STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 156-2401 MARY A. O’CONNELL, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against MARY A. O’CONNELL. 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 1034180, covering the areas of English, English for Speakers of Other Languages (“ESOL”), Reading and Exceptional Student Education, which is valid through June 30, 2019. 2. At all times pertinent hereto, the Respondent was employed as a Language Arts Teacher at Pinellas Park High School in the Pinellas County School District. MATERIAL ALLEGATIONS 3. On or about December 14, 2015, Respondent called J.N., a tenth-grade student, a “bitch,” on school grounds and during school hours. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of section 1012.795(1)@), Florida Statutes, MARY A. O’CONNELL Administrative Complaint Page 2 of 2 in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. RULE VIOLATIONS COUNT 2: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2){a)1, 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 student’s mental health and/or physical health and/or safety. 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 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 Réspondent 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; 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. EXECUTED on this 6% day of__ September. 2016. ca a TAZ Lower} PAM STEWART, as Commissioner of Education State of Florida STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, V5. Case No.: 156-2401 MARY O’CONNELL, Respondent. — NOTICE OF APPEARANCE Please take notice that the undersigned hereby files this Notice of Appearance on behalf of the Respondent in the above-referenced matter. Copies of all pleadings, notices and correspondence regarding the above-referenced matter(s) are tequested to be served on the undersigned. Respectfully submitted this 9° day of August, 2016. /s{ Branden Vicari Branden Vicari, Esq. Herdman & Sakellarides, P.A. 29605 U.S. Hwy 19 North, Suite 110 Clearwater, Florida 33761 (727) 785-1228 (727) 786-4107 (Fax) Florida Bar No. 0086830 Attorney for Respondent CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via e- mail to Bonnie Wilmont, Esq., @ bonnie.wilmont@fldoe.org, and tracey.tobert@fldoe.org, this 9th day of August, 2016. si Branden Vicari Branden Vicari

Docket for Case No: 17-003293PL