In the Show Cause Notice dated 22 July 2011, Racing NSW particularised the conduct and behaviour (the subject of the notice) alleged against Mr Barnes. It reads as follows:

i) You failed to surrender to the Stewards of Racing NSW the Registration document/card for the horse ZACCONI despite being issued a direction to do so by Mr. Ray Murrihy, Racing NSW Chairman of Stewards. ...

ii) You failed to attend a steward's inquiry set for Monday 21 March 2011 despite being issued a direction to do so by My (sic) Ray Murrihy, Racing NSW Chairman of Stewards. ...

iii) In January 2010 you sold the registered thoroughbred mare HELVIA to licensed trainer Michelle Tucker of Cessnock, NSW for which she paid you the sum of $7,000, the sale did not proceed as another person Mr. Les Smith had ownership of the Horse, and you failed to repay Ms Tucker the full $7,000 having repaid $1,000 in January 2010 and $2,500 in February 20101 leaving $3,500 outstanding. ...

iv) In February 2011 you sold the thoroughbred mare MISS DODDS (NSW) to Mr Steve Hawkes of Mt Walker Queensland for which he paid you the sum of $13,500 + GST, you then failed to deliver the horse to Mr Hawkes and failed to refund the purchase price to Mr Hawkes when the sale did not proceed. ...

A second Show Cause Notice dated 1 August 2011 alleged an additional matter against Mr Barnes as follows:

v) In June 2011 you sold the thoroughbred mare TRACKO to Queensland licensed Trainer Mr Neil Hocking on behalf of his client Mr Shum Rane for which you were paid in the sum of $9,500, you then failed to deliver the horse to Mr Hocking and failed to refund the purchase price when the sale did not proceed. ...

From- http://www.racingnsw.com.au/site/_content/document/00000771-source.pdf