucson approved Circle K’s plans to re-develop the site with a 5,200 square foot store with a 6 fuel-pump canopy.

On or about June 25, 2025, Circle K filed its application with the Arizona Department of Liquor Licenses and Control (“Department”) for the location transfer of its liquor license to the southeast corner of the Grant/Craycroft intersection, approximately 375 feet immediately south of Store #1632. If the Department approved the application, Circle K intended to close Store #1632.

On or about August 19, 2025, the Tucson City Council voted to recommend disapproval of Circle K’s application to transfer its liquor license based on the location’s qualifications, citing Arizona Administrative Code (“A.A.C.”) Rule R19-1-702(A) subsections 1, 2, 6, 7, 9, and 12. The Department did not protest the application.

On or about November 6, 2025, the Arizona State Liquor Board (“Board”) voted by a vote of 3 to 2 to grant the Location Transfer. The vote did not meet the supermajority requirement of A.R.S. § 4-201(J) of a two-thirds vote.

On or about December 26, 2025, Circle K filed a Motion for Rehearing, which the Board considered on February 5, 2026. After oral arguments and review of motions, the Board granted Circle K’s Motion for Rehearing.

On or about March 5, 2026, the Board voted to refer the rehearing for Location Transfer to the Office of Administrative Hearings.

On April 17, 2026, at 9:00 a.m., the hearing of this matter convened and concluded within the allotted three-hour timeframe. The parties stipulated to the admission of all exhibits.

Circle K contended that it meets all criteria for a Location Transfer. Circle K called Jordan Ridberg and Troy Beatty as witnesses.

The City of Tucson opposed the location transfer and called Felix Kadiri and Dr. Adam Pershing as witnesses.

Protester Dr. Deron Davenport opposed the location transfer and testified on his own behalf and called Elaine Hill as a witness.

Hearing Evidence

A.A.C. R 19-1-702 cites 12 criteria to consider when evaluating a location’s qualifications as follows:

To determine whether public convenience requires and the best interest of the community will be substantially served by issuing or transferring a license at a particular unlicensed location, local governing authorities and the Board may consider the following criteria:

1. Petitions and testimony from individuals who favor or oppose issuance of a license and who reside in, own, or lease property within one mile of the proposed premises;

2. Number and types of licenses within one mile of the proposed premises;

3. Evidence that all necessary licenses and permits for which the applicant is eligible at the time of application have been obtained from the state and all other governing bodies;

4. Residential and commercial population of the community and its likelihood of increasing, decreasing, or remaining static;

5. Residential and commercial population density within one mile of the proposed premises;

6. Evidence concerning the nature of the proposed business, its potential market, and its likely customers;

7. Effect on vehicular traffic within one mile of the proposed premises;

8. Compatibility of the proposed business with other activity within one mile of the proposed premises;

9. Effect or impact on the activities of businesses or the residential neighborhood that might be affected by granting a license at the proposed premises;

10. History for the past five years of liquor violations and reported criminal activity at the proposed premises provided that the applicant received a detailed report of the violations and criminal activity at least 20 days before the hearing by the Board;

11. Comparison of the hours of operation at the proposed premises to the hours of operation of existing businesses within one mile of the proposed premises; and

12. Proximity of the proposed premises to licensed childcare facilities as defined by A.R.S. § 36-881.

A.A.C. R19-1-702(A)(1)

Petitions and testimony from individuals who favor or oppose

issuance of a license and who reside in, own, or lease property within one

mile of the proposed premises.

Troy Beatty, Director of Operations for Circle K for Southern Arizona, and a native to Tucson, testified that he had been employed with Circle K for 30 years and oversaw 121 stores and approximately 1,200 employees. Mr. Beatty also lived and owned property within one mile of the current and proposed locations.

Mr. Beatty testified regarding two petitions in support of the new location. The first petition from 2025 garnered 62 signatures of patrons who were in support of the new location and resided, owned, or leased property within one mile of the proposed location. There were many more signatures obtained in support of the proposed location, however, those signatures did not qualify for the required geographic area.

