1LEGAL DIVISION of Social Services Office of Chief Couese P, AVALOS essisteet Chieic Counset Senior Staff Attoreey 744 I3 Street, MS 8%?1531 f?EES?eerereferee}= CA 958141? Telephohe Number: (91 6-) 053-188th T?eostm?ie Numberi (Q10) SEEKMTKE for Comeleihe IN THE MATTER OF: et a JENNIFER WOODFOREX Stete No. 153685? BEFORE TEE, DEPARTMENT OF SOCIAL SERVICES STATE OF CALIFORNIA KATRIEN dba Sediqi Femi ly Child Care 17472 Matinal Road San Diego, CA 92127 KATRIEN Ql SEDIQI ROIN SEDIQI Respondents. C388 No. 7715170101 OAH No. (LICENSE REVOCATEON) CD88 No. 77151701018 ACCUSATION (EXCLUSION ACTION) CD88 No. .7715170101C ACCUSATION (EXCLUSION ACTION) CD88 NO. 771517010113 ACCUSATION (EXCLUSION ACTION) JURISDICTION 1. This matter arises Lieder the California Child Day Care Facilities Act, Health and Safety Code section 1596.70 et seq, which governs the licensing and operatiori of faITiily child care homes. 2. The regulations which govern the licensing and operation of family child care homes are contained in California Code of Regulations, title 22, section 102351 .1 Sediqi, et. al. Accusatton rev. exclusion seg.1 The term ?famiiy chiid care home?, as used iri regulation section is the same as the term ?family day care home? as seed to fieaith sad Safety Code section i5?i5f8fai 3. The Caiiforr?iia Departrr?ierit of Sociai Services is the agerioy of the State of Caiiforaia for the licensing arid ii-?ispectiori of fareiiy iid care he i't?i . Iii. ihe Department may prol?iitiit iiceosee from employihg, continuing the employrrieht of, allowing iri, or aiiowing contact with ciieots of a licensed facility lay any employee, prospective employee, or other persori who is act a. clierit of a family chiid care home pursuant to Health and Safety Code section 15968897. 5. Administrative proceedings before the Department must be conducted in conformity with the provisions of the California Administrative Procedure Act, Chapter 5, Government Code section 11500 et seq. 8. Pursuant to Health arid Safety Code section the Department may institute or continue a discipliriary proceeding agaihst a person following the resignation, withdrawal of employment application, or change of duties, or any discharge, failure to hire, or reassignment of the person by the licensee or if the person no longer has contact with clients of the facility. 7. Pursuant to Health and Safety Code section ?1598.854, the Department may institute or continue a disciplinary proceeding against a licensee following the suspension, expiration, or forfeiture of a license. 8. Pursuant to Heaith and Safety Code sections t596.889, and the standard of proof to be applied in this proceeding is the preponderance of evidence. Subsequent references to any regulation sectionts) are to Titie 22 of the California Code of Regulations. Sedioi, et. at. - Accosation rev. excursion 2 PARTEES 9. Cemptaieeht ie the Deputy Directer' ot the Care Liceheicg Divietee of the Departmeet. Pereoertt to Cede eectioh 11.58153, (Serratjiteit'im?rt t?itee thie Acmeatier?: it?; her otticial? capacity. it}. Reepot?rdeet ie tice-oeed by the to epetete a temit?y chite cat'e heme at Witt-m ti/ietirtei Road, Siam Qiego, Catt-terri?e The tectiity wee l?c-ei?reed ori Juiy 8, 28?33. ?t cepy cst" Reepecdeht most recerrt: eettihg forth the capacity, limitatione, arr-d ettective datee accempartiee this; Accusatiori as ?re, and is incorporated by reterehce. Respondent ABDULLAH residee Err the facility of or bars contact with the ct?eote of the family child care heme. Respondent RGEN SEQEQE resides in the facility of or has contact with the ciierite of the tamin child care home. 12. Responderrt KATREEN 8EQEQE, by virtue of ticeneure, must operate in accordance with the statutes and regulations governing the licensing and operatioe of family chitd care homes. Reepoodente 8&9th aed RQEN by virtue of presence in or contact with ctients ot a family child care heme, is subject to the jurisdictional provisions of Health and Safety Code sections 1598.871 and 15988897. Copies of the applicable statutes and regulations accompany this Accueation as AYYACHMENT and are incorporated by reference. ALLEGATEGNS SUBJECT MATTER: PERSONAL RIGHTS ENVIRONMENT APPLECABLE LAW: Health and Safety Code sectione 1598.871, 15988897, and 1598.885 Regulation sections 1024-02, 102417, and 102423 trite-titet et, at. Accusation rev. 3 1 2 t3. tho- patioo of iioonooia i??iaaponoant itaWtiEt-?i $Ett??l to ptovioto a and violated ot' aiiowad othota to violates: the pataohai rights of in para toil-owa: iit'ooa on or apoot Ciotohai Ma aota to Jon-a "i2: Etit i3 zaEtMitaimt?itii aaptat apt-malty Eti?ld took ii?iappt?opttato with oititoi?an in aa toiiowa; 8 l2) Respondent SEEM solid in 9 oara?a genital area with his hand, and took photographs of thia act 3.0 . while attl'to facility; 1.1 .2) Reapoodont ?tBEtULL?ti-t 3E5?i?i took photographs of 12 at least four children in oato?o vagina-l areas While at the facility; 13 3) Respondent ?tEDtiLL?tii SEmml took photographa 1 4 under the skin: of children in care while at tho facility; and, 15 B. On or about June ?32, 2015, and at other times the exact dates of 16 which are unknown to Complainant, Respondent ABDULLAH 17 possessed at least 23 photos of child pornography. 