Soner Tarim's (Unity School Services) motion to dismiss, (not granted) Mr. Tarim has a loose relationship with the truth and reckless disregard for the future of Washington County Schools. http://www.woodlandprep.blogspot.com http://www.stopwoodlandprep.com

1. AlaFile E-Notice
To: LOPER THOMAS MATTHEW
tloper@loperlawllc.com
65-CV-2019-900064.00
Judge: GAINES C MCCORQUODALE
NOTICE OF ELECTRONIC FILING
IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ALABAMA
The following matter was FILED on 9/9/2019 7:24:21 PM
KRISTA WILSON ET AL V. SONER TARIM ET AL
65-CV-2019-900064.00
MOTION TO DISMISS PURSUANT TO RULE 12(B)
Notice Date: 9/9/2019 7:24:21 PM
[Filer: WEBSTER WILLIAM HOUSTON]
VALERIE KNAPP
CIRCUIT COURT CLERK
WASHINGTON COUNTY, ALABAMA
PO BOX 548
CHATOM, AL, 36518
251-847-2239
valerie.knapp@alacourt.gov
45 COURT STREET
D001 TARIM SONER
D002 UNITY SCHOOL SERVICES

2. Motion to Intervene ($297.00)
Oral Arguments Requested
Pendente Lite
CV201990006400
9/9/2019 7:18:16 PM
0
D001 - TARIM SONER
D002 - UNITY SCHOOL SERVICES
Local Court Costs $
*Motion fees are enumerated in §12-19-71(a). Fees
pursuant to Local Act are not included. Please contact the
Clerk of the Court regarding applicable local fees.
**Motions titled 'Motion to Dismiss' that are not pursuant to Rule 12(b) and are in fact Motions for Summary Judgments are subject to filing fee.
*This Cover Sheet must be completed and submitted to the Clerk of Court upon the filing of any motion. Each motion should contain a separate Cover Sheet.
($50.00)pursuant to Rule
(Subject to Filing Fee)pursuant to Rule
Other
Withdraw
Vacate or Modify
Supplement to Pending Motion
Strike
Stay
Special Practice in Alabama
Sever
Sanctions
Release from Stay of Execution
Quash
Protective Order
Preliminary Injunction
Plaintiff's Motion to Dismiss
Objection of Exemptions Claimed
New Trial
Motion to Dismiss pursuant to Rule 12(b)
More Definite Statement
Joinder
In Limine
Extension of Time
Disburse Funds
Judgment as a Matter of Law (during Trial)
Designate a Mediator
Deposition
Continue
Consolidation
Compel
Change of Venue/Transfer
Amend
Add Party
Other
Motion to Dismiss, or in the Alternative
SummaryJudgment($50.00)
Judgment on the Pleadings ($50.00)
Renewed Dispositive Motion(Summary
Judgment,Judgment on the Pleadings, or other
DispositiveMotion not pursuant to Rule 12(b)) ($50.00)
Summary Judgment pursuant to Rule 56($50.00)
Joinder in Other Party's Dispositive Motion
(i.e.Summary Judgment, Judgment on the Pleadings,
orother Dispositive Motion not pursuant to Rule 12(b))
($50.00)
Default Judgment ($50.00)
Motions Not Requiring FeeMotions Requiring Fee
TYPE OF MOTION
WEB030
MONTGOMERY, AL 36104
105 TALLAPOOSA STREET, SUITE 101
WILLIAM H. WEBSTER
Attorney Bar No.:
Name, Address, and Telephone No. of Attorney or Party. If Not Represented.
Name of Filing Party:
CIVIL MOTION COVER SHEET
KRISTA WILSON ET AL V. SONER TARIM ET AL
Revised 3/5/08
Circuit CourtDistrict Court65-WASHINGTON
Unified Judicial System
STATE OF ALABAMA Case No.
Check here if you have filed or are filing contemoraneously
with this motion an Affidavit of Substantial Hardship or if you
are filing on behalf of an agency or department of the State,
county, or municipal government. (Pursuant to §6-5-1 Code
of Alabama (1975), governmental entities are exempt from
prepayment of filing fees)
Date: Signature of Attorney or Party
/s/ WILLIAM H. WEBSTER
ELECTRONICALLY FILED
9/9/2019 7:23 PM
65-CV-2019-900064.00
CIRCUIT COURT OF
WASHINGTON COUNTY, ALABAMA
VALERIE KNAPP, CLERK
DOCUMENT 43

