FILED Department of Business and Professional Regulation Deputy Agency Clerk CLERK Evetle Lawson-Proctor Date 7/24/2019 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.: 2019-018241 v. JOSEPH J. RUMORE, IV, Respondent. / ADMINISTRATIVE COMPLAINT The Department of Business and Professional Regulation, Division of Pari-Mutuel Wagering (“Petitioner”), files this Administrative Complaint against Joseph J. Rumore, IV (“Respondent”), and alleges: 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 83265-1021, issued by Petitioner. 3. At all times material hereto, Respondent was the greyhound trainer for JR Racing, LLC, a racing kennel located at Bonita-Fort Myers Corporation d/b/a Naples-Fort Myers Greyhound Racing & Poker. 4. On or about March 14, 2019, Respondent failed to keep proof of vaccinations on file for eleven greyhounds under his care. 5. Rule 61D-6.009(8)(a), Florida Administrative Code, provides, in pertinent part: All racing animals shall be inoculated for infectious, contagious, and epizootic diseases including the following, and given boosters as recommended by veterinarians: 1. Canine: Each of the following, once per year: Distemper, Adenovirus (Hepatitis), Leptospirosis, Para-Influenza, Parvo, Bordetella bronchiseptica and Rabies. 6. Rule 61D-6.009(8)(b), Florida Administrative Code, provides, in pertinent part, “Proof of vaccination for each active or inactive racing greyhound must be kept on file by the kennel owner/operator, trainer of record and be subject to inspection by the Division.” 7. Based on the foregoing, Respondent violated Rules 61D-6.009(8)(a) and (b), Florida Administrative Code, by failing to keep proof of vaccinations on file for eleven greyhounds under his care at the JR Racing, LLC. WHEREFORE, Petitioner respectfully requests the Division Director enter an Order imposing against Respondent one or more of the penalties specified in chapter 550, Florida Statutes, and/or the rules promulgated thereunder. This Administrative Complaint for DBPR Case Number 2019-018241 is signed this 23rd day of July, 2019. ‘S/ James A. Lewis [s/ Megan S. Silver JAMES A. LEWIS MEGAN S. SILVER Assistant General Counsel Chief Attorney Florida Bar No. 1002349 Florida Bar No. 115518 James.Lewis@MyFloridaLicense.com Megan.Silver@MyFloridaLicense.com Office of the General Counsel Division of Pari-Mutuel Wagering Department of Business and Professional Regulation 2601 Blair Stone Road Tallahassee, Florida 32399-1035 Telephone: (850) 717-1585 Facsimile: (850) 921-1311 2019-018241 Page 2 of 3 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 representative, 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. Mediation under section 120.573, Florida Statutes, is not available to resolve this Administrative Complaint. 2019-018241 Page 3 of 3

Docket for Case No: 20-004341PL