STATE OF FLORIDA EDUCATION PRACTICES COMMISSION DR. TONY BENNETT, as Comunissioner of Education, Petitioner, ys. CASE NO. 123-1703 PAMELA PRUDENT, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Dr. Tony Bennett, as Commissioner of Education, files this Administrative Complaint against PAMELA PRUDENT. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 1012.315, 1012.795, and 1012.796, Florida Statutes, and pursuant to Rule 6A-10.081, 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 1016298, covering the areas of Reading and Marketing, which is valid through June 30, 2014, 2. Atall times pertinent hereto, the Respondent was employed as a Marketing Teacher at Miami Central Senior High School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3. On or about August 26, 2009, the Respondent signed a form entitled “2009-2010 Miami-Dade County Public Schools Application for Free and Reduced Price Meals.” By signing the document, the Respondent certified that all information submitted on the form was true and included all household income. The Respondent misrepresented her income and failed to state the income of other members of the Respondent’s household. 4. On or about August 26, 2010, the Respondent signed a form entitled “2010-2011 Miami-Dade County Public Schools Application for Free and Reduced Price Meals.” By signing PAMELA PRUDENT Administrative Complaint Page 2 of 3 the document, the Respondent certified that all information submitted on the form was true and included all household income. The Respondent omitted her income.and misrepresented the income of other members of the Respondent’s household. 5. As a result of the Respondent’s application for free and reduced price meals, the Applicant’s three children who attended public schools in Miami-Dade County Public Schools received benefits for which they were not qualified for nor entitled to, including free and reduced price school meals, tutoring, and waivers of testing fees. 6. On or about November 26, 2012, the Miami-Dade County School District notified the Respondent of its intention to terminate the Respondent’s employment. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(d), Florida. Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude as defined by rule of the State Board.of Education. COUNT 2: The Respondent is in violation of Section 1012.795(1)(g), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces her effectiveness as an employee of the school board. COUNT 3: The Respondent is in violation of Section 1012.795(1)Q), 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 6A- 10.081(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. (SIGNATURE ON FOLLOWING PAGE) PAMELA PRUDENT 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 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, but are not limited to, any one ora 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 Prograrn; 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; determining the Respondent to be ineligible for certification; or barring the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently. 32013. ay DR. TONY BENNETT as Commissioner of Education State of Florida EXECUTED on this ie _ day of

Docket for Case No: 13-004960PL