STATE OF FLORIDA EDUCATION PRACTICES COMMISSION RICHARD CORCORAN, as Commissioner of Education, Petitioner, vs. CASE NO. 178-2824 ANGEL OSCAR CABALLERO, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Richard Corcoran, as Commissioner of Education, files this Administrative Complaint against ANGEL OSCAR CABALLERO. 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 1156557, covering the area of Physical Education, which is valid through June 30, 2024. MATERIAL ALLEGATIONS 2. On or about April 16, 2018, Respondent took the General Knowledge Essay of the Florida Teacher Certification Examination. This was Respondent’s sixth time taking the General Knowledge Essay of the Florida Teacher Certification Examination. 3. On or about April 30, 2018, Leisy Otuzar took the General Knowledge Essay of the Florida Teacher Certification Examination. This was Leisy Otuzar’s sixth time taking the General Knowledge Essay of the Florida Teacher Certification Examination. 4. On or about May 18, 2018, Leisy Otuzar’s General Knowledge Essay Test Score was invalidated because of significant similarities between her General Knowledge Essay and Respondent’s General Knowledge Essay indicating possession of the exam questions, prompts, Probable Cause Letter and Administrative Complaint. (Amended from Denial)-2 ANGEL OSCAR CABALLERO Administrative Complaint Page 2 of 3 answers or responses, in advance of the examination and/or writing an essay that was prepared before the examination. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of section 1012.795(1)(a), Florida Statutes, in that Respondent obtained or attempted to obtain a teaching certificate by fraudulent means. 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. COUNT 3: The Respondent is subject to section 1012.795(1)(p), Florida Statutes, in that Respondent has violated test security as provided in section 1008.24, Florida Statutes. RULE VIOLATIONS COUNT 4: 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. COUNT5: 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. COUNT 6: The Respondent is in violation of Rule 6A-10.081(2)(c)12, Florida Administrative Code, in that Respondent has assisted into entry or continuance in the profession of a person known to be unqualified in accordance with the Principles of Professional Conduct of the Education Profession in Florida and other applicable Florida Statutes and State Board of Education Rules. (SIGNATURE ON FOLLOWING PAGE) Probable Cause Letter and Administrative Complaint. (Amended from Denial)-3 ANGEL OSCAR CABALLERO 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 { 7] dayof June _, 2020. fc Mc RICHARD CORCORAN, as Commissioner of Education State of Florida Probable Cause Letter and Administrative Complaint. (Amended from Denial)-4

Docket for Case No: 21-000729PL