Soner Tarim sued by Alabama Education Association #WoodlandPreparatory

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IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ALABAMA
CIVIL DIVISION
KRISTA WILSON, BETTY BRACKIN, SUMMER
BEECH, and the WASHINGTON COUNTY
EDUCATION ASSOCIATION,
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Plaintiffs, )
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v. ) Case No.: CV-2019-________
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SONER TARIM; UNITY SCHOOL SERVICES,
LLC; WASHINGTON COUNTY STUDENTS
FIRST; THAD BECTON, individually and in his
official capacity as a member of the Board of
Directors of Washington County Students First;
TIFFANY DUMAS, individually and in her official
capacity as a member of the Board of Directors of
Washington County Students First; PAUL (GENE)
BROWN, individually and in his official capacity
as a member of the Board of Directors of
Washington County Students First; LEO
LEDDON, individually and in his official capacity
Washington County Students First; NANCY
ALSTON, individually and in her official capacity
Washington County Students First; JESSICA
ROSS, individually and in her official capacity as a
member of the Board of Directors of Washington
County Students First; JACOB SNOW,
individually and in his official capacity as a
member of the Board of Directors of Washington
County Students First; and Fictitious Defendants A,
B, C, whether singular or plural, those other persons,
corporations, firms, or other entities whose wrongful
or fraudulent conduct contributed to the events
leading to the unlawful expenditure of public funds, all
of whose true and correct names are unknown to the
Plaintiffs at this time, but will be substituted by
amendment when ascertained,
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Defendants. )
ELECTRONICALLY FILED
8/2/2019 9:16 AM
65-CV-2019-900064.00
CIRCUIT COURT OF
WASHINGTON COUNTY, ALABAMA
VALERIE KNAPP, CLERK
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COMPLAINT
This is a Complaint alleging fraud and illegal solicitation of students, and seeking a
declaratory judgment and injunctive relief with regard to the application of Soner Tarim
(hereinafter referred to as “Defendant Tarim” and/or “Defendant Soner Tarim”), in the name of
Washington County Students First (“WCSF”), to form a charter school in Washington County.
This action involves the Alabama School Choice and Student Opportunity Act, Ala. Code § 16-
6F-1, et seq. Among other relief, Plaintiffs seek to prohibit any transfer of public funds or any
other public property to Woodland Preparatory (hereinafter referred to as “Woodland Prep”). The
Defendants are obligated by law to follow the statutes set forth herein and have a duty to provide
full and factual information but have failed to do so.
JURISDICTION AND VENUE
1. This Court has jurisdiction under Ala. Code (1975) § 6-5-1, et seq. and § 6-6-220.
2. Venue is appropriate in this Circuit under Ala. Code (1975) §§ 6-3-2 and 6-6-222.
PARTIES
3. Krista Wilson (hereinafter referred to as “Wilson”), a taxpaying adult resident of
Washington County, Alabama and an employee of the WCBOE brings this action individually.
Wilson also brings this action as the President of Plaintiff Washington County Education
Association
4. Betty Brackin (hereinafter referred to as “Brackin”), an adult taxpaying resident of
Washington County, Alabama and an employee of the Washington County Board of Education
(“WCBOE”) brings this action individually.
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5. Summer Beech (hereinafter referred to as “Beech”), an adult taxpaying resident of
Washington County, Alabama and an employee of the WCBOE brings this action individually.
6. The Washington County Education Association (WCEA) is an unincorporated non-
profit association comprised of teachers, education support professionals, school administrators
and other school employees, many of whom are likely to be subject to adverse employment action,
up to and including termination, if Woodland Prep is allowed to proceed, due to a loss of
enrollment in schools operated by the WCBOE. All WCEA members have an interest in the lawful
expenditure of public tax funds.
7. On information and belief, Defendant Soner Tarim is a Turkish national and a
resident of the State of Texas residing at . Defendant
Tarim does business in Alabama as a representative of “Unity School Services,” and has a personal
financial interest in the opening of Woodland Prep. If the school opens, then Defendant Tarim,
through Unity Services, will receive 15% of all public funds paid to Woodland Prep.
8. Defendant Unity School Services, LLC (hereinafter referred to as “Unity” and/or
“Defendant Unity”) is a foreign limited liability company whose principal place of business is in
the State of Texas but is registered to do business in the State of Alabama.
