Best V MedVance - Amended Complaint

business as MedVance Institute ("MedVance"), for breach of contract, breach of the covenant of
good faith and fair dealing, fraud in the inducement, fraudulent misrepresentation, and for
violating laws prohibiting misleading advet1ising, Fla. Stat. § 817.41, and unfair and deceptive
trade practices, Fla. Stat. § 501.204. Plaintiffs also sue Defendant Sallie Mae, Inc., seeking
rescission ofloan agreements entered into as a result ofMedVance's fraud.
Introduction
1. This lawsuit concerns a private, for-profit educational facility, MedVance, which
diligently and fraudulently recruits students to attend its campuses in Florida and elsewhere.
MedVance's goal is matriculation of students, not education. The more students who enroll and
matriculate, the higher the profits for MedVance. In order to convince students to enroll,
MedVance recruiters make false statements regarding the quality of the education and facilities,
accreditation, graduates' preparedness to pass certification exams, the costs of education, the
ease of repaying federal loans, and most important to Plaintiffs, job prospects upon graduation.
To prevent irreparable harm to hundreds of students, it must be shut down.
2. As a recipient and beneficiary of state and federal funds and loan guarantees,
MedVance has a vested interest in enrolling as many students as possible, no matter their
qualifications or interests. MedVance was and still is under scrutiny by the Government
Accountability Office, Congress, and the Florida Attorney General's Office because of its
business practices. The GAO cited MedVance on August 4,2010 for "encouraging fraudulent
practices" and for making "deceptive or otherwise questionable statements." See Exhibit A.
MedVance is part of the burgeoning phenomenon of for-profit private career colleges, which
"have grown in enrollment from 365,000 students to nearly two million over the past several
years ... [and whose] students borrowed more than $20 billion in federal loans last year." See
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id. Although only about 12% of American post-secondary students attend these colleges, those
students represent 43% of 2008 student loans in default. See id. Despite accreditation and
auditing requirements and supposed federal scrutiny of career colleges that take advantage of
federal student aid, MedVance is allowed to continue to operate.
3. MedVance victimizes its students. Plaintiffs, who were enticed by promises of a
better life, left MedVance with little more than an insurmountable debt burden. Instead of
learning the skills required to succeed in various specialized medical fields, Plaintiffs were
subjected to out-of-control classes taught by disinterested and unqualified instructors. Instead of
educational externships capable of enhancing professional development, Plaintiffs were placed
with employers who assigned menial tasks. Instead of sound financial advice, MedVance's
financial department rushed Plaintiffs through the loan application process, simply assuring them
not to worry about a major life decision. MedVance is solely focused on the bottom line, to the
detriment of its students.
Parties, Jurisdiction, Venue Etc.
4. Plaintiff Donesia Best, a current resident of Palm Beach County, Florida, attended
MedVance Institute's West Palm Beach campus from 2009 to 2010.
5. Plaintiff Guerlande Exantus, a current resident of Palm Beach County, Florida,
attended MedVance Institute's West Palm Beach campus from 2009 to 2010.
6. Plaintiff Diana Medina, a current resident of Palm Beach County, Florida,
7. Plaintiff Teri Dolecki, a current resident of Martin County, Florida, attended
MedVance Institute's Stuart campus from 2008 to 2009.
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8. Plaintiff Diana Meyer, a current resident of St. Lucie County, Florida, attended
9. Plaintiff Linda O'Neill, a current resident of Palm Beach County, Florida,
attended MedVance Institute's Stuart campus from 2008 to 2009.
10. Plaintiff Patricia Bennett, a cut'l'ent resident of Palm Beach County, Florida,
11. Plaintiff Yanno Bevacqua, a current resident of Palm Beach County, Florida,
12. Plaintiff Lorene Caudy-Richardson, a current resident of Palm Beach County,
Florida, attended MedVance Institute's West Palm Beach campus from 2009 to 2010.
13. Plaintiff Claire Francy, a cut'l'ent resident of Palm Beach County, Florida,
attended MedVance Institute's West Palm Beach campus in 2009.
14. Plaintiff Ronald Goss, a current resident ofIndian River County, Florida, attended
MedVance Institute's West Palm Beach campus from 2009 to 2010.
15. Plaintiff Kecia Kearney, a cut'l'ent resident of Palm Beach County, Florida,
attended MedVance Institute's West Palm Beach campus in 2010.
16. Plaintiff LaMarsha Turner, a cut'l'ent resident of Palm Beach County, Florida,
17. Plaintiff Samona Bradley, a current resident of St. Lucie County, Florida,
attended MedVance Institute's Stuart campus in 2009.
18. Plaintiff Michelle Daniels, a current resident of Martin County, Florida, attended
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19. Plaintiff Ashlee Davis, a CUtTent resident of St. Lucie County, Florida, attended
20. Plaintiff Carol LaCroix, a current resident of Palm Beach County, Florida,
attended MedVance Institute's Stumt campus from 2009 to 2010.
21. Plaintiff Marianne Mackenzie, a current resident of Martin County, Florida,
attended MedVance Institute's Stumt campus from 2008 to 2009.
22. Plaintiff Jo Ann Maitland, a current resident of Martin County, Florida, attended
MedVance Institute's Stumt campus from 2008 to 2009.
23. Plaintiff Susan Sinko, a current resident of Martin County, Florida, attended
MedVance Institute's Stumt campus from 2009 to 2010.
24. Plaintiff Victoria Wesley, a current resident ofSt. Lucie County, Florida, attended
25. Plaintiff Annette White, a current resident of Martin County, Florida, attended
26. Plaintiff Louisanne Saint-Vii, a current resident of Broward County, Florida,
attended MedVance Institute's Ft. Lauderdale campus from 2008 to 2009.
27. Plaintiff Jordana Soler, a current resident of St. Lucie County, Florida, attended
MedVance Institute's Ft. Lauderdale campus from 2009 to 2010.
28. Plaintiff April Townsell, a current resident of Broward County, Florida, attended
MedVance Institute's Ft. Lauderdale campus from 2008 to 2010.
29. Defendant Education Affiliates Inc. is a Maryland corporation that owns several
private career colleges in Florida doing business under the name, "MedVance Institute."
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Education Affiliates purchased MedVance Institute from KIMC Investments, Inc. in December
2009. All Plaintiffs attended Defendants' Stuart, West Palm Beach or Ft. Lauderdale campuses.
30. Defendant KIMC Investments, Inc. is a Maryland corporation that owned several
private career colleges in Florida doing business under the name, "MedVance Institute." KIMC
Investments, Inc. sold MedVance Institute to Education Affiliates Inc. in December 2009. Upon
information and belief, KIMC Investments, Inc. was under tremendous pressure to improve its
balance sheet in the months preceding the sale to Education Affiliates Inc.
31. Defendant Sallie Mae, Inc. ("Sallie Mae") is a Virginia corporation that services
and collects Plaintiffs' student loans. MedVance employees fraudulently induced Plaintiffs to
enter into loan agreements with Sallie Mae. MedVance employees acted as apparent agents of
Sallie Mae.
32. Jurisdiction is proper pursuant to Fla. Stat. § 26.012 because this is an action at
law in excess of $15,000.
33. Venue is proper pursuant to Fla. Stat. § 47.041 because actions on several causes
of action may be brought in any county where any of the causes of action arose. Multiple causes
of action accrued in Palm Beach County, Florida.
Facts Common to All Counts
34. Plaintiffs were convinced to emoll because of promises that they could stali a
successful career in an in-demand occupational field. Oral representations aside, even
MedVance's informational literature makes umealistic forecasts and assurances. MedVance tells
recruits that it is "dedicated to preparing qualified candidates for careers in the medical field and
has been doing so for decades." See Exhibit B. It also claims that classes are taught by "highly
trained professionals." See id It boasts that students learn on-the-job training at "a variety of
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medical settings." See id. The Medical Office Administration program information guide states:
"Upon completion of this program, graduates will be able to seek entry-level positions in
healthcare facilities ... With strong skills sets in office technology, office management and
customer service, the graduate will possess the knowledge and be positioned to work within the
team dynamic required in healthcare administration today." See id. The Medical Billing and
Coding program information guide similarly states: "The Medical Billing & Coding Specialist
program prepares students to analyze medical records and assign codes to medical conditions,
diagnoses and procedures . . . Graduates find entry-level employment opportunities in
physician's offices, billing offices, hospitals .... " See id
35. MedVance recruits students aggressively with mailings, television advertisements
and internet advertisements: "from classroom to career in less than one year." MedVance
recruiters, pressured to sign up as many students as possible, are directed by their supervisors,
and have an independent incentive, to make various misrepresentations to potential students to
accomplish statistical emollment objectives. MedVance recruiters and financial aid personnel,
who present themselves as expelts on complicated federal loan regulations, urge students to cut
corners or flat out lie to either inflate wealth and income so that the student becomes an attractive
loan candidate, or understate income and wealth so that the student can receive Pell Grants. One
particularly manipulative feature is that most MedVance students are required to pay a $25 fee in
order to meet with financial aid employees and fill out a FAFSA 1 Sometimes the fee is waived,
in which case the student is meant to feel that he 01' she is receiving special treatment through the
waiver, assisting MedVance's recruitment objectives. Once this fee is paid, the potential student,
typically with limited resources, feels psychologically invested in the process and is not likely to
The first "F" in the acronym FAFSA stands for "Free."

