Os: DL4>PC Fits 2» STATE OF FLORIDA bs EDUCATION PRACTICES COMMISSION 2088 sy 4 Ath 39 . 4 ARTI fie JEANINE BLOMBERG, as ADMINIS 5 Dass Commissioner of Education, HEAR ine VE Petitioner, vs. CASE NO. 056-3649-B FRANCES SEPULVEDA, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Jeanine Blomberg, as Commissioner of Education, files this Administrative Complaint agains! FRANCES SEPULVEDA. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to Sections [012.795 and 1012.796, Florida Statutes, and pursuant to Rule 6B-1.006, Florida Administrative Code, Principles of Professional Conduct for the Education Protession in Florida, said sanctions specifically set forth in Sections 1012.795(1)} and 1012.796(7), Florida Statutes. The Petitioner alleges: JURISDICTION I. The Respondent holds Florida Educator’s Certificate 823792, covering the area of Foreign Language-Spanish, which is valid through June 30, 2009. 2. Atall times pertinent hereto, the Respondent was employed as a Spanish Teacher at Coleman Middle School in the Llillsborough County Schoo] District. MATERIAL ALLEGATION 3. During the 2005-2006 school year the Respondent engaged in sexual intercourse with a fellow teacher in her classroom on onc or more occasions during the school day. Several students witnessed the Respondent engaging in sexual intercourse on one occasion. FRANCES SEPULVEDA Administrative Complaint Page 2 of 2 The Petitioner charges: 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 VIOLATION 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 (he student’s mental health and/or physical health and/or safety. 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 Practiccs Commission impose an appropriate sanclion 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 writlen 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 lime up to 10 years or permanently. EXECUTED on this > _ day of ageless, 2007. JEANINE BLOMBERG, as Commissioner of Education State of Florida

Docket for Case No: 08-002643PL