STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 112-2422 NELLY RAMOS-SALGUEIRO, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against NELLY RAMOS-SALGUEIRO. 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 6A4-10.081, 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 L The Respondent holds Florida Educator’s Certificate 819559, covering the areas of Elementary Education and English for Speakers of Other Languages (ESOL), which is valid through June 30, 2016. 2, At all times pertinent hereto, the Respondent was employed as a First Grade Teacher at West Homestead Elementary School in the Miami-Dade County School District. MATERIAL ALLEGATIONS 3, On multiple occasions during the 2011-2012 school year, Respondent inappropriately disciplined her first grade students by pinching the students on the back or arm when they misbehaved. 4, On multiple occasions during the 2011-2012 school year, Respondent directed inappropriate language at her first grade students, including statements with the words “fuck” and “bitch.” NELLY RAMOS-SALGUEIRO Administrative Complaint Page 2 of 3 5. Asa result of the conduct alleged herein, on or about December 14, 2011, Respondent was issued several directives by the Miami-Dade County School District including: a. Cease and desist from using inappropriate means in order to discipline students; and b. Cease and. desist from using inappropriate language to include the use of profanity. 6. Asa result of the conduct alleged herein, on or about February 16, 2012, Respondent was suspended from her duties without pay for seven days by the Miami-Dade County School Board. The Petitioner charges: STATUTE VIOLATIONS COUNT i: 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)