IN THE MATTER BEFORE THE STATE BOARD OF FOR RACHELL GRANT EDUCATOR CERTIFICATION AGREED FINAL ORDER On the?? day of I 2018, the State Board for Educator Certi?cation (?Board" or considered the matter of the certi?cation of RACHELL GRANT, ReSpondent. This Agreed Order is executed pursuant to the authority of the Administrative Procedure Act, TEX. CODE ?2001.056. and I9 TEX. ADMIN. CODE which authorize the informal disposition of contested cases. In a desire to conclude this matter without further delay and expense, the Board and Respondent agree to resolve this matter by this Agreed Final Order. The Board makes the following Findings of Fact and Conclusions of Law: 1 OF CT I. RACHELL GRANT, Respondent, holds Texas Educator Certi?cate No. I and is subject to the jurisdiction of this Board. Respondent holds a standard Principal Certi?cate (Grades EC- 1 a standard Secondary Sociology Certi?cate (Grades 6-12); and a provisional lifetime Secondary Speech Communications Certi?cate (Grades 6-12). 2. The State Board for Educator Certi?cation received information alleging that Respondent, while employed as an at Prosper Independent School District, violated 19 TEX. ADMIN. CODE ?247.2 (l or 19 TEX. ADMIN. CODE by intimidating an educator in an effort to prevent reporting of the inappropriate conduct of another educator toward a student. 3. Respondent was provided with the Opportunity to remand to the allegations and to show compliance with the law. Respondent specifically denies that she has engaged in any conduct or behavior that would require any disciplinary action be taken against her certificate. However, in light of the costs and uncertainty associated with litigation, she agrees to the entry of this Order. 4. Respondent agrees to accept a ONE-YEAR SUSPENSION of her Principal Certificate, commencing on June 22, 2018 and ending on June 22, 2019. CONCLUSI NS OF LAW l. RACHELL GRANT is subject to thejurisdiction of this Board and is required to comply with 19 TEX. ADMIN. CODE, ch. 227 through 250, and Board rules. The Board is authorized, pursuant to 19 TEX. ADMIN. CODE to issue a one- year suspension. The Board is authorized to order disciplinary action against Respondent based upon satisfactory evidence that Respondent violated 19 TEX. ADMIN. CODE and and/or 19 TEX. ADMIN. CODE (2X19, The State Board for Educator Certi?cation and Respondent agree to the disciplinary action set forth herein in lieu of formal disciplinary proceedings. IT IS THEREFORE ORDERED, ADIUDGED AND DECREED THAT: 1. Respondent?s Principal Certi?cate is hereby SUSPENDED FOR ONE YEAR, commencing on June 22, 2018 and ending on June 22, 201,. During the period of suspension, Respondent is not allowed to work as an administrator for a Texas public school, including an open enrollment charter school, or shared services arrangement pursuant to TEX. EDUC. CODE 21.003, and and I9 Tax. ADMIN. CODE l53.l 1(d) and 153.1] as applicable. The suspension imposed by this Order shall not automatically terminate at the end of the period of suspension, but shall remain in place until Respondent?s certi?cate has been reinstated. Respondent must request reinstatement, pay any applicable reinstatement fees, and demonstrate compliance with all terms and conditions of this Order. Respondent shall comply with all provisions of 19 TEX. ADMIN. CODE, ch. 227 through 250, and Board rules. If the Board ?nds that Respondent has violated any of the terms of this order, the Board may extend the term of suspension or take any other appropriate action authorized by 19 Tax. ADMIN. CODE I, RACHELL GRANT, HAVE READ AND UNDERSTAND THE FOREGOING AGREED FINAL ORDER. I UNDERSTAND THAT BY SIGNING THIS AGREED FINAL ORDER, I WAIVE CERTAIN RIGHTS, INCLUDING ANY RIGHT TO A FORMAL HEARING, ANY RIGHT TO SEEK REMOVAL OR MODIFICATION OF THE SANCTION PROVIDED FOR IN THIS ORDER AND ANY RIGHT TO SEEK JUDICIAL REVIEW OF THIS ORDER. SIGN THIS ORDER VOLUNTARILY, WILLINGLY AND KNOWINGLY AND I UNDERSTAND THIS AGREED FINAL ORDER CONTAINS THE ENTIRE AGREEMENT AND THERE IS NO OTHER AGREEMENT OF ANY KIND, VERBAL, WRITTEN OR OTHERWISE. - SIGNED this 5" dayof ng?gors RACHELL GRANT 2 Agreed Fina! Order RACHELL On behalf of the State Board for Educator Certi?cation: 6% @256 SIGNED this day of 20! 