UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

OFFICE OF ADMINISTRATIVE LAW JUDGES

FTC DOCKET NO. D09418

ADMINISTRATIVE LAW JUDGE: D. MICHAEL CHAPPELL

CHIEF ADMINISTRATIVE LAW JUDGE

IN THE MATTER OF:

MILTON PINEDA APPELLANT

RESPONSE TO NOTICE OF APPEAL

AND APPLICATION FOR REVIEW

The Horseracing Integrity and Safety Authority (the “Authority”) files this Response to 

Appellant Milton Pineda’s Notice of Appeal and Application for Review. The Authority moves 

the Commission to uphold the imposition of sanctions (the “Imposed Sanctions”) by the 

Horseracing Integrity & Welfare Unit (“HIWU”) under the Authority’s Anti-Doping and Medical 

Control (“ADMC”) Program and deny Appellant’s request for an evidentiary hearing. In addition, 

Appellant’s request to stay the Imposed Sanctions during the pendency of the Administrative Law 

Judge’s (“ALJ”) review should be denied, as Appellant has made no effort to meet the four-prong 

test set forth in 16 CFR 1.148(d). 

The Imposed Sanctions in this case were not based upon a Final Decision of HIWU, the 

Arbitral Body, or the Internal Adjudication Panel. They were based upon an Admission of Equine 

Anti-Doping Rule Violations and Acceptance of Consequences (the “Admission”), which was 

signed by Mr. Pineda himself. (See Exhibit 1). The Admission states: “I admit that I have 

committed eight (8) Equine Anti-Doping (“EAD”) Rule Violations pursuant to Anti-Doping 

Medication Control (“ADMC”) Program Rule 3212, (Presence of a Prohibited Substance in a Post 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 1 of 54 * -PUBLIC 
2

Race Sample) under the Protocol and I accept the following Consequences”; those “following 

Consequences” are the Imposed Sanctions at issue here. It also states:

“I knowingly and voluntarily waive my right to a hearing under the 

Protocol. 

I acknowledge that I have the right to seek my own legal counsel. I 

acknowledge that I have either consulted with my own counsel 

regarding the terms and conditions of this agreement, or I knowingly 

and affirmatively waive the right to do so. 

By signing below, I acknowledge that I have read and fully 

understand this Admission of an EAD Rule Violations and 

Acceptance of Consequences form and admit to the above violations 

and accept the resulting Consequences set forth above.”

The Appellant was represented by counsel at the time that he executed the Admission. In fact, his 

counsel submitted the signed Admission to HIWU.

Prior to the Admission, under the ADMC Program Arbitration Procedures, Mr. Pineda 

requested a hearing before the Arbitral Body, which was initiated on August 22, 2023 (See Exhibit 

2), and Arbitrator Nancy Holtz was selected by JAMS (the administrator of the Arbitral Body) to 

hear the case. Instead of proceeding to a hearing under the ADMC Program, Mr. Pineda 

voluntarily signed the Admission. Based upon the Admission, notice of the Imposed Sanctions 

were served on Mr. Pineda on September 21, 2023. Between that date and the filing of this appeal, 

Appellant never contacted HIWU to request the withdrawal of Admission and/or to reassert his 

request for a hearing before the Arbitral Body. It is a request that HIWU would have permitted. 

(In fact, HIWU accepted such a withdrawal today. (See Exhibit 3).) Allowing the first evidentiary 

hearing at the appeal stage after the execution of the Admission would allow Mr. Pineda to 

improperly circumvent the procedures and process of the ADMC Program. He expressly waived 

his right to a hearing, and, as a result, forfeited all arguments on the merits as to whether he 

committed the eight ADMC Program violations at issue.

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 2 of 54 * -PUBLIC 
3

Appellant challenges the Imposed Sanctions and requests de novo review under 15 U.S.C. 

§ 3058(b)(l)-(3) and 16 C.F.R. 1.l 46(b) for multiple reasons. First, Appellant states that the

penalty assessed is “arbitrary, capricious, an abuse of discretion, prejudicial, or otherwise not in 

accordance with law.” The Imposed Sanctions were based upon the Admission, which was 

voluntarily signed by Mr. Pineda, who was free to refuse to sign it and move forward with the 

procedures before the Arbitral Body. He should not be able to “skip the line” and move straight 

to an evidentiary hearing before the Commission because he now has “buyer’s remorse.” That

result would allow Appellant to completely ignore a vital part of the ADMC Program, the 

Arbitration Procedures, and would be an assault on the integrity of the ADMC Program itself.

Such gamesmanship should not be permitted.

Second, Appellant argues that the “Imposed Sanctions” violate “accepted standards 

established in the decisional law of the FEI and CSA as to how the punishment must follow and 

be commensurate with the violation.” The Admission which provided the basis for the Imposed 

Sanctions is consistent with, and complies with, the requirements of the ADMC Program with 

respect to Consequences and the determination of Anti-Doping Rules Violations. In addition, this 

is not the proper forum to challenge the requirements of the ADMC Program itself, which are 

federal regulations that have been approved by the Commission.

Lastly, Appellant claims that the Imposed Sanctions are unconstitutional under the Eighth 

Amendment. This is also not the proper forum for any claims that the ADMC Program or the 

provisions thereof are unconstitutional. However, the Authority again notes that Appellant was 

free to reject the Admission and not accept the Consequences include therein. 

For the reasons set forth above, the Imposed Sanctions should be upheld and Appellant’s 

request for an evidentiary hearing should be denied. If Appellant wishes to withdraw his 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 3 of 54 * -PUBLIC 
4

Admission, the Authority will accept that withdrawal and re-initiate the Arbitration Procedures

before the ADMC Program’s Arbitral Body.

ALL OF WHICH IS RESPECTFULLY SUBMITTED THIS 23rd day of October, 2023.

STURGILL, TURNER, BARKER, &

MOLONEY, PLLC

/s/ Bryan Beauman

BRYAN BEAUMAN

REBECCA PRICE

333 W. Vine Street, Suite 1500

Lexington, Kentucky 40507

Telephone: (859) 255-8581

bbeauman@sturgillturner.com

rprice@sturgillturner.com

HISA ENFORCEMENT COUNSEL

CERTIFICATE OF SERVICE

I hereby certify that on October 23, 2023, pursuant to Federal Trade Commission Rules

of Practice 4.2(c) and 4.4(b), I caused the foregoing Response to Notice of Appeal to be filed and 

served as follows:

Hon. D. Michael Chappell

Chief Administrative Law Judge

Office of Administrative Law Judges

Federal Trade Commission

600 Pennsylvania Ave. NW

Washington DC 20580

Via e-mail to OALJ@ftc.gov

April Tabor

Office of the Secretary

Federal Trade Commission

600 Pennsylvania Ave. NW

Washington, DC 20580

Via email to electronicfilings@ftc.gov

Darrell J. Vienna CA SBN: 163794

5256 S. Mission Road, Ste. 703-808

Bonsall, CA 92003

626.590.9999

horselawyer@gmail.com

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 4 of 54 * -PUBLIC 

PUBLIC
5

Carlo Fisco CA SBN: 166274

P.O. Box 2554

Culver City, CA 90231

310.390.3311

cfisco@aol.com

/s/Bryan Beauman

Counsel for Horseracing Integrity and Safety

Authority

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 5 of 54 * -PUBLIC 

2 

and other compensation, prizes, trophies, points, and rankings and repayment or surrender 

(as applicable) of such to the Race Organizer (ADMC Program Rule 3221); 

4. Disqualification of the results of Bella Renella obtained on June 18, 2023, with resulting

Consequences of Disqualification of results including forfeiture of all purses and other

compensation, prizes, trophies, points, and rankings and repayment or surrender (as

applicable) of such to the Race Organizer (ADMC Program Rule 3221);

5. Disqualification of the results of Chollima obtained on June 23, 2023 and July 4, 2023,

with resulting Consequences of Disqualification of results including forfeiture of all purses

and other compensation, prizes, trophies, points, and rankings and repayment or surrender

(as applicable) of such to the Race Organizer (ADMC Program Rule 3221);

6. Disqualification of the results of Catbernay obtained on July 1, 2023, with resulting

Consequences of Disqualification of results including forfeiture of all purses and other

compensation, prizes, trophies, points, and rankings and repayment or surrender (as

applicable) of such to the Race Organizer (ADMC Program Rule 3221);

7. Disqualification of the results of Keep Your Coil obtained on July 2, 2023, with resulting

Consequences of Disqualification of results including forfeiture of all purses and other

compensation, prizes, trophies, points, and rankings and repayment or surrender (as

applicable) of such to the Race Organizer (ADMC Program Rule 3221); and

8. Disqualification of the results of Wegonahavagoodtime obtained on July 4, 2023, with

resulting Consequences of Disqualification of results including forfeiture of all purses and

other compensation, prizes, trophies, points, and rankings and repayment or surrender (as

applicable) of such to the Race Organizer (ADMC Program Rule 3221).

9. A fine of $100,000.00 ($12,500 per violation) in accordance with ADMC Program Rule

3223;

10. A 12 year (144 month) period of Ineligibility (18 months per violation) in accordance with

ADMC Program Rule 3223; and

11. Public reporting in accordance with ADMC Program Rule 3610(b) and Public Disclosure

in accordance with ADMC Program Rule 3620.

I understand that during my period of Ineligibility, my Covered Horses cannot participate

in any Timed and Reported Workouts or Covered Horseraces. I understand I may engage in caring 

for and exercising my Covered Horses. In addition, I understand that I: (i) must take down or cover 

any personal signage bearing my name where the Covered Horses are located at the racetrack; (ii) 

cannot claim Covered Horses or bring new Covered Horses into my barn; and (iii) cannot be 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 7 of 54 * -PUBLIC 
3 

employed in any capacity involving Covered Horses (including, but not limited to, acting as an 

agent for an Owner of Covered Horses or working as an exercise rider for Covered Horses.) 

As a Trainer, I understand that my Covered Horse(s) may not participate in any Timed and 

Reported Workout or Covered Horserace unless and until they have been transferred to another 

Responsible Person. For the “transfer” to be valid, I understand it must be (i) approved by the 

stewards, and (ii) registered with HISA. If I am an Owner of any Covered Horses, I understand 

that ownership of the Covered Horse must be transferred in order for it to be eligible to participate 

in any Timed and Reported Workout or Covered Horserace. Failure to comply may result in an 

Anti-Doping Rule Violation under Rule 3216(c). 

If, during the period of Ineligibility, I violate the prohibition against participation as

described in ADMC Program Rule 3229 (Protocol), I understand that any results obtained from 

such participation shall be Disqualified and a new period of Ineligibility equal in length to the 

original period of Ineligibility shall be added to the end of my original period of Ineligibility. By 

admitting the EAD Rule Violations and accepting the Consequences, I agree that HIWU shall 

determine whether there has been a violation of the prohibition against participation and apply the 

appropriate consequences pursuant to ADMC Program Rule 3261 (Protocol). 

I understand that to be reinstated I must have respected the period of Ineligibility and repaid 

or surrendered any purses and other compensation, prizes, trophies, points, and rankings forfeited, 

and paid any fines and reimbursed any costs imposed or accepted to HIWU, unless an installment 

plan was established pursuant to ADMC Program Rule 3232(b) (Protocol), in which case I must 

have made all payments due under that plan. Where fairness requires, HIWU or the Arbitral Body 

may establish an installment plan for repayment of amounts due to be paid or reimbursed under 

the Protocol. The payment schedule may extend beyond any period of Ineligibility imposed upon 

me. 

Where fairness requires, the Horseracing Integrity & Welfare Unit (“HIWU”) or the 

Arbitral Body may establish an installment plan for repayment of amounts due to be paid or 

reimbursed under the Protocol. The payment schedule may extend beyond any period of 

Ineligibility imposed upon me.

