STATE OF FLORIDA ele py EDUCATION PRACTICES COMMISSION 03 Te Bad FEB 27 PM Io: 24, CHARLIE CRIST, as A Diy ih eet Commissioner of Education, nena i Petitioner, vs. CASE NO. 001-2090-M CATHERINE A. LICHTMAN, Oy 0706 PL Respondent. / ADMINISTRATIVE COMPLAINT . Petitioner, Charlie Crist, as Commissioner of Education, files this Administrative Complaint against CATHERINE A. LICHTMAN. 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: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 779434, covering the area of Elementary Education, which is valid through June 30, 2006. 2. At all times pertinent hereto, the Respondent was employed as a ist Grade Teacher at Royal Palm Elementary School in the Broward County School District. CATHERINE A. LICHTMAN Administrative Complaint Page 2 of 3 MATERIAL ALLEGATIONS 3. During the spring of 2001, Respondent on various dates became verbally abusive with the staff of the school board’s Benefits Department, the schoo! district’s health maintenance organization, and at least two doctors’ offices. In addition to being verbally abusive, Respondent threatened various individuals’ jobs and made violent threats against them. Specifically, on or about March 14, 2001, Respondent threatened the lives of two doctors and their employees, as well as the staff at the health maintenance organization. On or about June 13, 2001, the school district required Respondent to submit to a psychological examination. On or about February 19, 2002, the school district issued Respondent a letter of reprimand or this conduct. 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 State Board of Education. RULE VIOLATIONS COUNT 3: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(5)(d), Florida Administrative Code, in that Respondent has 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; and further, failed to make reasonable effort to assure that each individual was protected from such harassment or discrimination. CATHERINE A. LICHTMAN 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 @"_ dayof_MAY. 2002. fut: Cex Charlie Crist, as Commissioner of Education, State of Florida

Docket for Case No: 03-000706PL