8 Dam/7k Wit/J LAURA MORIATY Director SBEC Enforcement for Educator Leadership and Quality Texas Education Agency Nate: Pursuant to the Resolution of the State Board for Educator Certification dated December 2015. the Associate Conunissioner for Educator Certification and his designee have the delegated authority to sign an order informally disposing ofa contested case involving educator certification. APPR VED AS TO FORM: argar cGee, Assistant Counsel State No. 24032724 Texas Education Agency Of?ce of Legal Services I701 N. Congress Avenue Austin, Texas 78701-1494 Claw, (SQPZ H. 40(- Tiger Hanner State Bar No. 08925580 Law Of?ces of Tiger Harmer 807 McPhaul Street Austin, Texas 78758 Attorney for Respondent RACHELL GRANT 3 Agreed Final om: Texas Education Agency Commissioner Mike Morath 1701 North Congress Avenue Austin,Texas 78701-1494 0 512 463-9734 0 512 463-9838 FAX 0 tea.texas.gov July 13, 2017 Rachel] Grant Via 7016 2070 0000 2702 6178 428 Dartmoor Drive and First Class US. Mail Celina, TX 75009 Tiger Hanner, Esq. Via 7016 2070 0000 2702 6123 807 McPhaul Street and First Class US. Mail Austin, TX 78758 Re: In the Matter of Gregory Wright, Rachel! Grant, and Shelia Winter; Before the State Board for Educator Certi?cation Dear Ms. Grant: Enclosed please ?nd a copy of the Original Petition to take action against your Texas Educator?s Certi?cate. You have thirty (30) days ?'om the date of receipt of this Original Petition to ?le an Answer in this proceeding. If you have any questions or need assistance, please contact Margaret McGee at (512) 463-7307 or via email at Margaret.McGee@tea.texas.gov. If you obtain legal counsel, please notify our of?ce of their name and contact information, or ask him/her to contact our of?ce. We appreciate your cooperation in this matter. Sincerely, U. S. Postal Service? CERTIFIED RECEIPT Domestic MaiiOniy fs/ Margaret McGee :1 :3 For visitourwebsllo at Margaret McGee, Asst. Counsel ru ru WOF Fl i A Texas Education Agency- Of?ce of Legal Services 2 .5 mm 1701 Congress Avenue ?1 Austin, Texas 78701 3 RachelIGrant_ (512) 463-9700 :1 3% 428 Dartmoor Drive =1 =1 Um: Celina, TX 75009 I 0" IPt't' E?i?m nc osures: ma 6 1 10 a mus-moron .1: 5.1.1 5.5mm: 1-4 I: I: n- PS Form 3800. April 2015 PSN 7510020009047 See Reverse Ior Instructlons IN THE MATTER BEFORE THE STATE BOARD OF 2 FOR GREGORY WRIGHT, RACHELL EDUCATOR CERTIFICATION GRANT, and SHELIA WINTER ORIGINAL PETITION Pursuant to TEX. EDUC. CODE ?2 .035, the Texas Education Agency, Educator Leadership and Quality Division ("Petitioner?) on behalf of the State Board for Educator Certi?cation (?the Board? or ?les this Petition against GREGORY (?Respondent Wright?), RACHELL GRANT (?Respondent Grant"), and SHELIA WINTER (?Respondent Winter") based on alleged violations of Title 19, TEXAS ADMINISTRATIVE CODE ch. 227 through 250, and in support thereof shows the following: I. LEGAL AUTHORITY AND JURISDICTION 1. Pursuant to TEX. EDUC. CODE 21.031 and SBEC is a State Board conducting its duties under the authority of the laws of the State of Texas, and rules and regulations duly promulgated thereunder. Pursuant to TEX. EDUC. CODE 21.035, administrative ?mctions, including the enforcement of educator standards of conduct, are provided by the Texas Education Agency, Of?ce of Legal Services, 1701 N. Congress Ave, Austin, Texas 78701-1494. [0 Re5pondents are natural persons who at all times relevant to this proceeding has held active Educator Certi?cates. Therefore, SBEC has jurisdiction for the purposes of this proceeding as provided in 19 TEX. ADMIN. CODE 249.18. Respondents may be served with notice of all actions and proceedings relating to this case through Respondents? last known address in the Board?s records and his/her attorney of record: Gregory Wright Jay Brim, Esq. 1210 Packsaddle Trail 2525 Wallingwood Dr., Bldg. 14 Prosper, TX 75078 Austin, TX 78746 Raehell Grant Tiger Harmer, Esq. 