STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF PARI-MUTUEL WAGERING DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF PARI-MUTUEL WAGERING Petitioner, ve CASE NO. 2008037365 ROSS B, WOLFENDALE, Respondent, Se ADMINISTRATIVE COMPLAINT The Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering ("Division"), files this Administrative Complaint against Ross B. Wolfendale, UT ("Respondent"), and alleges as follows: 1, The Division is the state agency charged with Tegulating pari-mutuel wagering, pursuant to Chapter 550, Florida Statutes, 2, At all times material hereto, Respondent held a pari-nmutuel wagering occupational license, number 1218720-1021, issued by the Division. 3. On June 23, 2008, the County Court in and for Broward County, Florida issued 4 Final Judgment in Case # 07016735 (50), Respondent Ross B. Wolfendale, Ill a/k/a Rudy Wolfendale was ordered to pay Finish Line Feeds $10,899.59, comprising a principal of $10,544.59 ptus $355.00 court cosis, The total bears interest at the rate of 119% annually, : 6882 /68/28 TIETTZ6898 éT+ST Md O80 Ada éa/pa Fovd ’ TZ:967 6007 6 gad 4. The debt owed was for feed, bedding and supplies delivered to Calder Race Course and/ or Gulfstream Park, and directly relates to pari-mutuel wagering in the state of Florida. 5. Section 550.105(7), Florida Statutes, states: | The division may deny, revoke, or suspend arly occupational license if the applicant therefore or holder thereof accumulates unpaid obligations or defaults in obligations, or issues drafts or checks that are dishonored or for which payment is refused without reasonable cause, if such unpaid obligations, defaults, or dishonored or refused drafts or checks directly relate to the sport of jai alai or racing being conducted at a pari-mutuel facility within this state, 6. Respondent violated Section 550.105(7), Florida Statutes, by accumulating unpaid obligations which are directly related to thoroughbred racing at pari-mutuel facilities in this state, totaling $10,899.59, ) 1, Additionally, Respondent has outstanding fines due to the Division totaling $2,000.00, | 8. On June 16, 2006, the Judges/ Stewards at Calder Race Course entered written Ruling No. 325-00896, suspending Respondent for sixty (60) days and ordering him to pay a $1,000.00 fine. 9. Also on June 16; 2006, the Judges/ Stewards at Calder Race Course entered Written Ruling No. 3253-00897, suspending Respondent for forty-five (45) days and ordering him to pay a $1,000.00 fine. 10. On June 26, 2006, Respondent appealed the rulings and requested a stay, which was granted. The appeals were heard by the Department in Case Nos. 2005049776 and 2005049780. Mad 200 sda] TTETTC6aS8 éT:ST 680¢/60/28 46/S@ Jad Te: ST 60026 6 a4 11. At an informal hearing held October 4, 2006, upon agreement of Respondent and the Department, a Consent Order was prepared for Respondent to execute and retum. To date, the Consent Order has not been returned. 12." On December 11, 2007, the Department issued its final order in cases 2005049776 and 2005049780, Respondent was ordered to pay a total of $2,000.00 in fines and to serve a suspension of 60 days, to run concurrent with his 45 day suspension, 13. To date, Respondent has not paid any portion of the $2,000.00 owed to the Department, or served his 60 day suspension. WHEREFORE, Petitioner respectfully requests that the Division enter an Order . imposing one or more of the following penalties as specified in Sections 550,105(5)(b) and 350.0251(10), Florida Statutes: Tevoke or suspend the Respondent’s occupational license; impose a fine against the Respondent in an amount not exceeding $1,000, in addition to the $2,000 already adjudged to be paid; or impose against the Respondent any combination of such penalties. . gf Signed this “Gay or C2. A, few 2008 a | * FILED Dapartment of Business and Professional Regulation DEPUTY CLERK EPH M. HELTON, oR. da Bar No, 0879622 eL 3 , WM Tlechole Chief Attomey 2 10-13-2003 rowenta DATE 10-13-2003 partment of Busines ; Northwood Center ® & Professional Regulation 1940 North Monroe Street, Suite 40 Tallahassee, Florida 32399-2202 MAd O80 add TTETTC6093 4T:ST 6882/68/28 48/98 Sod éce:oT 600¢ 6 a4 Copies furnished to: Ross B. Wolfendale, TI - Cert. Mail/Retum Receipt Office of Operation/Licensing Section Office of Investigations David N. Perry, Assistant General Counsel é@/é@ Fold MAd O80 add TTETTC6093 4T:ST 6882/68/28 éce:oT 600¢ 6 a4

Docket for Case No: 09-000674PL