STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGUL DIVISION OF PARI-MUTUEL WAGERING DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF PARI-MUTUEL WAGERING, Petitioner, vs. CaseNo. 2006025143 SHERYL SHELDON, Oo 0 lo _ iT a PL Respondent. : / ADMINISTRATIVE COMPLAINT . Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (hereinafter "Division"), files this Administrative Complaint against Steven Dwoskin (hereinafter Respondent"), and alleges as follows: 1 The Division 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 occupational license, number 285418-1021, issued by the Division. 3. Rule 61D-6.002(1), Florida Administrative Code, provides in pertinent part that “[t]he trainer of record shall be responsible for and be the absolute insurer of the condition of the horses or racing greyhounds, he/she enters to race," 4, Respondent was the trainer of record of a racing greyhound named “Tkes Trudy” on April 10, 2006. 5. On April 10, 2006, “Ikes Trudy” was entered in the sixth (6) race of the performance at Sanford-Orlando Kennel Club, Inc. ' 6. Sanford-Orlando Kennel Club, Inc. is a facility authorized to conduct pari- mutuel wagering in this state, 7. “Ikes Trudy” finished first (1) in the sixth (6") race of the performance at Sanford-Orlando Kennel Club, Inc. on April 10, 2006. 8. “Tkes Trudy” was immediately thereafter sent to a Division employee for the taking of a urine sample. 9. Urine sample number 208476 was collected from “Ikes Trudy” and was processed in accordance with established procedures and forwarded to the University of Florida Racing Laboratory for analysis. 10. | The University of Florida Racing Laboratory tested urine sample number 208476 and found it to contain Benzoylecgonine (a metabolite of Cocaine), and/or a derivative thereof. ll. The University of Florida Racing Laboratory tested urine sample number 208476 and found it to contain Ecgonine Methyl Ester (a metabolite of Cocaine), and/or a derivative thereof. 12, Cocaine is a Class 1 drug under the Uniform Classification Guidelines for Foreign Substances, as promulgated by the Association of Racing Commissioners International, Inc. 13. Section 550.2415(1)(c), Florida Statutes, states “[tJhe finding of a prohibited substance in a race-day specimen constitutes prima facie evidence that the tw substance was administered and was carried in the body of the animal while participating in the race.” . 14. Cocaine, or its metabolites Benzoylecgonine and Ecgonine Methyl Ester, and/or derivatives thereof, is an impemnnissible substance that was carried in the body of “Tkes Trudy” while participating in the sixth (6") race of the performance at Sanford- Orlando Kennel Club, Inc, on April 10, 2006. . 15. Based on the foregoing, Respondent has violated Section 550.2415(1)(a), Florida Statutes, which: provides, "[t}he racing of an animal with any drug, medication, stimulant, depressant, hypnotic, local anesthetic, or drug-masking agent is prohibited. It is a violation of this section for a person to administer or cause to be administered any : drug, medication, stimulant, depressant, hypnotic, narcotic, local anesthetic, or drug- masking agent to an animal which will result in a positive test for such substance based on samples taken from the animal immediately prior to or immediately after the racing of that animal." ) WHEREFORE, Petitioner respectfully requests the Division enter an Order imposing one or more of the following penalties as specified in Section 550.2415(3)(a), Florida Statutes: revoke or suspend the license or permit of the violator or deny a license or permit to the violator; impose a fine against the violator in an amount not exceeding $5,000; require the full or partial return of the purse, sweepstakes, and trophy of the race at issue; or impose against the violator any combination of such penalties. Signed this 11" day of May, 2006. Florida Bar Nurnber: 879622 Department of Business and Professional Regulation Northwood Centre 1940 North Monroe Street Tallahassee, FL 32399-2202 Copies furnished to: Office of Operations Licensing Section ; F | |. : i ‘Investigations Section Department of Business and Professional Regulation AGENCY CLERK curk Soy wh jp. (Wear nm pate_S Ll 200

Docket for Case No: 06-001781PL