428 Dartmoor Drive 807 McPhaul Street Celina, TX 75009 Austin, TX 78758 Shelia Winter John McCormick, Esq. 213 Hilltop Drive 1901 East Palm Valley Blvd, Suite 218 Anna, TX 75409 Round Rock, TX 78664 63 3. Respondents are required to keep his address current under the terms of 19 TEX. ADMIN. CODE 4. Pursuant to [9 TEX. ADMIN. CODE Petitioner may take the following actions: place restrictions on the issuance, renewal, or holding of a certificate, either inde?nitely or for a set term; issue an inscribed or non-inscribed reprimand; suspend a certi?cate for a set term or issue a probated suspension for a set term; revoke or cancel, which includes accepting the surrender of, a certificate without opportunity for reapplication for a set term or permanently; or impose any additional conditions or restrictions upon a certi?cate that the SBEC deems necessary to facilitate the rehabilitation and professional deveIOpment of the educator or to protect students, parents of students, school personnel, or school officials. 5. Pursuant to 19 TEX. ADMIN. CODE Petitioner may order disciplinary action against a person or certi?cate over which Petitioner has jurisdiction upon a determination based on satisfactory evidence that: the person is unworthy to instruct or to supervise the youth of this state; the person has violated a provision of the Educators' Code of Ethics; the person has failed to report or has hindered the reporting of child abuse pursuant to the TEX. FAM. CODE 261.00l, or has failed to notify the SBEC under the circumstances and in the manner required by the TEX. EDUC. CODE 21.006, and 19 TEX. ADMIN. CODE 249. l4(d) and and/or the person has committed an act that would constitute an offense (without regard to whether there has been a criminal conviction) that is considered to relate directly to the duties and responsibilities of the education profession, as described in l9 TEX. ADMIN. CODE 6. Petitioner may order disciplinary action pursuant to its enforcement authority under 19 TEX. ADMIN. CODE 247, upon a determination based on satisfactory evidence that a person has violated a provision of the Educators? Code of Ethics. 7. Petitioner may order disciplinary action for criminal conduct in accordance with TEX. OCC. CODE, Ch. 53, TEX. Eouc. CODE, Ch. Subch. B, and I9 Tex. ADMIN. CODE, Ch. 249. ll. MATTERS ASSERTED In support of this Original Petition and based on information and belief, Petitioner charges and alleges the following: 1. GREGORY WRIGHT holds Texas Educator Certi?cate No. and is subject to the jurisdiction of this Board. Respondent Wright currently holds a standard Superintendent Certificate (Grades effective June 2004 until June 30, 2021; a TEA Gregoo- anlu era! 2 Original Petition 10. ll. standard lifetime Mid-Management Administrator Certi?cate (Grades effective May 29, 1995; a standard lifetime All-Level Physical Education (Grades and Secondary History (Grades 6-12), both effective May 17, I985. Respondent Wright?s Texas Educator Certi?cates were in full force and effect at all times material and relevant to this Petition. Respondent Wright was employed as the Principal at Prosper High School, Prosper Independent School District, at all times material to the allegations herein. RACHELL GRANT holds Texas Educator Certi?cate No. and is subject to the jurisdiction of this Board. Respondent Grant currently holds a standard Principal Certi?cate (Grades EC-IZ) effective July 25, 2009 until September 30, 2020; a standard Secondary Sociology Certi?cate (Grades 6-12) effective February 5, 2003 until September 30, 2020; and a provisional lifetime Secondary Speech Communications (Grades 6-12) effective November 3, I996. Respondent Grant?s Texas Educator Certi?cates were in full force and effect at all times material and relevant to this Petition. Respondent Grant was employed as an Assistant Principal at Prosper High School, Prosper Independent School District, at all times material to the allegations herein. SHELIA WINTER holds Texas Educator Certi?cate No. and is subject to the jurisdiction of this Board. ReSpondent