9. Defendant Washington County Students First (hereinafter referred to as “WCSF”
and/or “Defendant WCSF”) is a nonprofit corporation registered to do business in the State of
Alabama that ostensibly applied for and had approved by the Alabama Public Charter School
Commission (“Commission”) an application to establish Woodland Prep within the Washington
County Board of Education’s (“WCBOE”) jurisdiction.
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10. Upon information and belief, Defendant Thad Becton (hereinafter referred to as
“Defendant Becton”) is a resident of Choctaw County residing at
and is the Chairman of the WCSF Board of Directors.
11. Upon information and belief, Defendant Tiffany Dumas (hereinafter referred to as
“Defendant Dumas”) is a resident of Washington County residing at
and is a member of the WCSF Board of Directors.
12. Upon information and belief, Defendant Paul (Gene) Brown (hereinafter referred
to as “Defendant Brown”) is a resident of Washington County residing at
13. Upon information and belief, Defendant Leo Leddon (hereinafter referred to as
“Defendant Leddon”) is a resident of Washington County residing at
14. Upon information and belief, Defendant Nancy Alston (hereinafter referred to as
“Defendant Alston”) is a resident of Washington County residing at
15. Upon information and belief, Defendant Jessica Ross (hereinafter referred to as
“Defendant Ross”) is a resident of Washington County residing at
16. Upon information and belief, Defendant Jacob Snow (hereinafter referred to as
“Defendant Snow”) is a resident of Washington County residing at
17. Fictitious Defendants A, B, C, whether singular or plural, are those other persons,
corporations, firms, or other entities whose wrongful or fraudulent conduct contributed to the
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events leading to the unlawful expenditure of public funds, all of whose true and correct names
are unknown to the Plaintiffs at this time, but will be substituted by amendment when ascertained.
18. Named and Fictitious Defendants will hereinafter be referred to collectively as
Defendants when not referred to individually.
FACTS
SECTION 1: RELEVANT SECTIONS OF THE CHARTER SCHOOL LAW
19. The Alabama School Choice and Student Opportunity Act, Ala. Code (1975) §16-
6F-1, et seq., (hereinafter referred to as “the charter school law”) authorized the establishment of
charter schools in Alabama and sets forth the requirements for their creation.
20. Charter schools are quasi-public schools formed pursuant to the charter school law
that receive for each of its students the same amount of state funds and local tax revenue that would
have otherwise been allocated on behalf of said student to the local school system where the student
resides.
21. Charter schools are exempt from most state laws and regulations regarding the
operation of a public school.
22. Moreover, charter schools have no accountability to taxpayers or elected officials,
but answer only to their “authorizer,” as provided for by the charter school law.
23. An authorizer is either a local school board or the Alabama Public Charter School
Commission (hereinafter referred to as “the Commission”).
24. Each city and county board of education in Alabama may decide whether or not it
wishes to become an authorizer and go through the approval process.
25. The WCBOE is not an authorizer of charter schools.
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26. Thus, any charter school that wishes to open within the jurisdiction of the WCBOE
can only be authorized by the Commission.
SECTION 2: SONER TARIM’S DECEPTION IN MULTIPLE CHARTER SCHOOL APPLICATIONS
27. On information and belief, Defendant Tarim was the CEO of the Texas-based
Harmony Public Schools (the largest charter school system in Texas) until 2017.
28. He is presently the founder and head of Defendant Unity School Services.
29. Defendant Unity is a Texas-based for-profit entity that advertises itself as a provider
of various educational services to public, charter, and private schools in the United States and
throughout the world.
30. Defendant Unity has no staff outside of Defendant Soner Tarim.
31. Moreover, Defendant Unity has no physical location despite Defendant Tarim’s
false representation that it does.
32. The Woodland Prep charter application identifies Defendant Unity and Defendant
Tarim as helping establish the Woodland Preparatory charter school.
33. On information and belief, Defendant Tarim is also presently the CEO of The
Royal Public School System (hereinafter referred to as “Royal”), another Texas-based entity.
34. On or about January 4, 2019, Defendant Tarim submitted a charter application to
establish multiple start-up charter schools in the Austin, Texas area.
35. While Defendant Tarim’s Texas charter school application was pending, he was
actively pushing for the establishment of the Woodland Prep charter school in Alabama.