If any installment(s) subsequently become(s) overdue under that plan (i.e., after 

reinstatement), myself and the Covered Horse(s) under my ownership and/or training may not 

participate in any Timed and Reported Workout or Covered Horserace until such overdue 

installment(s) is/are paid in full. An installment plan can be requested from the HIWU attorney 

that handled your matter. 

I acknowledge and understand that HIWU will communicate the Decision related to my 

admission of the EAD Rule Violations and my acceptance of the Consequences to the Horseracing 

Integrity and Safety Authority (“HISA”). 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 8 of 54 * -PUBLIC 


Horseracing Integrity & Welfare Unit • 4801 Main Street, Suite 350 • Kansas City, Missouri 64112-2749 • T +011 816 285 1425 •

hiwu.org

Sincerely, 

Encls.: EAD Notice Letters 

EAD Charge Letters 

Allison J. Farrell 

cc (w/ encls.): Counsel for Covered Person, Darrell Vienna 

HISA

Lizbeth Medina, Owner of Bella Renella, Wegonahavagoodtime per HISA portal 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 11 of 54 * -PUBLIC 
Horseracing Integrity & Welfare Unit • 4801 Main Street, Suite 350 Kansas City, Missouri 64112-2749 • T +011 816 474 8655 •

hiwu.org

CONFIDENTIAL

Allison J. Farrell

Senior Litigation Counsel 

 Horseracing Integrity & Welfare Unit

4801 Main Street 

Suite 350 

Kansas City, MO 64112-2749 

July 6, 2023

DELIVERED VIA PERSONAL SERVICE

Milton Pineda 

 

Re: EAD Notice of Alleged Anti-Doping Rule Violation 

Covered Horse: Bella Renella

Sample #U100331404 

Dear Mr. Pineda, 

This Equine Anti-Doping (“EAD”) Notice letter is issued pursuant to Anti-Doping 

Medication Control (“ADMC”) Program Rule 3245 of the Protocol (defined below) and serves to 

inform you that a Sample collected from the Covered Horse Bella Renella as part of a Sample 

Collection Session conducted under the authority of the Horseracing Integrity & Welfare Unit 

(“HIWU”) has resulted in an Adverse Analytical Finding (“AAF”) and may result in Anti-Doping 

Rule Violation(s) and related Consequences. The violations, as described below, may only be 

committed by Covered Persons, but the Consequences may apply to both you and Bella Renella. 

I. Anti-Doping Rules - General

You and Bella Renella are subject to the Equine Anti-Doping and Controlled Medication

Protocol codified as Rule Series 3000 of the ADMC Program (the “Protocol”), including its 

supporting rules and documents. Results Management of this matter is the responsibility of HIWU. 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 12 of 54 * -PUBLIC 
 July 6, 2023 | Page 2 of 6

HIWU conducts Results Management in accordance with ADMC Program Rule 3240 of the 

Protocol and the Equine Testing and Investigations Standards. Capitalized terms used, but not 

defined within this letter, are as defined in Rule 1020 of the General Provisions and the Protocol. 

II. Alleged Anti-Doping Rule Violation(s) and Potential Consequences - Specific

Specifically, as a Responsible Person as defined in ADMC Program Rule 3030 of the

Protocol, ADMC Program Rule 3212 holds you strictly liable for any Banned Substance and/or its 

Metabolites or Markers present in a Sample collected from your Covered Horse(s). Pursuant to 

the Protocol, the AAF may result in the following Anti-Doping Rule Violation(s): Presence of a 

Banned Substance and/or its Metabolites or Markers (ADMC Program Rule 3212) – 

Diisopropylamine. 

If it is agreed or determined that an Anti-Doping Rule Violation has occurred, the following 

Consequences may be imposed pursuant to ADMC Program Rules 3221, 3222, and 3223,

including, but not limited to, Disqualification of Covered Horse’s results; forfeiture of 

compensation, prizes, purses, trophies, points, and rankings; fines; a period of two years of

Ineligibility for you and a period of up to fourteen (14) months of Ineligibility for Bella Renella; a 

fine of up to $25,000 USD or 25% of the purse, whichever is greater; payment of adjudication 

costs and some or all of HIWU’s legal fees; and Public Disclosure pursuant to ADMC Program 

Rule 3620 of the Protocol. 

Note that, in the event that Bella Renella’s results are subject to automatic Disqualification 

under ADMC Program Rule 3221(a) of the Protocol, the Responsible Person, the Owner, and 

HIWU may agree to apply ADMC Program Rule 3221 (Protocol) immediately or any one of them 

may request that the Arbitral Body apply ADMC Program Rule 3221 (Protocol) immediately. 

III. AAF Testing and Results

On June 18, 2023, Sample Collection Personnel collected a urine Sample, designated as

Sample #U100331404 from Bella Renella Post Race from Race 4 at Santa Anita Park. Bella 

Renella’s A Sample was submitted the Kenneth L. Maddy Analytical Chemistry Laboratory (“UC 

Davis Lab”) in Davis, CA for analysis. The UC Davis Lab analyzed the A Sample in accordance 

with the Equine Standards for Laboratories and Accreditation and reported an AAF because it 

detected Diisopropylamine. Diisopropylamine is a category S0 Banned Substance on the 

Prohibited List and Technical Document–Prohibited Substances. The UC Davis Lab’s A Sample 

certificate of analysis is enclosed for your reference, as well as a copy of the Sample Collection 

Documentation. 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 13 of 54 * -PUBLIC 
 July 6, 2023 | Page 3 of 6

You, as the Responsible Person, and the Owner of Bella Renella both have the right to 

receive copies of the A Sample Laboratory Documentation Package after the B Sample analysis 

has been completed or the analysis of the B Sample is waived. The details regarding the B Sample

are set forth below. 

IV. B Sample Analysis

You and the Owner have the right to request the analysis of the B Sample. You or the

Owner will be required to pay the cost, in advance, to have the B Sample analyzed and B Sample 

Laboratory Documentation Package prepared. If you or the Owner would like the B Sample 

analyzed, please submit a request, in writing, to results@hiwu.org by July 11, 2023, on or before 

5pm CST. If such request is not made by the deadline, then the B Sample analysis will be deemed 

waived.

Provided HIWU receives a request by July 11, 2023, on or before 5pm CST, HIWU will 

notify you and the Owner, in writing, of the scheduled date, time, and Laboratory where the B 

Sample analysis will be completed, the amount due, and date on which the payment must be 

received. Payment for the analysis must be received by HIWU before the Laboratory will begin 

such analysis. Please submit your payment on the Horseracing Integrity and Safety Authority’s 

(“HISA”) online portal. If such payment is not made on time, then the B Sample analysis will be 

deemed waived.

You and the Owner, if agreed upon, may waive analysis of the B Sample and accept the A 

Sample results. If you and the Owner choose to accept the A Sample results, please sign the 

enclosed Acceptance of A Sample Results and B Sample Waiver Form and return it to 

results@hiwu.org no later than July 11, 2023. Please note that, regardless of said waiver, HIWU 

retains the right to proceed with the B Sample analysis at its own expense.

V. Provisional Suspension

As required by ADMC Program Rule 3247(a)(1) of the Protocol, HIWU has imposed a

Provisional Suspension on you as the Responsible Person and Bella Renella effective as of today, 

July 6, 2023. Bella Renella may not participate in any Timed and Reported Workout or Covered 

Horserace and shall remain subject to Testing. You may not participate in any capacity in any 

activity involving Covered Horses, or in any other activity (other than authorized anti-doping 

education or rehabilitation programs) taking place at a Racetrack or Training Facility, or permit 

anyone to participate in any capacity on your behalf in any such activities, except to the extent that 

you are an Owner and the activity is necessary to ensure the safekeeping and wellbeing of the 

horse during the Provisional Suspension. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 14 of 54 * -PUBLIC 

PUBLIC
 July 6, 2023 | Page 4 of 6

As a Trainer, your Covered Horse(s) may not participate in any Timed and Reported 

Workout or Covered Horserace unless and until your Covered Horse(s) have been transferred to 

another Covered Person. For the ‘transfer’ to be valid, (i) it must be registered with HISA, and (ii) 

the Covered Horse(s) must be physically relocated to facilities under the care or control of a 

Covered Person who is not affiliated with you. Failure to comply may result in an Anti-Doping 

Rule Violation under ADMC Program Rule 3216(c) of the Protocol. To transfer your Covered 

Horse(s), please contact Linda Lankester, System Integrity & Operations Assistance at HISA, at 

(859) 514-0287. Please be advised that, during your Provisional Suspension, you will not have

access to the full functionality of the HISA Portal.

Additionally, the Covered Horse of an Owner who is subject to Provisional Suspension or 

period of Ineligibility may not participate in any Timed and Reported Workout or Covered 

Horserace unless they have been transferred in a bona fide transaction to a different Owner. If an 

Immediate Family Member has any ownership or property interest in the Covered Horse following 

such transfer, the transfer shall not constitute a bona fide transaction to a different Owner. 

You, on your own behalf and on behalf of Bella Renella, have the opportunity for a 

Provisional Hearing on a timely basis after imposition of the Provisional Suspension or an 

opportunity for an expedited hearing in accordance with ADMC Program Rule 3262 (Protocol) on 

a timely basis after imposition of the Provisional Suspension. 

Please inform HIWU, in writing, by July 11, 2023, on or before 5pm CST if you intend 

to exercise your right to a Provisional Hearing. Provisional Hearings will be conducted by the 

Arbitral Body and heard via telephone or video conference. Arbitral Body will only make a 

determination regarding whether HIWU’s decision to impose a Provisional Suspension shall be 

maintained; the Arbitral Body will not take up any other issues in the Provisional Hearing. ADMC 

Program Rule 3247(c) (Protocol) requires that HIWU’s decision to impose a Provisional 

Suspension shall be maintained unless the Responsible Person/Covered Person requesting the 

lifting of the Provisional Suspension establishes one of the four criteria set forth in ADMC 

Program Rule 3247(c)(1-4) (Protocol). Note that if you and Bella Renella respect the Provisional 

Suspension, the time served under the Provisional Suspension will be credited against any period 

of Ineligibility that may ultimately be imposed.

If you or Bella Renella intends to participate in a Covered Horserace within forty-five (45) 

days, HIWU may, in its sole discretion, choose to address the case on an expedited basis to ensure 

resolution of the matter prior to the Covered Horserace. Please notify HIWU, in writing, 

immediately if you or Bella Renella intends to participate in any Covered Horserace within fortyfive (45) days. 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 15 of 54 * -PUBLIC 
 July 6, 2023 | Page 5 of 6

VI. Resolution and Your Rights Under the Protocol: Substantial Assistance, Early

Admission, and Explanation

In accordance with ADMC Program Rule 3226 of the Protocol, you have the opportunity

to provide Substantial Assistance or admit the alleged Anti-Doping Rule Violation(s) with the 

potential benefit of receiving a reduction to any period of Ineligibility that may be imposed. 

Further, you may seek to enter into a case resolution without a hearing pursuant to ADMC Program 

Rule 3249 (Protocol). In this case, early admittance and acceptance of the violations under ADMC 

Program Rule 3226(d)(2) would reduce your period of Ineligibility by six (6) months. Please note, 

at any time during or after the Results Management of your matter, you can provide Substantial 

Assistance and HIWU will evaluate if a suspension of all or part of any resulting Consequences is 

appropriate. 

At this time prior to the issuance of formal charges, you have the opportunity to provide an 

explanation to HIWU. Please submit all applicable information along with your explanation to

HIWU’s Senior Litigation Counsel, Allison Farrell, by email to afarrell@hiwu.org by July 13, 

2023. Furthermore, if you seek to enter into a case resolution without a hearing, please notify 

HIWU, in writing, immediately.

VII. Other Information

As a reminder, Bella Renella remains subject to Testing pending the outcome of this matter.

