FROM: The Education Practices Commission TO: DOAH Clerk of Court RE: REDACTION OF CERTAIN LANGUAGE The Education Practices Commission reviewed and redacted certain verbiage within the documents included prior to transferring the case to DOAH so that the Respondent/Educator’s home address; telephone number; date of birth; and photographs remain exempt from public records in accordance with Section 119.071(4), F.S. {2018). STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, VS. CASE NO. 156-3036 YADIRA DESVERGUNAT, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against YADIRA DESVERGUNAT. 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 1185540, covering the areas of Gifted and Exceptional Student Education (ESE), which was valid through June 30, 2017. 2. At all times pertinent hereto, the Respondent was employed as an Assistant Principal at Pathways Academy Charter School in the Broward County School District. MATERIAL ALLEGATIONS 3. Between the months of May and August, 2015, Respondent directed Assistant Principal (AP) Ramjit, to generate fraudulent Individual Education Plans (IEP’s) and code of conduct acknowledgment forms in preparation of a district monitoring visit and to forge the signatures of both students and parents. When AP Ramjit refused, Respondent forged the signatures herself. YADIRA DESVERGUNAT Administrative Complaint Page 2 of 3 The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of section 1012.795(1)(j), 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 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. 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 allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(c)6, Florida Administrative Code, in that Respondent has used coercive means or promised special treatment to influence professional judgments of colleagues. COUNT 5: 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) YADIRA DESVERGUNAT 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 th day of duly , 2017. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 18-005531PL