, STATE OF FLORIDA I Mg y nd EDUCATION PRACTICES COMMISSION. 2h Py bs - Aged 'S10H Gr He STR Dative 4 Puy £ CHARLIE CRIST,as Case No. 001-0828. Vv. Commissioner of Education, . ‘Petitioner, - 7 “OSB TYPL VS. _ CLINTONB. NEILLY, I, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, CHARLIE CRIST, as Commissioner of Education, files this ; Adninietv Complaint against CLINT! ON B. NEILLY, Il. The Petitioner secks ‘the . - appropriate disciplinary sanctions 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, ' sald ¢ Sanctions specifically set forth i in sections 231.262(6) and 231, 2615(1), Florida Statutes. The Petitioner alleges: 1. The Respondent holds Florida Educator’s Certification no. 719222, covering the areas of Educational Leadership, English to Speakers of Other Languages, and Political Science, which are valid through June 30, 2005, 2. At all times pertinent hereto, the Respondent was employed as an Assistant Principal at Miami Central Senior High School, in the Miami-Dade County School District. Clinton B. Neilly, II Administrative Complaint Case No. 001-0828.V *: _ MATERIAL LAL LEGATIONS 3. Onor about January 14, 2000, the Respondent brough a hand gun to bed and gestured i ina threatening manner towards hs s wife. The Respondent’ 's wife fled the residence and contacted police. “The Respondent w was as charged and arrested for aggravated assault (domestic violen ‘The Respondent’ s conduct was | reported to the Bureau of Educators “asernes eae, Standards, The Respondent continues to > be employed by the Miami-Dade County Public School District. STATUTORY VIOLATIONS COUNT I: The Respondent is in violation of Section 231.2615(1)(c), Florida Statutes, in that at Respondent has been guilty of gross immorality oran act involving moral turpitude, . WHEREFORE, the Petitioner recommends that the “Education Practices Commission i impose an appropriate penalty pursuant to the authority provided i in Sections 234. 262(6) and 231, 1.26150), Florida Statutes, which penalty may include a reprimand, | | probation, restriction of the authorized scope of practice, administrative fine, suspension of the teaching écttificate not to exceed three (3) 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. Clinton B. Neilly, II inistrative Com; plaint Case No. coo -V PECUTED oni ZI Pdayof Maced CRIST, as Commissioner of Education, State of Florida FADATA\DOE\NEILLY\PLDGS\COMPLAINDOC ng

Docket for Case No: 03-000374PL