STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE

JARED DAVIS
an individual,

Plaintiff,
Case No.
v
Hon. ______________________
THREE PILLARS D/B/A
CORNERSTONE EDUCATION GROUP
a Michigan Non Profit Corporation,
NEW COMMON SCHOOL FOUNDATION
a Michigan Non Profit Corporation,
CLARK DURANT,
an individual,
and MINDY BARRY, an individual,

Defendants.
______________________________________________________________________

Anthony Adams, Esq (P33695)

Marine Adams Law PC
400 Renaissance Center
Suite 2600
Detroit, Michigan 48243
(313)961-5535;fax (313) 961-9897
aadams@marineadamslawpc.com
______________________________________________________________________

COMPLAINT

There is no other civil action pending between the parties.

Plaintiff Jared Davis, by and through his counsel, Marine Adams Law PC, a professional

corporation, and for his Complaint against Defendants states as follows:

 PARTIES

1. Jared Davis is an individual residing in Wayne County, Michigan.

2. Three Pillars d/b/a Cornerstone Education Group (“CEG”) is a Michigan non-profit

corporation that conducts its business in Wayne County, Michigan.

3. New Common Schools Foundation (“NCSF”) is a Michigan non-profit corporation

that conducts its business in Wayne County, Michigan.

4. Clark Durant is an individual who, upon information and belief resides in Wayne

County MI.

5. Mindy Barry is an individual who, upon information and belief resides in Wayne

County MI.

JURISDICTION AND VENUE

6. This Court has jurisdiction over this matter as the matter involves an amount in

controversy in excess of Twenty-Five Thousand Dollars ($25,000.00).

7. Venue is proper in this Court under M.C.L. § 600.1621 and § 600.1627 as

Defendants conduct business, and has a place of business within the county. Defendants Clark

Durant and Mindy Barry upon information and belief, are residents of Wayne County. Further,

the actions of all Defendants occurred and injuries arose in Wayne County, Michigan.

BACKGROUND

8. Mr. Davis is a fifty-year-old African-American male residing in Detroit, Michigan.

9. He has been an educator for twenty-seven years and has held school leadership

positions for the past thirteen years.

10. Throughout Mr. Davis’s exemplary career, he has never received disciplinary

action and has earned a stellar reputation in the education community.

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 11. In June 2015, Mr. Davis became the principal of Cornerstone Health + Technology

High School (“CHTHS”).

12. Accolades followed his arrival, as CHTHS was celebrated for achieving a 100%

graduation rate, and receiving a top ranking by the Michigan Association for Public School

Academies for the school’s composite SAT scores during Mr. Davis’s tenure. Cornerstone even

selected Mr. Davis to represent the organization on a trip to Africa with CHTHS students as a

testament to the trust and goodwill he earned during his tenure.

13. While leading CHTHS, Mr. Davis’s students have received over twenty-Million

($20,000,000) dollars in scholarships to graduates in the first four graduating classes.

14. Mr. Davis also achieved the highest student and teacher retention rate in the CEG

network of schools in 2016.

A COMPLEX WEB OF NON-PROFIT ENTITIES CONTROLLED BY MR. DURRANT

15. In 1991, Clark Durant founded Cornerstone Schools, an independent school whose

mission was to provide a quality Christian-based education for Detroit children.

16. Over the years, Mr. Durant has transformed the independent school into a network

of public charter schools (that receive millions of taxpayer dollars), by developing a web of non-

profit entities that he controls and to wit, he receives significant personal gain.

17. CHTHS is public charter school comprised of board members handpicked by Mr.

Durant.

18. CHTHS, under the direction of Mr. Durant, “hired” Cornerstone Education Group

(“CEG”) to provide education management services, and in turn, relinquished complete control

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over the school’s operations and decision making— including how funds are spent to provide

services to students.

19. Mr. Durant serves as President of CEG.

20. Mindy Barry serves as Chief Executive Officer of CEG despite failing to hold an

administrator certification as required by the Michigan Department of Education.