A second petition from 2026 garnered many signatures as well, however, that petition did not specify how many signatures were obtained from those who resided, owned, or leased property within one mile of the proposed location.

Sole Protestor, Dr. Deron Davenport, a dentist who owned an office south of and within one mile of the proposed location, protested the transfer of the liquor license. Dr. Davenport strongly opposed the transfer of the liquor license for several reasons including increased traffic concerns, loitering, trespassing, property damage, and increased trash, which all admittedly existed at the current location, however, Dr. Davenport believed that a larger site would magnify the issues.

Dr. Davenport testified that a larger site would increase traffic, as well as alcohol sales. Dr. Davenport expressed his concern with the proximity of the proposed location to health care offices and a preschool.

Dr. Davenport testified regarding the number of police calls for service in the area within a quarter-mile radius of his office over the past two and half years. However, Dr. Davenport failed to link any of those calls for service to Circle K or any other source for that matter. The area of the current Circle K is densely commercially populated, and those calls for service could have been related to any number of those businesses and many of those retail stores also sell liquor.

While the photographs submitted by Dr. Davenport were disturbing and concerning, none of what was depicted in those photographs could be definitively linked to the current Circle K as the area in question is a heavy commercial corridor that has a large retail presence of big box stores, as well as Tucson Medical Center. Dr. Davenport’s concerns are speculative at this point.

Dr. Davenport called Elaine Hill, President of the Old Fort Lowell Neighborhood Association, Inc. (“Fort Lowell”), as a witness. Ms. Hill testified that 325 homes within Fort Lowell are located within a one-mile radius of the proposed location. Ms. Hill asserted that traffic was already a problem, and the area was not only a commercial hub, but also a medical hub as Tucson Medical Center was re-developing and additional medical complexes were moving to the area. Ms. Hill expressed safety concerns for residents and neighbors as ambulances were “constantly” going through the intersection. Ms. Hill testified that the proposed location for the new Circle K was also a half mile from a public park and the homeless population and litter was already a problem. Ms. Hill acknowledged that this was an existing problem and moreover, she acknowledged that this was an issue “all over town.”

Dr. Adam Pershing, a dentist and the President of a six-unit medical condominium association where his and Dr. Davenport’s offices were located, testified primarily regarding his concern for increased traffic. Dr. Pershing testified that it was a busy area and he was “not sure” of the traffic study previously conducted, therefore, he contacted Curtis C. Lueck, Ph.D., P.E. (Retired) to obtain his opinion regarding the proposed location. Mr. Lueck opined that the intersection “would be safer” without a Circle K because “this intersection accommodates all modes and there are literally over a hundred conflict points between these modes proximate to the site. The addition of a C-store exacerbates the potential conflict points and accident potential by adding dangerous left, right, and U-turns that are particularly dangerous for non-motorized traffic.” Mr. Lueck’s email also that stated, “C-stores at intersections diminish intersection capacity by adding what traffic engineers call ‘side friction.’” Mr. Lueck did not testify at hearing, nor did Mr. Lueck conduct a traffic study of the area.

In contrast, Circle K commissioned a traffic study from an independent third-party engineering firm, Southwest Traffic Engineering, LLC. The detailed Traffic Impact Analysis dated February 4, 2025, was 112 pages and authored by Andrew Smigielski, PE, PTOE, PTP and Matthew Reeg, PE, PTOE, both Professional Engineers and Professional Traffic Operations Engineers. Mr. Smigielski also has a designation as a Professional Transportation Planner. Jordan Ridberg, a Real Estate Development Manager for Circle K, testified regarding the traffic analysis. Mr. Ridberg testified that a variety of methodologies were utilized in the analysis and that the engineers were physically present at the location to perform calculations. Mr. Ridberg testified that the traffic analysis revealed no impact, but recommended new signage and striping. This traffic analysis was submitted to the City of Tucson and was approved.

