i 9 STATE OF FLORIDA : EDUCATION PRACTICES COMMISSION JEANINE BLOMBERG, as ( 1 . OSO « PL Commissioner of Education, 2009 ey Petitioner, vs. CASE NO. 056-3454-T HELEN VIRGINIA WADE, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Jeanine Blomberg, as Commissioner of Education, filés this Administrative Complaint against HELEN VIRGINIA WADE. 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 291119, covering the areas of Speech Correction, Gifted, and Teacher Coordinator of Work Experience Programs, which is valid through June 30, 2010. 2. At all times pertitent hereto, the Respondent was employed as an Exceptional Student Education Speech Language Pathologist at Charles Drew Middle School in the Miami-Dade County School District. : MATERIAL ALLEGATIONS 3. During August 2005, Respondent submitted a transcript showing the conference of a doctoral degree from a non-accredited school to the Miami-Dade County Schools Office of Compensation for the purpose of receiving additional compensation from the district. Additionally, Respondent submitted documents that indicated she had completed course work and graduated Magna Cum Laude when in fact she had never attended the school or completed any online or correspondence courses. On or about March 31, 2006, Respondent resigned from her teaching HELEN VIRGINIA WADE Administrative Complaint Page 2 of 3 position with the district. 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 her effectiveness as an employee of the school board. COUNT3: The Respondent is in violation of Section 1012.795(1)(), 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(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. COUNTS: The Respondentis in violation of Rule 6B.1006(5)(g), Florida Administrative Code, in that Respondent has misrepresented one's own professional qualifications. COUNT6: TheRespondentis in violation of Rule 6B.1006(5)(h), Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. COUNT?7: The Respondent isin violation of Rule 6B.1006(5)(i), Florida Administrative Code, in that Respondent made a fraudulent statement or failed to disclose a material fact in one's own or another’s application for a professional position. (SIGNATURE ON FOLLOWING PAGE) HELEN VIRGINIA WADE Administrative Complaint Page 3 of 3 WHEREFORE, based on the reasons set forth herein 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 approptiate 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, but 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 22™iny of March 2007. JEANINE BLOMBERG, as Commissioner of Education State of Florida

Docket for Case No: 09-000508PL