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back out. After this fee, students are made to sign "Enrollment Agreements." Potential students
are told that these complicated documents simply established the student-school relationship and
that the complicated legal jargon therein simply anticipated instances in which a student suffers
an injury on the premises. Students are not given a copy of this document after they sign it.
Recruiters and financial aid personnel are trained to rush the student through the enrollment
process before they change their mind. They also create artificial pressures by telling students
that if they do not sign up then and there, they will have to wait months or even a year to start
another program. Disturbingly, recruiters make promises that MedVance is "accreditated,"
implying that credits can be transferred and that employers and other school recognize
MedVance as a quality institution. In reality, MedVance's "accreditation" was recognized by a
private agency and this serves as a minimum benchmark for schools that wish to take advantage
of federal student aid programs. It means nothing concerning employers or other schools
respecting MedVance's quality. Indeed, MedVance has a bad reputation with area employers
and other schools such as community colleges do not recognize credits earned at MedVance.
MedVance recruiters tailor their "pitch" to the student. For example, African American student
Donesia Best was told that President Obama has indicated that America needs more medical
workers to care for the aging population and that she would be performing an important public
service by attending MedVance. Middle-aged student Teri Dolecki was told that the program is
perfect for people of her age and was shown pictures of middle-aged graduates during a tour
while being told, "if they can do it, so can you." Also, instead of carefully counseling its
students on the pros and cons of incurring debt, recruiters and the financial aid depatiment
sought only the minimum information required to fill out federal loan documents.
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36. In reality, MedVance does not prepare its students for certification exams and
employment in a turbulent and competitive job market. Classes are taught by unqualified
individuals, many of which have no background in the field they are teaching. Multiple students
have stated that some instructors appear to be on drugs; there have also been numerous
complaints that instructors cannot speak English, or control a classroom. Most instructors rubber
stamp "A's" and grades have little correlation to academic achievement. This is likely because
federal student aid regulations require a student to maintain a minimum GP A to take advantage
of federal loan programs.
37. Across the board, MedVance's Career Services Office does little to connect
students with wOlthwhile job opportunities. Job postings are outdated and seek employees with
at least a few years of experience. MedVance has had difficulty placing students at externships,
in part because of MedVance's reputation, and in palt because MedVance enrolls more students
than it can manage. Externships are also a requirement for graduation in multiple programs, and
students are punished through no fault of their own, by MedVance' s failure to provide on-the-
job-training.
38. In hindsight, Plaintiffs see their time and money spent at MedVance as wasted.
At the end of the day, even if Plaintiffs do not receive the training promised, MedVance remains
the beneficiary of substantial federal-backed student loans. When the drive for profits
overshadows the drive to educate, students suffer and business thrives.
Donesia Best
39. Donesia Best was enrolled in the Medical Office Administration night program at
MedVance's West Palm Beach campus between October 2009 and June 2010. She graduated
with a 3.85 GPA. Ms. Best received some financial aid but incurred federal student loan debt of
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about $11,500. She was attracted to MedVance by the promise that, after graduation, she would
be hired for a full time position with benefits. She was told that President Obama needed more
employees in the medical field, and that she would be performing a public service by going to
MedVance and later working at a medical office. After expressing skepticism at filling out loan
paperwork given her financial position and the inability to pay a $25 enrollment fee, a recruiter
told her, "between you and me, there's a $25 fee and I will front it if you do not tell anyone."
MedVance Recruiters and financial aid personnel had no interest in Ms. Best's ability to repay
her loan and simply assured her that she would find a job in her field after graduation. They
hastily procured her personal information so that they could fill out loan paperwork on her
behalf. After filling out the paperwork, MedVance employees told Ms. Best to write down the
names and addresses of friends who might also be interested in enrolling. Ms. Best recalled that
instructors lacked effort and in a highly technical transcription class that required textbooks,
weeks went by without textbooks as the instructor simply passed the time.
40. During her studies, MedVance's Career Services Office told Ms. Best they would
help her with her resume, but they simply added a line for MedVance institute and sent it back to
her. They sent her on 2 "interviews": one consisted of dropping a resume in a pile at a nearby
job fair; the other was at a doctor's office, where she was told that she did not have requisite
experience. Ms. Best knows of only one peer in the Medical Office Administration Program
who found gainful employment. After MedVance, she enrolled at Broward College as a general
studies major seeking to satisfy prerequisites to be a registered nurse. Broward does not
recognize the credits she earned, at a hefty rate, at MedVance. Ms. Best currently works part
time at Publix and considers her graduation from MedVance and the experience in general as
"wOlihless."
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Guerlande Exantus
41. Guerlande Exantus was enrolled in the Medical Office Administration night
program at MedVance's West Palm Beach campus between November 2009 and August 2010.
Ms. Exantus graduated with about a 3.5 GPA. She incurred federal loan debt split between
subsidized and unsubsidized loans totaling approximately $11,500. MedVance's recruitment of
Ms. Exantus was extremely aggressive. Her first contact with MedVance occurred when they
called her directly and promised a great education and future employment. Initially, Ms. Exantus
was not interested but MedVance called several times and convinced her to come to the campus
and meet with a recruiter. Ms. Exantus set up an appointment and missed it. Despite her
missing the appointment, MedVance continued calling her and another appointment was set up.
Finally, after months of resistance, she went to MedVance's West Palm Beach campus to discuss
the possibility of enrollment with a recruiter named Christy. Christy indicated that right after
graduation, it would be easy to find a good job as a medical office manager paying at least $18
an hour. Ms. Exantus asked if credits earned at MedVance were transferrable to other schools,
Christy responded they were. The recruiter also pressured Ms. Exantus to sign up right away,
stressing that if she did not sign up right then and there, she would have to wait many months
because it was uncertain when the next Medical Office Administration Program classes would
begin. After asking her to pay a $25 fee, MedVance's financial aid department hastily
completed Ms. Exantus' loan paperwork. Ms. Exantus found that classes were taught by
unqualified individuals and the educational atmosphere was chaotic. At one computer training
and word processing class, MedVance did not even provide a teacher, and Ms. Exantus and her
peers complained to MedVance administration after a few weeks of instructional negligence.
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Finally, MedVance provided an instructor to teach the last few weeks of the class, who simply
sat in a chair and sent text messages.
42. After her attendance, MedVance's Career Services Office did nothing to help Ms.
Exantus find a job or even an internship. Career Services employees told her that they would
call her with job openings, edit her resume, help her develop job search strategies and
periodically check on the job search. None of this was done. When Ms. Exantus asked for
assistance, the Career Services Office told Ms. Exantus that she was "on her own" and urged her
to go to various medical offices to ask if they were hiring. Ms. Exantus has considered enrolling
in a community college but that idea was thwarted by the fact that the college told her that they
did not recognize any credits earned at MedVance, despite the recruiter's pre-enrollment
promises. She was previously a customer relations employee and has been out of work, caring
for her family, for over four years. She has stated that her debts are piling up and that MedVance
was a major waste of time and money.
Diana Medina
43. Diana Medina was enrolled in the Medical Office Administration night program
at MedVance's West Palm Beach campus between November 2009 and August 2010. Ms.
Medina completed her studies with a perfect 4.0 GPA. She paid approximately $3,000 out-of-
pocket in tuition and incurred federal student loan debt of about $9,000. Ms. Medina found
MedVance while searching online and was attracted by the oppOltunity to attend night classes
and better her job prospects. She contacted MedVance's West Palm Beach campus and was
assured by recruiter Norma Jimenez that she would definitely get a job as a medical office
manager nearby upon graduation. MedVance's financial aid depmtment told Ms. Medina that
they would take care of the loan paperwork and that she would not have to worry about it until
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she got ajob. During class, Ms. Medina recalls that answers to tests were spoon-fed to students
and that when she asked for clarification of a difficult subject, instlUctors would tell her to just
read the book. InstlUctors were woefully unqualified and would often ramble about their
personal lives or gossip, instead of thoughtfully teaching the subject matter.