Mr. Ridberg testified that the “backup offers” on the site were a Chick-fil-a, an In-and-Out, and a Dutch Bros., all of which would be “traffic generators” because they are a “destination,” rather than a stop on a customer’s way to a destination. Therefore, if a fast food restaurant were to open at the proposed location, traffic would definitively increase. In contrast, a Circle K at that location would not generate additional traffic, but rather would capture existing traffic as Circle K captures customers who are on their way to somewhere else, and are not going out of their way to stop at Circle K.

Mr. Felix Kadiri, owner and director of Kids Palace Preschool, testified that he had operated the preschool at the current location since 2009, and has had no “major” issues. Mr. Kadiri testified that the proposed location for Circle K was approximately 50 feet from the preschool and 20 feet from the playground. Mr. Kadiri expressed concern that if the proposed location transfer were granted, the children attending the preschool will be exposed to alcohol, trash, and loitering. Mr. Kadiri further expressed that the proposed location would attract more homelessness and increased drinking and driving. Mr. Kadiri testified that the parents trusted him to care for their children and Mr. Kadiri feared their safety would be compromised on the preschool’s open playground. Mr. Kadiri testified that by law, he must allow the children access to the outside for at least one hour per day.

However, Mr. Kadiri acknowledged the presence of homeless individuals currently at the vacant property. Mr. Kadiri also testified that the door to his preschool remained unlocked from 6:00 a.m. until 6:00 p.m. on a daily basis.

In early September 2025, Mr. Ridberg personally met with Mr. Kadiri at the preschool and listened to his concerns. Mr. Ridberg followed up with an email to Mr. Kadiri dated September 5, 2025, that reiterated portions of what they had discussed at that meeting, in pertinent part as follows:

We discussed your low, see-through wrought-iron fence which secures your playground. Circle K would like to donate the design, permitting, and construction of a 6’ block wall to enclose your playground. In addition, Circle K would like to donate a new play-structure and picnic tables for your playground area.

• We discussed the 30+ cameras that we would install at our new store and believe that having security cameras on your property would benefit us both by covering more area with cameras - providing the ability to use those cameras both to deter crime and to provide footage to law enforcement in the event of any criminal activity. Circle K would like to donate a surveillance camera system and installation for your property.

• We discussed that it would bring peace of mind to your employees and families if your front door had magnetic locking hardware so that your facility could remain locked at all times, with the ability to restrict access to only those that you “key or buzz in”. Circle K would like to donate such an access control system and the installation of such.

Mr. Kadiri asserted that the offers made by Circle K were made in an effort to “bribe” him and that he did not “ask for help.”

In total, only four individuals had expressed concern over the transfer of Circle K’s existing liquor license to a location 375 feet away.

A.A.C. R19-1-702(A)(2)

Number and types of licenses within one mile of the proposed premises

Circle K’s application is a transfer of its existing license to a location approximately 375 feet south of its current location. If the Department approved the application, existing Store #1632 would close. Transferring the license to a location across the street from its current location would not change the number of licenses within one mile of the proposed premises. The number of licenses would remain the same.

A.A.C. R19-1-702(A)(3)

Evidence that all necessary licenses and permits for which the applicant is eligible at the time of application have been obtained from the state and all other governing bodies.

It was undisputed at hearing that the City of Tucson reviewed and approved Circle K’s development package to build a 5,200 square foot building with 6 fuel pumps and canopy at the proposed location. It was further undisputed at hearing that structural, mechanical, plumbing, and electrical plans, supported by research and analysis of site and zoning plans, civil and geotechnical engineering reports, land surveys, and building and landscape plans, were all considered and approved.

A.A.C. R19-1-702(A)(4)

Residential and commercial population of the community and its likelihood of increasing, decreasing, or remaining static.

It was undisputed at hearing that residential and commercial populations continued to increase throughout Tucson.

A.A.C. R19-1-702(A)(5)

Residential and commercial population density within one mile of the proposed premises.

It was undisputed at hearing that residential and commercial population density within one mile of the proposed Circle K location would increase. Tucson Medical Center alone employed approximately 4,000 individuals and provided medical services to members of the community, and additional medical centers would be added to the area in the future.

