FILED Department of Business arid Professional Regulation Deputy Agency Clerk STATE OF FLORIDA CLERK Tara Ashiock DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATI] pete 6/49/2017 File # DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, DIVISION OF PARI-MUTUEL WAGERING, DBPRCASENO.: — 2017-025746 Petitioner, V. EDWIN T. BROOME, Respondent. / ADMINISTRATIVE COMPLAINT The Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering, (‘Petitioner’), files this Administrative Complaint against Edwin T. Broome, (“Respondent”), and alleges as follows: 1. 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 1366314-1021, issued by Petitioner and worked as a horse trainer. 3. According to Section 550.2415(1), Florida Statutes: (a) The 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 animal or for an animal to have a prohibited substance present resulting in a positive test for such medication or substances based on samples taken from the animal before or immediately after the racing of that animal. (c) The 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. 4. Additionally, Rule 61D-6.002(1), Florida Administrative Code, provides that “[t]he trainer of record shall be responsible for and be the absolute insurer of the condition of the horses... he/she enters to race.” 5. On May 11, 2017, Respondent was the trainer of record for a racing horse named “MORE THAN A PARTY.” 6. On May 11, 2017, MORE THAN A PARTY was entered in race eight of Gulfstream Park’s afternoon performances. 7. Gulfstream Park is a permitholder authorized to conduct pari-mutuel wagering in this state in accordance with Chapter 550, Florida Statutes. 8. On May 11, 2017, “MORE THAN A PARTY finished in first place in race eight. 9. On May 11, 2017, a Division employee collected serum sample 048207 from MORE THAN A PARTY.” 10. Sample 048207 was processed in accordance with established procedures and forwarded to the University of Florida Racing Laboratory (“the lab”) for analysis. 11. The lab tested sample 048207 and found that it contained flunixin at a concentration of 42.9 +/- 1.9 ng/mL. 12. Flunixin is an anti-inflammatory analgesic and class 4 drug according to the Uniform Classification Guidelines for Foreign Substances, as promulgated by the Association of Racing Commissioners International, Inc. 13. According to Rule 61D-6.008(3)(a), Florida Administrative Code, flunixin detected at a concentration greater than 20 ng/mL in horse serum is prohibited. 14. Based on the foregoing, Respondent violated Section 550.2415(1)(a), Florida Statutes, by racing MORE THAN A PARTY with a prohibited drug, medication, stimulant, depressant, hypnotic, local anesthetic, or drug masking agent. WHEREFORE, Petitioner respectfully requests the division enter an Order imposing one or more of the penalties specified in Chapter 550, Florida Statutes, and/or the rules promulgated thereunder. Signed this 15™ day of June, 2017. /s/ Louis Trombetta LOUIS TROMBETTA Florida Bar No. 108119 Chief Attorney Division of Pari-Mutuel Wagering Office of the General Counsel Department of Business and Professional Regulation 2601 Blair Stone Road, 5 Floor Tallahassee, Florida 32399-2202 (850)-717-1508 Telephone Louis. Trombetta@MyF loridaLicense.com NOTICE OF RIGHT TO REQUEST A HEARING 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. NOTICE OF RIGHT TO REQUEST A SPLIT SAMPLE With respect to the “Report of Positive Result” from the University of Florida Racing Laboratory (UF Racing Laboratory) here supplied you and attached as Exhibit A to the Administrative Complaint, please be advised you have a right to request a split sample pursuant to Rule 61D-6.006, Florida Administrative Code, by submitting Form DBPR PMW-3290, Notification to Stewards/Judge of Split Sample Request. You can obtain Form DBPR PMW-3290, Notification to Stewards/Judge of Split Sample Request, as well as a list of approved split sample laboratories, at the State Office located in any Florida pari-mutuel facility or on the Division of Pari-Mutuel Wagering’s (Division) website: www.myfloridalicense.com/dbpr/pmw/forms.html. You must submit your Form DBPR PMW- 3290 split-sample request to the Division’s steward or judge within no more than ten (10) days from your receipt of this notice, or you will waive your right to a split sample. 6-16-17:00:419M PAW! 0 DATE Sclf/t 048207 SALIX (CHECK IF DECLARED) UNIVERSITY of ana. f1oke Than apart UF FLORIDA ee eee ace be College of Medicine FINISH. L_ RACE Department of Pathology, Immunology and Laboratory bie Zz . Racing Laboratory TRACK. i Th OWNER thar 1a Our ORT T_PAyoMR- May 26, 2017 rrainen_£- 7 - Broome Be TeEDO : SAMPLED BY_ OSTOLOZ4- ANU Mr. Anthony J, Glover, Director 2, , Division of Pari-Mutuel Wagering WITNESS K_\OrRwo7icdd ic Department of Business and Professional Regulation OWNER’S YID THeon 2601 Bialr Stone Road WITNESS (SIGNATURE) Tallahassee, FL 32399-1037 TATTOO NUMBER ONbSB: D . RE: Raport af Positive Result RL.172-03 Sample 048207 has been analyzed by liquid chromatography-tandem mass spectrometry (LC-MS/MS) and found 1o contain the fallowing: flunixin found in serum flunixin (an anti-intlammatory; analgesic and class 4 drug) - the concentration of flunixin is 42.9 4/- 1.9 ng/mL. C276313-FHB Horse Serum 10.89 INTACT Laboratory Number Specimen Final Weight Seal Gulfetream Park 05/11/2017 05/16/2017 Collected From Date Collected Date Received Pursuant to Chapter 550.2415 (1), £.S., the public disclosure of the information: contained in thls Report of Positive Result is authorized on or after 06/04/2017, or upon commencement of administrative action, whichever occurs first, Margaret fiding, FAORG : Patrick T. Russell Associate Director Chemist IV University of Fiorida Racing Lab |SOMEC 47025-2005 Cortificate # AT-1842 Page 1 of 1 . 17-252 The Foundation for The Gator Nation &n Equal Opportunity Insceuton EXHIBIT A

Docket for Case No: 19-004978PL