YY lor” oft, December 18, 2003 es ey MEMORANDUM omar TO: MEMBERS OF THE SCHOOL BOARD FROM: RONALD BLOCKER [lire Superintendent SUBJECT: Josephine Peterson, Registered Nurse Termination/Suspension Attached is a complaint regarding Josephine Peterson, who | am charging with conduct unbecoming a public employee and misconduct in office. Ms. Peterson has been negligent in administering medication to students and communicated a threat to her Principal. | have relieved Josephine Peterson from duty with pay pending presentation to you of formal administrative charges. Attached you will find a copy of those charges. | am now recommending that you act to suspend her without pay in accordance with the negotiated agreement with the Classroom Teacher's Association and Florida law, and terminate her unless a hearing is requested. | am also recommending that you approve Frank C. Kruppenbacher to act as my representative in this matter. RECOMMENDED RESOLUTION: oe eee | move that Josephine Peterson be suspended without pay and be terminated 15 days from receipt of the attached charges. ! further move that Frank C. Kruppenbacher, Esq. be appointed to represent the superintendent in this matter. Attachment SCHOOL BOARD OF ORANGE COUNTY, A FLORIDA, BY AND THROUGH ITS SUPERINTENDENT, RONALD BLOCKER, Petitioner Vs. Josephine Peterson Respondent ADMINISTRATIVE COMPLAINT RONALD BLOCKER, as Superintendent of Schools, for and on behalf of the School Board of Orange County, Florida, (hereinafter referred to as “Petitioner’), files this Administrative Complaint against Josephine Peterson (hereinafter referred to as “Respondent’). Petitioner seeks the severance of Respondent's Registered Nurse services with Petitioner pursuant to management right. The Petitioner alleges: 1, The Respondent, at all times material to this Complaint, was employed as a Registered Nurse by the Petitioner. The Respondent holds a Florida Registered Nurse license and is employed by the School Board of Orange County, Florida. That on or about February 26, 2003, the Respondent was issued directives for leaving work early and without authorization. Attached hereto and ‘incorporated herein by reference as Exhibit “A” ic the dirantive issued to the Respondent. That on or about August 12, 2003, a parent reported a concern over the Respondent's attempt to shorten a feeding tube of a student receiving services. That on or about September 15, 2003, the Respondent was placed on a performance improvement plan due to a continuous decline in problem solving and communication. Attached hereto and incorporated herein by EXHIBIT "A" reference as Exhibit “B” is a copy of the performance improvement plan and summaries issued to the Respondent. 6. That on or about September 26, 2003, the Respondent was issued a written directive for assigning an untrained staff member to administer medication that had been pre-poured for an extended period of time. Attached hereto and incorporated herein by reference as Exhibit “C” is the directive issued to the Respondent. 7. That on or about November 6, 2003, a Registered Nurse filling in for the Respondent notified the principal there was no authorization form for administering Phenobarbital, a licensed narcotic, to a student. 8. That on or about November 7, 2003, the Respondent was asked by the principal about the authorization form. The Respondent stated the parent had never returned the authorization form. 9. That on or about November 13, 2003, when served with a written notice to appear at the district office, the Respondent did threaten her principal by saying, “you will pay for this”. 10. That on or about November 14, 2003, the Respondent was placed on relief of duty status with pay and served a trespass citation by law enforcement for a reported assault on a school employee. 11. Such actions by the Respondent are in violation of School Board Policies and constitutes misconduct in office, willful neglect of duty, gross insubordination, conduct unbecoming a public employee, and breach of Respondent's employment agreement with the School Board. 12. Said violations are sufficient grounds to sever the employment status of Respondent, Josephine Peterson, with the School Board of Orange County, Florida. THEREFORE, the Superintendent of Schools for the School Board of Orange County, Florida, recommends that the Board sever its Registered Nurse services with the Respondent and terminate immediately the employment of Respondent, Josephine Peterson. Dated this | 7%, of December, 2003. Attorney for Ronald Blocker, Superintendent, The School Board of Orange County, Florida 445 W. Amelia Street Orlando, Florida 32801 (407)317-3411

Docket for Case No: 04-001085