SUGARHOUSE HSP GAMING, L.P. COWONWEALTH OF dba RIVERS CASINO PHILADELPHIA GAMNG IDENTIFICATION NO, 1356 GAMING CONTROL BOARD IN RE: Underage Access Gaming Referral(s) 2 CONSENT AGREEMENT AND STIPULATION OF SETTLENIENT THIS CONSENT AGREEMENT AND STIPULATION 0F SETTLEMENT is made and entered into by and between the Office of Enforcement Counsel and SugarHouse HSP Gaming, L.P. d/b/a Rivers Casino Philadelphia (?Rivers Philadelphia?). Rivers Philadelphia and OEC collectively are referred to as the ?Parties?; and WHEREAS, Rivers Philadelphia is a limited partnership organized and existing under the laws of Delaware and at all times referenced herein, has its business of?ce located at 1001 North Delaware Avenue, Philadelphia, PA, 19125 . Rivers Philadelphia is a Category 2 slot machine facility licensee; and WHEREAS, OEC is the prosecutorial body established by 4 ?1517(a.2) and has the power and duty to initiate proceedings for administrative violations of the Race Horse Development and Gaming Act pursuant to ?1517(a.2) (1) of the Act; and WHEREAS, Rivers Philadelphia and OEC, through their authorized representatives whose signatures are af?xed hereto, have investigated the are the subject of this Consent Agreement (?Events?), have conferred extensively on the Events, and now desire to conclusively and amicably resolve all matters arising out of the Events, and enter into a Consent Agreement before the ?ling of a Complaint, pursuant to 58 Pa. Code which provides that ?[p]arties may propose consent agreements at any time prior to the entry of a ?nal order?; and WHEREAS, pursuant to Condition 1 of the Statement of Conditions to its Category 2 Slot Operator Facility License; most recently signed on June 10, 2016, RJVers Philadelphia agreed at all times comply with any and all provisions of the Race Home Development and Gaming Act and any rules, regulations, technical standards or orders in effect as of this date or later amended or promulgated by the Board?; and WHEREAS, pursuant to 58 Pa. Code an individual under 21 years of age, whether personally or through an agent, may not-operate, use, play or place a wager on, a slot machine in a licensed facility, and pursuant to 58 Pa. Code a person holding a license, permit, registration or certi?cation issued by the Board is prohibited from permitting or enabling an' individual to engage in conduct that violates 58 Pa. Code and pursuant to 58 Pa. Code ?Sl3a.5, it shall be no defense that the person believed an individual to be 21 years of age or older; and WHEREAS, pursuant to 4 Pa. C.S. 1518 a (13) (as amended), it shall be unlawful for an individual under 21 years of age to enter and remain in any area of a licensed facility where slot machines are operated, and pursuant to 4Pa. C.S. 1518 a (13.1) (as amended), it shall be unlawful for an individual under 21 years of age to wager, play or attempt to play a slot machine or table game at a licensed facility; and WHEREAS, Rivers Philadelphia submitted, and the Gaming Control Board (the ?Board?) approved, internal controls pursuant to 58 Pa. Code ?465a.2, which includes a Compulsive and Problem Gambling Plan which states that Rivers Philadelphia will comply with the underage gambling provisions speci?ed at 58 Pa Code ?513a.2; and WHEREAS, the Parties do not dispute the jurisdiction of the Board; and WHEREAS, the Parties now seek to enter into this ConSent Agreement as an accord, satisfaction and compromise of any disputed claims and in consideration of the Parties waiving, releasing, and forbearing any regulatory dispute; and WHEREAS, the DEC has previously entered into four Consent Agreements with Rivers Philadelphia regarding underage gambling (Docket Numbers 2701-2012, 3730- 2014, 5050-2016 and 5485-2017}. NOW, THEREFORE, the Parties stipulate and agree, and present to the Board for its consideration, the following: STIPULATED FACTS On April 6, 2018, the Bureau of Casino Compliance referred an underage gaming violation to OEC. BCC reported that at 12:44 am. on February 11, 2018, security of?cers stopped an underage woman after she presented a fraudulent driver?s license as identi?cation at the North Entrance to the casino. The underage woman was taken into custody by security and reported her presence to the State Police who determined not to charge her because she did not gain entry into the casino. Rivers Philadelphia security personnel issued the underage subject a formal eviction notice. The BCC conducted a compliance review of the