STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 112-0973 MICHAEL.O. MOSAKU, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against MICHAEL O. MOSAKU. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant'to Sections 1012.315, 1012.795, and 1012.796, Florida Statutes, and pursuant to Rule 6A-10.081, 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 760019, covering the areas of Chemistry, Mathematics and Gifted, which is valid through June 30, 2014. 2. At all times pertinent. hereto, the Respondent was employed as a Chemistry Teacher at Miami Coral Park Senior High School in the Miami-Dade County School District, MATERIAL ALLEGATIONS 3. During the 2010-2011 school year, Respondent held private tutoring sessions before and after school where he rubbed up against and touched the breasts, thighs and buttocks of minor female students M.C., LW., S.Y., C.E., and HLZ. Respondent’s conduct caused the female students to feél-hurt and embarrassed. 4, Miami-Dade County Public Schools investigated Respondent based on. the conduct alleged herein and subsequently initiated dismissal proceedings. On-or about January 4, 2012, the School Board of Miami-Dade County accepted Respondent’s resignation. MICHAEL O, MOSAKU Administrative Complaint Page 2 of 3 The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of Section 1012.795(1 )(d), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude as defined by rule-of the State Board of Education. COUNT 2: The Respondent is in violation of Section 1012.795(1)(g), Florida Statutes, in that Respondent has been found guilty of personal conduct which seriously reduces effectiveness as an employee of the school board. COUNT 3: The Respondent is in violation of Section 1012.795(1)(j), Florida Statutes, in that Respondent has violated the Principles of Professional. Conduct for the Education Profession prescribed by State Board of Education rules. RULE VIOLATIONS COUNT 4: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081@)(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 5: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(3){e), Florida Administrative Code, in that Respondent has intentionally exposed a student to unnecessary ¢mbarrassment or disparagement. COUNT 6: The.allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(3)(g), Florida Administrative Code, in that Respondent has harassed or discriminated against 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 7: The allegations of misconduct set forth herein are in violation of Rule 6A+ 10,081(3)(h), Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. (SIGNATURE ON FOLLOWING PAGE) MICHAEL O. MOSAKU Administrative Complaint Page 3 of 3 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 in the Recovery Network Program; suspending the Responderit’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 tirne upto 10 years-or permanently; determining the Respondent to. be ineligible for certification; 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 218" day of Max 2014. PAM STEWART, as Commissioner of Education State of Florida

Docket for Case No: 15-000194PL