Pursuant to ADMC Program Rule 3610(b) of the Protocol, HIWU will use its reasonable

endeavors to ensure that Persons under its control do not publicly identify Covered Horses or 

Covered Persons who are alleged to have committed a violation under the Protocol, unless and 

until: (i) in presence cases, the B Sample confirms the results of the A Sample analysis, or the B 

Sample analysis is waived; (ii) a Provisional Suspension has been imposed or voluntarily accepted; 

(iii) a charge has been brought; or (iv) a violation has been admitted, whichever is earlier. In such

circumstances (except where the Covered Person is a Minor), HIWU shall publicly report: (i) the

identity of any Covered Person who is the subject of the alleged violation; (ii) the identity of any

relevant Covered Horses(s); and (iii) the rule violated and, where appropriate, the basis of the

asserted violation. HIWU shall not be required to publicly report a matter if it would risk

compromising an ongoing investigation or proceeding. If HIWU determines that an ongoing

investigation or proceeding will no longer be compromised by public reporting, HIWU shall at

such time make any public reporting. HIWU shall Publicly Disclose the resolution of an alleged

violation of the Protocol in accordance with ADMC Program Rule 3620.

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 16 of 54 * -PUBLIC 
 July 6, 2023 | Page 6 of 6

By copy of this EAD Notice letter, HIWU is notifying HISA and the California 

Horseracing Board. 

Please read this EAD Notice letter carefully and take note of the deadlines set forth herein. 

You have the right to contact an attorney of your choosing in an effort to seek legal advice, should 

you desire to do so. If you have any questions regarding this letter, please contact me at (816) 602-

0945 or afarrell@hiwu.org. 

Sincerely,

Allison J. Farrell

Senior Litigation Counsel 

Encls.: A Sample Certificate of Analysis

Sample Collection Documentation 

B Sample Analysis Waiver Form

cc (w/ encls.): California Horseracing Board

John Roach, HISA 

Samuel Reinhardt, HISA 

Lisa Lazarus, HISA

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 17 of 54 * -PUBLIC 

PUBLIC


Version 2/2023 WHITE copy = HIWU YELLOW = Laboratory

NOTICE OF SELECTION: POST-RACE TESTING 

Pursuant to HIWU Regulations: 

The Covered Horse named on this form is required to undergo Sample collection. The Covered Horse must be brought to the Test Barn as soon as 

practicable, unless there are valid reasons for delay (as determined by Sample Collection Personnel). 

As the Nominated/Responsible Person, your responsibilities are: 

▪ To report to the Test Barn located on the backside of this racetrack;

▪ To comply and cooperate with Sample collection procedures and processes, your failure of which may result in significant penalties;

▪ To ensure that the Covered Horse remains under continuous observation of the Sample Collection Personnel, to the extent possi ble, until the

completion of the Sample collection process;

▪ To remain with the Covered Horse, to the extent possible, until completion of the Sample collection process;

▪ On request, to produce identification for yourself and facilitate the identification of the Covered Horse;

▪ To ensure that the Covered Horse is not administered any medications or supplements from notification of Sample collection until completion of

the Sample collection process, unless there is a medical emergency (as determined by the Test Barn Veterinarian or a Regulatory Veterinarian);

▪ TR FRQILUP WKDW WKH CRYHUHG HRUVH’V ZDWHU EXFNHW LV FOHDQ DQG DFFHSWDEOH DQG HQVXre that it is only used for your Covered Horse during the Sample

collection process.

AVISO DE SELECCIÓN: RECOLECCIÓN DE PRUEBAS DESPUES DE LA CARRERA 

De acuerdo con las regulaciones de HIWU: 

El Caballo cubierto mencionado en esta forma debe someterse a la recolección de muestras. El caballo cubierto debe llevarse al establo de prueba tan 

pronto como sea posible, a menos que existan razones válidas para demorarse (según lo determine el personal de recolección de muestras). 

Como Persona Designada/Responsable, sus responsabilidades son: 

▪ Presentarse al Establo de Pruebas ubicado en la parte trasera del hipódromo;

▪ Cumplir y cooperar con los procedimientos y procesos de recolección de Muestras, incumplimiento puede resultar en sanciones significativas;

▪ Garantizar que el Caballo cubierto permanezca bajo la observación continua del Personal de recolección de Muestras, en la medida posible, en todo

momento hasta la finalización del proceso de recolección de Muestras;

▪ Permanecer con el Caballo cubierto, lo más posible, hasta que se complete el proceso de recolección de Muestras;

▪ Bajo pedido, debe presentar identificación de usted y facilitar la identificación del Caballo cubierto;

▪ Asegurarse de que al Caballo cubierto no se le administren medicamentos o suplementos desde la notificación de la recolección de Muestras hasta la

finalización del proceso de recolección de Muestras, a menos que haya una emergencia médica (según lo determine el Veterinario del Establo de

pruebas o un Veterinario regulador);

▪ Confirmar que el balde de agua del Caballo cubierto esté limpio y aceptable y asegurarse de que solo se use para su Caballo cubierto durante el

proceso de recolección de muestras.

NOTICE OF SELECTION: OUT-OF-COMPETITION TESTING

Pursuant to HIWU Regulations: 

The Covered Horse named on this form is required to undergo Sample collection. Immediate access to the Covered Horse shall be granted and the 

Sample collection process shall take place immediately in a secure location, unless there are valid reasons for delay (as determined by Sample Collection 

Personnel). Failure to produce the Covered Horse for Sample collection within six (6) hours of notification may result in significant penalties for the 

Responsible Person. 

As the Nominated/Responsible Person, your responsibilities are: 

▪ To comply and cooperate with Sample collection procedures and processes, your failure of which may result in significant penalties;

▪ To ensure that the Covered Horse remains under continuous observation of the Sample Collection Personnel at all times until the completion of

the Sample collection process;

▪ To remain with the Covered Horse until completion of the Sample collection process;

▪ On request, to produce identification for yourself and facilitate the identification of the Covered Horse;

▪ To ensure that the Covered Horse is not administered any medications or supplements from notification of Sample collection until completion of

the Sample collection process, unless there is a medical emergency (as determined by a Regulatory Veterinarian, or, if not available, a Veterinarian).

AVISO DE SELECCIÓN: RECOLECCIÓN DE PRUEBAS FUERA DE COMPETICIÓN

De acuerdo con las regulaciones de HIWU: 

El Caballo cubierto mencionado en esta forma debe someterse a la recolección de muestras. Debe otorgarnos acceso inmediato al Caballo cubierto, el 

proceso de recolección de muestras se llevará a cabo de inmediato en un lugar seguro, a menos que existan razones válidas para demorarse (según lo 

determine el Personal de recolección de muestras). Falta de no presentar el Caballo cubierto para la recolección de muestras dentro de las seis (6) horas 

posteriores a la notificación puede resultar en sanciones significativas para la Persona responsable. 

Como Persona Designada/Responsable, sus responsabilidades son: 

▪ Cumplir y cooperar con los procedimientos y procesos de recolección de Muestras, incumplimiento puede resultar en sanciones significativas;

▪ Garantizar que el Caballo cubierto permanezca bajo la observación continua del Personal de recolección de Muestras en todo momento hasta la

finalización del proceso de recolección de Muestras;

▪ Permanecer con el Caballo cubierto hasta que se finalize el proceso de recolección de Muestras;

▪ Bajo pedido, presentar una identificación de usted y facilitar la identificación del Caballo cubierto;

▪ Asegurarse de que al Caballo cubierto no se le administren medicamentos o suplementos desde la notificación de la recolección de Muestras hasta la

finalización del proceso de recolección de Muestras, a menos que haya una emergencia médica (según lo determine un Veterinario regulador o, si no 

está disponible, un Veterinario).

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 20 of 54 * -PUBLIC 

PUBLIC
Horseracing Integrity & Welfare Unit • 4801 Main Street, Suite 350 Kansas City, Missouri 64112-2749 • T +011 816 474 8655 •

hiwu.org

 

Covered Horse: Bella Renella

Responsible Person: Milton Pineda 

Sample #U100331404 

Owner: Milton Pineda 

_______________________________________________________________________________ 

I accept the result of the Kenneth L. Maddy Analytical Chemistry Laboratory (“UC Davis 

Lab”) in Davis, CA that Bella Renella’s urine Sample #U100331404, collected Post-Race from

Race 4 on June 18, 2023 at Santa Anita Park, was reported as an Adverse Analytical Finding 

(“AAF”) because it detected Diisopropylamine. 

I understand that in accordance with the Equine Anti-Doping and Controlled Medication 

Protocol, Bella Renella’s Sample #U100331404 shall not be considered an AAF until the B Sample 

analysis confirms the A Sample analysis, the Responsible Person or the Owner does not timely 

request the B Sample analysis, or the Responsible Person and the Owner, if agreed upon, waive

the B Sample analysis by signing this form. I understand that the UC Davis Lab’s result is based 

on the analysis of the A Sample of Sample #U100331404 only. 

I understand that I have the right to have the B Sample analysis completed and I voluntarily, 

knowingly, and intelligently waive the right to have the B Sample analysis completed. I do not 

contest the UC Davis Lab’s results of Bella Renella’s Sample #U100331404. 

____________________________________ _______________________ 

Signature of Responsible Person Date

____________________________________ 

Printed Name of Responsible Person 

____________________________________ _______________________ 

Signature of Owner Date

____________________________________ 

Printed Name of Owner 

Acceptance of A Sample Analytical Results and B Sample Analysis Waiver Form

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 21 of 54 * -PUBLIC 
Horseracing Integrity & Welfare Unit • 4801 Main Street, Suite 350 Kansas City, Missouri 64112 • T +011 816 474 8655 •

hiwu.org

CONFIDENTIAL

Allison J. Farrell

Senior Litigation Counsel 

 Horseracing Integrity & Welfare Unit

4801 Main Street 

Suite 350 

Kansas City, MO 64112-2749 

July 21, 2023

DELIVERED VIA EMAIL

Darrell J. Vienna 

5256 S. Mission Road, Suite 723 

Bonsall, CA 92003 

Horselawyer@gmail.com

(626) 590-9999

Counsel For: 

Milton Pineda 

Re: EAD Charge of Anti-Doping Rule Violation 

Covered Horse: Bella Renella

Sample #U100331404 

Dear Mr. Pineda: 

You were notified on July 6, 2023 that Bella Renella’s A Sample was submitted to the

Kenneth L. Maddy Analytical Chemistry Laboratory (“UC Davis Lab”) in Davis, CA for analysis. 

The UC Davis Lab reported an Adverse Analytical Finding (“AAF”) because it detected 

Diisopropylamine. Because you did not request the analysis of Bella Renella’s B Sample by the 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 22 of 54 * -PUBLIC 
July 21, 2023 | Page 2 of 7

deadline, the B Sample was not analyzed and your opportunity to request the analysis of the B 

Sample has been waived. 

I. Charge and Proposed Consequences

In the initial Equine Anti-Doping (“EAD”) Notice letter, HIWU invited you to provide an

explanation regarding Bella Renella’s reported AAF. As we did not receive any explanation from 

you, HIWU is satisfied that you have committed Anti-Doping Rule Violation(s). This EAD Charge 

Letter is issued pursuant to Anti-Doping Medication Control (“ADMC”) Program Rule 3248 of 

the Equine Anti-Doping and Controlled Medication Protocol (the “Protocol”) and constitutes 

formal notice that HIWU is charging you with Anti-Doping Rule Violation(s) for the (i) Presence 

of Diisopropylamine in Bella Renella’s urine Sample collected Post-Race on June 18, 2023 at Race 

4, at Santa Anita Park.

