efile.fara.gov · 2019-04-01 · empire of deceit: an lll'lestigation of the gulen charter...

40
. ' '.\ ,;:,~ : 1 _.-~r~, ~..11~? __ - ... .. r:.~:;r-, ~-r·x~-~~.€ i ~ j • E; :,..,.;.i.:,...,:.r:c;:, .:_:£; ...... ' ~-:.~~:.::::.: - _-:~-~ ;::,;: E•i t&,~f.2t1 '1__:j I -:l ·~• 1~--' ~--,,. ' .. :f~, ,N' ::i .:1' . - ~-- ,;.J ' '-'Pci!.i. ' I ='~1 5;;~;,ll~r ·. ·'4•., .. ·=~ it 07/27/2017 6:J,J:32 PM Quick Facts Region: Western School Names_(known as): 1> Sonoran Science Academy 1> Paragon Science Academy Total # of Schools in State: -6 charter schools open, 1 charter school!closed, 1 pre-kindergarten academy Total Student Enrollment 2015-16: 2,292' Charter Holder/Governing Board(s}: 1> Daisy Education Foundation Organized as a non-profit with 501(c) (3) status Operates 5 charter schools and 1 •pre-kindergarten academy 1> SonoranScienceAcademy-Broadway Organized as a non-profit with 501(c) {3) status Operates .1 charter school Charter :Management Services Vendor: Sonoran Schools, Inc. Regional GUlen ·Organization. Over~ight Entity: Accord Institute for Education Research Regional Sister Networks: Magnolia (CA), Coral (NV); Lotus, (CO); Beehive (UT). Attempted, Networks: Pioneer (~A); Sonoran (HI); Coral (WA)Z. Overview As of the 2016-2017 schoot year, Arizona has six GUlen Organization charter-schools in oper- ation and one pre 0 kindergarten academy. These Empire of Deceit: An 111\/estigatioo oi the GUleo Cha1ter School Network Total Revenues for the 2015-16 school year: $18,983,866 3 Network Founders: t> Nasuhi Yurt: now works at Ebru TV, a GUlenist television station in NJ t> Abdullah Yilmaz: still ·runs Daisy & Sonoran Schools. t> Turgay K0rkmaz: now serves as board president of Aiverwalk Education Foundation, the governing board: of the GUlenist Si::hootof Si::ience·and Technology (SST).charter network in Texas. t> Melin Yildirim:,later served as board member for Mokapu Stem. School, a failed GUlenist charter school in Hawaii also partnering with Accord and;Daisy. t> Ozkur Yildiz: CEO of Daisy/Sonoran, connections toiBay.Area·rechnology School (CA),.now President·of·West American Turkic Council, Director of Turkic American• Alliance; lobbied members of Hawaiian legislature to expand charter network there. t> Mehmet Argin: began as Daisy/ Sonoran principal, then became ceo·ot Daisy/Sonoran, then CEO of M8gnolia, seived on board ofMcikapu STEM School, a failed GUlenist char- ter school"in:Hawaii also partnering with Accord and Daisy. schools are overseen by the Daisy Education Foundation ("Daisy"), a non-profit governing board of directors in ~peration since 1999. Daisy Demographic information available at: http://tinyurl.com/gwa7aoc (last checked 3/24/2017) Coral Academy of Science Application that was later denied by the Washington State Charter Commission available at: http://tinyurl.com/hvytvse (last checked 211/2017). Figure includes Daisy Early Learning Academy, taken from adding the re-.ienues of both Darsy Education Corporation as well as $~A-Broadway, audits available at: http://tinyurl.com/kpumzfd (last checked 3/24/2017). lhlS l!Alt.elAI 15 DISIHIBUlED ~i AMSl[f-DAM S ~,\Rltff~', ILP Crl rlf~ALf Of lhC REPU~IIC Of IUH{fy AOUIIIONAI INfOH.IAllCN IS AVAllABlt Al !hf DCPAAll.lfN! Of 111sr1u. W~SHNr,ION, llC 07/27/2017 6: U :32 PM

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Page 1: efile.fara.gov · 2019-04-01 · Empire of Deceit: An lll'lestigation of the GUlen Charter School Network : EmpJra of Deceit: An lrnrest1gatroo of the Giilen Charter School Network

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I

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' '-'Pci!.i. ' I

='~1 5;;~;,ll~r ·. ·'4•., .. ·=~

it 07/27/2017 6:J,J:32 PM

Quick Facts

► Region: Western

► School Names_(known as):

1> Sonoran Science Academy

1> Paragon Science Academy

► Total # of Schools in State: -6 charter schools open, 1 charter school!closed, 1

pre-kindergarten academy

► Total Student Enrollment 2015-16: 2,292'

► Charter Holder/Governing Board(s}: 1> Daisy Education Foundation

Organized as a non-profit with 501(c)

(3) status

Operates 5 charter schools and 1 • pre-kindergarten academy

1> SonoranScienceAcademy-Broadway Organized as a non-profit with 501(c)

{3) status

Operates .1 charter school

► Charter :Management Services Vendor:

Sonoran Schools, Inc.

•► Regional GUlen ·Organization. Over~ight

Entity: Accord Institute for Education

Research

► Regional Sister Networks: Magnolia (CA), Coral (NV); Lotus, (CO); Beehive (UT).

Attempted, Networks: Pioneer (~A);

Sonoran (HI); Coral (WA)Z.

Overview

As of the 2016-2017 schoot year, Arizona has six GUlen Organization charter-schools in oper­

ation and one pre0kindergarten academy. These

Empire of Deceit: An 111\/estigatioo oi the GUleo Cha1ter School Network

► Total Revenues for the 2015-16 school

year: $18,983,8663

► Network Founders: t> Nasuhi Yurt: now works at Ebru TV, a

GUlenist television station in NJ

t> Abdullah Yilmaz: still ·runs Daisy & Sonoran Schools.

t> Turgay K0rkmaz: now serves as board

president of Aiverwalk Education Foundation, the governing board: of

the GUlenist Si::hootof Si::ience·and

Technology (SST).charter network in

Texas. t> Melin Yildirim:,later served as board

member for Mokapu Stem. School,

a failed GUlenist charter school in

Hawaii also partnering with Accord

and;Daisy.

t> Ozkur Yildiz: CEO of Daisy/Sonoran, connections toiBay.Area·rechnology

School (CA),.now President·of·West

American Turkic Council, Director of Turkic American• Alliance; lobbied

members of Hawaiian legislature to

expand charter network there.

t> Mehmet Argin: began as Daisy/ Sonoran principal, then became

ceo·ot Daisy/Sonoran, then CEO of

M8gnolia, seived on board ofMcikapu STEM School, a failed GUlenist char­

ter school"in:Hawaii also partnering

with Accord and Daisy.

schools are overseen by the Daisy Education Foundation ("Daisy"), a non-profit governing

board of directors in ~peration since 1999. Daisy

Demographic information available at: http://tinyurl.com/gwa7aoc (last checked 3/24/2017)

Coral Academy of Science Application that was later denied by the Washington State Charter Commission available at: http://tinyurl.com/hvytvse (last checked 211/2017).

Figure includes Daisy Early Learning Academy, taken from adding the re-.ienues of both Darsy Education Corporation as well as $~A-Broadway, audits available at: http://tinyurl.com/kpumzfd (last checked 3/24/2017).

lhlS l!Alt.elAI 15 DISIHIBUlED ~i AMSl[f-DAM S ~,\Rltff~', ILP Crl rlf~ALf Of lhC REPU~IIC Of IUH{fy AOUIIIONAI INfOH.IAllCN IS AVAllABlt Al !hf DCPAAll.lfN! Of 111sr1u. W~SHNr,ION, llC

07/27/2017 6: U :32 PM

Page 2: efile.fara.gov · 2019-04-01 · Empire of Deceit: An lll'lestigation of the GUlen Charter School Network : EmpJra of Deceit: An lrnrest1gatroo of the Giilen Charter School Network

I

Received by NSD/FARA Registration Unit 07/27/2017 6: 11 :32 PM Empire of Decdl: An lnvestiga!100 o1 !he Gillen Cnarter School NelWOI~ Emptni of Decatl: An lnvestigauoo of !he GU!en Charter School Ne!WO(k

e> Renai Shaykhutdlnov: Board Member, .Palm Beach •Science, Inc.

(FL); Board President, Riverside Science, lnc.-(FL);>Presenter at mul­tiple GUlen Conferences; Author of articles regarding Gulen and Education; Presenter for The At1antic Institute.•

e> AkH Aydin: Founding Board Member,

River City Education Services, Inc. (FL); Director, Istanbul Cultural Center of Jacksonville (FL); Director, Amity

Turkish Cultural Center (FL); Board Member, Green·charter School,(SC);

Presidert of the Atlantic Institute of South Carolina (SC).b

e> Selcuk Bilyukaaarac: lncorporator, Founding Board Member, River City EducationiServices, Inc. (FL); Public

Relations Director, River City Science

Overview

As of the 2016-2017 schOOI year, FIOrida has 12 charter· schools within· the GUien- Organization.

Unlike other states, 1FIOrida has numerous small Gulen charter.networks across-the state,

ranging from one to four schools in size. While

each of these networks.is controlled:by its.own

governing board, giving the ~ppearance that these networks are separate, these networks

share the same vendors, founders, and charter

Academy (Fl); Chief of Public Affairs and Government Relations, River City Science Acadeff!y (FL).e

1> Dogan Tozoglu: Board President, Stars Edllcation Seniices (FL); Board member, Consultant, •Sweetwater Education, Inc. (FL); Founding Board:member, Palm Beach Science Academy (FL)(attempt); Petitioner, capitalCityCharterScienceAcademy (FL){Bttempt); Executive Director, River City Science Academies (FL).'

t> Mehmet Taakan: lncorporator, Discovery Education , Services, Inc. (FL); lncorporator, Universal· Education Services, Inc. (FL); Owner,

Blue Ocean construction {FL) (River City construction vendor);,Employee,

Khatib Development LLC (FL) -Gulenist L_andford entity.8

management, corporations and have connec•

tions throughout the Southeastern region of

the,Gulen OrQanization. Furthermore, based on

student enrollment and financial resources con• trolled, our research indicates that Florida is one

of the larger networks in the country.

Charter Educational Services & Resources

("CESA") is the charter man~gement organization

lnformanon gathereG from the R01icla Sec1etary of State, available al: http.//tinyurl.com/mh72fhf (last checked 6/15/2017); Conference was held Nov. 3. 2007 in San Antonio, Texas, and the conference agenda is available at: http:// tinyurl com/gt2vuJS (last checked 6/15/2017); Conference speaker hst, available at: http://tinyurlcomfkj7Y882 (last checked 6/15/2017);_Conference presentatH)n, ava~able at: http://t1nyurl.com/k!xu29d (last checked 6/15/2017). Art,c:le listing {search name), available at: http://tinyurLCO'l1/m5cfaq5 (last checked 6/15/2017).

lnformat,On taken from: G1een charter board minutes, available at: http://tinyurlcom/lp4rppx (last checked 6/15/2017); Green chaner pet1non pg 18, available a!: http://tinyurl.com/mb7sjmi. {last checked 6/15/2017); Anicie d,scussing Aydin and Amity, available at: http.//tinyurlcom/y7pQl78 (last checked 6/15/2017); Article discussing Aydin and the Atlantic Institute. ava,lable at: http://tinyurl.com/menn3mk (fast checked 6/1512017).

Information taken from: Linkedin prof,le, ava,lable at http://Myurl.com/lqyiehu (last checked 6/15/2017).

lnforn1atOn taken from: LinkeGin profile, available at: http:/lhnyurlcom/kn2ykaj; (last checked 6/15/2017); Stars Education corporate fil,ngs. available at: http://t1ny1,1rl.com/lfbv3fv (last checked 6/15/2017); Palm Beach Science Academy Petition. pg 5 http://tinyurl.com/nx6693g (last checked 6/15/2017); 2013• 14 Charter school report, available at: http://tinyurl.com/kd5c6bs (last checked 6/15/2017); Sweetwater 2010 990 fo1m. available at: http://tinyurl.com/goj3z.w3 (last checked 6/1512017)

lnformat>On taken from: Discovery Education Services. Articles of lnc01pora1ion available at: http://tinyurl.com/ml8qjeh (last checked 6/15/2017); UniverSal Education Services, corporate information available at: http://tinyurl.com/kwwpz7p (last checked 6/15/2017); R,ver City Plata LLC corporate information available at: http·//tmyurl.com/mc32ngh (last checked 6/15/2017); Khattb Development corporate information available at: http://tinyurl.com/kc.u\g5u (last checkeG 6/15/2017), Blue Oce.in Corporate !.lings, available at: http://tinyurl.com/lb5e5bs (last checked 6/15/2017)

lf,ll l1Ult~IAI IS IJl:il~l~IJT![1 Bl AMSlthLlAl,I \ P~RINE~S LL~ ON :lE11Alf 01 IHi:. RfP~~IIC QI IUR•.i~ A[JDIIIG~AI l~!OHMAIION IS ~\'AllABI EAT lht UrPAHIMeNr Of IUSIICE, WAS~l~GIO~. 0(

Received,by NSD/F ARA Registration Unit

responsible for the Southeastern region of the state average; 9.3% English language learners vs. Gulen Organization charter network. CESR 9.8% state average; 59.5% minOrity students vs.

allegedly provides additional.educational man• 60.5% state average; and.40-5% Caucasian stu·

agement services for the charter schools for a dents vs. 39.5% state average. As these numbers percentage fee of total school revenues.·On aver- indicate, the· Florida GUlen charter schools serve

a~,theFloridaGUlencharterschoolsserve41.7% a significantly smaller percentage of vulnerable

free and reduced lunch population vs. 58.7% state student populations, such as economically disad-:­average; 5.8% students with disabilities vs.:13.2% vantaged studerits and students with disabilities.

I ,School Operation' Student Demographic Authorizer Gov9n!ing EkNlrd1· •· ---------------~•~~n • . -Orlando Science Grades S:12 1.9% ELL Middle High Charter 2008-Present 36% FAL

;{0089) 2.7% SWD 2427 Lynx Lane Orlando; FL 32804

'Orlando Science iElementary ,Charter (0200) 2611 TechnoloO)'.Drive •Orlando,' FL 32804

Seminole Science Charter School

. (9236) 3580· N us · Highway 11~92 Lake · Mary, FL 32746

Osceola Scleilce Charter School (0181)

•2880 North Orange , SloSSom Trail : Kissimmee, FL 34741

River City Science Elementary Academy (1291) 7450 Beach Blvd: Jacksonville, FL 32216

, River City Science .Academ)' Innovation School (5441)

, 3251 Newell Blvd. Jacksonville, FL 32~16

River City Science Academy (120_1) 3266 Southside Blvd Jacksonville, FL 32216

· Rivei.City Science Academy at

·, Mandarin (5601) 109n·Old st. Augustine Rd.

. !acksonville, FL

Grades K-5 2012-Present

Grades K-6 2015-Present

Grades K-6 2016-Present

Grades K-5 2010-Present

Gr&des K-6 2013-Present

Grades 6·12 2007-Present

Grades K--8 2016-Present

72.8% Minority 27.2% Ce~casian

6,S'ffi'ELL 39.2% FRL :J.3%SWD

69.6% Minority 30.4% Caucasian_

2.9% ELL 39.2% FRL 8,6%SWD

54.9% Minority 45.1% caucasilin

29.39& ELL 57.7% FRL 0.9'bSWD

79.6% -Mitlority 20.4% caucasian

11.6% ELL 0.8%"FRL 3.5%SWD

42.2% Minority 57.8% Caucasian

6.2%ELL 17.6'1, FRL 5.3'J& SWD

50.1% Minority 49.9% Caucasian

6.1% ELL 7.0% FRL-6.8%SWD

42.4% Minority 57.6% Caucasian

8.5%ELL 37.8%FRL 9.6%SWD

47.6% Minority 52.4% caucasian

urange L;ounty School Board

Orange County School Board

Seminole County School Board

Osceola C0L.inty School Boerd·

Duval County ,School Board

Duval County ·School Bi>ard

Duval County School Board

Duval C0unty School Board

l~IS I.IAIHilAl 1$ Dl)l~IA~lrn Ai AMSl!OUHI ~ ~AHlflERI IIP or1BfH!+ OF !Hf Hu,uauc (I, IU~,H ADUIIIONAL IIHORI.IAIION IS AVAIi ABI! Al I Hf D1PAHll.tflH 01 lllSIICf, W~SOINf,fON. OC

07/27/2017 6: 11 :32 PM

Discovery Education

Services, Inc.

Discovery Educatioo

Services, Inc.

Discovery Education

Services, Inc.

Discovery Education

Services, Inc.

River City Educatioii.

Services, Inc,

River City EducatiOO.

Services. Inc.

River.City Education

Services, Inc.

River City Education

Services, In~-

Page 3: efile.fara.gov · 2019-04-01 · Empire of Deceit: An lll'lestigation of the GUlen Charter School Network : EmpJra of Deceit: An lrnrest1gatroo of the Giilen Charter School Network

Received byNSD/FARA Registration Unit 07/27/201,7 6:H:32 PM Empire of Deceit: An lll'lestigation of the GUlen Charter School Network : EmpJra of Deceit: An lrnrest1gatroo of the Giilen Charter School Network

. . School·

Tallahassee School Of Math & Science (1425) Formerly Stars Middle School 3434.N Monroe St· Tallahassee, FL 32303

Broward Matti-and , ~ience School ,(5038} 6101 NW 31st street

·Margate, FL 33063

Discovery Academy Of Science Charter School (North & South c.impuses) (7331)· 1380 Pinehurst Rd. Dunedin, FL 34698

•New.Springs Schools :cee57J · ,2410 E Busch Blvd: . 'f&mpa, fl 33612

Opel'8Uoi1 7_.-. .-. ·student l>enlognlptiic . .. fntOmliilon ·• · · -

Grades K·B 7.3% ELL 2015•Present 76.5% FAL***

a'.a%SWD 63.4% Minority

36.6% Caucasian

Grades K~12 ta7%·eu 2014~Present 67,7%FRL

6.6%SWD-et3% MiOOrity

19.7% Caucasian Grades K-12 0.6%EU 2013-Present 41.7% FRL

7.7%SWD 26.9% Minority

73.1% Caucasian

Grades k-a 12.1% ELL EJementary 79.4•Ji/FRL

2010-Present 7.3%.SWD Middle 83% Minority

:fon:pre~nt 17%. CalJ'?8sian,

Autf!orizer - .

Leon c_c,unty School Board

Broward Courity Schoof Board

Pinellas County School Board

HitlSborough CoUnty SchOOI

Board I

G~~ng~~1 Stars Education,

Inc.

Riverside Science, Inc.

Galaxy Education, "Inc.

· New Springs, Inc.

Closed ~•rtet Schools and Attempted Charter school Appllcatlons Riversid8 ScilJflce . Denied 2009 Broward Cou~ Riverside ScieriCe,: ~emy_8200 S:outh· School ~oard ,inc; iPalm Dr, Deerfield• · BeaC~; Fl 33~35 ·Sweetwater 2010-2013 Closed Elementary closed Alachua County Neosprings, Inc. Branch 'AC:ademy due to failing ·gradE!s;, School Board (Elementary and middle due tci financial ·Middle) insol~ency :Palm Beach Science APproved 2011; Palm Beach Palin Beach .School Dela~20·13, County School Science, Inc.

~~r_O~n~d. Boa!(_ Atlantic Science Authorized 2005, Miami-Dade Sweetwater Academy never opened Schools Education, Inc.

~Miami-Dade Science Appr~ _2010, Miami~Oade Sweetwater •Schools Delayed _2012, Schools- Education, inc.

never opene_d i Osceola Universal Denied 2006 Osceola County Univers&I Charter· School School B6ard Education

Services, Inc. Capital City Charter Application with- UtO"nCounty starSiEi::lucation

(Science Ac~my drawn 2013 ScJ'!o:_ol Boerd Servic~s, Inc.

Student demographic information was taken from the 2015·2016 school year, with the exception of those schools opened in 2016. «ELL» ind,cates English Language Learners. «FRL».indicates students receiving freEi/reduced lunch, and ~sWD> ind1tates students w1tn disabilities.• River Cfti Science Academy experienced a dramatit decrease in students eligible for free/reduced lunch between 2015-16 to 2016-17, from 48% to 7%. This decline should be investigated, Tallahassee School of Math and science experienced a dramatic decrease in students eligible for free/reduced lunch between 2015-16 to 2016-17, from 76.596 to 5896. This decline should be investig8ted.

Student enrollment and demographic information available at: http://tinyurl.com/mtzdnmw (last checked 4/19/2017)

]CIS MMEflAl IS DISTHl3CTCD 3\ A\!SIE~O•I! & PARTl'l'.RS LLP 0~ BCHAll or THC RfPUrJIIC or IUR,EY ADDITIONAL 1'1fORMAIIG~ lo AVAILABLE Al IH~ OiPARTMiNI Of IUSflCL WA',~l~GIO~. DC

Received by NSD/FARA Registration Unit

A History of Strategic Ambiguity -and Conflicting Interests

ll!e Florida· GUI en charter network· consists of several smaller charter networks that appear

,toibe Unrelated·on<iheir face, but our research indic<:'~es· that in··reality,they Share the .same founding 'board members, vendors, landlords, -and employees. Furthermore, the Florida net­woi-k shares significant oV_erlap with Gulenists, from the failed Georgia network.

The first educational foundiltion formed in- Florida was Sweetwater Education, Inc., in 2003. Di". Cengiz .Alacaci incorpoi"ated the governing board, which ~ent on to submit two charter applications for Gulenist ,charter schools in1Miami.·Both,were approved, but"nei~ -ther. opened.10 :sweetwater Education continues to:exist today, though it serves no known pur• pose at.this time. The second foundation to form was Stars1Edllcation ,Services"dnc., founded by Valcin Akin• in•2004. Akin:is one of the primary ,founders of.the Floi"ida Gulen network as he has. been involved in at IE!ast four.of the ten GUleniSt

·networks (both- attempted and established) in

Florida, including Tampa, Miami; Tallahassee, and.Orlando.

Discovery:Edi.Jcation·Services was the third •foundatior to form, incorporated ,in 2005 by Mehmet Taskan, -owner of Blue Construction. Blue·ocean Construction is the ·GUlenist-con• structiOn vendOr for-the Southeastern region:of the Gulen Organization.11 A· year later, Taskan formed -Universal EdUc8tion: Services· in Miami· with one of his fE!llow Discovery board members, Mustafa lnce.'2 River City also formed in 2006 by

:selcuk BUyuksarac. Among its~founding board ,members was Akif Abdulbasit-Aydin. Aydin.'has also wor~ed as the director of the Amity Turkish Cultural Center and the Istanbul Cultural Center, ,both.Gulenist cultui"al associations. Aydin:Iater admitted to being a : Giilenist during a radio

i~terview gi_ven after the ~attempted coup in 2916, discussed further below,.and stated that teach­ers and administrators at :River City Science Academy were. Blso GUlenists.

While.many.of theJoundations:formed from 2003-2006, the· first, school to succesSfufly open was River City Science-Academy in 1 2007. Orlando Science Charter School opened a year later in,2008, and,since-then, elE!ven,more schools opened. Only two ~ave closed down so far--:Sweetwater Branch Academy Elementary and MiddlE!. The schOOls shut dowrfdue to poor academic performance and bad financial condi· tion, classic markers for Gulen charter schools.

The Florida:Gulen charter network•is·over­seen 1by the regional charter management organizatiOn, charte"r Educational Services

·& Resources ("CESR"). CESR was formeriy known.as the Gi"ace'lnstitute, bufthe company chang~d its branding after a series of damaging 'forensic audits condUcted.by a Georgia school district revealed it to be a:sham:corpoi"ation. 13

The Fulton Science ACademies in GeO_rgia we_re investigated for periodic jnsolvency and•other .financial concerns in the:2012~2013:timeframe. The audits uncovered 811 the haHmai"ks of a Gulen charter network, including:the use of a sham· external· charter manaQement: organiza­tion, the Grace Institute. Th"e audit investigations reveciled that Grace only had two employees­one of which was a. paid administrator of the

.Fulton,ScienCe schools,-and the o_ther a part• · time:person to answer the;-phone. Despite the

fact that the" Fulton Science schools paid Grace significant ,fees eaC:h year, Grace did not in fact;provide any services of·value:and consti­tuted·a-conflict of intefest:due.to-.their.shared employee, Ali Ozer.

Sweetwater corporate filings. available at: http:/ /tinyurl.com/kjq6hsb (last checked 6/15/2017)

Discovery Education Seri.rices, Articles of lncOd'poration available at: http://tinyurl.com/ml8qJeh (last checked 6/15/2017),

Universal Education Services, corporate information available at: http:/ /tinyurl.com/kwwpz7p (last checked 6/15/2017),

For more information, see the Georgia profile,

lHIS IJ~IEKIAL IS DISIRltiUHD gy Ar.lSIEROAM & PHl'!ER', llP ON ~•HAif Of [Hf HPlibllC Of IUK•,iY ,IOUI I 10.~Al l~fOHMAl ION IS AVAILABL f Al IH '. Ut P~ k l'ilf:N I GI JU',I ICC, WASHl"IG 10'1. DC.

07/27/2017 6:11:32 PM

Page 4: efile.fara.gov · 2019-04-01 · Empire of Deceit: An lll'lestigation of the GUlen Charter School Network : EmpJra of Deceit: An lrnrest1gatroo of the Giilen Charter School Network

Received.by NSD/FARA Registration Unit 07/27/2017 6:11:32 PM Empire of Deceit: An lnvest1gahoo of the GUI en Charter School Network

After the.Fulton Science (GA} school$ were non-renewed due to numerous issues, the Grace Institute changect'its name to·CESR and continued to provide "services" to ,its FIOrida customers from its Atlanta and Jacksonville offic­es.,. CESR was incorporated in Florida:by Avni COkavci, the.former principal.of Fulton·Science Academy High School (formerly TEACH}.'~ Many

cif the H-1B teachers and·employees,utilized by the Fulton Science.{GA) schools were ultimately dispersed throughouMhe Florida Gulen char7 ter schools, though the two. networks shared employees prior to,that, as ~II. For example, Murat Cetin, Principal of the Fulton Science elementary school, is currently·Principal of the Osceola Science Charter Sc~ool.115

A Sample of'Board Member/Employee Overlap Across the Florida Network"

Elvan Aktas Sweetwater River City Education Education Services 2013-Present 2005-07

Mehmet Taskan Discovery Universai 'Education Education Services 2006-12

Servlce52005~12

Mustafa Ince Discovery Universal Education Education Services 2006-12

Services 2005-06

Valcin Akin Stars Education Employed by Sweetwater New Springs· Inc. Servtces Inc. Discovery.Education 'Education Inc. 2014~Present 200472014 Services, Inc, (non~v!Jllng advi7

2007-Present sor) 20~-10

Dogan Tozoglu Stars Education Sweetwater-Education Palm Beach Employed Services, Inc. Inc. (non-voting Science Inc. by River City 2006-Present advisor) (only in petition Education

2009-10 2010) Services Inc. 2010:Present

Aenat Shaykhutdinov Riverside· Science, P81m Beach Science inc. Inc.

2008-Present 2010-13

For an archived vers,on of the Grace Sc~s website as of February 2010. list.ng member schools. see: hnp://linyurl. com/n2racps {last checked 6/1512017)

GA Department of Education report, listing TEACH informat,on, available at: http://tinyurl.com/kgpv22v (last checked 6/15/2017)

Information taken from: Orlando Science ij511ng, available at: http://tinyurl.com/~ptbng (last checked 6/15/2017); and Linkedin profile, available at: http://t1nyurl.com/lp6m7dy (last checked 6/15/2017),

Information gathered from corporate filings fo1 each of the FJorida Giilen charter foundation boards

INIS \!Altl-lAl 15 OISIH!a'.JIEO BY M!~TEAOA\I & PA~l~EVi LLP 0~ 8tHAlf ar !Ht fiEPUBllC Cf !UR,.O ~UOI JIONAL IIH 01 IIA 1!011 IS A'iAIL A Bl C Al I Hf" l\E PA~ r~, EN [ nr JU>T ICl. \\iAShlNG!Oll, oc

Received-by NSD/FARA Registration,Unit

EmplreatDeceH: An lnvest1gat1on of the GUI en Charter School Network

Inter-Entity Lending Practices

Our investigation.would suggest that charter schools within the GUlen Organization and their ¥endors.engage.in frequent inter-entity lending practices, ranging from school to school, from employees to the school. board.members to the school, and even from.vendors to the school, a known warning sign for-money'laundering.11 In 2015-16, both River City Science Elementary and River City Science Innovation owed River• City Science Academy money-$23,726 and $53,834 respectively." All:of the River·City schOOls are under the same governing board, meaning the board owes fiduciary duties of care and k>yalty to each of its schools. Shuffling, funds between schools, particularly• when River ·City Science Academy operated at a deficit net position for the same year, could be indicative of a breach of fiduciary duty to the school.

Similarly indicative of the.poor financial con­ditions seen throughou,t charter networks in the Gulen Organization, Broward Math and Science borrowed $19,500 from its principal Ali Gum us in 2015-16, who earned $60,000 that year in salary, to cover operating costs. The school also bor­rowed $83,000 from one-to~two unnamed board members in the same year as well: as $15,000 from an unnamed individual. This is not the first time Broward·Math and'Science has taken out loans-itsiprincipal loaned it $27,000 the year before, and board·member and:Florida founder,

Renat Shaykhutdinov loaned it $14,800'prior to that.20

Tallahassee School of · Math and ScH!nce also received a significant loan $45,000 from its board member, Zeki Akdemir in 2014.21

The Anti-Maney Laundering and Countering Terrorist Financing Guidance to accompany the federal arid intemat,onal legislation hst numerous unusual transactions made with little to no justification between affiliated entities as warning signs. See Guidance at http://tinyurlcom/zb56xe1 (last checked 6/1512017)

See 2016 aud,ts for each school.

'" lnformat10n taken from the 2014-15 audit, available at: http.//lmy,Jrl.com/jZyfbul {last checked 6/15/2017); and 990 tax documemation .

See the 2014 990 form for Stars Education, Inc

fl-IS \IAl[AIA\ IS OIS!RldUffO Bl A,\ISl!f,DAY ~ P~F11~ff\S llP 0~ 8f~I.Lf Of fHi H~U3LIC Of IUhEY APDIIIO'i,\\ IIIIOH'-IATION IS AVAllAOlt II fHf DiPAHl\lf'H Of IUSIICf WAS~1r1GTOr( DC

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Real Estate

Our interpretation of the evidence suggests that ,one of the most significant :Profit cen­ters for the Gi.ilen Organization,is through real estate. This property financing scheme has been replicated throughout the country-in fact,•Yahap Uysal,.a-board.member of Concept Schools/2 wrcite ancfpresented 0an article enti­tled «GUlen -Movement and School• Financing» at the Third Annual Conference on Islam, in the-Contemporary World: The Fethullah GUlen Movement in Thought and,Practice.23 :GUlenists throughout the country attended and presented, including the Greater Texas regi_on's founder Alp Aslandogan,2' as well as Aorida's own Renat Shaykhutdinov, board member for Broward Math and,Science and Petitioner for the failed Palm Beach Science School.

Like other vendor relationships, the GUlen Organization profits off of· requiring its charter schools to rent or buy property from Gi.llenists, usually at exorbitant-prices. Our research leads to the conclusion t.hat the Gulenists gener­ally provide kickbacks to the overall Gulen Orgariization in return for the· business, all at the expense of the charter school's public funds. The scheme extends.to the use of affiliated GUlenist construction companies to renovate the charter schools' ,properties, who appear to-overcharge and underperform with impun~.

tn Aorida,.by far the most egregious example of the Gulen Organization's real:estate scheme

concerns the acquisition of the River City Science, Academy's 7555 and ?605 Beach ·Boulevard property in"Jacksonville, F.L In 2010. Vazan Khatib purchased the 7555 property at a foreclosure auc­tion fo, $100.00 through his company, River City ~laze LLC, which also employs Mehmet Taskan.~ Over the next three years, Khatib·and,Taskan pro­

cured numerous building permits for construction and renovation:to,update the property for River City Scierice Academy mentioned by name as early as 2011. Khatibspent$1,583,5000 in construc­tion and acquisition costs on the 7555 property.2G

Khatib and-Taskan often Ii ired ,Taskari's own com­pany, Blue 10cean Construction, to perform the renovations. In 2014, River. City Science Academy took over the payment for the building permits for­the :property, despite:not officiaUy owning:it'yei. ln 2015,-River City Science Academy purchased the.building from•Khatib for $12,509,500 with the proceeds of bond financing, discussed below.

The $12.5 million purchase also included the 7605 property next door, which Khatib pur­chased in 2012·for $340,000.2' 1From 2012-2014, this property was renovated to include a, gym constructed by Blue Ocean Construction. ~a While­Khatib technically owned the 7605 property until 2ms, River City,Science Academy paid for the majority of the construction-costs from 2012-14. A-brief.rundown of the parties' costs and prof~ its r~garding_the 7555_property ("7555") and the 7605 property ("7605") is as follows:

"' See Concept Schools 990 tax form, available at: http.//tinyurlcom/h5yvjlt (last checked 6/15/2017)

" Conference was held Nov. 3, 2007 in San Antonio, Texas. and the conference ager,da is available at: http./ltinyurl.coml gt2vujs (last checked 6/15/2017)

i, See Texas profile for more mformat1on about Alp Aslandogan.

" Foreclowre information available at: http://tinyurl.com/mzxg2u7 {last checked 6/15/2017); Property history available at http //tinyurlcom/leqctfa (last checked 6/15/2017): and Rive, City Plaza LLC corporate information availaole at: http:// tfnyurl.com/mc32ngh (last checked 6/15/2017); Khatib Development corporate information avaclable at: http://t1nyurl com/kczqg5u (last checlo:ed 6/15/2017)

"" This figure IS !he S100 sale price plus the aggregate total of fees listed in the permits. available at: http.//t,nyurlcom/ mv7k7au (last checked 5/15/2017).

" Property history, available at: http://tinyurl.com/kusft9s (last checked 6/15/2017)

'" All information regarding the construction costs is available through searching the building permit database, available at: http;//linyurlcom/mv7k7au (last checked 6/15/2017)

1~13 ~Ui:f,l•l IS OISl~IBUIED ~y UISJCFDAM ~ PHI Iii Fl\ llP 0~ '!E~Alf Of l~f fifPUBIIC Of ICR•O ~ OUII ICN•t 1•!fCS \ll,TIOr4 IS •VAi\ A~I: •t I"' OE P~Rll.li rn Cl Jd~ I IC.. mS~ING.ION, oc

Received by NSD/F ARA Registration Unit

Empire of Deceit: An lrwestigation of the GiHen Charter School Network

y,;.- -Khatib& Tnkan .-·RIYor CltJ Plaza, UC; 790118eacll

Boillnlllrd Li.c

Tnkln- Blue Ocean AIYer ctt, Sclence'AcademJ

2010 • $100 to purchase 7555 building • $115,000 for roof ~pair

---: 20ft -$910.000. fOI' •improvements" +$910,000 "improvements• paid •$2,000 for 7555 tree removal·

for 7555 ,by Khatib in cash for 7555 -$73,500 plumbing foi 7555 +$14,500 tenCS for 7555 •$15.000 wiring for 7555 +$8.500 canopies for 7555 •$25,000 electrical ·tor 7555 --$55,000 $pririkler system for 7555 •$50,000 sprinkler system for 7555 •$155.000 duct work for 7565 -$800 tree rell1oval for 7556 -$14,500 fence for 7555 -$8,500 canopies for ,7555 -'1,200 fe~ lighting _for 7555

2012 •$340,000 purchase for 7605 •$89,000 electrical for 7555 •$6,000 sprinklers for 7555 •$5,000 electrical for 7555 •$24,500 drains for 7555

•ZOU •$8,500. site prep for 7555 ·SS,500 site work for 7555

2014

:2011

•$2,380 demo building for 7605 -$85,500 landscaping for 7605

•$2,858 sign for 7605 -$2,858 sign for 7605 +s12,5o9,SOO for sale ol 7555 aild 7605'to'River City Science Academy

Total = $1,998,696 spent total

= .$12,509,500 gained = $10,510,804 net profit

+$8.500 site work for 7555

+ 2,380 demo building for 7605 +$964,595 gym construction for 7605

+$7855 gym canopy for.7605

=$1.916,130 profit

·$30,949 LED sign for 7555 paid in cash •$98,000 duct work for 7605 •SS.000 security for 7605 •$16,000 sprinkler for 7605 •$9,000 electrical for 7605 •$33,500 drains for 7605 -$6,000 sprinkler.for 7605

-$964,595 gym construction for 7605 in cash

-S12,509,500 purchase 7555 and

7605 •$50 1£0 sign bulbs ·$30;949 LED sigri for 7555 -$1000 lighting fo_r 7605

=$1.168,044 spent before awning either building =$13,678,594 spent total =$29,326,656 ultimate cost due to bond financing

[~IS •H!EhlA( IS Ol'i!f13Llfi0 g1 ~~~JfhOII.I ~ fllil~CF', UP G!i DE"III o, ,~, ~EP~auc Cf TUF•fl ADDIIIO~Al ll!IOl<i,t~IIOI! IS ilVAllABlt Al H,f UiPM-1\ICII! Cf ILlSIICE. WASW!G!O~, DC

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Received by NSD/FARA Registration Unit 07/27/2017 6:11:32 PM EmpirsotDecdt: An lmestigalion of the GUI en Cha1ter School Network

As·the chart demonstrates, both•Khatib and

Taskan profited extensively off of these property

transactions with1River City·Science Academy.