Winter currently holds a standard Principal Certi?cate (Grades EC-IZ) effective June 10, 2016 until September 30, 20l9; a standard English as a Second Language Supplemental Certi?cate (Grades 6-12) effective June 2, 2008 until September 30, 2019; a provisional lifetime Secondary English Certi?cate (Grades 6-12) effective June I, 1990; a provisional lifetime Secondary Physical Education Certi?cate (Grades 6-l2) effective June 30, 1989; and a lifetime paraprofessional Educational Aide 1 Certi?cate effective September 28, 1981. Other than her Principal Certi?cate, Respondent Winter?s Texas Educator Certificates were in full force and effect at all times material and relevant to this Petition. Respondent Winter was employed as an Assistant Principal at Prosper High School, Prosper Independent School District, at all times material to the allegations herein. On or about March 27, 2015, Maribeth Thomas, a nurse at Prosper High School where all three Respondents, Wright, Grant, and Winter, are employed as administrators, was approached by a - student (?Student who made an outcry of inappropriate physical conduct employed by Cameronn Mon?ison, an employee at Prosper High School. On or about March 27, 2015, Student I was in Morrison?s classroom, sitting next to Morrison and ?his hands were under the table where my legs were and I felt a ?nger kind of touching my leg.? TEA Gregor}- at a! 3 Original Petition 12. l3. I4. 15. l6. I7. 18. Student 1 reported that prior to this incident, Student I said that Morrison?s hand touched Student l?s leg again and Morrison said ?l?m so sorry I didn?t mean too I could lose my job for that I?m sorry.? On March 27, 20l5, Morrison wrote on his white board the phrase like you." Student was unsure if Morrison ?meant" it or not when Morrison said don't know if I will be here next year so I wanted to tell you that I like you.? Monison also told Student 1 ?Don?t tell anybody I said that please, please don"t tell anyone?? Before Student I left the workroom that day, Morrison again told Student 1 ?Please don?t tell anyone I said that.? On December 16, 2016, Cameronn Morrison was sanctioned by the State Board of Educator Certi?cation, as a result of this incident, for violating: a) Title 19, Texas Administrative Code by not maintaining professional boundaries with a student and b) Title 19, Texas Administrative Code by misrepresenting his disciplinary record on employment applications when applying for subsequent employment. The Texas Administrative Code de?nes ?child abuse" as follows, and includes the following acts or omissions: a) causing or permitting a student or minor to be in a situation in which the student or minor sustains a mental or emotional injury that results in an observable and material impairment in the student's or minor?s development, learning, or functioning; or b) sexual conduct harmful to a student's or miner's mental, emotional, or physical welfare.1 The relevant portion of The Texas Family Code de?nition of ?child abuse,? is as follows, and includes the following acts or omissions: a) sexual conduct harmful to a child's mental, emotional, or physical welfare, including conduct that constitutes the offense of continuous sexual abuse of young child or children under Section 21 .02, Penal Code, indecency with a child under Section 1, Penal Code, sexual assault under Section 22.0l l, Penal Code, or aggravated sexual assault under Section 22.021, Penal Code; or Texas Administrative Code 247.] TEA Gregnn Wright. and 4 Original Petition 19. 20. 