Our records indicate that you have no prior Anti-Doping Rule Violations. Therefore,

HIWU is seeking imposition of the following proposed Consequences: 

• Disqualification of the results of Bella Renella subsequent to June 18, 2023, and any

period of retroactive Ineligibility, including forfeiture of all purses and other

compensation, prizes, trophies, points, and rankings and repayment or surrender (as

applicable) to the Race Organizer (ADMC Program Rule 3221) (Protocol);

• A period of Ineligibility of 14 months for Bella Renella, beginning on June 18, 2023

(ADMC Program Rule 3222) (Protocol);

• A period of Ineligibility of 2 years, for you as a Covered Person, beginning on July 6,

2023, the date you received notice of your Provisional Suspension (ADMC Program

Rule 3223) (Protocol);

• A fine of USD 25,000 or 25% of the total purse (whichever is greater) and payment of

some or all of the adjudication costs and HIWU’s legal costs (ADMC Program Rule

3223) (Protocol);

• Public disclosure in accordance with Rule 3620 (ADMC Program Rule 3231)

(Protocol); and

• All other Consequences which may be required by the Protocol, including its

supporting rules and documents.

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 23 of 54 * -PUBLIC 
July 21, 2023 | Page 3 of 7

Please be advised that in accordance with ADMC Program Rule 3227 of the Protocol, your 

period of Ineligibility can be increased by up to two (2) additional years and an additional fine of 

up to USD 10,000 or an additional 10% of the total purse (whichever is greater) for Aggravating 

Circumstances.

II. Your Options Under the Protocol

A. Rights Provided by ADMC Program Rule 3248(d).

Under ADMC Program Rule 3248(d) of the Protocol you as the Covered Person, on or 

before 5pm CST on July 28, 2023, can either: 

Admit the Anti-Doping Rule Violation(s) charged and: 

(i) accept the Consequences proposed by HIWU, in which case HIWU will

issue a decision under ADMC Program Rule 3249(b) of the Protocol;

(ii) seek to agree to mitigated Consequences with HIWU pursuant to ADMC

Program Rule 3249 (Protocol), failing which the Consequences may still be

disputed at a hearing; or

(iii) dispute or seek to mitigate the proposed Consequences at a hearing in

accordance with ADMC Program Rule 3261 (Protocol) and the Arbitration

Procedures; or

Deny the Anti-Doping Rule Violation(s) charged and dispute the proposed Consequences 

at a hearing in accordance with ADMC Program Rule 3261 (Protocol) and Arbitration Procedures. 

B. Further Detail on Resolution Options.

(i) Early Admittance and Acceptance – You have the right to an automatic

6 month reduction in your 2 year period of Ineligibility by making an early

admittance of the alleged violation(s) and accepting the mandated Period of

Ineligibility within seven (7) calendar days of the date of this EAD Charge

Letter, which deadline is 5PM CST on July 28, 2023. Pursuant to ADMC

Program Rule 3226 of the Protocol, no further reduction shall be allowed

under any other Rule. See enclosed Early Admittance and Acceptance

Form.

(ii) Case Resolution Without a Hearing – Pursuant to ADMC Program Rule

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 24 of 54 * -PUBLIC 
July 21, 2023 | Page 4 of 7

3249(a) (Protocol), a Covered Person has the right – at any time prior to a 

Final Decision under the Arbitration Procedures – to agree to admit the 

violation(s) charged and accede to specified Consequences consistent with 

the Protocol. In this event, HIWU will issue a Final Decision confirming 

the commission of the Anti-Doping Rule Violation(s) and setting forth the 

factual basis for the decision and all the Consequences to be imposed 

(unless doing so could compromise an ongoing investigation or proceeding) 

and will send notice of the decision to each Interested Party. Public 

Disclosure is also required in accordance with ADMC Program Rule 3620

of the Protocol. 

Thus, if you have or discover exculpatory evidence or evidence that you 

contend establishes that you committed No Fault or Negligence or No 

Significant Fault or Negligence, you could be entitled to the elimination or 

a reduction in your period of Ineligibility as provided for in ADMC Program 

Rules 3224 or 3225 of the Protocol. Please provide said evidence to HIWU. 

HIWU will evaluate your evidence, and, if it determines you have met your 

burden under the Protocol, it has the ability to enter into an agreed Case 

Resolution Without a Hearing consistent with the framework of ADMC 

Program Rule 3249 (Protocol). 

(iii) Proceed to a Hearing on the Merits of the Case – You have the right to

deny the Anti-Doping Rule Violation(s) charged and dispute the proposed

Consequences at a hearing before an adjudicator from the Arbitral Body in

accordance with ADMC Program Rule 3261 of the Protocol and Arbitration

Procedures codified at Rule Series 7000. You must exercise this option by

requesting a hearing on the merits in writing via email sent to me at

afarrell@hiwu.org on or before 5PM CST July 28, 2023.

C. Substantial Assistance.

Additionally, you also have the option to provide Substantial Assistance in an

effort to eliminate or reduce your period of Ineligibility and/or other Consequences. Under 

ADMC Program Rule 3226(a) (Protocol), HIWU may suspend all or part of the 

Consequences imposed on a Covered Person in any one case (other than Disqualification 

of results as required by ADMC Program Rule 3221 of the Protocol) based upon the 

following: 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 25 of 54 * -PUBLIC 
July 21, 2023 | Page 5 of 7

(1) The Covered Person provides Substantial Assistance to HIWU, the

Horseracing Integrity and Safety Authority (“HISA”), or a State Racing

Commission, a criminal authority, or a professional disciplinary body that

results in:

(i) HIWU discovering or bringing forward an Anti-Doping Rule

Violation or a Controlled Medication Rule Violation by another

Covered Person; or

(ii) a criminal or disciplinary body discovering or bringing forward a

sport-related criminal offense or the breach of professional or sports

rules by another Person, including offenses arising out of a sport

integrity violation or sport safety violation, or the violation of any

rule or requirement in the Act, and the information provided by the

Covered Person providing Substantial Assistance is also made

available to HIWU.

(2) The extent to which the otherwise applicable period of Ineligibility may be

suspended shall be based on the seriousness of the Anti-Doping Rule

Violation committed by the Covered Person and the degree to which the

Substantial Assistance provided by the Covered Person assists the effort to

promote doping-free racing, compliance with the Protocol, or the integrity

of racing. In any event, no more than three-quarters of the otherwise

applicable period of Ineligibility may be suspended. If the otherwise

applicable period of Ineligibility is a lifetime, the non-suspended period

under this section must be no less than 8 years. For purposes of this Rule

3226, the otherwise applicable period of Ineligibility shall not include any

period of Ineligibility that could be added under Rule 3228(c)(2).

(3) If so requested, HIWU shall allow the Covered Person who seeks to provide

Substantial Assistance to provide the information to HIWU subject to a

Without Prejudice Agreement.

(4) If the Covered Person fails to continue to cooperate or fails to provide the

complete, accurate, and credible Substantial Assistance promised, HIWU

shall reinstate the original Consequences. That decision is not subject to

review.

Please inform HIWU, in writing at afarrell@hiwu.org, by 5pm CST on July 28, 2023, 

which option you choose. If you are willing to admit and accept the violation(s) and Consequences 

set forth in this EAD Charge Letter, please complete the enclosed Admission of Equine AntiDoping Rule Violation(s) and Acceptance of Consequences form and return by 5pm CST on July 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 26 of 54 * -PUBLIC 
July 21, 2023 | Page 6 of 7

28, 2023 by email to afarrell@hiwu.org. Note that, if you admit the violation(s) and accept the 

period of Ineligibility by the above-stated deadline, the period of Ineligibility to be served will be 

automatically reduced by one (1) year without any further reduction allowed under any other 

Rules.

If you choose to deny and challenge the Anti-Doping Rule Violations, you have the right 

to request a hearing. Please inform HIWU, in writing, by 5pm CST on July 28, 2023, of your 

request for a hearing (including any request for an expedited hearing) before the Arbitral Body. 

Note that, if you do not respond to HIWU’s assertion of an Anti-Doping Rule Violation or 

the proposed Consequences by the above-stated deadline you shall be deemed to have waived your 

right to a hearing, admitted the Anti-Doping Rule Violation(s) charged, and accepted the 

Consequences specified by HIWU in this EAD Charge Letter without any mitigation of those 

Consequences. 

III. Provisional Suspension

As a reminder and as set forth in detail in your EAD Notice letter, HIWU has imposed a

Provisional Suspension on you as the Responsible Person and Bella Renella, effective as of July 

6, 2023. Provided that you and Bella Renella respect the Provisional Suspension, the time served 

under the Provisional Suspension will be credited against any period of Ineligibility that may 

ultimately be imposed.

IV. Other Information

As a reminder, Bella Renella remains subject to Testing pending the outcome of this matter.

Please note, at any time during or after the Results Management of your matter, you can

provide Substantial Assistance in accordance with ADMC Program Rule 3226 (Protocol) and 

HIWU will evaluate if a suspension of all or part of any resulting Consequences is appropriate.

By copy of this EAD Charge Letter, HIWU is notifying the Owner, the Horseracing 

Integrity and Safety Authority (“HISA”), and the California Horseracing Board. Pursuant to 

ADMC Program Rule 7060(a) (Arbitration Procedures), the Owner and HISA are invited to 

participate as observers in this case. If they accept by sending an acceptance email to HIWU at 

afarrell@hiwu.org they will receive copies of the filings in the case. Except as provided in the 

Protocol, HIWU will not publicly disclose the specifics of this matter until resolution of the case.

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 27 of 54 * -PUBLIC 
July 21, 2023 | Page 7 of 7

Please read this EAD Charge Letter carefully and take note of the deadlines set forth in this 

letter. You have the right to contact an attorney of your choosing in an effort to seek legal advice, 

should you desire to do so. If you have any questions regarding this letter, please contact me at 

(816) 602-9045 or afarrell@hiwu.org.

Sincerely,

Allison J. Farrell

Senior Litigation Counsel 

Encl.: Admission of EAD Rule Violation(s) and Acceptance of Consequences

cc (w/ encl.): California Horseracing Board 

John Roach, HISA 

Samuel Reinhardt, HISA 

Lisa Lazarus, HISA

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 28 of 54 * -PUBLIC 
Horseracing Integrity & Welfare Unit • 4801 Main Street, Suite 350 Kansas City, Missouri 64112-2749 • T +011 816 474 8655 •

hiwu.org

Early Admission of Equine Anti-Doping Rule Violation(s) 

and Acceptance of Consequences

I, Milton Pineda, hereby acknowledge that I have violated Rule Series 3000 Equine AntiDoping and Controlled Medication Protocol (the “Protocol”) as a result of Diisopropylamine in 

Bella Renella’s Sample #U100331404 collected on June 18, 2023 at Santa Anita Park. I admit that 

I have committed Equine Anti-Doping (“EAD”) Rule Violation(s) pursuant to Anti-Doping 

Medication Control (“ADMC”) Program Rule 3212 (Presence of a Banned Substance) under the 

Protocol and I accept the following Consequences: 

1. A period of Ineligibility for myself of 18 months as described in ADMC Program Rule

3223 (Protocol) from June 18, 2023 to December 18, 2024;

2. A period of Ineligibility for Bella Renella of at least 60 days with reinstatement being

subject to a Negative Finding in an Out of Competition test administered by HIWU,

beginning on June 18, 2023;

3. Disqualification of the results pursuant to ADMC Program Rule 3221 (Protocol) of Bella

Renella obtained on June 18, 2023, with resulting Consequences of Disqualification of

results including forfeiture of all purses and other compensation, prizes, trophies, points,

and rankings and repayment or surrender (as applicable) to the Race Organizer;

4. A fine of $12,500 USD in accordance with ADMC Program Rule 3223 (Protocol);

5. Public disclosure in accordance with ADMC Program Rule 3620 (Protocol); and

6. All other Consequences which may be required by the Protocol, including its supporting

rules and documents.

I understand and acknowledge that Bella Renella may not participate in any Timed and

Reported Workout or Covered Horserace while serving a period of Ineligibility. Further, I may not 

participate in any capacity in any activity involving Covered Horses, or in any other activity (other 

than authorized anti-doping education or rehabilitation programs) taking place at a Racetrack or 

Training Facility; nor shall I permit anyone to participate in any capacity on my behalf in any such 

activities, except to the extent that I am an Owner, and the activity is necessary to ensure the 

safekeeping and wellbeing of the horse during my period of Ineligibility. 