36. During Defendant Tarim’s charter school application interview with the Texas
Education Agency (the Texas-based equivalent of the Alabama State Department of Education
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hereinafter referred to as “T.E.A.”), agency members directly questioned Defendant Tarim about
his involvement with Woodland Prep.
37. Defendant Tarim responded with indirect answers, but explicitly testified that he
wrote Woodland Prep’s charter school proposal.
38. He expressly stated that he has a vision for not only Texan students but also for
students nationwide and possibly across the world.
39. Defendant Tarim intentionally provided to the T.E.A. false and misleading data
about the performance of Washington County schools to T.E.A.
40. Defendant Tarim intentionally provided to the T.E.A. false and misleading
information about the need for a charter school in Washington County.
41. But Defendant Tarim intentionally failed to inform the T.E.A. that Washington
County public schools are not failing schools.
42. He intentionally failed to inform the T.E.A. that on the Alabama State Department
of Education’s 2018 State Accountability report, Washington County public schools received an
overall grade of “B” on a scale of “A” to “F.”
43. Defendant Tarim intentionally failed to inform the T.E.A. that a large and broad
swath of citizens of Washington County, Alabama have repeatedly publicly declared that they do
not want Woodland Prep or any charter schools in their community.
44. Instead, Defendant Tarim intentionally misled the T.E.A. by falsely accusing only
Washington County public school teachers of opposing his charter school, when in fact, he faced
opposition from a broad spectrum of concerned taxpaying Washington County citizens.
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45. He openly made these false representations and misleading omissions regarding
Alabama schools while advocating for the T.E.A.’s approval of his Texas charter school
application.
46. He also openly made these false representations and misleading omissions while
having a personal financial stake in Woodland Prep in Alabama, Royal Public Schools in Texas,
and other charter schools in Alabama and across the United States.
47. Further, when asked by the T.E.A. if his “vision” is in Texas right now and whether
he was going to get Royal Public Schools started and then go off somewhere else, Defendant Tarim
responded that Texas is his home.
48. Defendant Tarim made these representations to convince the T.E.A. that his
allegiance is to the successful start-up and operation of the Royal Public Schools charter school
network in the State of Texas, not to Woodland Prep in Alabama.
49. Notably, Defendant Tarim intentionally failed to disclose to the T.E.A. his true
degree of involvement with Woodland Prep.
50. Defendant Tarim intentionally failed to disclose to the T.E.A. that he was and is
actively representing Woodland Prep before the Alabama Public Charter School Commission.
51. He intentionally failed to disclose to the T.E.A. that he has been intricately and
actively involved in establishing and advocating for Woodland Prep since at least March 2018.
52. Moreover, Defendant Tarim intentionally failed to disclose to the T.E.A. during his
May 23, 2019 Royal Public Schools charter application interview that he was and is intricately
involved with more than one Alabama charter school applicant.
53. Instead, Defendant Tarim intentionally, falsely and deceptively minimized his
degree of involvement with Woodland Prep and in Alabama charter schools as a whole.
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54. The T.E.A. ultimately rejected Defendant Tarim’s application to open multiple
charter schools in Austin, Texas.
55. Prior to the T.E.A.’s rejection of Defendant Tarim’s charter school application,
Woodland Prep’s charter school application was submitted to the Alabama Public Charter School
Commission on or about March 16, 2018.
56. Defendant Tarim actively participated in Woodland’s application process,
including extensively testifying before the Commission during multiple public meetings.
57. Defendant Tarim’s participation in the Commission meetings created the
appearance that he was and is the primary agent of Woodland Prep, despite his false and misleading
representations to the T.E.A. that his involvement with Woodland was only as a consultant.
SECTION 3: THE NACSA REJECTION OF WOODLAND PREP’S CHARTER SCHOOL APPLICATION
58. The Commission had a contract with the National Association of Charter School
Authorizers (hereinafter referred to as “NACSA”), a recognized national leader in evaluating
charter school applications, to evaluate each charter school application it receives.
59. NACSA evaluated WCSF’s application and found that “The Woodland Preparatory
proposal does not meet the standard for approval.”
60. In finding the education program insufficient, NACSA found that “Woodland
Prep’s educational plan does not constitute a rigorous, quality instructional design that ensures
students will meet or exceed standards.” Supra at p. 7.
61. In finding the operations plan insufficient, NACSA found that “board members
appropriately indicated that they would use an evaluation matrix; however, when listing the
components of the matrix board members did not reference critical components such as academic
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or financial performance. Notably, the list of board responsibilities does not include overseeing
and evaluating the ESP (education service provider).” Supra.