21. b) 0 failure to make a reasonable effort to prevent sexual conduct harm?il to a child.2 Texas Family Code Sec. 261.101 describes persons required to report child abuse: 8) b) A person having cause to believe that a child's physical or mental health or welfare has been adversely affected by abuse or neglect by any person shall immediately make a report as provided by this subchapter. If a professional has cause to believe that a child has been abused or neglected or may be abused or neglected, or that a child is a victim of an offense under Section M, Penal Code, and the professional has cause to believe that the child has been abused as de?ned by Section 261.001 or 261.401, the professional shall make a report not later than the 48th hour after the hour the professional ?rst suspects that the child has been or may be abused or neglected or is a victim of an offense under Section 21.1 1, Penal Code. A professional may not delegate to or rely on another person to make the report. In this subsection, "professional" means an individual who is licensed or certi?ed by the state or who is an employee of a facility licensed, certi?ed, or operated by the state and who, in the normal course of of?cial duties or duties for which a license or certi?cation is required, has direct contact with children. The term includes teachers, nurses, doctors, day-care employees, employees of a clinic or health care facility that provides reproductive services, juvenile probation of?cers, and juvenile detention or correctional of?cers. Unless waived in writing by the person making the report, the identity of an individual making a report under this chapter is con?dential and may be disclosed only: (1) as provided by Section 261201; or (2) to a law enforcement of?cer for the purposes of conducting a criminal investigation of the report.3 Texas Education Code 21.006 speci?cally requires school superintendents to report abuse, and report to the State Board of Educator Certi?cation when an educator resigns or is terminated and there is evidence that the educator was involved in or solicited a romantic or sexual relationship with a student or minor. Per PrOSper FFG (EXHIBIT), policy dictates that a reporter can report suspected abuse to: a) A law enforcement agency: The Prosper Police Department, or the Collin County Sheriff's Of?ce; 3 Texas Family Code 3 Texas Family Code TEA Oregon- Wright. rm! 5 Original Petition 22The CPS division of the Texas Department of Family and Protective Services; or, c) If applicable, the state agency operating, licensing, certifying, or registering the facility in which the suspected abuse or neglect occurred. Following all applicable laws and policies of the Texas Family Code, the Texas Education Code, and ProSper Independent School District Policy, Maribeth Thomas noti?ed Assistant Principals Rachel Grant and Roger Barr about the outcry of abuse and made a report with Prosper Police Department. Respondent Wright was informed that Ms. Thomas made a child abuse report with the Prosper Police Department. Respondent Wright was infuriated that Ms. Thomas reported to ProsPer PD instead of Prosper ISD Police. Respondent Wright immediately called a meeting with Maribeth Thomas to discuss her report, not the facts or allegations made by Student I. Wright also called in Prosper ISD Police Chief Chad Vessels, Assistant Principals Shelia Winter and Rachel] Grant, and another administrator to the meeting as well. At the beginning of the meeting, ReSpondent Wright pretended to not know that it was Ms. Thomas who made the suSpected child abuse report to Prosper ISD in order to shame her into admitting she had reported the suSpected abuse. During the meeting, Respondent Wright admonished Maribeth Thomas for making a report to the city police department. Grant explained to Ms. Thomas that rather than immediately reporting the abuse to police, she should have called the school administration ?rst and foremost for direction. All three Respondents incorrectly told Maribeth Thomas that Student l?s name would be leaked to the ?press? because of her report to the City police. They all led Ms. Thomas to believe that her report to PrOSper PD had compromised student con?dentiality. All three Respondents did not treat Student outcry as a child abuse allegation. Respondents Wright and Grant told Maribeth Thomas that she was not to go outside the parameters of the PISD police and that she should go to her administrator for guidance, which is contrary to local policy FFG (EXHIBIT). Respondent Wright made it clear that Ms. Thomas was making the school look bad. Wright said that he believed Student l?s outcry did not need to be reported because it was not abuse. TEA Oregon Wright era! 5 Original Petition 34. 