THE SCHOOL BOARD OF BROWARD COUNTY FLORIDA ROBERT W. RUNCIE, Superintendent of Schools, CASE NO.: Petitioner, vs. SERENA JONES, Respondent. ADMINISTRATIVE COMPLAINT. Petitioner, ROBERT W. RUNCIE, Superintendent of Schools of Broward County, Florida, by and through his undersigned counsel, files this Administrative Complaint, pursuant to Chapters 120, 1001, and 1012 of the Florida Statutes, as well as Chapter 6B-1 and Chapter 6B-4 of the Administrative Code, and states the following: L JURISDICTIONAL BASIS 1. The agency is the School Board of Broward County, Florida, located at 600 Southeast Third Avenue, Fort Lauderdale, Broward County, Florida 33301. 2. The Petitioner is Robert W. Runcie, who is the Superintendent of Schools of Broward County, Florida. 3. The Petitioner is statutorily obligated to recommend the placement of school personnel and to require compliance and observance with all laws, rules and regulations. Any violation thereof shail be reported with the appropriate disciplinary action against any School Board personnel! failing to comply therewith, inclusive of the Respondent, Serena Jones (hereinafter “Jones”. 4. The Respondent, Jones, is an employee of the Broward County School Board and is currently employed as a teacher at Driftwood Middle School. 5. The fast known address of the Respondent, Jones, is 10293 Southwest 55" Lane, Cooper City, Florida 33328. Il. SPECIFIC CHARGES 6. The Respondent, Jones, a middle school teacher, engaged in inappropriate conduct by engaging in neglect of a child as it relates to her 16 year old daughter as well as her 11 year old daughter and 6 year old son, which was inappropriate and contrary to the provisions of Florida law cited herein. On or about January 2011, Jones was arrested on charges of neglect of a child, a second degree felony, against her two daughters and minor son. See, Fla. Stat. §827.03(3)(C). Specifically, Jones stood by and failed to take reasonable action to protect the victim of child abuse, and her daughters and son, from physical abuse at the hands of Darren Jones. Respondent failed to intercede, failed to contact appropriate state or local regulatory agencies for assistance and stood by while Darren Jones inflicted physical abuse on her 16 year old minor daughter, which included his physically striking her numerous times with an extension cord and causing bruising/scarring to the minor daughter’s arms, legs and back. Additionally, Respondent, Jones, stood by while Darren Jones uses a belt or a brush to strike her two other minor children as a form of punishment. Child Protective Services (“CPIS”) determined that the husband’s actions constituted “extreme child abuse” and the husband was arrested on charges of aggravated child abuse, a first degree felony, against his 16 year old minor daughter. 7. Darren Jones engaged in intentional infliction of physical injury upon his children by willfully striking, torturing and/or maliciously punishing the children. Upon information and belief, this abuse was premeditated and a pattern within the household. Respondent, Jones, stood by and failed to take reasonable action or effort to protect her other daughter (11 years old) and her son (6 years old) from physical abuse inflicted by Darren Jones upon the children as a form of alleged discipline using a belt or brush. Respondent, Jones, was aware of the physical discipline inflicted by the husband, was present when the discipline took place, and failed to make a reasonable effort to protect all three of the children from physical abuse by the father. Wl. JUST CAUSE 8. Just cause exists for the requested relief pursuant to §1012.33 Fla. Stat., the Respondent’s employment contract, School Board rules and regulations, the Code of Ethics of the Education Profession, and the Employee Disciplinary Guidelines promulgated by the School Board, including but not limited to the following: (A) Moral turpitude: The Respondent, through her above-described conduct, has violated §1012.33 Fla. Stat., and Rule 6B-4.009(6) of the Administrative Code, and the baseness, vileness, and depravity of her actions constitute moral turpitude in violation of the social and private duties to which she owed her fellow man and society, both in general and as an educator. Additionally, the Respondent’s above-described conduct further violates the Code of Ethics of the Education Profession, Rule 6B-1.001, 6B-1.006, Florida Administrative Code. The Respondent’s conduct as factually set forth herein is sufficiently notorious to bring the Respondent and/or the education profession into public disgrace or disrespect and impair the Respondent’s service in the community. (B) Immorality: The Respondent, through her above-described conduct, violated §1012.33 Fla. Stat., and Rule 6B-4009(2) of the Florida Administrative Code, and her actions constitute immorality, which is conduct inconsistent with the standards of public conscience and good morals. Additionally, the Respondent’s above-described conduct further violates the Code of Ethics of the Educational Profession, Rule 6B-1.001, 6B-1.006, Florida Administrative Code. The Respondent’s conduct, as factually set forth herein, is sufficiently notorious to bring the Respondent and/or the education profession into public disgrace or disrespect and impair the Respondent’s service in the community. WHEREFORE, based upon the foregoing, the Petitioner, Robert W. Runcie, Superintendent of Schools, recommends that the School Board, subsequent to providing the requisite notice, dismiss the Respondent, Serena Jones, from her employment as a middle school teacher, based upon the foregoing facts and legal authority. DATED this of [bay of Decomber- 2011, OBERT W. RUNCIE, Superintendent Superintendent of Schools Respectfully submitted, PANZA, MAURER & MAYNARD, P.A. Attorneys for Petitioner BROWARD COUNTY SCHOOL BOARD Bank of America Building — Third Floor 3600 North Federal Highway Fort Lauderdale, Florida 33308 Telephone: (954) 390-0100 Facsimile: (954) 390-7991 Prepared By: MARK A. EMANUELE, ESQUIRE FLORIDA BAR NO.: 541834 FACLIENT\ 190\1 1-19294 (Jones \PLEADINGS\Adminstrative Complaint.Doc ae

Docket for Case No: 12-000778TTS