STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION FLORIDA STATE BOXING COMMISSION O71-U 80 PL FLORIDA STATE BOXING COMMISSION AND THE STATE OF FLORIDA, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, Petitioners, v. , CASE NO. 2007-035676 PATRICK WASHINGTON, 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 Action against Respondent, PATRICK WASHINGTON, and alleges: . 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 Statutes (the “Joe Lang Kershaw Act”), and the rules promulgated thereto. 2. Respondent’s address of record is 1013 Del Nova Lane, Orlando, FL 32818. 3. Respondent, atthe time of the alleged violations, was a Licensed Participant, in accordance with Section 548.017(1), Florida Statutes, and Rules 61K1-1.003 and 61K1-1.018, General Rules for Boxing, Florida Administrative Code. 4, On or about June 7, 2007, Respondent was examined by GEORGE PANAGAKOS, M.D. who certified that Respondent was not in appropriate condition to engage in a boxing match, . 5, According to the post-match physical examination report, Respondent’s blood pressure was in the 170/120 range and warned of a risk of stroke and/or heart attack. 6. On or about June 8, 2007, the Commission suspended Respondent’s license indefinitely. 7. Section 548.041(2)(c), Florida Statues, provides in pertinent part that “Tajny participant who has been suspended by any state as a result of a recent knockout or series of consecutive losses, an injury, requirement for a medical procedure, physician denial of certification, failure of a dnig test, the use of aliases, or the falsifying or attempting to falsify official identification cards or documents shall not be permitted to participate in this state until such time as the state in which the participant is suspended removes his or her name from the suspension list or until the requirements of such suspension have been fulfilled and proof of such has been provided to the state...” 8. Section 548.071(1), Florida Statutes, provides that the Commission may suspend or revoke a license or permit if the Commission finds that the licensee is guilty of violating Chapter 548, Florida Statutes, or the rules of the Commission. 9. Based on the foregoing, Respondent is in violation of Section 548.041(2)(c), Florida Statutes, by being denied certification to participate in a boxing match. WHEREFORE, Petitioner respectfully requests the Florida State Boxing Commission to issue a Final Order as final agency action finding the Respondent(s) guilty as charged. The 2 penalties which may be imposed for violation(s) of Chapter 548 of the Florida Statutes, depending upon the severity of the offense(s), include: revocation of the license, registration, or certificate; suspension of the license, registration or certificate for a period not to exceed ten (10) years; imposition of an administrative fine of up to $5,000 for each count or offense; imposition of investigative costs; issuance of a reprimand; imposition of probation subject to terms including, but not limited to, requiring the licensee, registrant, or certificate holder to complete and pass additional appraisal education courses; publication, or any combination of the foregoing which may apply. See Section 475.624, Florida Statutes and Rule 61J 1-8.002, Florida Administrative Code. The penalties which may be imposed for violation(s) of Chapter 455 of the Florida Statutes, depending upon the severity of the offense(s), include: revocation of the license, registration, or certificate; suspension of the license, registration, or certificate for a period not to exceed ten (10) years; imposition of an administrative fine of up to $5,000 for each count or offense; imposition of investigative costs; issuance of a reprimand; imposition of probation subject to terms including, but not limited to, requiring the Hocnsee, registrant, or certificate holder to complete and pass additional appraisal education courses; publication; restriction of practice; injunctive or mandamus relief: imposition of a cease and desist order; or any combination of the foregoing which may apply. See Section 455.227, Fla. Statutes and Florida Administrative Code Rule 61J1-8.002, SIGNED this /§ day of Sgbem fen , 2007. FILED Tom Molloy Department of Business and Professional Regulation Executive Director AGENCY CLERK Florida State Boxing Commission CLERK gre fe fy Spd: Hecke eo DATE, Attorney for Petitioners: Charles F, Tunnicliff Chief Professions Attorney Fla. Bar No, 0153831 Office of the General Counsel Department of Business and Professional Regulation 1940 N. Monroe Street Tallahassee, Florida 32399-0750 Phone: (850) 487-4526 Facsimile: (850) 922-1278 CFT/jas CF/ 9-12 07

Docket for Case No: 07-004860PL