35. 36. 37. 38. 39. 40. 41. 42. 43. 45. 46. 619 Wright accused Thomas of being inaccurate in her account to the Prosper Police Department, based on the written statement of Student 1. Respondent had not read that statement when he accused her of being inaccurate. After repeatedly telling Thomas that her statement had a number of discrepancies, Respondent Wright suggested to Maribeth Thomas that she change her statement to police because it did not align with Student l?s statement. Student l?s statement and Maribeth Thomas's police report did not have discrepancies. The description of the abuse events was consistent in both instances. In the meeting with Thomas, the administrators and ISD Chief of police, Wright also suggested that he needed to tell the other teachers to report abuse solely to administrators and At the same meeting, Respondent Grant declared that Student l?s outcry was a non-abuse issue. Grant also stated that the proper procedure was to ?handle things here.? Grant incorrectly told Thomas that the Prosper PD was subject to open records and teachers were required to check with administration before telling the police about potential abuse. Respondent Grant made cements to Thomas saying that her reporting should have stayed within the district only, with "our" police department. Winter incorrectly told Thomas that the reason for this was to keep the student?s name ?out of things." Respondent Grant also told Thomas that her police report con?icted with the Student 1?s written statement and those con?icts could hurt the accused male teacher. Grant had not read Student?s statement when she made these remarks. Grant misrepresented Student l?s concerns regarding how- felt about the situation and was more concerned about a false accusation of the alleged perpetrator than about accurately reporting Student l?s claims to law enforcement. Respondent Grant, in her written statement to Human Resources, declared that if abuse happens, there are ?two options. report it to CPS or the Police Department. WE [sic] (administrators) are the Respondent Grant said that the outcry was not abuse and should not have been reported to the police. In the same meeting, Respondent Shelia Winter incorrectly said that Ms. Thomas was legally obligated to report the incident to police. TEA I Gregor) Wright e! at 7 Ongmal Petition 47. 48. 49. 50. 51. 53. 54. 55. 56. 57. 58. 59. Winter also suggested that Thomas should ?go her police report. During the meeting, Respondent Winter repeatedly referred to following a ?protocol." Winter said this was an ?unwritten policy.? When Ms. Thomas said that she communicated with the school administration before going to the Prosper PD, Winter jumped on Thomas and accused Thomas of not giving the administrators ?a chance.? Respondent Winter had interviewed Student 1 and received a written statement. Winter relayed that information to Respondent Wright. During the meeting, Winter never corrected Respondent Wright nor properly represented Student account to the group. None of the respondents read Student l?s outcry statement before using it to coerce Ms. Thomas into changing her child abuse police report. None of the respondents believed student I?s outcry was about abuse. None of the respondents reported the allegation of child abuse to Children?s Protective Services. None of the respondents reported the allegation of child abuse to the District Superintendent for further reporting to the Texas Education Agency, as required. None of the respondents reported the allegations of child abuse and solicitation of a sexual or romantic relationship to either the P180 superintendent or the Texas Education Agency. Pursuant to TEX. EDUC. CODE it is the policy of this state to treat with dignity and respect all students, including students with disabilities who receive special education services. Petitioner asserts that Respondents? conduct as outlined herein indicates that the Respondents are persons unworthy to