Aug 18 2006 16:32 @a/1e/28686 16:29 8589211311 DEPR OGG PM PAGE @7/12 STATE OF FLORIDA ; DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF PARI-MUTUEL WAGERING DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF PARI-MUTUEL WAGERING, Petitioner, V5. DBPR Case No. 2006039141 CHAD E. MICHAUD, Respondent. / ADMINISTRATIVE COMPLAINT Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (hereinafter "Division”), files this Administrative Cormplaint against Chad E. Michaud (hereinafter "Respondent"), and alleges as follows: L. 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 16293-1021, 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. Cocaine is a Class 1 drug under the Uniform Classification Guidelines for Foreign Substances, as promulgated by the Association of Racing Commissioners International, Inc. Aug 18 2006 16:33 @a/1e/28686 16:29 8589211311 DEPR OGG PM PAGE 8/12 5. 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,” 6. Respondent was the trainer of record of a racing greyhound named “Ikes Trudy” on June 23, 2006. 7. On June 23, 2006, “Ikes Trudy” was entered in the seventh (7") race of the performance at CCC Racing. &. CCC Racing is a facility authorized to conduct pari-mutuel wagering in this state. 9. “Ikes Trudy” participated in the seventh (7") race of the performance at CCC Racing on June 23, 20006. 10. “Tkes Trudy” was immediately thereafter sent to a Division employee for the taking of a urine sample. ll. Urine sample number 169563 was collected from “Ikes Trudy” and was processed in accordance with established procedures and forwarded to the University of Flotida Racing Laboratory for analysis. 12. The University of Florida Racing Laboratory tested urine sample number 169563 and found it to contain Benzoylecgonine (a metabolite of Cocaine), and/or a derivative thereof. 13. The University of Florida Racing Laboratory tested urine sample number 169563 and found it to contain Eegonine Methy] Ester (a metabolite of Cocaine), and/or a derivative thereof, @a/1e/28686 16:29 Aug 18 2006 16:33 8589211311 DEPR OGG PM PAGE 9/12 14, Cocaine, or its metabolites Benzoyleogonine and Ecgonine Methy] Ester, and/ot derivatives thereof, is an impermissible substance that was carried in the body of “Ikes Trudy” while participating in the seventh (7") race of the performance at CCC Racing on June 23, 2006. 15. The concentration of Benzoylecgonine (a metabolite of Cocaine) found in urine sample number 169563, drawn from “Ikes Trudy” on June 23, 2006, is extraordinarily high. 16. Based on all the foregoing, Respondent has violated Section 550.2415(1)(a), Florida Statutes, which provides, "[tJhe 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, and as aggravated herein, Petitioner respectfully requests the Division enter an Order imposing a penalty as specified in Section 550.2415(3)(a), Florida Statutes. Signed this 28" day of JULY, 2006. M. Helton, Jr. fi hole J Pyacdyll Chief Attorney 900(0 Division of Pari-Mutuel Wagering ON - Florida Bar Number: 879622 DATE Department of Business and Professional Regulation Northwood Centre ‘ 1940 North Monroe Street Tallahassee, FL 32399-2202 Aug 18 2006 @a/1e/28686 16:29 8589211311 DEPR OGG PM PAGE 18/12 Copies furnished to: Respondent — Hand Service and Cert. Mail/Return Receipt Office of Operations Licensing Section Office of Investigations 3, Thomas Peavey Hoffer, Assistant General Counsel

Docket for Case No: 06-003045PL