44. Since completing her studies, Ms. Medina has received no help finding a job from
MedVance's Career Services Office. Ms. Medina, who attended the University of Florida,
considers her education at MedVance worthless and omits the experience from her resume. She
has stated that, "you are basically paying for a piece of paper that says, I graduated here, and I
still have no experience." She currently works at Publix but is actively seeking employment in
the Medical Office Administration field.
Teri Dolecki
45. Teri Dolecki was enrolled in the Medical Coding and Billing night program at
MedVance's Stuart campus between August 2008 and July 2009. Ms. Dolecki graduated with a
perfect 4.0 GPA. To pay for the $15,000 program, she took out federal loans. She is able to
repay a portion of these loans through VA assistance since her husband was a disabled veteran.
Ms. Dolecki saw a commercial on TV and went on MedVance's website, where she was
attracted by representations that the medical coding and billing fields were in high demand. Ms.
Dolecki, who had been out of school for 30 years and whose husband had recently passed away,
was interested in the prospect of going from "classroom to career in under a year." She visited
the campus and was reclUited by MedVance's Tamara Stephens who, on a campus tour, showed
her a picture of middle-aged graduates and told Ms. Dolecki that that individual graduated with
honors and was able to find a job. Ms. Stephens also told her that she could work part time from
home after graduation, that jobs in the field were in demand, and that MedVance would prepare
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her for the Celtified Professional Coder (CPC) examination. Ms. Dolecki has stated that Ms.
Stephens "told her everything that she wanted to hear." To entice attendance, MedVance
refunded Ms. Dolecki's emollment fee. The financial aid department hastily processed her
paperwork and told her it would be easy to payoff loan debt. Ms. Dolecki was one of the many
students who signed up for the new 4-week curriculum, whereby MedVance would teach
subjects in four, rather than six weeks. This new curriculum hutts students and teachers, who
must speed through the material; it helps MedVance, which is able to recruit and sign up more
students per year. During her externship, Ms. Dolecki was placed at Martin Memorial Hospital
and Treasure Coast Surgical Center. At these placements, she received some coding experience,
but spent most of her time xeroxing repolts, copying papers, stuffing envelopes and answering
phones.
46. Ms. Dolecki took and passed the CPC exam and upon information and belief, was
the only student in her program to do so. She recalled that reading the textbook was more useful
than MedVance's exam prep classes, which consisted of crossword puzzles. See Exhibit C. Ms.
Dolecki accepts the possibility that her 25 years experience in medical transcription and
terminology helped prepare her for the exam more than MedVance did. After celtification and
graduation, MedVance' s Career Services Office put her in contact with employers who only
wanted her to answer phone calls. This differed greatly from pre-emollment promises. Highly
motivated, Ms. Dolecki offered to volunteer at medical offices to learn more about coding, but
employers told her that she lacks the requisite experience. MedVance agents made pre-
emollment misrepresentations concerning the employability and earning potential of graduates.
MedVance never told her during recruitment and emollment that almost all medical coding and
billing employers are only seeking employees with at least two years experience in the field.
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Recruiters and financial aid employees neglected to inform her that maintaining a license in the
field costs about $200 a year. Since the filing of this lawsuit, in an apparent push to right past
wrongs after months of inaction, a Career Services employee has contacted and told her that they
are looking for part time jobs in the Stualt area for her. She is currently living off of her pension
and actively seeking a coding job, which she has been unable to attain, despite her 4.0 GPA and
passage of the CPC exam. Ms. Dolecki has stated that she was "proud of herself for having the
courage to go back to school, but it was all a waste."
Diana Meyer
47. Diana Meyer was enrolled in the Medical Coding and Billing night program at
MedVance's Stuart campus between August 2008 and July 2009. Ms. Meyer attended classes
but left after her externship and did not graduate. Ms. Meyer paid for the $15,000 program by
incurring federal loan debt of about $11,500; the rest was covered with Pell Grants. She was
first attracted to MedVance's "classroom to career in less than one year" advertisements on the
internet and television. She visited the campus and MedVance recruiter Tamara Stephens
promised Ms. Meyer, who has 20 years of accounting experience, a job that paid approximately
$50,000 upon graduation. Ms. Stephens told Ms. Meyer that MedVance was accredited and that
passage of the exam would be a virtual certainty after a MedVance education. She also told her
that billing and coding graduates were in high demand in the job market. After Ms. Meyer told
Ms. Stephens that she wanted to speak with her husband before filling out loan paperwork and
enrolling, Ms. Stephens pressured her to enroll by stressing that if she did not sign up right then,
she would have to wait months or a year to fill a spot in another program. MedVance's financial
aid department filled out her FAFSA and told Ms. Meyer that paying the loans off would not
pose a problem and that other MedVance graduates easily paid off the debt. Ms. Meyer thought
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that she could claim her husband and daughter as dependents in the loan paperwork. However,
while filling out the loan paperwork, an employee named "Kiki" claiming to be an expert on the
federal loan process told Ms. Meyer that she could and should claim Ms. Meyer's financially
independent mother and aunt, who lived with her. They also told Ms. Meyer that she should
claim her 23 year old daughter who lived away at college as a dependent. Because of the
financial aid employee's advice, the number of dependents went from three to six. Ms. Meyer
was placed at a 32-hour-a-week externship for no pay with All American Physicians LLC in Port
St. Lucie. Although given the opportunity to do some medical coding, her supervisor was not
qualified and failed to give her guidance or teach her more about the field. After the externship,
Ms. Meyer left MedVance when the instructors gave her and her peers crossword puzzles and
word searches in order to prepare for the intensive CPC exam. See Exhibit C. Coding
instructors were not qualified and one in particular had not passed the CPC exam. She recalls
that much of the classroom teaching directly conflicted with the textbook and caused confusion
for students.
48. Ms. Meyer, like almost all of her classmates, eventually failed the CPC exam and
was not properly prepared by MedVance, despite their promises. Linda Hedges, Director of
Education at the Stuart Campus, emailed Ms. Meyer in June 20 I 0 to try to get her to re-emoll.
In response, Ms. Meyer requested statistics concerning how many MedVance students actually
pass the CPC exam and told Ms. Hedges that classes were not helpful. In July, Ms. Hedges
replied that of the 2008-09 students, 80% passed; of the 2009-10 students, 78% passed and that
MedVance strived for a 70% rate. See Exhibit D. Upon information and belief, this was a flat
out lie concerning passage rates, directly relating to employability of graduates. She has re-
emolled at Indian River State College and is taking courses to further her goal of becoming a lab
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technician. The credits earned at MedVance are not transferrable, despite Ms. Stephens'
representations of institutional legitimacy and accreditation. In addition to these misleading
statements, Ms. Meyer has found statements by Ms. Stephens and "Kiki" regarding the quality of
education and employability of graduates to be misleading.
Linda O'Neill
49. Linda O'Neill was emolled in the Medical Coding and Billing night program at
MedVance's Stuart campus between October 2008 and September 2009. Ms. O'Neill graduated
with a perfect 4.0 OP A. She incurred federal loan debt of about $15,000. Ms. O'Neill has stated
that she was "sucked in" by a recruiter named Lynette who stated that "most girls" get a job with
a starting salary of about $30,000. She was pressured to emoll by representations that if she did
not emoll right there and then, she would have to wait months or even years to join a similar
program. Before applying for federal student aid, Ms. O'Neill was told to pay, and did pay, a
$25 emollment fee that the recruiter said was necessary in order to "get the ball rolling." She
was rushed through the loan application process and was not told to carefully consider the
implications of incurring substantial debt, despite the fact that she expressed apprehension. Ms.
o 'Neill remembers that instructors were unqualified and textbooks needed to be updated.
During her unpaid externship at an eye doctor's office, she folded letters, stuffed and stamped
envelopes and completed other menial tasks umelated to forging contacts and developing
professionally in the medical billing or coding fields. She has stated that she "did her time," in
order to receive externship credit, a requirement to graduate.
50. Ms. O'Neill did not pass the CPC exam and has stated that MedVance did not
properly prepare her for it because classes were rushed and students were made to complete
crossword puzzles and word searches. See Exhibit C. During her job search, she has found
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MedVance's representations that graduates can become coders right out of school to be false.
During classes and after graduation, MedVance's Career Services Office did nothing to help her
find a job anywhere within 30 miles of Jupiter, where she lives. She looked into re-emolling at a
community college but that plan was stymied by the fact that credits earned at MedVance are
non-transferrable. On November 10,2010, Career Services emailed Ms. O'Neill and presumably
many others to check on the job search. Indicative of MedVance's recruitment practices, the
email reminds: "you will receive a $25.00 gift card for each verifiable job lead you provide to
Career Services, and another $25.00 gift card for each job lead that turns into a hire for one of
MedVance's graduates!" See Exhibit E. Ms. O'Neill currently works at a small cleaning
business and has no prospects finding a job related to her studies at MedVance despite her best
efforts.
