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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
FETULLAH GULEN, :
Plaintiff
No. 07-CV-2148
V. !
Judge Dalzell
MICHAEL CHERTOFF, et al.,
Defendants
DEFENDANTS' RESPONSE IN OPPOSITION
TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT

Text marked in bold type are highlighted by gulen.network


Case 2:07-cv-02148-SD Document 31 Filed 06/18/2008 Page 4 of 26
.................Further, the record contains overwhelming evidence that plaintiff is primarily the leader of a large and influential religious and political movement with immense commercial holdings.....................

Case 2:07-cv-02148-SD Document 31 Filed 06/18/2008 Page 13 of 26:
...................
The Ebaugh-Koc paper also purports to explore the sources of funding for the Gulen movement's projects, but in fact it merely presents a series of unattributed anecdotes. The authors explain the need for examining the issue of finances:

Questions regarding the financing of these numerous and expensive projects are periodically raised by both critics of the Gulen Movement and newcomers to the movement who are invited to Gulen related events.

Because of the large amounts of money involved in these projects, on occasion people have raised the possibility of a collusion between the movement and various governments, especially Saudi Arabia and/or Iran, and including the Turkish government. There have even been suspicions that the American CIA may be a financial partner behind the projects.

Ex. A 00057 (citation omitted). Despite this explanation of their purpose, the authors made no systematic study of the....
( Page 14 of 26).... sources, or even amounts, of Gulen movement funding.

The authors claim to have interviewed twelve businessmen in Ankara who contribute "from 10%-70% of their annual income, ranging from $20,000-$300,000 per year." Ex. A at 00062. Another "very successful businessman in Istanbul" contributes "20% of his 4-5 million dollar yearly income to movement-related projects." Id.

Finally, the authors assert that many "graduate students, many of them on small stipends from Turkey or from their American universities, pledge $2,000-$5,000 every year even though such pledges means [sic] great sacrifice on the students' part." Ex. A at 00064. The authors provide no source for these alleged facts, other than their claim to have asked twelve unidentified businessmen how much they contributed. This is not scholarship; it is not even respectable journalism.

The evidence submitted by plaintiff, when carefully examined, reveals that he is not a scholar and his work is not the subject of serious scholarship. He is a religious and political figure attempting to buy academic prestige by paying people to write papers about him.6

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