STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATIONS DIVISION OF PARI-MUTUEL WAGERING DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION: & DIVISION OF PARI-MUTUEL WAGERING eos Ly ~o an oes = : _ Petitioner & vs. JILL K. SPICER-HALL, Case No. 2004040006 Respondent. OS 35 T#L ADMINISTRATIVE COMPLAINT Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (hereinafter "Division"), files this Administrative Complaint against Jill K Spicer-Hall (hereinafter "Respondent"), and alleges as follows 1. The Division is the state agency charged with regulating pari-mutuel 2. wagering, pursuant to Chapter 550, Florida Statutes At all times material hereto, Respondent held a pari-mutuel wagering occupational license, number 1287971-1021, issued by the Division 3. trainer. At all times material hereto, Respondent was employed as a Greyhound 4. On July 30, 2004, Armstrong Kennels, Inc. (license number 2006575- 1020) had two greyhound entries, “TF Senator” and “JR’s Mercury,” in the third a" race at Sanford-Orlando Kennel Club 5. On July 30, 2004, “IR’s Mercury” finished first (1) in the third (3) race at Sanford-Orlando Kennel Club and was selected for drug testing pursuant to Rule 61D- 6.005(1), Florida Administrative Code. 6. Following the third (3") race, Respondent retrieved both “TF Senator” and “JR’s Mercury” from the finish area. 7. Veterinarian Assistant Mr. Anthony Manfredi requested that Respondent give “TF Senator” to another trainer while he sampled “JR’s Mercury.” 8. Respondent refused to give “TF Senator” to another trainer while Mr. Manfredi attempted to collect a urine sample from “JR’s Mercury.” 9. Mr. Manfredi told Respondent that walking both “TF Senator” and “JR’s Mercury” at the same time would interfere with the taking of a urine sample from “JR’s Mercury.” 10. Mr. Manfredi again requested Respondent to give “TF Senator” to another trainer so that he could collect a urine sample from “JR’s Mercury.” 11. Respondent again refused to give “TF Senator” to another trainer while Mr. Manfredi attempted to collect a urine sample from “JR’s Mercury.” 12. Mr. Manfredi informed Respondent that she was interfering with his collection of a urine sample from “JR’s Mercury” by keeping “TF Senator” within such a close proximity of “JR’s Mercury,” and again requested that Respondent give “TF Senator” to someone else so that a urine sample could be collected from “JR’s Mercury.” 13. Respondent again refused to give “TF Senator” to another trainer while Mr. Manfredi attempted to collect a urine sample from “JR’s Mercury.” 14. Mr. Manfredi was unable to collect a urine sample from “JR’s Mercury.” 15. Rule 61D-6.005(9), Florida Administrative Code, states that: “Tajny licensee who threatens to or interferes with, or fails to allow the taking of urine, blood, or other specimens authorized by Chapter 550, Florida Statutes, is subject to suspension by the stewards or judges of the meet and to action by the Division. The stewards and judges shall refer any such incident to the Division for review.” 16. Rule 61D-6005(1), Florida Administrative Code, states thet: [t]he winner of every race and other such racing animal participants the stewards, judges, Division, or track veterinarian of the meet designate, shall be sent immediately after the race to the detention enclosure for examination by the authorized representative of the Division and for the taking of urine, blood or other such samples as shall be directed for the monitoring and detection of both permissible and impenmissible substances. Blood specimens shall be taken only by a Florida licensed veterinarian (Division or track) and witnessed by the racing animal’s trainer of record, owner, or designee. Said veterinarian should attempt to attain up to six full 15-millileter blood tubes from each horse sampled. 17. Section 550.105(5)(b), Florida Statutes, states in pertinent part that: “(t]he division may deny, suspend, revoke, or declare ineligible any occupational license if the applicant for or holder thereof has violated the provisions of this chapter or the rules of the division governing the conduct of persons connected with racetracks and frontons.”” 18. Based on the foregoing, Respondent violated Rule 61D-6.005(9), Florida Administrative Code, by interfering with or failing to allow the taking of a urine sample as authorized by Chapter 550, Florida Statutes. WHEREFORE, Petitioner respectfully requests the Division enter an Order suspending or revoking Respondent’s occupational license pursuant to Section 550.105(5)(b), Florida Statutes, and an order declaring the Respondent ineligible for an occupational license, and imposing a fine not to exceed $1,000, pursuant to Section 550.0251(10), Florida Statutes. JA Signed this [ day of MVeye nm ber , 2004, Division of Pari-Mutuel Wagering jonal Regulation of Business ant ERK Florida Bar Number: 879622 Department DEPUTY Department of Business and Professional Regulation Northwood Centre CLERK - 1940 North Monroe Street - Tallahassee, FL 32399-2202 DATE Copies furnished to: Office of Operations Licensing Section Investigations Section Case Number 2004040006

Docket for Case No: 05-002357PL