Ultimately, River City Science Academy will spend_' $29.3 million due to the bond debt it incurred to pay Khatib's $12.5 million price; Taskan was-listed,as both the:property owner and the·contractor:on numerous:building per­mits as he routinely hired his own cOmpany Blue Ocean Construction for work on behalf of Khatib

and River,City Science.Academy. Both'Khatib

and Taskan have connections thi'oughout the GUlen Organization. Khatib sits on the board of

directors for the Atlantic Institute of Jacksonville,

a GUlenist cultural association which hosts dialogue dinners and trips to Turkey for local pol­

iticians. Khatib's company Pelham oaks PJaza

LLC is also the laildlord for a. Gulenist char­

ter school in South Carolina, GREEN Charter School}'" Taskan's Blue Ocean Construction

is the preferred construction vendor for the

Southeastern region of the GUlen Organization. Blue Ocean continues to do numerous .jobs for

GUlenist charter schools throughoufFlorida and

the Southeastern region. Blue Ocean also uses the same H-1B attorneys as the rest of the Giilen

Organization.10

Taskan _ also has other concerning connec­

tions to the, Florida sch001s-he served on the

founding board of Discovery Education Services,

which oversees Orlando Science, Osceola Science, and SeminOle Science.'' He also.incor­

porated Universal Education Services with many

of the-same- indivjduals "°om Discovery, which

submitted an application.for a:Gi.llenist:charter school in Osceola that was not aJ?proved.32 As is

common.with Gi.ltenist '!l"endors, Taskan served first as:a_school:creator that he.then.later prof­

ited as a vendor.

The other schools that are-implicated in· the

Gulen Organization's· real estate scheme are Seminole ·Science and Tallahassee Math and

Science. The school~ renHheir Properties from 5M Associates and 3434 Monroe Holdings

respectivety, both of which are owned by Naeem Haider."-' Haider sits on the board for the Atlantic

lnstitute'alOngside Yazan Khatib in Jacksonville.

The rent information is only available for the year

2015-2016, which was the_ first year each school

began renting from Haider. Seminole Science paid between $178,000- $215,000 that year, and

Tallahassee Math.and Science paid $210,000-$240,235,:u Using Ohio as a comparator, the rent

prices should be- closely scrutinized for later years as the GUlenist landlord entities in Ohio

dOubled, tripled, and in one case, quadrupled

rent each year.35

Orlando Science also rents an·outdoor recre­ation area from, Discovery Educa~ion Properties

at Technology, LLC, a related party under

common·control. lil 2015-16; it paid itself$78,000 in rent. 35 Executive,Dir!!ctor Yalcin:Akin is listed

as the owner.of this related for~profit entity, More

infoi"mation is needed to determine whether this

is an appropriate relationship.

,. GREEN charter school minutes, available at: htlp /ltinyurl.com/lwuodat (last checked 6/15/2017).

"' Blue Ocean uses Atlorney Remzi Kulen, see Abuse of the H-1B Program section.

Discovery Education Services Articles of Incorporation. available at: http·//linyurlcom/mlBqjeh {last checked 6/15/2017)

" Universal Educat10n Services, corporate information available at: http://tinyurl.com/kwwpz7p (last checked 6/15/2017) .

.., Corporate information for 5M Associates. available at: htt,o://tinyurl.com/k3a6pl2 (last checked 6/15/2017); 3434 Monroe Holdings, available at: http://tinyurlcomtld38apf (last checiled 6/15/2017).

.. Figures taken ftom the 2016 audits and 2016 accountab1l1ty reports for each school, which for some reason, hst d1~erent amounts for leases paid. available at: http://tinyurl.com/m9ldgth (last checked 6/15/2017)

'.. See Ohio profile for more detail 30 See 2016 aud,t, availaole at: availaole at: http://tinyur!com/m9ldgth (last checked 6/15/2017)

!HIS IH!f~IAI IS UISl~l~UlfO 81 AMSlt~~AM & PAiil•HJ<S 11~0~8Ef-~Lf Gf lhi AfPU8!1CO! TU~•!Y. A(lOI l HHlAI 1•1; O~MA I 101·1 IS AVAi\ ~Bl l AT I Hf UlPA~l Mf N l 01 IUSI ICC, WASHI~ GlO~. DC

Received by NSD/FARA Registration Unit

Bond Financing,

To date, the River City Science Academy gov­

erning; board is the ori"ly• Florida networ~ ihat has:secured bond 1financing,'ln,2015;-the board

received three bond issuances in the cumulative

amount of $14.4 mitlion from the Capital Trust

Agency.3' The bonds financed the acquisition of the properties owned by River ·CitY Plaza,

LLC, discussed above in the real estate sec­

tion. According to.the bond statement, the River City board entered into-a purchase.agreemerit with khatib·of•River City Plaza on OctOber 24,

&n,treotDeceft: An 1mes1igat1on of the GL!len Charter School Network

2014,311 ·8IthouQh the sale•Was nOt.fiilalized;until

2015; An appraisal conducted in 2015 stated-the

value of the property as $12 million, but notably, this included the gym, Which River City Science

Academy had just paid $1 million to renovate. The amounts paid by River City Science Academy

were nOt credited:10,the purchase price, how­

ever, further underscoring the bad deal ·the schools received compared to the profit of the

GUlenist landlord entity.

Excessive use of the H-1B Visa Program

Like other GU!en Organization charter net­

works, the Florida GUlet1 charter schools utilize the H-1B visa program to immigrate·large num­

bers of Turkish GUlenists into the United:States

for eJf!ployment in the schools and ne!work. The Florida network filed·at•least-195 H:1B applica­

tions from 2001-2016, while CESA itself filed e H-1B applications during the.same.period."

While the GUlen . Organization typically states that these H~1Bs are only to fill shortage·areas­

for math and,science teachers, these-applica­"tions were filed for such positions as:,principel,

curriculum coordinator, business operations

specialist, instructional coordinator, business manager, and Science Olympiad coordinators.

Stars,Education Services has.recently been

sued for employment discrimination as of December 2016,411

Florida's Gulen charter schools use the

same immigration attomeys to file and process their' H-18 applications as other known· Gulen

Organization charter networks, vendors, and

cultur!:1I associations,, indicating once again•the

existence of an overall network. For example:

► Cherie Cookorlnla: the Florida network (including: Discovery, River City, New

Sj:Jrings, Neosprings, Stars Edllcation, Galaxy), used Cookorinis, a Georgia­

based attorney· to file numerous H-1B

applications.41 Cookorinis also-filed aP,pli­

cations for: E> Fulton Science {GA}

t>- Chesapeake Lighthouse Foundation

(MD). E> lriad Math and Science {NC)

t>- Charter Educational Services & Resources (GA, FL)

E> Grace Institute (GA, FL)

" Bond statements available at http://tinyurl.com/meh94uv {last checked 6/15/2017).

'" Bond olkia:I statement, pg 10. ava,lable al: http://:inyurlcom/k5pb7cf (last checl<ed 6/15/2017).

"' See MyVisa.lobs.com for each goveming board"s information. 1) Discovery Edl.lCation Services 61 H'.1Bs, available_ at: http.l/tinyurl.ccim/kcf21af (last checked 6/15/2017); 2) River C,ty Education Services 80 H-18s. available at: http://tinyurl. com/lb6kgyll (fast checked 6/15/2017); 3) Stars Education Services1a H-1Bs. available at: http://tinyurlcom/m6wme9m (last checked 6/15/2017); 4) Riverside Science 3 H·1Bs, available st: http.//tifl)'t.lrlcom/mcJzfaf (last checked 6/15/2017); 5) Galaxy Education, 5 H-1Bs, available at: htlp.//tmyurl.com/k5q5v44 (last checked 6/15/2017); 6) New Springs Inc. 19 H-1Bs, a ... ailable at: http://tinyurl.com/kai429x (last checked 6/15/2017); 7) Sweetwater Education 2 H-1Bs, available at: http://tinyurt.com/n5zdb2n (last checked 6/15/2017); 8) Neosprings, Inc. 12 H-lBs a:vailable at: http://tinyurl com/ldm.52 (last checked 6/15/2017) and http·//tinyurl.com/kr6wa2w (last checked 6/15/2017)

.. COurt docket, available at: http·//t,nyur!com/m244vxw (last checked 6/15/2017).

List of entities represented by Chefie Cookorinis. available B1: http.//1inyurl.com/m4e6cgl (last checked 6/15/2017).

IJ<ISi.tAHflAl l~DISJ;a13~JEO :Ji AMSltfD.IM ~ tAklN:liS llP 011 H(11ALI ~I l~t f;cJ·U~IIC Gf IU~•E! AD~lll8~AI l~fOhMAIIO~ IS A\'AllA'H[ Al l~f OCF~HIIIIEIII 01 l'J511CC. WASHl~GIO~. UI:

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Received by NSD/FARA Registration Unit 07/27/2017 6: 11 :32 PM Emplreol Deceit: An lnvestiga11on of the Gillen Charter Schorn Network

► Rernzfl<ulitn: the Florida network:used Kulen, a New York-based. attorney, to file numerous H~1B applications.•1 Kulen also

filed applications for:

1> Orlando Culture & Dialog Center (fl) t> Blue Ocean Construction (FL) t> Fulton Science (GA}

t> Charter Educational Services & Resources (GA, FL)

Scandals and Notable Events

River City Science Academy and,Tallahassee

Math:and Science Academy both,received s!g­nificant media:attention in'the aftermath of the attempted coup.in Turkey in·2016. River City's Executive Director Dogan Tozoglu wrote a letter to Jacksonville's mayor stating that the schools had no.direct affili8tion with.Gulen or involve• ment with thecoup:0 Also, Akif Aydin, a founding board member of River City Education Services, gave a forty•minute radio interview during whiCh he.spoke extensively of the GOien Movement, Gulen charter schools, and Gulen•s·suspected

role in the attempted coup." Though Aydin was interviewed due·to his involvement•with River City Science Academy, he spoke openly and on behalf of.Gi.ilen'charter sChools throughout the country. Some of his more interesting comments were as follows:

► Aydin stated thaMhere .was "no doubt" that the charter schools often-referred to as Gi.ilen charter schools· were founded by Turkish-individuals inspired by Gi.ilen. He himself is a follower of Gi.ilen.

► If the Turkish teachers on H·1B visas choose to donate their money from their salaries, that's a personal choice. muCh like donating to a local church. e> Commentary: What's fascinat•

ing .about this remark from Aydin was that the interviewer ,had not

t> ConceptSChoolS(OH, IL, IN;'MliMN) 1> Pioneer (MA)

t> Niagara Foundation (IL)

t> Yourig Scholars (PA) t> Gulen's home, the Golden Generation

Workshop Center {PA)

1> Academy of Science, Syracuse, Buffalo (NY)

1> Arts & Science, Bergen, Passaic (NJ)

brouQht·up the tuzuk paymerits at all during the interview. Aydin. offered this justification apropos of noth· ing. Whistleblower testimony from several former Gulenist employees makes it clear -thanhese payments are not optional.

► Aydin referred to the concerns. against Gi.ilen charter schools around the country for·.oyerpayments •to Gi.ilenist;vendors as· ·slandering." which had never been proven. e> Commentary: Again, Aydin was

defending Gi.ilen charter schools nationally, rather than discussing his,own school River City Science Academy.

► Aydin stated that, to his,knowledge, the teachers hired on H·1Bvisas were only for harcHo•fill math and- science :positions around.the country in scho0ls founded, by Turkish individuals inspired by_ Gi.ilen. e> Commentary: This is in direct con-

tradiction to the H·1B applications themselves, which demonstrate the positions hired are for positions-.that help the Gi.ilen Organization mliin• tain financial control and secrecy over the use of school'funds, such es·eccoLintants,·busiriess managers, and administrators.

" list of entities represented by Remzi Kulen, available at http./ /tinyurl.com/gptw•Sx (last checked 6/15/2017)

., Tozoglu letter, avaitable at: http://tmyurl.com/mtmr65g (last checked 6/15/2017)

"' A'p'din interview, available at: http://t,nyurlcom/j2a7b8q (last checked 6/15/2017).

iris IIAICH~I IS i.llSl~l8Ul!O di Jl,ISE~OAM i, p~~r~:rs llPO'l 'lihAlf Of IH F.:f~allC Of IUfh;, ~OOl!IO'l'l l'HCiH,!AIIO'l IS A~Al!ASI: •1111; o,n~f\,lf'd Qi J~Slltc. r1isr1•1G10'I, oc

Received'by NSD/FARA Registration Unit

Notable Turkish Vendors

Charter Educational Servlcea & R8sourcee '"CESR': formertj 1knoWII as Grace ln1ittvte: CESA is a smaller•scale charter management organization that over~ sees the Southeastern region of the Gulen Organization, including the Rorida ne~orks and the failed Fulton Science (GA) network. CESA is incoi'poreted by former FultOn Scieiice {GA) administrator, Avni,Cokavci, and receives a per-head amount in fees:from each of its customer charter schools, allegedIy:for curric­ular support, professional deyelopment, and student information management systems,.fn Florida, Ri'ler City Science schoi:>Js, Tallahassee School•of Math and Science, Orlando Science Schools, Seminole •Science, Broward Math and Science, Osceola Science, New Springs Schools, Discovery Academy o~ Science all use CESR for student information-services, as well as Fulton Si::ience pri'late school (GA)'and Green Charter School (SC).4~

Empire of Deceit: An lnvestiga11on of the GLilen Chaner School Network

Blue Ocean Construction: Blue Ocean Construction is the pt'eferred construction vendor for the Southeastern ·region. Like its charter'customers, Blue Ocean also depends on the H-1B program. Numerous schools through• out the Rorida Gi.ilen charter network and the, Southeastern region have utilized Blue Ocean for construction work. Mf!'hmet Taskan, the owner,of Blue Construction, also incorporated two Gulenist chart~r '•boards in Florida,: Discovery: Education Services and Universal EdLication Services:•11

E~ete Funding:,Several of.the Florida net~ works have received federal· E•Rate funds, but the information regarding the vendors chosen is unavailable. In light of the alleged,E·Rate fund~ ing fraud that is under investiQation by federal authorities throughout the Gulen Organization, the vendors chosen by the Florida networks should be examined to determine whether they are controlled by related Gi.ilenist parties.

Glllenist Cultural Foundations

The Atlantic Institute: The Atlantic liistitute has branches throughout the Southeast·region. It-promotes GUlen's teachings., and infer.faith dialogue, and two of the Rorida.Network's land• lords are currently listed on its governing board, Naeem Haider and Yazan Khatib.41 Additionally, it hosts dialogue dinners and trips to Turkey for local politicians.

Istanbul Cultural Center: The Istanbul Cultural Center has branches throughout Florida.

tt hosts Gi.ilenist inter.faith dielOQue dinners and trips to Turk.ey.49 River City •Science founding board member Akif Aydin is the former director of the Center.

Amity Turkish CUiturai Center: .The center iS a Gi.ilenist cultural center operated by·Akif A\'din, founding board member of River City· Science Academy. It provides Gi.ilenist culturiil outreach, diBlogue dinners, and trips to Turk.ey.~0

., All of the following sd'lOOI websites contafl the langllage "Powered by Charter Eoucatilnal 5efvices & Resources," evuEncirg the tie between CESR's Giilenist charter schoo customers, available at: http.//tinyurl.com/154sqwb (last dlE!Ckd 6/15/2017). http./ /tnyurl.com/mm9s22a (last checked 6/15/2017). http //tiny,Jrlcom/kofnlk4 (last checked 6/15/2017). http:/ /tinyurlcom/ krphQs (last checked 6/15/20m http:/ /tinyurl.comlk35Qx8y (last checked 6/15/2017). http-/ /tinyurlM/lke2m4c (tast checked 6/15/2017). http://l1nyurlcom/m2vKrlu (tast dlecked 6/15/2017). http.I /t,nyurl.com/lv23dcd (last checked 6/15/2017). http:// t,nyurl.com/kxth73J (last checked 6/151201,i http· //tinyurl.com/rfBc....:jJ (last checked 6/15/2017),

.. Discovery Education Services Articles of Incorporation, available at: http://tinyurl.com/ml8qjeh (last checked 6/15/2017); U11iversal Education Services, corporate information available at: http:/ /tinyurl,com/kwwpz7p (last checked 6/15/2017) .

., Fethullah Gi.ilen bio on Atlantic lnstitute's website. available at: http://tinyurl.com/mvjxmo9 (last checked 6/15/2017)

.. Board of directors, avarlable at: http://tinyurlcom/1Ke4wq (last checked 6/15/2017)

" Istanbul Cultural Center website, available at: http://tinyurl.com/1vsrwvn (last checked 6/15/2017)

'° Corporate information, available at: http.//tin~urlcom/16dgujm (last checked 6/15/2017)

'"IS ll•IHl~l ,s 01~1~1auHD Si ~l.()JHn•1.1 & PARrn;k'., uro•1 ~'"AH Of lcC ViPU3llC Of TUH,, AOOHIO'IAI I~! O~'>IAIIO'I IS Al'AII A3U: •I lc.C OCPAk!IJf~/1 01 !US llCC. WASrl'<filO~. DC

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Individuals Caught in the Giilen Organization Web

It is quite common fo, the Gulen Organization

charter networks within a:,egion to shuffle their Tlirkish H-18 visa teachers from school to school, as well as between r~gions, This-is just a small number of individuals •with these overlapping ties throughout the region, which further.demon­strates the region's interconnections. Notably, this shuffling only occurs with Turkish ef!1ployees.

► Emro Akbaba: Science Teacher, Fulton

Science Academy High School/TEACH {GA}; River City Science Principal, New Sj)ring Science Elementary and Middle-School·(FL); Prin<:ipal, Discovery Academy of Science (FC).~1

► Serkan Gunplnar: Board Member, Minnesota Math and;Science·Academy (MN);iFounding Board: President, Sirius foundation, Inc. - GUlenist cultural asso­ciation (FL); Board Member, New Springs, lnc.-(FL).~

► Yunu■ Aksu: ·Substitute teacher, Noble Academy Clevelllnd (OH); Princip.i1, Seminole:Science Charter School (FL); Principal, New Springs Schools (FL).u

► Murat_Cetin:, Principal, Fulton Sunshine Academy (GA); Principal, Osceola Science Charter: Scho0I (FL).60

► Alaaddln Akgul: Science Coach & Gifted Education consultant, CESA (Southeastern); Dean, River.c~ Science Academy (FL); Principal, River City :science Elementary (FL);. Regional Director, Science Olyrripiad (FL}; Principal, River City · Science Mandarin (FL)."

► All Ou mu■: Four,der and Superintendent, ·LISA Academy·(AR); Principal, Memphis School of Excellence (TN); Presenter, Harmony Public Schools Conference (TX); Principal, Broward. Math and Science (FL). 511

► Oun Slpahloglu: Principal, 1River City Science Academy (FL);• Pacific Technology School Orangeville {Magnolia CA)Y

Information ta Ken from: Pinellas charter schools, available at: http./ /tinyurtcom/m2q4z2I (last checked 6/15/2017): a;o, available at: http://tinyur!com/m473l24 (tast checked 6/15/2017); Newsletter, available at: http:/ /t,nyurlcom/lmz6yvs (last checked 6/15/2017).

"' Information ta Ken from:· MMSA 990 forms, available at: http://tinyur1.com/kz4nkqg (last checked6/15/2017); F!or;da Corporate Documents available at: http://tinyur!.com/mmj67c7 (last checked 6/15/2017): Florida Corporate Documents available at: http://linyur!.com/l56cxns (last checked 6/15/2017)

"' Information taken from: Principal newsletter, available at: http://tinyurl.com/mquljva (last checked 6/15/2017); School listing, available at: http://tinyurtcom/k3ptbng (last checked 6/15/2017). Employee credential search OH, available at: ht1p:/ltmyurl.com/j7bxyhk (last checked 6/15/2017).

.. Information 1aken from: Orlan<io Science listing, available at: http://tinyurlcom/k3ptbng (last checked 6/15/2017}; and Linkechn profile. available at: http://tinyurLcom/lp6m7dy (last checked 6/15/2017).

., Information taken from; Linked in Profile, available at: http./ ltinyurl com/I59zuql (last checked 6/15/2017)

"" Information ta Ken fmm: School listing, available at http.//tinyurl.com/jwszpod (last checked 6/15/2017); Linked in profile, available at: http://tinyurLcom/lm6o1dk (last checked 6/15/2017), Harmony schedule, available at: http://tinyurl.com/ I5g7p6f {last checked 6/15/2017); LISA Academy information. available at: http://tinyurl.com/jwg9ups (last checked 6/15/2017); Article re: Gu mus, Harmony, and Giilen, available at: http;//tmyurl.com/k6f7y44 (last checked 6/15/2017).

"' Information taken from: Charter newsletter, available at: http://tinyurl.com/ksox4ns; Bood statement at A-8, available at: ht!p:f /tinyurl com/k5pb7cf (last checked 6/1512017);

I HIS MA I HHAl IS DIS I islBUl ~ Ii IIY AMS! ER DAM & f'~H I Nf HS I LP ON BfHAl I Ill I Hf Kf PUrll IC CI I UH sf I. AVOIIIO~•! H!I O~l,!AIIO~ IS AVlllA~l; Al IH[ DEPARIIAtNI Of 1us11r,. w~~HFIGfOIJ, ~c

Received by NSD/F ARA Registration Unit

Empire of Deceit: An Investigation olthe GUI en Charter Schro Network

Notable Articles regarding the Florida Network

-Saacks, Bradley Joseph. U.S. schools caught in Turkey's crackdown after attempted coup. Bloomberg, September · 2, 2016. {Discussing whether Florida ,officials will .open a fo~al probe into-River-City Science Academy in 1Jacksonville due to troubling financial connections). Available at: https://tinyurl.com/k7o4i::tp2, {lilst checked 6/15/2017).

·MicolUcci, Vic. Charter schOOJ JeaiJers deny ties to wanted Turkish rebel. WJXT News4Jax, August 2, 2016. Available at: https://tinyurl.com/ n5xtpdw {last checked 6/15/2017).

Brown, Marina. Attempted coup in Turkey sends shockwaves locally. T811ahassee Democrat, July 1 25, 2016. Available at: https://tinyurt.com/ lxmj43q {last checked 6/15/2017).

Sokol, Marlene. Landlord·sues North Tampa charter school for. back rent. Tampa Bay Times, July 25, 2016. (Discussing New Springs' failure to

pay rent). Available at: https://tinyurl.com/mes­baaw (last checked 6/15/2017).

Aydin, Akif. First Coast Connect. WJCT News,. July 19, -2016 (Radio Interview with Aydin dis­cussing Gulen Movement and River City Science Academy). Available at: https://tinyurl.com/ j2a7b8q {last checked 6/15/2017).

Benk, Ryan. Coup attempt highlights Jacksonville connections to Turkey. WJCT News, July 19, 2016. (Discussjng how Founder Aydin would renounce his support of GUlen's phi­losophy if it' was proven· he had a: hand in the unsuccessful rev0tution). Availiible at: https:// tinyurl.com/hm2e5j4 {last checked 6/15/2017).

Amos, Denise· Sinith. More Rorida,charter school audits·show signs of financial stress. The Florida Times-Union, July 6, 2016. •{Discussing how ,River .City Science .Academy· Innovation

experienced fund balance deficits). Available at: https:/ /tlnyurl.com/metddqa (last checked 6/15/2017).

Development today."The-Daity Record, June 1, 2016. {Discussing River City's use of Blue Ocean Construction). Available at: tittps;//ti~yurl.com/ lky6ywe (last checked 6/15/2017),

Dickey, Will. lstaribul Cultural Center: The Language and Culture Festival. The Florida Times-Union, May 16, 2015. (Discussing River

City students performance of Turkish fo.lk danc­ing· at the festival). Available·at: https://tinyurl. com/lv8744k (last checked 6/15/2017).

Sokol, Marlene. New requirement reveals struggles inside some Hillsborough charter schools. Tampa Bay Tiines, October 15, 2014,

(Discussing how.half the faculty at New.Springs are inexperienced, and· the school received. a "D" rating). AV'ailiible at:- https://tinyurtcom/ mqhrwt6 {last checked 6/15/2017).

Stricklllnd, Sandy .. Galt Box: Resident wants new grocery store for 'forgotten' Mayport area. The t=iorida Times-Union , August 16, 2014. (Discussing details of River City construction j0b awarded to Blue Ocean Construction). Available at! https://tinylirl.com/mk58jx1 {last checked 6/15/2017).

:Segal, ·Sabrina. Margate charter school jit­ters. Margate News, August 11, 2013. (Discussing Broward Math and Science and J)Otential ties to Gulen). Available at: https://tinyurl.com/ mmfps87 {18st Checked 6/15/2017).

Jester, Erin. 3 'F's for elementary school. force Sweetwater ACademj, to close. The Gainesville Sun, August 7, 2013. (Discussing poor school grades and financial trouble). Available at: http:// tinyurl.com/zdvl4yr {last checked 6/15/2017).

!HIS Mi'HIIAI IS fll'llAHlUHO ~I ~MSlfllD~M & l';HJN[R5 (IP 0~ llfHAlf r:; !CE HFP:J~I IC 01 IU~r'eY ADDIIIONAI IIHOeMAIIOfl IS AVAIi ABI r Al lei D1PSHIMfNI Of JUSIIU. WAS~INfdOIJ, DC

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•Received'by NSD/FARA Registration,Unit 07/27/2017 6:.Jl :32 PM

Quick• Facts

► Region: Midwestern

► SchoOI Naffies,(known as): 1> Horizon Science Academy 1> Math and'Science Academy

► Total # of Schools in State: 4

► Total Student Enrollment 2015-16; 21961

► Charter Holder/Governing Board(s}: 1> Chicago Math and Science Academy,

Inc. Non-profit organization with ·501(c) (3) -status, oversees Chic_ago M8th and Science Academy:

1> Concept Schools NFP Oversees·HSA-McKinley-Park, HSA Belmont, HSA Southwest

► Charter Man~gement Services Vendor: Concept Schools, Inc.

► Regional· Gi.ilen ·Organization Overs!Qht Entity: Concept _Schools, Inc.

► Regional.Sister:Networks:-Horizon (OH); Noble (ciH); ~ath and Science (IN); Math and ,Science •(MN); Math and :science

EmptreotDecelt: An ln~stigation of the GUlen Charter Schro Nelwork

•{Ml); Gateway'(MO); Math- and Science •(WI).

► Total Revenues for the- 2015-16 school year: Approximately $22,827,2321

► Network Founders: •I> Taner ·Ertekin: ,Established ·GuJenist

SChools in Thailand: -and Japan;3

Co-founder of first Horizon Science Academies; founder of Concept Si::hools;4 used'HSA Cleveland funds to pay immigration. expenses for his.wife;~ founder and president'.of ~reeze, Inc., Concept'S preferred Gi.ilenist,landlord1entity;8 founder of Chicago Math and Science Academy.'

1> Sedilt, Duman: Founder of Horizon Science Academies;8 •Co-Founder of Concept • Schools, lnc.;9 CEO of Concept Schools, lnc;1° Currently being:investigatect:by the:FBI for his role in purportedly.certifying fraudu­lent forms to procure E:Rcite funding."

1> Salim Ucan: Founding Pr!ncjpal Chicago Math and Science;12

Co-Founder of Concept SchOOls, lnc.;13 ·Founding board member for Breeze Inc., for-profit Gi.ilenists

Student enrollment and demographic information available at http://tinyurl.com/lhvvo8r (last checked 4/19/2017)

Figure includes revenues from 2015-16 revenues for CMSA, available at: http://tinyurl.com/kx7zjm9 (last checked 4/23/2017); 2014-15 revenues for HSA Belmont, HSA McKinley Park. and HSA Southwest. available from a FOIA request at: http:/ /tinyurl.com/llrtsubt (last checked 4/23/2017)

Bond statement at A-23 describi~g Ertekin's involvement, aV<!ilable at: http://tinyurl.com/keaa5f5 (last checked 4/19/2017}.

Id See, e.g., H_SA Cleveland 2002 audit, pg 24, where a finding was made against the school for paying the immigration expenses of the spouses of sedat Dum,!n and Taner Ertekin, Concept's founders, ava1lable at http.//tinyurl.com/llpzg45 (last checked 9/8/2016).

2007 Breeze Inc. 990 form, availa~e at: http://t1nyurl.com/zj9xbzx (last checked 9/8/2016)

CMSA 990 tax documents listing Ertekin, ava,lable at: http://tinyurl.com/hdu6gbe (last checked 4/20/2017)

See Cor,cept Schools, Our Story narrative, available at: http:/ /tinyurl.com/z6s23yh (last checked 9/6/2016),

See Concept Schools, Our Story narrati~. available at: http://tinyurl.com/z6s23yh (last checked 9/6/2016).

CEO's welcome, available at: http://tinyurl.com/k2ybgnm (last checked _4120/2017),

Search warrant. pg 22; available at: http://tinyurl.com/jt9j4ed (last checked 4/20/2017)

Linked1n profile, available at: http://tinyurl.com/tt6se6n (last checked ·4/19/2017)

See Concept Schools, Our Story narrative, available at: http://tinyurl.com/z6s23yh (last checked 9/6/2016).

IHIS MAit HiM IS DISIHIJUIEO Bl AMSIEfOAM & ~.;Hr~rns LlP ON 3ff1Alf Of THE l,fPU~LIC Of IUK~CI AlllllrlCNA! INfO~MAIION IS A\'AILA8LE .'[ I Hf GCP~HlM!NI Gf J~SIICi, WAShlN[ I~~. IJC

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Received·by NSD/FARA Registration Unit 07/27/2017 6: 11 :32 PM EmptreotDeceit: An lrJl/esOga~on ol the GUI en Charte1 School Networ~

landlord for Concept Schools;1• Vice

President of.Concept Schools,·tnc.;'~

currently Professional Development

coach for Concept.'' t> Engin Karatas, a.k.a. Engin

Blackstone: Co-founded Chicago Math and Science Academy;• Assistant Principal HSA Denison

Overview

Middle; Principal HSA Toledo; Principal Quest Charter Academy; Assistant Principal Wisconsin career

Academy;" visited Fethullah Gulen at the ·Golden· Generation Retreat Center with Concept· whistleblower

Mustafa Emanet;1• Superiritendent

G81teway science Academy (MO).'a

As of the 2016-2017 school ·year, Illinois has

4 GUlen Organization-charter schools in opera­

tion. CMSA is overseen by its own incorporated

governing board, but the Concept Schools gov­

erning board directly controls and oversees HSA McKiriley Park, HSA Belinont, and HSA

·Southwest. Ail 4 schools contract with,Concept

· Schools, Inc,. the charter management organiza­tion responsible for the Midwestern region of the

GUlen Organization: charter network. Concept

allegedly provides additional educational man­agement services for the charter schools for a

percentage fee of t0t8I school revenues.

r"ool Chicago Math and Science Academy 7212 N. Clark St. Chicago, ll 60625

HSA'Belmont 5035 W.1 North Ave: Chicego, ll 60639

HSA McKinley Park 2245 W. Pershing Ad. Chicago, IL60609

HSA Southwest 640; 5. Western Avenue Chicago,·IL60609

Clpenltlon,

Grades 6-12 2004-Present

•Grades K-7 (eventually

K-12) 2013-Presenl

Grades K~n (~ventually

K-12) 2013-Present

Grades K-10 (eventually ·

:K-12) 2014-Present

Stildent Demographic Information• ·

1~·swo 13% Ell

92.5% FAl 97.5% Minority

2.5% Caucasian

10.6o/oSWD 13.3% Ell 94.7% FAL

98.5% Minority 1.5% Caucaiian

9%SWD 25% ELL 83% FAL

95%'Minority 5% Caucasian

~4%SWO 24% Ell 95% FRL

99% Minority 1% Ceucasi&n

Authormi

Chicago Public

Schools

Illinois State Charter School

Commission

Illinois State Charter SC:hool

Commission

Illinois State Charter School

Commission

Breeze Articles of Incorporation, available at: http://tinyurl.com/mlc5jc4 (last checked 4/20/2017)

linked in profile, available at: http:/ /tinyurl.com/lt6se6n (last checked 4/19/2017).

linked in profile, available at: http://tinyurl.com/Jt6se6n (last checked 4/19/2017)

Governing - J Chicago Science

and Math Academy Inc.

concept Schools NFP

Concept_Schools NFP

Concept Schools NFP

Interview with Eng in Blackstone, available at: http·//tinyurl.com/mw9be~ (last checked 4/23/2017)

2015 letter from Mary Addi and Mustafa Ema net to OH legislature. ava,lab~ at: http://tinyur1.com/meuup~ (last checked 4/20/2017)

linked in profile, available at: http:/ /tinyurl.com/lylm33o (last checked 4/25/2017)

IHS VAl:~•~l IS OISl~IBUIEU 81 A\ISHHW.I ~ Y'fil!i~HS lLP Oil >f~Alf 01 IHC HPU'lll[ □[ flJ~'.lY ,□□ IIIDNAL 1)lfOriMA!IO)l IS AVAILABLE AT !Hi DlHHlMt~l or JUSTICE, WAShlNUIOr;, DC

Received by NSD/F ARA Registration 11nit

Empln at Deceit: An lnves11ga:100 ol the GUleri Charter School Network

School Operation Student Demographic . lrlfomiation•~

Autho~r ;1aove'1'1neBoart1

Former Concept-Managed Charter Schools

Quest ·Charter Acadf!my 2503 N University St, Peoria, IL 61604

Grai:les's-12

•2010-Present 14.3% ELL 62%FAL

7.5%SWD

Peoria-Publlc School

District 150

Peoria Charter School Initiative Co

86%' MiOOiity 14% Caucasian

-Student demographic information was taken from the 2015-2016 school year.· ·swo· indicates stu­dents with disabilities. •ELL" indicates_English language learners. "FRL" indicates students receiving free/reduced lunch. le

A History of Strategic Ambiguity -and-Conflicting Interests

After GUlen relocated to the Urlited,States in own charter sch00Is in Ohio and Illinois.

1999, his followers promptly formed non:profit educational foundations end ,filed applications

for the first of the Gulen Organization's char­

ter schools throughout- the·country. Some of

the.earliest charter school efforts by-the Giilen Organization took pt.Ice in the Midwestern region

orchestrated by a tight-knit group of Turkish

businessmen, · led predominantfy by T.iner Ertekin and Vedat Akgun. After forming the first

of the Horizon Science Academies in Ohio, these Gulenists.formed Concept Schools to serve as

an external charter management·organization that would oversee- the charter schools they

opened in throughout.the Midwestern reglon.21

Then, in 2003, Ertekln and Akg~n followed, up by forming,Breeze Inc., a:tor-profit corporation

to serve,as the,Concept.schoolS' landlord.'2 In

2004, :the first of the Concept IL schools was opened-Chicago Math and Science Academy

("CMSA"). Within four years, Ertekin, Akgun, and

their Gulerist colleagues created· a vertically integrated:chain of businesses and vendors, all feeding-upon 8,captive customer base of their

After CMSA, Concept did not attempt to open

another of its own schools until 2013. Before that,

however, Concept was-:hired by Quest,Charter Academy to,provide charter management ser­

vices in 2010. Quest _was unique within the Gi.ilen

Organization as it was the only school under Gulenist coritrol that was not directly. created

by GUlenists, nor·operatedjby a GUlenist gov­

erning board:ln 2009, community efforts within Peoria to open a· STEM-charter schooi: began."

An application was submitted;for approval an~

granted in January of 2010. The governing board then hired concept SchoOls· as· its mailage­

ment,partner shortly thereafter. As,a result, the Quest governing board-was not controlled by

Gi.ilenists, although the school's administi'ation

was GUlenist since Concept controlled hiri~g the administration. In 2015, the Quest governing

board and Concept "nlutt.ially agreed tO end their

contract:'24 The authorizer then renewed Quest's charter has been operating independently since.i-;

•• StLJdent enrollment and demographic information available at: http://tinyurl.com/k52paej (last checked 4/19/2017),

Concept Schools NFP corporate informat,on, available at: http://t1nyL1rl.com/zallyt7 (last checked 4/20/2017).