Patricia Bennett
51. Patricia Bennett was emolled in the Medical Billing and Coding night program at
MedVance's West Palm Beach campus from 2009 to 2010. She had about a 3.7 GPA and
recently completed her studies. She incurred federal loan debt of about $15,000 to pay for the
program. She wanted to enter the medical field and increase her earning potential and visited a
MedVance campus after seeing an advertisement. A recruiter there promised help with job
placement and told her that graduates could expect to earn about $50,000 annually or $35 an
hour after graduation. After further representations concerning the quality of education, Ms.
Bennett decided to emoll and was asked to pay, and did pay, a $25 emollment fee to speak with
financial aid. Financial aid hastily processed her federal loan paperwork for her and asked her to
sign. She thought the experience was "sloppy." During her attendance, there was an erroneous
overpayment that Ms. Bennett discovered and MedVance would have pocketed had she not
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pointed out the error. During classes, she found that teachers were unqualified, unprepared and
oftentimes truant. At her unpaid externship, she was asked to file all day and was not permitted
to do, or observe, any billing or coding work.
52. She is preparing for the certification exam and receiving no help from MedVance,
despite their promises. She currently works at a restaurant, and part time at Code Blue Billing, a
job she found on her own. She is a middle-aged individual who says that if she would have
known the truth about MedVance when she enrolled, she would have gone to a traditional
community college. She has been lied to and feels that at MedVance, she was "throwing money
away."
Yanno Bevacqua
53. Yanno Bevacqua was enrolled in the Medical Billing and Coding day program at
MedVance's West Palm Beach Campus from November 2008 to October 2009. He graduated
with about a 3.9 GPA. He incurred federal loan debt of about $15,000 to pay for the program.
He saw an advetlisement on the internet and was interested in entering the medical field. He
visited a MedVance campus, where he expressed interest, but also communicated that the cost of
the program was more than he could afford. The recruiter asked if his parents were willing to
co-sign the loan paperwork and he said no. Mr. Bevacqua has stated that "like a car salesman"
the recruiter haggled and convinced him to enroll by stating that the quality of education was
first rate, that MedVance graduates easily find employment following graduation, that the school
was accredited, and that it would be easy to pay loans after finding a job. Next, he was asked to
pay, and did pay, a $25 "enrollment fee" so that he could speak with financial aid employees.
He recalls that financial aid had "a confusing time" filling out his federal loan paperwork. When
Mr. Bevacqua was having trouble making a $63 monthly tuition payment, a financial aid
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employee threatened to kick him out of school if he did not pay. He found that the classes were
taught by unqualified individuals who either did not know how to teach, did not know the subject
matter, or both. He has stated that MedVance did not provide the right education to be
competent in the field. For his unpaid externship, he was placed at Magnetic Medical
Management, where he prepared spreadsheets and organized files; he was not given the chance
to perform tasks related to billing or coding.
54. Despite promises made pre-enrollment at orientation, the Career Services Office
never connected Mr. Bevacqua with potential employees or helped him with job search skills.
He thinks it likely that he is treated differently by MedVance employees because it is a female-
dominated campus and profession. Following his externship and after graduation, Career
Services consistently told him that they were busy with other students. They did not return
emails or phone calls seeking help. He is looking for work but feels that his current job
prospects are "dismal." He never would have gone to MedVance without their
misrepresentations regarding the quality of education and employability upon graduation.
Because of the debt burden he faces, Mr. Bevacqua had to move back in with his parents.
Lorene Caudy-Richardson
55. Lorene Caudy-Richardson was enrolled in the Medical Billing and Coding day
program at MedVance's West Palm Beach campus from November 2009 to October 2010. She
graduated with a perfect 4.0 GPA and is currently studying for the certification examination.
She incurred federal loan debt of about $15,000 to pay for the program. Ms. Caudy-Richardson
is a middle-aged individual who wanted to learn an interesting subject and increase her earning
potential. She was recruited by Michelle Weinberg, who talked her into the Medical Billing and
Coding program by promising an excellent education and stating that there were many job
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openings paying about $40,000 annually. Ms. Weinberg represented that even after graduation,
MedVance would take an active role injob placement and would pay the CPC examination fee.
Ms. Caudy-Richardson was motivated, but apprehensive about the cost. Ms. Weinberg promised
to reduce her monthly fee from $190 to $60 (almost all students pay a $60 fee, so this was a
ploy), and in return, Ms. Weinberg wanted her to find five people who would be interested in
attending. To pressure a compulsive decision, Ms. Weinberg told Ms. Caudy-Richardson that
there was only one seat left in the class, and that if she did not sign up right then, she would have
to wait months to enter a new program. Because of this pressure, Ms. Caudy-Richardson paid
the $25 enrollment fee and was then permitted to speak with financial aid. Financial aid spoke
with her to find out her financial position and family situation. As a result of this conversation,
they asked her to bring in her husband's 2008 taxes, even though he did not many her until May
2009. Ms. Caudy-Richardson tried to tell financial aid that her husband's taxes, before he was
her husband, were irrelevant. Because of her husband's higher income, she was not eligible for
grants because their combined income was much higher than hers alone; at the same time, she
was a more attractive loan candidate in the eyes of the government because her husband's higher
income gave the appearance of solvency. After this act of fraud by financial aid, Ms. Caudy-
Richardson began classes. She has stated that since MedVance will "take anyone in off the
street." Classes were chaotic and instructors were unable to control disruptive students.
Teachers would often ramble about their personal lives to pass time. Ms. Caudy-Richardson
witnessed cheating on tests, and reported this to instructors, who took no action. In a class about
anatomy (critical to coders), several chapters on anatomy that would be tested on the CPC
examination were not covered due to instructional neglect. She has stated that the only time you
can get one-on-one attention at MedVance is when payments are past due and administrators
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personally threaten expulsion. MedVance promised to find her an externship but never did;
however, her mother was able to find her one at a urologist's office in Lake Worth.
56. As Ms. Caudy-Richardson has begun looking for jobs, she has found that
employers require at least two years of experience and do not employ MedVance graduates.
This is due in part because of its general reputation, and in part because students placed on
externships act in an unprofessional manner and harm qualified students' job prospects. Ms.
Weinberg's statements concerning earning potential and the quality of education turned out to be
false. Ms. Caudy-Richardson and her family are now faced with a heavy loan debt burden and
her experience at MedVance was a waste of time and money. She also has stated that she feels
let down by the government, which permits MedVance to avail itself of federal student aid
programs and the benefits of accreditation.
Claire Francy
57. Claire Francy was enrolled in the Medical Assistant day program at MedVance's
West Palm Beach campus from January to September 2009, when she was expelled by Louise
Nicholson, Director of Education, for being an agitator in the eyes of the administration. She
had a 4.0 GPA when this happened. To pay for the program, she incurred federal loans debt of
about $13,000. Ms. Francy, who is middle-aged, attended MedVance seeking to learn something
new and enter a new field. She was shocked at the speed with which she was able to sign up,
apply for federal loans, and begin classes. At orientation, Brenda Green, campus director, told
all the students what nice cars and shoes they could buy going into the allied medical field.
Classes were awful. In anatomy and physiology class, textbooks were not provided until the
course was almost over. One teacher, Dr. Martinez, could not communicate in English; he was
eventually removed after the students complained. She remembers that because of the school's
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lack of student suitability criteria, local police were called to campus frequently to break up
fights. Ms. Francy did not feel safe and she emailed Ms. Nicholson and other administrators to
bring this legitimate concern to their attention. Ms. Nicholson condescendingly responded that
such matters should be handled verbally (so as to prevent a paper trail) and that sending such
emails "could get [Ms. Francy1 in a lot of trouble." Ms. Francy replied that she did not agree.
The administration was invisible once loan payments were secured by MedVance. Two weeks
before graduation, nothing was told to the students regarding the on-the-job-training externships
that MedVance was supposed to provide. Career Services Director Kristina Ciupberger told Ms.
Francy that it was difficult to find externship sites because many students did not show up,
dressed properly, communicate or behave, or generally act professionally, so no suitable sites
were interested.
58. Ms. Francy has no job prospects in the field. After attaining a perfect GPA and
being invited to graduation in late 2009, she was expelled by Ms. Nicholson on September 28,
2009. This left her "high and dry" with respect to employment options. This expulsion was
directly related to her whistle blowing activities with respect to campus security and educational
quality.
