FILED Department of Business arid Professional Regulation Deputy Agency Clerk STATE OF FLORIDA CLERK Evette Lawson-Proctor DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATI| ose 44/8/2016 DIVISION OF PARI-MUTUEL WAGERING File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF PARI-MUTUEL WAGERING, Petitioner, DBPR CASE No. 2016-036100 Vv. TERESA M. POMPAY, Respondent. / ADMINISTRATIVE COMPLAINT The Department of Business and Professional Regulation, Division of Pari-Mutuel Wager- ing (“Petitioner”), files this Administrative Complaint against Teresa M. Pompay, (“Respondent”) and alleges as follows: 1. The Petitioner is the state agency charged with regulating pari-mutuel wagering pur- suant to Chapter 550, Florida Statutes. 2. Respondent’s address of record is reported as 1125 Cliffrose Street, Hollywood, FL 33019. 3. At all times material hereto, Respondent held a pari-mutuel wagering professional individual occupational license, number 1001817-1021, issued by the Division. 4. At all times material hereto, Gulfstream Park was a facility operated by a per- mitholder authorized to conduct pari-mutuel wagering in this state under Chapter 550, Florida Statutes. 5. At all times material hereto, Esteban Ramirez did not hold an occupational license issued by the Division. 6. Section 550.105(4), Florida Statutes, provides that, “it 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.” 7. Rule 61D-2.2025, Florida Administrative Code, provides that, “no person shall con- spire with, solicit, aid, abet, counsel, hire, or procure any other persons to engage in a violation of Chapter 550, Florida Statutes, or the rules promulgated thereunder...” COUNT I 8. Petitioner realleges and incorporates paragraphs one through seven as through fully set forth herein. 9. On or about July 25, 2016, hot walker Esteban Ramirez was walking a horse trained by Respondent on the backside of Gulfstream Park. 10. Based on the foregoing, Respondent violated Rule 61D-2.025, Florida Administra- tive Code, by conspiring with, soliciting, aiding, abetting, counseling, hiring, or procuring Esteban Ramirez to work on the backside of Gulfstream Park when Esteban Ramirez did not hold an occupational license. COUNT II 11. Petitioner realleges and incorporates paragraphs one through seven as through fully set forth herein. 12. On or about July 29, 2016, hot walker Esteban Ramirez was walking a horse trained by Respondent on the backside of Gulfstream Park. 13. Based on the foregoing, Respondent violated Rule 61D-2.025, Florida Administra- tive Code, by conspiring with, soliciting, aiding, abetting, counseling, hiring, or procuring Esteban Ramirez to work on the backside of Gulfstream Park when Esteban Ramirez did not hold an occupational license. WHEREFORE, Petitioner respectfully requests the Division enter an Order imposing against Respondent one or more of the penalties specified in Section 550.2415(3)(a), Florida Statutes, and/or any other relief that the Division is authorized to impose pursuant to Chapter 550, Florida Statutes, and/or the rules promulgated thereunder. Signed this 7th day of November, 2016. KEN LAWSON, Secretary Department of Business and Professional Regulation /s/ Caitlin R, Mawn CAITLIN R. MAWN Florida Bar No. 99545 Deputy Chief Attorney Department of Business and Professional Regulation Division of Pari-Mutuel Wagering Office of the General Counsel 2601 Blair Stone Road Tallahassee, Florida 32399-2202 NOTICE OF RIGHTS Please be advised that within twenty-one (21) days of your receipt of this administrative complaint, you have the right to request an administrative hearing. Any such hearing would be conducted in accordance with the provisions of Sections 120.569 and 120.57, Florida Statutes, and you would have the right to be represented by counsel or other qualified representative, to call and examine witnesses, and to have subpoenas issued on your behalf. However, if you do not file (i.e., we do not receive) your request for hearing within twenty-one (21) days, you will have waived your right to any hearing. Please also be advised that mediation is not available in this matter.

Docket for Case No: 18-002977PL