A.A.C. R19-1-702(A)(6)

Evidence concerning the nature of the proposed business, its potential market, and its likely customers.

The evidence established that Circle K sold general merchandise items, including fresh, refrigerated, frozen, and packaged foods and beverages, hot prepared foods and fountain drinks, snacks, alcohol and tobacco products, household goods, baby supplies, personal care items, and fuel. The evidence established that many of Circle K’s customers lived and/or worked in the immediate area and many stopped for fuel and convenience/general merchandise items on their way to, from, and during work, or while visiting Tucson Medical Center, a 24-hour hospital and emergency room that is part of a 60-acre medical campus on the northwest corner of the Grant/Craycroft intersection that had over 37,000 discharges in 2024. Thousands of employees, medical staff, patients, and visitors frequent the current Circle K location at all hours of the day and night, with the current location conducting an average of 500 in-store transactions per day. Mr. Ridberg testified that the current Circle K had outgrown its space to adequately meet its customers’ needs. Both Mr. Ridberg and Mr. Beatty testified that the proposed new location would provide customers an enhanced shopping experience with easier access to a “beautiful” store that would “enhance” the neighborhood.

Mr. Ridberg testified at length regarding the enhanced security features of the proposed new Circle K store. Specifically, Mr. Ridberg testified that there would be 11 exterior cameras and 18 interior cameras that the police would have access to as necessary. The exterior cameras would have a range that covered areas of the preschool and the nearby medical offices, enhancing safety. Mr. Ridberg referenced the rendering of the new Circle K store during his testimony. Mr. Ridberg testified that the proposed site was designed to be CPTED-compliant (Crime Prevention Through Environmental Design), featuring LED lighting, clear sightlines, enhanced security cameras, and increased staffing levels.

Mr. Beatty testified regarding the capabilities of the interior and exterior camera systems, including the tracing of alcohol sales, camera interaction with the point-of-sale system to identify purchased items, the scanning of IDs, the ability to zoom in on individuals and specific products, and the ability to capture detailed, clear images, which extends to the preschool and medical offices.

A.A.C. R19-1-702(A)(7)

Effect on vehicular traffic within one mile of the proposed premises.

While this was one of the more contested issues at hearing, the undisputed evidence established that the City of Tucson approved Circle K’s new site and building plans, that included the traffic analysis. The owner of the property east of Circle K’s site and the owner of the property of which the preschool was a tenant, both approved a cross-easement for use of the driveway between the properties. The detailed traffic analysis performed by an independent third-party engineering firm, authored by Professional Engineers and Professional Traffic Operations Engineers and a Professional Transportation Planner, revealed no impact on traffic and solely recommended new signage and striping. This traffic analysis was submitted to the City of Tucson and was approved.

While Drs. Davenport and Pershing, as well as Ms. Hill, contended there would be a negative impact on traffic, none provided probative evidence establishing such. The email authored by Mr. Lueck was given little weight versus the traffic analysis, in light of the fact that Mr. Lueck did not perform a traffic study using actual site calculations.

A.A.C. R19-1-702(A)(8)

Compatibility of the proposed business with other activity within one mile of the proposed premises.

Circle K has operated at the current site for more than 40 years. The proposed site is 375 feet to the south and would be larger, with more modern and enhanced safety features, and would offer a wider variety of products to consumers. Dr. Davenport offered aerial maps and site plans showing the proposed Circle K location at Grant and Craycroft, including proximity to medical, dental, preschool, and professional offices. Those maps and site plans illustrated that the location was a heavy commercial corridor with businesses including Ross, BevMo, Costco, Trader Joe’s, Dick’s Sporting Goods, etc., within one mile of the proposed premises. Some of these businesses also sold liquor.

A.A.C. R19-1-702(A)(9)

Effect or impact on the activities of businesses or the residential neighborhood that might be affected by granting a license at the proposed premises.

