FILED STATE OF FLORIDA Department of Business and Professional Regulation DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATI Deputy Agency Clerk DIVISION OF PARI-MUTUEL WAGERING CLERK vette Lawson-Proctor bete 12/7/2016 DEPARTMENT OF BUSINESS AND re PROFESSIONAL REGULATION, DIVISION OF PARI-MUTUEL WAGERING, Petitioner, DBPR CASE NO.: 2016-053887 Vv. NATASHA L. NEMETH, Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, the Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (“Petitioner”), and hereby files this Administrative Complaint against Respondent, NATASHA L. NEMETH (“Respondent”), and alleges as follows: 1. The 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 1615438-1021, issued by the Petitioner. 3. At all times material hereto, Respondent trained and raced greyhounds at Orange Park Kennel Club (““OPKC”). 4. | OPKC is a facility operated by a permitholder authorized to conduct pari-mutuel wagering in this state under Chapter 550, Florida Statutes. 5. At all times material hereto, Respondent was the trainer of record of the racing greyhound named “WW’S QUICK BRADLY,” tattoo number, 54A63843. 6. Pursuant to Section 550.2415(1)(a), Florida Statutes (2015), "[t]he 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 DBPR, PMW v. Natasha L. Nemeth DBPR Case No.: 2016-053887 Administrative Complaint Page 2 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." 7. 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.” 8. Rule 61D-6.002(1), Florida Administrative Code, provides, "[t]he trainer of record shall be responsible for and be the absolute insurer of the condition of the...racing greyhounds, he/she enters to race." 9. Pursuant to Rule 61D-6.007, Florida Administrative Code, the presence of Benzoylecogonine (a metabolite of cocaine), regardless of the concentration level, determined to be in the race-day specimen of a greyhound is strictly prohibited. 10. On or about October 27, 2016, “WW’S QUICK BRADLY” participated in the ninth 9") race held at OPKC; “WW’S QUICK BRADLY?” finished in the eighth (8) place. 11. On or about October 27, 2016, an employee of Petitioner collected a urine specimen sample, number 115111, from “WW’S QUICK BRADLY,” and the collected urine sample was forwarded to the University of Florida Racing Laboratory (“the lab”) for analysis. 12. The lab, in accordance with applicable procedures, tested urine sample number 115111, and found that it contained Benzoylecogonine, a metabolite of cocaine and classified as a Class One drug under the Uniform Classification Guidelines for Foreign Substances, revised December 2014, as promulgated by the Association of Racing Commissioners International, Inc. The concentration of Benzoylecogonine contained in the sample was 10 nanograms per milliliter. These results were issued to the Petitioner in a report dated November 23, 2016. A true and DBPR, PMW v. Natasha L. Nemeth DBPR Case No.: 2016-053887 Administrative Complaint Page 3 correct copy of the November 23, 2016, Drug Positive Letter is attached hereto and incorporated herein as Petitioner’s Exhibit “A.” 13. Under Rule 61D-6.007, F.A.C., the presence of Benzoylecogonine (a metabolite of cocaine), regardless of the concentration level, determined to be in the race-day specimen of a greyhound is strictly prohibited. 14. Based on the foregoing, Respondent, as “WW’S QUICK BRADLY” trainer of record, is strictly liable for, and thus is in violation of Section 550.2415(1)(a), Fla. Stat., by racing an animal that was determined to contain and test positive for a prohibited substance present in its race-day specimen. WHEREFORE, Petitioner respectfully requests the Division enter an Order against Respondent imposing one or more of the penalties specified in Rule 61D-6.012, F.A.C., and Section 550.2415(3)(a), Florida Statutes, together with any other relief the Division is authorized to impose pursuant to Chapter 550, Florida Statutes, and the rules promulgated thereunder. Signed on this 7th day of December, 2016. KEN LAWSON, Secretary Department of Business and Professional Regulation /s/_ Thomas J. Izzo THOMAS J. IZZO Florida Bar No.: 120905 In-House Counsel Division of Pari-Mutuel Wagering Department of Business and Professional Regulation 2601 Blair Stone Road Tallahassee, Florida 32399-2202 P: (850) 717-1768 F: (850) 921-1311 Tj.izzo@myfloridalicense.com DBPR, PMW v. Natasha L. Nemeth DBPR Case No.: 2016-053887 Administrative Complaint Page 4 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 (1.e., we do not receive) your request for hearing within the 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: 17-000877PL