STATE OF FLORIDA EDUCATION PRACTICES COMMISSION Sl oK PL JOHN L. WINN, as 0 3 is Commissioner of Education, Petitioner, vs. CASE NO. 023-1718-V STEVEN KOUFOGAZOS, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, John L. Winn, as Commissioner of Education, files this Administrative Complaint against STEVEN KOUFOGAZOS. 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 881280, covering the,area(s) of Educational Leadership and Social Science, which is valid through June 30, 2007. 2. Atall times pertinent hereto, the Respondent was employed as an Assistant Princip al at Madeira Beach Middle School in the Pinellas County School District. MATERIAL ALLEGATIONS 3. On or about June 10, 2002, Respondent falsified his employment application with the Pinellas County School Board. Contrary to his declaration on the employment application, Respondent willfully and knowingly omitted pertinent material and information by failing to disclose his reasons for leaving his position in Massachusetts after the 2001-2002 school year. Effective February 18, 2003, Respondent resigned his position with the school board. 4. On or about August 13, 2004, a jury found and the court adjudicated Respondent STEVEN KOUFOGAZOS Administrative Complaint Page 2 of 4 guilty of Assault to Rape a Child (Under 16). Among other sanctions, the court sentenced Respondent to 2 to 4 years in prison. 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)(e), Florida Statutes, in that Respondent has been convicted of 2 misdemeanor, felony, or other criminal charge, other than a minor traffic violation. COUNT 3: The Respondent is in violation of Section 1012.795(1)(0), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces his effectiveness as an employee of the school board. COUNT 4: 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. COUNTS: 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. COUNT6: TheRespondentis in violation of Section 1012.7 95(2), Florida Statutes, which provides that the plea of guilty in any court or the decision of guilty by any court is prima facie proof of grounds for the revocation of the certificate. RULE VIOLATIONS COUNT 7: _ 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 health and/or safety. COUNT 8: 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 S$: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(g), Florida Administrative Code, in that Respondent has harassed or discriminated against STEVEN KOUFOGAZOS Administrative Complaint Page 3 of 4 a student on the basis of race, color, religion, sex, age, national or ethnic origin, political beliefs, marital status, handicapping condition, sexual orientation, or social and family background and shall make reasonable effort to assure that each student is protected from harassment or discrimination. COUNT 10: The allegations of misconduct set forth herein are in violation of Rule 6B- 1.006(3)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. COUNT 11: 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 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 all professional dealings. COUNT 13: TheRespondent isin violation of Rule 6B.1006(5)(g), Florida Administrative Code, in that Respondent has misrepresented one's own professional qualifications. COUNT 14: TheRespondentis in violation of Rule 6B.1006(5)(b), Florida Administrative Code, in that Respondent has submitted fraudulent information on a document in connection with professional activities. COUNT 15: The Respondentis in violation of Rule 6B.1006(5)@), F lorida 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. STEVEN KOUFOGAZOS Administrative Complaint Page 4 of 4 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 m 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_Q-} day of eh , 2006. JOHN L. WINN, as Commissioner of Education State of Florida

Docket for Case No: 08-004128PL