STATE OF FLORIDA EDUCATION PRACTICES COMMISSION PAM STEWART, as Commissioner of Education, Petitioner, vs. CASE NO. 090-2609 TIMOWTY JERMAINE WARD, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, Pam Stewart, as Commissioner of Education, files this Administrative Complaint against TIMOTHY JERMAINE WARD. 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 815474, covering the area of Social Science, which was valid through June 30, 2013. 2. At all times pertinent hereto, the Respondent was employed as an Adult Basic Education Teacher at Hallandale Adult Center in the Broward County 5chool District. MATERIAL ALLEGATIONS 3, During the period between August 1, 2008 and April 22, 2009, Respondent knowingly submitted fraudulent timesheets claiming hours on days he did not work resulting in an overpayment to Respondent in excess of four thousand dollars ($4,000) at the expense of the school district. 4, On or about January 16, 2010, Respondent was arrested and charged with sixteen (16) counts of Official Misconduct and one count of Grand Theft. TIMOTHY JERMAINE WARD Administrative Complaint Page 2 of 3 5. On or about Tune 15, 2010, Respondent's District initiated termination proceedings against him. On or about July 8, 2010, Respondent requested a hearing on the termination at the Division of Administrative Hearings (DOAH). On or about January 6, 2011, the DOAH judge issued a Recommended Order recommending Respondent’s termination. On or about August 20, 2011, Respondent’s district issued a Final Order adopting the recommendations of the Administrative Law Judge and terminating Respondent’s employment. 6. On or about March 14, 2014, Respondent’s criminal charges were nolle prassed without conditions. 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)G), 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(4)(b), Florida Administrative Code, in that Respondent has intentionally distorted or misrepresented facts concerning an educational matter in direct or indirect public expression. COUNT 5: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(4)(c), Florida Administrative Code, in that Respondent has used institutional privileges for personal gain or advantage. COUNT 6: The allegations of misconduct set forth herein. are in violation of Rule 6A- 10,081(5)(a), Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings. (SIGNATURE ON FOLLOWING PAGE) TIMOTHY JERMAINE WARD Administrative Complaint Page 3 of 3 WHEREFORE, based on the reasons set forth herein and in accordance with Explanation of Rights and Election of Rights forms attached to and made a part of this Administrative Complaint, Petitioner respectfully recommends that the Education Practi Commission impose an appropriate sanction against the Respondent’s educator's certificate pursuant to the authority provided in sections 1012.795(1) and 101.2.796(7), Florida Statutes. The sanctions imposed by the Education Practices Commission may include, but are not limited “sany 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 Respondent's educator’s certificate the Ces G, or a period of time not to exceed five years; revoking the Respondent’s educator’s certificate for a period of time up to 10 years or permanently; determining the Respondent to be ineligible certification; or barring the Respondent from reapplying for an educator’s certificate for a per of time up to 10 years or permanently. EXECUTED on this (2 dayot_Cictober _. 2015. hb —ftcord PAM STEWART, as Commissioner of Education State of Florida for iod

Docket for Case No: 16-001196PL