matter on February 1 l, 2018. The surveillance review revealed that the underage patron, identi?ed as Alexia Stipa, age 20 years old, was able to gain entrance into Rivers Casino Philadelphia on at least four previous days utilizing the fraudulent driver?s license that security of?cers either missed or ignored. While in Rivers Casino Philadelphia on these previous four days, Ms. Stipa was able to game at various Blackjack games and slot machines and consume alcoholic beverages. Surveillance coverage showed that on February 5, 2013, Ms. Stipa arrived at the North Entrance of Rivers Casino Philadelphia at 9:30 pm. She presented her fraudulent identi?cation to a security of?cer who scanned the identi?cation and the surveillance coverage showed it was ?agged with a ?Red rl'he security of?cer requested a supervisor and a security'class 2 of?cer responded and he rescanned and reviewed the identi?cation. The surveillance coverage showed it was?again ?agged with a ?Red However, the security class 2 of?cer did not stop Ms. Stipa but, instead allowed her to proceed to the casino ?oor. Ms. Stipa gamed at the blackjack game on table BJ 607 from 9:38 pm. to 9:58 pm. when she cashed out at the cage. She was served one alcoholic beverage at 9:48 p.111. Ms. Stipa briefly played two slot machines (EN 2406 and EN 2405) before returning to the blackjack game on table BJ 607 at 10:07 pm. and continued to game until moving to the blackjack game on table B1 702 at 10:12 pm. where she gamed untii cashing out again at the cage, window 3 at 10:54 pm. While gaming at the blackjack game on table B1 702, Ms. Stipa was served a second alcoholic beverage at 10:35 pm. After cashing out, Ms. Stipa brie?y played a slot machine (LN 2003) before exiting the casino at 11:02 pm. Surveillance coverage showed that on February 6, 2018, Ms. Stipa arrived at the North Entrance of Rivers Casino Philadelphia at 10:44 p.111. She was not stopped by a security of?cer. Instead, she walked past the security of?cer and entered the casino. Ms. Stipa proceeded to the Rush Rewards desk and obtained a Rush Rewards Card. Utilizing the Rush Rewards Card, Ms. Stipa gamed at the blackjack game on table B1 702 ??om 10:57pm. to 11:42 pm. when she cashed out at the cage. She was served one alcoholic beverage at 11:32 pm. Ms. Stipa brie?y played two slot machines (BN 2406 and LN 2003) before exiting the casino at 11:53 pm. Surveillance coverage showed that on February 2018, Ms. Stipa arrived at the North Entrance of Rivers Casino Philadelphia at 10:12 pm. She presented her fraudulent identi?cation to security of?cers who scanned the identi?cation. The surveillance coverage showed it was ?agged with a-?Red The security of?cers did not stop Ms. Stipa but, instead allowed her to proceed to the casino ?oor. Ms. Stipa gamed at the blackjack game on table 901 from 10:18 p.111. to 10:30 pm. At 11:05 pm. Ms. Stipa took a seat at the blackjack game on table 3] 702 where she utilized her Rush Rewards Card and gamed until 11:49 pm. when she cashed out at the cage. She was served one alcoholic beverage at 11:17 pm. Ms. Stipa brie?y played a slot machine (LN 2003) before exiting the casino at 11:54 pm. Surveillance coverage showed that on February 10, 2018, Ms. Stipa arrived at the North Entrance of Rivers Casino Philadelphia at 12:59 am. She presented her fraudulent identi?cation to a security of?cer who scanned the identi?cation. The surveillance coverage showed it was ?agged with a ?Red The security of?cer did not stop Ms. Stipa but instead allowed her to proceed to the casino ?oor. At 1:03 Ms. Stipa took a seat at the blackjack game on table 131 703 where she utilized her Rush Revvards card and gamed until 1:36 am. when she cashed out at the cage. She was served one alcoholic beverage at 1:08 am. At 1:39 am, Ms. Stipa took a seat at the blackjack game on table BI 904 where she utilized her Rush Rewards Card and gamed until 1:43 am. when she moved to the blackjack game on table El 908 where she gamed until 1:47 am. when she cashed out at the cage. Ms. Stipa brie?y played two slot machines (KN 2004 and LN 2003) before exiting the casino at 1:56 am. compliance review determined that Ms. Stipa was in Rivers Casino Philadelphia on at least four separate days for a total of at least ?ve (5) hours and tWenty (20) minutes, during which she was able to game on various blackjack games and slot machines. She also consumed alcoholic beverages. As a result of these incidents, the security of?cers involved