Received Event (Event Succeeded) Date: Pages: Sender: Fax Numhar- Typ 2005-02-10 14:19 SBBC-General Counsel 2/10/2005 Time: 2:27 PM 11 Duration: 2 min 52 sec SBBC-General Counsel Company: Suthiact- 754-321-2705 >> DOAH THE SCHOOL BOARD OF BROWARD COUNTY, FLORIDA DR. FRANK TILL, Superintendent of Schools Petitioner, vs. _ AARON MOHANLAL, O Ss -OS { | Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Dr. l’rank Till, as Superintendent of Schools, files this Administrative Complaint pursuant to Section 1001.51, 1012.27(5) and 1012.33, Florida Statutes and Chapter 120, Florida Statutes, repealed, and states the following: LJURISDI I S 1. The agency is the Schoo! Board of Broward County, Florida, which is located at 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301. 2. Petitioner is the Superintendent of Schools for Broward County, Florida. 3. Petitioner is statutorily obligated to recommend the placement of school personnel and to require compliance and observance with all laws, rules and regulations. Petitioner is authorized to report and enforce any violation thereof, together with recommending the appropriate disciplinary action against any instructional personnel employed by the Broward County School Board. 4. Respondent, Aaron Mohanla (“Mohanlal” , was employed, at all times material herein, by the Broward County School Board as a teacher at New Renaissance Middle School pursuant to a Temporary Three (3) Year Certificate which expires on June 30, 2005 and currently Received Event (Event Succeeded) Date: 2/10/2005 Time: 2:27 PM Pages: 11 Duration: 2 min 52 sec Sender: SBBC-General Counsel Company: Fax Number: Subiart- Typ 2005-02-10 14:19 SBBC-General Counsel 754-321-2705 >> DOAH holds Florida educational certificate no: 885432, 1. MATERIAL ALLEGATIONS 5. That during the 2003/2004 and 2004/2005 school years the Respondent engaged in inappropriate conduct with one of his students. 6. Specifically, the Respondent was an art teacher for the 7” grade. In May/June of 2003, the Respondent solicited a 13 year old male student, to display and permit the Respondent to touch his penis. The incident occurred in the Respondent’s office adjacent to the classroom. 7. In August of 2003, the student returned to the school and was assigned the Respondent as an art teacher. During the 2003/2004 school year, the Respondent engaged in sexual acts with the student on at least thirty (30) occasions, including masturbation and copulation, 8. The Respondent also provided the student with a cell phone in order to arrange future meetings. During these meetings, the Respondent would meet the student at a shopping center where the Respondent would place a sun visor in the windshield and perform sexual acts on the student. 9. The student graduated middle school and went on to high schoo! the following schoo! year. The Respondent would have the student cut class, while the Respondent called in sick for work. The Respondent took the student to his home, where they engaged in inappropriate sexual acts, including oral copulation. 10. During thisrelationship, the Respondent developed certain code words to usc in their discussions in the event they were overheard. These code words even provided names for their respective penis’, the Respondent's being called “Pedro” and the student’s being called “Pablo.” 11, The Respondent also produced a flyer that depicted the student kissing the Respondent’s dogs and included the following message: P 8/11 Received Event (Event Succeeded) Date: 2/10/2005 Time: 2:27 PM Pages: 11 Duration: 2 min 52 sec Sender: SBBC-General Counsel Company: Fax Numhar: Suthiart- Typ 2005-02-10 14:19 SBBC-General Counsel 754-321-2705 >> DOAH “DANGER/PET ALERT... Witnesses have come forward confessing that (victim)... Has been violating his pets...and male dogs in his neighbourhoud(sic)... He fingers their private parts, makes-out with them, jacks them, give and Receive (sic) oral sex, and penetrates them, Even in the presence of girls, he always choose his pets! IF YOU HAVE A PET/BE ON GUARD!” 12. The Respondent was eventually arrested by the Miramar Police and charged with thirty-seven (37) counts of Lewd and Lascivious Molestation in violation of Florida State Statute 800.04 (5¢2). 1. IMMORALITY 13. Respondent has violated Fla. Stat, §§ 1012.36(1 (a) and 1012.33(1)(a) and Rule 6B- 4.009(2) of the Florida Administrative Code. Respondent's acts constitute acts of immorality, that is, conduct inconsistent with the standards of public conscience and good morals, Respondent's conduct is sufficiently notorious to bring Respondent and/or the educational profession into public disgrace or disrespect, and impair Respondent’s service in the community. - MISCONDUCT FFICE 14, Respondent has violated Fla. Stat. § 1012.33(1)(a) and Rule 6B-4.009(3). Respondent’s actions constitute misconduct in office through violation of the Principles of Professional Conduct for the Education Profession in the State of Florida and the Standards of Competent Professional Performance for the Education Profession in the State of Florida, to wit: (3) Obligation to the student requires that the individual: (a) shall make a reasonable effort to protect the student from conditions harmful to learning and/or to the student's mental and/or physical health and/or safety. (b) shall not unreasonably restrain a student from independent action in pursuit of learning. Received Event (Event Succeeded) Date: 2/10/2005 Time: 2:27 PM Pages: 11 Duration: 2 min 52 sec Sender: SBBC-General Counsel Company: Fax Numher- Suhiact- Typ 2005-02-10 14:19 SBBC-General Counsel 754-321-2705 >> DOAH (e) shall not intentionally expose a student to unnecessary embarrassment or disparagement. 169) shall not intentionally violate or deny a student’s legal rights, (h) shall not exploit a relationship with a student for personal gain or advantage. 4 @ shall take reasonable precaution to distinguish between Personnel views and those of any educational institution or organization. ©) shall not use institutional privileges for personal gain or advantage. 3. MORAL TURPITUDE 15. Respondent has violated Fla. Stat. § 1012.33(1)(a) and Rule 6B-4.009(6) of the Florida Administrative Code. Respondent's acts constitute acts of moral turpitude, that is, acts of baseness, vilencss or depravity in the private and social duties, which, according to the accepted standards of the time, a person owes to his fellow human or to society in general, and the doing of the act itself and not its prohibition by statute fixes the moral turpitude. 16, This Administrative Complaint is brought pursuant to the authority outlined in Fla. Stat. §§ 120.57; 1001.42; 1012.22; 1006.07; 1006.28; 1006.21; 1001.50; 1001.49; 1001.51; 1012.27; 1006.08; 1012.33(1}(a) and Chapters 6B-1 and 6B-4 of the Florida Administrative Code and the appropriate bill or rules. ill. DEMAND FOR RELIEF WHEREFORE, based upon the foregoing, Petitioner, Dr. Frank Till, Superintendent of Schools, recommends that the School Board, subsequent to providing the requisite notice, dismiss the Respondent, Aaron Mohanlal, from his employment based upon the foregoing facts and legal authority. Petitioner further, recommends the immediate suspension of Respondent without further 10 P 10/11 Received Event (Event Succeeded) Date: 2/10/2005 Time: 2:27 PM Pages: 1 Duration: 2 min 52 sec Sender: SBBC-General Counsel! Company: Fax Number: Suhiart- Typ 2005-02-10 14:19 SBBC-General Counsel 754-321-2705 >> DOAH ; P 11/11 pay or benefits in the event the Respondent should challenge the school board’s recommendation of the termination of his employment. EXECUTED this 25 _ day of January, 2005. an County Supérmtendent of Schools,

Docket for Case No: 05-000511