ADAM PAUL LAXALT ‘Attorney General CAROLINE BATEMAN Deputy Attorney General Nevada Bar No. 12281 Bureau of Government Affairs 555 E. Washington Ave., Ste. 3900 Las Vegas, Nevada 89101 Telephone: (702) 486-2625 Facsimile: (702) 486-3773 Email: cbateman@aq.nv.gov BEFORE THE NEVADA STATE ATHLETIC COMMISSION IN THE MATTER OF: COMPLAINT FOR DISCIPLINARY ACTION ) ) JONATHAN JONES ) ) Robert Bennett, Executive Director for the Athletic Commission of the Department of Business and Industry, State of Nevada, complains for disciplinary action against Jonathan Jones ("Jones") as follows: JURISDICTION 1. Atall times relevant to the Complaint, Jones was licensed in Nevada as a professional mixed martial artist by the Nevada State Athletic Commission (‘Commission’). As a licensee of the Commission, Jones was subject to the provisions uf Chapter 467 of the Nevada Revised Statutes (NRS), and of Chapter 467 of the Nevada Administrative Code (NAC). 3. Pursuant to NRS Chapter 467, the Commission is vested with the sole discretion, management, control and jurisdiction over contests, exhibitions and licensees of unarmed combat, which includes mixed martial arts. 4. Pursuant to NAC 467.922, the Executive Director or a Commissioner may institute disciplinary proceedings described in NRS 467.110 to 467.117, inclusive, or 467.157 or| 467.158 against a person who is licensed pursuant to Chapter 467 by filing a complaint with the Commission Page 1 of 6te 3900 Attorney General's Office Tas Vegas, NV 891 SSS Washington 24 22 23 24 25 26 27 28 10. " 2 13. FACTUAL ALLEGATIONS On February 25, 2016, the Commission granted Jones an Unarmed Combatant’s License for the 2018 calendar year On April 27, 2016, Promoter Ultimate Fighting Championship (“UFC”) announced that Jones would participate in the main event of UFC 200, a professional mixed martial arts event set for July 9, 2016 in Las Vegas, Nevada. On June 16, 2016, Jones voluntarily submitted to a urinalysis (the “Urinalysis") by a representative of the United States Anti-Doping Agency (“USADA") and provided a specimen for testing. The Urinalysis reflected the presence ot Hydroxyclomiphene, which is a metabolite of Clomiphene. Clomiphene is not a drug or stimulant approved by the Commission and it is a prohibited anti-estrogenic substance pursuant to the World Anti-Doping Agency's Prohibited list (‘WADA Prohibited List’) The Urinalysis also reflected the presence of Letrozole Metabolite. Letrozole is not a drug or stimulant approved by the Commission and it is a prohibited Aromatase Inhibitor pursuant to the WADA Prohibited List. On or about July 8, 2016, the *B Sample” of the Urinalysis was tested. The “B Sample” testing reflected the presence of Hydroxyclomiphene and Letrozole Metabolite. The administration ot or use ot any drug that has not been approved by the Commission by a Nevada licensed mixed martial artist is prohibited by the Regulations of the Commission. By his administration or use of one or more prohibited substances, Jones brought disrepute to unarmed combat and he is guilty of foul or unsportsmanlike conduct that was detrimental to a contest. VIOLATIONS AND AUTHORIZED DISCIPLINE NAC 467.850 governs the administration or use of alcohol, stimulants, drugs or injections, urinalysis or chemicals tests, and disciplinary action and it provides, in pertinent part: Page 2 of 641. The administration of or use of any: Zt (a) — Alcohol; (b) Stimulant; or 2 (c) Drug or injection that has not been approved by the Commission, 3 in any part of the body, either before or during a contest or exhibition, to or by any unarmed combatant is prohibited. 4 2. The following types of drugs, injections or stimulants are 5 prohibited pursuant to subsection 1: 6 (f) Any drug identified on the most current edition of the Prohibited List published by the World Anti-Doping Agency, 7 which is hereby adopted by reference. The most current edition of the Prohibited List may be obtained, free of 8 charge, at the Internet address www.wada-ama.org. 9 5. An unarmed combatant shall submit to a urinalysis or 10 chemical test before or after a contest or exhibition if the _ Commission or the Commission's representative directs him to do 80. 6. A licensee who violates any provision of this section is 12 subject to disciplinary action by the Commission. In addition to any other disciplinary action by the Commission, if an unarmed Pa combatant who won or drew a contest or exhibition is found to Ss have violated the provisions of this section, the Commission may, 3a in its sole discretion, change the result of that contest or exhibition Bez to ano decision. 