18 19 SUBJECT MATTER: FAILURE TO REPO RT 20 APPLICABLE LAW: Health and Safety Code Sections 1596.885lo) and 2 1 t596.8897(a) (2) 22 Regulation section 1024152 2 3 24 i4. Respondent failed to report 25 arrest for child pornography and lewd and iasoivioua conduct, on Gt? about Jana l5, 27"31? Sediql, (at. at. Accusaiol rev. 4 SUBJECT MATTER: CONDUCT t-ieaith and Safety Code sections i596.885{c 2 ma?a a. m; :1 ?596,889?ax2} titegtriation section ?324-02. ?tt?t?e?li?i?r?: ?i 5, {Zin- or about Liane ?i Zi?tfi?i and at other times the street dates ot? Witter: are unknown to Cornpiair?iant, Reaper-idem. tooit and videos under the skirts of worsen, without their ltriowiedge or cor?rsent. to. On or about June ?i4, 20'i 5, Respondent RQEN seeroi had t4 grants cocaine in his possession and accessible to children in care while at the ?17. Respondents engaged in conduct that is inirnical to the heaith, morals, welfare, or safety of either an individual in or receiving services from the or the people of the State of California as alleged in paragraphs '13 through 15, above, and incorporated herein by reference. CAUSE FQR ANS QRDER 0F EXQLUSEGN 18. The facts alleged in paragraphs 13 through 15, individually orjointly, provide cause, pursuant to Health and Safety Code section to revoke Respondent license to operate the facility; and pursuant to Health and Safety Code section 1596.889? to prohibit Respondents SEWQE, and RGEN employment in, presence in, and contact with clients of, any facility licensed by the Department or certified by a licensed foster family agency and from holding the position of member of the board of directors, executive director, or officer of the licensee of any licensed by the Department, for the remainder of Respondents respective lives. ?19. The facts alleged in paragraphs i3 through i6, individualiy oriointly, constitute conduct by Respondents SEDEQE, SEDEQEE and Kathi I which is inirnical to the health, safety, morals or welfare of clients receiving care (It Sediqi, et. at. Accusation rev. exctusion 3.3 14 15 l6 17 1.8 3.9 from the tecility, or to the people of the State of Cait?l?omie These facts provide cattee, bureueet to Heattb eed $etety Code eectiorte i5?i6885t?c) end to revel/\e tee ttcertee te operate the end to et'ehibit Reepertdertte EFWWREEN SEt?t?tty e?titiciictc?t end 3Etitt?ltie id, irm e-rtd t?IEi?it?E-?tct nitrite cl-Eertte ct} aity tactiity by the Depet-tweet es" ey itee to egeecy eed trt'tet- l-"totdirtg the o't o-t" the ot' citi-?ectete executive dtt'ectetj or office? et? the ot erty tacitity by tee ft)? the remainder of Reeboederite teebectiye tiyee. PENN FUR RENEE 20. WHEREFORE, Complement tequeete that Respondent Etiet?EEtEht license to operate a family chiid care home be revoked and Respondet?tte KeTRtEt?tt SEQEQE, SEEiim eed RQEN be prohibited for the remainder of Respondents respective Eivee, from employment in, presence in, and contact with clients of, any facitity licensed by the Department; or certified by a ticeneed teeter family agency and from holding the position of member of the board of directors, executive director, or of?ces? of the of any facility iiceneed by the Department. DATED: .-J PAMELA DICKFOSS if" Deputy Director Community Cate Licensing Division California Department of Social Sediqi, et. aL Acetieation rev. exctueiort 6 {fwm r? rm a? i r?r?sr?r?; :131.3: Effeciive Dare: Totai (Sagacity; in with provisions 0? the E-Eriairh and Safety Code or? {Iaiiforr?ria, and its wires; and reguiatioms; the Department of Sociai Service-33 hereby memes this Manama to operate and maintain 8 FAMILY DAY CARE HOME Name or Facii?ry SEDIQE, FAFWLY {3mm CARE W472 MATINAL ROAD SAN CA 92127 This License is not transferable and is granted 50$er upan the foiiowing: MAX. CAP (WHEN THERE {8 AN ASSISTANT PRESENT): ?12 NO MORE THAN 4 ENFANTS. CAP 14 NO MORE THAN 3 1 CHILD IN KINDERGARTEN OR ELEMENTARY SCHOOL AND 1 CHILD AT LEAST AGE 8. Ciient Groups; Served: Complaints regarding services in this facility should be directed {.01 COLD Regionai Office (E519) ?67--2200 I mum-g,? tiff-I?M, ?rm? I. ?ifPameEa . r? Deputy Director, Authorized Representative of Licensing Agency Communiiy Care Licensing Division war A ?35.ch Pdni Daie