BEFORE THE SCHOOL BOARD OF LEON COUNTY, FLORIDA JACKIE PONS, Superintendent, Petitioner VS. WOODY HILDEBRANDT, Employee, Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, JACKIE PONS, Superintendent of Leon County Schools, and files this Administrative Complaint and states the following: I. JURISDICTIONAL BASIS 1. The Agency is the School Board of Leon County, Florida, located at 2727 W. Pensacola St, Tallahassee, Florida 32304. 2 The Petitioner is Jackie Pons, the Superintendent of Schools of Leon County, Florida. His address is 2727 W. Pensacola St., Tallahassee, Florida 32304. 3. The Petitioner is statutorily obligated to recommend the placement of Schoo! 3oard personnel, and require compliance and observance by all personnel with all laws, rules and regulations. See §/0/2.27, Florida Statutes. 4. The employee against whom termination from employment is recommended, Respondent, Woody Hildebrandt, is employed by the School Board of Leon County, Florida, with his last known employment as the Principal at Lively Technical Center. 5. The legal basis for Mr. Hildebrandt’s termination is misconduct in office. See 1012.33, Fla. Stat.; Fla. Admin. Code. R. 6A-10.080, 6B-1.006, 6A-5.056. Il. ADMINISTRATIVE CHARGES The Petitioner, Jackie Pons, alleges as follows: 6. This recommendation for termination from employment is based on the Respondent, Woody Hildebrandt’s actions and conduct in his official capacity as an employee of Leon County Schools. 7. On or about June 24, 2014, Woody Hildebrandt requested a full internal audit of Lively Technical Center’s financial activity. 8. On or about October 23, 2014, Floyd “Mann” Roberts submitted written correspondence to Dr. Marvin Henderson alleging that Mr. Hildebrandt engaged in misconduct that was in violation of Florida law and/or Leon County School Board Policy. 9, On or about November 7, 2014, Keith Moore submitted written correspondence to Deputy Superintendent Marvin Henderson alleging that Mr. Hildebrandt engaged in misconduct that was in violation of Florida law and/or Leon County School Board Policy. 10, The Leon County School District, Department of Safety, Security and Professional Practices conducted an investigation into: (1) the allegations raised in the October 23, 2014 correspondence, (2) the allegations raised in the November 7, 2014 correspondence, and (3) irregularities discovered during the audit initiated at Mr. Hildebrandt’s June 24, 2014 request. Lk. During their administrative investigation, district investigators conducted interviews, reviewed documents and obtained photographs and videos that sustain findings that Mr, Hildebrandt: Ne a. Stole or caused to be stolen material that was later used on several projects at his private residence; b. Stole or caused to be stolen metal racks that were later used for his private business; c. Caused to be stolen several thousand dollars by ordering employees to pad their time in order to pay his son; d. Awarded several contracts for thousands of dollars thal was funneled directly 10 his sons through a company he initiated; Stole or caused to be stolen several pallets of sod, the property of Lively e. Technical Center; f Stole or caused to be stolen several rubber mats; g. Attenipted to influence a witness in a Leon County Schools Investigation; h. Caused to be stolen materials that were made into a window seat by ordering an employee to construct the seat using Lively material and during school time; i. Caused private work to be done on his personal vehicles and those of his children. Materials were never paid for in these cases; j. Caused to be stolen several hundred dollars of materials and employee time by ordering an employee to purchase and then paint his garage floor; k. Caused an employee to order Tervis Tumblers from his wife at a cost greater than that which could have been obtained from another company; 1 Caused the purchase of flags/tents from his sister-in-law; and m. Failed to report employee misconduct. 12, The conduct set forth in Paragraph 11 (a) through (m) constitutes violations of llorida law and/or Leon County School Board Policy. fhe Office of the State Attorney for the Second Judicial Circuit conducted a roe) ne criminal investigation into some of the allegations raised in the October 23, 2014 and November 7, 2014 letters. Upon the conclusion of the criminal investigation, Mr. Hildebrandt was arrested on four (4) counts of felony Grand Theft and one (1) count of misdemeanor Petit Theft. The disposition of the criminal charges is pending. Some, but not all of the sustained findings in Paragraph | i(a) through (m) served as a basis for the criminal charges. 14. Having reviewed the materials supporting the charges against Mr. Woody Hildebrandt, including the full investigative report and supporting exhibits, the Petitioner Superintendent hereby recommends that Mr. Hildebrandt be terminated from his employment. wo 5. ‘This recommendation is in accordance with the Florida Statutes, the Florida Administrative Code and the policies of the School Board of Leon County. 6. In accordance with Florida law, this recommendation for termination must be reviewed, and approved by the School Board. See $1012.33(6)(b), Fla. Stat. 7. If the Board’s decision is adverse to him, Mr. Hildebrandt may challenge the decision by seeking appellate review pursuant to Chapter 120 of the Florida Statutes. EXECUTED this day of February, 2015. CKAE PONS Superintendent

Docket for Case No: 15-001038