FILED Department of Business and Professional Regulation AGENCY CLERK CLERK Ronda L. Bryan Date 1/7/2020 STATE OF FLORIDA Pale DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF PARI-MUTUEL WAGERING DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF PARI-MUTUEL WAGERING, Petitioner, v. DBPR Case No.: 2019-062802 JENNIFER A. HAYFORD-QUINONES, Respondent. / ADMINISTRATIVE COMPLAINT The Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (‘Petitioner’), files this Administrative Complaint against Jennifer A. Hayford- Quinones (“Respondent”), and alleges as follows: 1. Petitioner is the state agency charged with regulating pari-mutuel wagering pursuant to chapter 550, Florida Statutes. 2, At all times material hereto, Respondent held a Pari-Mutuel Wagering Professional Individual Occupational License, number 980255-1021, issued by Petitioner. 3t Respondent has one prior violation of section 550.2415, Florida Statutes, in the previous 365 days, in DBPR Case Number 2019-043388. 4. At all times material hereto, Respondent was the trainer of record for the racing horse “Chief White Sox,” with microchip number 985141001304784. Ds On November 13, 2019, “Chief White Sox” participated in the 4th race of the performances held at Gulfstream Park Racing Association, Inc. (“Gulfstream Park’). 6. On November 13, 2019, “Chief White Sox” finished in 2nd place in the 4th race of the performances held at Gulfstream Park. 7. Gulfstream Park is a facility operated by a permitholder authorized to conduct pari-mutuel wagering in this state under chapter 550, Florida Statutes. 8. On November 13, 2019, blood sample number 921815 was collected from “Chief White Sox.” 9. Blood sample number 921815 was processed and forwarded to the University of Florida Racing Laboratory (“UF Lab”), for analysis. 10. The UF Lab tested the serum extracted from blood sample number 921815 and found that it contained xylazine, which is a central nervous system depressant and Class III drug according to the Uniform Classification Guidelines for Foreign Substances, as promulgated by the Association of Racing Commissioners International, Inc. 11. In blood sample number 921815, xylazine was detected at a serum concentration of 21.1 +/- 1.8 pg/mL. 12. Pursuant to section 550.2415(1)(a), Florida Statutes: The racing of an animal that has been impermissibly medicated or determined to have a prohibited substance present is prohibited. It is a violation of this section for a person to impermissibly medicate an animal or for an animal to have a prohibited substance present resulting in a positive test for such medications or substances based on samples taken from the animal before or immediately after the racing of that animal. 13. According to Rule 61D-6.008(2)(w), Florida Administrative Code, it is a violation of section 550.2415, Florida Statutes, if xylazine exists at a serum concentration greater than 0.01 ng/mL 2019-062802 Page 2 of 5 14. Section 550.2415(1)(c), Florida Statutes, states, “[t]he finding of a prohibited substance in a race-day specimen constitutes prima facie evidence that the substance was administered and was carried in the body of the animal while participating in the race.” 15. Rule 61D-6.002(1), Florida Administrative Code, provides that, "[t]he trainer of record shall be responsible for and be the absolute insurer of the condition of the horses...he/she enters to race." 16. Based on the foregoing, Respondent violated section 550.2415(1)(a), Florida Statutes, and Rule 61D-6.008(2)(w), Florida Administrative Code, by racing “Chief White Sox” with an impermissible concentration of a permitted substance in its body on November 13, 2019. WHEREFORE, Petitioner respectfully requests the Division enter an Order imposing against Respondent one or more of the penalties specified in Rule 61D-6.011, Florida Administrative Code, 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. This Administrative Complaint for DBPR Case Number 2019-062802 is signed this 6th day of January, 2020. /s[ Mike Gordon /s/f Megan S. Silver MIKE GORDON MEGAN S. SILVER Senior Attorney Chief Attorney Florida Bar No. 84217 Florida Bar No. 115518 Michael.Gordon@MyFloridaLicense.com Megan.Silver@MyFloridaLicense.com Office of the General Counsel Division of Pari-Mutuel Wagering Department of Business and Professional Regulation 2601 Blair Stone Road Tallahassee, Florida 32399-1035 Telephone: (850) 717-1585 - Facsimile: (850) 921-1311 2019-062802 Page 3 of 5 NOTICE OF RIGHTS TO REQUEST A HEARING Pursuant to sections 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 representative, 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. Mediation under section 120.573, Florida Statutes, is not available to resolve this Administrative Complaint. NOTICE OF RIGHT TO REQUEST A SPLIT SAMPLE Pursuant to Rule 61D-6.006, Florida Administrative Code, you have the right to request a split sample with respect to each “Report of Positive Result” from the UF Lab. (Copy attached as Exhibit A). To request a split sample, use Form DBPR PMW-3290, Notification to Stewards/Judge of Split Sample Request (Form 3290). You can obtain Form 3290, as well as a list of approved split samples laboratories, at the State Office located in any Florida pari-mutuel facility, or on the Division’s website: http:/Awww.myfloridalicense.com/DBPR/pari-mutuel-wagering/forms-and-publications/. | You must submit Form 3290 to the state steward, Division hearing officer, or office of the General Counsel, within 10 days from receipt of this Notice, or you will waive your right to request a split sample. 2019-062802 Page 4 of 5 EXHIBIT A 12-13-19;02:21PM: Pat ee e219 921815 UF ORI of Beat OE ihe Sox FLORIDA coior _{ h sexQ_ AGE a College of Medicine Department af Pathology, Immunology ard Laboretory Med FIN‘SH 2 _nace Rating Laboratory TRACK ON : .Senni . December 13,2019 TRAINER SAN erin SAMPLED BK <2 Mr. Louis Trombatta, Director SAMPLED BY. aR Division of Pari-Mutuel Wagering 2 Department of Business and Professional Regulation STATE 2601 Blair Stone Road » XGarati Tallahassee, FL 32809-1037 ownen’s VAtque2. LICENSE NUMBER — RE: It of Positive Result Hane va O45 | he t 3 ‘TATTOO NUMBER. a Sample 921815 has been analyzed by liquid chromatogrephy-tanden -RL-252-01 T 10 contain the following: xytezina found in serum xylazine (a central nervous system depressant and class 3 drug) - the concentration of xylezine is 21,1 -+/- 1.6 pg/ml. 0118166-FHB Horse Serum 1219 INTACT Laboratory Number Specimen Final Weight Seal Calder Race Course 11/13/2019 11/49/2019 Coilected From Date Collected Date Recetved Purguant to Chapter 550.2415 (1), F.S., the public disclosure of the information containad in this Report of Postive Resut is authorized on er after 12/22/2019, or upon commencement of administrative action, whichever Occurs first. Cynthia & DVM, PhO sat Dirk A Hunt ‘Associate Director 20-31 Page f of 1 Unlvoretty of Flaida Racing Lab The Foundation for The Gator Nation ‘An Equal Opportunity Institution 2019-062802 Page 5 of 5

Docket for Case No: 20-002644PL