" Corporate information available at: hnp:/Jtinyu1tcom/kn9xUZ1 (last checked 4/20/2017).

» Quest history, available at: http://l;nyurl.com/m4awbgx (last checked'4/23/2017)

,. Id.

" Adams, Pam. Quest Charter Academy Approves Five-Year Plan, Peoria Journal Star, February 27, 2015. Available at: http://tinyurl com/kqzxcc7 (last checked 4/2312017)

TC.IS !,IAHRIM IS ~IS!~IBUTEO rll AMSTfF,N',! ~ PAfil~E~S UPC~ ilf~Ail 01 1hC HPUBII( Of l~l'•CY AUOITIGIIAI l~f0fiMA!l0'J IS AVAIi ABIE Al Jf,E OtPA~lMf~I OF IUSTICf WASHtir,rn~. OC

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Received'by NSD/FARA Registration Unit 07/27/2017 6:11:32 PM Empire of Deceit: An Investigation ofttie GUI en Charter School Network

In· 2013, Concept applied to: Chicago Public

Schools to open HSA Belmont and ·HsA McKinley Park. Chicago Public,Schools denied both applications, however, stating _that cMSA's poor academic performance did not warrant Concept's expansion. Con~pt then appealed CPS's denials to the Illinois State Charter School Commission, which approved -both charter schools to. open under its management that same year. The following·year, the Commission

approved a fourth Concept-managed school, HSA Belmont, to open as well.

Concept's.most serious controversy·to date is the ongoing FBtiinvestigation concerning the purported collusion:of,concept employees-and their vendors to defraud the federal E-Rate grant program of millions of dollars." According to the released FBJ's search warrant application, Concept executives violated the competitive bidding-rules of the E-Rate-program1by selec_t­ing a vendor complicit with Concept's plans to defraud E-Rate outside of the normal Procure­ment process. Then, a_ccording to the search warrant application, Concept's Chief Information Officer directed that vendor to divert: hefty •subcontracts" to affiliated Turkish individu­als and companies in.exchange for a cut of the proceeds. The actual work purportedly was per~ formed by Concept employees themselves, not by the-complicit vendor w!lo was approved by ·E-Rate to provide the work, or the so-named

·Financial Issues

While Illinois requires its charter schools to.undei"go:annual audits, these audits.are not made publicly availcible without submission of a

companies and Turkish vendors for the subcon­tracts.1' In ·2014, FBI agents raided numerous locations throughout Illinois and Ohio, includ­ing CMSA, Concept's regional offices, and the offices of several Gulenist vendors .. According tO several sources, former Concept, executive and Ohio Founder Ozgur Balsoy · was one of the fraudulently enriched Turkish vendors who was raided.21 While Balsoy and his business remains under suspicion in the FBI investigation, Concept continues to give him and'.the other Turkish-owned vendors named in the searCh warrant application substantial business.''' The investigation is ongoing.

Mustafa Emanet, a former H-1B employee and GUlenist. provided interviews to the FBI regarding his work as a network administrator and teacher at HSA Toledo. He corroborated that Concept purposefully used related ser­vice providers who overcharged, just like all of the-charter networks throughout the-GU.len Organization.Jg Since his cooperation with the FB1, Emanent and his wife who was also employed with Concept, Mary Addi, have come forward and provided information regarding the forced-tuzuk payments and.tithing to the GU.len Organization required of Turkish H-1B employ­ees.J' Emanet also produced a copy of the tuzuk agreement itself, whiCh is attached to this report as Appendix_.

Freedom-of Information Act request. Requests have been.madeJor these audits but;have not yet been fulfilled.

" M,halopoulos. Dan and Seidel. Jon. Charter Firm Suspected of Cheating Federal Grant Prog,em, Chicago Sun-Times (Aug. 9, 2016}. Available at: http./ /t,nyurtcom/j3snbad (last checked 9/8/2016).

Search Warrant application available at: http://tinyurl.com/jt9j4ed (last checked 9/8/2076)

" See Id.; see a/so Miha!opoulos, Dan and Seidel, Jon. Charter Firm Su$pected of Cheating Federal Grant Program, Chicago Sun-Times (Aug.9.2016). Available at: http://tinyurl.com/j3snbad (last checked 9/8/2016).

" See Mihalopoulos. Dan. Targeted firms StiN Get Tax Money After Chartet Raids, Chicago Sun-Times http:/ltinyur1.com/jzmzevh (last checked 9/8/2016).

30 Search Warrant apphca11on, pg 44, available at: http://tinyurl.com/jt9j4ed (last checked 9/8/2016)

2015 Letter from Mary Addi and Mustafa Ema net to OH legislature. available at: http://tinyurl.com/mezrup~ (last checked 4/20/2017)

IMIS \!A!!kl~I l~ DISl~ldUl:IJ 1V ~>.!SER~~!,! & PAHTNfRS LLP c~ ~iHA(I or TH Vil'!ldllC Of mi;;[, AOlll I IO~•.I INI OI' I.IAI IO~ 10 AVAIi A~I' AT l hf o: PAM IM E in Of IUS I ICl, \\'~~~rnGTWi, IJC.

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Real Estate

One of.the most significant profit centers for the Gulen · Organization, and in particular the Midwestern region, is through real estate. This prope~y financing scheme has·been·replic.ited throughout the-country-in_,fact, Vahap Uysal, a board member"of Concept Schools," wrote and presented an article entitled "Gulen Movement and School Financing• at the Third Annual Conference on Islam in the Contemporary World: The Fethullah GUlen MOveinent in Thought and Practice." Giilenists ~h,oughout the country attended and presented, including AIP Astandogan, former Harmony Public· Schools landlord, CEO of one Harmony's largest vendors, property buyer :from Dove Sdence Academy, and:GUlen's officiil spokesperson in his role as President of the,Alliance for Shared Values, a Giilenist cl!ltuial organization.i•

Early on, the founders of the Midwestern region established Breeze Inc, as a for'.'profit corporation to acq~ire properties for Concept Schools throughout the- Concept network.1

~

New Plan Learning was created shortly there­after, and now acts as the non-profit umbrella organization for Breeze and several other wholly owned su~sidiaries.:ie Murat. Afabaci,. a former Concept employee,n has managed New Plan Leaming and each of its subsidiaries since 2005.31 Together with its subsidiaries, New Plan Leaming buys, renovates, leases, and some­times sells properties to Concept-managed schools, allegedly as a supporting organization to those schools.

Effll!lreofDeceH: An Investigation of the Gulen Charier Schoel Network

Currently,· NE!w·Plan learning owns only orie of the Concept IL properties-the Chicago Math and Science Academy ("CMSA•)-though it owns over a dozen other. Coiicept school prop­erties throughout the Midwestern region. As many of'the Concept 1 IL charter schools-have opened wrthin the last five years, ·New f>tan Leaming will likely seek to acquire more of these new school properties over.time, as it did in Ohio and.other states where.it is more established. New Plan Learning's property dealings with CMSA are,particularfy egregious, however, and serve as a prime.d_einonstration.of the-appar­ent self-dealing by Concept and its preferred Gulenist vendors and the resulting exploitation of GU!enist-controlled charter, schools.

CMSA.bought its·property in 2009!for"$10.4 million. Two.years later, CMSA sold.its building to New Plan Leaming at a loss and entered into a lease-back-arrangement. with extremely poor terms. The Ieaseihad:a non-cancelcible term of thirty-five years, with'annuaJ.rents ranging from $1 million to ,$1.2 million set to increase each year.n Over the.term of the lease,·CMSA WOuld pay well over $40,million in rent'for a building it once owned and'sold at a loss. The tease:back agreement also.bound CMSA tO inclusion·in·a $33 million educational facility revenue bond.

Of the $33 million· borrowed by NPL with this bond, approximately $12,8 million was allocated to CMSA for two purposes: l) to cover NPL's purchase,of property from CMSA;for $10.2 mil­lion; and·2) for NPL to construct a 9,775 square

"' See Concept Schools 990 tax form, available at: http:/ /tinyurl.com/h5yvjlt.

,,, Conference was held Nov. 3, 2007 in San Antonio, Texas. and the conference agenda is available at: http·//!inyurl.com/gt2vujs (last checked October 31, 2016)

'° See Texas profile for more informat,on about A!p Aslandogan

"' New Plan Leaming, Inc. 2011A Bond Offic:at Statement pg A-4, available at: http·//tinyurtcom/zxoauxp (last checked 9/6/2016),

'" New Plan Learning, Inc. 2011A Bond Off1c,al Statemen1 pg A-4, A-5, available at: http://tinyurl.com/zxoauxp (last checked 9/612016); see also Exhibit A for Property infofmation. including landlords. renL and transfer history for the faC,hties of the Ohio Concept Schools.

See 2007 Concept 990 w,th Arabaci listed as employee. available at: http://tinyurl.comh9y361h (last checked 9/8/2016)

'" See Business profile for New Plan Learning; Inc. showing ,ts incorporation in 2005 and listing Arabaci as agent, available at: http //tinyurl.com/hu2d6x7 {last checked 9/8/2016)

'" See CMSA 2012 audit, ;ivailab!e at http·/ftinyurl.com/h5xcob2 (last checked 11/23/2016)

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foot gym for up to:St.5 million.~0 This means that

CMSA'will pay upwards of $40 million in.rent in

exchange for the constr!Jction of a gym costing less than $1.5 million,•• the approximate·price of

one year of CMSA's rent to NPL. CMSA's $40 mil­lion in rent over the next three decades will pay

off the construction of.the gym in a little over. one year,·NPL's mortgage on CMSA shortly thereaf­ter, with the remaining decades of million-dollar

rents resulting in pure profit to NPL, a nonprofit

organization that cannOt le{:lally,profit off of its

charter school customers.

What is particular1y concerning about CMSA's bad property deal with New Plan Leaming is that Edip Pektas, CMSA's board·treasurer"and

president, was a paid business development consultant for New Plan, Leaming during all of

the relevant.transactions.•' This was-an explicit

conflict of.interest.as Pektas was on-both sides

of the transaction and had a personal financial interest in New_ Plan Learning. cin<fin fact:was

paid to help New Plan Leaming develOp busi­

ness, A few years later, \fVhen Pektas was CMSA's board president, New Plan Learning renegoti­

ated the lease-back agreement with even worse

terms, taking away the.school's ability to·bl!Y back the ·property-anhe end of:the lease and

Bond Financing

In 2011 New Plan Leaming expanded its capital significantly by applying for a bond for approxi­

mately $33 million doll.irs to purchase, refinance,

and/or renovate·four Concept-schools, CMSA

increasing the rent significantly,0 Pektas' loyalty

to New Plan Leaming. tiis employer, instead ofto

CMSA, cannot be doubted.

In our view, New Plan Leaming put CMSA at an even greater disadvantage by hiring a related

Gulen-affiliated construction vendor, Quality Buildi!rs,of Midwest, to· construct CMSA's gym. CMSA's board·president Pektas·is also listed as

the registered agent.for Quality Builders, adding

another layer Of his:conflict of interest ... Within

one year of construction,·the $1 million gym ~is­played significant building issues, including

multif)le leaks in its roof, cracks in its foundation,

rodent problems, sanitary issues, and flooring

that peeled upward due to an improperly installed bleacher system.'~ Despite these maj':)r concerns

with-the gym's construction, Quality Builders did not provide repairs, and neither NPL nor Concept

covered the repairs' costs. CMSA was on the hook per the terms.of its lease-back agreement to fix

the gym's issues, and could not rely on a warranty with QU81ity Builders to'correct its building fl8ws. The exploitation of CMSA·is a:prime:example of

the Giilen Organization's highly suspect property

scheme, which appears to enrich private Giilenist

interests in both money and property holdings, all orchestrated et the tax payers' expense.

and three Concept OH schools--HSA Dayton HS, HSA.Toledo HS, and HSA_Springfield.• Due

to their inclusion in the bond, these schools are

now:subject'to extremety·high annual rents in

40 New Plan Leaming, lnc.-2011A Bond Offic'al Statement pg 9, a11ailable at: http://tinyurl com/zxoauxp {last checked 9/6/2016).

According to the p,oject information, the contract's price was listed as approximately $1 million. See project information, a11a1lable at http://tanyurl.com/zwzk.r.y2 (last checked 11/11/2016)

., New Plan Leaming. Inc.- 2011A Bond Offic'al Statement pg A-6, a11a1lable at: http://linyurlcom/zxoauxp (last checked 9/6/2016); Mihalopou\Qs, Dan. Lawyer.; fDr Turkey Call for Probe of Chicago Charter School. Chicago Sun-Times (Jan. 25, 2017). available at: http://tinyurl.com/jzmze11h (last checked 4/27/2016),

., See CMSA 2014 audit, pg 13 located at http://tinyurl.com/h37lko11 (last checked 11/11/2016).

.. Qual1ty,Bu1lde,s of Midwest corporate documents, available at: http://tinyurl.com/zal!yt7 (last checked 4/28/2017)

.. See Exhibit_ for a personal statement from CMSA's former athletic director regarding the quahty of the gym. P,ctures are a11ailable on line of the moisture damage and cracks in the gym's foundation. A concerned ci1izen documented these issues on a blog post, a11ailable at: http://tinyurl.com/hjq4z1k {last checked 11/11/2016)

.. New Plan Leaming, Inc. 2011A Bond Offic,al Statement. a11ailab!e at: http.I /tinyurl.com/zxoau~p (last checked 9/6/2016~

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non-cancelable leases set to expire in 2041."The

bond was issued'by the lndustri8I Development Authority·of the.county:of Pima, Arizona, the

Empln of Deceit: An 1nvest1ganon oltheGiilen Chartff School Ne1wo,~

same organization that issued bonds for both the Sonoran (AZ) and Coral {NV) Giilen Organization

charter networks.•

Excessive Use of the H-1B Visa Program

•Like other Giilen Organization charter net­works, Concept and their IL schools utilize the

H-1B visa program to immigrate,large numbers of Turkish Giilenists, into the United· States for

employment in the schools and network. The Concept:iL network filed between 200:-2S3'H-1B applications from 2001~2016, ·while Concept itself

filed between 176-197 H-1B applications during the same time:period,"9'11 is difficult-to ascertain the

exact amount because Concept used a number of

slightly, different names for its entities when filing H-18 applications. ·while.the Gillen Organization

typically states that these H~1Bs are:only to fill shortage areas for math and science•teachers,

these applications were filed for such. positioos

as: Physical education teaChers, school business

managers,·administrators, English te~chers, net­work administrators, accountants, and auditors.

Concept IL uses the same immigration attor­

neys to file,and·process their H-1B·applications as other known Giilen Organizatioi, charter

networks, ·vendors, and cultural associations,

indicating once again the existence of an overall

network. For example:

► Remzi Kulen. Coocept IL used Kulen, a New York-based attorney, to file numer­ous H-1B. applications. Kulen also-filed

applications for:

., Id.

1> Concept Schools:{OH, IL, MO, IN, Ml, MN)

1> Gateway (MO)

1> Pioneer (MA)

t> Niagara Foundatiora (IL) 1> Young Scholars (PA) t> Gofden Generation Workshop Center

(PA)

1> Blue Ocean Construction {FL)

1> Academy-" of Science, Syracuse, Buffalo (NY)

1> Arts and Science, Bergen, Passaic (NJ)"°

► David Nachman: Concept IL used Nachman, a .New 'Jersey-based attorney,

to file H-18 applications.5' Nachman-also

fited H-18 ~pplications for: 1> MilkyWay_Education Center (NJ)

t> Paterson Charter School for Science and Technology (NJ}

► NuzhafHafeez: Concept IL schools used Hafeez, an Illinois-based attorney, to file

numerous H-18 applications.!>Z Hafeez

also filed H-1B apj)lications for:

t> Conce~ Schools. Inc. 1> Niagara Educational Services; Inc. (IL) 1> Niagara Foundation (IL)

t> The Core Group (!L)

.. Pima County bond issuances, available at: http://t1nyurl.com/kards94 (last checked 3/30/2017)

'" In another example of strategic ambiguity, Concept and its scnools use 5ellel'al different wrsions of their names to malca ii d.fflcult to aggregate how many H-18 applications they are fifog. The sum Iota! of aD of the Concepl IL schools fran 2001-2016 is between 200-253 aPP~ and the numbers suppon:ing that total are located at the following links: 1) CMSA. anywhere from 24 H-lBs-60 H· 1Bs. due to multf:)le names used. http://tinyurl.com/lc9pbuvy; http://1inyurkom/ny94qjd;http://hnyurl.com/ nJyywtit;' http:/ /tinyurl.com/k8mz7aa: http:/ ttinyurl com/l,r5v79. Concept filed between 176· 197 H· 18 appt,catiol'"tS 2001-2016 See http:/ /tmyurLcom/jJwhatt for Concept Schools, Inc,: http./ /tinyurl.com/zhgxJxl for Concept Schools Nip.

,. List of entities represented by Remzi Kulen, 811a1iable at http://tinyurl.com/gptwx5x (fast checked 3/21/2017)

Nachman p1ofile listing entities rcp<esented fol" H-1B 11isa WOik. a11ailable at http://tinyurl.com/ny5h3ty (last checked 4/13/2017)

"' Hafeez profile listing entities represented for H·lB 11isa work, available at: http;/ /tinyurl.com/m11ntta11 (last checked 4/13/2017).

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Scandals, Investigations & Notable Activities Notable Turkish Vendors

In 2011, CMSA non-Gulenist employ~es com­

plained to the•American Federation of Teachers

C'AFT")'regarding CMSA and COncept's·exces­sive use of the H-1B ~ram to hire unqualified Turkish-teachers and discriminatory preferential pay to Turkish employees. The AFT presented

these complaints ·to the U.S. Department of Labor, who initiated an·investigation-that is still ongoing.5.JThe Department of Labor had already

been investigating-a-Horizon Science Academy

in Ohio due to a July 2008 complaint by Mustafa

Ema net regarding the forced tithing payments to

Concept.""

In 2010, CMSA principal Ali Yilmaz fired a teacher who was eight,months' pregnant at"the

time.!,!, The teacher had been involved in estab­

lishing-a union for CMSA.employees,:and,prior

to her.efforts to organize the staff, she'd received

performance bonuses and had her contract renewed. CMSA spent extensive resources

fighting its·teachers' union organization:efforts.

CMSA ultimately settled with the teacher in 2011 for the wrongful termination, and;no union was

formed on campus.

In 2015, two.Arizoria Membei's of Congress, U.S. Represeritative Raul Grijalva and U.S.

Representative Ruben Gallego, wrote letters urging the U.S. Oepartmerit of Education and the

Government Accountability Office respectively to urge an investigation of charter schools affili­ated with Giilen. These letters we resent in li9htof

the recent raids of the Concept Schools network

located in Ohio, lllinois,-and ·other Midwestern states-for suspected defrauding of the-federal

E-Rate program. by Concept's Turkish•adminis­

trators and vendors,:Both Grijalva and Gallego

were concerned about the connections between Concept and•the Sonoran,networit in Arizona

uncovered_ by· investigative journalisms at· the

time and asked for a thorough investigation.r..

Spotlight: Friends ot·Giilen Mike Madigan

Michael Madigan is the Speaker of the Illinois State House of Representatives, a title he has

held• for the last three decades. Madigan has

extensive ties with Concept Schools and the Niagara Foundation, and has taken at least

four trips.to Turkey coordinated,by the,Niagara

Foundation.~1 Madigan created the Illinois

Charter School Commission, the authorizer ·of three of Concept's four charter schools in

the state, though · the Commission states that

Madigan, did not pressure the Commission to

approve the applications tor either H SA McKinley Park or HSA Southwest.u Madigan has also vis­

ited CMSA's campus, speaking highly of the

school and its leadership, and his son, Andrew Madigan; provides insurance services to CMSA, HSA.McKinley Park, and HSA Southwest.!,i

"' Saul, Stephanie. Charter Schools Tied to Turkey Grow in Texas, The New York Times {June 6. 2011), available at: http.l/t,nyurl.com/3ua255n (last checked 4/23/2017)

"' Feds Question Schools' Visa Use, The Columbus Dispatch (May 20, 2011), ava,lable at http://tinyurl.com/m2ssl9h (last checked 4/23/2017)

"" Lydersen. Kari. Firing of pregnant Chicago teacher becomes battle over charter school unioniiation. In These Times {A"ugust 9, 2010) A...ailable at: http:/ /tinyurl.com/jqytnct

"" Representative Gnjatva's letter is available at: http:/ /tinyurl.com/hnhcbq5 (last checked 3/14/2017), Representative Gallego's letter is available at: http./ /tinyurl,com/z)'fhf3u (last checked J/14/2017)

Article discussing Madigan's involvement with Concept, available at pg 107-08 http://tmyurl.com/m9fmvo4 (last checked 4/22/2017)

.. Id.

'" Id.

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► Concept Schools, Inc. Concept is a com­

pfehensive services vendor that controls

human resources, fiscal management,

school design, curriculum, accourit­abili~y. compliance, and reporting tor a twelve percent fee·of each schoot's·total

revenues. Currently, Concept'is the con­tracted nonprofit management services

vendor for thirty such charter schools, with seventeen schools in. Ohio, four in

Illinois, three in Missouri, three in Indiana,

one in Michigan, one in Wisconsin, and

one in Minnesota.110 The founders of the first OH charter schools in the GUlen

Organization formed Concept shortly thereafter.

► Breeze lnc./New · ptan Leaming: Breeze,

lnc.,-was created in 2004 as a for~p,ofit corporation to acquire properties for

Concept Schools throughout the Concept

Network.8' New Plan·Learning was cre­

ated shortly thereafter, and now acts as the non-profit umbrella organization for

Breeze and several other wholly owned Ohio-based subsidiaries (250 Shoup

Mill LLC, OG-Ohio-LLC, NOG-Ohio LLC,

and 2350 Morse LLC).11 Together with its

subsidiaries, New Plan Learning buys, renovates, leases, and-sometimes sells

properties to Concept-managed schools,

allegedly as a supporting organization to those schools.

► Quality Builders of Midwest: Quality Builders is a Gillen-affiliated construc­

tion company·that does the majority of

Concept and•NPL's construction work.113

several Of Quality Builders' GUlenist employees have worked a! Concept and

its schools, _as well as at other char­ter networks throughout the GUlen

Organization.

► The Core Group: The Core Gi'oup, owned

by Ertugrul Gurbuz; is curre~tly under fed­

eral investigation as one of the vendors

Concept used purportedly to defraud the:E-Rate:program.°" The company and

its subsidiaries have received:over$3.2

million dollars from Concept schools.05

The Core:Group atso-provided•uniforms

to the Fulton· Science (GA} network at an

excessive cost and amount, as noted by the forensic audits prior to the network's termination.•

► Advanced Solutions for Education: Advanced Solutions for Education, owned by former Concept, employee

Ozgur Balsoy, is also· implicated in the

ongoing FBI investigation regarding the purported defrauding of the E:Rate pro­

gram,97 The company served as an E-Rate

funding consultant to the schools.

ec See Concept Schools network, available at: http://tinyurl.C(Jm/zJd8qsb (rast checked 8/26/2016).

New Plan Leaming, Inc. 2011A Bond Offic.al Statement pg A•4, available al: http://tinyurl.com/noauxp (last checked 9/6/2016)

., New f'lan Leaming, Inc. 2011A Bond Offtc,al Statement pg A·4, A·5, available at http://t1nyurl~om/zxoauxp (last checked 9/6/2016): see also Exhibit A for Property inlo.-mation. including landlords. rent, and transfer history for the facilit,es of the Ohio Concept Schools

63 see proiect information, available at http.//tinyurl,com/zwzkxy2 (last checked 11/11/2016)

"' See M,halopoulos, Dan. Tsrgeted Firms Still Get Tax lt,l(Jney After Charter Raids, Chicagci Sun"Times http:/ /tinyurl.com/jzmzevh (last checked 9/8/2016)

.. Id. 66 See Georgia profile, see also Georgia Forensic Audit of GUlen•aff1l·ated Charle, Schools (June 1, 2012), at 17•25, available

at http·//bit.ly/1TATHiy,

., See M,halopoulos, Dan. Targeted Firms Still Get Tax Mone¥ After Charter Raids, Chicago Sun-Times http://tinyurl.com/jzmzevh (last checked 9/8/2016)

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Gillenist Cultural' Foundations

► Niagara Foundation: The Niagara Foundation is a major·Turkish GOlenist cultural: association based in Chicago. GUlen is its honorary president.611 Niagara Educational Services, Inc., oversees both the.Niagara Foundation and the Science

Academy of Chicago, a1private GOlenist school. In 2007,-the Niagara_·Foundation

gave an extensive loan to Breeze Inc.

(New Plan Learning's predecessor) to purchase new properties :for Concept charter schools.99 Several Concept employees as well as school'employees are members of the Niagara·Foundation.

Niagara provides free/low-cost trips to Turkey for-legislators, as·well as·t,osting dialogue dinners and fundraisers.'°

Individuals Caught in the•Gillen Organization Web

It is quite common for the GUlen Organization charter networks within a region to shuffle their Turkish,H-18.visa teachers from,school to school, as·well as between-regions. This-is just a small:number of individuals with these over­lilpping ties throughout the region, which further demonstrates. the region's interconnections. Notably, this shuffling:only occurs with Turkish employees.

►. Aydin Kara: Teacher, Director at HSA Columbus; 11 · Director for HSA Cleveland MS;n Principal for Chicago Math and Science Academy (IL);n Director for HSA Triledo;14 Author for The Fountain,. a known GUlenist magazine/~

► Ali•Kuran: ·Teacher, Dean HSA·Columbus (OH);"' f>rincipal HSA Dayton Elementary (OH);" proposed Principal for Indiana Math and Science ·Academy South (IN);" Principal Quest Charter Academy (IL);19

Princip.il, CMSA (IL),80

► Ahmet Ozarslan: Board member·Fulton Science (GA};" Quality Builders of Midwest - GOien-affiiiated. construction vendor (Midwestern region);12

► Levent Elibal: Employed at Ramson Contractors - Giilenist construction vendor (Western region);83 Quality Builders of Midwest - GUian-affiiiated

"" See http://www.magarafoundation.org/ for information about the Niagara FoUndation and http://tinyurlcom/d8tlv5c for Information about Gillen as Honorary President (last checked 9/612016}

"' Aud,t available at: http.l/tinyurl.com/haos4qu (last checked 9/8/2016)

For a destription of a legislator's trip to Turkey with the Niagara Foundat,on, see; http:/ /linyurl.com/m kfando ( last ·checked ·412012011),

http://tinyurl.com/mkvkmgs (last checked 4/2012017)

http·//1inyur1.com/m6obc3h (last checked 4/20/2017).

CMSA 990 tax forms 2012·2015, available at; http.//tinyurl.com/hdu6gbe (last checked 4/2012017).

Director's message, available at: http://t1nyur1.com/kcc8v4S (last checked 4/20/2017)

http.//tinyurl.com/lzJbwoz {last checked 4/20/2017)

Bio available at: http://tinyurl com/15h956w (last checked 4123/2017)

Press release listing Ku ran as Principal available at: http://t1nyurl.com/lhgbatn (last checked 4/23/2017)

Petition available at: http://tinyurlcom/mej56l8 (last checked 4/23/2017}.

Anicle quoting Kuran as pnncipa~ available a1: http://tinyurlcom/ne6dwhy (last checked 4/23/2017).

"" Sthool information, availa~e at: http://tinyurl.com/mwkpu9I (last checked 4/2312017) .

See Fulton Educational Services 990 tax forms. available at http:/ /linyurl.com/zxtjkrm (last checked 11/23/2018). Ozarslan was on the board from 2007-2010

t;l See Unkedin profile for Ahrnet Ozarslan, available at: http://tinyurlcom/jdrhk34 (last checked 11/23/2016).

.., See Linkedin profile for Levcnt Eli bat available at hnp:/ltinyurlcom/zu3r3nv (last checked 11123/2016i

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construction vendor (Midwestern region); .. Director of Purchasing Concept

Empire otoecett: An lnvestIga1100 o! the Gulen Charter School Network

(Midwestern region);a.. Indiana Math·and Science Academy (IN).•

Notable Articles regarding the Illinois Network

► Mihalopoulos, Dan. Targeted Firms Still ·Get Tax Maney After Charter Raids, Chicago Sun-Times http://tinyurl.com/ jzmzevh,

► Co~en, Rachel M. The National Labor Relations Board says charter school teach­ers are private emj;,/oyees. The American Prospect. (~eptember·B, 2016) AvaitablEl at: http:/ /tinyurl.com/joesxk2.

► Torres, Louie, Teacher Accuses Chicago Charter Schaal of Sexual Harassment, Cook County Record (May 9, 2016) Available at: http://tinyurl.com/hvo72py.

► MihalopoulOS, Dan. Federal funds for clout school operator despite probe. Chicago Sun-Times. (May 1; 2016) Available at: http:/ /tinyurl.com/jmy8web.

► Adams, Pam. Quest Charter Academy Approves Five-Year Plan, Peoria Journal Star, FElbruary 27, 2015. Available at: http://tinyurl.com/kqzxcc7 (last-checked 4/23/2017).

► Mihalopoulos, Dan and Seidel, Jon, Charter Firm Suspected at Cheating Federal Grant Program, Chicag~ -Sun­Times (December 16,·2015). Available at: http:/ /tinyurl.com/j3snbad .

.. Id.

• Id

• Id

► Ravitch, Diane. Concept Schools in Ohio Import Large Numbers of Turlrish Teachers for Giilen Schools. (October 14, 2014)

Available at: http://ti~yurl.com/hcy34t9.

► Livingston, Doug, Auditor Joins Investigation of 19 Charter Schools, Akron Beacon Joumal.'(JulY 17, :2014) ,Available at: http://tinyurl.com/hevz2h8.

► Livingston, Doug. former Teachers at Turkish-run charter school all(!ge test-cheating, discrimination, sexual activ­ity, Aki'on Beacon Journal (July 15,·2D14) Available at: http://tinyurl.com/zsdkk35.

► Karp, Sarah. Concept'Charter SchClals get a green light. Catalyst Chicago. (April 22, 2013) Available at: http://tinyurl.com/ jag6699.

► Strauss, Valerie. Charter school ruled private entity for labo; relations. The Washington Post. ,(January 4, 201~)­

Available at: http://tinyurl.com/hhrn5jv.

► Lyderse"n, Kari. Firing of pregnant Chicago teacher becomes battle aver charter school unionization. Iii These Times. (August. 9, 2010) Avail8ble at: http://tinyurl.com/ jqytnct.

lhlSYATthlAI 1$ U1SU18Ul!D Ill ~MS I ff.DIM ~PAHINER\ llY ON Bf~ALr 01 rn, hl~UIHI[ OF IUH,f\ ADDIIIONAI 1Nf0~1,1AIION 13 AVAIIAH(C Af lhf LICPARl~E/11 Lil IUSll[t Yl'ASCIN[,I~~- or

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Quick Facts

► Region:-Midwest Region

► School Names (known a~): t> ·lndiana·Math and Science-Academy

("IMSA'.)

-► Total # of Schools in State: 3·charter schools currently open, 1 school to close at the end of the 2016-17.schOOI year'

► Total Student Enrollment 2015~16: 1,4761

► Charter Holder/Governing Board{s): t> Indiana· Math and Science Academy

- Indianapolis Inc. Organized as a non-profit with 501(c) (3) status Operates 1 charter school t•IMSA West")

t> Indiana Math and Science Academy - North Indianapolis Organized as a non-profit with 501{c) (3) status Operates 1 charter school ("IMSA North")

t> Indiana Math and Science Academy -South Indianapolis Charter School, Inc. Organized as a non-profit with 501(c) (3) status Operates 1 charter school ("'IMSA South")

► Charter Management. Services Vendor: Concept Schools

Emplr1 of Deceit: An lmes119w;,1 olthe GIJlen Charter SchOO Ne I work

► Regional Gulen Organization Oversight Entity: Concept Schools ("Concept")

► Regional Sister Nehvorks: Math and Science (IL); Horizon•(lll); Horizon.(OH); Noble (OH); Math, and Science (MN); Math and Science (Ml); Gateway (MO); Math and Science (WI),

► Total Revenues for the 2015-16 school year: $14,419,4903

► Network i:::ounders: t> Gultekin •John" Aytekin: Teacher,

Wisconsin Career Academy (WI); Teacher/Director, HSA Columbus ·(OH); ·Founding Principal, Indiana Math and Science Academy (IN);

·Superintendent for Concept (IN); Implicated in alleged de4 frauding of the E~Rate program and cur­rently under investigation by the· FBI; . Director of Accountability for Concept.•

t> Numan'Koca: Founder, IMSA; lncor­porator, The Holy Dove Foundation (iiow known as TurkiSh American Society of Indiana, lnc.);5 manager of Guven Transportation (Turkey); man• ager of Polen securities (Turkey); CEO of Elvan, LLC (TX and 1N);_ Pur­chasing manager at Bio-Botanical Labs (Canada);.real·estate S8Iesper• son for Century 21 (Csnada).'

Vic Ayckaert, Low Enrollment Leads to Indianapolis Charter School's Closure. USA Today (Feb. 7, 2017}, ava,la~e at: http://tinyurl.com/kdb6sf2 (last checked 4/17/2017).

Student er1rollment and demographic information a...aBab!e at: http //tinyurl.com/mbo5ens (IMSA - West); http://tinyurl.com/l6jvtto (IMSA North); http://t1nyurl.com/jvhi9J6 (IMSA - South) (last checked 4/17/2017)

Figure includes revenues ol lMSA North. IMSA Sou1h;a11d IMSA West audits available at http.//tinyurl.com/k4mmupk (last checked 4/19/2017).

Informal kin taken from: Resume avafable pg 99 at: http://tinyurlcom/mytqkaj (last checked 4/19/2017); Linkedin Profile available at: http://tmyurl.com/mf.1p3y2 (last checked 4/19/2017); Search Warrant application, pg 40, available at: http://tinyurlcom/jt9j4ed (last checked 9/8/2016)

Corporate documents in Indiana ere available et http://tinyurl.com/mmy5t79 (last checked 4/19/2017)

Numan Koca. Linkedln, available at: http./ltinyurl.com/kg~hw (last checked 4/19/2017).

lhl51Hlffl~I IS Ol!>IRIBUHD Bl AIIISHHIU & p~~IIHRS llPO•i e;H1r Of It-., f.CPUdll( 01 !UF•,E\ AD!il !ICNAL INI n~i.tAI 1011 IS AVAIi ~RI l Al r,.t OEPH IM; NT 01 /US 11c,. WASH1%ION, Dl

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Received by NSD/FARA Registration Unit 07/27/2017 6:11:32 PM Emplfl of Deceit: An lnvest1gat1on of the GL!len Charter School Network EmpireotDeceil: An llll/est19a1100 olttie GUI en Oiarter School Network

t> Kazim Eldes: Immigration fees paid.by Horizon (OH) to Concept;' Founder, IMSA (IN); lncorporator, Wisdom Educational Services, lnc.;8 lncorporator, The HOiy Dove Foundation {now known as Turkish American Society of Indiana, . Inc:);' Vice -President, Turkish American

•Society, lnc.;10 2007 Registered Agent, IMSA West (IN); 11 ·Math Consultant,

Concept.11

► Cemil Selcuk: Treasurer, Atlantis

Over.view

As Of the 2016-2017 ·school year, Indiana has 3 GUJen Organization charter schools in operation. These schools are overseen by three governing boards: Indiana Math aiid Science Academy Indianapolis Inc. incorporated in ·2006;· Indiana Math and Science Academy North:lndianapolis Inc. incorporated in 2008; and Indiana Milth and Science Academy South- Indianapolis Charter

· School, Inc. incorporated in 2012 (collectively, the "IMSA" network). In spite of the ~parat8 corporate entities governing each:school, there is significant overlap among all three governing boards. ·The first sChool opened in 2007, then 2010 and 2013: One school will close at the end of the 2016-17 school year. The IMSA network was the second attempt to start Gulen charter schools in

Foundation Inc.; lncorporator, Indiana Math and Science Academy Indianapolis lpc. and Indiana Math and, Science Academy Gary Inc (IN).13

► Tim Nation: Founding Board member, IMSA West (IN);1-1 currently Executive Director at Peace •Learning Center,'~ which includes Fet,hullah Gulen in its peacemaker curriculum taught to young students after a trip to Turkey wit~ the Turkish Friendship Center in lndianapolis.11

Indiana as two prior applications filed by other major GOien charter network founders failed in 2001." IMSA contracts with Concept ·Schools c•cOncept•), the co~rate·entity responsible for the Midwestern region of the Gulen Organization charter networks, allegedty·tor additional edu­cational management services for the state schools. On average, these.schools serve 10% English Language Learners vs. 5% state aver­age; ·85% free arid.reduced lunch population vs. 46% state; 15% students with disabilities vs. 15% state; 67% African American students vs. 12% state; 9% Caucasian students vs. 69% state; and 17%Jtispanic:students vs. 12% state. As these numbers indicate, the IMSA network serves high perceritages of vulnerable student populations.

