ex Gulen teacher tired of abuse and extortion of pay via tuzuking, files a lawsuit (complaint) against Utica Academy and Turkish Cultural Center of NY. http://www.pacificainstitutegulen.blogspot.com Gulen members have over 100 Non Profits layered around the United States schools used for extracting (money laundering) funds out of the publicly funded charter schools Gulen Movement operates. The money is then laundered to Gulen operations whether its in Turkey, Syria, Iraq or Africa and to the pockets of politicians in the USA. It must stop, Gulen Movement must cease the theft and poaching of billions of US Tax dollars intended for the education of American Children. http://www.gulenpoliticians.blogspot.com General Flynn is right in wanting to take down the Gulen Crime Operations. Mueller as former head of FBI has been protecting the Gulen Movement as far back as 2002, and in fact gave FBI awards to Gulen leaders like Gulen Lobbyist Bilal Eksili the photos are available on the internet. #ShameOnMueller

1. STATE OF NEW YORK
COUNTY OF ONEIDA SUPREME COURT
ERSIN KONKUR, VERIFIED COMPLAINT
Plaintiff. INDEX NO.
vs.
UTICA ACADEMY of SCIENCE CHARTER SCHOOL;
TURKISH CULTURAL CENTER; and HIGH WAY EDUCATION
Defendants.
Plaintiff Ersin Konkur, by his attorney David G. Goldbas, complaining of Defendants,
states as follows:
1. Plaintiff is a resident of Town of New Hartford, County of Oneida, and State of
New York. . .
2.. Defendant Utica Academy of Science Charter School (hereinafter "UASCS") is a
New York not-for-profit corporation doing business in Oneida County, New York.
3. Defendant Turkish Cuhural Center is a New York not-for-profit corporation doing .
business in Oneida County, New York.
4. Defendant High Way Education is a New York not-for-profit corporation doing
business in Oneida County, New York.
5. At all times material to this Complaint, Defendants acted jointly or as agents of
each other or as wholly owned affiliates of each other.
6. The three Defendants are all intimately connected and mutually supportive. All
follow a religious cult known as the "Gulen
Movement"
and all claim allegiance to Fetullah
Gulen, a religious leader now living in Saylorsburg, Pennsylvania.
7. At all times material to this Complaint, administrators of Defendant UASCS
including Superintendent Tolga Hayali; School Director Kadir Yavuz; and Board of Directors
President, Fehmi Damkaci, referred to officers of Defendant High Way Education and
Defendant Turkish Cultural Center as "our
leaders."
8. On August_14,-2R13,_.Maintiff-een_tergl-a-writteRone-yeatemployment-c-ontract
with Defendant UASCS by which Plaintiff would perform teaching and project coordinator
. services.at.the.Utica.Academy of Science, located at-1214 Lincoln Ave, Utica, New York,
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2. a
according to the academic calendar; in exchange for which Plaintiff would be paid a specified
salary.
9, Pursuant to contract, Plaintiff performed and discharged all of his employment
obligations from August 14, 2013 to June 30, 2014.
10. On June 24, 2014, Plaintiff and Defendant UASCS entered another one-year
employment contract by which Plaintiff would perform teaching and testing services full-time at
the Utica Academy of Science according to the academic calendar for a term ending June 30,
2015.
11. Pursuant to contract, Plaintiff performed and discharged all of his employment
obligations for the period August 14, 2013 to June 30, 2014.
12. From September 1, 2013 through and including Novernber 4, 2014, Plaintiff was
required by Defendants to pay $6, 646.81 (Six Thousand Six Hundred Forty Six Dollars 81/100)
in illegal kickbacks or in deductions of his wages, to be paid to Defendants, UASCS, Turkish
Cultural Center and/or High Way Education. Plaintiff was required to pay these illegal
kickbacks or deductions from wages on threat by
Defendants'
officers, agents or employees
working then and there in the course and scope of their office, agency or employment for
Defendants. The threats consisted of warnings, in words or substance, that if Plaintiff refused, he
would. be terminated from employment or else demoted in his employment.
13. Defendants UASCS, Turkish Cultural Center and/or High Way Education
collected, authorized, ordered, ratified and/or benefited from the illegal kickback of wages
described in Paragraph 12 above.