If, during the period of Ineligibility, I violate the prohibition against participation as 

described in ADMC Program Rule 3229 (Protocol), I understand that any results obtained from 

such participation shall be Disqualified and a new period of Ineligibility equal in length to the 

original period of Ineligibility shall be added to the end of my original period of Ineligibility. By 

admitting the EAD Rule Violation(s) and accepting the Consequences, I agree that HIWU shall 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 29 of 54 * -PUBLIC 
2 

determine whether there has been a violation of the prohibition against participation and apply the 

appropriate consequences pursuant to ADMC Program Rule 3261 (Protocol). 

If, during Bella Renella’s period of Ineligibility, Bella Renella participates in any Timed 

and Reported Workout or Covered Horserace in violation of the prohibition against participation

as described in ADMC Program Rule 3229(a)(2) (Protocol), I understand that any results obtained 

from such participation shall be Disqualified and that I shall receive the following period of 

Ineligibility: (i) if subject to an original period of Ineligibility, a new period of Ineligibility equal 

in length to the original period of Ineligibility shall be added to the end of the original period of 

Ineligibility. If the original period of Ineligibility has already expired, the new period of 

Ineligibility shall start on the date that it is accepted or imposed; or (ii) if not subject to an original 

period of Ineligibility, the period of Ineligibility for violating ADMC Program Rule 3229 

(Protocol) shall be from a reprimand to one (1) year, depending on my degree of Fault. 

I understand and acknowledge as a Trainer who is subject to a period of Ineligibility that 

those Covered Horse(s) under my training may not participate in any Timed and Reported Workout 

or Covered Horserace unless and until they have been transferred to another Covered Person. For 

the ‘transfer’ to be valid, (i) the transfer must be registered with the Horseracing Integrity and 

Safety Authority (“HISA”) in accordance with its procedures, and (ii) the Covered Horses must 

also be physically relocated to facilities under the care or control of a Covered Person who is not 

affiliated with the suspended Trainer (and failure to comply may constitute an Anti-Doping Rule 

Violation under Rule 3216(c), i.e., Prohibited Association). 

I understand that to be reinstated I must have respected the period of Ineligibility and repaid 

or surrendered any purses and other compensation, prizes, trophies, points, and rankings forfeited, 

and paid any fines and reimbursed any costs imposed or accepted to HIWU, unless an installment 

plan was established pursuant to ADMC Program Rule 3232(b) (Protocol), in which case I must 

have made all payments due under that plan. Where fairness requires, HIWU or the Arbitral Body 

may establish an installment plan for repayment of amounts due to be paid or reimbursed under 

the Protocol. The payment schedule may extend beyond any period of Ineligibility imposed upon 

me. 

If any installment(s) subsequently become(s) overdue under that plan (i.e., after 

reinstatement), myself and the Covered Horse(s) under my ownership and/or training may not 

participate in any Timed and Reported Workout or Covered Horserace until such overdue 

installment(s) is/are paid in full.

I understand that Bella Renella shall be reinstated once its period of Ineligibility ends, 

provided that (i) the Ineligibility has been respected in full throughout that period in accordance 

with ADMC Program Rule 3229 (Protocol), (ii) Bella Renella has been made available for Testing 

during that period in accordance with ADMC Program Rule 3132(d) (Protocol), and (iii) Bella 

Renella has completed any Vets’ List Workout(s) required by the Racetrack Safety Program or 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 30 of 54 * -PUBLIC 
3 

HIWU (for the avoidance of doubt, such workouts may be scheduled prior to the expiry of the 

period of Ineligibility and will not constitute a violation of ADMC Program Rule 3229 (Protocol)).

Any reinstatement pursuant to this ADMC Program Rule 3233 (Protocol) is without prejudice to 

any rest or stand down period that may be imposed on Bella Renella (e.g., due to injuries), and any 

requirements for release from the Veterinarians’ List, pursuant to the Racetrack Safety Program. 

I acknowledge and understand that HIWU will communicate the decision related to my 

admission of the EAD Rule Violation(s) and my acceptance of the Consequences to HISA. 

I understand that in accordance with the Protocol, Bella Renella shall remain subject to 

testing while serving a period of Ineligibility. I agree to update HISA’s online registration portal 

regarding any changes to Bella Renella’s whereabouts information. I understand that any failure 

to comply with whereabouts obligations during a period of Ineligibility may result in a 

Whereabouts Failure and resulting fine from HISA. 

I knowingly and voluntarily waive my right to a hearing under the Protocol. 

I acknowledge that I have either consulted with my own counsel regarding the terms and 

conditions of this agreement, or I knowingly and affirmatively waive the right to do so. 

By signing below, I acknowledge that I have read and fully understand this Admission of 

Equine Anti-Doping Rule Violation(s) and Acceptance of Consequences form and agree to the 

above Anti-Doping Rule Violation(s) and resulting Consequences and provisions of the Protocol. 

____________________________________ _____________________ 

Signature of Milton Pineda Date

____________________________________ 

Printed Name of Milton Pineda 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 31 of 54 * -PUBLIC 

PUBLIC
Horseracing Integrity & Welfare Unit • 4801 Main Street, Suite 350 Kansas City, Missouri 64112-2749 • T +011 816 474 8655 •

hiwu.org

CONFIDENTIAL

Allison J. Farrell

Senior Litigation Counsel 

 Horseracing Integrity & Welfare Unit

4801 Main Street 

Suite 350 

Kansas City, MO 64112-2749 

August 9, 2023

DELIVERED VIA EMAIL

Darrell Vienna, Esq.

5256 S. Mission Road, Suite 723-808 

Bonsall, CA 92003 

(626) 590-9999

horselawyer@gmail.com

Counsel for: 

Milton Pineda 

Re: EAD Notice of Alleged Anti-Doping Rule Violation 

Covered Horse: Wegonahavagoodtime 

Sample #U100331040 

Dear Mr. Pineda: 

This Equine Anti-Doping (“EAD”) Notice letter is issued pursuant to Anti-Doping 

Medication Control (“ADMC”) Program Rule 3245 of the Protocol (defined below) and serves to 

inform you that a Sample collected from the Covered Horse Wegonahavagoodtime as part of a 

Sample Collection Session conducted under the authority of the Horseracing Integrity & Welfare 

Unit (“HIWU”) has resulted in an Adverse Analytical Finding (“AAF”) and may result in AntiFEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 32 of 54 * -PUBLIC 

PUBLIC
 August 9, 2023 | Page 2 of 7

Doping Rule Violation(s) and related consequences. The violations, as described below, may only 

be committed by Covered Persons, but the Consequences may apply to both you and 

Wegonahavagoodtime. 

I. Anti-Doping and Controlled Medication Rules - General

You and Wegonahavagoodtime are subject to the Equine Anti-Doping and Controlled

Medication Protocol codified as Rule Series 3000 of the ADMC Program (the “Protocol”), 

including its supporting rules and documents. Results Management of this matter is the 

responsibility of HIWU. HIWU conducts Results Management in accordance with ADMC 

Program Rule 3240 of the Protocol and the Equine Testing and Investigations Standards. 

Capitalized terms used, but not defined within this letter, are as defined in Rule 1020 of the General 

Provisions and the Protocol. 

II. Alleged Anti-Doping Rule Violation(s) and Potential Consequences - Specific

Specifically, as a Responsible Person as defined in ADMC Program Rule 3030 of the

Protocol, ADMC Program Rule 3212 holds you strictly liable for any Banned Substance and/or its 

Metabolites or Markers present in a Sample collected from your Covered Horse(s). Pursuant to the 

Protocol, the AAF may result in the following Anti-Doping Rule Violation(s): Presence of a 

Banned Substance and/or its Metabolites or Markers (ADMC Program Rule 3212) – 

Diisopropylamine. 

If it is agreed or determined that an Anti-Doping Rule Violation has occurred, the following 

Consequences may be imposed pursuant to ADMC Program Rules 3221, 3222, and 3223,

including, but not limited to, Disqualification of Covered Horse’s results; forfeiture of 

compensation, prizes, purses, trophies, points, and rankings; fines; a period of two years of

Ineligibility for you as a Covered Person and a period of up to fourteen (14) months of Ineligibility 

for Wegonahavagoodtime; a fine of up to $25,000 USD or 25% of the purse, whichever is greater;

payment of adjudication costs and some or all of HIWU’s legal fees; and Public Disclosure

pursuant to ADMC Program Rule 3620 of the Protocol. 

Note that, in the event that Wegonahavagoodtime’s results are subject to automatic 

Disqualification under ADMC Program Rule 3221(a) of the Protocol, the Responsible Person, the 

Owner, and HIWU may agree to apply ADMC Program Rule 3221 (Protocol) immediately or any 

one of them may request that the Arbitral Body apply ADMC Program Rule 3221 (Protocol) 

immediately.

PUBLIC

-=-=

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 33 of 54 * -PUBLIC 
 August 9, 2023 | Page 3 of 7

III. AAF Testing and Results

On July 4, 2023, Sample Collection Personnel collected a urine Sample, designated as

Sample #U100331040 from Wegonahavagoodtime Post-Race of Race 6 from Los Alamitos Race 

Course. Wegonahavagoodtime’s A Sample was submitted to the Kenneth L. Maddy Equine 

Analytical Chemistry Laboratory (“UC Davis Lab”) in Davis, CA for analysis. The UC Davis Lab 

analyzed the A Sample in accordance with the Equine Standards for Laboratories and 

Accreditation and reported and AAF because it detected Diisopropylamine. Diisopropylamine is 

a category S0 Banned Substance on the Prohibited List and Technical Document – Prohibited 

Substances. The UC Davis Lab’s A Sample certificate of analysis is enclosed for your reference, 

as well as a copy of the Sample Collected Documentation.

You, as the Responsible Person, and the Owner of Wegonahavagoodtime both have the 

right to request a copy of the A Sample Laboratory Documentation Package after the B Sample 

analysis has been completed or the analysis of the B Sample is waived. The details regarding the 

B Sample are set forth below.

IV. B Sample Analysis

You and the Owner have the right to request the analysis of the B Sample. You or the

Owner will be required to pay the cost, in advance, to have the B Sample analyzed and B Sample 

Laboratory Documentation Package prepared. If you or the Owner would like the B Sample 

analyzed, please submit a request, in writing, to banalysis@hiwu.org by August 14, 2023, on or 

before 5pm CST. If such request is not paid withing seven (7) days of the date of the invoice, then 

the B Sample analysis will be deemed waived.

Provided HIWU receives a request by August 14, 2023, on or before 5pm CST, HIWU 

will notify you and the Owner, in writing, of the scheduled date, time, and Laboratory where the 

B Sample analysis will be completed, the amount due, and date on which the payment must be 

received. Payment for the analysis must be received by HIWU before the Laboratory will begin 

such analysis. Please submit your payment on the Horseracing Integrity and Safety Authority’s 

(“HISA”) online portal. If such payment is not made on time, then the B Sample analysis will be 

deemed waived.

You and the Owner, if agreed upon, may waive analysis of the B Sample and accept the A 

Sample results. If you and the Owner choose to accept the A Sample results, please sign the 

enclosed Acceptance of A Sample Results and B Sample Waiver Form and return it to 

banalysis@hiwu.org no later than August 14, 2023. Please note that, regardless of said waiver, 

HIWU retains the right to proceed with the B Sample analysis at its own expense. 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 34 of 54 * -PUBLIC 
 August 9, 2023 | Page 4 of 7

V. Provisional Suspension

As required by ADMC Program Rule 3247(a)(1) of the Protocol, as modified by the HISA

and HIWU Policy Change regarding Provisional Suspensions effective July 28, 2023, HIWU has 

imposed a Provisional Suspension on you as the Responsible Person and Wegonahavagoodtime 

effective as of today, August 9, 2023. You are not eligible for delayed imposition of a Provisional 

Suspension under the Policy Change because you are a Responsible Person with more than one 

horse that has tested positive for the same Banned Substance within a six (6) month-period. 

