STATE OF FLORIDA CRIMINAL JUSTICE STANDARDS AND TRAINING COMMISSION CRIMINAL JUSTICE STANDARDS AND TRAINING COMMISSION, Petitioner, O i OY: 45 vs, CASE NO. 25152 James S, Brown, Respondent. / ADMINISTRATIVE COMPLAINT The Criminal Justice Standards and Training Commission, hereinafter referred to as the Commission, files this Administrative Complaint against the Respondent, James S. Brown. The Commission seeks to impose disciplinary action upon the referenced individual based on the following allegations: 1. Respondent was certified by the Criminal Justice Standards and Training Commission on June 25, 1986, and was issued Law Enforcement Certificate Number 62023 and on April 26, 2000, was issued Instructor Certificate Number 211135. 2. (a) On or between September 1, 2006 and December 31, 2006, the Respondent, James S. Brown, did then while employed as a law enforcement officer with the Alachua County Sheriff's Office, engage in sexual contact with another, while on duty. (b) On or about February 20, 2007, the Respondent, James S. Brown, did unlawfully make a false statement, which he or she did not believe to be true, under oath administered by Inspector Mike Jones in an official proceeding, to wit: an internal investigation, in regard to a material matter. 3. The actions of the Respondent did violate the provisions of Section 837.02(1) or any lesser included offenses, Section 943.1395(7), Florida Statutes, and Rules 11B-27.0011(4)(c), (a) and 11B- 20.0012(2)(f), Florida Administrative Code, in that Respondent has failed to maintain the qualifications established in Section 943.13(7), Florida Statutes, which require that a Law Enforcement and Instructor officer or Instructor in the State of Florida have good moral character and which gives rise to a disciplinary action against Respondent's certification. 4. This Administrative Complaint is issued pursuant to Sections 120.60, 943.12(3), and 943.1395(7), Florida Statutes. Any proceedings concerning this Complaint shall be conducted pursuant to Sections 120.569 and 120.57, Florida Statutes, and Chapters 11B-20, 11B-27, 28-106, and 28-107, Florida Administrative Code. Mediation is not available under Section 120.573, Florida Statutes. WHEREFORE, it is alleged that the Respondent, James S. Brown is guilty of violating Sections 943.1395(7), and 943.13(7), Florida Statutes, and Rules 11B-27.0011(4)(c), (a) and 11B-20.0012(2)(), Florida Administrative Code. NOW, THEREFORE, the Florida Criminal Justice Standards and Training Commission hereby complains against James S. Brown and alleges that an appropriate penalty, as provided in Section 943.1395(7), Florida Statutes, should be imposed for the reasons set forth above and in accordance with the Election of Rights form (to which is attached an Explanation of Rights form) attached hereto and incorporated herein. BY ORDER OF THE CRIMINAL JUSTICE STANDARDS AND TRAINING COMMISSION THIS 7th DAY OF November, 2007. CERTIFICATE OF SERVICE THEREBY CERTIFY that a true copy of the foregoing has been served pursuant to Section 120.569 and Section 120.60, Florida Statutes, this 9th day of November, 2007, to James S. Brown, at 1203 SE 19th Terrace, Gainesville, Florida 32641. /sb ce: Alachua County Sheriff's Office

Docket for Case No: 08-000245PL