were issued disciplinary actions. The security class 2 of?cer" involved in the incident on February 5, 2018 was terminated. The security of?cer involved in the incident on February 6, 2018 was issued a Written Warning Level 1. One security of?cer involved in the incident on February 7, 2018 was issued a Written Wanting Level 2. The other security of?cer involved in the incident on February 7, 2018 was terminated. The security o?icer involved in the incident on February 10, 2018 was issued a Final Written Warning. As a result of the aforementioned circumstances, a subject under 21 years of age gained entry to the gaming ?oor at Rivers Philadelphia on at least four separate occasions and gambled on blackjack games and slot machines in ,violation of 4 SHE-059110248 On October 15, 2018, the BCC referred an underage gaming violation to CEO. BCC reported that at 1:49 pm. that on September 28, 2018, security of?cers caught a patron who had stolen a voucher from another patron and tried to ?ee the casino alter cashing it. A subsequent investigation of the patron by the State Police determined the patron to be 20 years of age. The BCC conducted a compliance review of the matter. The surveillance review revealed that at 9:43 pm. on September 28, 2018, the underage patron, later identi?ed as Robert Slade, entered Rivers Philadelphia through the North Entrance. Surveillance coverage showed that the security o?icer stationed at the entrance did not request identi?cation from Mr. Slade. Mr. Slade took a seat at slot machine JN 3504 at 9:49 pm. and began playing it until 10:16 pm. when he left the slot machine and began walking about the casino. Mr. Slade" returned to slot machine JN 3504 at 110:21 pm. and began playing it until 10:44 pm. when he left that slot machine and began walking about the casino again. At 10:47 pm, Mr. Slade was walking past a patron playing slot machine EN 2502 when he stole a voucher valued at $69.50 ??om the hands of the other patron. As Mr. Slade ?ed the casino, he stopped at ticket redemption machine 15 and cashed out the stolen voucher. At 10:49 pm, Mr. Slade was pointed out to security o?icers by the victim and taken into custody. An investigation by the State Police resulted in Mr. Sladel being arrested and charged with Robbery and related charges, including Unlawful to Permit Person Under 21, 4 1518(2)) (13), for which he was convicted on March 19, 2019. Mr. Slade was issued a formal eviction notice by SugarHouse. The compliance review determined that Mr. Slade was in Rivers Philadelphia for approximately one hour and six minutes and gambled on a slot machine. Mr. Slade was not served any alcoholic drinks. As aresult of this incident, the security of?cer stationed at the North Entrance was issued a Final Written Warning. As a result of the aforementioned circumstances, a subject under 21 years of age gained entry to the gaming floor at Rivers Philadelphia and played on a slot machine in violation of4 On March 13, 2019, the BCC referred an underage gaming Violation to CEO. BCC reported that at 2:40 pm. on February 21, 2019, security of?cers were summoned to the craps game at table CR 505 for a suspected underage patron. A Table Games Supervisor asked the patron for identi?cation and he presented a driver?s license that belonged to someone else. The patron, identi?ed as Naizier Om Grif?n-Holt, was determined by security of?cers to have presented a false identi?cation and took him into custody. A subsequent investigation of the patron by the State Police con?rmed the patron to be twenty years old. This name is an alias. The other charges ?led against Mr. Slade were dismissed as part of a plea agreement in Philadelphia Municipal Court. The BCC conducted a compliance review into the matter. The surveillance review revealed that at 6:34 am. on February 21, 2019, the underage patron, Mr. Grif?n-Holt, entered Rivers Philadelphia through the North Entrance. Surveillance coverage showed that security of?cers stationed at the entrance were engaged in conversation, observed Mr. Grif?n-Holt entering the casino, but did not request identi?cation from him. Mr. Grif?n- Holt went to the Craps game on table CR 505 and bought in at 6:38 am. The surveillance coverage showed Mr. Griffin-Holt remained on the craps game playing craps for nearly eight hours and did not stop until confronted by the Table Games Supervisor and security of?cers at 2:16 p.m. The State Police issued Mr. Grif?n?Holt a citation for Unlawful to Permit