Feb 26 2008 15:25 2008-02-26 15:28 >> 8509216847 P 6/10 THE SCHOOL BOARD OF BROWARD COUNTY, FLORIDA JAMES F.NOTTER, Superintendent of Schools Petitioner, V5. CONRAAD L. HOEVER Respondent. ADMINISTRATIVE COMPLAINT Petitioner, JAMES F. NOTTER, as Superintendent of Scheols, files this Administrative Complaint, pursuant to Section 1001.49, 1001.51, 1012.27(5) and 1012.33, Florida Statutes and Chapter 120, Florida Statutes, and states the following LJURISDICTIONAL BASIS }. The agency is the School Board of Broward County. Florida. which is located al 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Flarida 3330]. 2. Petitioner is the Superintendent of Schools for Broward County, Florida 3. Petitioner is statutorily obligated to recommend the placement of schoo! personne! and to requite compliance and observance with all laws, niles 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, Conraad {.. Hoever (“Hoever”), was employed, at all tmcs material herein, as a teacher at Blanche Ely High Schoo! pursuant to an Employment Contraet with the Broward County School Distriet Feb 26 2008 15:25 2008-02-26 15:28 >> 8509216847 P 7/10 I, MATERIAL ALLEGATIONS 5. On March 2, 2007, Respondent did intentionally touch a fiftcen (15) year-old female student (K.W.), in a lewd or lascivious or otherwise inappropriate manner. 6. Further, during the 2006/2007 schoo! year the Respondent made inappropriate comments to female student(s) on one or mere occasions. 7. That subsequently, the Respondent was arrested and criminally cnarged by information with threc (3) criminal counts of sexual battery, lewd or lascivious molestation and false Imprisomment. l._ IMMORALITY 8. Respondent has violated Fla. Stat. §§ 1012.36(1}(a) and 1012.33() )(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 gaod morals. Respondent's conduct is sufficicntly notorious to bring Respondent and/or the educational profession inte public disgrace or disrespect, and impair Respondent's service in the community. 2, MISCONDUCT IN OFFICE 9. Respondent has violated Fla. Stat. § 1012.33(1)(a) and Rule 6R-4.009(3) Respondent's actions constitute misconduct jn office through violation of the Principles of Professional Conduct for the Education Profession in the State of Florida and the Standards cf Competent Professional Performance for the Education Profession in the State of Florida, to wit: (3) Obligation to the student requires that the individual: (a) shal] make a reasonable cffort to protect the student from conditions harmful to learning and/or to the student's mental and/or physical health and/or safety. Feb 26 2008 15:25 2008-02-26 15:28 >> 8509216847 P 8/10 (b) shail not unreasonably restrain a student from independent action in pursuit of learning. (e) shall not intentionally expose a student to unnecessary embarrassment o: disparagement. () shall not intentionally violate or deny a student's legal rights. th) shall not exploit a relationship with a student for personal gain or advantage (4) (a) shall take reasonable precaution to distinguish berween personnel views and those of any educational institution or organization (c) shall not use institutional privileges for persona: gain or advantage. 3. MORAL TURPITUDE 10, Respondent has violated Mla. Stat. § 1012.33(1)(a} and Rue 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 accepled standards of the time. 4 person owes to his fellow human or to society in general, and the doing of the act itself and not its prohibition by stature fixes the moral turpitude. 1. This Administrative Comolaint is brought pursuant to the autherity outlined tn Fla, Stat. §§ 120.57: 1001.42; 1012.22: 1006 07; 1006.28: 1006.22; 1001 $0, 1001.49:100) 51, 1012.27, 1006.08; 1012.33(1)(a} and Chapters 6B-] and 6B-4 of the Florida Administrative Code and the appropriate bill or rules. IL_DEMAND FOR RELIEF WHEREFORE, based upon the foregoing, Petitioner, James F. Wolter. Superintendent of Schools, recommends that the Schoo] Board, subsequent to providing the requisite notice. dismiss the Respondent, Conraad L. Hoever. from his employment basedl upon the forcgaing facts and legal Feb 26 2008 15:25 >> 8509216847 2008-02-26 15:28 authority. Petitioner further, recommends the immediate suspension of Respondent without further pay or benefits in the event the Respondent should challenge the schoo! board's recommendation of the termination of his employment. o EXECUTED this 4 day of January, 2008 o f WMIES F. NOTTER / Stoperintondent af Schools. Broward County P 9/10

Docket for Case No: 08-001026TTS