STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JIM HORNE, as Commissioner of Education, Petitioner, D>: 2D St PL vs. CASE NO. 001-2106-M THOMAS D. LINDEMANN, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Jim Hore, as Commissioner of Education, files this Administrative Complaint against THOMAS D. LINDEMANN. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections 1012.795 and 1012.796, 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 1012.795(1) and 1012.796(7), Florida Statutes. The Petitioner alleges: JURISDICTION 1. The Respondent holds Florida Educator’s Certificate 672854, covering the areas of Mathernatics and Physical Education, which is valid through June 30, 2006. 2. Atall times pertinent hereto, the Respondent was employed as a Mathematics Teacher at Crystal Lake Middle School, in the Polk County School District. MATERIAL ALLEGATIONS 4 3. On or about April 19, 1999, the Respondent received a letter of reprimand from his principal for inappropriate remarks made to a student. 4. On or about September 24, 1999, the Respondent received a letter of reprimand from his principal for inappropriate remarks made to a student. THOMAS D. LINDEMANN Administrative Complaint 2 of 3 5. On or about November 17, 1999, the Respondent received a letter of reprimand from his principal for inappropriate remarks to, and behavior with, students. 6. On or about March 10, 2000, the Respondent received a letter of reprimand from his principal for using inappropriate, degrading language to his students. 7. On or about August 23, 2000, the Respondent received a letter ofreprimand from his principal for offensive comments made to a parent and a colleague. 8. On or about September 28, 2000, the Respondent was suspended for four days without pay by his Superintendent of Schools for inappropriate and derogatory remarks made to a student. 9. Following his reinstatement in the 2000-2001 school year, the Respondent continued to make inappropriate comments to his students which were embarrassing, disparaging, demeaning, and derogatory. As a result the Respondent was terminated from his position of employment effective August 1, 2001. STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(c), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude. COUNT 2: The Respondent is in violation of Section 1012.795(1)(i), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. 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 leaming and/or to the student’s mental health and/or physical health and/or 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. THOMAS D. LINDEMANN Administrative Complaint 3 of 3 WHEREFORE, the Petitioner recommends that the Education Practices Commission impose an appropriate penalty pursuant to the authority provided in Sections 1012.795(1) and 1012.796(7), 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_cfO" day of Feblich 2003. State of Florida

Docket for Case No: 03-002556PL