Horizon Science Academy-Dayton Initial Audit. at 27 (July 27, 2007), available at: http:/ /tinyurl.com/l4dc3es (last checked 4/19/2017).

Corporate documents in Indiana are available at: http./flinyurlcom/hhlt79 {last checked 4/19/2017)

Corporate documents in Indiana are available at: hnp.//linyurl.com/mmy5t79 (last checked 4/19/2017)

" Corporate documents in Indiana Math and Science Academy - Indianapolis Inc. are available at: http:/ /linyurl.com/ k6nd571 (last checked 4/19/2017),

IMSA - West Replicatioo Application, at 242 (Sep. 20, 2013), available at: http://tinyurlcom/m6b9vdy (tast checked 4/19/2017).

Corporate documents in Indiana for these ent1t1es are searchable at: http.//tinyurl.com/lylalta (last checked 4/19/2017)

IMSA - West, 990s, available at: http://tinyurl.com/lrzjkf7 (last checked 4/19/2017)'

Tim Nation. Peace Leaming Center, available _at: http://t,nyurl.com/knhe2wJ (last checked 4/19/2017); T,m Nation, Linked In, available at: http·/ltinyurl.com/kohj8w7 {last checked 4/19/2017)

Peace Curriculum Includes Fethul!ah Gii!en. Yoo Tube (Feb. 17, 2012), available at: http:/ltinyurlcom/lnj~huh (last checked 4/19/2017); Peace Curriculum Includes Fethullah Giilen, Hizmet Movement News Portal (Dec. 12; 2010), available at: http://tinyurl.com/lr4k7uz (last checked 4/19/2017)

Staff Report, 21 Applications Were Reviewed, The Indianapolis Recorde1 (Dec, 14, 2001), available at: http://tinyurl.com/ m51ses9 (last checked 4/17/2017)

!hiS MAI HIAI IS DISlH~UlilJ Sl AMSllFDA'd .I ~Af;!'iCRS LLI' ON BfHAll Of !He ~CPU3tlt Of 1UR•H ADOll IONAI INfOHMA!ID'J IS AVAILA5lC Al !Hf Df PAhlMfNT Of IUSIICf, J'IIASHINGIO'i, OC

Received by NSD/FARA Registration Unit

School Ope• Student Demographic Authl>!lur Gowmlng ... "' I lnforiniitlon•

Indiana Math and Science K-8 23% ELL Ball State Indiana Math and Academy- West (IMSA. (at various 80%-FRL University, Science Academy -Wes!) times, has 12%SWD 2007-2014 - Indianapolis, Inc. 4575 W. 38"' Street been 6-8, 61% African American Mayor's Indianapolis, IN 46254 6-12, and 04% Caucasian Office of

K-12) 32% Hispanic Indianapolis, 2007-Present 2014

- Present

Indiana Math and Science K-12 ·04% ELL Mayor's Indiana Math Academy- North (IMSA 2010~Present 85%FRL Office of end Science - North) 18%SWO Indianapolis Academy - NOfth 7435 N. Keystone Ave. 77% Afric8n American Indianapolis Inc. •Indianapolis, IN 46240 06% C&ucasian

09% ~(spanic

Indiana Math and Science K-8 04% ELL Mayor's Indiana Math and Academy- South (IMSA 2013-Present 85% FRL Office of Academy - South - South) (Closing 18%SWD Indianapolis Indianapolis 2710 Bethel Ave. in2017 77% African American Charter School, Indianapolis, IN 46203 due to low ci6%"caucasian Inc.

enrollment) 09% Hispanic

Failed Applications ·-] Indiana Science Academy Denied in Indianapolis Crossroads

200, Charter Educational Schools Board Services, Inc.

Indiana Life Sciences Denied in Crossroads Academy 2oo2 Educational

:services, Inc, (name changed to Indiana.Life

Sciences ACademy Inc, in 2002)

Indiana Math and Science Denied in Ball State Indiana Math and Academy - Gary ZOOS due to University Science Academy -

lack of facifi- Garyfnc. ties, students. and teachers

Indiana Math and Science Fat1ed , Indiana Math and Academy- Fort Wayne or never Scie~ Academy

attempted Fort Wayne Inc. application

•Student demographic information was taken from the 2015-2016 school year. •ELL• indicates English

Language Learners, ·FRL· indicates students receiving free/reduced lunch, and ·swa• indicates stu­dents with disabilities.is

Student emollment and demographic information available at: http.//tinyurl.com/mbo5ens (IMSA • West): hnp·fftinyurlcom/16jvtto (IMSA - North): http.//tinyurl.comtjvhjgJ6 {IMSA - south) (last checked 4/17/2017)

lf<IS !.IAHflAl I, DISlRli!UliU 31 H,ISfci,DI'~ & PUJN,1,S tlP Oli 80hAlf 01 TH HOPU~LIC (JI 1Uh•il A~Dlfl8NAL INFOUtAllOII IS A\'ftllAillC Al IHt O[PAl'H!UJl 01 1\ll(ICC, WASHl'IGION, DC

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Received by NSD/FARA Registration Unit 0712712017 6: M :32 PM ~ofDaclit: An I,...,es!iga1io~ of1MSii/fJ11 Cna,ier School r.'etwork

A History ot Strategic: Ambiguity and:Contlic:ting Interests

ll1.e first attempt to open a Giilen, chartw school'in lndiana was in 2001. Turgayfaki,Osman Ar:.Jan, Afi Korkl)Utl ,{Western region founder),

and Vedat Akgun (Midwestem region •founder) attempted to open lnQiana Science Academy under the control of Crossroads Educational Services, Inc.'' The application·was denied, and Vedat Atcgun, Ali Korkmat; and Bulent 8ayraktar then applied,to·operiAhe Indiana life Se\ences Academy in 2002:.w

Afterthissecondfaifedapp!ication, Crossroad& Educc1tiorral'Services, Inc. changed ils name,10 Indiana Life Sciences Academy. Inc, and Gregory Taylor and Theresa Wright became the efltity's principcil officers; until its dissolution in ~009.

cmagine·lndiaoa Life•Sciente$,Academy West, Im:., an entit)I controlled· by the non•Gulenist Imagine-Schools education management otga­nila.\\on and Theresa Wright, would later amend its nal'f'le to lodiana Life Stiences Atademy, Inc, The school which resulted, lndiana'Life Sciences Academy West, closed in 2016.11

After the earUer failed attempts, the, Indiana GU!enis.ts tucceeded (n gaining approval for IMSA - Wffl, which opened in 2007. ·A ctiarter ~ication;to, tMSA Gary.failed sh4,rtty the,e­after:in)2008,.but IMS~ North opened·in 2010, followed by IMSA South in .2013. IMSA South is &!ready si-heduled ·to do$e at the end of the

2016-17 school year due to low enroHment.

The IMSA co~te entities n.mninQ theae sct«x,1$ rnive u~rgone frequent and seeming!y needless;name changes tha1 make it difficult to piece togethet the history of· the. GUleni.st

presence in the·state. Indiana Math and Scilmt:e Academv East lndie,na,po!is Incorporated, cre­

a1ed in 2008, -changed ~ . name to Indiana

Math,end,Science Academy North Indianapolis lnco,poraied in 2010. ln 2m2, if changed lts name again to itS current name: -Indiana.Math and 5':ient:to Academy·North ,Indianapolis Inc, It now operates IMSA North under that,mi,me. ln

201:l, the ·easr label was,recycled:and: incor• porated - the now defunct Indiana Math and Science Academy East, )nc. In ~008; J(azim

Etdes incorpora1ed indta-na -Math and/Science

Academy Soo1h lndianapolls Inc., which would dlssolve in 2010. In 2012, GUlenists inco,porated

the s.imilerlv-named Indiana msth and!Scienee Academy South lndinapolis (sic] Charter SchOOI

loc. Just a year later, articles of amendment changed:the entity'$ name 1o lm:fiana Math and Academy South lndianapolis Charter School, Inc. This entity•cunently operates 1MSA·S<Juth, Only tM tlt$t governing board irtCOfJ)OH\ted

in 2000, Indiana Math· and Science Ai::lldemy Indianapolis, Inc. current)y has the name it received at its founding. It operates the original IMSA school, IMSA West,V'

The goveroing boards:of alHhre& IMSA cor­·pon.rt& entities sub$tantiaffy overlap. ,seven indi'41duals serve on all three boards, and the largest, bo6rd features only ten members, In total, 12 indiOOuals fill 29-board seats a-cro$'S· all three entitles, and only two individuals (Ferit

Akova. and Atilla Sit) serve on anly one bOard, Unlike other states,,thf?' board$ anit not•Turki!lih

dominated, alt.hough the boardi still feature a substantiat Turkish,presence. !n addition to the over18pplng boilrd members, IMSA West loe:ned,

Corporate document$ in lnd1a11<1 i!lre e1-a1/abla at: http://tinruritomlfrnecvliq (/a/it checked 4119/2017). See o1lso S1aff Aepo,'1;2! Appl'1catioris Were R&1iieweo. The lridianapol,s Recorder (Dec. )4, 2001), availi>ble at: ntrp.J lt1nyurl(;(1m/ m5\ses9{1~ checked 4J17J20H}; Indiana 5c;ence ~emy C~m-i School Pfop(IS<tl ;,t '\, &lati'ia~ at: htt?:I /tir\yu1t carnt~m5s8w \ last checked 4/li'/2017)

"' lf'l(1rana U~ Stier.ces. Academy, Charter ScnQot Prosp«:tus, s..,-a·1ill.ble at: http;/ ltlnyuttcomnn.~?a t}as.t che<:.k.ed 4/;!&12011)

The las.t imagine charw s-chtlol in lftQ\s!na-lMi;ma Ute Slcieoces Aca0£-l'f)y W~-:---closed in 20'ro Dflan Peers MtCO'J, Strugg(ir,g Ind,' Cliartiar Scl\oo! W,I! Close at the tnd ot Vie Year;Cha!k_~( (M-l!I' l-9. 20115:). availa~ st http:/ltinyurl. com/kc/Ii~ {la.s.t checked 4/19/2017J.

11 Cof()ara1e documerits irr Indiana for the$e eritities are searchable at: http://linyurl.com//ylalt8 /laSJ checked 4/1912017)

\~\')\,\~lfi'Ut 1:; l)!Sl!..\,f~l':cl\ 51 ~\t~IC~i.l.~\\ \ l'~~Pli~> ltf'll~ :If~~\\ ljf fr< ~~~~3!){. l)f \\J~<!t, ~0(1//iO'/~! )/If Cl< IJAl IOI/ IS ~VA/l 01: Al I rf r,~~~/-',lf ~) OJ JUS! IC!. IVAfrl!;(;Jtl'L ~c

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IMSA North •start•up funds, cementing the lack of, distinction between ·too:entities and the

,potential fot.bre.tehes of fith.1tiaty dum,$. ~3

AU three schools currently· comract with Coneept -Schools, fOf management sertic:es. EaCh schOClt has an·agreernent requiring them to pat Concept 10% ~ 12% of their revenue.-lMSA •South also has a $330,000 fine of credit with. -concept.14

Concept's mos.\ setious contro-.-ersy · to da1e is the ongoing FBI investigation concerning

the co11U!liion of Concept.·empA,oyees ancl'their

venctors to defraud the federal E~Rate gr;,11nt program of millions of dmla,s.Z'li According ta

the ,released FBl's search- warran, apµlication, Concept e1'e£"utives purportedly violated the competitive bidding roles of the e-Rate program

by seleciit'lg a wndor complicit with Concept'$ plans. to. defraud f~f:late,outside ofthe- normal

Financial Abuse

Indiana requires its charter lie-hoots to undergo annual audits, which_ are made public. These audits showcase a series of ongoing: financial issues et ttie 1MsA network that are endemic to

all G-Jle'"' Org.tni2:ation charter netwarks. On the whole, tt\ese is.&Ul!'s demonstrate a laclt of fman~

cial'contro\s, documentation, ;md tr..msparet'ICY 1hat are critlcai 10 obscuring the "true use of $1a~e

and feder8'1 funds by Gulen Organization char­ter networks, loter~entity lending practices in

particular-from school'to scllool'and between

Em,ltreofllet:tlt: An I/M!Stt9at,ori oftliefutlen Charter Scl'iool Network

procurement ptocess. Then, Concept's Ctiief

Information Office, alle~dly directed· that vendor:to di'fert hefty "subcont"5cts~ to affiliiltW TuOOsh individuals and companies in exchange for a cut of the proceeds. The ac.tua!'work:pur~ portedly was performed by Concep1·emptoyees .themse-tves, not by the complicit vendor who was a,oprove<f•by E-Rate-!o provide the work, or the so•named companies and, Turkish vendors

.for the subcontracts.~ Formef ·Concept e:,cec­

utive, and Ohio Founder Oz:gl.lr Ba(ooy was one of the purportedly fraudutently enriched .Turkish

veridors.u While 8a1Soy's· busine$.& is under SIJS­·picion in the,FS! investigation andiha1, already

been raided, concept cootinues: to give him .and the- other Turkish-owned vendors named in the search warrant application substantial

!business.u This,. investigation is ongoing and includes IMSA,ottier Concept st:hools, vem:tors, and Concept qJfices located in, both Ohio .and

.Illinois.

:schools and Concept-::-are a known warning sign for money laundering.~ ln•lndiana, IMSA West h,1s:loaned money to tMSA.NOrth; mean• while, IMSA South has a $330,000 crefflt ra<:ility

with Concept. In 2014, the school owed Concept

$280,000; in 2015, 1he $cl\OQl·owed $330.000 to Concept; io,ZOll:i, the·$Ch0ol·owed $2.45,000 to Concept.

There are-issues with ci<=curately·docu(!lent­ing attendance, absences, •Bnd wilhdrawals of

" !MSA West, 990-s, ..:.-ail.able at: !\ttiJ'f(tin~u1tt::om/Jri.iW (/as~checked '1/19/2017); IMSA North, !:190:s, a,.-a,ilaQ!e- .at: http:// tinyurl.com/J<goqh5j (last Checked #l9/2017J, IMSA SOorh, 9905, ava,l.rb/e at http.J/11nyurl.comlm1xwuJm (fast c/1«1«<! 4/19)2011).

,. Sc/lOO) oud'Jts from the ye-arts 2001·:CQ16 lire se-arcchat>le at: htq:i:J/liny.irl.oorn/lrnQ5Sgw /last checkeil 4J191W)7)

" Dan Milialopouloi; arrd Jon Seide~ Cha~, Firm Su,,oected of Cheating Federal GrllfTt Pmg,11111, Ctiicago Sun·'Times \Dec~mbet 16, 2015-), ~"ailab\e at: http://!inyurlc.C(!l/i:3snbad \!ast c.~~ !H8/20i6)

"' Sea1ch Wa1t1lN1 app\icat,on ;r,,ail~e &l: hl:tp·Jftin'fllrt.com/jt9j~ {\asl checked 9/l!./2016)

" See IQ.; see also Dan Miha,!opo\;loSaOO Jon Seide!, C~rtef Fm,, Suspwedof Chnlil'lg Federal Gram Program, Chi.::~ S(_u,./im.es (De,;ernbet W, 2015), a~a,\aD\£! at: htq:,:/Jtin!l'urli:omlj3snoad {last <::hec.ked: 9/812:01fl)

,. See Mihalopot.L\os, Dan, 711f91Jte4 Firms Stilt Get Tax Maney A/1.arCM<'tet Raids, Chicago S,.111.T,me; http:/ itinyur/comJ jm'i~li {lta1.t checkoo 9JB/2n"\6\.

21 The Mti-Mo,,ey lauflOerinQ .i.ro C\l\lntering Te,-torisi. l"ir.anc:ing G1.1id~r,ce,1t). accomPMI)' the feden,l ano inte-1r-.a\,onal !egi~t;Qrt !,it numen:i•JS urtlJWa! tlinsactons made with little t<J no (vs.ufieatJon be.tween <J:fWiste,j eot1tie.s as. w.imir,g signs. $~ Guidance at l'l-ttp://tir1yu,1com/ibSt;x.el (last checlrea 917/2016),

)~)5\J~l:~1~1 IS D!S}Pl'>l-1\Hl a1 l',1-Sit~~I\I '> ,~f,\\i·,~~ \jf{l'f3C~~II ll\ 1~, f'ffUStrt ll! !l.l~•il A/lt,/1/D~AJ l'H O~M '-110/i IS ~V~I! A~! ( Al lrf (Jf/'lfil'o!i ro DI IU~ rrn, \\'~St-11!(,JON, DC

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students throughout the Gulen Organization charter networks.·Failure in:this:recordkeeping, intentional or not, may allow a,school-to gamer the most public funds,while educating.the least number of students. If intentional, this.method particularty takes advantage of "problem• stu­dents, whose truancy is purposefully unreported while the schools continue to_collect:their FTE funding, Similarly, there are issues with accu­

·rately-documenting,free and·reduced meals for students throughout the Giilen Organization charter networks. Again, this method·would be effective for garnering the most public funds while serving the least number of students.

The numerous audit findings occur across multiple years and at multiple schools, including:

t> •Lack of Compliance with Required Financial Procedures and Accounting Standards:

t> Lack of proper controls and segre­gation of duties for ·the -collection, depositing, receipting, and refunding of money;

t> Failure to :timely make deposits, in spite of numerous and repeated promises to correct this issue;

t> Failure to reconcile receipts; t> Lack of documentation for refunds; t> Improper· calculation and failure·to

maintain balances for student text­book rentals;

1> Lack of a formal policy for handling uncollectible school lunch:and text­book rental accounts;

1> Lack of controls to verify free and reduced meat applications;

t> Lack of documentation justifying textbook reimbursements and free and reduced meal reimbursements;

t> Inappropriate dl?terminations on,free and reduced meal applications;

1> Lack of documentation for credit

card disbursements and electronic funds transfers;

1> Use Of a credit card and,electronic funds transfers that by~pass required cash disbursement procedUres;

1> Payment of interest and sales tax on

credit card transactions; t> OisburselTlent of : $500 petty cash

fund without documentation;-1> Failure to appropriately bond all indi­

viduals handling funds; t> Improper recordation and classifica­

tion of disbursements and receipts; t> Excess cash carried further between

years; 1> Understating cash on hand30; and t> Failure to maintain documentation

supporting the allocation of salaries to Title I activities.

► Improper Student Attehdance Records which Can Lead to Increased Funding: t> Incorrect attendance reports.31

On top_ of these financial concerns, the Office· of Education Innovation for the Mayor of Indianapolis. maintains reports on the IMSA schools. These·.reports·detail similar financial, educational, and governance issues -common among GUlen charter schools. The numerous criticisms occur across multiple years and multi­ple schools, including:

► Governance Issues: t> Untimely submission of documents; t> Board communication through

e-mails in violation of the Indiana Open Door. Law;

t> Lack-of formal method·to evaluate the superintendent;

1> Failure·to- evaluate the performance of the school leader, the management organization; or. the· board itself; and

t> Failure- to properly post or update board meeting,agendas or meeting

"' In 2013, the IMSA - North supplemental audit revealed that the school unders1ated its cash on hand in the Indiana Department of Revenue by $202,066

These findings were taken from a review of school audits from the years 2007·2016, searchable at: hnp://tinyurl.com/ lmq55gw (last checked 4/19/2017) .

IHI'> \.IA!fl'IAI 11 UISIRl~UlfV :lY ~MSltROAM ~ PAHlNEfiS ILP GN Bfh~.LI Of lhf ~EPUilllC 01 IIJliHT AI.IDIIIONAI INfU~MAIION IS AVAtL;B1; Al I Hf UEPA~lldrnl 11/ l~SIICE, WASHl~Glll~. QC.

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times and locations.

· ► Financial Issues: t> Lack of sufficient days cash on hand; t> Years with negative net-income; t> Insufficient current ratio; 32

t> Insufficient debt service coverage; and

1> , LaCk of resources for teachers.

► Improper Student Attendance_ and FRL Records which Can Lead to Increased Funding: 1> · Missing documentation for' FRL

students.

► Teacher. Certification Issues:

Bond Financing.

IMSA does not have any known municipal bonds. Concept Schools and its affiliated real estate arm,,howevei", have used bond-financing

Real Estate

Of the three IMSA schools, one school (IMSA West) owns its own building and appears to have recently pul"Chased the building,from,an unaffiliated third party. Before the:purchase of the property in Januai"y 2016, the school leased its facility fn)m the same pa~. lMSA North cur­rently leases its facilities from what appears to be an i.Jnretated entity.3<1

IMSA South leases its facility from 2710 Bethel LLC, an Indiana LLC that. is a wholly owned subsidiary of Concept's real estate arm,

Emptreal Deceit: An Investigation al the Giilen Charter School Network

1> Teacher retention issues; 1> Deficiency · in amount of appropri­

ately licensed.teachers; and t> Tea.chers ·with expired or question­

able licenses.

► Special Education and ELL Issues: 1> IEP services provided in.hallways; 1> Lack cif , Individual Language Plans

(ILPs) for ELL students; t> Missing information · in Special

Education and IEP filE!s; t> IEP goals lacked specificity and mea­

surability; and t> Concerns about licensure of Sj>ecial

Education staff.33

for schools in.other states. For that reason,.the situation:should be monitored in-the event that •IMSAdoes apply.for.bond financing.

New Plan Learning.3i. Murat Arabaci, the presi­dent of New Plan Leaming, Inc., created 2710 Bethel'lLC in.2012. 2710 Bethel LLC shares the same address and'suite number·as New Plan •Learning.38 The school's total: lease expenses (facility :lease plus office equipment lease) for ·2014-2018 are: $262,643 in 2014:- $283,303 in ·2015; and $288,662 in 2016.3' Wrthout additional information or comparisons, the reasonableness of amounts spent on•the facilities lease 0cannot be determined. BUt these payments warrant fur­ther investigation.given,the fact that New Plan

An insufficient current ratio indicat~ that a school"s assets are too low and lidbihties are too high, imperiling its financial stability.

" Tl">ese repo1ts are available at: http //linyud.com/kqczlfl (IMSA - West): http:l/tinyurl.com/mphf6ff (IMSA - North): http·l/linyurl.com/nKofa3k (IMSA • Sou1h)

,. lf\diana corporate records available at: hnp://tinyurl com/lylalt8 (last checked 4/21/2017). Property records are available at: hnp://tinyurl com/kr8juov (last checked 4/17/2017).

'" IMSA SoUth lease information found in audits available at: http://tinyurl.com/k4mmupk (last checked 4/2112017) Property records are a.,.ailable·at: http://tinyurl.com/kr8juov (last checked 4/17/2017)

• Indiana coiporate records aY<!ilable at: http://tinyurl.com/lylalt8 (las1 checked 4121/2017).

" IMSA - South lease information ta Ken from audrts available at, hnp://tinyurl.com/k4mmupk (last checked 4/2112017).

lhlS lilAl!AIAL IS w;rn1auTEO ill AMSTf/<llA\t \ ~AF!NCR:i 11 P vr1 6fhAI f OF !Hf HPU~ll( Of l~R,t1 Al)UIIIO~AL ll<IORMAlll)IJ I~ A'/All,\~IE Al I Hf lliPAf,IMiNI Cl 1us11n, e/AOC.1~01011, UI.

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Received by NSD/FARJ\ Registration Unit 07/27/2017 6:H:32 PM EmplJt of Dacett: An lmestigatioo ol the GUI en Chaner School NeiWOfk

Learning apparently overcharges- its Concept­

controlled SChools in other states and is a prime tenet· of GUlen Organization's suspicious real estate·dealings.311

Excessive use of the H-1B Visa Program

Like all GUlen Organization charter net­works, the IMSA network utilizes the H-1B·visa

program to immigrate large,numbers of Turkish

GUlenists into the United _States for employment in the schools and' network. From 2001~2016, IMSA filed 83 H-1B visa applications for foreign workers.:1•-While Gulen charter networks claim

the heavy dependence,on,the H~1B program is

to hire hard-to-firid math and science teachers, these applications were.filed for such positions

as: educational•and school:counselors. educa­tion administrators, school business,managers,

ESL teachers, network administrators, accoun­tants, Turkish teachers, and ·assistant directors.

IMSA use the same immigration attorneys to

file and process their H-18 applications as other

known Gi.ilen Organization charter networks, vendors, and cultural associations, indicating

once again the existence of an overalt·network.

For example:

► Remzi Kulen. IMSA used Kulen, a New

York-based attomey, to file numerous H-tB·applications. Kulen also filed appli­

cations for:

t> concept Schools (9H, IL, MO, IN, Ml, MN),

1> Gateway (MO)

1> Pioneer (MA) C> Niagara·Foundation'(ll)

C> Young Scholars (P~)

t> Golden Generation Workshop .Center (PA)

t> Btue Ocean Construction (FL) t> Academy of Science, Syracuse,

Buffalo'(NY)

t> Arts and ·Science, Bergen, Passaic (NJ)4o

► Nuzhat Hafeez: IMSA schools used Hafeez, an· lllinois~based attorney, to file numerous H-1B·applications. H8feez also

filed H-1B applications for:

·1> Concept Schools, Inc.

1> Niagara Educational Services, Inc. (IL)

1> Niagara Foundation (IL)

1> The Core Group (JL)4'

►. Mustafa Gene. IMSA used Gene, an Illinois-based attorney, to file niJmerous

H-18 applications. Gene also filed appli­

cations for: t> Concept School$ (OH, IL, MO, IN, Ml,

MN)

1> Gateway (M0)0

'" See, e.g., the Te,;as, Ohio, and Oklahoma for more information on this pattern of fraud

" !n another example of st1ategic ambiguity, lMSA schools use several drfferent versions of their names to make 11 d•fficutt to aggregate how many H-1B applications they are filing. The sum total of all of their organizations is 83, and the numbers supporting thiJt iota I are located 'at the following lmks: from 2001-2015, http://tinyurl.com/mhfltf8 (53); http://tinyurl.com/ kku2st>g (4); http://t1nyurl.com/l67e4lm (18); http://tinyurl com/k4hdddf (1~ http //tinyurl.com/jw7m2a3 (1). For 20)6. refer to the 2016 data on the US OOL website, ava,!ab!e at: http://t1nyurl.com/zm5dvec (6) (last checked l/3012017)

"° L,st of entities represented by Aemzi Kulen. available at http://tinyurl.com/gptwx5x (last checlo:ed 4121/2017).

Hafeez profile listing entities represented for H-lB visa work, available at: http://tinyurl.com/m..,nttav (last checked 4/1312017)

., List of entities represented by Mustafa Gene. a...ailable at http./ /tinyurlcom/ko771iqq (last checked 4/20/2017).

THIS MAlfSIAI IS GISH18111~0 ~i AMSTfROA•J & PH!NfRS LLP Q~ 3EHALI or !Ht litPUBLIC 01 T~H••I. WfllllU·~Al INfOAM~IION ISAVAIIABlE Al IH OEPAf.lM[NI 01 IUCIIU. WASHl~C10ti,0C

Received by NSD/FARA Registration Unit

EmptreofDKeH: An lnvestrgat10'1 olltle GOien Charte1 Schod Network

Scandals, Investigations & Notable Activities

As detailed above, federal agents ar~ investi­. gating I MSA as part of a broader probe into E: Rate

fundil'lQ fraud by Concept.'"·ln 2015, two Arizona.

Members of Congress, U.S. Repre~ntative Raul Grijalva and U.S. Representative Ruben Gallego, wrote letters u;ging the U.S. Department of

Education and the. Government Accountability Office respectively: to urge an investigation of

charter schools affiliated with Gulen. These let­

ters were sent in light of the recent raids of the

Notable Turkish Vendors

►- Concept Schools, Inc.: Concept is a com­

prehensive services vendor that controls

human resources, fiscal management, school, design, cur,iculum, account­

ability, compliance, and reporting for a

twelve.percent,fee of each school's total revenues, Currently, Concept is,the con­

tracted nonprofit management' services vendor for thirty such-charter schools,

with seventeen schools in Ohio, four in

Illinois, three in Missouri, three in Indiana, one,in.Michigan, one in Wisconsin, and

one-in Minnesota.•~ Gultekin Aytekin, a

founder of IMSA, is currently the DirectOf'

of Accountability at Concept.48 Between 2007 ,and ·2016, IMSA paid Concept

$5.496,673.•1

► 2710 Bethel LLC: 2710 Bethel LLC was

Concept Schools network located in Indiana, Ohio, Illinois, and other Midwestern_ states for · suspected.defrauding Of the,fedei'al:E-R8te pro­

gram by Concept's Turkish administrators and

vendors. Both Grijalva• and Gallego were con­cerned about the connections between concept

and,the·5c?noran network·in Arizona:uncovered ·by ·investigative journalisms at the time and

·asked for a thorough investigation.44

created in 2002 by Murat Arabaci, the

president- of New Plan Learning, Inc., and ·owner. of the facility leased by IMSA

South.48 New P4an Learning acts as a

non:-J)fofit umbrella organization for

several subsidiaries.49 Together with its subsidiaries, New Plan Leaming buys,

renovates, leases"and sometimes sells

properties to Coni:ept-manaQed schools, allegedly as a supporting org~nization.to

those schools.

► Advanced Solutions for Education:

Advanced Solutions for Education, owned by former Concept employee

Ozgur Baisoy, is also implicated; in the

ongoing FBI investigation regarding the alleged defrauding of the E-Rate program.r.o The company served-as-an

'"' Bill McClce1y, Charter School Indicates FBI Raid Is Over Federal Grant Money, lndyStar (June 6, 2014), available at: http:// tlnyur!.comlkv6pjh9 (last checlo:ed 4/20/2017),

.. Representati...e Grijalva's letter is avi!dable at: http.//tinyurlcom/hnhcbq5 {last checked 3/14/2017). Representative Gallego's Jetter is available at. http //tinyu,lcom/,yrhfJu (last checked J/14/'2-017).

" See Concept Schools network, available at: http:f/tinyurl.com/zJdBqsb (last checked 8/26/2016).

.. Linkedin Profile available at: http://tinyurl.com/my9p3y2 (last checked 4/19/2017)

Figure includes payments by IMSA North, IMSA South, and IMSA West, audits available at: http:/ /tinyurl.com/k4mmupk (last checked 4/19/2017), and IMSA · West 990S ava;!able at: http://t,nyurl.cooi/lr21kf7 (last checked '4/19/2017)

• IMSA - South lease information found in aud,ts available at: http://tmyurl com/k4mmupk (last checked 4/21/2017). Property records are avatlable at: http://tinyurl.com/kr6juov {last checked 4/17/2017)

" New Plan Leaming. Inc. 2011A Bond Official Statement pg A-4, A•!>, available at: http://tinyurl.com/zxoauxp {last checked 9/612016); see a/so the Ohio State Narrative

"' See Dan MihalOl)OUlos. Targeted Firms Still Get Tax Money After Charter Raids, Chicago Sun-Times http://tinyurl com/ i,Z.mzevh (last checked 9/812016).

!~15 MAHHl~I I!, w;1a1,u!EO ~' AMSlfHAM /, PAhl~fR> LLP ON S,~Alf Ol lhf f<CP~rlllC Of TUh!,D i,DOl!IO~~.l INfOfi•~AliON IS ~VAll~~I f Al lot L\CPHT~fNI 01 IUS!ICf WASfll~GTON, OC

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Received by NSD/FARA Registration Unit 07/27/2017 6:11:32 PM Empireaf Decefl: An lrivesuga11on ollt1eGlllen Chan er School Network Empire af Deceit: An !nvestigat:on of the Gillen Chaner School Ne1work

E~Rate funding consultant to the schools.

In 2014, Guftekin Aytekin filed an FCC Form 471 on behalf of, IMSA. The form

names Ozgur Balsoy, who is implicated in Concept's suspected E~Rate fraud, as the contact person and.Advanced,Solutions

for Education as a consultant.~1

► The core· Group: The Core Group, owned

by Ertugrul Gurbuz, is currently· under federal investigation as:one of the ven­

dors Concept,allegedly•used to defraud the E-Rate program.62 ·The company and

its subsidiaries haYe received. ove,·$3.2

niillion dollars from Concept schools.53 In 2014; Gultekin Aytekin filed an FCC Form 471 on.behalfaof.lMSA. The form names Core Group, Inc. as the service provider.~

Gillenist Cultural Foundations

► Niagara Foundation: The Niagara Foundation is· a major Turkish Gutenist

cultural association based in Chicago. Gulen is its honorary president.~ Niagara

Educational Services, Inc., oversees· both the Niagara Foundation and the Science

Academy of'Chicago, a private GUlenist sChoOI. 111 2007, the Niagara ·Foundation gave an extensive loan to Breeze Inc. to

purchase new properties for ·Concept charter schools,M Several Concept employees as well as school employees are members of the·Niagara Foundation. It maintains-a presence in Indiana that provides free/low•cost trips t_o Turkey for legislators, as-well as hosting dialogue dinners and fundraisers.5

'

► Turkish American Federation-of Midwest (TAFM): TAFM is a member of the Turkic

American Alliance (TAA).!>11 The .TAA posts articles_and op-eds written.by Fethull8h Gulen.,;g TAFM has four member orga­

nizations in Indiana, three of which overlap with the Niagara. Foundation:

Niagara Foundation Indianapolis, -Niagara Foundation ·Lafayette, Niagara

Fou~dation Bloomington, and- Turkish

American Society of Indiana."° TAFM pro­

vides year-round· informational bulletins to members of.·Congress, sponsors con­

gressional trips to Turkey,· and provides a.platform:for Turkish American activism

and advocacy.~ One board meniber for IMSA has served·on the·board of TAFM,

as described below.~

► Turkish American Society of ·Indiana,

Inc. {TASI} (formerly The HOiy Dove Foundation, Inc.): Two IMSA founders,

USAC Form 471 available at: http;/ /tinyurl com/mw4ewf8 (last checked 4/21/2017)

"' See M1halopoulos, Dan. Targeted Firms Still Get Tax Money After Charter Raids, Chicago Sun-Times http./ /tmyurl.com/ jzmzevh (last checked 9/8/2016).

" Id ,.. USAC Form 471 available at: http.//lin)'\.lr1.comtmw<lewf8 (last checked 4/21/2017).

.. See http://www.niagarafo1.mda1;on.org/ for informat,on about the N,agara Founda11on and http.//tmyurl.com/d8tfv5c for information about Giilen as Honorary President (last checked 9/6/2016)

"" Aud,t avajlable at: http://tinyurl.com/haos4Qu (last checked 9/8/2016)

" For a description of a legislator's trip to Turkey w,th the Niagara Foundation, see: http://tin)'\.lrl.com/mkfando (last checked 4/20/2017); BilalEksili.com, available et; http://tinyurl.com/m477Jnd (last checked 4/21/2017).

"" Turkic American Alliance, ava~able at: http.l/tinyur1com/mm9ko3r (last checked 4/2112017).

,. Turkic American Alliance, available at: http://linyuri.com/ll5~8rd (last checked 4/21/2017)

"" Turkic American Federation of Midwest, available at: http://tinyurl.com/lgz6odt (last checked 4/21/2017).

Turkic: American Federation of Midwest, available at: http://tinyurl.com/k7occf5 (last checked 4/21/2017)

., IMSA - West, 9905, available at: http:/ /tinyurl.com/lrzjkfl (last checked 4/19/2017). IMSA - North, 9905, available at: http·//tinyurl.c0m/kgoqh5j (last checked 4/19/2017); TAFM, 990s, available at: http://tinyurl.com/luzmomm (last checked 4/19/2017).