Person Under 21, 4 1518(a) Rivers Philadelphia security of?cers con?scated $130 from Mr. Grif?n-Holt and issued him a formal eviction notice. The compliance review determined that Mr. Grif?n-Holt was on the Rivers Casino Philadelphia ?oor for approximately seven hours and 38 minutes and gamed on a craps game. The surveillance review did not reveal any alcohol consumption by Mr. Grif?n?Holt. As a result of this incident, the security officers involved in the matter were issued inal Written Warnings. I As a result of the aforementioned circumstances, a subject under 21 years of age gained entry to the gaming ?oor at Rivers Philadelphia and played on a Craps game in violation of4 sterner. Since its last renewal, Rivers Philadelphia has entered into two (2) consent agreements related to underage gaming for a total of $110,000.00 in civil penalties. Additionally, since its last renewal, OEC has conducted three (3) compliance conferences with Rivers Philadelphia related to underage gaming and issued eight (8) warning letters to Rivers Philadelphia on this subject. TERMS OF AGREEMENT In consideration of the foregoing stipulated facts, and in full and ?nal settlement of any and all claims, or causes of action which could or might be brought under the Act or the regulations promulgated thereunder, whether against Rivers Philadelphia, or any of its owners, employees or agents, arising out of the matters identi?ed in the above stipulated facts, the Parties do hereby further stipulate and agree that: 1. This Consent Agreement shall become ?nal and effective only upon its approval by the Board; 2. This Consent Agreement is offered and, if approved by the Board, entered for settlement purposes only. If the Board determines not to approve the effectiveness of same, then this Consent Agreement and the representations and Obligations contained herein shall be null and void, and neither Party nor any other person shall be entitled to use or rely on any portion hereof for any purpose whatsoever or to admit any portion hereof into evidence in the captioned matter or any subsequent proceeding; 3. Rivers Philadelphia shall reinforce policies and provide training and guidance to its employees, which will minimize the potential for underage persons gaining entrance to the gaming floor; 4. The Parties acknowledge that in response to the above incident, Rivers Philadelphia has effected the following disciplinary and remedial actions: A. Rivers Philadelphia has terminated and issued Written Warnings to the security employees involved in these incidents. Any additional in?ections by security employees may be cause for ftuther disciplinary actions. B. Rivers Philadelphia will continue to regularly train its security personnel in underage identi?cation. 5. Rivers Philadelphia shall pay a ?ne of sixty thousand dollars ($60,000) to the Board within ?ve days of the approval of this Consent Agreement; 6. Within ?ve days of the Board?s Order approving this Consent Agreement, Rivers Philadelphia shall pay the Board two thousand ?ve hundred dollars ($2,500,00) for the costs incurred by DEC, the ECG, and other related staff in connection with this matter; 7. If approved, the Board may make information public with respect to the terms and conditions of this Consent Agreement; 8. This Consent Agreement may be set aside by the Board if any term herein is violated by Rivers Philadelphia; 9. Rivers Philadelphia, through its authorized representative whose signature appears below, has read and fully understands the terms of this Consent Agreement, and 10. This Consent Agreement shall not preciude the Board? ECG or CEO from reviewing and considering any facts in any future proceeding relating to any application for licensure or quali?cation of the licensee. Rivers Philadelphia eXpressiy acknowledges and agrees that the Board reserves the right to take any actions that the Board, in its sole discretion, believes is necessary to protect the integrity of gaming in including the right to suspend or revoke any license, approval or permit without limitation if any further violations occur or are subsequently discovered, all in accordance with the Act and the regulations promulgated thereunder. The undersigned consent to the form and entry of the above. GAMING CONTROL BOARD If/ I /9 . DATED I 1 Senior Enforcem it Counsel RIVERS CASINO PHILADELPHIA SUGARHOUSE HSP GAMING, L.P. r: I By: M. DONNELLY, ESQ. DATED Attorney for Rivers Casino Philadelphia SugarHousc HSP Gaming, LR