Cuvee Club Temecula LLC,

25 October 2018

M & M Concepts LLC,

1205 Prospect Street, Suite D,

San Diego/7979

Ivanhoe Avenue

RE: Letter of Demand

Dear M & M Concepts LLC,

On the 31st Day of July , 2018, We as the Cuvee Club Temecula and M&M Concepts LLC, dba Covo La Jolla (Covo) entered into a Memorandum of Understanding regarding the development and operation of the Supper Club Concept developed by the Cuvee Club Temecula LLC. In good faith, the Cuvee Club Temecula LLC, herein referred to as the Cuvee Club, through its managing partners Collin Rand and Dave Neugart, paid the agreed figure of $50,000 for the two units of ownership in Covo and began what was assumed to be a lasting business relationship between the two companies. Cuvee undertook steps to market and prepare various activities at Covo, thereby investing large sums of money as agreed in the Memorandum of Understanding.

However, on Friday, October 12th 2018, the managing partner at Covo, Mr. Michael Viscuso, and Mr Rand had a meeting whereby Mr. Viscuso stated clearly that Covo was not interested in doing business with the Cuvee Club due to past cases against Dave Neugart. Viscuso said that the information provided to him came from an investigative journalist, whose name he has refused to provide. Mr Viscuso has further refused to provide the detailed reports from the investigative journalist. During the meeting, Mr. Viscuso stated that the shareholders would be unhappy to do business with a company managed by a person with a reputation as soiled as Mr. Neugart’s. Mr. Viscuso suggested that the initial capital be refunded and that the two companies go their separate ways.

However, since the said date, Mr. Viscuso has been unresponsive to any form of communication. Your actions are clearly malicious and are intended to defraud the Cuvee Club. The allegations brought forward by Mr. Viscuso are unconfirmed allegations that have no investigative backing. The fact that Mr. Viscuso could not provide the name of the Investigative journalist further bolsters this fact. Furthermore, if one of the directors being involved in various court cases was an actual problem, then Mr. Viscuso would have also had to relinquish his position as well/. A quick search at the Superior Court of Carlifornia shows that Mr. Viscuso has been involved in a total of 24 cases, at least five of which were related to a breach of contract.

With these facts in mind, we hereby demand:

  1. That the initial figure of $50,000 paid for the two units of ownership, with interest of $3,375 accrued over the 3-month period, is paid back within 48 hours of receipt of this letter.
  2. That $12,000 of back-pay in management and operational fees is also paid within 48 hours of receiving this letter
  3. The remaining figure of $117,804, accrued by Cuvee Club throughout the business engagement with Covo, be refunded within 30 days of receipt of this letter.

Attached is a breakdown of the costs undertaken by the Cuvee Club, along with copies of the Memorandum of Understanding, Subscription Agreement and Acknowledgement of Investment Intent, a log of text message communication between Mr. Rand and Mr. Viscuso and a search of Cases relating to Mr. Viscuso.

These demands should be met soonest possible, lest we shall be forced to escalate this matter to commercial arbitration. In the event that we fail to reach an amicable solution at arbitration, we shall then file a formal lawsuit for punitive damages to the fullest amount that the law will allow. Furthermore, we shall ensure to inform the media, both print, television and electronic, about the dealings and the current legal situation.


Cuvee Club Temecula LLC,

Los Angeles,


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