STATE OF FLORIDA: DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION FLORIDA STATE BOXING COMMISSION FLORIDA STATE BOXING COMMISSION AND THE DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION Petitioner, ay DBPRCase No, 2005-047160 v. WARRIORS BOXING PROMOTIONS, INC., O 5S . 2d 9/ Respondent. / ADMINISTRATIVE COMPLAINT Petitioners, the Florida State Boxing Commission (“Commission”), and the State of Florida, Department of Business and Professional Regulation (Department, files this Administrative ‘Complaint against Respondent, WARRIORS BOXING PROMOTIONS, INC., and state: | - ESSENTIAL ALLEGATIONS OF MATERIAL FACT 1. Petitioners are the State agencies charged with supervising and regulating professional pugilistic exhibitions in the State of Florida, pursuant to Florida Statutes, specifically, Chapter 120, Florida Statutes, and Chapter 548, Florida Statues, (the “Joe Lang Kershaw Act”), and the rules promulgated thereto. 2, Respondent’s address of record is 4151 North State Road 7, Hollywood, Florida 33021. 3. Respondent has been, at all times material hereto, a Licensed Promoter in accordance with section 548.017(1), Florida Statutes, and the rules promulgated thereto. 4, On or about August 26, 2005, Respondent was the Promoter of Record in a Commission sanctioned match in Hollywood, Florida. 5. Ray Mercer was the Licensed Participant of record for the August 26, 2005, match. 6. The Letter of Agreement between Promoter and Participant signed August 25, 2005 and attached hereto as Exhibit “A”, provides that “Warriors Boxing Promotions, Inc. agrees to pay Ray Mercer seventy thousand dollars ($70,000) for services rendered”. 7. Participant Ray Mercer received partial payment of $13,000 before the August 26, 2005 match, but did not receive the remaining fifty-seven thousand dollars ~. ($57,000) owed to him under the contract within 24 hours of the match, As of September. 9, 2005, the remaining fifty-seven thousand dollars ($57,000) has not been paid by Respondent to Ray Mercer or his manager. 8. Section 548.053(1), Florida Statutes, provides is pertinent part: Unless otherwise directed by a representative of the commission, all purses shall be distributed by the promoter no later than 24 hours after the match. A written statement showing the distribution of the purse, including each item of receipt and each expenditure or deduction, shall be furnished to the participant and her or his manager, together with the participant's share of the purse. The promoter shall retain a copy of the statement, certified by her or him to be correct, with receipted vouchers for all expenditures and deductions, for a period to be designated by the commission, which copy shall be provided to the commission upon demand. : COUNT I 9. Petitioners re-allege and incorporate by reference the allegations of fact set forth in paragraphs one (1) through eight (8) as though fully set forth herein. deems appropriate. 10. Based on the foregoing; Respondent violated Section 548.053(1), Florida 24 hours of the boxing match. Statutes, by failing to distribute all purse money to the participant and his manager within WHEREFORE, Petitioners respectfully request the Florida State Boxing Counsel for the Department: CHARLES F. TUNNICLIFF Florida Bar No. 0153831 Lead Professions Attorney Office of the General Counsel Department of Business and Professional Regulation 1940 North Monroe Street Tallahassee, Florida 32399-0750 Phone: (850) 487-9656 Facsimile: (850) 414-6749 Case No. 2005-047160 CFT/JL Commission issue a’Final Order as final agency action finding the Respondent guilty as charged and imposing one or more of the following penalties: revocation of Respondent’s license(s) or permit(s); suspension of Respondent’s license(s) or permit(s); imposition of an administrative fine of not more than $5 ,000 (five thousand dollars), for each count or offense; surrender of the remaining $57,000 owed match participant, Ray Mercer; any combination of the foregoing which may apply; or, any other relief the Commission oft SIGNED this day of AY , 2005. j Casa = Qusmeif Ks ASON PENLEY Executive Director Florida State Boxing Commission FILED Department of Gusinass and Professlonat Ragulation DEPUTY CLERK

Docket for Case No: 05-003991