FILED Department of Business and Professional Regulation Deputy Agency Clerk CLERK Evetle Lawson-Proctor Date 2/19/2018 STATE OF FLORIDA File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF PARI-MUTUEL WAGERING DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF PARI-MUTUEL WAGERING, Petitioner, DBPR Case No.: 2018-001391 v. CRYSTAL A. ZWART, Respondent. / ADMINISTRATIVE COMPLAINT The Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (Petitioner), files this Administrative Complaint against Crystal A. Zwart (Respondent), and alleges as follows: 1. Petitioner is the state agency charged with regulating pari-mutuel wagering pursuant to Chapters 550, Florida Statues. Dh At all times material hereto, Respondent held a PMW Professional Individual Occupational License, number 7304947-1021, issued by the Petitioner. 3 At all times material hereto, Respondent was the trainer of record and owner for the T & A Kennels at Sarasota Kennel Club, Inc. 4. Sarasota Kennel Club, Inc. is a facility operated by a permitholder authorized to conduct pari-mutuel wagering in this state under Chapters 550, Florida Statutes. 5. On January 5, 2018, Petitioner’s investigator performed a routine facility inspection at the Sarasota Kennel Club, Inc. Page 1 of 3 6. During the inspection of Respondent’s Kennel, the investigation revealed that the greyhound roster was incomplete, and did not indicate the name and license number of persons transporting the racing greyhounds. 7. Rule 61D-2.023(3), Florida Administrative Code, states, in pertinent part, that: G) A roster is maintained to identify each racing greyhound housed in the kennel. The roster shall contain the following information: 1. Initial date of arrival; 2. Name and tattoo number of the racing greyhound; 3. Owner’s name; 4. Trainer’s name; 5. Kennel name; 6. Date of departure from the kennel; and 7. Name and license number of person transporting the racing greyhound. 8. Based on the foregoing, Respondent is in violation of Rule 61D-2.023(3), Florida Administrative Code, by failing to maintain a complete roster that includes the name and license number of persons transporting the racing greyhounds. WHEREFORE, Petitioner respectfully requests the Division Director enter an Order imposing against Respondent one or more of the penalties specified in Sections 550.105 and 550.0251, Florida Statutes, and/or any other relief that the Division is authorized to impose pursuant to Chapters 550, Florida Statutes, and/or the rules promulgated thereunder. [Signatures appear on the following page] Page 2 of 3 The administrative complaint in DBPR Case 2018-001391 is signed this 15th day of February, 2018. SAsL Louis Trombetta LOUIS TROMBETTA Chief Attorney Florida Bar No. 0108119 Louis. Trombetta@MyF loridaLicense.com Office of the General Counsel Division of Pari-Mutuel Wagering Department of Business and Professional Regulation 2601 Blair Stone Road, Mail Stop N21 Tallahassee, Florida 32399-2202 Telephone: (850)-717-1508 Facsimile: (850) 921-1311 NOTICE OF RIGHTS TO REQUEST A HEARING Pursuant to Section 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 Tepresentative, 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. Page 3 of 3

Docket for Case No: 18-004810PL