THE STATE OF FLORIDA BEFORE THE SCHOOL BOARD OF MONROE COUNTY, FLORIDA MARK T. PORTER, ) Superintendent of Schools, ) Petitioner } v. ‘ Case No. KATHY PRICE, } Respondent. ‘ ee ADMINISTRATIVE COMPLAINT Petitioner, MARK T. PORTER, Superintendent of Schools of Monroe County, Florida, files this Administrative Complaint, pursuant to Sections 435.01 and 435.05, Florida Statutes School Board of Monroe County Administrative Procedure 8600B, and the School Board Policies for the School District of Monroe County, Florida, and states as follows: JURISDICTIONAL BASIS 1. The agency is THE SCHOOL BOARD OF MONROE COUNTY, FLORIDA, located at 241 Trumbo Road, Key West, Florida 33041. 2. The Petitioner, MARK T. PORTER, is the Superintendent of Schools of Monroe County, Florida. His address is 241 Trumbo Road, Key West, Florida 33041. 3. The Petitioner is statutorily obligated to recommend the placement of all school personnel and to require all employees to observe and comply with all laws, rules and regulations. Petitioner is required by law to report and recommend appropriate disciplinary action against any school employee who fails to comply therewith, inclusive of the Respondent, KATHY PRICE, to the School Board of Monroe County, Florida. 4. The Respondent, KATHY PRICE, is an employee of the School Board of Monroe County, Florida, and is currently employed as a Bus Driver, within the Monroe County School District. Pursuant to School Board Administrative Procedure 8600B [Safe Driver Plan] and Sections 435.01 and 435.05, Florida Statutes and in accordance with the collective bargaining agreement, Petitioner suspended Respondent, KATHY PRICE on February 17, 2014. 5. The last known address of the Respondent, KATHY PRICE, is 10100 Overseas Highway, Key Largo, FL 33037. The Respondent can be served personally at this address. ADMINISTRATIVE CHARGES Petitioner, MARK T, PORTER, states as follows: 6. At all times pertinent hereto, the Respondent, KATHY PRICE, was employed as a Bus Driver for the School District of Monroe County, Florida, 241 Trumbo Road, Key West, Florida 33041. 7. On February 16", 2014 Respondent was arrested by the Monroe County Sheriffs Department and charged with: a. Violation F.S. 316.1995 — Drive on sidewalk/Bike Path b. Violation F.S. 322.15 - Driver’s License Not Carried c. Violation F.S. 316.193 - Driving Under the Influence 8. The Florida Department of Education School Bus Driver Records System indicates that the Respondent’s class B Driver’s License has been suspended 18 months for refusal to submit to breath/urine/blood test. 9. A Class B Driver’s License is an essential requirement of a School Bus Driver. 10. Petitioner seeks the suspension of Respondent, KATHY PRICE, on one or more of the following grounds: A. Driving while intoxicated or unlawful blood alcohol content, a 10-point violation under School Board Administrative Procedure 8600B — Safe Driver Plan. Such a violation warrants termination of employment under the same, though Petitioner seeks suspension of Respondent without pay pending the conclusion of these proceedings. B. Violation of an excluding offense under Sections 435.01 and 435.05, Florida Statutes. 11. The above-referenced authority correlates to, and provides authority for, disciplinary action for Respondent, KATHY PRICES’s DUI arrest. 12. Due to the seriousness of the charges involved, Petitioner requests that Respondent, KATHY PRICE, be suspended without pay from her employment as a Bus Driver with the School District of Monroe County without pay until the conclusion of criminal proceedings in this matter. DEMAND FOR RELIEF 13. Petitioner, MARK T. PORTER, Superintendent of Schools of Monroe County, Florida, recommends and requests that the School Board of Monroe County, Florida, after providing the requisite notice, suspend Respondent, KATHY PRICE, without pay, from her employment as a Bus Driver with the Monroe County School District pending the conclusion of the criminal proceedings, predicated upon the foregoing facts and legal authority. EXECUTED this 71 dayor_/ Arch 2014. . PORTER Superintendent of Schools STATE OF FLORIDA ) )SS: COUNTY OF MONROE ) BEFORE ME, the undersigned authority, personally appeared, MARK T. PORTER, to be known to be the person described in the foregoing instrument; and he acknowledged that he executed the foregoing instrument for the purpose therein contained. WITNESS my hand and seal this al day of Ml Ute a 2014. Sil th Ae NOTARY LIC, oma dk SSS RGR OF FLORIDA My Commission Expires: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this document has been furnished via U.S. Mail to: Kathy Price at the following addresses: (i) 10100 Overseas Highway, Key Largo, FL 33037 and (ii) P.O. Box 1926, Key Largo, FL 33037; and via email to: Dr. Ramon Dawkins, Director of Human Resources, Monroe County Schools, 241 Trumbo Road, Key West, Florida 33040 and Mark Herdman, Esquire, 29605 US Highway 19 North, Suite 110, Clearwater, Florida 33761, this 24th day of March, 2014. VERNIS & BOWLING OF THE FLORIDA KEYS, P.A. Attorney for Petitioner Islamorada Professional Center 81990 Overseas Highway, 3“! Floor Islamorada, Florida 33036 Telephone (305) 664-4675 Telecopier (305) 664-5414 _/s/ Theron C. Simmons Theron C. Simmons Florida Bar No.: 623385 Benjamin L. Zeskind Florida Bar No.: 102908

Docket for Case No: 14-001370