Dp-DUS De. STATE OF FLORIDA a a a Charlie Crist, as Commissioner of Education, Petitioner, vs. CASE NO. 001-1485-C KRISTIN EZQUERRA, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against Kristin H. Ezquerra. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 231.262 and 231.2615, Florida Statutes, and pursuant to Rule 6B-1.006, Florida Administrative Code, Principles of Professional Conduct for the Education Profession in Florida, said sanctions specifically set forth in Sections 231.262(6) and 231.2615(1), Florida Statutes. The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 755347, covering the area of Elementary Education, which was valid through June 30, 2001. 2. At all times pertinent hereto, the Respondent was employed as an ESE Teacher at Patterson Elementary School in the Clay County School District. Kristin H. Ezquerra Administrative Complaint Page 2 of 3 MATERIAL ALLEGATIONS 3. During the 2000-2001 school year, Respondent submitted forged documents to obtain leave and was otherwise absent from campus on more than one occasion without permission and without having accurately signed out. Specifically, on or about January 10, 2001, Respondent submitted, through her husband, a form for Family Medical Leave indicating that she was undergoing surgery that day and would be out through January 16, 2001. Respondent forged, or caused to be forged, the doctor’s signature on that form and presented a document she knew to be forged to the school district to qualify for leave to which she was not entitled. On or about January 22, 2001, Respondent failed to obtain permission to leave early and gave conflicting accounts of the reason for her absence. Respondent was also absent on the following day for medical reasons. On or about February 16, 2001, Respondent was supposed to attend a workshop, but failed to do so and did not sign out accurately for that day. 4. On or about February 27, 2001, Respondent was notified that the superintendent would seek her suspension and termination. Respondent was directed to remove her personal belongings from the classroom and to return any and all keys to her principal. Thereafter, Respondent vandalized the classroom and failed to return any keys. 5. On or about February 28, 2001, the school district suspended Respondent with pay. On or about March 15, 2001, the school district terminated Respondent’s contract effective March 16, 2001. STATUTORY VIOLATIONS COUNT 1: The allegations of misconduct set forth herein are in violation of Section 231.2615(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT 2: The allegations of misconduct set forth herein are in violation of Section 231.2615(1)(f), Florida Statutes, in that Respondent, upon investigation, has been found guilty of personal conduct which seriously reduces her effectiveness as an employee of the school board. COUNT 3: The allegations of misconduct set forth herein are in violation of Section 231.2615(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession in Florida prescribed by State Board of Education. RULE VIOLATIONS COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. Kristin H. Ezquerra Administrative Complaint Page 3 of 3 WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 231.262(6) and 231.2615(1), Florida Statutes, which penalty may include a reprimand, probation, restriction of the authorized scope of practice, administrative fine, suspension of the teaching certificate not to exceed three years, permanent revocation of the teaching certificate, or combination thereof, for the reasons set forth herein, and in accordance with the Explanation and Election of Rights forms which are attached hereto and made a part hereof by reference. EXECUTED on this 26 dayof Oct . , 2001, Charlie Crist, as Commissioner of Education, State of Florida NO.34@ «~DGGET 86/84/2882 17:84 ABE — MEYER AND BROOKS, P.A. ATTORNEYS AT LAW - 2544 BLAIRSTONE PINES DRIVE . TALLAHASSEE, FLORIDA 32301 eet 850/878-5212 RONALD G. MEYER ra wine RES; THomasS W. BROOKS C2 JUL oe hee £8 1547 ANTHONY D. DEMMA els SEE, FLORIDA 32302 MARY F. ASPROS ul 7856x6750 pros®ireyerandbroaks.com JANESSA L, GURR ; ; LEGAL ASSISTANT. June 4, 2002 = “ae” VIA FACSIMILE: 850-487-6591 ne Ms. Temi H. Crews = ~~ Office of Professional Practices Services Florida Education Center, Room 224-E =: 325 West Gaines Street on Tallahassee, Florida 32399-0400 . ll a Re: Ms. Kristin Ezquerra Dear Teri: Please be advised that this firm represents Ms. Kristin Ezquerra in all matters concerning the complaint investigated by the Department of Education. I request that you direct all inquiries and correspondence to this office. I also request that you provide us a complete copy of the investigative file in this matter. If you have any questions, please feel free to contact me at any time. Thank you for your assistance in this matter. Sincerely, Mary F. Aspr cc: Ms. Kristin Ezquerra Mr. Ron Stowers — mos, Page 1 of I Richards, Kathleen : From: — Satterwhite, Carolyn _ : - - i it Sent: Wednesday, July 03, 2002 4:12 PM yee To: Richards, Kathleen; Leffler, Mary; Thomas, David; McKoy, vee Hh 22 PH \2: 20 Ce: Odom, Tamara = Subject: 3 cases to DOAH Please send the following cases to DOAH: 001-0291-R Bryan Chadwick 001-1485-C Kristen Ezquerra 012-0782-C Refair Freeman Attorney Ron Weaver will be representing the Department for these cases. Carolyn Satterwhite 487-8718 1232 TUR Office of the General Counsel 7/3/02

Docket for Case No: 02-002914PL