PUBLIC

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

OFFICE OF THE ADMINISTRATIVE LAW JUDGES

) 

In the Matter of ) 

) 

Joseph Peacock and Oscar Ceballos, ) Docket No. 9415 

) 

Appellants. ) 

) 

APPELLANTS’ EXHIBIT LIST

Pursuant to 16 CFR 1.146(c)(4)(i)(C) and the Chief Administrative Law Judge’s Order on 

Stay Application and Application for Review entered July 3, 2023, Appellants hereby submit the 

following cover sheet listing the documentary evidence they intend to introduce at the evidentiary 

hearing on July 13, 2023: 

1. 3.27.2023 – Appeal Hearing Oscar Ceballos & Joey Peacock.mp4 (video of the

March 31, 2023, hearing held before the Horseracing Integrity and Safety Authority (“HISA”) 

(“HISA hearing”))

2. Oscar Ceballos Stewards’ Ruling1

3. Joseph Peacock Jr. Stewards’ Ruling2

4. HISA May 17, 2023, Decision on Appeal

5. 2022 9-24 Race 6 head-on view.mp4 (video of race at issue, head-on view)3

6. 9-24-22 - Head on.mp4 (video of race at issue, head-on view)

7. 9-24-22 - Pan.mp4 (video of race at issue, pan view)

1 Part of the record as Exhibit 1 at the HISA hearing. 2 Part of the record as Exhibit 2 at the HISA hearing. 3 The video does not appear to be part of the record as an exhibit at the HISA hearing but was played by HISA’s 

counsel at the HISA hearing at timestamp 00:07:13. 

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8. 9-03-22 - Head on.mp4 (video of prior race, head-on view) 

9. 9-03-22 - Pan.mp4 (video of prior race, pan view)

10. Joseph Peacock Jr. analysis and summary of race videos4

The PDF exhibits are labeled with exhibit numbers and are being filed through AEFS. Due 

to their nature as MP4 files, the video exhibits cannot readily be labeled with exhibit numbers, and 

due to their file size, they cannot readily be filed through AEFS. However, both the PDF and video 

exhibits are being submitted to the Chief Administrative Law Judge and to opposing counsel with 

a sharefile link from which they can be downloaded. 

Further, Appellants reserve the right, if the need arises (including for impeachment 

purposes), to introduce as evidence any of the following documents or other exhibits: 

1. Any document which has been produced or offered as evidence by Appellants or 

HISA;

2. Any exhibit introduced at the HISA hearing not otherwise included herein; 

3. Any document or exhibit identified in HISA’s exhibit list; and

4. Any document or exhibit necessary to impeach or discredit any testimony or other 

evidence presented by HISA.

Respectfully submitted,

 /s/ Nolan M. Jackson 

 Joel B. Turner

Frost Brown Todd LLP 

400 West Market Street, Suite 3200 

Louisville, KY 40202-3363 

Washington, DC 20001 

Phone: (502) 568-0392 

Fax: (502) 581-1087 

jturner@fbtlaw.com

and

4 Part of the record as Exhibit 12 at the HISA hearing.

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Nolan M. Jackson 

Frost Brown Todd LLP 

20 F Street NW, Suite 850 

Washington, DC 20001 

Phone: (202) 292-4165 

Fax: (202) 292-4151 

njackson@fbtlaw.com

Counsel for Appellants

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CERTIFICATE OF SERVICE

Pursuant to 16 CFR 4.2(c)(1)(i), a copy of the forgoing is being filed electronic through the 

Federal Trade Commission’s electronic filing system (AEFS) this 10th day of July, 2023, with 

courtesy copies being served via email upon the following: 

Office of the Secretary

electronicfilings@ftc.gov

Office of Administrative Law Judges

oalj@ftc.gov

Bryan Beauman

bbeauman@sturgillturner.com

John L. Forgy 

johnforgy1@gmail.com

0151952.0762715 4859-7642-5326v1

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