14. During a pay period which ended on or about March 14, 2014, Plaintiff performed
services on Saturdays for Defendant UASCS which services had not been specified in his written
employment contract. For these Saturday sessions, Plaintiff earned, in addition to his contractual
salary, $1399 (One Thousand Three Hundred Ninety Nine Dollars). Plaintiff was thereupon
issued a check for Saturday pay, which Defendant UASCS called "Instructional Pay", in that
same amount, but when the check was issued, Defendant UASCS through its School Director
Kadir Yavuz, demanded all of Plaintiffs Saturday pay in cash, and, on threat of employment
termination or demotion, seized it, telling Plaintiff this money was to benefit the Gulen
Movement.
15. . When he collected Plaintiffs March 2014 Saturday pay as described in Paragraph
14 above, Kadir Yavuz acted as agent for all Defendantsrand his collection was ordered, ratified,
confirmed by and ultimately delivered to one or all of the Defendants which were then and there
acting together for a common scheme or plan.
16. During a pay period which ended on or about June 20, 201 4, Plaintiff performed
services on Saturdays for Defendant UASCS which services had not been specified in his written
employment. contract.. For these Saturday. services, Plaintiff earned, in addition to his contractual
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3. salary, $1421(One Thousand Four Hundred T enty One Dollars). Plaintiff was thereupon
issued a check for Saturday pay, which Defendant UASCS called "Instructional
Pay"
in that
same amount, but when the check was issued, Defendant UASCS, through its School Director
Kadir Yavuz, demanded all of Plaintiffs Saturday pay in cash, and on threat of employment
termination or demotion, seized it, telling Plaintiff this money was to benefit the Gulen
Movement.
17. When he collected Plaintiffs June 2014 Saturday pay as described in Paragraph
16 above, Kadir Yavuz acted as agent for all Defendants, and his collection was ordered, ratified,
confirmed by and ultimately delivered to one or all of the Defendants, which were then and there
acting together for a common scheme or plan.
18. On or about January 27, 2015, Plaintiff refused to make illegal payments from
wages or to pay illegal kickbacks as demanded by Defendants. Defendant UASCS responded
by demoting Plaintiff in his employment. and on February 2015, by cutting his pay without any
right in law or contract to do so. Plaintiff s pay cut was imposed without warning or notice or
opportunity to respond.
19. Defendant UASCS eventually reversed its demotion of Plaintiff s employment
and on June 12, 2015 paid him his full salary according to his written contract and retroactive to
January.30, 2015.
20. The collection by Defendants of Plaintiffs salary or wage deductions and
overtime pay was without just cause or contractual authorization; totally lacked good faith and
fair dealing; and was perpetrated in willful violation of law.
21. In further retribution for Plaintiff's refusal to pay illegal deductions from salary
or wages and his refusal to pay illegal kickbacks from wages, Defendant UASCS refused to
renew Plaintiff's contract after June 30, 2015, and in effect terminated Plaintiff from
employment.
22. In order to recover the full amount of his employment earnings, including
overtime, Plaintiff has had to hire the services of the undersigned attorney and to pay him a
reasonable fee.
FIRST CAUSE OF ACTION .
Violation of Fair Labor Standards Act, 29 U.S.C §§207 and 216
23. Plaintiff repeats paragraphs 1-17 above and incorporates them herein as if fully
set forth.
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4. which.
illegal
24. Defendant's failure to pay Plaintiff overtime in March 2014 and June 2014
constitutes a violation of the Violation of Fair Labor Standards Act, 29 U.S.C §§207 and 216.
SECOND CAUSE OF ACTION
Violation of Labor Laws § 191 and § 198
25. Plaintiff repeats and realleges paragraphs 1 through 17 stated above and
incorporates them herein as if fully set forth.
26. The failure by Defendant UASCS, to pay overtime, violates Labor Law §191.
27. Defendant UASCS failure to pay Plaintiff's full wage violates of Labor Law
§191.
28. Defendant is in violation of Labor Law 191 which entitles Plaintiff to liquidated
damages equal to 100% of the unpaid wage or overtime pay, pursuant to Labor Law §198(1-a).
THIRD CAUSE OF ACTION
Violation of Labor Laws § 198 and 198-b
29. Plaintiff repeats and realleges paragraphs 1 through 21 stated above and
incorporates them herein as if fully set forth.
.3Û.30. Defendant's demanding and collecting, from Plaintiff, on threat of employment or
demotion in employment, portions of Plaintiff's wage, salary, and or overtime paid constitute
.illegal kickbacks are prohibited by Labor Law§ 198-b. .
31. Defendant's taking illegal kickbacks from Plaintiff's wage, salary and or overtime
pay, entitles Plaintiff to judgment including compensatory damages, liquidated damages;
attorney fees, and costs per statute of $50 (Fifty Dollars) per day, not exceed $5,000.00; plus
punitive damages.
