THE SCHOOL BOARD OF BROWARD COUNTY FLOR WD» - / , AM Ip. 4 al! 14849 10: 56 JAMES F. NOTTER, Superintendent of UE Schools, ‘ Petitioner, CASE NO.: ; vs }O-OWSY ALEXANDRA KRALIK, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, JAMES F. NOTTER, Superintendent of Schools of Broward County, Florida, by and through his undersigned counsel, the Law Offices of Panza, Maurer & Maynard, P.A., files this administrative complaint pursuant to Chapter 120, 1001 and 1012 of the Florida Statutes as well as Chapter 6B-1 and 6B-4 of the Florida Administrative Code and states the following: I. JURISDICTIONAL BASIS i. The agency is the School Board of Broward County, Florida, located at 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301. 2. The Petitioner is James F. Notter, who is the Superintendent of Schools of Broward County, Florida. His address is located at 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301. 3. The Petitioner is statutorily obligated to recommend the placement of school personnel and to require compliance in observance with all of the laws, rules and regulations. Any violation thereof shall be reported with the appropriate disciplinary action against any School Board personnel failing to comply therewith, inclusive of the Respondent Alexandra Kralik. 4. The Respondent, Alexandra Kralik is an employee of the Broward County School Board and is currently employed as a teacher at A. C. Perry Elementary School. 5. The last known address of the Respondent, Alexandra Kralik, is 5730 Raleigh Street, Hollywood, Florida 33021. 6. The legal basis for Alexandra Kralik’s termination is for misconduct in office that has been deemed so serious as to impair her effectiveness within the district. (See § 1012.33 (1)(a), (6)(a)). Il. ADMINISTRATIVE CHARGES 7. On or about September 3, 2009, the Respondent engaged in inappropriate conduct and contact with a minor student ranging from pushing, pulling and/or grabbing a minor student’s person or apparel to yelling loudly at the student and uttering statements to the student of a derogatory nature. 8. Alexandra Kralik has been counseled and disciplined repeatedly in the past to correct behavior similar to that which is the subject of these proceedings wherein which she improperly pushed, pulled or touched the person or apparel of students under her charge, and engaged in inappropriate or threatening verbal communications. 9. Prior to the incident giving rise to these administrative proceedings, the School Board has taken lesser corrective measures against Alexandra Kralik including counseling and suspension, but she has failed to abide by such counseling and lesser disciplinary measures. 10. Just cause exists for the relief requested pursuant to § 1012.33 (1)(a) and § 1012.33 (4)(c), the Respondent’s contract, School Board Rules and Regulations, the Code of Ethics of the education profession, and the employee disciplinary guidelines promulgated by the School Board including but not limited to the following: (A) Misconduct in Office. The Respondent through her above-described conduct has violated § 1012.33 (1)(a) and § 1012.33 (4)(c) Fla. Stat. and Rule 6B-41009 (3) of the Florida Administrative Code, and her actions constitute misconduct in office through violations of various provisions of the Code of Ethics of the Educational Professional, Rule 6B-1.001, 6B- 1.006 Florida Administrative Code.; (B) Immorality. The Respondent through the above-described conduct has violated § 1012.33 (4)(c) Fla. Stat. and Rule 6B-4.009(2) of the Florida Administrative Code and her actions constitute immorality, that is conduct inconsistent with the standards of public conscience and good morals. Additionally the Respondent’s above-described conduct further violates the Code of Ethics of the Educational Professional, Rule 6B-1.001, 6B-1.006, Florida Administrative Code. The Respondent’s conduct as factually set forth herein is sufficiently notorious to bring the Respondent and/or the educational profession into public disgrace or disrespect and impair the Respondent’s service in the community.; (C) Incapacity. The Respondent through her above-described misconduct has violated § 1012.33(4)(c) Fla. Stat., and Rule 6B-4.009(1)(b)(1) of the Florida Administrative Code, and her actions evidence a lack of emotional stability which creates a hostile environment for both the students as well as the Respondent’s colleagues. WHEREFORE, based upon the foregoing, the Petitioner, James F. Notter, Superintendent of Schools, recommends that the School Board, subsequent to providing requisite notice, dismiss the Respondent, Alexandra Kralik from her employment as an instructional employee based upon the foregoing facts and legal authority. DATED this g day of January, 2010. AMES F. NOTTER, Superintendent Superintendent of Schools Respectfully submitted, PANZA, MAURER & MAYNARD, P.A. Attorneys for Petitioner BROWARD COUNTY SCHOOL BOARD Bank of America Building — Third Floor 3600 North Federal Highway Fort Lauderdale, Florida 33308 Telephone: (954) 390-0100 Facsimile: (954) 390-7991 FACLIENT\1190\09- 18301 PLEADINGS\ADMNISTRATIVE COMPLAINT - KRALIK.DOC

Docket for Case No: 10-000654TTS