I w, MAI E kl Al IS lilS I klH~ I FD ill AMS] tf.lJAM ~ p;R I Ni HS 111' ON l!fl1AL I Of ml Rfl'U81 IC or IU~ d I. AUIIIIIU'JO.l H!F0R\!ATI0N IS AV~IIARI t Al !Hf MPABIMENT Of l'JSIIC!, WASHINCrDN, DC

Received by NSD/FARA Registration Unit

Kazim Elde5: and·Numan·Koca,.incorpo­rated TAS1-as The·Holy Dove Foundation

in 2004. The third inco-rJ)Orator, Turgay

Faki, attempted to founcMndiana Science

Academy in •2001. Othei" IMSA. board. meniberS later served on the board or

workfor TASl.63 TASI organized dialogue

events and friendship trips to Turkey.14 ,lt

dissolved-in 2014 .. ln:another example of

strategic ambiguity, multiple ertities con­nected to individuals with Gulenist ties

in Indiana.have used names based on ·TurkiSh American Society.-

,friends of Gillen Spotlight: Bilal Eksili

Bilal, •Eksili exemplifies the Gulen

Organization's cultural and prilitical outreach

with -political and community leaders. Eksili's roots are in the IMSA network where he served

as vice_ presidE!nt and director of IMSA West end

IMSA North. His wife was also employed at IMSA

West.111 Eksili also served as executive director of •the Niagara Found8tion Indiana, vice,president

of TAF:M, and president of ihe Turquoise Council of Americens,and:Eurasians.(TCAE),-an entity

active in GUlenist:po1itics,nati0nally-and at,one

point -investigated 'by the ·Congressional Ethics

Committee." Eksili has also worked wtth .Ant Travel & Tours and Artun Travel in Chicago, out­

fits that arrange the Gillenist junkets to Turkey.111

· His person at website features news critical of the Turkish,government,and favorable to Fethullah

GUlen.~• He currently works-as a consultant in

Washington, D.C.10

► Trips: Eksili'.has hosted and coordinated

multiple trips to Turkey across,his differ­

ent roles to build political support for the

Gulenist agenda.'1

► Donations: ln·2013,· Eksili donated $5,000 to federal campaigns. At the time, he

worked as the vice presi_dent of the Turkic

American Federation of Midwest but only earned a salary of only $31,592.n

This led one news report to questiOn the legitimacy of the donations.'] Since

2010, he has given over $33,ooo:to-polit­

ical campaigns, including: $5,000 to

Corporate documents are available at: http://tJnyurl.com/mmy5t79 (last checked 4/21/2017);

.. IMSA - West Replication Apphcat,on, at 85 (Sep. 20, 2013), ava,lable at: http://t1nyurl.c:om/m8b9vdy (last checked 4/19/2017),

"' Corparate documents are ava,lable at: http://tinyurl.com/lylalt6 (last checked 4/21/2017). Murat Dundar and Emin Ozdemi1 serve.on IMSA boards IMSA - West, 990s, available at: http://tinyurl.coni/lrzJkf7 (last checked 4/19/2017); IMSA - North. 990s. available at: http·//Myur1.com/kgoqh5j (last checked 4/19/2017); IMSA • South, 990s. available at http:// tin)'\.lrl.com/mzxwu3m (last chec:ked 4/19/2017)

"' IMSA - West, 990s, available at: http://tinyurl.com/lrljkf7 (last checked 4/19/2017); IMSA - North, 9905. available at: http://tinYurl.com/kgoqh5j (last check.ed 4/19/2017); IMSA - South Apphcation al 115, available at: http.//linyurl com/ i)()(kags (last checked 4/21/2017)

•1 Linkedm Profile available at: http://tinyurl.com/t9vl)(B5 (last checked 4/19/2017); BilalEksili com, available at: http://t1nyurl

com/m477jnd (last checked 4/21/2017). TCAE has a histo,y of questionable involvement in trips to Turkey and Azerbaijan. Paul Singer and Paulina Fir-021, Turkish Faith Movement Secretly Funded 200 Trips for Lawmakers and Stafl, USA. Today (Oct.29.2015). ava,lable at: http://t.rJyurl.com/m3ztm7Q (last checked 4/20/2017); Srolt Higham, Steven Ric:h & Alice Crites, 10 Members of Congress Took Trip Secretly Funded by Foreign Government. The Washington Post (May 13, 2015) (discussing former senator from lridoana Richard Luga r's speech at an Alerbaiiani conference ostensibly sponsored in part by TCAE), available at: http://tinyurl.com/rtxqnsm5 (last checked 4/22/2017)

.. IMSA West Replica11on Application, at 65 (Sep. 20, 2013~ available at: http://tinyur!.com/m6b9vdy (last checked 4/19/2017).

00 Bila!Eksili.com, available at: http:l/tioyurlcom/m18ntgw {last checked 4/21/2017).

,. BilalEksili.com, available at: http:/ /tinyurlcom/m477jnd (last checked 4/21/2017)

Id.; 2008 D,rcctor's CommuMy Leadership Awards, FBL available at: http./ /tioyurl com/myumu6g (last checked 4/22/2017)

Paul Singe,, U.S. Lawmakers Got Suspect Turkish Cash, USA Today (Nov, 19, 2015), available at: http://t1nyurl.com/ me9aett (last checked 4/22/2017).

" Id.

!HIO M~T[RIAI ISOIOIRl~l/Hll OT ~M~lfl•Ul\l g PAHJNCII~ llf' ()N llEHlt Of IHf IH~'.lllllCOF llJk,fl AIJUIIIONAI l~IO~MAIIO~ ISAVAIJABlf Al IHf l)fPIRllll~NI Of IIISTICC, WAse1111,11:·~. IJC

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Received by NSD/FARA Registration Unit 07/27/2017 6:11:32 PM Empire of Deceit: An lflYestigat1on of the GUlen Charter Schoo! Network Empir1 DIDllceh: An lfl'les!lgaoon of tile GU ten Charter School NetWOlk

Todd Rokita (U.S. Representative for Indiana's 4"' Congressional District), $2,500 to Joseph Donnelly {U.S. Senator

for lildiana), and $2,650 to Andre Carson (U.S. Representative for Indiana's, 71h Congressional District).14 The IMSA - South website features praise and favorable testimonials from both Rep. Rokita and Sen. Donnelly.r..

► Political Networking: Eksili networked extensively with Indiana and national pol­

iticians. He has been pictured with Hillary Clinton/11 Bill Clinton/' Jeb,BuSh,11 Sen.

Ted Cruz,'' Gov. Scott walker,ao former U.S. Sen. from Indiana I Richard Lugar,81

FBI Director Robert Mueller,12 U.S. Rep. from Indiana .Andre Carson,113 fom,er •Indiana Lt. Governor Becky Skillman,14

and Virgil Madden, a policy advisor for tf'ldiana Lt. Governor and proposed. board member for IMSA South.e Notably, former Sen. Richard Lugar would provide

.a video greeting,as co•sponsor for the Niagara Peace-and Dialogue-Award! for the Niagara Foundation posted to Bilal Eksili's YouTube channel."'

Individuals Caught in the-Giilen Organization Web

II is quite:common for-the charter networks within a region to shuffle their Turkish H.:.1B visa teachers from school to school, as well as between education management vendors·such as Concept. This is juSt a small number of indi­viduals,with these overlapping ties throughout

the region, which further demonstrates the region's interconnections. Not.ibty, this shuf­fling only occurs with Turkish employees.

► Ali• Kuran: ·reacher/Dean of Academics/ Director, Horizon (OH); proposed. Principal of IMSA ·South;a1 Princi~I, Quest Academy (IL) when school cut ties with :Concep1;n Principal; Chicago Math and Science Academy (IL).•

► Mustafa Yazici: Teacher/Dean of Academics/Director, Horizon (OH); School Leader/Proposed Founder, IMSA (IN);'° currently Executive Director, Turkish

Campa<Qn contribut,ons are seaichable at http://tinyurlcom/fgdcj (last checked 4/21/2017)

" IMSA - South Testimonials available at: hnp.lltinyurlcom/m4th7wg (last checked 4/21/2017)

BIiai Eksili on Ftickr, ava,iable at: http:f/tinyur1.com/ml49gch (last checked 4/21/2017).

Bilal Eks1h on Flickr, available et: http://tinyurl.com/n52d5al (last checked 4/21/2017)

Bilal Eks,li on Fl1ckr, available at: http://linyurl.com/lwesq6w (last checked 4/21/2017)

B,lal Eksili on F!Jckr, available at: http://tmyurl.com/lJ8xpmw (last checked 4/21/2017)

., Bilal Eks1h on Fhckr, available at: hnp://tinyL1r!.com/mjtb8t9 (last checked ◄/21/2017)

Bilal Eksih on Flickr, available at: hnp://t1nyL1rl.com/loctdn55 (last checked 4/21/2017)

"' Bilal Eks,li on Flickr, avarlable at: http://t1nyurl.com/mcd54rc (last checked 4/21/2017). 13 TAA Slaff, Congressional Ramadan Dinrier al the U.S. House of Representatives, Turkic American Allicance (July 16, 2014),

available at: http:/ /tinyull.com/mho4yut {last checked 4/21/2017).

.. Bilal Eks,h on Flickr, available at: nnp·/ /linyurl com/kad4pad\last checked 4/21/2017)

"" IMSA - South Application available at: http://tiny1,1rl com/lxxkags (last checked 4/21/2017); B,lal Eksd1 on Flickr, available

at: hnp / flinyurlcom/19j5d6m (last checked.4/21/2017).

"" Bilal Eks,I, on Youtube, BVllilable at: http://tinyurl.com/kxer8l5 (last checked ◄/21/2017)

"' IMSA South Application at 81, available at: http://tinyurl.com/lukags (last checked 4/21/2017)

"" Pam Adams. Quest Academy Cuts Ties with Management Company, EXtends Deal with District 150, Journal Star (Jan. 22, 2015), available at: http://tinyurl.com/koq86ay (last checked 4/21/2017)

"" CMSA Press Release available at: http://tinyurl.com/mv66vuy (last checked 4/21/2017); Illinois H,gh School Association Contact Information. CMSA available at: http.1/tinyurl com/l(Sg8qks (last checked 4/21/2017)

"' IMSA West Replication Application, at 94 (Sep 20. 2013). ava,lable at: hnp.//tinyurlcom/m8b9vdy (last checked 4/19/2017).

,~1, MAlcHIAL IS DIST~lilUIUJ lll AMSIERDA•~ \ l'AfilNfl'S llP ON 31HAll 01 lf,I R~PUBlll Of r~in1 AOOIIIONAL INfQIM~IIO'I IS ~VAllABI E Al IHE DfPAh!M[Nf U+ IU$1ICf, WAShlNGIO~. [IC

Received by NSD/FARA Registration Unit

American Society of Chicago (IL),91

► Levent Elibai: Employed at Ramson Contractors • GU!enist construction vendor (Western regiorl);92 : Employed, at, Quality Builders of Midwest - Gutenist construction vendor (Midwestern ~ion};93 Director of Purchasing, Concept (Midwestern region);114 Operations Manager, IMSA (IN),9~

► Hasan Akkaya: Assistant Director/ Director, Horizon·(OH); currently director IMSA(IN).91

► Murat Oundar: Board member for IMSA;" President, TASl;98 Secretary, CrossroadS Community Center, Inc. (d/b/a Turkish American:SocietY);" currently Associate Professor, Indiana University/Purdue University,·Indianapolis.100

► Ali Korkmaz: Co-Founder of attempted Indiana Science Academy and Indiana Life Sciences Academy;'01 Board Member Magnolia (CA);102 Researcher, Accord (WE!stern regi0n);,Strategic•Data· Project

fellow; currently·Director o1'Institutional Research, Univ. of Missouri·Kansas City.=

► Turgay Faki: Co•Founder of Indiana Science Academy;10• lncorporator, Wisdom Educational Services, lnc.;106

lncorporator/President, Crossroads Community Center, Inc. {d/b/a Turkish American Society);'08 lncorporator/ President, TASl.'0'

► Vedat Akgun: Co-founder of first Horizon Science Academies (OH);',. co.founder of Attempted Indiana Science Academy and Indiana Life Sciences Academy;'09

Founder of Concept Schools;"0

linked,n Profile available at: hnp://tinyurl com/lg9npe (last checked 4/19/2017)

"' See linkedin profile for levent El,bal, available at htlp./ /tinyurl.com/w313nv (last checked 11/23/2016)

"' ld .

.. ld.

• Id

• Linkedin Profile available at; http://l,nyurl.com/n7g68nc (last checked 4/19/2017)

., lMSA West, 990s,. available at: http.//tinyurl.com/lrzJkf7 {last checked 4/19/2017); IMSA North. 990s, available at: http://tinyurl.com/kgoqh5j (last cllecked 4/19/2017); IMSA South. 990s, avaj!able at http://tinyurl.com/mi:xwu3m (last checked 4/19/2017).

•• Coiporate documents in Indiana are available at: http://linyurl.com/mmy5t79 (last checked 4/19/2017),

" Corporate documents in Indiana ate available at: http://t1nyurl.com/n6y7qhf {last checked 4/19/2017)

Murat Durxlar Curriculum Vitae, available at: hnp;//tinyurl,com/m2pnezn (last checked 4/21/2017)

Corporation registration information available at hnp:/ltinyurl.com/kjr61u4 (last checked 4/19/2017), Indiana Science Academy Charter School Proposal at 1, available at: hnp./ltinyurl.com/kem5s8u (last checked 4/17/2017); Indiana Ltfe Sciences Academy. Charte1 School Prospectus. avajlable at: hnp://tmyurl.com/lnkq7cz (last checked 4/26/2017).

Magnolia Public Schools Board available at: http://tinyurl.com/m64mtrh (last checked 4/26/2017).

linked in Profile available at: http://tinyurl.com/lx3h7no (last checited 4/19/2017)

Indiana Science Academy Charter School Proposal at 1, available at: http://tinyurl.com/lcem5s8u (last checked 4/17/2017)

Corporate documents in Indiana are ava~abie at: http·//tinyur!com/kllhfr79 (last checked 4/19/2017)

Corporate documents in Indiana are ava~abie at: hnp://tinyurlcom/n6y7qhf (last checked 4/19/2017) .

Corporate documents in Indiana are available at: http://tinyur1.com/mmy5t79 (last checked 4/19/2017).

New Plan Leaming, Inc. 2011A Bond Official Statement pg A-32, available at: http://tinyurlcom/2lCoaulCp (last cr.eck!!C 9/6/2016),

Corporation registration information available at: http://tinyurl.com/kjr6lu4 (last checked 4/19/2017); Indiana Science Academy Charter School Proposal at 1, available at: http·//tinyurl.com/kem5s8u (last checked 4/17/2017); Indiana Life Sciences Academy, Charter School Prospectus, ava,table at: http://tinyurl.com/lnkq7cz (last checked 4/26/2017).

New Plan Leaming. 1nc, 2011A Bond Offic'al Sta1ement pg A-32, :wa·dable at: http://tiny1.1rt.com/2mauxp (last checked 9/6/2016).

l~IS\!AIEklAl IS u1,1~rnu1:o BY AMSIOl•UAM &P.HINtR~ Ill' □ N !H~.~Ll 01 r~, HOPUilll[ 01 IUHr\tY AO~l 1I0~~1 IIH 01'-MAIIOII IS A VAil ~ ~I l ',I IH f D0P,> fiHIC ~ I or IUS I ICE, ""' s~1•1r, Io~. DC

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"

Received by NSD/FARA Registration Unit 07/27/2017 6:11 :32 PM Empire o10Kelt: An lrrves1,gat1on of the Gulen Char1er School Network Emptr1ot0Kett: An lnves11ga1;00 of the GUI en Cnarter Scllool Network

Co-founder of Breeze, Inc. and New Plan Leami~g;"' Board member, Fulton Science (GA);ni CEO, Charter Housing

Corporation {GA);"3 CFO, Global Spectrum Foundation, Inc; 0.8.A. Istanbul

Center (GA);1meoard member of·Fult0n

,Science Private School·(GA);n~ President of the Turkic American Federation of

:southeast {GA)."8

Notable Articles regarding the lndiana·Network

► Shaina cavazos, These 10 Indianapolis

Schools Have ,the Fewest Kids Passing the·20'6·ISTEP Test, ChalkBeat (Nov. 18, 2016) (lists IMSA - South. as one of the

ten worst perfonning schools on ISTEP

tests in 2016 in Marion County)."'

► Scott Elliott, Most Indianapolis Charter Schools Scored Below the Indianapolis

Public Schools Average on /STEP, ChalkBeat (Apr. 17, 2016) (details aca­demic failures 1MSA schools and mentions FBI probe into Concept).111

► Jill Glavan, Dirty Dining: Critical Violations Found Inside Local School Cafeterias,

Fax59 {Feb. 16, 2015) {detailing critical

issues with.sanitation in the cafeteria.at

IMSA - West.due to a lack of hot Water,

rating IMSA - West's sanitation an •F;

and,describing how-an,inspector forced

the school provide cold sack lunches at "IMSA. - North to be delivered to IMSA -West).nt

► •Sandra Chapman, Nearly Half of Indiana's Charter Schools Doing Poorly or Fililing, 13 WTHR (Nov. 6, 2014) (discussing;issues

·with teacher reterition, unlicensed teach­ers from·reach for America, and a lack of

textbooks).'20

► Amber , Steams, Feds Probe Parent

Company of Charter School, Nuvo (June 18, 2014) {discussing FBI executing a

search warrant at IMSA in conjunction with E-Rate fraud investigation).•ti

2007 Breeze Inc, 990 form, available at: http:/ /tinyurl.com/zJ9xblx (last checked 9/8/2016)

"' 2012 990 ta• retum, showing Ak.gun as a board member, available at: http:/ /linyurl.com/lvassnk (last checked 4/19/2017).

"' Georg la Secretary of State business 5earch for Ot11cer Veda! Akgun, available at: http / /tinyurl.ccm/pa73vlw (last checked 4/19/2017).

, .. "" Linked in profile, ava1la~ at: http:/ ftinyuficom/kamscfk (last checked 4/19/2017)

Linked,n profile, available at: http,/ /tinyurl.com/kamscfk (last checked 4/19/2017)

'11 http.//tinyurl.com/htlqJtz (last checked 4/21/2017)

"" http://tinyurl.com/jh6d3l3 (last checked 4/21/2017)

"' http:l/tinyurl.com(jf7u)(Cffi (last checked 4/21/2017).

http.//tLnyurl.com/grxqgke (las1 checked 4/21/2017).

"' http://tirryurt.com/h3vs88g (last checked 4/21/2017)

IHI\ MAlfAIAI 10 DIS!f<IBUleD ~Y~.!.ISltRDAO.I ~ f'AIIINfflS llP 0~ llfHA!I (lf IHE AEPuBLICOI IUR<;iY ADOIJIC'~~l IMI Qf;',l~llm4 10 A'IAILASLC Al lhE DEPH1"1fNI OJ IUSIICt, WASHl'1GIUN, DC

Received by NSD/FARA Registration Unit

IHIS \IAlflllAI IS DISIHl:JUIEU Kl A"1SlfHDAM I. fAIIIIHf•~ IIP Ii~ ~t~AII ilF I Ht Hfhl~IIC Of TUK!\C\ AUIJIIIU'1~l 11HOA\!.~TIOIJ IS A'/AILA~lf Al !Hf DEP,\~ll'~Nl Of JUSTICE, WAS~ING\(IN, DC

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Quick Facts

► Region: Midwestem

► School Names (known as): t> GateViay Science Academy t> Frontier ·

► T0t81 # of Schools in State: 9 t> 4 Gateway Science Academies:

Overseen by Concept Schools, and

included in Midwestem rE:gion t> 5 Frontier schools: Overseen by

. Harmony Public Schools, and included in Greater Texas ~gion

► Total Student Enrollment 2015-16: 2789'

t> Gateway Science Academies: -1285

t> Frontier schools: 1504

► Charter Holder/Governing Board(S}:

t> Gateway Science Academy of St. Louis Organized as a non-profit 501(C)(~) organization

Oversees the 4 Gateway Science Academy campuses

t> Frontier Schools, Inc. {formerly Millenium Education Foundation sic) Organized as a non-profit 501(C){~) organization

Oversees the 5 Frontier campuses

► Charter Management Services Vendor: Concept Schools, Inc.

► Regionai Gulen Organization Oversight Entity: ·Concept Schoots, Inc.

EmptreotDtceit: Art tmestiganon of the Glllen Charter School Network

► Regional Sister ·Networks: Math and Science,(IL); Horizon:(IL); Horizon (OH); Noble (OH); Math and Science {IN); Math and ·Science (MN); Math and Science (Ml); Math and Scie~ce ·{WI); ·career ACademy (WI).

► Total Revenues for the 2015*16 school year: S:12,538,9W

-► Gateway MO Network Founders: t> Kemal· Akkaya: lncorporator of

Gateway Science Acade~y of St. Louis {MO); Board President of Gateway Science Academy of St.

Louis; former boar~ member of MARTI, a Gulenist cuitural associa­tion in Maryland; led trip to Turkey for fellow professors sponsored by the Niagara Foundation and disclosed that it was openly Gulenist; Professor at Florida liitemational University. 3

t> Ugur · Zengince: Email listed as Representative for Gateway Scien6e Academy charter petition; Principal HSA Cleveland Middle School {OH); Principal HSA Dayton(OH); Featured in OH Whistleblower testimony because

of his misuse of ·federal funding;"' ·Provided signature on E-Rate funding form for Concept and The Core Group, one of the vendors under investigation for allegedly defrauding the E-Rate

, program; Superintendent Concept Schools; Superintendent Triad Math and Science Academy (NC).~

Student enrollment and demographic information available at: htlp.//tinyurl.c~m/k6mbw3y (last checked 4/19/2017).

Figure represents only the Gateway MO school5, taken from the Gateway Science Academy 2016 audit.

!nformaMn gathered from Articles of Incorporation, pg 67, available at: http://tinyur!.com/J2elx4y (last checked 4/25/2017), Akkaya bio from Gateway·s charter petLtion, pg 13; Tnp summary featuring Akkaya and write-up regarding sponsorship oftr1p, available at: http:/ /tinyurl.com/lfjlyc6 (laS1 checked 4/25/2017); Bio available at: http://tinyurlcom/kxbr6wv (last checked 4/25/2017).

'The first day ofschool;the principal, Mr. Ugur Zeng,nce - he goes by Mr. Zen. - pulled me into his office and said, 'You can teach· English, right? You are going to teach fre5hman and Sophomore Engli5h' instead of being a Title I teacher, They still were collecting federal Title I money but had nobody performing Title I services~ Testimony available at, http://til'lyurlcom/kdamb9a (la5t checked 4/25/2017)

Information gathered from Gateway charter petition, pg 7; E-rate form, available at: http.//tinyurl.com/lln2o8s (last

l~IS \l~H~IAl ,s DISJE1:;~1,o ~· A'IS!cfC~\I ~ r~air,;FS llP G'f ~Ce•lr Cf r~, ViPU~llC Of [Uf;•:'l AD!lillO'IAl !'ii Of'\IAIIG'l IS ~~AllA3lf Al 1 MC Di PAH\le:u Of J~S 11cc. WAS~1·,Gror1, oc.

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t> EmreCelebi: lncorporatorofGateway

Science Academy of St. Louis; Published several academic,papers

with V. Alp·Aslandogan, Gulen's offi­cial spokesperson and Executive Director Of Alliance for Shared Values, Harmony (T~) landlord, and major

. Harmony (TX) vendOf; Professor at LSU Shreveport,8

1> Taner Ertekin: Established Gulenist

Overview

As of the 201672017 school year, Missouri

has nine charter schools within the Guren

Organization. Unlike other states, Missouri is split

across two regions:of.the Gulen Organization. Four of the nine charter schools are operated by

Gateway Science Academy of St. Louis and are

managed by·Concept·Schools, which classifies them within the Midwestern.region. The.other

five charter schools are:operated -by •Frontier

Schools and are managecf by Harmony Public SChoolS (TX), which classifies them within the

Greater Texas region of the Gi.ilen Organization.a

The information in this.profile is limited!to the Gateway (MO) network.

schools in Thailand and· Japan; co~founder of firsf Horizon Science

Acad_emies; founder of Concept Schools; used HSA Cle~eland•funds to.pay immigration expenses for·his wife; founder and president of Breeze,

Inc., Concept's preferred Gulenist landlord. entity; founder of· Chicago

Math and Science Academy. 1

Concept Schools, Inc. is the charter man­

agement organization responsible for the

Midwestern region of the Gulen · Organization

charter network. Concept allegedly provides additional educatKlnal management • services

for the·charter-schools for a percentage fee-of

total school revenues .. On-average, the Concept Gateway MO -schools serve 50% ,free and

reduced lunch population YS.'100% district aver­

age; 28.3% minority students vs.:ae.7% district

average; and 71.7% Caucasian students vs. 11.~%

district average. As these numbers indicate,.the Concept Gateway MO schools do. not serve a proportional share, of -the vulner8bie student

populations within the city.

1•choot OperatlOrl Student Demographic At..ithortnr ·G;vemlrig Board Information•

Gateway Science Academy Grades K-5 1.1%ELL Undenwood Gateway Science of St. Louis-Elementary 2010-present 31.5% FAL University Academy of St. School Srl'liley Campus 5.7%SWD Louis 6576 Smiley Avenue.-Saint 17.8% Minority Louis, M0.63139 82.2% Caucasian

checked 4/2512017); linked,n profile. available at: hnp.t/t1nyurl.com/kjcze93 (last checked 4/25/2017)

Information taken from Art,cles of Incorporation, pg 67, available at: httJ)·//tinyurl.com/l2el~4y {last checked 4/25/2017). List of three art,cies by Celebi and Aslandogan, available at: http:/ltmyurlcom/lysx8v6 (last checked 4/25/2017); see Greater Te~as region for more information about Alp Aslandogan; Celebi resume, available at: http://tinyu1l.com/mml9lma (last checked 4/25/2017)

Information taken from Bond statemerit at A-23 descr,b,ng Ertekin·s involvement. available at: http://tinyurl.com/keaa5f5 (last checked 4/19/2017); See, e.g., HSA Cleveland 2002 audit, pg 24, where a finding was made against the school for paying the immigrat!Of1 e~penses of the spouses of Sedat Duman and Taner Ertekln, Concept's founders, available at: http.//tinyurl.com/zl~45 (last checked 9/8/2016}; 2007 Sreeze Inc. 990 form, available at: http./ltinyurl com/zj9xbzx (last_checked 9/8/2016); CMSA 990 tax documents listing Ertekin, available at: http://tinyurl.com/hdu6gbe (last checked 4/20/2017)

For more information about the Front,er (MO) network, please see the Missouri profile in the Greater Te~as region.

IHI~ ~AICHI~[ IS UISIHl,!UICU :l1 AMSIEhDAr.t & raArnE~S LLF or1 3E~~Lf er [l,f REPU3LIC GF IUR,O AUOII IO~Al I~/ OHM~ 11~~ IS •V~ll A81 f Al l~E UEP.>RH.1;:•1 I 01 Ius1Ic;:, wA,rl % ION, UC

Received by NSD/F ARA Registration Unit

[~ .. ~~

0pe~----Stu~ Deritgraphic ------------ I Authorizer Governing Board

Information" _J Gateway Science Academy of St. Louis~Elementary School South

Grades K~5 2013-present

9.9% ELL 68%.FRL

9.6%SWO 6651 Gravois Avenue, Saint Louis, MO 63316

38.7% Minority 61.3% Caucasian

Grades6-8 ·2010-present

2.5%ELL 45'ff,'FRL

3.8%SWD

Gateway Science Academy of St. Louis-Middle School 5049 Fyler Avenue, Saint Louis, MO 63139 27.2% Minority

72.8% Caucasian

Gateway Science Academy Grades g;.12 3.3%ELL :of~L Louis-High School 2012-present 5049 Fyler Avenue, Saint ~~s~·

. Louis, MO 63139 29.5%'Min0fity 70.5% Caucasian

•Student'demographic information was taken from the 2015-2016 school yea;. "ELL'" indicates English Language Learners, '"FRL'" indicates students·receiving free/reduced lunch, and '"SWD'" indicates-stu­dents with disabifities.9

A History.ofiStrategic Ambiguity and Conflicting Interests

After Gulennlocated·to·the United States in

1999,,his followers promptly·formed non-profit

educational foundations and filed applications for the first of the Gulen Organization's char­

ter schoots throughout the country. Some of the earliest-Charter schoDI efforts by·.the·G_ulim

Organization took place in the Midwestern region orchestrated by a tight-knit group of Turkish

businessmen, led predominantly by Taner Ertekin and Vedat Akgun. After forming the first of the Horizon Science Academies in Ohio, these

Gulenists formed Concept Schools to serve as an external charter management organization

that would. oversee the charter schools they opened throughout the Midwestern region.•~

Concept's efforts to expand into Missouri began in 2006, when the Gateway Science

Academy of St. Louis formed as a non-profit

organization, led·by a founding 1board of Kemal Akkaya, Mehmet Kahveci, and Emre Celebi.

All three were graduate students-at the time.of

forming the foundation, which from our research appears to be typical of most founding governing boards for,Gule·n Organization charter schools.

Akkaya lived and• worked in Carbondale, IL, two hours away from St. Louis; Celebi lived and attended university in· Rolla, MO, also two hours

away; and l<ahveci lived and attended university

four hours away.at the time. Kahveci eventually move_d to,Columbia, MO, still two hours away.

Two-years after:they·formed the foundation·in 2008, Akkaya and Kahveci submitted a charter

petition to the Missouri Science and Technology

University, which was unsuccessful. In 2009, they submitted the charter petition again, this

time to Lindenwood University, which approved them to open the first campus for the 2010-11

Student enr~lment and demographic information available at: http://tinyurl.com/k6mbw3y (last checked 4/19/2017)

Concept Schools NFP corporate information, available at. http://tinyurl.com/ia11yt7 (last checked 4/20/2017).

IMIS MATfAIAI 15 Dl,l~ltlUl!U ~l AIJSltfDAM & PARl1CWi Llf GIi BChAlf Ol IH HCPUBIIC Of 1%•il .~U[IIIION~l INI Gfl,IAIIU~ I~ Al/AIIA~I E Al lh[ DCPAHr',j!:NT OF J~Ofl[(, \HSrl%f0'1, DC

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Received by NSD/FARA Registration Unit 07/27/2017 6: II :32 PM fmlllreol Deceit: An lnvest1gatIon olthe Gui en Charter School Network Em,lreotDecett: An lnves1igation of the GUI en Charter School Network

school.year.11 During th-e entirety of their:time on

the Gate~y,board,·Akkaya and K8hveC:iifived over two hours away from St.'Louis.'2 During this time, Akkaya led a trip:paid;for by the•Niagara Foundati_on to Turkey ,for several of, his col­leagues at the Southern· University of Illinois, which they documentediextensively and·noted that it was paid fofby the' Gui en MoVement.'3

Gateway expanded with:its.additional cam­puSes in 2012 for the rriiddle'and hiQh school, and in 2013 for the Gateway South campus. Concept has-been Gateway's charter management orga­nization since it submitted its firSt applicatiOn in 2008,

Acc_or_ding to media,reports, C_on~pt's_most serious-controversy to date is the ongoing FBI investigation concerning' the alleged collusion of concept employees and their.vendors to:defraud the fecteral'E-Rate grant program:of·millions of dollars."'According to the released-FBl's search warrant -apf)lication, ·Concept executives vio­lated the competitive bidding rules of the E-Rate program by selecting:a vendor complicit with Concept's plans to defraud E-Rate outside of the norm.ii procurement process. Then, Concept;s Chief Information Officer directed that vendor: to divert hefty "su~ontracts" to affiliated Turkish individuals and companies in exchange for a_ cut of the proceeds. The actual work was:pei"­formed by Conci;ipt employees,themselves,· not by.the=complicit vendor who:was approved by

E-Rate to provide· the work, or the so-named

companies and Turkish vendors foi" the subcon­tracts.1~ tn-2014, FBI agentS raided numer~us locations throughout Illinois and Ohio, including Corii:::ept-managed:schools, Concept's:reQional offices, and•the offices of several Gulenist:ven­dors. :Former•Concept executive Ozgur Balsoy

was one of the purportedly frauduleritlYenriched Turkish vendors who _was_ raidE!d. 18 According to the:same:media reports, While·Balsoy and his business remains under suspicion in.' the FBI investigation, concept continues to give him and the-other Turkish~owned vendors named in the search warrant:application substantial-busi­ness.'7 In fact, Gateway Sci_ence Academy uses

Balsoy's business to-provide services, as we/1.'8

The investigation is Ongoing.

Mustafa Erna net, a former H-1B employee and Gulenist, provided interviews to-the·Fe1·regard­ing ·his work, as a_ network administratOr and

teacher at a Concept~managed school:in-Ohio. He corroborated that Concept purposefully used related service providers who overcha~ged, just as·he said all of the.charter·networks did throughout the Gulen Organization." Since his cooperation with the-FBl,,Einaneilt and tiis wife, who was also empioyed with Concept, Mary Addi, have come forward and provided infor­mation regarding· the forced tuzuk payments and !ithing to the:Gulen Organization required of Turkish H;1e employees,w Emanet 81so,pro­

,;tuced a. copy of ttie tuzuk -~greeme!1t itself, which is attached to this report as Appendix:___.

Information ava;lable at Lindenwood University's charter website, available at: http:/ /tinyurl.com/lymkxbk (tast checked 4/25/2017) as well as from Gateway's initial chartar petition.

See Akkaya's resume, available at: http://tinyurl.com/kxbr6wv (last checked 4/25/2017)

Trip summary featuring Akkaya and wr,te:up regarding sponsorship of trip, available at: http-/ /tinyurLcom/lfjlyc6 (last checked 4/25/2017)

M,halopoulos, Dan and Seidel, Jon, Charter Firm Suspected of Cheating Federal Grant Program, Chicago Sun-Times (December 16, 2015), Available at: http://tinyurl.com/jJsnbad (last checked 9/8/2016).

Search Warrant application available at: http://tinyurl.com/jt9j4ed (last checked 9/8/2016)

'1 See id.; see also Mihalopoulos;Dan and Seidel, Jon, Charter Firm Suspected Of Cheating Federal Grant Program, Chicago Sun-Times (December 16, 2015). Avaitable at: http./ /tinyurl,com!j3snbad (tast checked 9/8/2016}

See Mihalopoulos, Dan. Targeted Firms Still Get Ta:,; Money A~er Charter Raids, Chicago Sun-Times http·//t1nyurl,com/jzmzevh (last cheCked 9/8/2016)

ASE provides day-camp services at Gateway, available at: http:/ /tinyurl.com/lh4bpc5 (last checked 4/25/2017)

Search Warrant application, pg 44, available at: http:/ /tinyurl.com/jt9j4ed (last checked 9/8/2016).

" 2015 Letter from Mary Addi and Mustafa Ema net to OH legislature, available at: http://tinyurl.com/mezzupx (last checked 4/20/2017)

101$ MA! 81;1 lo Dl$l~l~UIF0 8Y AMSlf~lJI.M & PART~!:HS ti PON Bf~Alf OF !Hf Hf PUBLIC ~I TUHKtY. ;,ODIIIONAl l'lf0RMAIION IS A1/AILAatf Al lhE Df"PAH1MfNT Of IUSI It!, '.VASHINGION, DC

Received by NSD/F ARA Registration lcJnit

Financial Abuser

Missouri requires its charter schools to undergo -annual:audits .. A review of. these audits revealed· the extensive amounts:Gatewayipaid in rent-to. ,New Plan _Learning, the Gulenist-controUed:real,

estate arm of.Concept Schools. Gateway's prop­erty arral'lgements:a-re discussed1in more,detail,

· in the Real Estate section beiow.' Furthermore,_the .audits atso-revealedithat Gateway's tax-exempt •status was in j~pardy due to its repeated failure to,fi/e mandatory·IRS tax documentation for its •first three years of operation.11

While the Gateway MO audits are overall

Real Estate

One of the most.Significant profit centers,for the Gulen Organization, and in -particular the

.Midwestern region, is_through reat estate. This _property financil'!g schef'1"e has.,been replicated throughout the country-in fact,-Vahap Uysal, a 'board member of.Concept Schools,zz Wl'ote and: presented_an article eritltled ~GUlen Movement and School 'FinancingM at the Third Annual• Conference on Islam in the Contemporary World: Th"e FE!thullah GUlen Movemel'lt in Thought and Practice.23 Gulenists throughout the couritry attended and preserited, including· Alp Aslandogan, former Harmony Public sChools landlord,' CEO of one Harmony's largest vendors,: Property buyer from Dove Science Academy, and:Gulen's_official ~pokespersOn-in his role as· President of the AIHance;for:Shared Values, a Gulenist cultural organization. 24

i, Gateway Science Academy 2012 audit

much cleaner than-its sister networks within the Gulen Organization, ,Gateway utilizes the same Gulenist• vendors currefltlY being! imfestigated by the F;Bl .for, defrauding the federal E-Rate pro­gram. BecaUse Gateway uses the same vendors implicated in the F;BI- investigation ard identi­fied· by· Concept wt-iist_letilowers as fraudulent, -a_forensic accounting, which examines specific ,payouts to vendors.in comparison to goods and services actually· received would ·likely reveal

.the same pattern of purposeful"overcharging and underperformance endemic across the •Midwestern region and the Gulen Organization.

