STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JOHN L. WINN, as Commissioner of Education, Petitioner, vs. ; CASE NO. 045-1233-V ANTHONY LALLI, ' Hlo-O770 PE Respondent. / 8 ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against ANTHONY LALLI. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 1012.795 and 1012.796, Florida Statutes, and pursuant to Rule 6B-1,006, Florida Administrative Code, Principles of Professional Conduct for the Education Profession in Florida, said sanctions specifically set forth in Sections 1012.795(1) and 1012.796(7), Florida Statutes. The Petitioner alleges: JURISDICTION “ 1. The Respondent holds Florida Educator’s Certificate 792915, covering the area of Music, which is valid through June 30, 2008. 2. At all times pertinent hereto, the Respondent was employed as a Music Teacher at Hollywood Hills Elementary School in the Broward County School District. MATERIAL ALLEGATIONS 3. During the 2001 -2002 school year, Respondent engaged in inappropriate conduct with minor female students. Respondent’s inappropriate conduct included hugging various students and also included, but is not limited to, the following. a. Respondent inappropmiately touched the chest areas of K.D., J.B., B.P. (twice) and ALL., all were fifth grade students. ~ ANTHONY LALLI Administrative Complaint 2: 40 Page 2 of 3 GOFEB IS AW 8 45 b. Respondent inappropriately touched or mule Geteehy K_D. (touched inner thigh area below her privates), K.P. (rubbed upper thigh area), T BY ‘dGBbet tlegs close to private area, touched under shorts close to private area), JE. (rubbed from hip down leg), and A.L. (touched outside thigh area and on top of leg). All students were in fifth grade, except T.B., who was in second grade. c. Respondent inappropriately touched the bras or bra straps of T.M., K.P., T.C. and S.B., all were fifth grade students. d. Respondent inappropriately touched or rubbed the shoulders or neck area of B.P., KP., T.C., J.E. and M.D. (three times), all were fifth grade students. ae @. Respondent inappropriately massaged T.B. (rubbed her back near her butt and side butt area) and S.B. (massaged her arm). T.B. was a second grade student and S.B. was a fifth grade student. f. Respondent inappropriately hugged T.B., J.E., $.B. and A.L. All were fifth grade students, except T.B., who was in second grade. g. Respondent had female students sit on his lap, including A.R. h. Respondent took inappropriate pictures of students, including M.D. On or about June 5, 2002, Respondent was arrested and charged with three counts ofa Lewd and Lascivious Act—Indecent Assault on a Child Under 16 regarding his inappropriate conduct with * J.B., K.D. and B.P. On or about January 31, 2005, the superintendent filed an administrative complaint against Respondent seeking his dismissal. STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT 2: The Respondentis in violation of Section 1012.795(1)(f), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. COUNT 3: The Respondentis in violation of Section 1012.795(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. Ee ie ANTHONY LALLI AM 8:45 “ 4. Administrative Complaint FY >, bo Page 3 of 3 kay RULE VIO: AnTrONS oe me ARE Al ve COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(a), Florida Administrative Code, in that Respondent has failed to make reasonable effort to protect the student from conditions harmful to learning and/or to the student’s mental health and/or physical health and/or safety. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6B- 1,006(3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(g), Florida Administrative Code, in that Respondent has harassed or discriminated against a student on the basis of race, color, religion, sex, age, national or ethnic origin, political beliefs, marital status, handicapping condition, sexual orientation, or social and family background and shall make reasonable effort to assure that each student is protected from harassment or discrimination. COUNT 7: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 1012.795(1) and 1012.796(7), Florida Statutes, which penalty may include a reprimand, probation, restriction of the authorized scope of practice, administrative fine, suspension of the teaching certificate not to exceed *’ three years, permanent revocation of the teaching certificate, or combination thereof, for the reasons set forth herein, and in accordance with the Explanation and Election of Rights forms which are attached hereto and made a part hereof by reference. EXECUTED on this ‘I day of > oplenboar , 2005. Phin JO Commissioner of Education State of Florida

Docket for Case No: 06-000770PL