RECEIVED/FILED JAN 25 2019 NGC 18:15 aE mn eutsovenh eno STATE OF NEVADA BEFORE THE NEVADA GAMING COMMISSION NEVADA GAMING CONTROL BOARD, Complainant, COMPLAINT WYNN LAS VEGAS, LLC dha WYNN LAS VEGAS: WYNN RESORTS, LIMITED (PTC) Respondents. ‘The State of Nevada, on relation of its NEVADA GAMING CONTROL BOARD] (BOARD), Complainant herein, by and through its counsel, AARON D. FORD, Attorney) |General, by JOHN 8. MICHELA, Senior Deputy Attorney General, MICHAEL P. SOMPS, [Senior Deputy Attorney General, and EDWARD L. MAGAW, Deputy Attorney General, hereby files this Complaint for disciplinary action against WYNN LAS VEGAS, LLC, dba, WYNN LAS VEGAS (WYNN) and WYNN RESORTS, LIMITED (PTO) (RESORTS) (collectively RESPONDENTS), pursuant to Nevada Revised Statute (NRS) 463.310(2), and| alleges a follows: JURISDICTION, 1, Complainant, BOARD, is an administrative agency of the State of Nevada duly organized and existing under and by virtue of Chapter 463 of the NRS and is charged with the administration and enforcement of the gaming laws of this state as set forth in Title 41 ‘ofthe NRS and the Regulations of the Nevada Gaming Commission, 2. WYNN, located at 8181 Las Vegas Boulevard, Las Vegas, Nevada, is organized| under the laws of Nevaia and holds a nonrestrieted gaming license, manufacturer license, and distributor license. WYNN activated these licenses on or about April 28, 2005. Page 1 of 2210 n 2 18 M 16 7 18 19 20 a1 22 2s 24 25 26 an 2s 3. RESORTS, Ibeatod at $181 Las Vegas Boulevard, Las Vegas, Nevada, is| registered as a publicly traded company by the Nevada Gaming Commission and, through wholly owned intermediaries and holding companies, is the owner of WYNN. RESORTS| activated its approvals with regard to WYNN on or about April 28, 2005, RELEVANT LAW, 4, ‘The Nevada Logislature has deelared under NRS 463.0129(1) that: (@) The gaming industry is vitally important to the economy of the State and the general welfare of the inhabitants. (@) The emtinued grovth and success of gaming is dependent ‘upon public confidence and trust that licensed gaming and the ‘manufacture, sale and distribution of gaming devices and ‘associated equipment are conducted honestly and competitively, that establishments which hold restricted and nonrestricted licenses where gaming is conducted and where gambling devices are operated do not unduly impact the quality of life enjoyed by residents of the surrounding neighborhoods, that the rights of the creditors of licensees are protected and that gaming is free from eriminal and eorruptive elements. (©) Public confidence and trust ean only be maintained by strict regulation of all persons, locations, practices, associations and achivities related to the operation of licensed | gaming establishments, the manufacture, sale or distribution of gaming devices and. associated equipment and the operation of inter ceasino linked systems, NRS 463.0129), (| and (©. 5, The Nevada Gaming Commission has full and absolute power and authority to limit, condition, restric, revoke or suspend any license, or fine any person licensed, for any| cause deemed reasonatle, See NRS 463.1405(4), 6, ‘The BOARD is authorized to observe the conduct of licensees in order to ensure| that the gaming operations are not being conducted in an unsuitable manner. See NRS| 463,1405(0). 7. This continuing obligation is repeated in Nevada Gaming Commission Regulation 5.040, which provides as follows: ‘A gaming license is a revocable privilege, and no holder thereof shall be daemed to have acquired any vested rights therein or thereunder. The burden of proving his or her qualifications to hold any license rests at all times on the licensee. The Board is charged by law with the duty of observing the conduct of all Page 2 of 22licensees tothe end that licenses shall not he held by unqualified or disqualified persons or unsuitable persons or persons Whose operations are conducted in an unsuitable manner. Nev. Gaming Comm'n Reg. 5.040. 8, Nevada Revised Statute 463.641 provides as follows: If any comporation, partnership, limited partnership, limited- liability company or other business organization holding a lieenae is owned or controlled by a publicly traded corporation subject to the provisions af this chapter, or that publicly traded corporation, does not comply with the laws of this state and the regulations’ of the Commission, the Commission may in its diseretion do any one, all or a combination of the following: 1. Revoke, limit, condition or suspend the license of the licensee; 2, Fine the persons involved, the licensee or the publicly traded corporation, in accordance with the laws of this state and the regulations of the Commission, INRS 403.641. 9, Nevada Gaming Commission Regulation 3.080 provides as follows: ‘The Commission may deny, revoke, suspend, limit, condition, or restrict any registration or finding of suitability or application therefor upon the same grounds as it may take such action with respect to licenses, licensees and licensing; without exclusion of any other grounds, The Commission may take euch action on the grounds that the registrant or person found suitable is associated with, or controls, or is controlled by, or is under common control with, an unsuitable person. Nev. Gaming Comm'n Reg. 8.080. 10, Nevada Revised Statute 463.170 provides as follows: 1. Any pesson who the Commission determines is qualified ta Zoonivel leene, tobe found sultabhe or to seceive aay approval equired under the provisions of this chapter, or to be found Suitable regarding the operation ofa chavitableftiery under tho provisions of chapter 482 of NRS, having due consideration for the prope: protection of the health, safety, morals, good order ‘and general welfare of the inhabitants of the State of Nevada and the declared policy of this Stato, may be issued state gaming Iicense, be found suitable or receive any approval required hy this charter, as appropriate, ‘The burden of proving an applicants qualification to receive any license, be forma suitable Page 8 of 22