FOURTH CAUSE OF ACTION
Violation of Labor Laws § 195
32. Plaintiff repeats and realleges paragraphs 1 through 24 stated above and
incorporates them herein as if fully set forth.
33. In February 2015, Plaintiff's change in employment from teacher and testing ..
coordinator to teacher alone constituted a new hiring of Plaintiff.
34. In February 2015, Defendant UASCS, violated Labor Law 195(1) by failing to
provide Plaintiff with a notice required by Labor Law 195(1)(a) and by failing to obtain
Plaintiff's acknowledgement in writing as required by Labor Law 195(1)(a),
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5. 'I
SlXTB'
35. Failure by Defendant UASCS to fully comply with Labor Law § 195(1) entitles
Plaintiff to civil action damages of $5,000 pursuant to Labor Law §198(1-B) plus unpaid wages;
plus liquated damages as provided by statute; plus attorney fees, pre-judgment interest and costs
pursuant to Labor Law §198(1)(a).
FIFTH CAUSE OF ACTION
Violation of Labor Law§ 193
36. Plaintiff repeats and realleges paragraphs 1 through 28 stated above and
incorporates them herein as if fully set forth.
37. Between August 2013 and June 2015, Defendant UASCS violated Labor Law
§193 by deducting $9,466.81 from Plaintiff's wages without Plaintiff's express authorization.
38. The violations of Labor Law § 193 by Defendant UASCS against the Plaintiff
entitle the Plaintiff to the remedies set forth in Labor Law § 198(1)(a).
S1XTH CAUSE OF ACTION
Violation of Labor Law§ 215(1)(a)
39. Plaintiff repeats and realleges paragraphs 1 through 31 stated above and
incorporates them herein as if fully set forth.
40. The refusal by Defendant UASCS to renew the Plaintiff's employment contract in
June 2015, was a discriminatory penalty or discharge as defined by Labor Law§ 215(1)(a)
because Defendant UASCS's sole purpose and intent in denying Plaintiff his renewal of
employment was to punish or penalize him for complaining about an illegal act or series of
illegal acts by Defendant UASCS.
41. The violation of Labor Law § 215 by Defendant UASCS entitles the Plaintiff to
back pay; front pay; liquidated damages; costs; reasonable attorney's fees and prejudgment
interest.
WHEREFORE, Plaintiff seeks Judgment against Defendant as follows:
a. On the First Cause of Action, compensatory damages of $2,820 plus liquidated
damages equal to 100% of the unpaid wages or $2,820; plus attorney's fees and costs incurred
herein;
b. On the Second Cause of Action, Judgment for $9,466.81 plus liquidated damages
equal to 100% of the amount of Plaintiff's unpaid wages salary and or overtime compensation,
plus attorney's fees, costs and prejudgment interest;
c. On the Third Cause of Action, Judgment for $6,646.81 plus liquidated damages
.equal to 1000/0 of that amount plus attorney'.s fees.and.costs,- plus punitive damages.
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6. d. On the Fourth Cause of Action, Judgment for $6,646.81 plus costs of $5,000, plus
attorney's fees, plus costs incurred herein plus prejudgment interest.
e. On the Fifth Cause of Action, Judgment for $6,646.81 plus costs of $5,000, plus
attorney's fees, plus costs incurred herein, plus prejudgment interest.
f. On the Sixth Cause of Action, Judgment in an amount to be determined by the
Court after jury trial for back pay; front pay; liquidated damages; costs; reasonable attorney's
fees and prejudgment interest.
March 2018
David G. boldlSasoldbas
Attorney for Plaintiff
'185 Genesee Street, Suite 905
New York 13501Utica,
Tel. 315-724-2248
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7. FQ» ML
—
:
V E R I F I C A T I O N
STATE OF NEW YORK )
COUNTY OF ONEIDA ) ss.:
ERSIN KONKUR, being duly sworn deposes and states, that I have read the foregoing
Verified Complaint and I know the contents thereof; the same is true to the extent of my
knowledge, except as to the matters therein stated to be alleged on information and belief, and as
to those matters I believe it to be true.
ERSIN KONKUR
Swo to before me this
day of oh, 2018.
Notary
PiffÏc-
County of: Oneida
DAVIDG.GOLDBAS
Notafy Public in the State of New Yofk
inted In onelda County
AP
g. No. 01G04933334
Nly
Contmission Ettptresdttiy ao,2g
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