3. IN THE CIRCUIT COURT OF
WASHINGTON COUNTY, ALABAMA
KRISTA WILSON, et al., )
)
Plaintiffs, )
)
v. ) Case No. CV 2019-900064
)
SONER TARIM, et al., )
)
Defendants. )
MOTION TO DISMISS OF DEFENDANTS
SONER TARIM AND UNITY SCHOOL SERVICES, LLC
COME NOW Defendants Soner Tarim and UnitySchool Services, LLC (collectively, “these
Defendants”), and pursuant to Rule 12(b)(6) and 12(b)(7) of the Alabama Rules of Civil Procedure,
move this Court to dismiss Plaintiffs’ Complaint in its entirety, and as grounds, state as follows:
1. Plaintiffs’ Complaint includes four claims: (1) Defendants misrepresented and failed
to discloseto theAlabamaPublicCharterSchool Commission (“theCommission”)and theAlabama
State Department of Education (“ALSDE”) the extent of these Defendants’ involvement with
Woodland Preparatory charter school in Washington County, Alabama (“Woodland Prep”); (2)
Defendants misrepresented that there was significant communityinterest in openingacharter school
in Washington County, Alabama; (3) Defendants have advertised outside the State of Alabama to
students in Mississippi; and (4) as a result of the foregoing claims, Defendants have been improperly
authorized by the Commission, and Woodland Prep should be barred from receiving state funding
from ALSDE.
2. This Court has no subject matter jurisdiction over Plaintiffs’ claims.
Page 1 of 4
ELECTRONICALLY FILED
9/9/2019 7:23 PM
65-CV-2019-900064.00
CIRCUIT COURT OF
WASHINGTON COUNTY, ALABAMA
VALERIE KNAPP, CLERK
DOCUMENT 44

4. 3. Plaintiffs failed to follow the procedures set forth in the Alabama Administrative
Procedures Act (“AAPA”), and the matters set forth in the Complaint do not fall into any exceptions
to the requirements to strictly adhere to such procedures. Ex parte Alabama Pub. Charter Sch.
Comm’n, No. 2170150, ___ So.3d ___, 2018 WL 301330 at *1 (Ala. Civ. App. Jan. 5, 2018), LEAD
Education Foundation v. Alabama Education Association, No. 1170706, ___ So.3d ___, 2019 WL
1090680 at *5 (Ala. Mar. 8, 2019).
4. All Plaintiffs’ claims, to the extent they should have been brought at all, should have
been brought first to the attention of the Commission. Plaintiffs failed to intervene, failed to seek
rehearing or reconsideration, failed to timely appeal from the Commission’s decision, and failed to
provide proper notice of the intent to seek judicial review, all as required under the AAPA.
5. Plaintiffslackstanding(astaxpayers orotherwise)to pursuetheirclaims against these
Defendants, as they have shown no actual, real or tangible injury, no causal connection between the
injury claimed and the conduct complained of, and cannot show that their concerns could be
redressed, even by a favorable decision from this Court.
6. Plaintiffs’ claims are non-justiciable, in that they ask the Court to make declarations
regarding issues that are now moot, are abstract and not capable of redress, or which constitute an
advisory opinion.
7. Plaintiffs have failed to join indispensable parties to this litigation, to wit, the
members of the Commission and the State Superintendent of ALSDE, in that they seek to undo the
decision of the Commission to grant a Charter to Woodland Prep and they seek to bar Woodland
Prep from receiving state funds. Because Plaintiffs have failed to join these indispensable parties,
the declaration and equitable relief they seek is void, and their suit is due to be dismissed.
Page 2 of 4
DOCUMENT 44

5. 8. These Defendants adopt in full the Motion to Dismiss previously filed by the
remaining Defendants to this suit, incorporating as if fully set forth herein the terms thereof, to the
extent applicable and appropriate to the interests of these Defendants.
WHEREFORE, in light of the foregoing, these Defendants request that this Court will
DISMISS Plaintiffs’ claims in their entirety.
Respectfully submitted on this 9th
day of September, 2019.
/s/ William H. Webster
William H. Webster
Attorney for Defendants
Soner Tarim and Unity School Services, LLC
OF COUNSEL:
WEBSTER, HENRY, BRADWELL,
COHAN, SPEAGLE & DESHAZO, P.C.
105 Tallapoosa Street, Suite 101
Montgomery, Alabama 36104
Tel: 334-264-9472
Fax: 334-264-9599
will@websterhenry.com
Page 3 of 4
DOCUMENT 44

6. CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the foregoing on all counsel of record as listed
below by electronic filing or by placing a copy thereof in the United States mail, postage prepaid,
on this 9 September 2019.
Thomas M. Loper
Loper Law, LLC
452 Government Street, Suite E
Mobile, AL 36602-2320
Clinton M. Daughtrey
Victoria D. Relf
Alabama Education Association
P.O. Box 4177
Montgomery, AL 36103-4177
M. Jansen Voss
Michael A. Vercher
David L. Faulkner, Jr.
Christian & Small, LLP
505 North 20th
Street, Suite 1800
Birmingham, AL 35203
/s/ William H. Webster
Of Counsel
Page 4 of 4
DOCUMENT 44