325 15 By 14. NRS 467.153 governs drug testing and it provides as follows: “The Commission shall perform drug testing of amateur and professional unarmed combatants. Such drug testing may take place at any time, including, without limitation, during any period of 18 training.” Ww 20 A person who is licensed by the Commission may have his license 2 suspended or revoked, or ho may be fined or be subject to discipline by the Commission if he has: 15. _ NAC 467.885 governs grounds for disciplinary action and it provides, in pertinent part 22 2. Violated any provision of this Chapter [467]; 23 3. Provided false or misleading information to the Commission or a representative of the Commission; 24 5. Conducted himself at any time or place in a manner 25 which is deemed by the Commission to reflect discredit to unarmed combat. 26 27 ||18 NAC 467.886 governs prohibitions on licensees and it provides that a person licensed 28 by the Commission shall not engage in any activity that will bring disrepute to unarmed Page 3 of 6S332 Washingt Ste 3900 as Vegas NV 89101, Attorney Geneal's Office oan wn = 41 12 13 14 15 16 17 18 a} 20 24 22 23 24 25 26 27 28 combat. NRS 467.158 govems penalties in lieu of, or in addition to, other disciplinary action and it provides, in pertinent part 2. If disciplinary action is taken against a person pursuant to this chapter, including, but not limited to, a hearing for the revocation of a license, and the disciplinary action relates to: (a) The preparation for a contest or an exhibition of unarmed combat; or (b) The occurrence’ of a contest or an exhibition of unarmed combat; or (c) Any other action’ taken in conjunction with a contost or an exhibition of unarmed combat, the Commission may prescribe a penalty pursuant to subsection 3. 3. A penalty prescribed by the Commission pursuant to subsection 3 (a) Must not exceed $250,000 or 100 percent of the share of the purse to which the holder of the license is entitled for the contest or exhibition, whichever amount is greater; and (b) May be imposed in addition to or in lieu of any other disciplinary action that is taken against the person by the Commission. 4. In adaition to any other disciplinary action that is taken against a person by the commission pursuant to this chapter, the Commission may impose a ban from participation in unarmed combat in this State for a certain period, including a lifetime ban from participation in unarmed combat in this State. 6. If disciplinary action is taken against a person pursuant to this, chapter, the commission may require the person against whom such action is taken to pay the costs of the proceeding, including investigative costs and attorney's fees, NRS 467.110 governs suspensions, revocatione and othor disciplining of contestants and it provides as follows: The Commission may suspend or revoke the license of, otherwise discipline, or take any combination of such actions against any contestant, promoter, ring official or other participant who, in the judgment of the Commission: (e) _ Is guilty of an act or conduct that is detrimental to a contest or exhibition of unarmed combat, including, but not limited to, any foul or _unsportsmanlike conduct’ in connection with a contest or exhibition of unarmed combat. Page 4 of 61B 19 20 21 22 23 24 25 26 27 oR RELIEF SOUGHT 19. Based upon the allegations contained herein, the Executive Director prays for relief as follows ‘A. That the Commission take action against Jones's license pursuant to NRS 467.110; B. That Jones pay the applicable costs of the proceeding, including investigative costs, attomey’s fees, and/or drug testing fees; C. That Jones provide the Commission with negative urine tests for prohibited drugs upon filing his next application for an unarmed combatant's license, and D. For such other and further relief as the Commission may deem just and proper. DATED this 1st day of September, 2016. FOR THE NEVADA STATE ATHLETIC COMMISSION, DEPARTMENT OF BUSINESS AND INDUSTRY, STATE OF NEVADA a) = a Evscave Doctor & SUBMITTED BY: ‘ADAM PAUL LAXALT Atiorney General By: — /s/ Caroline Bateman CAROLINE BATEMAN Deputy Attorney General Page 5 of 6Attorney Generals Office SiS Waban Sure 2800 Tas Vega, NV BS » Sec mernNoaa 12 13 14 15 16 17 19 20 21 22 23 24 25 26 27 28 CERTIFICATE OF SERVICE | hereby certify that on the 6th day of September, 2016, | served the COMPLAINT FOR DISCIPLINARY ACTION by depositing a copy of the same in the United States mail, properly addressed, postage prepaid, CERTIFIED and REGULAR MAIL addressed as follows: Jonathan Jones 7340 SW 48th Street Miami, FL 33155 malki@firstroundmanagement.com Certified Mail No,__ 7022 L040 0000 11bb S614 Bee Ae x An Employee of the Nevada Staté Athletic Commission's Office Page 6 of 6