62. In finding Woodland Prep’s proposal insufficient with regard to finance, NACSA
found that “unreasonable fundraising assumptions raise concerns about the budget’s viability.” It
further noted that Woodland Prep planned to secure a start-up loan of $200,000 at a 9% interest
rate from a private company, American Charter Development (“ACD”). Supra at p. 9.
63. Within less than two months of the application’s submission, the Commission
approved the application on or about May 14, 2018, despite NACSA’s rejection of the proposal.
64. Woodland Prep was scheduled to open in August 2019 for the 2019-2020 academic
year.
65. However, on June 7, 2019, the Commission held a public meeting.
66. During that meeting, the Commission considered a request made on behalf
Woodland Prep to delay the school’s opening date.
67. Defendant Tarim appeared and testified at that Commission meeting.
68. Defendant Tarim openly testified on behalf of Woodland Prep.
69. Other than Defendant Thad Becton, no other WCSF Board Member attended or
testified at the June 7, 2019 Commission meeting.
70. On June 7, 2019, the Commission voted five to one to grant the request to delay
opening Woodland Prep by one year, to August 2020.
71. Woodland Prep was nowhere near meeting the pre-opening conditions set forth by
the Commission and this delay is intended to allow Defendant Tarim to try to salvage his failing
vision for a charter school, a source of personal financial enrichment as described below.
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72. Defendant Tarim, through Defendant Unity School Services, intends to charge
Defendant WCSF a 15% management fee to operate Woodland Prep. Thus, before a light is turned
on at Woodland Prep, before a pencil is bought, and before a teacher is paid, Defendant Tarim will
receive 15% of the taxpayer funding for Woodland Prep off the top.
73. Additionally, Defendant Tarim requested a one-year extension to open Woodland
Prep because he has been unable to secure the enrollment that he represented to the Commission
would happen by spring and summer 2019.
74. Defendant Tarim’s enrollment estimations were false when he represented them to
the Commission
75. Moreover, Defendant Tarim’s enrollment estimations were false when he
represented them to the citizens of Alabama.
76. If Defendant Tarim fails to secure sufficient enrollment over the course of the
upcoming academic year to satisfy the Commission, Defendant Tarim’s charter contract will be
void and Woodland Prep will be statutorily prohibited from opening.
77. If Woodland Prep does not open, Defendants Tarim and Unity will not make money
in their venture in Washington County.
SECTION 4: DEFENDANTS’ UNLAWFUL & DECEPTIVE OUT-OF-STATE ADVERTISING
78. In light of the pressure Defendant Tarim faced in trying to meet his deceptively
inflated enrollment numbers for Woodland Prep’s inaugural school year, Defendant Tarim
illegally advertised Woodland Prep to out-of-state parents and students in the State of Mississippi.
79. Defendant Tarim’s out-of-state advertisements encourage people to enroll their
children in Woodland Prep in Washington County, Alabama.
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80. Defendant Tarim intentionally omitted from the advertisements that Woodland
Prep is an Alabama school.
81. Nor does Defendant Tarim disclose in those Mississippi advertisements that
Mississippians cannot attend the Alabama-based Woodland Prep.
82. Through those Mississippi advertisements, Defendant Tarim is recruiting
Mississippi children to fill the student vacancies reflected in his enrollment numbers.
83. This recruitment practice is deceptive and illegal.
84. On information and belief, Defendants have intentionally executed multiple
deceptive, illegal, and fraudulent recruitment practices.
85. More specifically, Defendant Tarim’s Mississippi recruitment campaign violates
Alabama’s charter school law.
86. Defendant Tarim’s end goal is having out-of-state students enroll at Woodland Prep
to make his required enrollment number in time to submit an updated report to the Commission.
87. Defendant Tarim is using deceit to bolster his enrollment numbers to a level
sufficient to allow him to open Woodland Prep.
88. Once Defendant Tarim obtains adequate enrollment numbers through his false
representations and deceptive practices, he will open Woodland Prep’s school doors.
89. As a result, the State of Alabama will unlawfully expend public funds to pay
Defendant Tarim for his deceptive and illegal practices.
90. The remaining Defendants are complicit in Defendant Tarim’s deceit and
misrepresentations.