Ronald Goss
59. Ronald Goss was enrolled in the Information Technology and Biomedical
Technician night program at MedVance's West Palm Beach campus from February 2009 to
October 2010. He graduated with a perfect 4.0 GPA. To pay for the program, he incurred
federal loan debt of about $25,000. When Mr. Goss went to visit the campus, he told a recruiter
that he wanted to go into the radiology tech field. According to MedVance's website,
MedVance's radiology tech "programs have, or are in the process of seeking, programmic
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approval" by a recognized accrediting agency. However, the recruiter convinced Mr. Goss that
he had an insufficient background in mathematics to qualify for that program so he was
pressured into MedVance's new Information and Biomedical Technician program, which does
not have programmic accreditation. He was told that although the program was new, MedVance
had solid facilities and equipment. He was also told by the recruiter that externships usually lead
to jobs and that even if not in his case, MedVance's Career Services Office had connections with
area hospitals and employers and that they could surely find him a position following graduation.
Although hesitating because of the cost of the program, Mr. Goss paid the enrollment fee
because of promises that he would earn about $50,000 annually. Next, the financial aid
department processed his federal loan paperwork. He found that the teaching was horrible and
the school did not even have internet access, unheard of for an IT program. The textbooks and
course materials were outdated and did not prepare Mr. Goss with modern positions in the field.
Despite promises by the recruiter, MedVance never placed Mr. Goss at an externship site and he
never received any on-the-job-training. Mr. Goss recollects that none of his peers in this new
program were placed at extern ship sites.
60. Following graduation, MedVance's Career Services Office did "absolutely
nothing" to help him try to find suitable employment. When he has found potential employers
on his own, he has found that they "run away" from MedVance graduates. He is currently
studying information technology online, and the credits earned at MedVance are not
transferrable to this online program. He feels that he was lied to during recruitment, particnlarly
with respect to the employability of graduates, the availability of on-the-job-training and the
quality of instruction and facilities for the new program.
Kecia Keal'lley
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61. Kecia Kearney emolled in the Medical Billing and Coding day program at
MedVance's West Palm Beach campus in February 2010 and is finished with classes.
MedVance has neglected to place her at an externship. She has about a 3.0 GPA. She is paying
for the $15,000 program by incurring federal loan debt of about $10,000 and Pell Grants totaling
about $5,000. Just after her mother passed away, Ms. Kearney saw a MedVance advertisement
on television when she was unemployed. She thought nothing of it but kept seeing the
advertisement on television at her home, at friends' homes, at the gym, etc. Finally, she called
and set up an appointment with a recruiter. The recruiter told her that it was a quick and
effective program, and that MedVance would find her a good job, with benefits, with the help of
the Career Services Office. She was asked to pay, and did pay, the $25 emollment fee and was
then permitted to speak with financial aid. She presented her tax return to financial aid and when
she found out about the program's cost, she got cold feet. The financial aid employee told her
not to worry because MedVance would provide a great education, services, job placement, and
that loans would be easy to payoff when she was earning a substantial salary as a biller or coder.
Financial aid hastily processed her paperwork and had her sign it without allowing her to read it.
During her classes, she found that the instructors were "no good." Some classes had no
instructor at all, and she was frustrated to be paying a lot of money so that she could read a book.
She complained to administrators, but no corrective action was taken with respect to educational
quality. One instructor only spoke French and students could not understand him.
62. Ms. Kearney plans to take the CPC examination and enter the field, but feels she
is ill prepared. She has had some contact with the Career Services Office. They told her they
would help her with her resume; Ms. Kearney emailed it to them and did not receive a response.
Ms. Kearney was laid off from her position as a human resources coordinator in 2009,
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counseling victims of violent crime. Previously, she also worked with mentally disabled adults.
She thought that the medical field was related to her experiences and that she could earn more
money. The recruiter's promises increased her hopes. She was lied to and thinks that MedVance
needs to be "shut down."
LaMarsha Turner
63. LaMarsha Turner was enrolled in the Medical Billing and Coding program at
MedVance's West Palm Beach campus from September 2008 to September 2009. She has
completed the program but is not allowed to graduate because she purpOliedly failed to make a
few monthly payments of about $60. Ms. Turner is a single mother with a blind, special needs
son who wanted to go back to school to earn money to suppOli her family. She previously took
courses in the medical assisting field at another school and sought to complete her studies at
MedVance. When she visited the campus, a recruiter told her that she did not want to complete
her medical assisting courses because "coders make more money" and graduates in the field are
in higher demand. The only thing that is "more money" is the cost of the Medical Billing and
Coding program, by about $2,000. Ms. Turner asked what percentage of students is employed
within a few months of graduation; the recruiter responded, about 90%. Ms. Turner asked if she
took out the loan, whether it would cover costs up to and including the CPC exam; the recruiter
responded, yes. These answers being sufficient, Ms. Turner was rushed to the financial aid
office, which prepared her loan application. When reviewing the paperwork, Ms. Turner told a
financial aid employee that she did not understand a few portions. The employee responded,
"don't worry, you'll pay it off" and that "the loan will help you, just sign the paperwork."
Classes were chaotic and taught by unqualified teachers. It took MedVance "forever" to find her
an externship site, and that site involved filing and other menial tasks. She left and found her
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own externship at Palm Beach Heart. She had a decent expenence while completing her
externship there; she says that she learned much more there than she did at MedVance.
64. Ms. Turner's graduation status is uncertain. She completed the coursework but
MedVance claims she owes them money, even though the recruiter and financial aid specifically
instructed her that the loan would cover costs up to and including the CPC exam and financial
aid was unwilling to answer her questions when she was confused by loan paperwork. She
refuses to sign a loan exit interview because she was misled. She has reviewed the Career
Services Office's "career board" which only listed jobs requiring a few years of experience. She
has not received any other assistance regarding job placement, despite her requests and
MedVance's promises.
Samona Bradley
65. Samona Bradley was emolled in the Medical Assistant day program at
MedVance's Stuart campus from March to November 2009. She graduated with about a 3.3
OP A. She paid for the $13,000 program by incurring federal loan debt of about $8,000 and
receiving grants totaling about $5,000. She first learned about MedVance from watching a
television advertisement and liked the idea of attaining a quality education that would boost her
earning potential, in a far shorter time than a traditional college. She visited the campus and
recruiter Tamara Stephens enticed her by telling her that the medical assisting field was in high
demand and that MedVance would allow her to enter that field, that the school was accredited,
that MedVance's facilities and equipment were second to none, and that the Career Services
Office would find her ajob. Ms. Bradley was asked to pay, and did pay, a $25 "emollment fee."
Ms. Bradley has no recollection of filling out a FAFSA, and thinks that this was done for her.
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She was placed at an unpaid externship at All American Physicians LLC. She found that her
education at MedVance did not allow her to meaningfully help out at the externship.
66. Following graduation, Ms. Bradley was unable to find a job related to the medical
field. She thinks that the Career Services Office did everything in their power to help, but that
they were understaffed and unable to find realistic job leads for the high volume of graduates
from MedVance. She has looked into going back to school and transferring her credits to other
colleges, but has found they do not recognize credits earned at MedVance. She is still searching
for the job promised by Ms. Stephens, and is working as a substitute teacher to make ends meet.
Michelle Daniels
67. Michelle Daniels was enrolled in the Medical Billing and Coding day program at
MedVance's Stuart campus from November 2008 to October 2009. She graduated with a 4.0
GPA and paid for the program by incurring federal loan debt totaling about $14,000. She was
attracted to the challenge of going back to school and was enticed by a recruiter named Lynette
who promised a high paying job after graduation, ease in loan repayment and high quality classes
on the cutting edge of the field. She was asked to pay, and did pay, a $25 enrollment fee,
permitting her to seek financial aid. Financial aid employees "did all of the work" and asked her
to sign. They assured her that the debt would be paid off after she found a job and that in any
event, there was a six month grace period. She found that classes were unhelpful. She has stated
that "they took our money and did not give us an education." MedVance promised to find her an
externship, failed, and Ms. Daniels found an unpaid externship at Treasure Coast Surgical Group
and Liberator on her own. At the externship, she performed filing tasks and observed others
perform their jobs.
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68. Medvance's Career Services Office did not help Ms. Daniels with her resume and
the only job 0ppOltunities presented required a few years of experience. In her job search, Ms.
Daniels found that employers did not respect the MedVance brand. She currently does temp
work with Spherion and works in the posting depattment at Liberty Medical. She is unable to
pass the CPC examination after several tries. MedVance did little to assist her with preparation
for this test, critical to those seeking to enter the field. Ms. Daniels feels that she was lied to and
her hopes of a better life were exploited for money.
