STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JOHN L. WINN, as Commissioner of Education, Petitioner, vs. CASE NO. 056-0553-Q [) b- DTABPE ALAN EDWARD GYOREFFY, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against ALAN EDWARD GYORFFY. 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 929342, covering the area of Biology, which is valid through June 30, 2006. 2. At all times pertinent hereto, the Respondent was employed as a Science Teacher in the Duval and Clay County School Districts. MATERIAL ALLEGATIONS 3. On his application for a Florida Educator’s Certificate dated October 7, 2003, and on prior and subsequent school district employment applications, Respondent knowingly provided false information that he had obtained a bachelor’s degree, when in fact he had not. Respondent further provided to state and district personnel, on several occasions, forged transcripts in furtherance of his efforts to obtain a teaching certificate and employment. ALAN EDWARD GYORFFY Administrative Complaint Page 2 of 3 STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1)(a), Florida Statutes, in that Respondent obtained the teaching certificate by fraudulent means. COUNT 2: 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 3: 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. COUNT 4: The Respondent isin violation of Section 1012.795(1)(j), Florida Statutes, in that Respondent has otherwise violated the provisions of law, the penalty for which is the revocation of the teaching certificate. RULE VIOLATIONS COUNT 5: 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. COUNT6: TheRespondentis in violation of Rule 6B.1006(5)(g), Florida Administrative Code, in that Respondent has misrepresented one's own professional qualifications. COUNT7: | The Respondentis in violation of Rule 6B.1006(5)(h), Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. COUNTS8: The Respondentis in violation of Rule 6B.1006(5)(i), Florida Administrative Code, in that Respondent made a fraudulent statement or failed to disclose a material fact in one's own or another’s application for a professional position. ad (SIGNATURE ON FOLLOWING PAGE) ALAN EDWARD GYORFFY Administrative Complaint Page 3 of 3 WHEREFORE, based on the reasons set forth herein and in accordance with the Explanation of Rights and Election of Rights forms attached to and made a part of this © Administrative Complaint, Petitioner respectfully recommends that the Education Practices Commission impose an appropriate sanction against the Respondent’s educator’s certificate pursuant to the authority provided in Sections 1012.795(1) and 1012.796(7), Florida Statutes, The sanctions imposed by the Education Practices Commission may include, but are not limited to, any one or a combination of the following: issuing the Respondent a written reprimand; placing the Respondent on probation for any period of time; restricting the Respondent’s authorized scope of practice; assessing the Respondent an administrative fine; directing the Respondent to enroll in the Recovery Network Program; suspending the Respondent’s educator’s certificate for a period of time not to exceed five years; revoking the Respondent’s educator’s certificate for a period of time up to 10 years or permanently; or barring the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently. EXECUTED on this (G4 dayot oven __, 2006. J L. WINN, as Comnunissioner of Education State of Florida

Docket for Case No: 06-003723PL