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SECTION 5: DEFENDANT TARIM’S ALTER EGO
91. The charter school law provides that an “applicant” is “[a]ny group with 501(c)(3)
tax-exempt status or that has submitted an application for 501(c)(3) tax-exempt status that develops
and submits an application for a charter school to an authorizer.”
92. The law further permits applicants to contract with an “education service provider”
to provide services to the school.
93. Ostensibly, Defendant WCSF is the applicant for Woodland Prep and Defendant
Tarim/Unity is the education service provider.
94. However, on information and belief, it was Defendant Tarim’s idea to open a
charter school in Washington County (against the wishes of Washington County residents) in an
effort to begin franchising charter schools in Alabama.
95. On information and belief, it was Defendant Tarim who initiated the process to
establish and open Woodland Prep.
96. Defendant Tarim created Defendant WCSF as a front intended to meet the
requirements that a 501(c)(3) be the applicant for a charter.
97. On information and belief, the Woodland Prep management contract between
Defendant WCSF and Defendant Tarim was not negotiated at arms’ length.
98. Defendant WCSF’s board did not have separate legal counsel to advise them.
99. On information and belief, Defendant WCSF’s board takes no action without prior
approval from Defendant Tarim.
100. The WCSF has zero funding independent of Defendant Tarim or the Utah company
selected by Defendant Tarim to provide financing for Woodland Prep’s construction and opening.
101. Defendant Tarim is using Defendant WCSF as a shell corporation.
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102. This practice is deceptive and illegal.
103. Through this illegal and deceptive practice, Defendant Tarim has intentionally
manipulated the charter school law to establish and operate Woodland Prep under the guise of
there being a requisite non-profit entity overseeing the school.
104. Defendant Tarim is so extensively intertwined and intermingled with Woodland
Prep and Defendant WCSF that those entities are his alter egos.
105. It was Defendant Tarim who appeared before the Alabama Public Charter School
Commission to request an extension for Woodland Prep’s opening date when it became obvious it
would not be able to open for the 2019-20 academic year.
106. The NACSA evaluation of Defendant WCSF’s application also demonstrates that
Woodland Prep and Defendant WCSF are Defendant Tarim’s alter egos, finding that “[t]he board
delegates to its ESP, Defendant Unity School Services, the responsibility for purchasing, accounts
payable, accounts receivable, payroll, human resources, benefits administration, information
technology, and insurance.”
107. Further, NACSA found that Defendant WCSF’s application did “not address what
other organizations were considered, how USS was selected, or a plan for holding the ESP
accountable.”
108. No other organizations were considered.
109. And this is because Defendant Tarim created Defendant WCSF.
110. Defendant WCSF was not created organically by its members.
111. Nor did Defendant WCSF initiate retaining Defendant Tarim.
112. Defendant Tarim’s representation that Defendant WCSF retained him on the
Board’s own volition is also false.
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113. There is no real plan to hold Defendant Tarim accountable because, for all intents
and purposes, Defendant Tarim, Woodland Prep, and Defendant WCSF are one and the same.
114. This relationship is misleading, deceptive, and illegal.
SECTION 6: COMMUNITY OPPOSITION
115. The mayor of Chatom, the county seat of Washington County, has publicly stated
that he does not want a charter school in the area.
116. He further stated that he does not know of anyone who does.
117. Open Records Requests were submitted to the Commission to secure the statutorily
required objective evidence of community interest in a charter school.
118. In response to the Open Records Request, Defendants submitted to Plaintiffs
materials submitted by Defendant Tarim and his alter ego, Defendant WCSF.
119. In public testimony to the Commission on June 7, 2019, counsel for Defendant
WCSF stated that Woodland Prep had not completed construction of the school because they had
lost subcontractors who were pressured by the community not to work on the project.
120. On information and belief, this same counsel for Defendant WCSF was selected by
Defendant Tarim.
121. Moreover, on information and belief, Defendant Tarim is compensating this same
legal counsel for services rendered regarding Woodland Prep.
122. There simply is no significant local community support for Woodland Prep.
123. Thus, the representations made by Defendant Tarim and his alter ego, Defendant
WCSF, in their application stating that there was significant local support were and remain false.