Ashlee Davis
69. Ashlee Davis was enrolled in the Medical Assistant day program at MedVance's
Stuatt campus from August 2009 to May 2010. She graduated with about a 3.3 GPA. Ms. Davis
incurred federal loan debts totaling about $8,500 and she received about $4,500 in Pell Grants to
cover the $13,000 tuition. She was excited to go back to school and enter the medical field and a
recruiter at MedVance named Lynette "painted a beautiful picture." She was told by Lynette that
she would receive help finding a job and would be well-trained to enter the field. Ms. Davis also
appreciated that it was advet1ised as a short, condensed program, because she had a baby and
sought to "get on with her life." After paying the $25 fee required before speaking with financial
aid and applying for loans, she gave a financial aid employee her tax return, and they did the rest.
She found that classes were not helpful and had a hard time learning the material. Teachers were
unprepared and students were out-of-control. She was placed at an unpaid externship at All
American Physicians, where she had a decent experience, but felt unqualified to provide
meaningful help.
70. Following her time at MedVance, she found that the Career Services Office, and
MedVance in general, did nothing after "promising the world." Following the filing of the
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Complaint, she began regularly receiving calls checking up on the job search from Career
Services employees. She felt that these gestures were "fake." She decided to enroll at Indian
River State College and pursue a career in criminal justice. After telling the Career Services
Office this, Ms. Davis was repulsed when she receive a waiver that MedVance wished her to
sign, authorizing them to have no further responsibility with respect to her job search. Ms. Davis
thinks she was lied to and considers her time and money spent at MedVance a colossal waste.
Carol LaCroix
71. Carol LaCroix was enrolled in the Medical Assistant day program at MedVance's
Stuart campus from June 2009 to March 2010. She graduated with about a 3.8 GPA. She
incurred federal loan debt of about $12,000 and the remainder of the tuition was covered with
Pell Grants. A MedVance salesperson somehow got Ms. LaCroix's home phone number and
cold-called her one day, with promises of an exciting career in an in-demand occupational field.
She visited the campus with a friend and they met with a recruiter named Lynette who told her to
not worry about the cost because MedVance would "make it so you can afford it." They did this
by "allowing" Carol to pay monthly installments of $50 and enjoy a six month deferment on loan
repayment. She was told that she would not only be able to pay the loans back with ease after
graduation, but that she would also be able to buy a new car. She was told during recruitment
that if she could find ten people that signed up, MedVance would provide her with a "free
lunch." She accepted and was asked to pay, and did pay, a $25 "enrollment fee" so that she
could speak with a financial aid representative. She was rushed through the loan application
process and was simply asked to sign a print out, no questions asked. She found that classes
were surprisingly easy because instructors gave correct answers right before tests. Instructors
also appeared disinterested and were not knowledgeable. She has stated that "as long as you
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show up, they pass you-this is a problem." The only positive experience occurred at her unpaid
externship, where there was some discussion concerning hiring Ms. LaCroix. This never
happened, likely because the site received so much free labor from MedVance.
72. Following graduation, Ms. LaCroix thinks that the Career Services Office made a
sincere effort to find her a job, but it was severely understaffed and did not have the resources to
accommodate MedVance's ever-expanding student body. They provided some advice and
stressed the importance of networking; however, Ms. LaCroix found it difficult to network in the
relatively sparsely populated Stuart-Jupiter area, particularly without any real experience. In
retrospect, Ms. LaCroix feels let down after Lynette told her exactly what she wanted to hear.
Before she attended MedVance, she worked in retail and as a caregiver to the elderly. Following
her attendance at MedVance, she has resumed working as a caregiver to the elderly. She would
have found this job, and did have this job, before her MedVance education.
Marianne Mackenzie
73. Marianne Mackenzie was enrolled in the Medical Assistant day program at
MedVance's Stuart campus from June 2008 to April 2009. She graduated with about a 3.9 GPA.
She incurred federal loan debt totaling about $15,000 to pay for the program. She saw "from
classroom to career in under a year" adveliisements on television, called the school and set up an
appointment with a recruiter. The recruiter "promised the world" to Ms. Mackenzie and
promised that medical assistants were in high demand and that she would find future
employment. Ms. Mackenzie, who like Ms. Dolecki is a middle-aged individual, was enticed by
representations that persons in her age group frequently attend MedVance and secure high
paying jobs in the field. In fact, she was told by the recruiter, "your experience and maturity
alone will get you a position anywhere." She was told that the school was accredited and well-
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respected by employers in South Florida. Although hesitant of incurring loan debts, Ms.
Mackenzie decided to enroll after meeting with the recruiter, and was asked to pay, and did pay,
a $25 fee to speak with a financial aid representative. That employee filled out the FAFSA for
Ms. Mackenzie and the whole process took a matter of minutes. She was disappointed by
classes, taught by inexperienced faculty unable to answer student questions regarding the
material. She was shocked to learn that teachers gave answers to the tests before tests were
given. MedVance placed Ms. Mackenzie with a small doctor's office in Port St. Lucie and
primarily conducted clerical work. She was never given an opportunity to perform the types of
tasks typically performed by medical assistants but did get the chance to observe the doctors.
74. Following graduation, the Career Services Office did little to connect Ms.
Mackenzie with job openings. They set her up with exactly one interview. While expressing
frustration at the inability to secure employment, a Career Services employee told her that the
problem could be her age. Again, a major reason that she enrolled was the recruiter's promise
that her "experience and maturity" would benefit her greatly during the job search. She is
actively searching for jobs in the field and is unemployed. One potential employer told her that
having MedVance on her resume was "a strike against her." Ms. Mackenzie is disappointed that
because of MedVance's misrepresentations, she could be struggling to payoff her student loan
debt for the rest of her life.
Jo Ann Maitland
75. Jo Ann Maitland was enrolled in the Medical Billing and Coding day program at
MedVance's Stuart campus from September 2008 to September 2009. She graduated with a
perfect 4.0 GPA. She incurred federal loan debt and made small monthly payments totaling
$15,000 to pay for the program. She was caught in a bad job and sought a career change. She
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was attracted to MedVance's "classroom to career in under a year" advet1isements. The recruiter
flattered her by telling Ms. Maitland that with her background, she would have "no problem
securing employment." She was presented with a publication by the American Academy of
Professional Coders indicating that education and title "translates into bucks" and that cettified
coders could expect to earn about $40,000 annually. She does not recall the experience of filling
out loan paperwork and believes that this was done for her. Her relationship with financial aid
was "sketchy." She found that courses were taught by instructors who were not prepared to
teach the subject matter. She was placed at an externship site at an eye doctor's office where she
received no mentoring or on-the-job-training and spent most of the day staring out the window
because no help was needed. She left and found her own externship, where she was eventually
hired.
76. Ms. Maitland is currently employed at the externship site she found, but is not
earning the salary she was promised, and is having trouble re-paying loans and making ends
meet. She thinks that the Career Services Office was understaffed and could not meet the needs
of MedVance's many students. Job postings were outdated and many positions listed were
already filled. Almost all listings required at least a few years of experience. She is able to boil
down the misrepresentations by MedVance into two central lies: 1) MedVance prepares its
students for the intense CPC Exam; 2) potential employers hire MedVance's Medical Billing and
Coding graduates right out of school.
Susan Sinko
77. Susan Sinko was enrolled in the Medical Billing and Coding night program at
MedVance's Stuatt campus from January 2009 to January 2010. She graduated with about a 4.0
GPA. To pay for the $15,000 program, she inculTed federal loan debt of $12,000, and the
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remainder was covered by Pell Grants. She saw advertisements for MedVance on television and
called for more information and an appointment with a recruiter was set up. At that meeting, the
recruiter indicated that MedVance's instructors were experienced, that the medical billing and
coding fields were in high demand, and that graduates of the program could expect a salary of
about $40,000 annually upon completion. She was asked to pay, and did pay, a $25 fee before
being able to speak with a MedVance financial aid employee and fill out a FAFSA. She was
reminded that there was a six month grace period and that the loans would be easy to payoff
after she secured a job. She found that in reality, classes were taught by unqualified individuals
who could not control a hectic classroom atmosphere. At the unpaid externship site set up by
MedVance, she primarily performed menial tasks and did not gain valuable experience or forge
connections in the billing and coding fields.
