: ; PTCES STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JOHN L. WINN, as Commissioner of Education, Petitioner, vs. Case Number: 034-0092-V ROBERT EDWIN JONES, Respondent. O eC ° O 807 PL / ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against ROBERT EDWIN JONES. 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-1006, 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 242472, covering the areas of Mathematics, Gifted and Middle Grades which is valid through June 30, 2005. 2. At all times pertinent hereto, the Respondent was employed as a Mathematics Teacher at Greenwood Lakes Middle School in the Seminole County School District. MATERIAL ALLEGATIONS 3. During the 2001-2002 and 2002-2003 school years the Respondent engaged in unprofessional conduct in that he used ineligible students to compete in math competitions, falsified student information in order to enroll students in these competitions, violated competition rules, entered students of one grade level in competitions for a different grade level and entered students in competitions using false ROBERT EDWIN JONES Administrative Complaint Page 2 of 3 names. STATUTE VIOLATIONS COUNT 1. The allegations of misconduct set forth herein ate 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 allegations of misconduct set forth herein are in violation of Section 1012.795(1)(), 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(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)(d), Florida Administrative Code, in that Respondent has intentionally suppressed or distorted subject matter relevant to a student’s academic program. COUNT 5. 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 6. The allegations of misconduct set forth herein are in violation of Rule 6B-1.006(4)(b), Florida Administrative Code, in that Respondent has intentionally distorted or misrepresented facts concerning an education matter in direct or indirect public expression. COUNT 7. The allegations of misconduct set forth herein are in violation of Rule 6B-1.006(4)(c), Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. COUNT 8. The allegations of misconduct set forth herein are in violation of Rule 6B-1.006(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional! dealings. ROBERT EDWIN JONES 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 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 Bt sey of Octo bere 2005. il lle John L. Winn, as Commissioner of Education, State of Florida

Docket for Case No: 06-000807PL