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COUNT I
FRAUDULENT REPRESENTATION OF A NON-PROFIT APPLICANT
124. All paragraphs above are readopted and reincorporated as if fully set out herein.
125. As alleged above, Defendants made false representations concerning existing
material facts, and failed to make truthful disclosures under circumstances requiring such
disclosures, regarding Defendant Tarim’s interests in, and involvement with, the establishment of
Woodland Preparatory charter school in Washington County, Alabama;
126. In particular but without limitation, Defendants have falsely represented that
Defendant Tarim is a mere consultant to, or merely the provider of services to, Defendant WCSF
when in truth he is the alter ego of, the controller of, and creator of, Defendant WCSF for his own
financial benefit;
127. When Defendants made their representations regarding the Woodland Prep charter
school application, Defendants knew them to be false;
128. Defendants made these representations with the intent to defraud and deceive the
Alabama Public Charter School Commission, the Alabama State Department of Education, the
citizens of Washington County including the Plaintiffs, and the State of Alabama at large;
129. Had Defendant Tarim’s true relationship to Woodland Prep and his actual
intentions with respect to charter school in Alabama, been disclosed and not misrepresented, the
Woodland Prep charter school application could not have been approved under the law;
130. The deceit will, in the absence of relief from this Court, harm the public by draining
funds from the State of Alabama and the Washington County public schools;
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131. As taxpayers having an equitable ownership in Alabama’s public funds and being
responsible for replenishing public funds if those funds are misappropriated, Plaintiffs have
standing to seek relief to prevent the unlawful distribution of public funds or public property to the
Defendants.
132. Therefore, Plaintiffs request a finding by this Court that the application for a charter
school ostensibly filed by Defendant WCSF for Woodland Prep was fraudulently made and that
the subsequent charter contract is void ab initio—prohibiting any public funds from being paid to
any of the Defendants.
COUNT II
FRAUDULENT REPRESENTATION OF
LOCAL COMMUNITY INTEREST & SUPPORT
134. For the Commission to authorize a charter school, it must find “significant and
objective evidence of interest for the charter school from the community.” Ala. Code (1975) § 16-
6F-7(b)(2)d.
135. Defendants lack the requisite significant community interest in the opening of a
charter school in Washington County.
136. Contrary to Defendants’ representations otherwise, Plaintiffs possess significant
and objective evidence of widespread community opposition to Woodland Prep and the
Defendants.
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137. When the Defendants represented to the public and the State of Alabama that there
was and is significant local community support for Woodland Prep, the Defendants knew those
representations were and are false.
138. The Defendants made these representations with the intent to defraud and deceive
the Alabama Public Charter School Commission, the Alabama State Department of Education, the
citizens of Washington County including the Plaintiffs, and the State of Alabama at large;
139. Had the Charter School Commission not been deceived, and had Defendants been
truthful about the lack of community support, the application of Woodland Prep could not have
been approved under the governing law.
140. The deceit will, in the absence of relief from this Court, harm the public by draining
funds from the State of Alabama and the Washington County public schools;
141. As taxpayers having an equitable ownership in Alabama’s public funds and being
responsible for replenishing public funds if those funds are misappropriated, Plaintiffs have
standing to seek relief to prevent the unlawful distribution of public funds or public property to the
Defendants.
142. WHEREFORE, Plaintiffs request a finding by this Court that the application for a
charter school purportedly filed by Defendant WCSF for Woodland Prep was fraudulently made
and that the subsequent charter contract is void ab initio—prohibiting any public funds from being
paid to any of the Defendants.
143. Plaintiffs respectfully request a judgment declaring the same and forbidding the
disbursement of any public funds to Woodland Prep.
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COUNT III
UNLAWFUL SOLICITATION OF OUT-OF-STATE STUDENTS
145. Ala. Code (1975) § 16-6F-5(a)(1) states that “A public charter school shall be open
to any student residing in the state.” (Emphasis supplied.)
146. Defendants advertised outside the State of Alabama to students in Mississippi.
147. Defendants violated the charter school law by actively recruiting Mississippi
students to enroll in Woodland Prep.
148. As a result, Plaintiffs seek from the Court:
a. a declaration by the Court that enrollment in Alabama charter schools is
limited to residents of Alabama;
b. a writ of mandamus to Defendants to immediately remove any out-of-state
students listed as pre-enrolling in Woodland Prep; and
c. a writ of prohibition to Defendants to cease and desist all advertising and
other efforts to solicit or accept students from outside the State of Alabama.