78. Ms. Sinko was one of the few Medical Billing and Coding students to pass the
CPC examination. She passed by studying the textbooks with friends and found MedVance's
"synthesis" exam preparation course to be wOlthless. See Exhibit C. Despite this certification,
she has found it impossible to find a solid-paying job in that field since employers do not place a
high value onjob applicants with "MedVance Institute" on their resume. She did find ajob with
McKesson Corporation as a data entry specialist, where she earns far less than the recruiter's
$40,000 projection. Ms. Sinko believes that she would have gotten the job at McKesson without
ever having attended MedVance. McKesson is a leader in the medical industry and is employs
many medical billers and coders. Despite this, and its close proximity to MedVance's campus,
the Career Services Office does not connect its students with this employer. Ms. Sinko has
attempted to apply for a higher paying position as a medical biller at McKesson but her boss told
her that she did not receive enough hands on experience at her externship, and that her
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accounting knowledge did not translate specifically to the medical field. In other words,
supervisors at McKesson has indicated that a top MedVance Medical Billing and Coding
graduate is ill-prepared for employment in the field. She thinks of her decision to attend
MedVance as a waste of time and money and is frustrated at the misrepresentations made by
MedVance agents during recruitment.
Victoria Wesley
79. Victoria Wesley was enrolled in the Medical Assistant program at MedVance's
Stuart campus from April 2009 to January 2010. She incurred about $10,000 in federal loan debt
to pay for the program, and covered the rest with Pell Grants. She graduated with about a 3.5
GPA. Ms. Wesley saw a television advetiisement for MedVance, "from classroom to career in
under a year." Along with her sister, Ms. Wesley visited a recruiter and expressed interest in
entering a Licensed Practical Nurse program. The sisters passed an entrance examination that
qualified them for the LPN program, but they decided that the program cost too much. As they
were leaving, the recruiter mentioned that the Medical Assistant program was "basically the
same thing." The recruiter promised good jobs upon graduation and assured the sisters that they
would be able to repay their loans following graduation. The recruiter urged them to sign up
soon, or else they would have to wait months for another program to begin. The recruiter stated
that Medical Assistant graduates earn at least $15 an hour right out of school. The recruiter
waived a $25 enrollment fee for Ms. Wesley and the financial aid depatiment hastily prepared
her federal loan documents. During classes, Ms. Wesley found that teachers did not know how
to teach and that some teachers were arrested for drug violations, mid-semester. Ms. Wesley
found her own unpaid externship at an eye doctor's office. She still works there, earning $10 an
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hour. At the office, she now knows the functions of a medical assistant, and the experience has
revealed to her how poorly MedVance prepares its students for the real world.
80. After graduation, Ms. Wesley has found out that employers seek LPNs more than
they seek those with medical assisting backgrounds because LPNs can perform a broader set of
functions in a medical office. Ms. Wesley has found that Medical Assistant graduates typically
stmi at $9, not $15 per hour. She has attempted to transfer her credits to Indian River State
College, but they do not recognize credits earned at MedVance, despite the recruiter's
representations concerning quality and accreditation. She is "starting from scratch" but is
committed to advancing her career in the medical field.
Annette White
81. Annette White was enrolled in the Medical Billing and Coding day program at
MedVance's Stuart campus from February 2009 to February 2010. To pay for the $15,000
program, she incurred federal loan debt of about $10,000 and received Pell Grants of about
$5,000. She found MedVance on her computer when she clicked a pop-up adveliisement.
Minutes after clicking the advertisement, she received a call from a recruiter named Lynette.
Ms. White went to MedVance to meet Lynette personally and told her that she was unemployed
but had a strong secretarial and office background and was excited about possibly entering the
medical field. Lynette responded that the billing and coding fields were in high demand and paid
about $40,000 annually. Lynette indicated that MedVance was accredited and well-respected in
the South Florida medical community. Despite the initial interest, Ms. White skipped orientation
because she did not feel that she could afford the program. Lynette called her to tell her that she
did not see her at orientation, convincing Ms. White to come back. She was unable to pay the
$25 enrollment fee, so a MedVance employee gave her some junk and told her to have a yard
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sale, which she did. The financial aid depattment quickly processed the loan paperwork and Ms.
White began classes. She found courses on terminology and biology somewhat helpful but
found several instructors to be under-qualified. The teacher responsible for the "coding" course,
probably the most important course for the CPC exam, was not licensed, and the information he
provided frequently conflicted with the authoritative text. Her unpaid externship was "not so
bad" and she was allowed to do some billing work.
82. Ms. White was one of the few students in her class who passed the CPC
examination following graduation. This was done with diligent study in solitude and had little to
do with MedVance's instruction. Despite Lynette's promises and Ms White's passage of the
exam, she has encountered difficulties finding suitable employment. She is earning $10 as a
temp worker doing insurance verification. She is looking for a more secure job, and
MedVance's Career Services Office only set her up with one interview and has not otherwise
meaningfully assisted Ms. White with her resume and job search. For a short time, she worked
at MedVance and found the staff to be amiable, but grossly stressed and overworked. She has
found from working in the industry that someone with MedVance on their resume is at a major
disadvantage in the job market. She also has found that there is not a large enough demand for
medical office workers in the Stuart area to accommodate for the scores of graduates coming out
of MedVance's large Stuart campus. She feels that she was told numerous lies, up front, to
entice her to emoll.
Louisanne Saint-Vii
83. Louisanne Saint-Vii was emolled in the Pharmacy Technician night program at
MedVance's Ft. Lauderdale campus from 2008 to 2009. She incu1'1'ed about $11,000 in federal
loan debt to pay for the program. She graduated with about a 3.5 GPA. She heard about
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MedVance because her sister attended and she wanted to increase her earning potential and enter
the medical field. A recruiter told her that MedVance would find her a job and help her pass a
licensing test required for jobs in the field. She had to take a fifteen minute entrance
examination to qualify and did not think that she did very well, but she was told that she passed.
After taking that test, she was told to attend orientation. She recalls that the process happened
very quickly: during orientation, a financial aid employee processed her federal loan paperwork
and the very next day, classes started. The financial aid employee did not allow Ms. Saint-Vii to
read her FAFSA, telling her that it was too long to read and to "just sign it." When Ms. Saint-Vii
remarked at the high cost of the program, financial aid told her to not worry because there was a
six month grace period between graduation and loan repayment and that securing employment
was a virtual certainty. She found that classes were taught by unqualified teachers and that the
school enviromnent was chaotic. At one point, she tried dropping out but administration
aggressively pressured her to finish, which she did. She was placed at an externship with Florida
Medical Center, a hospital near the school. She liked her externship and asked her boss if they
were hiring; he responded that they did not need anyone. Florida Medical Center services
hundreds of patients, employs many in the medical field, is always hiring, and her supervisor's
response is a reflection of MedVance's inability, or unwillingness, to prepare its students for
entry into the medical field.
84. MedVance's Career Services Office did almost nothing to help Ms. Sant-Vil find
ajob. She dropped off her resume at their request, but nobody from MedVance ever followed up
with her. They did not set her up with any interviews. They did not send her any job listings.
To prepare for the certification exam for pharmacy technicians, MedVance simply gave her a
book and told her to read it. Ms. Saint-Vii has remarked that, "once they have your money, they
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are done with you." She feels that she has been lied to concerning the quality of education and
the school's ability to connect its graduates with potential employers. She is currently working
at a hotel at $9 an hour but is still interested in one day finding a job in the medical field.
Jordana Soler
85. Jordana Soler was emolled in the Medical Lab Technician program at
MedVance's Ft. Lauderdale campus from January 2009 to December 2010. To pay for this two
year program which costs about $25,000, Ms. Soler incurred federal loan debt of about $13,000
and received Pell Grants totaling about $12,000. She completed the coursework with a 3.85
GPA but MedVance has not allowed her to graduate, maintaining that because she moved to
Stuart, she has "withdrawn" from the program. Before moving to Stuart, Ms. Soler confirmed
with Ft. Lauderdale MedVance externship employees that the move would not cause any
complications with graduation. Ms. Townsell found MedVance on the internet, was attracted to
the idea of entering the medical field and enhancing her earning potential, and set up an
appointment with recruiter Sandra Gabriel. Although Ms. Soler was initially interested in
emolling in the radiology program, she was talked into Medical Lab Tech, which upon
information and belief was newer and more expensive. Ms. Gabriel promised that jobs in the
field were in high demand and that she could expect to earn at least $40,000 after graduation.
After paying a $25 fee, Ms. Soler was permitted to speak with financial aid. This was done
hastily and she was not given an opportunity to review the accuracy of the loan application. Ms.
Soler has stated that the classes were "horrible." The teachers were likely on drugs or suffering
from severe cognitive dysfunctions. There was no lab. There was also no lab equipment for the
lab tech students. The closest thing to hands-on learning occurred when the students drew each
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others' blood, in a classroom. When Ms. Soler asked the school's director if it indeed was
accredited, he responded that the school was, but the program was not, information that would
have been useful during recruitment for a $25,000 program. In August 2009, Ms. Soler, along
with Co-Plaintiff April Townsell and several other students, signed and sent a petition to the
Department of Education. See Exhibit F. They attempted to notify the government, which did
not respond, that MedVance does not have a laboratory and that students were woefully
unqualified to enter the field as a result. The petition also raised skepticism regarding the
school's accreditation and turnover rates. It states, "We are investing time and money into this
program and for us to be cheated is unacceptable." See id.