21. CEG, on behalf of CHTHS, goes on to pay the New Common School Foundation

(“NCSF”) approximately $432,000.00 annually to sublease a building to CHTHS.

22. Mr. Durant also serves as President of NCSF.

23. NCSF also receives millions of dollars in rent payments from other schools under

the direction and control of Mr. Durant.

24. In 2018, Mr. Durant received over $500,000 in compensation from NCSF.

25. This compensation is derived at least in part, from taxpayer dollars received by

educational institutions paid to NCSF which Mr. Durant serves as President.

26. Upon information and belief, NCSF has withheld payment for extended periods to

the owner, Archdiocese of Detroit, despite collecting such sums from CEG.

27. Ms. Barry also serves as Secretary of NCSF.

28. The Cornerstone Schools Foundation (“CSF”) is a non-profit corporation which is

self-described as “the owner of properties where charter schools are housed to build a sustainable

model of excellence for a new common school.”

29. Mr. Durant also serves as President of CSF.

30. Ms. Barry serves as Secretary of CSF.

31. The Cornerstone Schools Association (“CSA”) is a non-profit corporation that is

self-described as organized for “chartable and education purposes.”

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 32. CSA receives $45,000 monthly payments from another Cornerstone Charter

School, Jefferson-Douglass Academy.

33. Mr. Durant is a Director for CSA.

34. It is clear, that Mr. Durant is the puppet master for the entire Cornerstone operation

and Ms. Berry carries out the orders.

35. As such, all of the Cornerstone entities act as a single enterprise under the dominion

and control of Mr. Durant.

CORNERSTONE PRESSURES PLAINTIFF TO EXECUTE A NO-SHOW CONTRACT

36. In July of 2018, Mr. Davis was pressured by members of CEG to approve a no-

show contract in which Mr. Daniel Budzinski, a close personal friend of Mr. Durant, received

$44,500 for a sham mentoring program aptly titled, “Purpose Prep.”

37. Mr. Davis raised his concerns to the previous CEO of CEG, Reid Gough, and stated

that he feared his approval of this contract would violate the law.

38. Mr. Davis did not understand why he had to sign off on the contract in the first

place, as he was but a mere employee of Mr. Gough.

39. In fact, Mr. Davis was so bothered by these prospects that he informed Mr. Gough

that he would be forced to report such a contract to the attorney general.

40. Eventually, Mr. Davis succumbed to the pressure and signed the contract but made

a notation that [his signature] was “per CEG directive”. (Exhibit 1).

41. It became clear that for some reason, CEG wanted no ties to approving this contract.

42. He was then told by former Chief Academic Officer, Pamela Farris, to “take that

off and white it out.” (Exhibit 2).

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 43. Ultimately, Mr. Budzinski came to the school on no more than two occasions

despite receiving such a large sum.

CEG MOVES TO DISPOSE OF PLAINTIFF

44. Upon information and belief, several members of the CEG executive leadership

team have either resigned or have been terminated as a result of the chaotic environment there.

45. Chief Academic Officer, Lisa Key, continued a coordinated mission to humiliate,

harass, and ultimately discard of Mr. Davis during her short tenure.

46. Mr. Davis’s entire staff has witnessed such harassment by Ms. Key and several

other CEG leadership.

47. Mr. Davis believes the source of their ire was none other than the fact that he

refused to participate/tolerate unethical and unlawful behavior—a position sanctioned by

Cornerstone, which is under the direction and control of Mr. Durant.

48. On December 3, 2019, Cornerstone seized the opportunity to get rid of Mr. Davis

once and for all.

49. At approximately 6:00p.m., a physical incident took place between two female

CHTHS students and an adult female employee of Securitas (a security contractor for CEG).

50. The Securitas employee in question was brand new to the building, and engaged in

inappropriate physical aggression toward the two students shortly after Mr. Davis’s departure that

evening.

51. The Securitas employee escalated an already heated exchange by physically

assaulting one of the students and forcibly pushing her out of the door.

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 52. After several minutes of screaming and cursing at one another, a physical

altercation ensued.

