STATE OF FLORIDA EDUCATION PRACTICES COMMISSION JOHN L. WINN, as O Commissioner of Education, Petitioner, ¥8. CASE NO, 034-2811-M LAINIE KIM WOLFE, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L, Winn, as Commissioner of Education, files this Administrative Complaint against LATNIE KIM WOLFE. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s cducator’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 sct forth in Sections 1012.795(1) and 1012.796(7), Florida Statutes. The Petitioncr alleges: {, The Respondent holds Florida Educator's Certificate 690933, covering the area of Guidance and Counseling, which is valid through June 30, 2007. 2, Atall times pertinent hereto, the Respondent was employed as a Guidance Counselor at Lollywood Park Elementary School in the Broward County School District. MATERIAL ALLEGATIONS 3 During the 2003-2004 school year thc Respondent engaged in inappropriate and unprofessional conduct in that she: (a) made false and malicious charges against her Principal in 2 sworn "petition lor injunction for protection against repeat violence” which she filed against her principal; (b) failed to follow school board policies in regard to her receipt of a suicide note LAINIE KIM WOLFE Administrative Complaint Page 2 of 4 written by a student at her school; (c) removed FCAT testing materials without authorization from school grounds; and (d) forged the signature of a parent on a student consent form. STATUTE VIOLATION COUNT1: — The Respondentis in violation of Section 1008.24(1), Florida Statutes, in that Respondent knowingly and willfully violated test security rules adopted by the State Board of Education for mandatory tests administered by or through the State Board of Education or the Commissioner of Education to students, educators, or applicants for certification or administered by school districts pursuant to s. 1008.22. COUNT2: _ The Respondent is in violation of Section 1008.24(1)(b), Florida Statutes, in that Respondent knowingly copied, reproduced, or used in any manner inconsistent with Lest security rules all or any portion of any secure test booklet. COUNT3: The Respondent is in violation of Section 1008.24(1)(e), Florida Statutes, in that Respondent failed to follow security rules for distribution and return of secure test as directed, or {uiled to account for all secure test materials before, during, and after testing. COUNT 4: — 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 5: The Respondent is in violation of Section 1012.795(1)(f), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces her effectiveness as an employee of the school board. COUNT 6: ~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 ?: — The Respondent is in violation of Section 1012.795(1)(), 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 8: The allegations of misconduct set forth herein are in viotation of Rule 6A- £0.042(1), Florida Administrative Code, in that Respondent failed to maintain or administer a test in a secure manner such that integrity if the test was preserved. LAINIE KIM WOLFE Administrative Complaint Page 3 of 4 COUNT 9: — The allegations of misconduct sct [orth herein are in violation of Rule 6A- 10,042(2), Florida Administrative Code, in that Respondent faited to keep testing materials, booktcts, answers keys, or student responses secure and precisely accounted for. COUNT 10; The allegations of misconduct set forth hercin 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 health and/or safety. COUNT 11: 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 educational matter in direct or indirect public expression. COUNT 12: 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 al] professional dealings. COUNT 13: The allegations of misconduct sct forth herein are in violation of Rule 6B- 1,006(3\(c), Florida Administrative Code, in that Respondent has made malicious or intentionally false statements about a colleague. COUNT 14: The Respondent js in violation of Rule 6B.1006(5)(h), Florida Administrative Code, in that Respondent has submitted (raudulent information on a document in connection with professional activities (SIGNATURE ON FOLLOWING PAGE) LAINIE KIM WOLFE Administrative Complaint Page 4 of 4 WHEREFORE, based on the reasons set forth hercin 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 practicc; 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 cxcecd live 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. d - EXECUTED on this 37% — day of Uh arub._, 2006. pte L. WINN, as Commissioner of Education State of Florida

Docket for Case No: 07-005670PL