STATE OF FLORIDA 03 FE» EDUCATION PRACTICES COMMISSION 18 py 2: CHARLIE CRIST, as ABT Ge Commissioner of Education, ME ARIAe VE Petitioner, vs. CASE NO. 001-0304-V 2. HSS ALLAM I. YAZBEK, 6% OSS BoPL Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against Allam I. Yazbek. 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(7) and 231.2615(1), Florida Statutes. : The Petitioner alleges: JURISDIC LIGN 1. The Respondent holds Florida Educator’s Certificate 781552, covering the areas of Biology and Health, which was valid through June 30, 2002. 2. At all times pertinent hereto, the Respondent was employed as a Substitute Teacher in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3. On or about May 18, 2000, Respondent harassed and followed a female student all over the campus at Miami Beach Adult Education Center. When Respondent was confronted about the harassment, he lied claiming he was a long-time friend of the student’s father. On or about June 5, 2000, Respondent was notified by the Miami-Dade County School District that he was precluded from employment during the summer of 2000 pending an investigation. On or about August 16, 2000, Respondent received directives from the Miami-Dade County School District during a conference-for-the-record. Respondent was also advised that he would not be considered for future employment with the District for at least one year. ALLAM I. YAZBEK Administrative Complaint Page 2 of 3 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)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession in Florida prescribed by the State Board of Education. RULE VIOLATIONS COUNT 3: | The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(a), 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 safety. COUNT 4: _ The allegations of misconduct set forth herein are in violation of Rule 6B- 1,006(3)(e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary embarrassment or disparagement. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(d), Florida Administrative Code, in that Respondent engaged in harassment or discriminatory conduct which unreasonably interfered with an individual’s performance of professional or work responsibilities or with the orderly processes of education or which created a hostile, intimidating, abusive, offensive, or oppressive environment. ALLAM I. YAZBEK 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(7) 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 _ 17 day of Decem ber, 2002. Gd. Charlie Crist, as Commissioner of Education, State of Florida

Docket for Case No: 03-000553PL