During a Provisional Suspension, your Covered Horses cannot participate in any Timed 

and Reported Workouts or Covered Horseraces. You may engage in caring for and exercising 

your Covered Horses. In addition, you: (i) must take down or cover any personal signage bearing 

your name where the Covered Horses are located at the racetrack; (ii) cannot claim Covered Horses 

or bring new Covered Horses into your barn; and (iii) cannot be employed in any capacity 

involving Covered Horses (including, but not limited to, acting as an agent for an Owner of 

Covered Horses or working as an exercise rider for Covered Horses.) 

As a Trainer, your Covered Horse(s) may not participate in any Timed and Reported 

Workout or Covered Horserace unless and until your Covered Horse(s) have been transferred to 

another Covered Person. For the “transfer” to be valid, it must be (i) approved by the stewards, 

and (ii) registered with HISA. If you are an Owner of any Covered Horses, ownership of the 

Covered Horse must be transferred in order for it to be eligible to participate in any Timed and 

Reported Workout or Covered Horserace. Failure to comply may result in an Anti-Doping Rule 

Violation under Rule 3216(c). To transfer your Covered Horse(s), please contact Linda Lankester, 

System Integrity & Operations Assistance at HISA, at (859) 514-0287. Please be advised that, 

during your Provisional Suspension, you will not have access to the full functionality of the HISA 

Portal.

Additionally, the Covered Horse of an Owner who is subject to Provisional Suspension or 

period of Ineligibility may not participate in any Timed and Reported Workout or Covered 

Horserace unless they have been transferred in a bona fide transaction to a different Owner. If an 

Immediate Family Member has any ownership or property interest in the Covered Horse following 

such transfer, the transfer shall not constitute a bona fide transaction to a different Owner. 

Because Wegonahavagoodtime tested positive for a category S0 Banned Substance as 

classified in the Prohibited List – Technical Document, he is suspended for a minimum of sixty 

days and his return to participation is subject to a Negative Finding in an Out of Competition test 

that it is to be administered by HIWU. This test must be coordinated through the regulatory 

veterinarian and can be scheduled such that the Covered Horse can return to participation on day 

61 if he tests Negative.

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 35 of 54 * -PUBLIC 
 August 9, 2023 | Page 5 of 7

You, on your own behalf and on behalf of Wegonahavagoodtime, have the opportunity for 

a Provisional Hearing on a timely basis after imposition of the Provisional Suspension or an 

opportunity for an expedited hearing in accordance with ADMC Program Rule 3262 (Protocol) on 

a timely basis after imposition of the Provisional Suspension. 

Please inform HIWU, in writing, by August 14, 2023, on or before 5pm CST if you intend 

to exercise your right to a Provisional Hearing. Provisional Hearings will be conducted by the 

Arbitral Body and heard via telephone or video conference. The Arbitral Body will only make a 

determination regarding whether HIWU’s decision to impose a Provisional Suspension shall be 

maintained; the Arbitral Body will not take up any other issues in the Provisional Hearing. ADMC 

Program Rule 3247(c) (Protocol) requires that HIWU’s decision to impose a Provisional 

Suspension shall be maintained unless the Responsible Person/Covered Person requesting the 

lifting of the Provisional Suspension establishes one of the four criteria set forth in ADMC 

Program Rule 3247(c)(1-4) (Protocol). Note that if you and Wegonahavagoodtime respect the 

Provisional Suspension, the time served under the Provisional Suspension will be credited against 

any period of Ineligibility that may ultimately be imposed. 

If you or Wegonahavagoodtime intends to participate in a Covered Horserace within fortyfive (45) days, HIWU may, in its sole discretion, choose to address the case on an expedited basis 

to ensure resolution of the matter prior to the Covered Horserace. Please notify HIWU, in writing, 

immediately if you intend to participate in any Covered Horserace within forty-five (45) days. 

VI. Resolution and Your Rights Under the Protocol: Substantial Assistance, Early

Admission, and Explanation

In accordance with ADMC Program Rule 3226 of the Protocol, you have the opportunity

to provide Substantial Assistance or admit the alleged Anti-Doping Rule Violation(s) with the 

potential benefit of receiving a reduction to any period of Ineligibility that may be imposed. 

Further, you may seek to enter into a case resolution without a hearing pursuant to ADMC Program 

Rule 3249 (Protocol). In this case, early admittance and acceptance of the violations under ADMC 

Program Rules 3226(d)(2) would reduce your period of Ineligibility by six (6) months. Please note, 

at any time during or after the Results Management of your matter, you can provide Substantial 

Assistance and HIWU will evaluate if a suspension of all or part of any resulting Consequences is 

appropriate. 

At this time prior to the issuance of formal charges, you have the opportunity to provide an 

explanation to HIWU. Please submit all applicable information along with your explanation to

HIWU’s Senior Litigation Counsel, Allison Farrell, by email to afarrell@hiwu.org by August 16, 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 36 of 54 * -PUBLIC 
 August 9, 2023 | Page 6 of 7

2023. Furthermore, if you seek to enter into a case resolution without a hearing, please notify 

HIWU, in writing, immediately.

VII. Other Information

As a reminder, Wegonahavagoodtime remains subject to Testing pending the outcome of

this matter.

Pursuant to ADMC Program Rule 3610(b) of the Protocol, HIWU will use its reasonable 

endeavors to ensure that Persons under its control do not publicly identify Covered Horses or 

Covered Persons who are alleged to have committed a violation under the Protocol, unless and 

until: (i) in presence cases, the B Sample confirms the results of the A Sample analysis, or the B 

Sample analysis is waived; (ii) a Provisional Suspension has been imposed or voluntarily accepted; 

(iii) a charge has been brought; or (iv) a violation has been admitted, whichever is earlier. In such

circumstances (except where the Covered Person is a Minor), HIWU shall publicly report: (i) the

identity of any Covered Person who is the subject of the alleged violation; (ii) the identity of any

relevant Covered Horses(s); and (iii) the rule violated and, where appropriate, the basis of the

asserted violation. HIWU shall not be required to publicly report a matter if it would risk

compromising an ongoing investigation or proceeding. If HIWU determines that an ongoing

investigation or proceeding will no longer be compromised by public reporting, HIWU shall at

such time make any public reporting. HIWU shall Publicly Disclose the resolution of an alleged

violation of the Protocol in accordance with ADMC Program Rule 3620.

By copy of this EAD Notice letter, HIWU is notifying the Owner, the current Responsible 

Person for this Covered Horse, HISA and the California Horseracing Board. 

Please read this EAD Notice letter carefully and take note of the deadlines set forth herein. 

You have the right to contact an attorney of your choosing in an effort to seek legal advice, should 

you desire to do so. If you have any questions regarding this letter, please contact me at (816) 602-

0945 or afarrell@hiwu.org. 

Sincerely,

Allison J. Farrell

Senior Litigation Counsel 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 37 of 54 * -PUBLIC 
 August 9, 2023 | Page 7 of 7

Encls.: A Sample Certificate of Analysis

Sample Collection Documentation 

B Sample Analysis Waiver Form 

cc (w/ encls.): Lizbeth Medina, Owner 

Salvador Naranjo, Current Trainer

California Horseracing Board 

John Roach, HISA 

Samuel Reinhardt, HISA 

Lisa Lazarus, HISA

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 38 of 54 * -PUBLIC 


Version 2/2023 WHITE copy = HIWU YELLOW = Laboratory

NOTICE OF SELECTION: POST-RACE TESTING 

Pursuant to HIWU Regulations: 

The Covered Horse named on this form is required to undergo Sample collection. The Covered Horse must be brought to the Test Barn as soon as 

practicable, unless there are valid reasons for delay (as determined by Sample Collection Personnel). 

As the Nominated/Responsible Person, your responsibilities are: 

▪ To report to the Test Barn located on the backside of this racetrack;

▪ To comply and cooperate with Sample collection procedures and processes, your failure of which may result in significant penalties;

▪ To ensure that the Covered Horse remains under continuous observation of the Sample Collection Personnel, to the extent possi ble, until the

completion of the Sample collection process;

▪ To remain with the Covered Horse, to the extent possible, until completion of the Sample collection process;

▪ On request, to produce identification for yourself and facilitate the identification of the Covered Horse;

▪ To ensure that the Covered Horse is not administered any medications or supplements from notification of Sample collection until completion of

the Sample collection process, unless there is a medical emergency (as determined by the Test Barn Veterinarian or a Regulatory Veterinarian);

▪ TR FRQILUP WKDW WKH CRYHUHG HRUVH’V ZDWHU EXFNHW LV FOHDQ DQG DFFHSWDEOH DQG HQVXre that it is only used for your Covered Horse during the Sample

collection process.

AVISO DE SELECCIÓN: RECOLECCIÓN DE PRUEBAS DESPUES DE LA CARRERA 

De acuerdo con las regulaciones de HIWU: 

El Caballo cubierto mencionado en esta forma debe someterse a la recolección de muestras. El caballo cubierto debe llevarse al establo de prueba tan 

pronto como sea posible, a menos que existan razones válidas para demorarse (según lo determine el personal de recolección de muestras). 

Como Persona Designada/Responsable, sus responsabilidades son: 

▪ Presentarse al Establo de Pruebas ubicado en la parte trasera del hipódromo;

▪ Cumplir y cooperar con los procedimientos y procesos de recolección de Muestras, incumplimiento puede resultar en sanciones significativas;

▪ Garantizar que el Caballo cubierto permanezca bajo la observación continua del Personal de recolección de Muestras, en la medida posible, en todo

momento hasta la finalización del proceso de recolección de Muestras;

▪ Permanecer con el Caballo cubierto, lo más posible, hasta que se complete el proceso de recolección de Muestras;

▪ Bajo pedido, debe presentar identificación de usted y facilitar la identificación del Caballo cubierto;

▪ Asegurarse de que al Caballo cubierto no se le administren medicamentos o suplementos desde la notificación de la recolección de Muestras hasta la

finalización del proceso de recolección de Muestras, a menos que haya una emergencia médica (según lo determine el Veterinario del Establo de

pruebas o un Veterinario regulador);

▪ Confirmar que el balde de agua del Caballo cubierto esté limpio y aceptable y asegurarse de que solo se use para su Caballo cubierto durante el

proceso de recolección de muestras.

NOTICE OF SELECTION: OUT-OF-COMPETITION TESTING

Pursuant to HIWU Regulations: 

The Covered Horse named on this form is required to undergo Sample collection. Immediate access to the Covered Horse shall be granted and the 

Sample collection process shall take place immediately in a secure location, unless there are valid reasons for delay (as determined by Sample Collection 

Personnel). Failure to produce the Covered Horse for Sample collection within six (6) hours of notification may result in significant penalties for the 

Responsible Person. 

As the Nominated/Responsible Person, your responsibilities are: 

▪ To comply and cooperate with Sample collection procedures and processes, your failure of which may result in significant penalties;

▪ To ensure that the Covered Horse remains under continuous observation of the Sample Collection Personnel at all times until the completion of

the Sample collection process;

▪ To remain with the Covered Horse until completion of the Sample collection process;

▪ On request, to produce identification for yourself and facilitate the identification of the Covered Horse;

▪ To ensure that the Covered Horse is not administered any medications or supplements from notification of Sample collection until completion of

the Sample collection process, unless there is a medical emergency (as determined by a Regulatory Veterinarian, or, if not available, a Veterinarian).