Early ,on, the founders of the Midwestern region·established Breeze Inc, to acquire prop­erties for ·Coflcept SChools ,throughout the Concept network. 25 New Plan Learning was createct:shortly thereafter, and now acts as the non-profit umbrella organizcition for Breeze and, several, other wholly· owned subsidiaries.ie

· Murat Arabaci, a former Concept employee,2' has.managed NeW Plan leaming:and.each of ·its subsidiaries•since 2005.ZII T~gether withiits

subsidiaries, New Plan Learning, buys, reno­vates, leases,- and sometimes sells propertieS .to Concept-managed schools. New Plan,Learning claims-it·operates as-a supporting organization to its Concept schOol tenants, but in real­ity, it buys properties that it then rents :to, the schools at: egregiously high lease rates. This model alloW's the Gulen Organization to acquire

" See Concept Schools 990 tax form, ava,lable at: http.//tinyurl.com/h5yvjlt.

" Conference was held Nov. 3, 2007 in San Antonio, Texas, and the conference agenda is available at: http://tinyurl.com/gt2vujs (last checked October 31, 2016)

,. See Texas profile for more information about Alp Aslandogan

" New Plan Learning, Inc, 2G11A_ Bond Official Statement pg A-4, available at · http:/ltinyurl.com/zxoauxp (last Checked 9/6/2016).

26 New Pla_n Learning, Inc. 2011A Bond Official Statement pg A-4, A•S, avaifable at: http~/ltinyurl.com/imauxp (last checked 9/6/2016); see also Exhibit A for Property information, including l<:mdlords; rent, and transfer history for the facilities of the Ohio Concept SC:hools.

21 See 2007 Concept 990 witrt Arabaci listed as employee, available at: http.I /tinyurlcom/z9y361h (last-checked 9/8/2016),

" See Business profile for New Plan Learning, Inc., showing its incorpor,ition in 2005 and listing Arabaci as agent, available at: http:/ /tinyurl.com/hu2d6x7 (last checked 9/8/2016).

f~IS M~IERIAL IS Gl\l~IBUliO Bl AMSlrou>,!,t -~ PHT~fHS LlP ON ~CHALi Of Inf REPU811C 01 ru,:r:,y ADDIIIONAl l~fOflMAIIDN IS WAllABLE Al I~> O[P~hl'~ENI Di l'JSIICf, WASHliiGl~'l. OC.

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property which it pays for with public tax dOllars,

and if the charter schooi is terminated or non-re­newed,·the publicly financed property·remains in the· hands of the Gui en Oi'ganization.

Currently,. New· Plan Learning owns •the Gateway South · buildirlg under its subsidiary 6651 Gravois LLC.' New Plan Leamif!Q purchased

the building in 2012 for $1.2 million. In May of 2013, the Gateway governing board entered into a fif­teen-year lease with New Plan Leaming. Per the terms of the lease, Gateway is also responsible for alhcosts associated with the use, mainte­nance, financing, orarepair of the. property and

all 1utilities, insurance, periodic:capital replace­ment reserve amounts and mana·gement fees. The ~se, rent started at $32,800 per month, which increases each year of the lease. From the leasE!'s inception in August of 2013 projected through,to·July 31, 2017, New Plan Learning 1will

have collecled·$1.6'million in rent for·the:build­ing/1 $400,000 more than the price it paid By

2028, when the lease-term ends, Gateway will have paid•New Plan Leaming over $6.7 million dollars in rent.•

In contrast to the .$33,000+ rent per month Gateway pays New Plan learning for the Gateway South facility, Gateway pays only $10,000-$11,000 per month in rent for the Gateway Smiley.cam­pus,31 While Gateway will pay $6.7 million in rent

to. New Plan teaming from 2015-28, Gateway will-pay only $1.8 million for the Gateway Smiley campus over the same period; nearly four-times' less.32 Based.on·our iriterpretation of the evi­dence, the rajionale for this extreme discrepancy is clear; Gateway_ rents the Smitey campus from an actual non-prcifit organization that is unaf­filiated• with the 1Gulen Organization and is not seeking to exploit its public resources.11

Gateway owns the Gateway Middle/High campus in its own name, having purchased it in 2013from an unaffiliated third party for $795,000. 34

Thus, according ,to Gateway's proposed 2016 budget,-approximately 72% of the funds it allo­cated for property leases and payments went to pay for only one of its three campuses, the one owned by New ~Ian learning.!'

Egregious rents far above the purchase price are not the only means that New Plan Learning, Concept, and the Gulen Organization extract· public funds in.real estate. Hiring Gulenist affil­iated contractors who routinely overcharge and underperform is another critical llloneym8ker for the Gui en Organization. Just as it had throughout Ohio and Illinois, New Plan Leaming hired Quality Builders of Midwest, the preferred Gulenist con­tractor for the Midwestern:region, for a million dollar renovation of the Gateway.South building at the school's_ addition SI expense.38

" Figures (aclllal rent paid 2013-14, 2014·15, 2015-16, and projected rent for 2016-17 as this aud,t has not been conducted as of the wrn1ng of this report) taken from New Plan Learning's financial reports, available at: http://tinyurl.com/m6xmpc8, hnp://tinyurl.com/kradwj6, hnp://tinyurl.com/l22szpv, and http://tinyurl com/lz9lqze (last checked 4/25/2017)

·"' Gateway Science Academy 2016 audit p<ojections, pg 14

Gateway Science Academy 2012 Audit, pg. 11

The Gateway Smiley rent projections are based off of those contained in the Gateway Science Academy 2016 audit projections, pg,14.

" Gateway Science Academy 2012 Audit, pg 11.

"' See sale p<1ce, available at: http://trnyurl.com/mtnbh-dc; purchase details at hnpJ/t1nyurlcom/he9gru6 (last checked 4/25/2017)

" Budget, pg 112, available at: http://tmyurl.com/l2elx4y (last checked 4/25/2017).

,. PrOject details, ava~able at: http,/lt<nyurl.com/mpml25u (last checked 4/25/2017). For a hst of other projects Quahty Builders has perfomied for Concept-managed schoots, see: hnp://tinyurlcom/kmbj878 (last checked 4/25/2017).

1H'.i \l~E!'IAL IS OISJH5U!iD BY H1Sltf0.,\I S P~f'l~Cf'S HP 0'.I ~Ch~li 0! !rt PiPIJ~tlC 0! l~H•.:"Y, AOO!llO'l~l 111'01<1.UTIO'I IS .IV/.ll~3LC Al lh OtP,Ht.l<'H 01 IUSIICI, flA)~l~G!O•l, DC

Received by NSD/FARA Registration Unit

Bond Financing

In 2011 New Plan Learning expanded its capital significantly •by applying for' a bond for approximately $33 million dollars .to pur­chase, refinance, and/or renovate_four Concept schools, CMSA and three Concept OH schools­·HSA Dayton HS, HSA Toledo HS, and HSA Springfif!ld.3' Due to_ their inclusion in the bond, these schools are ·now subject to extremely high.annual rents:in non-:eancelable leases set to expire in 2041.38 The bond was issued by the

Empln at Deceit: M l~es11ga1,on o! the Giilen Ctianer School Ne!WOfil

Industrial Development·Authority of,the County of Pima,. Arizorla, the same organization that issued bonds for both the 'Sonoran (AZ) ai,d:

Co~I {~V) G1Jlen ·Organi~tion charter net­works.39 New·Plan Learning has not implicated' any of the Gateway MO schools directly in a bond' to date, but the rental income from Gateway MO is reported as part of the·New·Plan Learning's assets to justify.the bond financing.

Abuse of the H-18 Visa Program

like all GUlen Organization .charter net­works,-Concept and their MO schools utilize the H-18 visa program.to-immigrate large numbers of Turkish Gulenists into the Uilited States for emJ)loyment in the schools and network. The Concept Gateway network filed 30 H-1B appli­cations from 2001-2016, while Concept itself filed,176 H-1B applications during the same time period.40 While the Gulen Organization typically states .that.these H-1Bs are only to fill shortage areas for math and SCience teachers, these apJ)li­cations we're filed for such positions as: physical education.teachers, school:business managers, administrators, and,school librarians.

Concept and Gateway MO use the same immi­gration attorneys_to-file-and,process their H-1B applications as other known GUlen Organization charter.networks, vendors, and cultural associa­tions, indicating once ~gain the existence of an overall network. For example:

► Remzi Kulen: Concept and Gateway MO .used Kulen,.a New York-based attorney,

to file numerous H-1B applications,41

Kulen Sllso filed applications for: e,.. ConceptSchools(OH, IL, IN, Ml, MN)• 1> Pioneer (MA) i> Niagara Foundation (IL) 1> Young Scholars (PA) 1> Golden Generation Workshop Ceriter

(PA)

1> Blue Ocean Construction (FL) 1> Academy of Science, Syracuse,

Buffalo (NY)

P Arts and Science, Bergen, Passaic (NJ)

► Mustafa Gene: Gateway MO used Gene, an Illinois-based attorney, to.file numer­ous H-1B applications.~2 Gene also filed applications for: i> Concept Schools i> Horizon (OH) t> Noble (OH)· 1> Math and Science (IL) 1> Math and Science (IN)

New Plan Learning, Inc, 2011A Bond Offic,al Statement. available at: hllp;//linyurl.com/zxoauxp (last checked 9/6/2016}.

Id,

"' P,ma County bond issuances, ava,lable at: http://t1nyur1.com/kards94 (last checked 3/30/2017)

'0 Gateway MO schools filed 30 H-18 applications from 2001·2016, available at: http://tinyurl.com/mhmefs9 (last checked

4/24/2017), Concept filed 176 H· 18 applications 2001·2016. See http://tinyurl.com/j3whatt for Concept Schools, Inc: http://tinyur1.com/zhgx3xl for Concept Schools Nfp

List of entities represented by Remzi Kulen, available at http://tinyurlcomtgptwx5~ (last cheeked 3/21/2017) .

., List oft!ntities represented by Mustafa Gene, available at http·//tin)'Llrl com/ko77hqq (last checked 4/24/2017).

!t-lS fUlfFIAI IS Ol'ilEl~l!HD 61 •ll>JffOHI ~ PA~J!:fi-S Uf'O'I :lirAlf Of J~i ~ffU3llC 0! l~r-;1 ~001 IIONAl l~f()[<l.(Al IOU IS ~HU ~Bl t 11 ,~, DE P~fil~, ~! Of l~S I 1Ct, ·.~·,;r116HJ~. Dl'

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Received by NSD/FARA Registration Unit 07/27/2017 6:11:32 PM Empire at DeceU: An lnvest9atoo of the Giiien Charla Schoo1 NetWOfk EmpireofDeclfl: An lnvestigat,on of the GUlen Charier sdicci NeiWOlk

► David Nachman: Concept used Nachman, a·New Jersey-based attom~, to file H-1B applications.43 'Nachman also filed H-18 applications for: t> MilkyWay Education Center {NJ) t> Paterson Charter School for Science

and Technology (NJ)

► Nuzhat Hafeez: Concept MO ·schools

Notable Turkish Vendors

►. Conc_ept Schools, Inc. Concept is·a com­prehensive services vendor that controls human resources, fiscal management, SChool dE!s(gn, curriculum, accountability, compliance, and reporting for a ten.per­cent fee of each school's total revenues.•~ Currently, Conc~pt is -the contracted nonprofit management services vendor for thirty such charter schools, with sev­enteen- schools in Ohio, -four in Illinois, three in Missouri, three in lndiana,.one in Michigan, one in Wisconsin,:and one in Minnesota.oaThe foundE!rs·of the first.OH

charter schools in the Gulen Organization formed Concept shortly.thereafter.

► Breeze lnc./New·Plan Learning: Breeze, Inc., was created in 2004.as a for-profit corporation ·to acquire properties for Concept Schools throughout the Concept Network,•1 New Plan Leaming.was cre­ated shortly thereafter, and now acts•as the non-profit:umbrella organizabon fDf Breeze.and several'other wholly-owned subsidiaries, including 6651 ·Gravois

used Hafeez, an Illinois-based attorney, to file numerous H-1B appfications .... Hafeez also filed H-1B applications for: t> ConC:ept SC:hools, Irle. t> Niagara Educational Services, Inc.

(IL)

t> Niagara Found8tion'(IL) t> The Core Group_{IL)

LLC, the . owner of the Gateway South property.411 Together with its subsidiar~ ies, New Plan Leaming buys, renovates, leases, and sometimes sells properties to Concept-managed· schools,: allegedly

.as :a supporting .organization to those schools.

► Quality Builders of Midwest: Quality Builders.is-a construction company that does the·majority of Concept and'NPL's construction work.•9 :several of Quality BuilderS' Gulenist employees have worked at Concept and its schools, as well as at other-charter networks throughoLit the Gulen,Organization. Quality B4Jilders

was hired by New Plan Learning:to-do a million dollar.renovation on 1the G8teway

· South property.

► Advanced ·sotutions for EdUcation: Advanced Solutions for Education, owned by former Concept employee Ozgur Baisey, is also implicated in the,ongoing FBI investigation regarding the defrauding

'' Nachman profile listing entities represented for H-1B visa work, available at http://t,nyur1.com/ny5h3ty (last checked 4/13/2017)

" Hafeez profile listing entities represented for H-1B visa work, available at: http://tinyurl.com/mvnttav (last checked 4/13/2017)

" Gateway Science Academy 2012 audit, pg. 12,

.. See Concept Schools network, available at: http://tinyurl.com/z3d8qsb (last checked 8/26/2016)

New Plan Learning, Inc. 2011A Bond Offic;al Statement pg A-4. available at http://tinyurl.com/z)(oau)(p (last checked 9/6/2016)

.. New Plan Learning, Inc. 2011A Band Official Sti!lemenl pg A-4, A-5, available al: http:/ /tmyurl.com/zxoau)(p (last checked 9/6/2016); see also E~hibit A for Property information, including landlords, rent, and transfer history for the fac1lit1es of the Oh10 Concept Schools.

.. See project information, available at http:/ /t1nyurl.com/zwlkry2 (last Checked 11/11/2016)

T~IS MAIE~IAL IS DISTRIBUJE[, Bl M!Ol~RDAM ~ PARINfRS ILPON 3f~ALF lH lh[ ~,1·uB11co1 lUM.fl AIIOITIONAL INFORJJATWN IS AVAllABI[ Al TH OfP,\RlMi~l OF JUSIIC1, WASelNGIO'i, DC

Received by NSD/FARA Registration Unit

of the E-Rate program !,(I The company

served as an-E-Rate fundingconsultanfto

Glilenist Cultural!Foundations

► Turkish American Society of Missouri: Gulenist cultural association that works in St. Louis alongside the Niagara Foundation to·lobby political leaders, host dialog din­ners, and sponsor trips to Turkey.~

► Niagara Foundation: The Niagara Foundation is a major Turkish· Gulenist cultural association based in Chicago. GUlen is its honorary president.§] Niagara Educational Services, Inc., oversees the Niagara Foundation, the Science Academy·of Chicago, a private Gulenist school, .and is very aciive throughout

the schools and also provtdes,services to the Gateway MO network.~•

the Midwestern region. For examl]le, in 2007, the ~iagara f:oundation gave an extensive loan to,Breeze lnc .. (New Pfan learning's predecessor) to purchase new properties for Concept charter schools.""' Several Concept employees as well as scho0I· eml)toyees are members of the Niagara Four,dation. Niagara provides free/low~cost trips to Turkey for'legisla­tors, as well as hosting dialogue dinners and fundraisers,!o!i In Missouri, Niagara assisted the .Turkish American Society of MissoUri in hosting a dialog dinner for the state legislature.ss

Individuals Caught in the Giilen Organization Web

Our research indicates that it is quite common for the Gulen Organization charter networks within a region to shuffle their Turkish H-1B visa teachers.from school.to school,.as well as between regions. This is just a small·number of individuals with these overlapping ties.through­out the region, which further demonstrates the region's interconnections. N0tablY, this shuffling only occurs with Turkish employees.

► Engin Karatas, a.k.a. Engin Btackstone:

Co-founded Chicago Math and Science Academy; Assistant Principal HSA Denison Middle; Teacher, HSA Cleveland Middle (Same year as·he was.a,principal-at'HSA Toledo); Principal HSA Toledo; Principal Quest Charter Academy; Assistant Principal Wisconsin career Academy; visited Fethull8h Gulen at the Golden Generation Retreat Center with Concept whistleblower Mustafa Emanet; Superintendent Gateway Science Academy (MO).~'

"° See M,halopoulos, Dan Targeted Firm! Srill Ger Tax Money After Charter Raids. Chicago Sun•Times http://tinyurl.com/jzmzevh (last checked 9/8/2□ 16).

ASE provides day-camp serv,ces at Gateway, available at: http://tinyurl.com/lh4bpc5 (last checked 4/25/2017)

"' See, e.g., Event details with Missouri lawmakers, Niagara, and TASOM, available at· ht1p:/ /tinyurl.com/128269f (last checked 4125/2017)

., See" http://www.niagarafoundation.org/ for information about the Niagara Foundation and http://tinyurl.com/d8tlv5c for information about G(ilen as Honorary President (last checked 9/6/2016)

"' Audit available at: ht1p:/ /tinyurl.com/haos4qu (last checked 9/8/2016)

.. For a description of a legislator's trip to Turkey with the Niagara Foundation, see: http;//tinyurlcom/mk;fando (last checked 4/20/2017)

"" See, e.g., Event details with Missouri lawmakers, Niagara, and TASOM, availat)je at: http: //tinyurl com/128269f (last Checked 4125/2017)

"' Information taken from an interview with Engin Blackstone, available at: http://t1nyurl.com/mw9bey6 (last checked 4/23/2017); 2015 Letter from Mary Addi end Mustafa Ema net to OH legislature, available at: http:/ /tinyurl.com/mezzupK (last checked 4/20/2017); Linked,n profile, available at: http·//tinyurl.com/lylm3Jo (last checked 4/25/2017); and state employee salary search, available at: http:/ /tin~url.com/kzp4Jaf (last checked 4/27/2017) (searching both ''Eng in Karates" and "Engin Blackstone'),

IHISMAlflllAL 1, Ul~IA1iu1eu BY~ilt',f!f<D~M & l'AlilNtlll llPOll llEHAII Of THI FlfPU~!IC 01 IUHsE\' AU~IIIONAI INfOHl.!AIIOf! 10 AV~llA~tl Al l~f Of l'AHI\H~ I 01 IU>IICC, WASHING TO~. IJC

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► Nuh Celik: Sub~itute teacher, HSA schools (OH);·Teacher; HSA Springfield (OH); Director HSA Denison (OH); Princjpal Gateway Smiley campus (MO}. 58

► Murat Silgnak: Substitute teacher! HSA Cleveland (OH); Principal, HSA Denison Middle (OH); Principal HSA Dayton Downtown (OH); Principal; Gateway Middle/High (MO).§'i

► Gerik KandE!mir: Substitute teacher, HSA

Toledo (OH); Teacher, HSA Cleveland (OH);. ~rincipal, HSA Cleveland Middle (OH);- ,Principal, Sc.erlce Academy of

·Chicago,(11.!); Principal, Gateway Middle/ High(MO).ao:,

► Cengiz Karates: Substitu!e teacher, HSA (OH); -Principal, HSA Cleveland (OH); Founding Principal, Gateway Science• Academy-Smiley (MO); riir~ctor of Concept Educational Programs;1Director of Concept Alumni NE!twork. 111

Notable Ar.ticles regarding theiMissouri Network

► Mihalopoulos, Dan. Targeted Firms Stil( Get Tax Mon~y After Charter Raids, Chicago Sun-Times http://tinyurl.com/ jzmzevh.

► Mihalopoulos, Dan. Federal funds for clout school operator despite probe. Chicago Sun-Times. (May 7, 201~) AvailablE! at: http:/ /tinyurl.com/jmyBweb.

► Crouch, Elisa. St. Louis .Public Schools tries to shed·vacant buildings. St. Louis Post-Dispatch. 17 April 2015. A~ailable at: http:/ /tinyurl.com/zk83ux8 (1 MarC:h 2017).

► MihalOpoulos, Dan and Sejdel, Jon, charter Firm Suspe,cted of Cheating Federal Grant Program, Chicago Sun­Times (December 16, 2015) .. Available at: http:/ /tinyurl.com/j3snbad.

► SLPS ·sells Gardenville:school. to-Concept' SChools for $1.2M. The St. LouiS American. 16 August ·2012. Available at: http:// tinyurl.com/js98995 (1.March 2017).

► Cambria,. Nancy. Charter school final­. izes. purchase of. vacant: St. ·Louis school. St. Louis Post-Dispati:h. 24 July 2012. Available at: http:/ /tinyurl.com/j4czbj4 (1 March 2017).

► Crouch; Elisa. Slay defends role as recruiter of charter schools:forcity.· 25.April\2011. Availab!t:! at: http:/ /tinyurl.com/zaz8n9y (1 March 2017).

► Clubb, Shawn. Parishioners say goodbye to St. Pius V school. St. Louis Post-Dispatch. 5 December:2000 .. Available at: http:// tinyurl.com/zo6owfw (1 March 2017).

"" Information taken from educator credentials search OH, available at: http://tinyurl.com/j7bxyhk (last checked 4/27/2017); Concept newsletter 2011, available at: http://tinyurl.com/jwbsmzt (last checked 4/27/2017); Missouri Department of Education School Directory, available at: http.//tinyurl.com/n7st5jg -

"' Information taken from educator credentials search OH, available at: http://tinyurl.com/j7bxyhk (last checked 4/27/2017); Missouri Department of Education School Directory, available at: http://tinyurl.com/n7st5jg

00 Information taken from Educator credentials search OH, available at: http://tinyurl.com/j7bxyhk (last checked 4/27/2017); state employee search, available at: http://tinyurl.com/kzp43af (last checked 4/27/2017); 2013 Missouri department of education directory, available at: http://linyurl.com/kw997d5 (last checked 4/27/2017); Linked1n profile, available at: http://tinyurl.com/m2'v28zc (last checked 4/27/2017)

Information taken· from Educator credentials search OH, available at: http:/ /tinyurl.com/j7bxyhk (last checked 4/27/2017); and Linkedin profile, available at: http:/ /tinyurl.com/mzvncps (last checked 4/27/2017).

IHli MAlfHIAl IS Dl$Thl]UTCIJ g1 A!.!SlcHOAM & PAHINEI-S IL~ ON :lf~Alf or rnE REPUBLIC OF TUR<;[; ADPl!IONAL l~f0R"4AIIO'i IS AVAILABlf AT IH: DtPAAIMi:Nl or JUSTICE \'1/ViHflGTON, DC

Received by NSD/F ARA Registration Unit

lhlS ',+AJERIAL IS Dl'llAltlUltD 8i Al.!SlEROAM & PARIN,HS IIP 0~ BfHAII OF !hf REPU3llf Qf IUHH ADDl!IONAl IWGf.lPIION IS AVAl!•.BLf ~I I Ht liiPARIMCNI Qf l~IIICF, IIM,i<l~(ilU~, DC

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Quick facts

► Region: Midwestern

► School Names (!<no~n as): t> Gateway Science Academy t> Frontier

► Total #'of Schools in State: 9 t> 4 Gateway Science Acadtlmies:­

Overseen by Concept Schools, and

included in Midwestern region t> 5 Frontier schools: Overseen by

Harmony Public Schools, and included in Greater Texas region

► Total Student Et!rollment 2015~16: 2789' t> Gateway Science Academies: 1285

t> Frontier schools: 1504

► Charter Holder/Governing Board{s): t> Gateway Science Academy of St.

Louis Organized as a non•profit 501(c)(3) organization Oversees the 4 Gateway Science Academy campuses

t> Frontier Schools, Inc. (formerly Millenium Education Foundation sic)

Organized as a non~profit 501{c)(3)

organization Oversees the 5 Frontier campuses

► Charter Management-Services Vendor: Concept Schools, Inc.

► Regional Gi.ilen O~anization Oversight

En~ty: ,Concept Schools, Inc.

Empire at Deceit: An lnves11ga~on of the GUI en Chaner School Nerwmk

► Regional Sister Networks: ·Math and Science (IL); Horizon (l_l.'.); Horizon,(OH);

Noble {OH); Math and Science (IN); Math

and Science (MN); Math ·and :Science (Ml):· Math alld Science {WI); Career

Academy {WI) .

► · TO ta I Revenues for the 2015-16 school

year: S 12,538,9111

► Gateway MO Network Founders:

t> Kemal Akkaya: ,lncorporator of

Gateway Science -Academy of St. Louis (MO); Board President of Gateway Science Academy of St.

Louis; former board member of MARTI, a Gulenist cultural associa­

tion in Maryland; led trip to Turkey for

fellow professors sponsored by the

Niagara Foundation and disclosed that it was openly·Gulenist; Professor

. at Florida International University. l

t> UQur Zengince: Email listed as Representative for Gateway Science

Academy charter petition;- f>rincipal HSA Cteveland: Middle School (OH);

Principal HSA Dayton (OH); Featured in

OH Whist1eblower testimony because of · his misuse of fedenil funding;"

Provided signature on. E-Rate funding form for Concept and :The Core Group,·

one of the vendors under investigation for allegedly defrauding the E-Rate program;- Superintendent Concept·

Schools; Superintendent Triad· Math and Science Academy (NC).~

Student enrollment anO Oemog1aphic information available at: hnp:/lt,nyurl.comlk6mbwly {last checked 411912017)

Figure represents only the Gateway MO schools, taken from the Gateway Science Academy 2016 audit.

lnfOfmation gathered from Articles of Incorporation, pg 67, avai~ble at: hnp://tinyurl.com/I2elx4y (last checked 4/25/2017); Akkaya bio from Gateway's charter petition, pg 13; Trip summary featuring Akkaya ~nd write-up regarding sponsorship of trip, available at: http://tinyurl.com11fjlyc6 (last checked 4125/2017}; Bio available at: http·/ltinyurl.com/kxbr6wv (last checke<l 4/2512017)

"The first day of school;tr'e principal, Mr. Ugur Zeng,nce - he goes by Mr. Zen. - pulled me into his office and said, 'You can teach English, right? You are going to teach freshman and sophomore English' instead of bemg a Title I teacher. They still were collecting federal.Title I moneY but rlad nobody performing Title I services~ Testimony available at: hnp://tinyurt.comlkdamb9a (last checked 4125/2017)

Information gathered from Gateway charter petIt1on, pg 7; E-rate form. available at: http/ /tmyurl.com/lln2o8s (last

l~IS l,IAl!~IAl IS 01$!fl3~1c0 5T •VSIHDA1J h PAl'l~;r.s llP 0'! CCf-.'-lf Cf r~= F,fF~511C 01 !~f.•<l A~Di110r,/ 1l 1·u 0f<'-IAll0IJ I: ~·1w ~31 i- .•I l ~, 0EP~~lU [I◄] 01 IUS! ICC. N~Scl~GI0'l, DC

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Received by NSD/FARA Registration Unit 07/27/2017 6:11:32 PM EmplreotOecalt: An l!'Vestigat1011 olthe G\/len Charter School Nerwork EmptreofDecett: An lnvest1gaoon of the GUI en Charter School Nerwoik

t> Emrece1ebi: lncorporatorofGateway Science Academy of St. Louis; Published- several:academic papers with ,Y. Alp Aslandogan, Gulen's·offi­cial spokesperson and Executive Director of Alliance for Shared .Values, Harmony (TX) landlord, and major Harmony {TX) vendor; Professor at LSU Shreveport.8

t> Taner Ertekin:- Established Gulenist

Overview

As of ·the ·201672017 school yea~. Missouri has nine charter schools within the Gulen Organization: Uiililteother states, Missouri is split across two regions of the Gulen Organization. Four of the nine charter schools are operated by

Gateway Science Academy of St. Louis and are managed by Concept Schools, which classifies them within the Midwestern region. The Other five charter schools are operated by Frontier Schools and are managed by Harmony Public Schools:(TX), which classifies them within the Greater Texas region of the Gulen Organization,8

The information in this profile is limited to the Gateway (MO) network:

schoolS in Thailand and Japan; Co-founder of first Horizon· Sc~nce Academies; founder of Concept Schools;-used·HSA Cleveland.funds to pay immigration expenses· for his wife; founder and president of Breeze, Inc., Concept's preferred Gulenist landlord entity; founder of Chicago Math and Science Academy. 1

Concept Schools, Inc. is the charter man­

agement organization responsible for the Midwestern region of the ·GUhm Organization charter network. Concept allegedly provides additional educational management services for the Charter SChoolS,for a percentage fee,of total school revenues. On average, the Concept Gateway MO schools sei"ve so% free and reduced lunch population vs. 100% district aver­age; 28.3% minority students vs, 88.7% district average; and 71.7% Caucasian students vs. 11.3% district average. As these numbers indicate, the Concept Gateway MO schools do· not serve a propoi"tional share of the vulnerable student populations within the city,

iSc:hool . - Operation student Demographic· Authorizer _ _,_ information• · '

GOV9mlng Boej Gateway Science Academy Grades K-5 cif Si:. Louis-Elementary 2010-present School Smitey Campus 6578 Smiley Avenue, Saint Louis, MO 63139

1.1%ELL 31.5% FRL 5.7%SWD

17.8% Minority 82.2% Caucasian

Lindenwood Gateway Science University Academy of St.

Louis

checked 4/25/2017): Linkedin profile. available at: http;/ /tinyurl.com/kjc.ze93 (last checked 4/25/2017)

Information taken from Articles of lnco1poration, pg 67, available at: http://tinyurl com/I2elx4y (last checked 4/25/2017); List of three art ides by Celebi and Aslandogan, available.at: http:/ /tinyurl.corn/lysxBvti {last checked 4/25/2017); see Greater Texas region for more information·about Alp Aslandogan; Celebi resume. available at http:/ /tinyurl.com/rnml9Ima (last checked 4/25/2017)

Information taken from Bond statement at A·23 describing Ertekin's involvement, _available at: http://tmyurl.com/keaa5f5 (last checked 4/19/2017); See, e.g., HSA Cleveland 2002 audit, pg 24, where a finding was made against the school for paying the immigration expenses of the spouses of Sedat Duman and Taner Ertekin, Concept's founders, available at http://tinyurl.com/zlpzg45 (last checked 9/B/2016i 2007 Breeze Inc. 990 form, available at: http://tinyurl.com/zj9xbzx (last checked 9/8/2016); CMSA 990 tax documents listing Ertekin, available at: http:/ /tinyurl.com/hdu6gbe (last checked 4/20/2017).

For more information about the Frontier (MO) network, please see the Missouri profile in the Greater Texas region

rH1S M'IEFIAI 10 UIOlklBUrto Ill" AMSrEP~Ar.t & PAHlll(fiS llf'ON RCHAII 01 IHl Af~U~IICOf lUR>.E\ ADDI] I0~ 'l INf 8AMn10~ IS ~VAIi ABll ,\I I~ f Of PAA I Ml NI Of IUS I ltl, WASH INGI o~. UC

Received byNSD/FARA Registration Unit

,~hool Operation Student Demographic Authortier .G~lrig.Baa~ Information•

Gateway Science Academy of St Louis-Elementary School South

Grades K-5 2013•present

9.9% ELL 68%FFIL 9.6%SWO

6651 Gravois Avenue, Saint Louis, MO 633;8

38.7% Minority 61.3% caucasian

Grades 6·8 2010•present

2.5%'ELL 45% FRL

3.8%SWO

Gateway Science Academy of St. Louis-Middle School 5049 Fyler Avenue, Saint Louis, MO 63139 27.2% Minority

72.8% Caucasian

Grades 9·12 2012•present

3.3'6.EU 55.8% FRL 8.6%SWO

Gateway.Science Academy of St. Louis-High School •5049 Fyler AYenue, Saint Louis, MO 63139 29.5% Minority

70.5% Caucasian

•student demographic information was taken from the 2015-2016 school year." "ELe indicates English

Language Learners, "FRL" indicates students receiving free/reduced lunch, and "SWD" indicates stu­

dents with disabilities.9

A History of Strategic Ambiguity and Conflicting Interests

After Gulen relocated,to the United States in 1999, his followers promptly formed non-profit educational· foundations, and filed, applications for the,first of the Gulen Organization's char­ter schools throughout the country. Some of the earliest charter school efforts by the Gulen Organization took Place in the Midwestem region orchestrated by a tight~knit group of Turkish businessmen, led: predominantly by Tener Ertekin-and,Ved8t Akg~n .. After formi~g_the first of the Horizon Science Academies in Ohio, these Gulenists formed:Concept Schools:to serve as an external charter man'agement organization

that would oversee the charter schools they opened throughout the.Midwestern region.10

Concept's efforts to expand into Missouri began in 2006, when the Gateway Science Academy of•St. LouiS formed, as a non-pfOfit

organization, led by·a,founding:board of Kemal Akkaya, Mehmet Kahveci, and Emre Celebi. All·three were graduate students:aUhe time of forming the foundation, which from our research appears to be typical of most founding governing boards for Gulen·OrganiZ8tion,charter schools. Akkaya lived and worked in Carbond8te, IL, two hours away from St. Louis; Celebi lived and' attended university in Rolla, MO, 8Iso two-hours away; and Kahveci lived and attended university four hours away.at.the.time: Kahveci eventually moved to,Colurribia, MO, still two hours.away. Two years after they formed the foundation in 2008,. Akkaya and: Kahveci-submitted 'a-c~arter petition to the Missouri Science and Technology Universify', which was unsuccessful. In 2009, they:submitted 1 the charter pe,ition again,_this

time to.Lindenwood·University, which approved them·to open the first campus for the 2010-11

Student enrollment and demographic information available at: http://tinyurl com/k6mbw3y (last checked 4/19/2017)

Concept Schools NFP corporate information, available at: http:/ /tin~url com/zallyt7 (last checked 4/20/2017).

I HIS MA I1 IIIM IS 1)1> I r:I11u It I) ~y AM~ It HDAM S f'~li I NE~S l 11' c~ llf Ml I 01 I HE HI PUBI IC 01 I Uf,, f Y i>DUIIIO~Al l~IO~MAIIUN IS AVAllA~lf >.I lhf OCl'AIIIMf~I ()f IUSIICf,WAlr1~1:rn~ Vl'

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Received,by NSD/FARA Registration Unit ,07127/2017 6:11:32 PM ~of Beceff; Af\ (\'l'j"eSll!lall'Jr\ o( t/1£ G(i!-e.n Crul.1lef Sci',oo( Nttwmk

school year/! During the entirety Of their.1ime on the:Gateway board,.Akkaya and Kahveci1 lived over two hours aw&'/. from St, Louls!2 During 1his time, Akkaya led a1trip P3ioifot by the,Niagara Foundation · to Tu11<ey for several of his col­leagues at the :Southern University of Illinois, which ,they documerited •extensively· and, noted that it was paid fur by the G.ulen Mo~ement.'3

0a1eway,expanded with its.additional cam­puses in 2012: for the middle and high school; and ln 2013 for the Gateway South campus. Concept has been Gateway's ihar1e-1 managemeri1 orga­nization since it submitted its first application in 2008.

According to media:reports, Cot1cept's most serious cootro...ers\l to date is t~ ongoing fBI investigaVGn concefning the alleged collusion of Concept employees: and th~r vendors to defraud tM federsf!E·Rate grant-program-of mlllicns of do!lals.t-t According to the released,FBl's search warrant application, Concept :eKecutives v«l­lated the competitive bidding rules of the E•Rate

program by seJecting a vendor complicit with Concept's plans to defraud E•Rate outside of the normal : procurement: process. Then, Concept's Chief Information Office, directed that vendor to divert hefty ·suboontraeU." to affiliated Turkish indi'.lidual$ and companies in exchange for _a cut of the proceeds-. The actual work was per­

formed bv Concept empkl~s themsetves, not by ihe eomplici1 vendor who was appn.wed•by E-Rate to prowde the work, o, the so-named

companies arid Turkish.vendors for the subcon­tra<:ts.~ tn· 2014, F8! agents raided -numerous locations throughouHllinois and Ohio, including Coneept-managed,schoofs,iConc~•s .regional offices, and the offices of sevetst-Gulettistven• dors .. Former ·concept execu1i...e ·Ozgur Safsoy was one of the purportedfy fraudulently enriched Turkish vendors Vfho was raided; 1e Acoording.to the same media teporl$, While Balsoy 1md, his businen remains under su~cion in the F91 lnvestigation, Conoept continues to give him and the o~ Turkish:owned vendors named in the $earth wcmam appfitation su-bstamial busi­ness? In fact, Gateway Science Academy uses Salsoy's business:to;p,ovide services, as-well.'~ lhe irivestigation is ongoing.