instruct or supervise the youth of this state, in violation of 19 TEX. ADMIN. CODE Petitioner asserts that the Respondents? conduct as outlined herein indicates that the Respondents have violated a provision of the Educators? Code of Ethics, in violation of 19 Tex. ADMIN. Coos Petitioner asserts that Respondents? conduct as outlined herein indicates that the Respondents have violated Standard 1.1 of the Educators? Code of Ethics, l9 TEX. ADMIN. CODE by intentionally, knowingly, or recklessly engaging in deceptive practices regarding of?cial policies of the school district, educational institution, educator preparation program, the TEA, or the SBEC and its certification process. TEA Gregor) Wright cm! Original Petition 60Petitioner asserts that Respondent Wright?s and Respondent Grant?s conduct as outlined herein indicates that Respondent Wright and Respondent Grant have violated Standard 1.6 of the Educators? Code of Ethics, 19 TEX. ADMIN. CODE by falsifying records, or directing or coercing others to do so. Petitioner asserts that Respondents? conduct as outlined herein indicates that the Respondent has violated Standard [.10 of the Educators? Code of Ethics, l9 TEX. ADMIN. CODE by failing to be of good moral character and not being worthy to instruct or supervise the youth of this state. Petitioner asserts that Respondents? conduct as outlined herein indicates that the Respondents have violated Standard l.7 of the Educators? Code of Ethics, 19 TEX. ADMIN. CODE 247.2( by failing to comply with state regulations, written local school board policies, and other applicable state and federal laws. Petitioner asserts that Respondents? conduct as outlined herein indicates that the Respondents have violated Standard 2.2 of the Educators? Code of Ethics, 19 TEX. ADMIN. CODE by banning others by knowingly making false statements about a colleague or the school system. Petitioner asserts that Respondents? conduct as outlined herein indicates that the Respondents have violated Standard 2.4 of the Educators? Code of Ethics, 19 TEX. ADMIN. CODE by interfering with a colleague?s exercise ofpolitical, professional, or citizenship rights and responsibilities. Petitioner asserts that Respondents? conduct as outlined herein indicates that the Respondents have violated Standard 2.6 of the Educators? Code of Ethics, 19 TEX. ADMIN. CODE by using coercive means or promise of special treatment in order to in?uence professional decisions or colleagues. Petitioner asserts that Respondent Wright?s and Respondent Winter?s conduct outlined herein indicates that Respondent Wright and Respondent Grant have violated Standard 3.3 of the Educators? Code of Ethics, 19 TEX. ADMIN. CODE by intentionally, knowingly or recklessly misrepresenting facts regarding a student. FAILURE TO REACH SETTLEMENT Pursuant to 19 TEX. ADMIN. CODE Petitioner avers that the parties have failed to reach settlement of the matters asserted in this Petition. TEA I. Gregorv Wright. cm! 9 Original Petition 0 IV. NOTIFICATION TO RESPONDENTS Pursuant to 19 TEX. ADMIN. CODE Petitioner hereby noti?es Respondents of the following: IF YOU DO NOT FILE A WRITTEN ANSWER TO THIS PETITION WITH THE TEXAS EDUCATION AGENCY ATTORNEY IDENTIFIED BELOW WITHIN 30 CALENDAR DAYS OF BEING SERVED WITH THIS PETITION, THE STATE BOARD FOR EDUCATOR CERTIFICATION MAY GRANT THE RELIEF REQUESTED IN THIS PETITION, INCLUDING REVOCATION OF YOUR CERTIFICATE BY DEFAULT. THE MATTERS ASSERTED IN THE PETITION WILL BE DEEMED ADMITTED UNLESS YOUR WRITTEN ANSWER SPECIFICALLY DENIES EACH ASSERTION PLED AND IS FILED WITHIN THE PRESCRIBED TIME PERIOD. IF YOU FILE A WRITTEN ANSWER BUT THEN FAIL TO ATTEND A SCHEDULED HEARING, THE STATE BOARD FOR EDUCATOR CERTIFICATION MAY GRANT THE RELIEF REQUESTED IN THIS PETITION, INCLUDING REVOCATION OF YOUR CERTIFICATE. V. PRAYER WHEREFORE, PREMISES CONSIDERED, Petitioner prays: I. That the Administrative Law Judge enter a Proposal for Decision recommending that the Board ISSUE AN ORDER FOR A SANCTION UP TO AND INCLUDING PERMANENT REVOCATION of the Texas Educator Certi?cates Number as authorized by 19 TEX. ADMIN. CODE 249. 