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COUNT IV
DECLARATORY JUDGMENT AND WRIT OF PROHIBITION TO PREVENT
UNLAWFUL EXPENDITURE OF PUBLIC FUNDS
150. Only lawfully-approved public charter schools are entitled to receive taxpayer
funds from the State Department of Education for their operations.
151. Only lawfully-approved charter schools are also entitled to receive certain local
funds from the local board of education.
152. Because Woodland Prep was not authorized in compliance with the charter school
law as set forth above, it would be unlawful for the State Department of Education to authorize
any funds to be distributed to Woodland Prep.
153. It would also be unlawful for Woodland Prep to receive any other public property.
154. Any contract purporting to provide public funds to or for Woodland Prep is void as
being against public policy, would cause harm to the public, and is void for having been tainted
by fraud ab initio.
155. Taxpayers have standing to seek injunctive relief to prevent the unlawful
distribution of public funds or public property. See Ingle v. Adkins, 256 So.3d 62 (Ala. 2017)
([T]axpayers have an equitable ownership in the public funds and will be responsible for
replenishing the public funds if those funds are misappropriated, and, thus, a taxpayer suffers an
injury when public funds are illegally spent.)
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156. Thus, Plaintiffs request that the Court issue a judgment declaring that Woodland
Prep, having not been lawfully authorized as a charter school, is not entitled to the receipt of public
funds.
157. Plaintiffs further request an Order prohibiting Defendant Soner Tarim or any
entity/individual acting in concert with him, from receiving any public funds or property from the
State of Alabama, the local board of education, and any other Alabama public entity.
PRAYER FOR RELIEF
WHEREFORE, THE PREMISES CONSIDERED, Plaintiffs respectfully pray that the
Court will:
(a) issue a judgment declaring that Defendant Soner Tarim is the alter ego of Defendant
WCSF and Woodland Prep;
(b) issue a judgment declaring that representations of community support for Woodland
Prep were fraudulent;
(c) issue a judgment declaring that only Alabama residents may enroll in Alabama charter
schools;
(d) issue a judgment declaring the Woodland Prep charter contract void ab initio;
(e) issue a judgment declaring the Woodland Prep charter school application to be a
fraudulent instrument;
(f) issue a writ of mandamus to Defendant WCSF to withdraw its Woodland Prep charter
school application;
(g) Issue a writ of prohibition proscribing Defendant WCSF, Defendant Soner Tarim, or
any individual/entity acting in concert with Defendant Soner Tarim and Defendant
WCSF from reapplying for a startup charter school;
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(h) issue injunctions, as well as writs of mandamus and prohibition, to prevent Defendant
WCSF and all other Defendants from opening Woodland Prep.
(i) provide such other relief as the Court deems appropriate, including, but not limited to,
attorneys’ fees, costs, and expenses.
RESPECTFULLY SUBMITTED on August 2, 2019.
/s/ Thomas M. Loper
THOMAS M. LOPER (LOP007)
Counsel for the Plaintiffs
Loper Law LLC
452 Government Street, Suite E
Mobile, Alabama 36602-2320
Phone: (251) 288-8308
Email: tloper@loperlawllc.com
/s/ Clinton M. Daughtrey
CLINTON M. DAUGHTREY (DAU005)
Alabama Education Association
P.O. Box 4177
Montgomery, Alabama 36103-4177
Phone: (334) 834-9790
Email: clintd@alaedu.org
/s/ Victoria D. Relf
VICTORIA D. RELF (REL004)
Alabama Education Association
P.O. Box 4177
Montgomery, Alabama 36103-4177
Phone: (334) 834-9790
Email: Victoria.Relf@alaedu.org
* * * * * * * * * * * * * * * * ** * * * * * * * * * * * * * * * *
DEFENDANTS WILL BE SERVED VIA CERTIFIED MAIL
DOCUMENT 2

[23]
SERVE DEFENDANTS AS FOLLOWS:
Soner Tarim
Unity School Services
c/o Registered Agents Inc.
212 W. Troy St, Ste B
Dothan, Alabama 36303
Washington County Students First
c/o Thad Becton
Thad Becton
Tiffany Dumas
Paul (Gene) Brown
Leo Leddon
Nancy Alston
Jessica Ross
Jacob Snow
DOCUMENT 2

Soner Tarim sued by Alabama Education Association #WoodlandPreparatory

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Soner Tarim sued by Alabama Education Association #WoodlandPreparatory