Circle K proposed to construct approximately 375 feet away from its current location, a more modern, accessible store with advanced technology to replace the existing location. Circle K’s security plans included the installation of 29 high-definition security cameras inside and outside the premises to monitor activity in and around the building, and the Tucson Police Department would have real-time access to the camera feeds. The evidence established that the proposed new location would be staffed 24 hours per day and staff and/or security would regularly walk the parking lot and rear of the building and would direct customers to leave the area and call the police or roving security when necessary.

There was no evidence presented supporting the claims that the purchase of liquor at the proposed location by Circle K’s customers would have a negative effect on the community. Liquor was readily available within proximity of the proposed location. Moreover, Circle K was requesting the transfer of a Series 9 Liquor License which allows for the sale of liquor for off-site consumption only, and Circle K is not a liquor store. Mr. Beatty testified that the sale of liquor was incidental to the sale of other goods.

The expressed concerns regarding homelessness was not singular to Circle K’s proposed location. Admittedly, it is a broader problem throughout Tucson. The enhanced security measures that would be implemented at the proposed location would enable Circle K to more readily control the environment within and around the premises. Therefore, by relocating to a larger, more secure, and better-lit facility equipped with modern surveillance, the business would actually enhance neighborhood safety and reduce opportunities for loitering or nuisance behavior.

A.A.C. R19-1-702(A)(10)

History for the past five years of liquor violations and reported criminal activity at the proposed premises provided that the applicant received a detailed report of the violations and criminal activity at least 20 days before the hearing by the Board.

Mr. Beatty credibly testified that Circle K had not been cited for a liquor violation at its current location or in the entire City of Tucson in the past five years. Reports of criminal activity at the proposed location were not provided or addressed at hearing. The evidence established that the proposed location had a vacant building(s) that attracted homeless and transient individuals, and that the proposed store would replace the vacancy with a safe, well-lit facility for customers to shop and re-fuel.

A.A.C. R19-1-702(A)(11)

Comparison of the hours of operation at the proposed premises to the hours of operation of existing businesses within one mile of the proposed premises.

Circle K’s hours of operation are 24 hours per day, 7 days per week, as is Tucson Medical Center’s hours of operation, as well as first responders, and individuals who work various shifts within that shared commercial corridor.

A.A.C. R19-1-702(A)(12)

Proximity of the proposed premises to licensed childcare facilities

as defined by A.R.S. § 36-881.

There was no dispute at hearing that Kids Palace Preschool was within 50 to 100 feet of the proposed location. However, the credible evidence presented established that Circle K had committed to ensuring that Kids Palace Preschool was not negatively impacted, and in fact, would benefit from the improvements proposed by Circle K. It was notable that Mr. Kadiri is concerned with the safety of the children entrusted to his care, yet the door to his preschool remained unlocked for 12 hours per day allowing access to anyone to enter the premises. Circle K had offered to: i) replace the low, see-through wrought-iron fence which currently surrounds the playground with a six foot block wall to enclose the playground; ii) donate a new play-structure and picnic tables for the playground area; iii) donate a surveillance camera system and installation for the preschool; and iv) donate an access control system and the installation of such at the front door of the preschool with magnetic locking hardware so that the facility could remain locked at all times, with the ability to restrict access.

Mr. Kadiri did not file a protest, did not attend the City Council or Board meetings, and the property owner of the preschool approved a cross-easement for use of the commercial driveway between the preschool and the proposed Circle K location. Any liquor purchased at Circle K would be sold for carry-out in a closed package and could not be consumed at the licensed premises. There was no evidence presented establishing that the sight of an adult who purchased packaged alcohol in a closed container was a danger to children or would negatively impact children.

CONCLUSIONS OF LAW

The Department was established to administer certain laws of the State of Arizona by protecting the public interest through the regulation of the spirituous liquor industry.

The Director of the Department has the authority to transfer a liquor license pursuant to A.R.S. § 4-203(C), A.R.S. § 4-201(I), and A.A.C. R19-1-702(A).