53. For the second time, the Securitas employee made direct physical contact by

delivering a blow to the face of one of the students.

54. The two students proceeded to defend themselves against the assault the Securitas

employee.

55. Mr. Davis was not involved in the hiring, training, or placement of this Securitas

employee. Furthermore, Mr. Davis promptly returned to the school building when he was made

aware that a physical incident took place and immediately notified members of the CEG leadership

team.

56. The following day, Mr. Davis was abruptly put on administrative leave by

Cornerstone and was terminated on December 6, 2019—Fait Accompli.

THE BOGUS TERMINATION OF THE PLAINTIFF

57. CEG cited three reasons listed for his termination:

Safety: Each employee is expected to obey safety rules and exercise causation in all work
activities...For their safety and security, students must be supervised by CEG personnel at all
times.

Standards of Conduct #10: Inefficient or careless performance or assigned work or poor

quality of work.

Workplace Harassment (third party as a witness): Also prohibited are statements or actions
that are threatening, intimidating, vulgar, or hostile, even if not based on protected class status.
Such conduct may make reasonable person (sic) uncomfortable in the work environment or
could interfere with an employee’s ability to perform his or her job, regardless of whether the
actions are from a fellow employee, supervisor, customer, or visitor. (Exhibit 3).

58. Aside from its impracticality and untruthfulness, CEG references an employee

handbook that was allegedly updated but never received by Mr. Davis.

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 59. Upon information and belief, the above-referenced items in the employee handbook

was also never approved by the board of directors.

60. Upon information and belief, CEG employee has ever been disciplined for this

policy.

61. Mr. Davis does, however, have a copy of the employee handbook that contains a

Safety Section that makes no mention of the above referenced mandate. (Exhibit 4).

62. The assertions that Mr. Davis was inefficient, careless, and acted hostile are

defamatory on its face, and have no basis in fact.

63. On December 9, 2019, Mr. Davis made a request for his personnel records pursuant

to the Bullard-Plawecki Right to Know Act. (Exhibit 5).

64. On December 12, 2019, Mr. Davis made a 2nd request for his personnel records, to

which CEG refused and directed Mr. Davis to speak with its attorney. (Exhibit 6).

COUNT I

WRONGFUL DISCHARGE IN VIOLATION OF

MICHIGAN WHISTLEBLOWERS PROTECTION ACT

65. Plaintiff incorporates by reference the allegations in Paragraphs 1 through 64

above.

66. Defendants’ decision to terminate Plaintiff Jared Davis and irrevocably change the

terms and conditions of his employment, was because the Plaintiff threatened and was about to

report violations and or suspected violations of numerous laws, standards, and/or regulations to

the Attorney General of Michigan which is a public body within the meaning of the Michigan

Whistleblowers Protection Act MCL 15.362(d)(v).

67. As a direct and proximate result of the wrongful conduct, harassment and the

change in the terms and conditions of his employment, Plaintiff has suffered damages including

8
but not limited to loss of physical well-being, anxiety, stress and stress related symptoms,

depression, and related loss of income, income opportunities, and benefits, humiliation, emotional

distress, attorney fees and associated expenses.

COUNT II

VIOLATION OF THE BULLARD-PLAWECKI RIGHT TO KNOW ACT

68. Plaintiff incorporates by reference the allegations in Paragraphs 1-67 above.

69. Defendant Cornerstone Education Group’s refusal to provide Plaintiff with the

opportunity to review and/or receive a copy of his personnel record is a violation of Mich. Comp.

Laws Ann. § 423.504.

WHEREFORE, Plaintiff prays for such damages as may be deemed to be just and fair at

the time of trial of this cause, including reasonable attorney fees, the damages in each instance to

be in excess of Twenty Five Thousand ($25,000.00) Dollars.

______________________________
Anthony Adams, Esq (P33695)
Marine Adams Law PC
400 Renaissance Center
Suite 2600
Detroit, Michigan 48243
(313)961-5535;fax (313) 961-9897
aadams@marineadamslawpc.com