STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 167-1817 KIMBERLY R. LASTNER, Respondent. / ADMINISTRATIVE COMPLAINT. Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against KIMBERLY R. LASTNER. 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 1275535, covering the areas of English and Reading, which is valid through June 30, 2020. 2. At all times pertinent hereto, the Respondent was employed as an English Teacher at PACE Center for Girls in the Lee County School District. MATERIAL ALLEGATIONS 3. On or about March 9, 2016, Respondent submitted fraudulent information in an educational matter when she submitted an application to add the subject area of Reading to her Florida Educator’s Certificate and falsely answered “No” to the following questions: 1. Have you ever had a professional license sanctioned or disciplined in this state or another state? KIMBERLY R. LASTNER Administrative Complaint Page 2 of 3 2. Have you ever had a professional license suspended or revoked in this state or any other state? On or about June 12, 2015, Respondent’s Maryland teaching certificate was suspended for a period of one year. Respondent was notified of the suspension prior to the submission of her application. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of section 1012.795(1)(e), Florida Statutes, in that Respondent has had an educator certificate sanctioned by revocation, suspension, or surrender in another state. COUNT 2: 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 3: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(c)1, Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. COUNT 4: The Respondent is in violation of Rule .6A-10.081(2)(c)8, Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. (SIGNATURE ON FOLLOWING PAGE) KIMBERLY R. LASTNER 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 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; 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 9YA day of wae , 2017. ld —heveerf PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 18-000155PL