Pursuant to A.R.S. § 4-201(I), “[t]he board shall adopt, by rule, guidelines that state criteria for use in determining whether the public convenience requires and the best interest of the community will be substantially served by the issuance or transfer of a liquor license at the location applied for. These guidelines shall govern the recommendations and other approvals of the department and the local governing authority.”

Pursuant to A.R.S. § 41-1092.07(G)(1) and A.A.C. R2-19-119(B)(1), Circle K has the burden to establish by a preponderance of the evidence that the Board should grant the transfer of its liquor license.

“A preponderance of the evidence is such proof as convinces the trier of fact that the contention is more probably true than not.” A preponderance of the evidence is “[t]he greater weight of the evidence, not necessarily established by the greater number of witnesses testifying to a fact but by evidence that has the most convincing force; superior evidentiary weight that, though not sufficient to free the mind wholly from all reasonable doubt, is still sufficient to incline a fair and impartial mind to one side of the issue rather than the other.”

A.A.C. R19-1-702(A) sets forth the standards for determining whether to grant a license for a certain location and those standards are set forth above. Pursuant to A.A.C. R19-1-702(A), “[t]o determine whether public convenience requires and the best interest of the community will be substantially served by issuing or transferring a license at a particular unlicensed location, local governing authorities and the Board may consider” the 12 criteria.

The cited rule does not specify that all criteria must be considered, and the use of the word, “may” within the rule is permissive, not mandatory.

The credible and probative evidence of record established that public convenience requires, and the best interest of the community would be substantially served by transferring this license. Circle K performed its due diligence in hiring an independent, third-party engineering firm to conduct a traffic analysis. The two individuals within the firm who conducted the analysis were both Professional Engineers and Professional Traffic Operations Engineers, and one of them also had a designation as a Professional Transportation Planner. The traffic analysis was detailed and contained specific calculations generated from the engineers’ onsite observations. The credible testimony of Mr. Ridberg established that the opening of a Circle K at the proposed new location would not have a negative impact on traffic in the area. The traffic analysis was also approved by the City of Tucson.

Drs. Davenport and Pershing’s concerns with vandalism, trash, and homelessness, while valid, could not be attributed to the existing Circle K versus any other commercial business in the area and their speculation that the operation of a Circle K at the new location would exacerbate existing conditions, was just that, pure speculation.

The vast majority of Mr. Kadiri’s concerns could be alleviated by Circle K’s offers of numerous safety improvements to the preschool, most notably the replacement of the playground fence and the installation of an access control system at the front door so the facility could remain locked at all times, providing the ability to restrict access.

The Administrative Law Judge concludes, based on the credible and probative evidence of record, that Circle K has demonstrated under the criteria set forth in A.A.C. R19-1-702(A), that the public convenience requires, and the best interest of the community would be substantially served, by transferring Circle K’s existing Series 9 liquor license, which solely allows for the sale of liquor for off-site consumption, to the proposed location for the new Circle K.

Therefore, the requested transfer of the liquor license should be granted to Circle K.

RECOMMENDED ORDER

Based on the foregoing, it is recommended that the Board grant the requested transfer of Circle K’s liquor license.

Pursuant to A.R.S. § 41-1092.08(I), the licensee may accept the Administrative Law Judge Decision by advising the Office of Administrative Hearings in writing not more than ten (10) days after receiving the decision. If the licensee accepts the Administrative Law Judge Decision, the decision shall be certified as the final decision by the Office of Administrative Hearings.

In the event of certification of the Administrative Law Judge Decision by the Director of the Office of Administrative Hearings, the effective date of the Order will be forty (40) days from the date of that certification.

Done this day, May 7, 2026.

/s/ Sondra J. Vanella

Administrative Law Judge

Transmitted by either mail, e-mail, or facsimile to:

Ben Henry

Liquor Licenses and Control

Deron Davenport

[email redacted]

Bradford Borman

City of Tucson

[email redacted]

Rachael Carrico

Lewkowitz Law Office, PLC

[email redacted]

By: OAH Staff