AVISO DE SELECCIÓN: RECOLECCIÓN DE PRUEBAS FUERA DE COMPETICIÓN

De acuerdo con las regulaciones de HIWU: 

El Caballo cubierto mencionado en esta forma debe someterse a la recolección de muestras. Debe otorgarnos acceso inmediato al Caballo cubierto, el 

proceso de recolección de muestras se llevará a cabo de inmediato en un lugar seguro, a menos que existan razones válidas para demorarse (según lo 

determine el Personal de recolección de muestras). Falta de no presentar el Caballo cubierto para la recolección de muestras dentro de las seis (6) horas 

posteriores a la notificación puede resultar en sanciones significativas para la Persona responsable. 

Como Persona Designada/Responsable, sus responsabilidades son: 

▪ Cumplir y cooperar con los procedimientos y procesos de recolección de Muestras, incumplimiento puede resultar en sanciones significativas;

▪ Garantizar que el Caballo cubierto permanezca bajo la observación continua del Personal de recolección de Muestras en todo momento hasta la

finalización del proceso de recolección de Muestras;

▪ Permanecer con el Caballo cubierto hasta que se finalize el proceso de recolección de Muestras;

▪ Bajo pedido, presentar una identificación de usted y facilitar la identificación del Caballo cubierto;

▪ Asegurarse de que al Caballo cubierto no se le administren medicamentos o suplementos desde la notificación de la recolección de Muestras hasta la

finalización del proceso de recolección de Muestras, a menos que haya una emergencia médica (según lo determine un Veterinario regulador o, si no 

está disponible, un Veterinario).

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 41 of 54 * -PUBLIC 

PUBLIC
Horseracing Integrity & Welfare Unit • 4801 Main Street, Suite 350 Kansas City, Missouri 64112-2749 • T +011 816 474 8655 •

hiwu.org

 

Covered Horse: Wegonahavagoodtime 

Responsible Person: Milton Pineda 

Sample #U100331040 

Owner: Lizbeth Medina

_______________________________________________________________________________ 

I accept the result of the Kenneth L. Maddy Equine Analytical Chemistry Laboratory (“UC 

Davis Lab”) in Davis, CA that Sample #U100331040 from Wegonahavagoodtime collected Post 

Race of Race 6 at Los Alamitos Race Course on July 4, 2023 was reported as an Adverse 

Analytical Finding (“AAF”) because it detected Diisopropylamine. 

I understand that in accordance with the Equine Anti-Doping and Controlled Medication 

Protocol, Sample #U100331040 from Wegonahavagoodtime shall not be considered an AAF until 

the B Sample analysis confirms the A Sample analysis, the Responsible Person or the Owner does

not timely request the B Sample analysis, or the Responsible Person and the Owner, if agreed 

upon, waive the B Sample analysis by signing this form. I understand that the UC Davis Lab’s

result is based solely on the analysis of the A Sample of Sample #U100331040. 

I understand that I have the right to have the B Sample analysis completed and I voluntarily, 

knowingly, and intelligently waive the right to have the B Sample analysis completed. I do not 

contest the UC Davis Lab’s results of Sample #U100331040 from Wegonahavagoodtime. 

____________________________________ _______________________ 

Signature of Milton Pineda Date

____________________________________ 

Printed Name of Milton Pineda 

____________________________________ _______________________ 

Signature of Lizbeth Medina Date

____________________________________ 

Printed Name Lizbeth Medina 

Acceptance of A Sample Analytical Results and B Sample Analysis Waiver Form

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 42 of 54 * -PUBLIC 

August 21, 2023 | Page 2 of 7

I. Charge and Proposed Consequences

In the initial Equine Anti-Doping (“EAD”) Notice letter, HIWU invited you to provide an

explanation regarding Wegonahavagoodtime’s reported AAF. Because HIWU has received no 

explanation from you, HIWU is satisfied that you have committed an Anti-Doping Rule Violation. 

This EAD Charge Letter is issued pursuant to Anti-Doping Medication Control (“ADMC”) 

Program Rule 3248 of the Equine Anti-Doping and Controlled Medication Protocol (the 

“Protocol”) and constitutes formal notice that HIWU is charging you with an Anti-Doping Rule 

Violation for the Presence of Diisoproplyamine in Wegonahavagoodtime’s urine Sample

#U100331040 collected on July 4, 2023 at Los Alamitos Race Course post-race from Race 6. 

Our records indicate that you have no prior Anti-Doping Rule Violations. Therefore,

HIWU is seeking imposition of the following proposed Consequences for a first-time Violation: 

• Disqualification of the results of Wegonahavagoodtime obtained on July 4, 2023 and

subsequent to the date of Sample collection and any period of retroactive Ineligibility,

including forfeiture of all purses and other compensation, prizes, trophies, points, and

rankings and repayment or surrender (as applicable) to the Race Organizer (ADMC

Program Rule 3221) (Protocol);

• A period of Ineligibility of up to 14 months for Wegonahavagoodtime beginning on

July 4, 2023, (ADMC Program Rule 3222) (Protocol);

• A period of Ineligibility of two years, for you as a Covered Person, beginning on

August 9, 2023, the date you received notice of your Provisional Suspension (ADMC

Program Rule 3223) (Protocol);

• A fine of USD $25,000 or 25% of the total purse (whichever is greater) and payment

of some or all of the adjudication costs and HIWU’s legal costs (ADMC Program Rule

3223) (Protocol);

• Public disclosure in accordance with Rule 3620 (ADMC Program Rule 3231)

(Protocol); and

• All other Consequences which may be required by the Protocol, including its

supporting rules and documents.

Please be advised that in accordance with ADMC Program Rule 3227 of the Protocol, your 

period of Ineligibility can be increased by up to two (2) additional years and an additional fine of 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 44 of 54 * -PUBLIC 
August 21, 2023 | Page 3 of 7

up to USD 10,000 or an additional 10% of the total purse (whichever is greater) for Aggravating 

Circumstances. 

II. Your Options Under the Protocol

A. Rights Provided by ADMC Program Rule 3248(d).

Under ADMC Program Rule 3248(d) of the Protocol you as the Covered Person, on or 

before 5pm CST on August 28, 2023, can either: 

Admit the Anti-Doping Rule Violation(s) charged and: 

(i) accept the Consequences proposed by HIWU, in which case HIWU will

issue a decision under ADMC Program Rule 3249(b) of the Protocol;

(ii) seek to agree to mitigated Consequences with HIWU pursuant to ADMC

Program Rule 3249 (Protocol), failing which the Consequences may still be

disputed at a hearing; or

(iii) dispute or seek to mitigate the proposed Consequences at a hearing in

accordance with ADMC Program Rule 3261 (Protocol) and the Arbitration

Procedures; or

Deny the Anti-Doping Rule Violation(s) charged and dispute the proposed Consequences 

at a hearing in accordance with ADMC Program Rule 3261 (Protocol) and Arbitration Procedures. 

B. Further Detail on Resolution Options.

(i) Early Admittance and Acceptance – You have the right to an automatic

six month reduction in your two-year period of Ineligibility by making an

early admittance of the alleged violation(s) and accepting the mandated

Period of Ineligibility within seven (7) calendar days of the date of this EAD

Charge Letter, which deadline is 5PM CST on August 28, 2023. Pursuant

to ADMC Program Rule 3226 of the Protocol, no further reduction shall be

allowed under any other Rule.

(ii) Case Resolution Without a Hearing – Pursuant to ADMC Program Rule

3249(a) (Protocol), a Covered Person has the right – at any time prior to a

Final Decision under the Arbitration Procedures – to agree to admit the

violation(s) charged and accede to specified Consequences consistent with

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 45 of 54 * -PUBLIC 
August 21, 2023 | Page 4 of 7

the Protocol. In this event, HIWU will issue a Final Decision confirming 

the commission of the Anti-Doping Rule Violation(s) and setting forth the 

factual basis for the decision and all the Consequences to be imposed 

(unless doing so could compromise an ongoing investigation or proceeding) 

and will send notice of the decision to each Interested Party. Public 

Disclosure is also required in accordance with ADMC Program Rule 3620

of the Protocol. 

Thus, if you have or discover exculpatory evidence or evidence that you 

contend establishes that you committed No Fault or Negligence or No 

Significant Fault or Negligence, you could be entitled to the elimination or 

a reduction in your period of Ineligibility as provided for in ADMC Program 

Rules 3224 or 3225 of the Protocol. Please provide said evidence to HIWU. 

HIWU will evaluate your evidence, and, if it determines you have met your 

burden under the Protocol, it has the ability to enter into an agreed Case 

Resolution Without a Hearing consistent with the framework of ADMC 

Program Rule 3249 (Protocol). 

(iii) Proceed to a Hearing on the Merits of the Case – You have the right to

deny the Anti-Doping Rule Violation(s) charged and dispute the proposed

Consequences at a hearing before an adjudicator from the Arbitral Body in

accordance with ADMC Program Rule 3261 of the Protocol and Arbitration

Procedures codified at Rule Series 7000. You must exercise this option by

requesting a hearing on the merits in writing via email sent to me at

afarrell@hiwu.org on or before 5PM CST August 28, 2023.

C. Substantial Assistance.

Additionally, you also have the option to provide Substantial Assistance in an

effort to eliminate or reduce your period of Ineligibility and/or other Consequences. Under 

ADMC Program Rule 3226(a) (Protocol), HIWU may suspend all or part of the 

Consequences imposed on a Covered Person in any one case (other than Disqualification 

of results as required by ADMC Program Rule 3221 of the Protocol) based upon the 

following: 

(1) The Covered Person provides Substantial Assistance to HIWU, the

Horseracing Integrity and Safety Authority (“HISA”), or a State Racing

Commission, a criminal authority, or a professional disciplinary body that

results in:

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 46 of 54 * -PUBLIC 
August 21, 2023 | Page 5 of 7

(i) HIWU discovering or bringing forward an Anti-Doping Rule

Violation or a Controlled Medication Rule Violation by another

Covered Person; or

(ii) a criminal or disciplinary body discovering or bringing forward a

sport-related criminal offense or the breach of professional or sports

rules by another Person, including offenses arising out of a sport

integrity violation or sport safety violation, or the violation of any

rule or requirement in the Act, and the information provided by the

Covered Person providing Substantial Assistance is also made

available to HIWU.

(2) The extent to which the otherwise applicable period of Ineligibility may be

suspended shall be based on the seriousness of the Anti-Doping Rule

Violation committed by the Covered Person and the degree to which the

Substantial Assistance provided by the Covered Person assists the effort to

promote doping-free racing, compliance with the Protocol, or the integrity

of racing. In any event, no more than three-quarters of the otherwise

applicable period of Ineligibility may be suspended. If the otherwise

applicable period of Ineligibility is a lifetime, the non-suspended period

under this section must be no less than 8 years. For purposes of this Rule

3226, the otherwise applicable period of Ineligibility shall not include any

period of Ineligibility that could be added under Rule 3228(c)(2).

(3) If so requested, HIWU shall allow the Covered Person who seeks to provide

Substantial Assistance to provide the information to HIWU subject to a

Without Prejudice Agreement.

(4) If the Covered Person fails to continue to cooperate or fails to provide the

complete, accurate, and credible Substantial Assistance promised, HIWU

shall reinstate the original Consequences. That decision is not subject to

review.

Please inform HIWU, in writing at afarrell@hiwu.org by 5pm CST on August 28, 2023, 

which option you choose. If you are willing to admit and accept the violation(s) and Consequences 

set forth in this EAD Charge Letter, please complete the enclosed Admission of Equine AntiDoping Rule Violation(s) and Acceptance of Consequences form and return by 5pm CST on

August 28, 2023 by email to afarrell@hiwu.org. Note that if you admit the Violation and accept 

the period of Ineligibility by the above deadline, the period of Ineligibility to be served will be 

automatically reduced by six (6) months without any further reduction allowed under any other 

Rules.

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 47 of 54 * -PUBLIC 
August 21, 2023 | Page 6 of 7

If you choose to deny and challenge the Anti-Doping Rule Violations, you have the right 

to request a hearing. Please inform HIWU, in writing, by 5pm CST on August 28, 2023, of your 

request for a hearing (including any request for an expedited hearing) before the Arbitral Body. 