Mustafa Emanet, a form~ H-1Bemployee and Guleni.st, provided inter11iews to the F8' regard• ing hts work as a network administrator and teachsr at-a Ccncept•man~ schoo,j in Ohio .. He corrobotated that Ccncept purposefully used retated service provlders who overcharged, just as-he said all'of_the chaner networks did throughout the Gulen Otganization,l'i Since his cooperation with the FBI, Emanent and his wife, wl'!o was also employed with Coocept, Mary Addi, have come forward and provided, irifor­mation regarding the forced tuzuk payments and tithing, to the Gulen.Organil81ion required of Tutkis-h H-18 employees,l!l Emal'let,also pr_o• duced a copy- of the h.czuk agreement rtse!f,

Which j$ 8fl&ched toth!s report BS Appendix-·

iofo<matiot'\ avai!ab!e at t.iMeflWOOd U"i...ers,ty'scharter ~llS1tt!. ava1!aole at: llttp·//ti<'l'f,,l(!.CQ(t\//ymbl:lk {!ast checked 4/25120\7} aswt-!! as 1,om ~te,•,af:s- ,miia\ chao11e, pe111iol).

SeeAlfkaya"s resume. a11ai!ab!e at: hltp.J!til'lyur!.wml~b,&wv (~ checked 4'2512017).

Tri(.! s1Jmmary fe/Jlwing Akkara al'IO write-up re,garOing ~SbtS>'lip of trip, avai)au.\e at: http:/ Jtinyuncoml>f;)V,:-6 (last cllecked 4/Z!i/2011),

M',h6k>pou!~, Daf\ er\O SC\00(, fol\. Cn4<tef Firm ~ of Chuti(lg h:dt;r,./ Gren( Prugr11rt1, Chic.ego SI.fl• Tinle$ (December 16, 2015). Available at: http://tinyur1.comfijsnbad (last checl\ed 9/8/2016}

Search Warr am application available at. http:/ /tioyu1lcomfit9j4ed (last checked 9/8/2016!

See id.; see also M,halopoulos, Dan and Seidel, Jon, Cha,ter Fintt S1Jspecttd of Cheating Fedtral Grilnt Program, Chicago Sun-Times (December 16, 2015). Av.ii table at; http://linyur/.cortVjJsnbad (/an checked 91812016)

See Mihafopoufos, Dm Targeted Firms Still Get rax Money After Chaffer Raids. Chieago Sun-Times http:/ ltinyur>.camljimielm {!ast cnecked 9/81201&)

ASE provides day-camp services at Gateway, available at: nrcp:Jltinyw-l.camnn<1apc5 (last criecked 4125/2017)

" Searcl"I Warranr app!icat1on, pg 44, available ar: http://tmYtJrl.comijtsi4ed Oastchecked &1812016)

,., 2015 letter from Mary Addi and Mustafa Emanet ta OH legislarure, av<1ilab/e at: http://t1nyurl.com/mea'1pJI.' (la51 thf'Ckeo 4/:!0/10,7)

rn, \IAltf.lAI IS LIISJJ,l~urrn ~· ~M<:HHOAM S f'MillliRS Ill' □ 11 ~!HAit m l~l HtPU~ll( Of ILJH,,Y W!)I I !!)II 11 !~f!)~\\\!)1)11 IS ~;1MI ~~! r ~! I~) D;;f'/,~ l\lfll) I;) ll,1~111:\, Y!~)filllf,)!)11, Vi,

Received,by NSD/FARA Registration Unit

Financial Abuse

Missouri requires its charter $Chools 1ounde;go annual audas. A review of~ audit& re-vealed the extensive amounts,Gateway paidiin rent·to New: Plan ,Learning, .the'Gufenist--con1rofled:reaf estate am~ of Con~pt SchOOls, Gateway's prop­erty arrangements are dlscuS$ed:in,more detail in the Real Estate section below, furthermore, the audits• 8!so1 revealed -tha1 Gateway's- tin-exempi status was in jeopardy, due. to as repeated faaure 1o file mandatory-JRS,iax.documeotatton fo, lit f11s:t 1hree years of opera1ion. ii

While ·the Gateway MO audits .are overall

Real:Estate

One of the mast-significant profit centers for the ·Gu!en Organization, and in. partkuJ&f the Midwestem region. is thtough real e$t_e. This property financing scheme ·has been replicated throughout the country-in.fact, Vahap Uysal a board membet. of Cohcept Schools,u wrote· and

presented an article entitled ·Golen ·Movement and :Schoof Rnancing ... at the Third. Annual conference on Islam in the Contemporary Wortd: The Fethutlah . GU.ten Movement in Thought and· Pracitee." Guh!niSts ihrooghout the country attended;and.·presentlm, indtldl-ng Alp Aslandogan, former Harmony Pubtic Sctloots landlord, CEO of one Harmony's farges1 vendors, property buyer from Dove . Science Academy, ahd Guteh's official spokesperson-in his ro1e·as Presitkmi otthe Alttance t01 Shared-Veiues,·a GuleniSl cultural organitation,t~

" Gateway Sciern::e Academy 2012 aud/1.

£mpife rd Ueuft: M, 1rn~1~i1icn ~ 1~ Gulen Ct1~1e1 Sctiool f,J21WNi.

much cleaner ihan its sister.-networks within the Gu!E'n Organization, Gateway -utilizes the same Gulenist vendors currently being investigated· fly the FBI for defrauding the·federal E-Rate pro­gfa_m, Because Gateway use!!. the same vendors implicated in the FBI tn~estigation and identi• fied by'Concept whiSUeblowers as;fraudulent, a forensic:accounting, which.•examines speei1ic payouts ~o vendor$ in compadson to goods and oowic.es actuaUy recelved· wDUSd !ike!y ,eveal the -same pattern of purposeful overCharging and underpertormance endemic across the. Midwestern region and the Gulen Organization,

Early· on. the founders of the Midwestern region esiab!ished Sreze;lnc._to acqui,e prop­erties- for Concept Schools throughout the Concept network.~ New Ptan leami"g was created shortly thereafter, and now ac-fs as the non-profit umbrella otganizatfon for areeze and severah:,rher wholly owned subsidiaries:. n

Murat ArabaCI, a former Concept-: employee/' has managed New Plan Leaming and each of its subaidlaries-Mnce,2005.n Together with its subsidiaries, New -Plan Leaming buys, reno­vates, leases-, and sometimes sellS-,properties to Corteept~managed schools. New Plan Learning daims·.Jt operates 8$ a suppo,-ting organitation to its Concept school tenants, but in real~ ity, it buys properties that it then rents to the schools Bi egtegicu$~ high lea~ rates. This model ciUows the Gulen·Organiution .to acquire

tt s«,> CQn<;C¢ Sc!7o<m 990 ta,.- fomi,ava~ahliz. at; hnp:JJtinyur!CM11r15yvilt.

" Conference- was~ N~ 3, 2007 irJ Sall Amaril(J, Te-,.-as, arid the cordererice-agenda is aWt~al:)1(/ at: hnpJJt,o:,i11rtrom/9'2'N.JS \last ~\r.00 Octnbe< 31, 1.016).

" ~ Texas profile Kif more. irifon-flaror\ about Alp Aslaridogi31\.

" Ni:-w ?Ian le.aming, Int- 20lV, Boll~ Offic'al Sralemimt pg A-4, ewi!able a\: http://tinyurl.com/lxoauxp llast dlecked 9/6/2016}.

'" N!!W Plan. Leaming, lni.:. 2011A &nd Ofka\ Statement pg A-4, A,5, 1111ail.ible at: http;! /tinyurleom/z:,-:Oiiuxp (1.ist checke<i 9/6/2016); see ab;o fahibit A for Property inform anon, inc!udiog la11a'lords, rent, arid traosfer history for the fac,lities of the on,a Concept &hoo~

11 See 2007 Com:-ept990 with Arab-¥(;i listed as empleyee, avarlaolear: http:llfinyurl.comlts-y:Satn Oas! cnec..ea &/8/20'1e).

See Busirle'S!l" pro-Me for New Plan Leaming, l~c,, $howiog rt:. iocorporatior1 in 2005 and iiSting Atatiad as agent, availaole et: l'll1p:/ltmyurlct>m/hu2of«7, {~ checkeo 9fe.J201fi~

!~IS M,'-HRIAl IS Dl'ilo1%HD 61 AM5llHDAM ~ PAHl~lVi lLP or, BffAlf OF [hf RfPU~IIC UI IUH,f1 h!)tJl/10/Ml l'iHlO'l!MIO'I ):; h/Ml~%t ~1 l~t bC?h~l\k'll f/1 )~$nO-, #1<5fll!;i,H·½, !It

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,property which it pays for with public tax dollars, and if the charter school is terminated or non:re•

newed, the publicly financed· property remains in the hands of the Gulen Organization.

Currently, New Plan Learning owns the Gateway ·South building under its subsidiary 6651 Gravois LLC. New Pian Leaming purchased the building in 2012 for $1.2 million. In May of 2013,

:the Gateway governing board entered into a'fif­teen-year lease with New Plan Learning. Per the terms of the tease, Gateway is.also responsible for all costs associated with the· use, mainte­nance, financing, or repair•of the property and all Utilities, insurance, periodic capital replace­ment reserve amounts and management.fees. The base rent started at $32,800 per month, which increases·each year of the·lease. From the lease's inception in August of 20l3_projected through to July 31, 2017. New Plan-Learning will have collected $1.6 million in rent for the build­ing," $400.000 more than the price it paid. By 2028, when the lease·term·ends, Gateway will

·have,paid'New Plan Learning,over $6.7.million

dollars in rel'lt.30

In contrasno the $33,000+ rent per. month Gateway pays New Plan Learning for the Gateway South facility, Gateway pays only $10,000-$11,000 per month in rent.for.the Gateway Smiley cam­pus.31 While Gateway will pay $6.7 million in rent

to New Plan L:.eami'!g from 2015-28, Gateway will·pay only $1.8 million for the Gateway Smiley camp Us over the same period, nearly four times' iess.32 Based on our interp~tion of the evi­dence, the rabonale for this extreme discrepancy is clear; Gateway rents the· Smiley campus from an-actual non-profit·CJ!ganization ~at is unaf­filiated with the Gulen-Organization and is not seeking to exploit its public resources."

Gateway owns the Gateway Middle/High campus in its own name, having purchased it in 2013 from an unaffiliatedthird Party for $795,000.,.

Thus, according to Gateway's proposed 2016 budget, approximately 72% of.the funds it allo­cated for property leaSE!s and payments went to pay for only one o_f its three campuses, the one owned by New Plan Leaming.3~

Egregious rents far above the purchase.price are not.the only means that New Plan leai'ning, Concept, and the Gulen Organization extract public funds in real estate. Hiring Gulenist affil­iated contractors.who routinely overcharge and underperforrn is another critical mon~ymaker for the Gulen Organization. Just as it had throughout Ohio and Illinois, New Plan Learning hired Quality Builders of.Midwest, the preferred Gulenist con­tractor for the, Midwestern region, for a million dollar renovation of the Gateway SOuth building at the school's,additional expense.:se

,. Figures (actual re flt paid 2013-14, 2014-15, 2015-16, and projected rent for 2016-17 as this audit has not been conducted as of the writing of ttiis rel)Oft) taken from New Plan Learning's financial reports, available at: http://tinyurLcom/m6xmpc8, htll)-//t1nyurl.com/kradwj6; http //tinyurl.com/122Upv. and http://1inyurl.com/l191Qze (last checked 4/25/2017)

"' Gateway Scieoce Academy 2016 audit projeciioris. pg 14

Gateway Sc,ence Academy 2012 Audit, pg. 11.

" li,e Gateway Smiley 1ent pro;ec:ions are based off o/ those con:ainec! in the Gateway Science Academy 2016 aud1I project,ons, pg 14

ll Gateway Science Academy 2012 Audit, pg. 11.

,. See sate price, available at: http://tinyurl.com/mtnbhdc; purchase details at: http://tinyurt.com/he9grU6 (last checked 4/25/2017)

,. Budget, pg 112, available at: http://tinyurlcom/l2elx4y (last checked 4/25/2017)

" Project details, available at: http://tmyurl.com/mpml25u (last checked 4/25/2017). For a list of other projects Quality Builders has performed for Concept-managed schools, see: http:/ /tinyurlcom/kmbj878 {last checked 4/25/2017).

1e1s ~AEHIM IS UISIHl:lU!:u ST AlilSIOf,OH( & PAHl'likS HP ON B[H.Lf OF TH i'CPUBllt 01 IUH>:EV Alilll I IONAI INf ORMA T 10f! IS ~VAIi A:llf .<I T Hi Df PAHl ME~ I 01 IUSl ICE, \'l'AS~l!lGIO'i, UC

Received by NSD/F ARA Registration Unit

Bond Financing

In 2011 New Plan Learning expanded its capital significantly by applying. for a bond for approximately $33 million dollars to pur­chase, refinance, and/_or renovate four Concept schools, CMSA and three Concept OH schools­·HSA . Dayton HS, HSA Toledo HS, and HSA SprinQfield.31 Due to their inclusion in the bond, these· schools are now• subject to extremely high annual:rents in non-cancelable leases set to expire in:2041.38 The bond was issued,by the

Empire of Deceit: An Investigation of the Gui en Charter School i'letwork

lndus1:rial,Oevel0pment Authority of-the County of· Pima, Arizona, the same organization that issued :bonds for both the Sonoran ·(AZ) and Coral (NV) Gulen Organi~tion charter net­works.39 Nev.r Plan•Learning·has not implicated any of the Gateway MO schools directly in a bond to date, but the rental income from G8teway MO is reported·as part of the New Plan·Learning's assets to justify the bond financing.

Abuse of the H-1B Visa Program

Like all Giilen Organization charter net­works, Concept and their MO schools utilize the H-lB-visa:program to immigrate·large numbers of Tuntish.GUlenists•into the·United!States.for employment in the schOOls and netw_ork. The Concept Gateway network filed 30 H-1B appli­cations. from 2001-2016, while Concept itself filed 176 H-1B applications during the same time period.•0 While-the.Gulen Organization typically states that these H~lBs are only,to-fill shortage areas for math and Science teachers, these appli­cations were filed for such positions as: physical education teachers, school business managers, administrators, and schOOl librarians.

Concept and Gateway MO use the same immi­gration attorneys to file and process their H-lB applications as other known Gulen Organization charter networks, vendors, and cultural associa­tions, indicating once again the existence of an o\lel'8II network. For example:

► RemzH<ulen:•Concept and Gatew~y MO used1Kulen, a New York-based attorney,

to file numerous .H-lB applications.•1

Kulen also filed ~pplications for: t> Concept Schools (OH, IL, IN, Ml, MN} 1> Pioneer.(MA) 1> Niagara Foundation (IL) 1> Young Scholars (PA) 1> Golden Generation Workshop Center

(PA)

1> Blue Ocean Construction (FL) 1> Academy of Science, •Syracuse,

Buffalo (NY) 1> Arts and Science, Bergen, Passaic

(NJ)

► Mustafa·Genc: Gateway 1 MO used Gene, an;lllinois-based·attorney, to file numer­ous H-lB applications.•2 Gene also filed applications for: 1> Concept Schools 1> Horizon (OH) 1> Noble (OH) 1> Math and Science (IL) 1> Math and Science {IN)

" New Plan learniog, Inc. 2011A Bond Official Statement, available at: http://tinyurlcom/zxoavro (last checked 9/6/2016) .

30 Id.

,. Pima County bond ,ssuances, available at: http:/ /tinyurl.com/kards94 (last checked 3/30/2017).

.. Gateway MO sc~s filed 30 H-18 applK:ations from 2001-2016. available at: htll)://t1nyurl.comJmhmefs9 (last checked 4/24/2017). Concept filed 176 H-1B ap?ications 2001-2016. See http://tinyurl com/j3whatt for Concept Schools. Inc.; http./ /tinyurl.com/zhgx3x1 for Concept Schools Nip

List of entities represented by Remzi Kulen, available at http://tinyurl.com/gptwx5x (last checked 3/2112017)

., List of entities represented by Mustafa Geflc, available at http:/ /tinyurl.i::om/ko77hqq (last checked 4/24/2017)

I IIIS MA 11 HIA! ·1s 01$1 Rl8U HO 81 Al~'> TE HAM ~ PA~ I NEfoS l LP 0~ 3EC ~lF or I hE REfrJBl IC o+ TUhfY AOfllllONA( l~IOHMAIIC~ 15 AVAIL AHif ~I lnE D!PAfllli!E~l or IUSTICi, WIStil~GJO~. [,['

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,.

Received by NSD/f ARA Registration Unit 07127/2017 6: l I :32 PM tm:plN. It Qiectl\t /1.n \rNestig~tioo 11\ ti:11!. CiU.\en Q\artei Sc\\CIQI Netw(l(\<.

• Dav¼.\ Nac"me.n: COf'\Cel)\ used Nachman, a New·Jersey-bas&d a11omey, 'lo file H-lB­a-pplications.~1 Nachman al.so flled H~la iipplications ror: !7-- M'ilk\'Way Education.Centef(NJJ e> Patersoo .Charter SchooHor Sciertce

arid Te<:hnolcgy (NJ)

► Nu?hat Hafeez: Concept MO schoots.

Notable Turkish V:endors

► Concept Schools, lnc. Concept is a com• prehen$iW! services vendor that controts human resources, fi:scil management, school design, curriculum, accountability, C()mpliance, and,,report\ng for a ten pet'·

cent fee of each school's 1otiil revenues.'~ Currently, Cone~ is the contracted r'!onprafit _ ma~t ser,..iees vend«

for thirty such charter tc.hoo!S, with sev­enteen sc-hOffis·in-Ohio, four in Winois,

three in-Missouri, three in Indiana, one in

Michigan, Orte in Wisconsin, and one in Minnesota.* The founders of the first OH charter school!. in the Gulen Otganiiation formed Concept short1y thereafter,

► Breeze l"c./~w f>lan:Leaming: Sreeu, lrvc,, was cre1ded in 2004 as a Jor-profit

corpolation 10 acquire ptoperties fo, Concept Schools throughout the Concept

Network/' Niaw P{e,n Leaming-wa$ 1::re­ated thort1y·1hereafter,.and now aclS as· the non-profit umbrella,organlzation tor

Breeze and severaJ·other-wtn;,Uy·owned subsidiaries. U'lcludirJi1 8851 Gravois

used Hateez, an lllinois.-besed attaroey, to file numerous H-1& applications.~ Hafeez atsQ fited t,M8 aP¢icatiOns tor: p.. Concept SchooJe, ln:c. 1> Niagara &ducational" Services, Inc.

{le)

1> Niag<.'ra Foundatioo {(l) t,. TheCoreGroup(IL)

LLC, the ~e, of 1he Ga1eway South property." Together with its suhsi-di8r­ies, New Plan Leaming, buys, renovates, leases, and sometimes selfs properties to Concept-mtt!'\U:ge(l· schoots. allegedly as a supporting organitation to those sthools.

,. Quality Builders of Midwest: Qv1dity Builde,s. is a construction compar,y · that does the majority of Concept.amt·NPL's construction work!' Several Of Quality Builders' Gulenist employees have wocked.stConceptandi~ schaot~.asweU as at other ch11rter,networks throughout the Gulen-Organiution. Qualify-Builders wet hired-.by New·fltan Leaming to do a

million dollar renovation on the Gateway Southp,operty.

" Ad\faflced ~utions fror f~: Advanced S01ution$ for Education, owned by former Concept emptoyee Ozgur aiil~ is also :implicated • ir, the ongoing

F8J inve.stigatiQll regar~nq the defrauding

., Nati'lmar. profile listi119 1l.1'\ti1ies 1ep1e!;~n,eo fu1 H•1B -.iisa wo,-k, a-.iai!a~ M http,Ntiny:,rl.comlny5h.Jtv (>.itllt check.M 4t)J!2017).

.. Ha!Mz prafi!e!iS!(l'lgelttiti~ represented tor H~1e vis~ work, av.ii la~ IN: t.t1p•J(t11'1)1111!.rom/f!Wn'M.3'1 (!a.st t~i<.e'l'l 4i1u201n.

.._ G;,i~ Scie,nu At:.&Ol)J'T'J)' 10\1 audit, pg,, 12

"' Si,e Ctmcf$1 St~ )')P,wt,/li., av3il3t)ll)- 31; tmp Jf!lllyl)JitPm/;z3oSQs.t (~ i;hec-1\eri i\f2612(l16}

" New >¾11 Leamir.g, !111:. 2tmA Semi onic-~! S1Mimwil pg A--\ aw,)lal:41!' .;1: 11ttp:Nti!1~\Jrl-OOm(l~'--'~P \last ~ 9(Gf201lil .

"' New Pl.in learning, !ric. Wt1A Bo11d O««:ia! Statemetit ~ P..-4.., A·5. a..-ai!ab/e .it: h(tp,(((i~yurl,-comfi~o.a\l~µ (!3~t-ch<ilc~ Sl512U15); ~e a.\.VJ E:tniM A ful Prope1ty informinit>fl, inthJD!t>g iallrllorrls. 1wi, Alnd t1a/'!Siei r',istc,ry fr,r tl"l1;>¼-t-i!i1i~ of 1he Ohio Cor.~pt &choo\~

.. See pro~\ if'lmimatioo, availatl\e: at hl.t?:I /tif'\yu1\.comltwlkl(_fl \last c1'e<::\<.e<:! 111il/'2.'l16),

(MIS VHtH~( rt OISfHolJriO :!, AMSl!~O!M, PAM'i:'R' ((P01/d{ff\(f ()/ l~t i'if:/0[[[ flf l!JF•·fr M:,\lll\(l\i,\ I'll (J~IH! 1Q'I I~ ~~~!\ ii)\~ ~l !~i {l,:Pi~!\\l'.11 \II 1\J$l\CL ~,~SHt\(.\(l''. I)(

Received by NSD/f ARA Registra\ion Unit

ot the E-Rate program 'oG The company served as an E-Rate funding consuhan1 to

&nptni 111:htttt: AA lnves.tiga110n tif the Gulen Charter St.\loo\ Networ\l

the schools and a\s.o prowtes ~ to 1h& Gatewa-)' MO ne-twork."

GDlenlst Cultural Foundations

" Turldsh American Society of- Missouri: Gulenist cu1turai association thal works In St Louts.alongside the Niagara F<iuodation to lobby political leaderi,, host dialog. din­ners, and $J)Of1SOf trips to Twkei~

• Niagara Foundation: The Niagara Fournia1}Dn is- a-majos Turkish-Gule-nist cultu-ra} association based in Chicago. Gulen is its honorary president.53 Niagara Educational Services, Inc., oversees the Niagara Foundation, the Science ~demy of Chicago, a 1private Gukmis.t school, and is very active 1hroughout

the Midwestem regiOfl. f"(l.f eJ.ampl'I!, in-2001, ttle Niagara Four.dation ga_ve- an eldeni.ive loan'.to·Breeze Inc. (New 1f>lan Learning's. predeceuor) to purchase new properties for Coocepi cha11e-r schools . .;. Several Concept employees :as well as school employees a,e "1embera of the Niagara Founda1ion. -Niagara pnwides free/low-cost trips- to .iu-rkeyJ'or legfsfa­tors, as,WE!ll,as hosting dialogue dinners and fundraisers.~ In Missouri, Niagara·

assisted the iurkish American·Sodety of MiS$0Uri in ~s1ing s dialog dinner for the s!al& legislature.~

Individuals Caught In.the Glilen Organization W.eb

Our research indicates that it is quite common for the Gulen Organiiation charter networt<:s within a region to shuffle their Turkish H-18 visa teacher$ from school .to school, as well· as between regions. This is just a small,number of

i(ldividuals with these overlapping ties rh,ough­out the. region, which · further demonstrates .the region's intercormections.,Notilbfy, this shuffling 01i!y occurs with Turkish employees .

., Engln Karatas, a.k.e. Engin Blackstone:

eo~fou-nded Chicago Math and Science Academy; Assistant Principal HSA DeniSOfl Middle; Teacher, H5A Clevefand Middfe (Sarne year.as he was a,principal at HSA

Toledo); Principal- HSA TOiedo; Principal Quest Charter Academv,· Assistant Principal Wisconsin C<!:reef Academy; i.istted Fethu!lah Gu!en et the Goiden Geneni.tion, Retreat Center with Concept wf1ist~ Mustafa Emarurt; Superin- Gateway Science Academy (MOJ.v

... See Mt>a\ope,ll!oo,. Dar,. nwgerea Ai'sm SfifJ Get fp MMfy All'l!t ~, Raid$. ChiUgo Sur,. T,IT!e$

htto:11tm;-1.1rl.camljzmzevh {/ifSt checked 9/8/2016t

AS€ i;ir~ dey-,;amp sen.ices .at Gateway, available at: http"l/t1~1.1r/.cor11111140pc5 (~ ctiecl:ed 4125120! 7}.

"' See, eg., EVE!l'1t detail$ with M,ssouri !awmake<s, Niagara and TASOM, avi1i(at>le at hll:p://tinyurlcom/I28269:f {las! dlixked 4/25/20in

"' See http:llwwwniagaralovndation.orgl to, inlormation about the N.iaJtara .~oundaliot'I arid tittp:/11,nyurl.comldt-tlv~ tor i11tormat'1on about GU\en as HOnorary Pres·1de11t {last cnec\<ed 9/612016)

,.. Aud11 ava'ilao1e at: \1ttp:/ltinyur1.com/haos4qu t1ast cl1ecked 9/812016)

"" For a description ot a legislator~ trip tolurkey witl1 the Niagara Fouridalion, U!e: http:t/\,ny\lfl.corn/m~ (4}$1. ¢'«.1'.ed 4f'l0/2011).

"' ~. t:1.9-, £-.iE:.-fl1 oelai\s wi\h MiS!,Ollli lawmaken. Kiagara, and TA.SOM, IJ'r.lilable ;n: t1ttp:l lt(fl<{W"!.COm,'IV32'M (last QleCked ,1/25/2017)_

~ !11:!o«natian ~ «-001 an interview with Engm Blacicsttme, ave:it.ab!e ac http.Utinyu.rl.comlmw!lbey6 (t.m chf!cio:.oo 4/23/2011); 2Dl5 Lei'\e-ffrom Mai¥ Ado> 300 M~stafa E~~ 11> OH ~s\.aMe, .wal!ab~ at: tmp:/lli¥r!.commienljp;. (la-st chec~ed 4/20/2017); Unkeeifl.profile, available at; http://6·n,-(lrl.comllylm33o Uast clied<ed 412512-0ti'); and state emp!cye-e sa\ar)' ~aich, iwai!~bleat l'lnp://1i~ilcom/kl,o43ai \lasl cl'letk~ 4/27/2017} {warching ~11-i 'Engm ~rata!i" and 'Erlgin 8Iac;l(stone'}

/i,i) ilA/fH~( IS ()/S/i'f~IJ/£0 i,1 M.IS/ifOM.t ~ PAff/i;f/'S [(f 0'13!C,~(i Oi i~C Uf-'IJ'!JICM ILJ~,f! ~0\)!(!(l••H ('<\ Of:1J.~t1a:, l~ ~·/Ml;',LC l/ (t,~ OtPHl\\'. 'll ,;;, !'J$!!Ci:. v1\<;C('t(il(l'I_ oc

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"

Received by NSD/FARA Registration Unit 07/27/2017 6: ll:32 PM Emplreol Deceit: An lnvest;ga1100 ol1he GUlen Chaner School Nerwor~

► Nuh Celik: Substitute teacher, HSA · schools (OH); Teacher, HSA Springfield (OH); Director HSA Denison (OH); ,Principal Gateway Smiley campus (M0}.§8

► Mllrat S8gnak: Substitute teacher, HSA Cleveland {OH); Principal, HSA Denison Middle (OH); Principal HSA Dayton Downtown (OH); Principal; Gateway Middle/High (Mo).K

► Cenk Kandemir: Substitute teacher, HSA

Toledo (OH); Teacher, HSA Cleveland· (OH); f:)rincipal, HSA. Cleveland Middle

{OH); Principal, ScieilC:e Academy of

Chicago•(IL); Principal, Gateway Middle/ High (MO),ff0

► Cengiz•Karatas: Substitute teacher, HSA {OH); Principal, HSA Cleveland (OH); Founding Principal, Gateway Science Academy-Smiley (MO); Director of Concept Educational! Programs:! Director

· of Concept Alumni Network. on

Notable Articles regarding the Missouri Network

► Mihalopoulos, Dan. Targeted Firms Still Get Tax Money A~er Charter Raids, Chicago Sun-Times http:/ /tinyurl.com/

jzmzevh.

► Mihalopoulos, Dan. Federal funds for clout school operator despite probe. Chicago Sun~Times. (May 7, 2016) Available at:

http://tinyurl.com/jmy8web.

► Crouch, Elisa. St. Louis Public Schools tries to shed·vacant·buifdings. St. Louis

Post-Dispatch. 17 April 2015. Available

at: http://tinyurl.com/zk83ux8 (1 March 2017).

► Miha10poulos, Dan and Seidel, Jon,

Charter Firm Suspected of Cheating Federal Grant Program, Chicago Sun­Times (December 16, 2015). Available at:

http:/ /tinyurl.com/j3snbad.

► SLPS selfs Gardenvif/e·SchOO/ to-Concept Schools for $1.2M. The St. Louis American. 16 August ·2012. Available at: http://

tinyurl.com/js98995 (1 March 2017).

► Cambria, Nancy.· Charter school final­izes purchase of vacant St. Louis school. St. Louis Post-Dispatch. 24 July 2012.

Available at: http://tinyurl.com/j4Czbj4 (1 March 2017).

► Crouch, Elisa. Slay defends role as recruiter of charter schools for city,·25 April!2011,

Available at: http://tinyurl.com/zaz8n9y (1 March 2017).

► Clubb, Shawn. Parishioners say goodbye to St. Pius V schoof St. Louis Post-Dispatch.

5 December:2008. Available at: http:// tinyurl.co"m/zo6owfw (1 March 2017).

,. Information taken from educator credentials search OH, available at: http-//tinyurlcom/j7bqhk (last checked 4/27/2017}; Concept newslener 2011. available at: hnp./ftinyurl.com/jwbsmzt (last checked 4/27/2017); Missouri Department of Education School Directofy. available at: hnp'//tinyurlcom/n7st5jg.

" Information taken from educator credentials search OH, available at: http://tinyurl.com/J7bxyhk (last checked 4/27/2017}; Missouri Depaitment of Education School Directory, available at: http://tinyurl.com/n7st5jg.

00 Information taken from EdllCator credentials search OH. available at: http://t1nyurlcom/j7bxyhk (last checked 4/27/2017); state employee search. available at: http·//tinyurl.com/kzp43af (last checked 4/27/201n 2013 MissOtJri department of edllcal1on directory, available at: http://nnyurl.com/kw997d5 {last checked 4/27/2017}; Linkedin profile, available at: http://tinyurl.com/mM8zc (last checked 4/27/2017)

Information taken from Educator credentials search OH, available at: http://tinyurl.com/J7bxyhk (last checked 4/27/2017); and Linked,n p1ol1le. available at: http://tinyurt.com/mzvncps (last checked 4/27/2017)

IHI\ ~AltHAI IS Ul(l~IBL•itO 51 l~ISIEf<OHI ~ PA~J~CF-E !lP ON 3t~Alf C! 111t F.EPUilllC (\! TU~KlY ADDII IO~AI I'll O~l,IAIION IS ~V~ILABlE M IMC UCPAf,IMC•J I 01 JUSIICt, W~SHl~GIU~. DC

Received by NSD/F ARA Registration Unit

EmptreolDecdt: An lnvestiga~oo of the GUleri Chaner School Ne1wor1<

lhlS I.IA!ERIA[ IS Ul~TF-1au1:o Bi A\l'lH!liA',! ~ f'~HINEfi! ll~ C1J MhAII Qf TH! ~fPUSI I(" O! IUhKrY ADOITIO~Al INfDR\IAllOIJ IS AVAllABlf II l~E OC~AR1Ml1H Of l~Sll(t, WASCl~GIO~. [)(

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Received'by NSD/FARA Registration Unit 07/27/2017 6: 11 :32 PM EmpiNotDeceit: An ifl'lestrgation of the GiJlei, Charter School NelWllfk

boards (though the directors were identical to Daisy's board members). In 2012, however, Daisy created Sonoran Schools, Inc., to serve as the charter management corporation for 811 of its schools, including Paragon Science Academy. After that. Daisy forwarded the multi7million dollars inipayments it was receiving.to·provide services to the schools to • So no ran Schools, Inc. While the numerous corporate entities at this point were separate on paper, the evidence would suggest that all of these entities were basicalty controlled by the same group of Turkish individuals.8 Sonoran Schools describes its his­tory as that of Daisy's on its website, further cementing the:lack of.true distinction between these entities.'

tn 2014, Daisy merged with Paragon Education Corporation, SSA-Phoenix Metro/SSA-Peoria, and, SSA-Davis Month an, with, Oaisy,remaining as the surviving corporate entity. SSA-Broadway remains a legally separate entity, thoUgh its board is comprised of the.same:individuals as Daisy's and Sonoran's board. SSA~Flagstaff and

Financial Issues

Arizona requires its charter schools to undergo.annual audits, which are made·public.

These audits showcase a series of ongoing finan­cial issues at the Daisy/Sonoran charter schools that are·endemic to other Gulen Organization

.charter networks. Our researCh suggests that these issues demonstrate a lack of financial con­

·trols, documentation, and transparency that are critical to obscuring the true use.of state and

federal funds by Gulen Organization charter

SSA-Oro Valley·are currently. registered corpo­rations in Arizona, though !10 charter has been approved.for either location to date.

Daisy.pays two entities for arguably duplica­tive services-Sonoran Schools, Inc. and Accord Institute for Education Research. Sonoran serves as the management entity in charge of the schools·and,is paid aihefty fee each·year, with $1.6 million in fees from Daisy to Sonoran in 2016,1 and:$1.4 million in 2015.9 Being.that SSA­Broadway_is a technically separate entity, it pays its own·hetty fees to Sonoran. In addition to the fees Daisy schools pay to·Sonoran, _the schools also pay amounts undisclosed:on:their-annual

·audits·to·Accord, which were uncovered by a local reporter's public record req~ests.10 Vf~ether these fees are for dupficative services as·Accord and Sonoran provide similar serYices is difficult to ascertain due to the secretive nature of Daisy/ Sonoran's relationship with.AccOfd,and•should be•investigated as GUlen Organization charter networks have. been caught paying funds to sham entities for. duplicative services before,11

networks. The frequent inter-entity lending prac­tices in,particular-from school to·school, from schools to their governing board Daisy, from Daisy to its hired management vendor Sonoran, and even from schools·to:sonoran-is a'known waming:sign for money laundering.'2 There are also issues•with accurately·documenting atten­dance, absences, and withdrawals.of students throughout.the GU/en Organization charter net­

works. Failure in this recordkeeping, intentional

The overlap between the boo1d member$ of the three primary entities. Daisy, Paragon. and Sonoran Schools.~ il\lailable as Figure_.

Sororan Schools, Inc. About Us History Section, available at: http://tinyurl.com/grskxft (last checked 1/26/2017)

Daisy°! 2016 financial statements. available at: http://tinyurJ.com/jbwwswt (last checked 2/2/2017),

Da,sy's 2015 financial statements, available at: http:/ /t,nyurl.com/h5opusm (last checked 2/2/2017).

Tim Steller, S,, Reporter; What does S36<1k in Tax Money Buy These Charter Schools, Arizona Daily Star (Oct. 22, 2010) available at: http://t1nyurl.com/ht36ex6 (last checked 2/1/2017).

See, e.g., the Georgia chapter,

The Anti-Money Laundering and Countering Terrorist Financing Guidance 10 accompany the federal and international legisl.:!tion I st numerous unusual transact,ons made with little to no justification between affiliated entities as warning signs. See Guidance at http.//tinyurl.comtzb56~el (last checked 9n/2016)

lHS \!Ali~l>l IS DISIF1%1CO ~I A\l<;JCFOA\! J, PAPl'lffiS LIP D~l OC~•ti Cf TH ~\PU311C Of lU~•fl. A00111~"1•t HlfOP\!AliC~ IS AVAI\A~li A! 1~, DEP.l~J',ICIH CF J~Sl!Ci, w•st-1•1~l()•L D(

Received by _NSD/F ARA Registration Unit

or not, may allOw a school to gamer the most public funds while educating the least number of students. If intentional, this method particularly takes advantage.Of"problem" students, whose truancy is pu~posefully unreported while the schools continue to collect their FJE funding. Similarly, there·are issues with accurately doc­umenting free• and reduced meals for students throughout the Gulen·Organization charter net­works. Again, this method would be effective for gamering the most public funds while serving the least number of students. Lastly, the fact that these schools do not maintilin accurate and com­plete immigration records for their numerous

foreign employees, including state mandated fingerprint,testing, is yet,more evidence of the Gulen Organizatior's suspect and excessive use of the federal H-1B visa program.

