FiLED STATE OF FLORIDA EDUCATION PRACTICES COMMISSREYCT 10 AM II: 31 , DIVISION OF JEANINE BLOMBERG, as 0 is SO Y Y fL Ar SRA IVE Commissioner of Education, Petitioner, vs. CASE NO. 056-3058-A KEITH ALAN PAVLICK, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Jeanine Blomberg, as Commissioner of Education, files this Administrative Complaint against KEITII ALAN PAVLICK. The Petitioncr secks 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 819162, covering the area of Elementary Education, which was valid through June 30, 2006. 2. At all times pertinent hereto, the Respondent was employed as a Social Studies Teacher at Bellalago Academy in the Osceola County School District. MATERIAT. ALLEGATIONS 3. During the 2005/2006 school year, Respondent exhibited aggressive behavior towards students and colleagues (hat escalated to the point of physical violence and intimidation. Examples of Respondent’s behavior include but are not limited to: A, On or about March 2, 2006, Respondent pursued B.O., a fiftcen-year-old, male student, in the hallway and shoved him in the back for talking too loudly while Respondent's class was going on. When B.O. objected, Respondent proceeded to yell at him cven after he had been instructed by an administrator to stop. On or about April 23, 2006, the district issued KEITH ALAN PAVLICK Administrative Complaint Page 2 of 3 Respondent a letter of reprimand with regard to the incident. B. In the fall semester, Respondent became upset when a student he referred for discipline was returned to his class after a onc half day suspension. As a result, Respondent confronted the Dean of Students by yelling and pointing his finger in her face with so much - aggression that latcr in the day the dean locked herself in her office to avoid him. Cc. Respondent made statements to his class such as, “I can’t stand you all,” “You're a bunch of idiots,” and “You make me sick,” or words to that effect. Dd. On or about May 1, 2006, upon returning to school from an allernative assignment, Respondent stated to another teachcr and within earshot ofa large number of students, “I wasn’t going to come back, but I came back to stick it to some people,” or words to that effect. The Petitioner charges: 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 Respondent is 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 schuol board. COUNT3: Thc Respondents 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. RULE VIOLATIONS 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 studcnt’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. KEITH ALAN PAVLICK Administrative Complaint Page 3 of 3 COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(d), Florida Administrative Code, in that Respondent has engaged in harassment or discriminatory conduct which unreasonably interfered with an individua]’s performance of professional or work responsibilitics or with the orderly processes of education or which created a hostile, intimidating, abusive, offensive, or oppressive environment; and further, failcd to make reasonable effort to assure that each individual was protected from such harassment or discrimination. WHEREFORE, based on the reasons set forth horcin and in accordance with the Explanation of Rights and Election of Rights forms attached to and made a part of this Administrative Complaint, Petitioner respectfully recommends that the Education Practices Commission impose an appropriate sanction against the Respondent’s educator’s certificate pursuant to the authority provided in Sections 1012.795(1) and 1012.796(7), Florida Statutes. The sanctions imposed by the Education Practices Commission may include, bul are not limited to, any one or a combination of the following: issuing the Respondent a written reprimand; placing the Respondent on probation for any period of time; restricting the Respondent's authorized scope of practice; assessing the Respondent an administrative fine; directing the Respondent to enroll in the Recovery Network Program; suspending the Respondent’s educator’s certificate for a period of time not to exceed five years; revoking the Respondent’s educator’s certificate for a period of time up to 10 years or permanently; or barring the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently. EXECUTED on this_ © day of Deplembec 2007. Kenene Slowberg JEANINE BLOMBERG, as Commissioner of Education State of Florida

Docket for Case No: 08-005044PL