Note that, if you do not respond to HIWU’s assertion of an Anti-Doping Rule Violation or 

the proposed Consequences by the above-stated deadline you shall be deemed to have waived your 

right to a hearing, admitted the Anti-Doping Rule Violation(s) charged, and accepted the 

Consequences specified by HIWU in this EAD Charge Letter without any mitigation of those 

Consequences. 

III. Provisional Suspension

As a reminder and as set forth in detail in your EAD Notice letter, HIWU has imposed a

Provisional Suspension on you as the Responsible Person and Wegonahavagoodtime, effective as 

of August 9, 2023. Provided that you and Wegonahavagoodtime respect the Provisional 

Suspension, the time served under the Provisional Suspension will be credited against any period 

of Ineligibility that may ultimately be imposed.

At this time, Wegonahavagoodtime may not participate in any Timed and Reported 

Workout or Covered Horserace and shall remain subject to Testing. Because 

Wegonahavagoodtime tested positive for a category S0 Banned Substance as classified in the 

Prohibited List – Technical Document, Wegonahavagoodtime is suspended for a minimum of sixty 

days from the date of initial suspension (August 9, 2023), and his return to participation is subject 

to a Negative Finding in a Re-Entry Test for all Banned Substances that is to be administered by 

HIWU. This Test must be coordinated through the regulatory veterinarian in the state where the 

Covered Horse is located and can be scheduled such that the Covered Horse can return to 

participation on day 61 if he tests Negative. The regulatory veterinarian can request the Test 

through the HIWU iPad. 

IV. Other Information

As a reminder, Wegonahavagoodtime remains subject to Testing pending the outcome of

this matter. 

Please note, at any time during or after the Results Management of your matter, you can 

provide Substantial Assistance in accordance with ADMC Program Rule 3226 (Protocol) and 

HIWU will evaluate if a suspension of all or part of any resulting Consequences is appropriate. 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 48 of 54 * -PUBLIC 
August 21, 2023 | Page 7 of 7

By copy of this EAD Charge Letter, HIWU is notifying the Owner, the Horseracing 

Integrity and Safety Authority (“HISA”), and the California Horse Racing Board. Pursuant to 

ADMC Program Rule 7060(a) (Arbitration Procedures), the Owner and HISA are invited to 

participate as observers in this case. If they accept by sending an acceptance email to HIWU at 

afarrell@hiwu.org they will receive copies of the filings in the case. In addition, under Rule 7060(a), 

the Owner may be permitted to intervene and make written or oral submissions. Unless otherwise 

agreed by the Arbitral Body, only the following Owners may attend hearings before the Arbitral 

Body: (1) if the Covered Horse is owned by one individual, that individual; and (2) if the Covered 

Horse is owned by more than one individual or by a partnership, corporation, limited liability 

company, syndicate, or other association or entity, either or both the Designated Owner or 

Managing Owner (or their designee). Except as provided in the Protocol, HIWU will not publicly 

disclose the specifics of this matter until resolution of the case.

Please read this EAD Charge Letter carefully and take note of the deadlines set forth in this 

letter. You have the right to contact an attorney of your choosing in an effort to seek legal advice, 

should you desire to do so. If you have any questions regarding this letter, please contact me at 

(816) 602-0945 or afarrell@hiwu.org.

Sincerely,

Allison J. Farrell

Senior Litigation Counsel 

Encl.: Admission of EAD Rule Violation and Acceptance of Consequences 

cc (w/ encl.): Lizbeth Medina, Owner 

California Horse Racing Board 

John Roach, HISA 

Samuel Reinhardt, HISA 

Lisa Lazarus, HISA

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 49 of 54 * -PUBLIC 
Horseracing Integrity & Welfare Unit • 4801 Main Street, Suite 350 Kansas City, Missouri 64112-2749 • T +011 816 474 8655 •

hiwu.org

Early Admission of Equine Anti-Doping Rule Violation(s) 

and Acceptance of Consequences

I, Milton Pineda, hereby acknowledge that I have violated Rule Series 3000 Equine AntiDoping and Controlled Medication Protocol (the “Protocol”) as a result of Diisopropylamine in 

Wegonahavagoodtime’s A Sample #U100331040 collected on July 4, 2023 at Los Alamitos Race 

Course. I admit that I have committed an Equine Anti-Doping (“EAD”) Rule Violation pursuant 

to Anti-Doping Medication Control (“ADMC”) Program Rule 3212 (Presence of a Banned 

Substance) under the Protocol and I accept the following Consequences: 

1. A period of Ineligibility for myself of 18 months as described in ADMC Program Rule

3223 (Protocol) with credit for time served under the Provisional Suspension that was

imposed;

2. A period of Ineligibility for Wegonahavagoodtime of at least 60 days, beginning on August

9, 2023, with reinstatement of Wegonahavagoodtime being subject to a Negative Finding

from a Re-Entry Test for all Banned Substances to be administered by HIWU and

coordinated by the regulatory veterinarian;

3. Disqualification of the results pursuant to ADMC Program Rule 3221 (Protocol) that

Wegonahavagoodtime obtained on July 4, 2023, with resulting Consequences of

Disqualification of results including forfeiture of all purses and other compensation, prizes,

trophies, points, and rankings and repayment or surrender (as applicable) to the Race

Organizer;

4. A fine of $12,500 USD in accordance with ADMC Program Rule 3223 (Protocol);

5. Public disclosure in accordance with ADMC Program Rule 3620 (Protocol); and

6. All other Consequences which may be required by the Protocol, including its supporting

rules and documents.

I understand and acknowledge that Wegonahavagoodtime may not participate in any

Timed and Reported Workout or Covered Horserace while serving a period of Ineligibility. During 

my period of Ineligibility, I understand my Covered Horses cannot participate in any Timed and 

Reported Workouts or Covered Horseraces. I understand I may engage in caring for and exercising 

my Covered Horses. In addition, I understand that I: (i) must take down or cover any personal 

signage bearing my name where the Covered Horses are located at the racetrack; (ii) cannot claim 

Covered Horses or bring new Covered Horses into my barn; and (iii) cannot be employed in any 

capacity involving Covered Horses (including, but not limited to, acting as an agent for an Owner 

of Covered Horses or working as an exercise rider for Covered Horses.) 

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 50 of 54 * -PUBLIC 
2 

As a Trainer, I understand that my Covered Horse(s) may not participate in any Timed and 

Reported Workout or Covered Horserace unless and until they have been transferred to another 

Responsible Person. For the “transfer” to be valid, I understand it must be (i) approved by the 

stewards, and (ii) registered with HISA. If I am an Owner of any Covered Horses, I understand 

that ownership of the Covered Horse must be transferred in order for it to be eligible to participate 

in any Timed and Reported Workout or Covered Horserace. Failure to comply may result in an 

Anti-Doping Rule Violation under Rule 3216(c). 

If, during the period of Ineligibility, I violate the prohibition against participation as 

described in ADMC Program Rule 3229 (Protocol), I understand that any results obtained from 

such participation shall be Disqualified and a new period of Ineligibility equal in length to the 

original period of Ineligibility shall be added to the end of my original period of Ineligibility. By 

admitting the EAD Rule Violation(s) and accepting the Consequences, I agree that HIWU shall 

determine whether there has been a violation of the prohibition against participation and apply the 

appropriate consequences pursuant to ADMC Program Rule 3261 (Protocol). 

If, during Wegonahavagoodtime’s period of Ineligibility, Wegonahavagoodtime 

participates in any Timed and Reported Workout or Covered Horserace in violation of the 

prohibition against participation as described in ADMC Program Rule 3229(a)(2) (Protocol), I 

understand that any results obtained from such participation shall be Disqualified and that I shall 

receive the following period of Ineligibility: (i) if subject to an original period of Ineligibility, a 

new period of Ineligibility equal in length to the original period of Ineligibility shall be added to 

the end of the original period of Ineligibility. If the original period of Ineligibility has already 

expired, the new period of Ineligibility shall start on the date that it is accepted or imposed; or (ii) 

if not subject to an original period of Ineligibility, the period of Ineligibility for violating ADMC 

Program Rule 3229 (Protocol) shall be from a reprimand to one (1) year, depending on my degree 

of Fault. 

I understand that to be reinstated I must have respected the period of Ineligibility and repaid 

or surrendered any purses and other compensation, prizes, trophies, points, and rankings forfeited, 

and paid any fines and reimbursed any costs imposed or accepted to HIWU, unless an installment 

plan was established pursuant to ADMC Program Rule 3232(b) (Protocol), in which case I must 

have made all payments due under that plan. Where fairness requires, HIWU or the Arbitral Body 

may establish an installment plan for repayment of amounts due to be paid or reimbursed under 

the Protocol. The payment schedule may extend beyond any period of Ineligibility imposed upon 

me. 

If any installment(s) subsequently become(s) overdue under that plan (i.e., after 

reinstatement), myself and the Covered Horse(s) under my ownership and/or training may not 

participate in any Timed and Reported Workout or Covered Horserace until such overdue 

installment(s) is/are paid in full.

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 51 of 54 * -PUBLIC 
3 

I understand that Wegonahavagoodtime shall be reinstated once his period of Ineligibility 

ends, provided that (i) the Ineligibility has been respected in full throughout that period in 

accordance with ADMC Program Rule 3229 (Protocol), (ii) Wegonahavagoodtime has been made 

available for Testing during that period in accordance with ADMC Program Rule 3132(d)

(Protocol), and (iii) Wegonahavagoodtime has completed any Vets’ List Workout(s) required by 

the Racetrack Safety Program or HIWU (for the avoidance of doubt, such workouts may be 

scheduled prior to the expiry of the period of Ineligibility and will not constitute a violation of 

ADMC Program Rule 3229 (Protocol)). Any reinstatement pursuant to this ADMC Program Rule 

3233 (Protocol) is without prejudice to any rest or stand down period that may be imposed on

Wegonahavagoodtime (e.g., due to injuries), and any requirements for release from the 

Veterinarians’ List, pursuant to the Racetrack Safety Program.

I acknowledge and understand that HIWU will communicate the decision related to my 

admission of the EAD Rule Violation(s) and my acceptance of the Consequences to HISA. 

I understand that in accordance with the Protocol, Wegonahavagoodtime shall remain 

subject to testing while serving a period of Ineligibility. I agree to update HISA’s online 

registration portal regarding any changes to Wegonahavagoodtime’s whereabouts information. I 

understand that any failure to comply with whereabouts obligations during a period of Ineligibility 

may result in a Whereabouts Failure and resulting fine from HISA. 

I knowingly and voluntarily waive my right to a hearing under the Protocol. 

I understand and acknowledge that I have the right to seek my own legal counsel. I 

acknowledge that I have either consulted with my own counsel regarding the terms and conditions 

of this agreement, or I knowingly and affirmatively waive the right to do so. 

By signing below, I acknowledge that I have read and fully understand this Admission of 

Equine Anti-Doping Rule Violation(s) and Acceptance of Consequences form and agree to the 

above Anti-Doping Rule Violation(s) and resulting Consequences and provisions of the Protocol. 

____________________________________ _____________________ 

 Signature of Milton Pineda Date

____________________________________ 

Printed Name of Milton Pineda

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 52 of 54 * -PUBLIC 

October 23, 2023 | Page 2 of 2

By copy of this letter, HIWU is notifying the Owner of Golovkin, the New Jersey Racing 

Commission and HISA of this withdrawal of sanctions. If you have any questions regarding this 

letter, please contact me at (816) 291-1864 or mpujals@hiwu.org. 

Sincerely,

Michelle Pujals

HIWU General Counsel 

cc: Sanjay Sirju, Owner 

New Jersey Racing Commission

John Roach, HISA 

Samuel Reinhardt, HISA 

Lisa Lazarus, HISA

PUBLIC

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 10/24/2023 OSCAR NO 608813 | PAGE Page 54 of 54 * -PUBLIC