The,numerous audit findings occur across multiple years and at multiple schools, including:

► Lack of Compliance with Required Financial Procedures .and Accounting Standards: t> lack of completed financial

statements; t> failure to file affidavits of publica­

tion of notice of the public hearing to adopt the budget;

t> joumal entries not prepared on proper forms;

t> lack of approval by .administrator before recordiiig j~urnal entries;

t> entries without auditable trails; t> budgets published · before meeting

held to vote on budget; t> deposits not monitored; t> incomplete capital asset schedule; t> insufficient unrestricted cash

reserves; t> subsidiary ledgers and quarterly tax

returns did not match the general le~ger;

Empire of Deceit: An 1nvest,ga1,on of the GUIE11 Chane, School Network

t> incorrect overbillings for school lunches to ~he federai program;

t> administrators at one campus approving and paying.for goodS and services at other campuses;

t> untimely posting invoices; t> . lack of income verification for stu­

dents for school lunch p~gram purposes;

t> lack Of authorization for disburse­ments; and

t> cash diSbursements did not match supporting docunientation.

► Improper Student Attendance Records which Iead·10 Increased Funding: t> lack of dates on enrollment forms; t> incorrect withdrawal dates in the

attendance systems; .t> incorrect reporting of absences; t> incorrect attendance reports;

t> lack of proof of residen~y;. t> and late attendance submissions.

► Insufficient Employee Records: t> lack of attendance registers for

teachers; t> lack of immigration documentation

for, employees; and

t> tack of fingerprint .records for empfoyees.

► Inappropriate Lending Between Entities: •t> loans to schoolS from governing

board members; t> loans to Daisy from schools; t> loans between Daisy and Sonoran; t> loans from schools to Sonoran;

,c,. loans between Daisy and Paragon: and

c,. inter-school lending and borrowing.13

13 These findings weie taken from a review of school and Daisy aud,ts from the years 2009-2015, searchable at: http://linyurl.com/zg5el1fs (last checked 1/2612017). lnstructfOns for searching for annual audits can be found at http:/ /rinyurl com/zd7obgu

It-IS 11•rH1A1 IS Dl'i!R13UIOO Si A\Vil<l'~A'.1 0 PH[~;~s LLP c~ ~=j-,l[f Of It-< ~,PUBLIC Of lUf•t\ AO{IIIIO'ln l'lfOH,ur10,1 IS A\"All .31 t A! I~; Dt pl~ 11,1,111 Ci )~i[ICC, WAOel'/GJO·J. DC

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Bond Financing

Oaisy/Sonoran has taken out at least two bonds, 1)-in 2006, for the SSA-Phoenix campus

in the amount of 2,085,000'•; and 2) in 2006, for the construction of SSA-Tucson's school campus in the amount of $10,605.00ci.i~ Notably, these bonds were issued by the Industrial

Real Estate

Of,the six-schools Daisy/Sonoran runs, two schools{SSA Phoenix and SSA Tucson) own their own buildings·and·appear to have purchased

Oevelopment,Authority·of the County of Pima,

Arizona, the same bond aut~orizer utilized by two other Gulen Organization charter networks-the COral Science Academy network in Nevada and

the Concept Schools network in the Midwest.

the buildings from-unaffiliated third parties. The

remaining four schools appear to lease their

buildings from unaffiliated third parties.

~. ~-=~~~· . . .·· c'l.\,.. I

•·\ 's.l ·.•.· I

\'\ 44~0. i'Jq,, · .. i 1.'.~,~...,. ·· · ~- ·&,..,;..·.-.··.I ·,.\ ,w-4 fr ,-_o .. ·. "q')· .•, \/". . 0 ~ · ... · .1 \.::-,. u _;,.,, . ·. ' "'""' .-vo., ', i

! I

I ,.· --------'--·-· --··· ~'

Excessive use of the H-1B Visa Program

Like other ·Giilen Organization charter net­

works, Oai~/Sonoran and their schools utilize the H-1B visa program to immigrate large num­

bersofTurkish Giilenists into the United States for

empk>ymenf:in the schools and-Daisy/Sonoran.

From 2001-2016, Daisy, Sonoran, Paragon, and their-six schools,have filed 358 H-1B \lisa appli­cations for foreign workers.'e While former

SSA-Tucson Bond Off:cial statement, pgJ 11Va1lable at: http://linyurLcom/zb•wqes (last chec~d 1/30/2017).

SSA-Tucson Bond Qff,c1al statement available at: http://tinyurl.com/zbnvqes {last checked 1/27/2017).

In another example of strategic ambiguity, Daisy/Sonoran and its schools use several d1fterenl versions of their names to make it difficult lo aggregate how many H-18 applications they are filing. The sum total of all of their organizations is 314, and the 11umbers supporting tl1at total are located at the following links: from 2001-2015, http:/ /tinyurl.com/zwe6xlc (113); http://tinyurl.com/h5z4g92 (1S); http://tinyurl.com/hj4l4x6 (5); http·//tinyurl com/J76Ja2e {4}; http://tinyurl.corri/jprS4xk (42); http://tinyurl.com/z2v9ycu (92) http://tinyurl.com/h2x7jh9 (14); http://tinyurl.com/ht34ntu (13); http://tinyurl.com/hpqwj2 (44). For 2016, refer to the 2016 data on the US OOL website, available at: hnp://!ioyud,com/zm5dvec (last checiled 1/30/2017)

lCIS \l,\f="••I ,~ DIS!f.13UlfD 3\ ~1,1$[/!'DU,1-\ P~H!lliH llP ON Mf~,\[I Of,~, Fic~urnc Of !UF•tl ll>DIIIO~•! 1raCHIAIICr1 IS AVAIi -~li Al !H OiPAld•~t~I Q, rnrnc,, WAS~l'.IGl01, DC

Received by NSD/F ARA Registration Unit

Daisy/Sonoran CEO Ozkur Yildiz has stated that these'.H-1Bs are only to fill shortage-areas.for

math and science teacherS,'1 these applications were filed. for such positions as: accountants,

education administrators, financial managers,

financial,operations, instruction&! coordinators,

elementary teachers, English teachers, Turkish teachers, and IT network administrators.

Oaisy/Sonoran use the same immigration

attorneys to file and process their H~18 applica­tions as other·. known Giilen Orgai1ization charter

networks, vendors, and cultural associations,

indicating once again the existence.of an overall

network.'. For example:

► Joshua Surowitz: Oaisy/Sonoran used Surowitz, a California-based attomey,.to

file numerous H-1B applications. Surowitz

also filed applications for: t> Magnolia {CA)

Empire of Deceit: An lrnes1ig~tllltl ol the Gulen Charter Sci1ool Network

t>. Accord (Western Region)

t> Coral (NV)

t> wmow Education·(CA charter holder

· for ~y Area Technology)'8

► Catherine Garcia: Daisy/SOnoran used

Garcia, a Calfomia-based attorney, to file numerous H-1B appficattOns. Garcia also

filed applications for: t> Magnolia (CA) t> •Paragon (AZ)

t> Lotus (CO)"

► Nancy Robinett. Daisy/Sonoran used

Robinett, a Minnesota-based attorney, to

file numerous H-18 applications. Robinett

also filed applications for: t> Paragon Education Foundation'(AZ)

t> Magnolia {CA) t> FoundattOn for lnter~Cultural

·Dialogue (AZF

Scandals, Investigations & Notable Activities

ln-2015, two Arizona-Members of Congress,

U.S. Representative Raul Grijatva and U.S. Representative Ruben Gallego, wrote letters

urging the U.S. Department of Education and the

Government Accountability Office respectively

to urge an invest!gation of charter schOOls affili­ated with Giilen. These letters were sent in light of

the recent raids of the Concept Schools network located in'. Ohio, lllinois, and other Midwestern

states for suspected,defrauding ·of ·the federal

E-Aate program by Concept's:Turkish adminis­trators;and,vendors. Both Grijalva and Gallego

were concerned abou! the connections between

Concept and the Sonoran network in Arizona

uncovered by investigative journalisms at the time and asked for a thorough investigation.21

Yu nus Avcu, formerly employed by Accord first

in Arizona.to.work with·SSA-fJhoeni,c, and.then later in Colorado, provided testimony regarding

Accord's true purpose and his work with both SSA.­

Phoenix and Lotus. As an accountant employed

by Accord, Avcu stated that he gathered tuzuk funds from each of Lotus's Turkish'H-1B employ­

ees in cash each"month and:delivered-them to Accord's headquarters in California. Despite what

Accord alleges it provides in-the manner of edu­cational services, • Avcu stated that Accord was

more focused on arranging trips to Turkey for

American dignitaries, ensuring that its Giilenist

charter schools maintained Turkish leadership at the school level, and requiring that Turkish leader­

ship regularty hire H-18 Turkish teachers in order

Steller, Tim. Foreigners fin ranks of local charter-school chain. Arizona Daily Star. (25 April 2010) http:/ /tinyurl.com/h9cnwxa (last checked 1/30/2017),

Surow1tz prof,le listi11g e11tities represented for H-16 visa work available at: http:/ ltinyurl.com/g..-a9h7t {last chec~d 1/31/2017),

Garcia profile listing entities represented !Or H-18 visa work a..-ailable at: http://tinyurl.com/h4vxfkx (last checked 1/31/2017).

"' List of entities represented by Na11cy Robinett, a..-ailable at: http://tinyurl.com/jcr9rn.i (last checked 1/31/2017)

Representative GnjaMl's letter is available at: http://t;nyurl.com/h11hcbq5 [last checked 3/14/2017). Representative Gallego's letter is avaitable at: http://linyurl.com/2yrhf3u (last checked 3114/2017)

l~IS !l'lt~IA! IS OISl~l~!J!fO M HtS!Cf'D~U & FAH'lel'S llP O'l gfHll 01 T~t HPU3UC N ]Uf,,Y •DDlllO~Al INIOHt.lAIIO~ 15 .l\'lll~3i': ~1 -~, l)C,l~]l,lf~I Cf JUrnc , WA!rl'l61QCJ, D(

07/27/2017 6: 11 :32 PM

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Received by NSD/F ARA Registration t,Jnit 07/27/2017 6: II :32 PM implrt GfDtcelt: An l~es~gat1on of The Gillen Dlarter School Network

to keep the cash flow frol'!'l these teachers' forced tithing:through tuzuk payments high. As an·H-18

employee recruited from Tt.irkey, Avcu himself had to tum aver as much as 40% of his salary, which he said went to fund GUlen himself.22

In 2003, the US Department of Education performed a special audit. and· uncovered;that

Sonoran Science Academy-Tucson (at that time:named Daisy Science.Academy) misused

$20,519 in federal funds by-using.the,money for una11owable expenses. 23 One of these expenses was for hiring foreign employees. The audit also found that $5,407.79 of federal funds were paid to

Notable Turkish Vendors

Accord Institute for Education Research (Accord): Like Daisy/Soooran, Accord contracts

with each of the~ GOien Organization char­ter· networks and allegedly provides them with

educational and operational services, including

~nancial services, for a fee. Accord has the gre8t­

est overlap in ties with Magnolia (CA) as they are both headquartered in the same state, but Accord

also provides services to Daisy/Sonoran (AZ)2\ Coral {NV}, Lotus {~0), Beehiye {UT}, and•was

listed as a-partner for failed:schools/regions, as

well, including Pioneer (OR) and:Mokapu STEM

{~I). Yunus Avcu, a Turkish Accord empioyee first

hired to work for SSA-Phoenix, provided detailed information about how Accord functions as a

regional oversight entity primarily focused with

Daisy board member and founder, Nasuhi Yurt, allegedly as a reimbursement. Mr . .Yurt claimed that he had loaned-the school'money to pay for

construction costs covered by.the grant, though

there was no record of this loan made by Mr. Yurt to the,school. The audit,alSO declilred:materia1

weaknesses in the school's financial controls.

The Arizona Stcite:Board for,Charter:Schools

placed Daisy/Sonoran on a corrective plan due

to numerous failures to implement!appropriate employee fingerpririting protocols to ensure stu­dent safety?•

operating the GOien Organization.

Apex Systems & Technology SOiutions {Apex)

(formerly Apex Educational Services): Daisy has

utilized Apex for IT services paid for by the fed­eral E-Rate grant program., Magnolia. (CA), also

utilizes Apex for IT services paid for through

E-Rate,:and Concept-Schools.(Midwest) is cur­rently under. federal investigation for .illegedly

defrauding the E-Rate program by using affiliated

vendors with a system of lockbacks to Concept's management. Apex may also. be an. affili.tited

vendor with Oaisy/Sonoran; a reporter found tax

documentation linking Apex as an owned prop­

erty/asset Of -Daisy and Sonoran, though this could not be independentlyverified.Zll

" Jason McGahan, Did a Ca!ifomia Charter School Gro1.1p F1.1nd an Effort to Overthrow the Turkish Government? LA Weekly (Dec. 1, 2016), avail.able at: https:/ /tiny1.1rl.com/jxceqp7 (last checked 2/9/2017).

" A1.1d,t 1eport available at: http:l/tmy1.1r!.corn/Jboyhc3 (last checked 1/25/2017).

http://tinyu1l.com/zzqozd2 (last checked 1/3112017)

" SSA·B Club Catalog 2016/2017 Fall Semester, Sonoran Schools, available at http://t1f1)'1.1rl.com/J34Uhb3 (last checked 2/1/2017): Min1.1tes of Meeting of Go.emir,g Board of Daisy Ed1.1eation CorporatiOfl dba Sonoran Science Academy - Phoeni:\", Sonoran Schools (Mar. 3, 2016), ava,table at:http;//tmyurl.com/hprollg (last checked 2/1/2017); Tim Steller, Sr. Reporter: What does $36411: in Ta:\" MOfley Buy These Charter Schools, Arizona Daily Star (Oct, 22, 2010), available at http://tinyurl. com/ht35ax6 (last checked Vl/2017) (discussing payments of over S350.000 to Accord from Daisy schools); Academic Compet1t10ns, Sonoran Schools, avail.able at http·//tinyurl.com/z9ft448 (last checked 2/1/2017) (the' Sonoran Schoo!s' wel:lsrte shows use of Accord products); Tim Vanderpoo~ Hidden Agenda?, Tucson Weekly, (Dec. 31, 2009). BWlilable at http //t1nyurlcom/zgwjkak; Magnolia Educational and Research Foundation, Magnolia Science Academy- Santa Clara: COuntywide Charter SChool Petition, Santa aara County Office of Education, at 17, available at http://tinyurLcom/hwg8jj8 (Last checked 2/1/2017} The Accord Edocation -..wbsrte even includes a promotlOMf blurb from the CFO of "Sonoran Schools" with other Giilen schools. Accord Education. available 81 http://tinyurl.com/gqM!lo (last checked 2/1/2017)

a http //tirryu,tcorntkfl5oor (last checked 1/25/2017)

!hi\ '>l~.!ii-l~l IS 01S IHd~liU 11 A\ISlePUA!,1 ~ ~AAl~ifiS llf• 0~ Bi~Alf 01 IH fHUrlll( 0! l~A•.Ci A[,[,I I IOIIAI I~! O~IUl 10~ IS AVAIL A~I i Al l HE Otl'Af; I Ui'll Cf IUS I llO, WH~l"!GI Oil, ll(

Received by NSD/FARA Registration Unit

Empire of Deceit: An lrrvest,ga1100 of the GUI en Charter School Network

Giilenist Cultural Foundations

► West American-Turkic Council {\¥ATC} t> Former Daisy/Sonoran CEO Ozkur

Yildiz is now the President Of the

WATC, a Gulenist cultural organiza­tion-under,the.umbrella of.the Turkic

American Alliance.

► Pacifica Institute t> The Pacifica Institute is a meniber

of the WATC, which is in turn

under the leadership of the Tllrkic

American Alliance. The Pacifica

Institute is openly GU\enist and is active throughout the western GOien

Organization region; with branches in

California, Arizona, Colorado, Hawaii, Utah, Nevada, and washingtonp

The Pacifica Institute works closely with the GUlen Organization.charter

networks to advocate with legislators on their-behalf.and also to coordi­

nate jurikets to Turkey. The Pacifica

Institute operates Turkish Olympiads, which the· Daisy/Sonoran schools participate in.ie

► Serna Foundation (AZ) e> Arizona Founder Metin Vildirim's wife,

Elif Yildirim, has served on the board of:the Sema Foundation, -an Islamic

religious foundation based in Tempe,

Arizona affiliated with GUlen. 211

► f:oundation · for Inter-cultural: Dialogue (AZ)

1> A Gi.ilenist religious:non-profit orga­

nization based in Tempe, Arizona.

Individuals Caught in:the Giilen Organization Web

It is quite common for the charter ·networks

within a region -to shuffle their Turkish H-18

visa teachers from school to school, as well as between education management vendors

such as Accord and Daisy/Sonoran. This is

just a small number of individuals with these overlapping ties-throughout the region, which

further demonstrates the region's interconnec­

tions. Former Daisy/Sonoran CEO Yildiz:stated

that these interconnections were a natural result_of-the schools going to the same charter

" http://tinyurl.com/hkng49u (last checked 1/30/2017)

,. http://tinyurl.com/zgwjkak (last checked 1/30/2017)

"" http://tinyurl.com/j2dej8c (last checked 1/30/2017).

conferences, however, this does not explain why

this shuffling only occurs with these schoOIS' Turkish employees, 3o

► Mehmet Argin: Principal, Dai~y(Sonoran (AZ)3'; Daisy board member (AZ)l~; CEO

at Magnolia (CA)"; currently lecturer at California Polytechnic, Pomona campus.:i-o

► Ozkur Yildiz: Principal Daisy/Sonoran (AZ)l$; Superintendent Daisy/Sonoran

,., Tim steller, Foreigners Fill Ranks of Local Charter-School Chain, Arizona Daily Star (Apr. 25, 2010) available at: http://tinyurl.com/jlpgo4a (last checked 2/2/2017),

Article quoting Argin during his tenure as SSA principal, available at. http./ /tinyurl.com/lcbKUff (last checked 2/15/2017).

"' See 2012 Daisy Education 990 tax form, available at: http://tinyurlcom/ijcr:\"h9 (last checked 2/15/2017).

" Article quoting Argin during his tenure as Magrolia CED, available at: http://tinyurl.com/mbj72a3 (last checked 2/15/2017).

,. According to Argin's Unkedin prof le. available at: http://bnYiJrlcom/jsdqztz (last checked 2/15/2017)

» Article quoting Yildiz during his tenure as Vice Principal at SSA-Tucson, a11a,!ab!e at: http·//tinY1Jrlcom/15msxcy (last checked 2/15/2017)

!~IS lil•E~IAL IS OIHRl3~r,o Bl ~lilSIH•DI~:, ~•HP!if,S llP 0~ '!EMlf O! 1~, etPIJS!IC 01 iu~-:,, AU[ill IO~I.I l~I 0/.IU! IOrJ 15 Al'AII A~I f AT I e f DEPA~l l,IC fl I or 1~5 IIC!. ~~Shl~G TO~. UC

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Received by NSD/FARA Registration Unit 07/27/2017 6: M :32 PM Empirl:otDecelt: An 1rwesngat1or, of the GiJlen Oiarter School NetwOfk

(AZ)"; Principal Bay Area Technology (CA)l~; President of the West American Turkic Council.38

► Adem Oksuz: Daisy/Sonoran CEO (AZ}39;

CEO at Accord (Western At!gion~; tied to,failed Mokapu·STEM charter school (~I); Lancaster Science Academy pro­posal (PAr1

; Regional Director of Apple Education Services (Northeast Region)4z; CEO of Vision Academy Charter School (PAJ,U

► Ibrahim Bayraktar: SSA-Tucson·teacher (AZ) .. , now works cit Accord (Western Region).-u

► Omer Guvener: Board me~berof Paragon Education Corporation (AZ), also· board

member·of Foundation for Inter-cultural Dia,iogue (AZ):•!

► Ali Unver: , Board member of Paragon Education:Corporation (AZ), also board membeiforCOral Academy Las Vegas (NV~

► Adnan Doyuran: Momentum Middle ·School (NOW Magnolia Science·Atademy •San Dieg~) Principal (CA)0

; LotuS Academy of Excellence Principal {CO); ·SSA-Tucson Principal (AZ); Sonoran Associate Superintendent {AZ).

► Murat Biyik: Math teacher at SSA; Vice Principal at Beehive (U"!"r'; then Magnolia {CA); then Accord {CA), and now is back at Beehive (UT).''

Notable Articles regarding the Arizona Network

► David Safier, Turkey's Failed Coup Attempt:

The Charter School Connection, Tucson Weekly (July 19, 2016, 3:09 PM) {discuss­ing potential. links between GUlen and the Sonoran Science-Academies, ~hich the schools deny,· and the use of the H-1B visa program to hire teachers).&a

► ADI News Services, Grijalva contacts Feds on Misuse Funds by Giilenist Schools,

Arizona Daily Independent {November 15, 2015) (discussing contents of Grijalva letter requesting investigation of Sonoran School network due to connections to Concept Schorils currently under FBI

111 Article quoting Y1ldiz durmg his tenure as Sonoran Superintendent, available at: http:/ /tinyurlcom/h6ancpq (last checked 2/15/2017)

Oakland Unified directory listing Yildiz as Principal of Bay Area Technology, aVil~able at: http:/ /tinyurl.com/zjhsu34 (last checked 2/15/2017)

"" According to Y1ld,z's Linked,n prof,le, aVililable at: http:/ /t,nyurl.com/h87ukmf (last checked 2/15/2017)

'" See 2003 Daisy Education 990 tax form, available at: http:/ /tinyurl.coni/jJCfxh9 (last checked 2/15/2017)

"' Accord Business profile listing Dksuz as CEO, available at: http:/ /tinyurl.com/hc7v9Im (last checked 2/15/2017).

Article discussing petition and Oksuz: available at: http·//tinyurl com/hxsmlllw (last _checked 2/15/2017).

" Oksuz resume available at page 196, http-//tinyurl.com/hrzqv5r (last checked 1/30/2017)

., Oksuz resume ava,lable at page 196, http://tinyurl.com/hrZQv5r (last checked 1/30/2017).

.. http://"'1yurlcom/ze77zwo (last checked 1/30/2017).

., http:/ltinyurl.com/J2kmusu (last checked 1/30/2017).

.. Check the 2007 990 form for Foundation for Inter-cultural Dialogue, aVililab!e at: http://t1nyurl.com/1unrwh3 (last checked 1/30/2017)

., Pg 15 of Magnolia apphcation, available af: http://tinyu1l.com/hcljhep (last checked 1/31/2017).

.. See 2008 990 form for Beehive list,ng 81yak as the vice principa~ available at: http://tmy!Jrlcom/zioq9nx (last checked 2/14/2017).

.. Tim Steller, Foreigners Fill Ranks of Local Charter-School Chain, Arizona Daily Star (Apr. 25, 2010) available at: http://linyurl.c.om/jlpgt>4a (last checked 2/2/2017).

"" http·//tinyurl com/zykglpe (last checked 2/1/2017)

IH15"1AlfM~l 1$ UISlfiBUltD ;; ~MSTEfD•."1 ~ PART NC RS LLP~N ~,~.,11 0I lHl Ffl'UBIILOI IIWl.lY Hlllll ION •t l~fORM. I IQ~ IS A\'A ll A~l: ·' I l H [ DFPA~l\!fN I c; J~ST ICE' l'/ViH l~GI o~. D(

Received by NSD/FARA Registration Unit

investigation for E:Rate frau~).51

► Tim Steller, Sr. Reprirter: What does $364k in Tax Money Buy These Charter Schools,

Arizona.Daily Star (Oct. 22,:2010)-(dis­cussing four Daisy schools that paid,

over $364,000 to the Accord lnstLtute for Education Research, an·alleged:hub for Gi.ilen-inSpired schools, and-questioning whether the services provided b~_Accord were worth the expense).~

► Elizabeth Stuart, Islamic Links to Utah's Beehive Academy-Probed, Oeseret-News Utah (June 1, 2010, 12:00 AM)'(discuss­ing the number of H-1B visas received by Sonoran. Science sch~s and the Gi.ilen practice requiring teachers to devote a percentage of, their paycheck to the movement, and the payment of manage­ment fees to.Accord to squeeze money out of schools). r,J

► Tim Steller, Sr. Reporter: More on Sonoran Science, on Gu/en, Arizona Daily Star, (Apr. 26, 2010) (publishing a letter from Mr. Fatih Karatas denying any ulterior motive and affiliations .with non-educational· organi­zations, and publishing letters from Ozkur .Yi!diz discussing,the schools'·use of the

H-1B visa;program for seemingly unnec­essary job positions,. transfer of teactiers between GUlen schools, discrimination against non-Turkish individuals, the rela­tionship with Accord,-and denying,any affiliation with the.GUIE!n movement. The article also discusses the history of Gulen

http·l/tinyurtcom/jqqkesa (last checked J/14/2017)

"' http://lmyurl.com/htJ6ax6 (last checked 2/1/2017).

·"' http·l/tinyurl.com/2b7dmlc (last checked 21112017)

,. http://tmyurl.com/z5hynep (last ctiecked 2/1/2017)

.. hnp:/ltinyurl.com/h9cnwxa (last checked 2/1/2017)

"" http:l/tinyurl.com/zs2s76e (last ctiecked 2/1/2017).

., http://tinyurl.com/zgwjkak (last checked 2/112017)

"" http://tinyurlcom/gl2ru9u {last Chetked 2/1/2017).

Emplf'I of Deceit: An liwestrgat:on of the GUlen Charter School Network

,, schools in A(!zona·and,the origins of the schools' employees) ....

► Tim Steller, ForeignersFilf Ranks-of Local Charter-School'Chain, Arizona Daily1Star (Aj:,r. 25, · 2010) · (hiQhlighting the dispro­portionately high number of H-1e,visas obtained: by · Daisy and I Sonoran · Science Ai::ademy Schools, the schOOls' .empha­sis on Turkish culture, overlap of teachers and founders with other GUlen, misuse of resources,. and the long-term goal of GUlenists to create a powerful TurkiSh commuflity · in America. The. article also discusses GUlenist links Of the Daisy founders, even while the superintendent denied formal GUlenist links but admitted to knowledge of Fethullah GUlen.).~

► Fatih Karatas, Letter,_Tucson Weekly (Jan. 28, ·2010) (Fatih Karatas denies:aUega­

tions· that Sonoran Science Academy schools have any links to any religious or nationalist movements).Y

► Tim vanderpool,.HiddenAgenda?, Tucson Weekly, (Dec. 31; 2009) (highlighting con­cerns of pa rents who feared reprisal if they discussed ties . to the Gi.ilen. movement and quOtingrFatih Karates-as denying a link between Accord and Gi.ilen).§1

► SBXOn Bums, Police Dispatch, Tucson Weekly, (July 24, 2003) (students at Sonoran Science Academy complained. a teacher repeatedly shut them in the closet).Y

lhlS. MATEi'IAL IS DLS!Cl3~1t0 31 ~MSl~f-D•M & P.~~lNCH'i II? 0~ B!CAII 01 IHI HPUBI IC 01 lUk<tl ADDil IO~Al INI OH.IA] 10~ IS AV•ll A:Jli AT re t Ut FAk I Mt~ I Cf JU)IICi. WASHl~GI o~. [JC

07/27/201.7 6:11:32 PM "

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·",a. 1--.~-.-I.~

'.: ..... ~ ~

Received by NSD/F ARA R~gis11" _\;J

Jl'. ·J •'.:;;..: .;,;:.::~~. -

it 07/27/2017 6:11:32 PM

Quick Facts

► Region: Southeast

► School Names (known as): t> Science Charter School t> River City Science Academy

t> School of Math & Science

t> Broward Math and Science School 1> Discovery Academy of Science t> New Springs Schools

► Total # of Schools in State: 12

► Total Student Enrollment 2015-16: 4,525'

► Charter Holder/Governing Board(~): 1> Discovery Education Services, Inc.

Organized.as a non-profit 501(c)(3) organization

Oversees the Science Charter Schools (4 schools)

t> River City Education Services. Inc. Organized as a non-profit 501(c)(3) organization Oversees the River City -Science Academies (4 schools}

1> Stars Education, Inc. · Organized as a non-profit 501(c){J) organization Oversees Tallahassee School of Math and Science (1 school)

t> Riverside Science, Inc. Organized as a non-profit 501(c)(3) organization Oversees Broward Math and Science School (1 school)

t>. Galaxy Education, Inc. Organized as a non-profit 501(c)(3) organization

Empire of Deceit: An l1111estiga1i011 of the Gi'llen Charter School Network

Oversees Discovery Academy of Science (1 SChool)

t>: New Springs, Inc.

Organized as a non-profit 501(c)(3) organization Oversees New Springs •Schools {2 schools)

► Charter Management • Services Vendor: Charter Educational Services & Resources

► Regional Gulen · Organization Oversight Entity: Charter Educational Services & Resources

► RegionarSister Networks: GREEN (SC); Closed Network Fulton Science (GA).

► Total Revenues.for the 2015-16 school year: $29,603,000Z

► Florida Network Founders: t> Yalcin Akin: Founding Board

Member, Stars Education Services, Inc. (FL); ·Board Member, New Springs, Inc. (Fl); Board Member, Consultant, Sweetwater Education, Inc. (FL); Principal, Orlando Science Middle/High School (FL); Owner, Discovery Education Operations, LLC (FL); Owner, 2611. Technology LLC, (FL); _Owner, Discovery Ed~cation Operations·at·Technology, LLC (Ft); Owner, 941 John Yourig, LLC (Fl:.);

Execu~ve Director, Orlando Science Schools,3

Student enrollment and demographic information available at: http://tinyurl.com/mtzdnmw (last chec~ 4/19/2017).

Figures are tal«on from F,scal Year 2016 audits for all schools curreiitly in operation. Audits are available ot: http://tinyurl. com/m91dgth {lost checl«od 6/15/2017).

lnformation taken from: Discovery Education Solutions Articles of Incorporation, available at http:/ /tinyurl.com/k44c5wz (last checked 6/15/2017); 2611 Technology corporate filing, available at: http://t1nyurl.com/lb3krmn (last checl«od 6/15/2017); Discovery Education Properties fihng, available at: http://tinyurl.com/l9byptv (lost checked 46/15/2017); 949 John Young LLC filing. available at: http:/ /tinyurl.com/ko5KOmx (last checked 6/15/2017); Article by Valcin, available at: http:/ ltinyurl.com/kb3cd22 (last checked 6/15/2017); New Springs corporate filings, ovailable at: http.//tinyurl.com/ krhhtmr (last checked 6/15/2017).

n,1s \IAIEiilAI IS LHSIRIBUlfD ~y AM51F~UA~ ~ PAH!Ni1~ LLP 8~ 3EhAL! or Hif' HEPU~llC Of lUH~fY AlilJlll:JNAI INIO~MMION IS AVAIi ~OIE Al l~i ldAHIMENl Of IUSTICf, VIASrlrlGION. OC

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Received by NSD/FARA Registration Unit 07/27/2017 6: 11 :32 PM Ernpireot Deceit: An lnvesllga~!tl ol the GUlen Char let School Netwof~

initially operated the schools for a fee,.but later created Sonoran Schools, Inc. to serve as its charter"· management company and then con­tracted with it to provide services.to its schools for a percentage of total school revenues. Daisy also contracts with Accord Institute for Education Research ("Accord"), the corporate entity responsible fo, the western!region of-the Gi.ilen Organization charter networks, allegedly

for additional educatiof!al management ser­vices for the Arizona schools. On average, these sch001s serve 8% En91ish Language Learners vs. 5% state·average; 45% free and reducetHunch population vs. 47% state; 3% students with dis~ abilities vs. 11% state;. 15% African American students vs, 5% state; 41% Caucasian students vs. 39% state; and 26% Hispanic students vs. 45%state.

f School Operation student Demographic Authorizer t Information• - , Govel'!'i:'-8::)

Paragon Science Academy 2975 W. Linda· Lane Chandler 85224

:sonoran Science :Academy- Broadway . 6880 E. Broadway Blvd . . Tucson, AZ 85710

Sonoran Science Academy­Davis Morlthan 5741'E. Ironwood St. Tucson, AZ 85709

Sonoren Science Academy­·peo,ia (originally known as SSA-Phoenix Metro) 17687 N, 91st Ave Peoria; .AZ 85382

Sonoran Science Academy-Phoenix 4837 E. McDowell Rd. Phoenix, AZ 85008

Sonoren Science Academy-TuCSOfl 2325 w. sunset Rd. Tucsoo, AZ 85741 ·(Otlginally known as Daisy.Science Academy)

K-12 2008~Present

'K-8 2008·Present

6-12 2009-Present

•·• 2011-Present

K-12 2003~Present

K-12 2001~Present

04% ELL 34%.FRL 4%SWD

19% African American 37'%' Caucasian 12% Hispanic

07.%'ELL 48% FRL 08%SWD

06% 'African American 40% Caucasian 35% Hispanic_

NIA% ELL 29%.FRL

N/A%SWD 08% African American

40% Caucasi&n 39% Hispanic

09% ELL 49% FRL

N/A%SWD 00% African American

54% caucasian 22% Hispanic

29%EU 79% FRL

N/A%SWD 51% African American

24% caucasian 20% Hispanic

N/A%'ELL 33% FRL 05%SWD

06% African American 48% caucasian 30% Hispanic

Arizona State· Boa rd for Charter

Schools

Arizona State Board foiCharter

Schools

Arizona State Board for Charter

Schools

Arizona State Board for Chaiter

School,

Arizona State Board for Charter

Schools

Arizona State Board for Charter

School,

2013: Paragon Education

Corporation 2013-Present: Daisy

Sonoran Science Academy­

'Broadway (same : board ·members as ,

Daisy,·though)

Daisy

Daisy

Daisy

Daisy

IHII IJ~HHIAt 10 li1Sll•IRlll1l1 ~y AIJ$10iUA!.t A PAfif~ERS llP 0~ 3f~All Of THC f.EPUSIIC Df lUR•.H. ALIOIIIONll l'lfOHMAIION IS A'/AltAALt Al,~, OfPAfilMCNT OF WSIICL W~Shl~GION, ur

Received by NSD/FARA Registration Unit

Em,tre of Deceit: An lmestig:a~oo of tre GUlen Char!ef School Network

[School Opention S1udent bemognphlc Au1h..- Govemi~ ~nl· I ·-Sonoran Science Academy• Ahwatukee (originally known as Paragon Science Academy-Elementary) 14647 S. 50"' Street, Building I, Suite 125, Phoenix, AZ 85044

D'aisy Early Leaming Academy 2325 W. Sunset Rd. '.'rucson AZ 85741

Sonoran Science Academy•Ragstaff

Sonoran Scierii:e Academy­Oro Valley·

K-5 2008-2016 Closed due

to inability to renegotiate lease or find

facility

Pre-K Not Charter

Registration filed

Registration fil,d

Arizona State Board for Charter

Schools

Daisy

•student demograi,hic'information was taken from the 2015-2016 school ,Year.:"ELL" indicates English Language-Learners, "FRL" indicates students receiving free/reduced lunch, and "SWD" indicates stu­dents with disabilities.•

A History of Strategic Ambiguity and Contlicting,1nterests

The Arizona GUlen charter schools and their management entities have undergone a series of name changes and corporate mergers over the last fifteen yeats which:make it·difficult to trace the evolution of-the Gulenist presence:in the state. Daisy first incorporated in 1999, and since.then, varying·combinations of its board members have appeared on a.number of sub­sidiary boards that govern the charter"schools as well as its hired educational services provider, Sonoran Schools,·lnc.

In the beginning, Daisy opened and operated its schools-itself, beginning with SSA7Tucson in 2001 and the pre-I< D8i~y E8rly Lea ming Academy in 2003. The charter:schools which came after that-SSA-Phoenix (2003}, ·SSA-Broadway (2008), Paragon Science Academy- Elementary/ SSA-Ahwatukee~ (2008-2016}, and SSA-Davis Monthan (2009)-had their own incorporated governing boards, but with members that

overlapped with Daisy. SSA- Phoenix Metro (2008}, which became SSA7Peoria in .2011, appears to have been goVemed directly by Daisy's. governing board and cori,orate enti~ Daisy also has overlap with Arizona's other GUlenist board, Paragon-·Education Foundiltion. Paragon formed in ·2005 with two directors­Mehmet Argin, the future CEO of Daisy/Sonoran in Arizona and, CEO of MagnOlia in California, and Ali Unver, who has appeared on Paragon and/or Sonoran's governing boards since.2005. Paragon·opened and operated ParaQon Science Academy (2008) in Phoenix (distinct from Daisy's Paragon Science Academy-Elementary}.

From 2001-2012, Daisy operated as both a governing.board for its·charter schools as well as a·paid charter management corporation:for the:schools. It-received 10% of each-school's total:- revenues: in this capacity, -including• those schools that technically had separate governing

Demographic information available at: http://tinyurlcom/gwa7aoc (last checked 3/24/2017).

Paragon Science Academy-Elementary changed its name in 2009 to SSA·Ahwatukee. Transfer application a11ai!able at http://tinyurl.com/z3J11f11a (last checked 3/1312017)

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07/27/2017 6:11:32 PM