2. That the Administrative Law Judge enter a PROPOSAL FOR DECISION containing FINDINGS OF FACT holding that the ReSpondents committed the acts as charged and alleged herein, CONCLUSIONS OF LAW holding that the Respondents violated the statutes and rules as charged and alleged herein, and a RECOMMENDATION that Petitioner exercise its authority pursuant to 19 TEX. ADMIN. CODE 249.15 to take the aforementioned DISCIPLINARY ACTION against the Respondents? Texas Educator Certi?cates; and TEA t' Oregon Wright. at al 10 Original Petition 3. Petitioner Speci?cally prays for any such other relief to which it may be entitled under law. TEA Gregarv Wright. ct u! Original Petition Respectfully submitted, By: ls! Margaret McGee Margaret McGee State Bar No. 24032724 Texas Education Agency 1701 N. Congress Ave. Austin, Texas 78701-1494 Tele: (512) 463?7307 Fax: (512) 463-7545 Email: Margaret.mcgeeggteatexasgov Attorney for Petitioner C7 0 OF SERVICE I hereby certify that on the 13th day of July 20l7, a true and correct copy ofthis Original Petition has been forwarded as follows to: Gregory Wright Via 7016 2070 0000 2 702 6154 1210 Packsaddle Trail and First Class Mail Prosper, TX 75078 Jay Brim, Esq. Via 7016 2070 0000 2702 6161 2525 Wallingwood Drive, Bldg. 14 and First Class U.S. Mail Austin, TX 78746 Rachel! Grant Via 7016 2070 0000 2 702 61 78 428 Dartmoor Drive and First Class US. Mail Celina, TX 75009 Tiger Hanner, Esq. Via 7016 2070 0000 2 702 6123 807 McPhaul Street and First Class U.S. Mail Austin, TX 78758 Shelia Winter Via 7016 2070 0000 2702 6130 213 Hilltop Drive and First Class U.S. Mail Anna, TX 75409 John McCormick, Esq. Via 7016 2070 0000 2 702 6147 1901 East Palm Valley Blvd, Suite 218 and First Class U.S. Mail Round Rock, TX 78664 Margaret McGee Margaret McGee TEA r. Grcgon' Wright. et a! [7 Original Petition Attorney at Law 807 McPhaul Street Austin, Texas 78758 TEXAS EDUCATION AGENCY W3. Travis Building 1701 North Congress Avenue Austin. Texas 73701-1494 01 I RETURN SERVICE REQUESTED -. RUEQ ?m 32a? "2 DIST lit-T seem-rs 291359.513 Ms. Margaret McGee Assistant Counsel Texas Education Agency Educator Certi?cation and Standards 1701 Congress Avenue Austin, Texas 7870] - . -r razor-:1 net ism rung? aar11,:7 2a 7B70i-14?3499 Ihlno>uu;u - I ?4 CERTIFIED MAI - 1? 32'! - 7003 3230 DUDE sun? nb?n Eageb; ff; (1 Rachel! Grant AUG 1 5 2075 428 Dartmoor Dr. Celina, TX 7500? RETURN TO 75559213225 1 success/11,116 GRANT 1445 CARUTH LN TX 75099?33w RN TO 5 NDER 5' i 4' "m ?v . TEXAS euucmon AGENCY 1' . .. .. W.B. Travis Building - I - . . . 1701 Noah Congress Avenue . . $001 . 4O Austin. Texas 78701-1494 . . . RECEIVED Rachell Grant 17 2017 428 Dartmoor Drive Celina.TX75009 TEAMAIL (3:1th 787 NFE TIME 57.? RTN TO SEND 1445 CARUTH LN CELINA 75959-3827 - RETURN TO SENDER u-Ia I COMPLC I Cornpietettemei.2.md3. I TL HHS SLC 7/033 COUPLE: L: iHle 03' DELIVERY I I A. XW um" B. Reoeivedbya?rintedName) O. Dateothivery I ?du- Addwocv? On- DYes I Print your name and address on the reverse SENDER: FTF THIS I Complete Items 1. 2, and 3. so that we can return the card to you. A. Signature I Attach this card to the back of the mailpiece. or on the tront If space permits. 23:; Name) QWO 0' Del: Fan?f 93.4%? 1. AnideAddressedto: D. Yes . &)24rr.)l iIYES.werdeiiveryaddressbelom 3639.233323'5'53 44?me Austin,TX78758 45;. 77 75?0?; Ema-m 31'" 3?33wa 2. 70?! 3070 0000 E708 51:33 WW 701.5 1.730 #133 ma?a 13me ?SForm 3811,July2015P8N Domestio?etum?eceigt 1 ram 3811, July 2015 PSN Domestic Betum?ec ENUER: COMPLETE THIS SECTION I Complete items 1. 2. and 3. I Print your name and address on the reverse I oronthe front if space permits. EiMdrusee ArticIoAddressedto P?bfi?f?? Np ?pf 17 Ii YES. enter delivery address betow: No *7 7.1374? 3. ServiceType gmm:wwm 9590 9403 0954 5223 8440 34 name-coma 70.05 3330 5'40? U713 .. i IMF [@9200 71m. emu anon 270a 51.75 IC HEQU Rachel! Grant HECEIV ED 428 Dartmoor Drive {y/q/Is 3 2m] Celina, TX 75009 ?7/20 TEA 758 N3E 71:: EXP TO SEN 1445 CARUTH LN CELINA TX 75809?3877 FWD RETURN TO SENDER Irautlla