FILED Department of Business and Professional Regulation Deputy Agency Clerk CLERK Evetle Lawson-Proctor Date 2/21/2018 STATE OF FLORIDA File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF PARI-MUTUEL WAGERING DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF PARI-MUTUEL WAGERING, Petitioner, DBPR Case No.: 2018-000696 v. RAYMOND GEORGE HANDAL, Respondent. / ADMINISTRATIVE COMPLAINT The Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (Petitioner), files this Administrative Complaint against Raymond George Handal (Respondent), and alleges as follows: 1. Petitioner is the state agency charged with regulating pari-mutuel wagering pursuant to Chapters 550, Florida Statues. Dh At all times material hereto, Respondent held a PMW Professional Individual Occupational License, number 7968289-1021, issued by the Petitioner. 3% At all times material hereto, Respondent worked as a trainer at the Tampa Bay Downs. 4. Tampa Bay Downs is a facility operated by a permitholder authorized to conduct pari-mutuel wagering in this state under Chapters 550, Florida Statutes. 5. On December 19, 2017, Petitioner’s investigators performed a routine inspection at the Tampa Bay Downs. Page 1 of 3 6. During the inspection, the investigators found three unlicensed people (Swan Lachester Jr., Francisco Gonzales, and Cesar Trejo), working in Respondent’s barn. 7. Rule 61D-2.005, Florida Administrative Code, states that “[n]o person shall conspire with, solicit, aid, abet, counsel, hire, or procure any other person or persons to engage in a violation of Chapter 550, F.S., or the rules promulgated thereunder, nor shall he/she commit any such act on his/her own.” 8. Section 550.105(4), Florida Statutes, states that “[i]t is unlawful to take part in or officiate in any way at any pari-mutuel facility without first having secured a license and paid the occupational license fee.” 9. Based on the foregoing, Respondent is in violation of Rule 61D-2.005, Florida Administrative Code, and Section 550.105(4), Florida Statutes, by allowing three unlicensed individuals to work in his barn. WHEREFORE, Petitioner respectfully requests the Division Director enter an Order imposing against Respondent one or more of the penalties specified in Sections 550.105, 550.0251, Florida Statutes, and/or any other relief that the Division is authorized to impose pursuant to Chapters 550, Florida Statutes, and/or the rules promulgated thereunder. [Signatures appear on the following page] Page 2 of 3 The administrative complaint in DBPR Case 2018-000696 is signed this 15th day of February, 2018. /s/ Louis Trombetta LOUIS TROMBETTA Chief Attorney Florida Bar No. 0108119 Louis. Trombetta@MyFloridaLicense.com Office of the General Counsel Division of Pari-Mutuel Wagering Department of Business and Professional Regulation 2601 Blair Stone Road, Mail Stop N21 Tallahassee, Florida 32399-2202 Telephone: (850)-717-1508 Facsimile: (850) 921-1311 NOTICE OF RIGHTS TO REQUEST A HEARING Pursuant to Section 120.569 and 120.57, Florida Statutes, you have the right to request a hearing to challenge the charges contained in this Administrative Complaint. If you choose to request a hearing, you will have the right to be represented by counsel, or other qualified Tepresentative, to present evidence and argument, to call and cross-examine witnesses, and to have subpoenas and subpoenas duces tecum issued on your behalf. Any request for an administrative proceeding to challenge or contest the charges contained in this Administrative Complaint must conform to Rule 28-106.2015, Florida Administrative Code. Pursuant to Rule 28-106.111, Florida Administrative Code, you must request a hearing within 21 days from receipt of this Notice, or you will waive your right to request a hearing. Page 3 of 3

Docket for Case No: 18-001779PL