86. Ms. Soler, as stated above, has struggled trying to graduate. She must complete
her externship credit, but it is MedVance's responsibility to find her an externship, which they
have failed to do. Ms. Soler has attempted to find herself an externship, to no avail. During this
delay, Ms. Soler has been unable to meaningfully apply for jobs, since she cannot take the
certification test until she graduates, and she cannot graduate until after the externship. The
constant turnover in MedVance' s administration does not help resolve the matter-she counts
four directors of the school during her two years, and multiple externship coordinators. She has
had little contact with the Career Services Office, besides them telling her the false information
that "when you are interviewing for an externship, you are interviewing for a job." Again,
nobody can find her an externship, and the school is attempting to use her move to Stuart as an
excuse to not find one. See Exhibit G.
April Townsell
87. April Townsell was enrolled in the Medical Lab Technician program at
MedVance's Ft. Lauderdale campus from December 2008 to October 2010. To pay for the
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program, which costs about $25,000, she incurred federal loan debt of about $14,000 and Pell
Grants covered the remaining $11,000. Ms. Townsell saw the "from classroom to career in
under a year" television adveliisement, went to the campus, and expressed an interest in
ultrasound and radiology. The recruiter, Sandra Gabriel, told her that the Medical Lab
Technician Program fit her interest and stated that jobs in the field were in high demand. Ms.
Townsell was motivated to enter the program but expressed apprehension at the cost. Ms.
Gabriel responded that graduates have such a high eaming potential, that repayment would not
be difficult. The recruiter waived the $25 enrollment fee since Ms. Townsell was unable to pay
it. She has no recollection of ever reading or signing federal loan paperwork and thinks that loan
paperwork was completed solely by financial aid employees. She was hurried through the
process because classes started that same night, before orientation. Throughout her enrollment,
Ms. Townsell had trouble paying the monthly fee of about $50, and financial aid threatened, but
never did, expel her for non-payment. During classes, teachers were unqualified and "looked
drunk or drugged" most of the time. Proper study in the medical lab technician field necessarily
involves medical lab equipment and Ms. Townsell found that MedVance's facilities and
equipment were essentially non-existent. In August 2009, Ms. Townsell, along with Co-Plaintiff
Jordana Soler and several other students, signed and sent a petition to the Department of
Education. See Exhibit F. They attempted to notify the government, which did not respond, that
MedVance does not have a laboratory and that students were woefully unqualified to enter the
field as a result. The petition also raised skepticism regarding the school's accreditation and
turnover rates. It states, "We are investing time and money into this program and for us to be
cheated is unacceptable." See id.
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88. In November 2010, Ms. Townsell was told that MedVance is not allowing her to
graduate because she did not complete "externship one," a program requirement. Ms. Townsell,
in actuality, did complete this externship, and signed her name on the externship sign- up sheet.
Ms. Townsell believes this is a ruse to force her to take out more federal loans to complete the
externship phase, which involves her working for no pay and limited expenditure by MedVance.
MedVance refuses to admit they lost the sign in sheets and refuses to communicate with Ms.
Townsell in writing regarding this matter. She never had any relationship with the Career
Services Office, which has never found a suitable position, 01' even ajob interview for her. Ms.
Townsell is primarily disappointed with misrepresentations concerning the quality of education
and facilities, and employability and help with securing a job.
COUNT I - Breach of Contract (against MedVance Defendants only)
89. Plaintiffs incorporate paragraphs 1 - 88.
90. The Plaintiffs entered into a binding contract with MedVance. MedVance's
literature assures that students "have made a commitment to us and to their future and we in turn,
have a commitment to help them realize it." In statements by recruiters and literature provided,
MedVance offered Plaintiffs a quality education that would, at a minimum, give a realistic
chance of employment after graduation. Plaintiffs accepted this offer, with consideration in the
form of incurring thousands of dollars of federal-backed student loans, and the expenditure of
time and effort.
91. Plaintiffs fully performed their obligations under the agreement by paying tuition
and making a good faith effort to attend classes, externship placements, and pursue available
employment avenues.
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92. Defendants breached the education contract by failing to provide a quality
education in the fields of Medical Coding 01' Billing and Medical Office Administration.
MedVance fell woefully short of making good on their many oral and written promises that good
jobs were attainable after earning a MedVance degree. For example, students in the Medical
Coding and Billing program were told that a MedVance education would prepare them for the
CPC exam. It did not. MedVance also breached the agreement by failing to connect Plaintiffs
with area employers.
93. Plaintiffs were damaged as a result of Defendants' breach of the agreement in the
form of being burdened with heavy loan debt without learning necessary skills, forging impoltant
contacts, 01' obtaining jobs with area employers. They are entitled to expectation damages,
which include both incidental and consequential damages for Defendants' breach.
COUNT II - Breach of Good Faith and Fair Dealing (against McdVance Defendants only)
95. As an educational institution entering into contracts with its students whereby
students give money and the institution gives education and a path to employment, a fiduciary
relationship was created between Plaintiffs and MedVance. In every contract, there is an implied
covenant of good faith and fairdealing.
96. MedVance was obligated to not take action which would deprive Plaintiffs of
their benefits arising from the contract and had to, in good faith, execute its contractual duties.
97. MedVance breached their duties by baiting students to enter into the education
contract by using deceptive recruiting practices. For example, recruiters told Plaintiffs that loans
would be easy to repay since jobs were in high demand and that MedVance provided the tools
and connections necessary to surely secure employment.
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98. MedVance also breached their duties by offering classes and placing Plaintiffs in
externships that did not fUlther professional development in various medical fields.
99. Plaintiffs have been damaged by MedVance's breach of duties arising from the
contract. They owe Plaintiffs damages proximately resulting from this breach.
COUNT III - Fraud in the Inducement (against MedVance Defendants only)
100. Plaintiffs incorporate paragraphs 1- 88.
101. MedVance's recruiters and financial aid personnel made numerous
misrepresentations of material fact to Plaintiffs in order to procure enrollment and become the
recipient of federal-backed loans. For example, they informed Plaintiffs that they would obtain
employment upon graduation and that because of this employment, loans would easily be paid
off.
102. Specifically, Plaintiff Best was told that she could easily find a full time job with
benefits upon graduation. When expressing uncertainty about taking out a loan, she was told,
"we are sure that you will find ajob, the field is in demand, so do not worry about it."
103. Plaintiff Exantus was falsely promised employment contacts during her education
and job opportunities after her education by MedVance recruiters.
104. Plaintiff Medina was assured by recruiter Norma Jimenez that she would
definitely get a job as a medical office manager nearby upon graduation. She was told by
financial aid personnel to take out a loan because "you will not have to worry about it until after
graduation, when you have ajob."
105. Plaintiff Dolecki was recruited by MedVance's Tamara Stephens, who promised
her that the program was perfect for middle-aged individuals, that she could work patt time from
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home after graduation, that jobs in the field were in demand, and that MedVance would prepare
her for the Certified Professional Coder (CPC) examination.
106. Plaintiff Meyer was promised by MedVance recruiter Tamara Stephens that a job
paying approximately $50,000 a year was awaiting after graduation. Ms. Stephens told Ms.
Meyer that passage of the exam would be a virtual celiainty after a MedVance education.
Financial aid personnel told Ms. Meyer that it would be "easy" to payoff loan debt.
107. Plaintiff O'Neill was told by a recruiter that most graduates acquire a job paying
about $30,000 a year after graduation. The recruiter told Ms. O'Neill MedVance success stories
about graduates attaining high-paying jobs and promotions with the opportunity to travel.
108. The GAO cited MedVance on August 4, 2010 for "encouraging fraudulent
practices" and for making "deceptive or otherwise questionable statements."
109. MedVance personnel knew, or should have known, the falsity of these statements.
Through their difficulties placing students at worthwhile externships, awareness of loan default
rates, and operation of a marginally effective Career Services Office, MedVance knew that their
representations were false.
110. MedVance intended that their false representations would induce Plaintiffs to rely
and act. MedVance intended to, and achieved their goal of, having Plaintiffs fill out loan
papelwork and incur substantial debt in order to emoll and attend classes.
111. Plaintiffs, through expenditures of time and money, suffered injury in justifiable
reliance on MedVance's false representations.
COUNT IV - Fraudulent Misrepresentation (against MedVance Defendants only)
112. Plaintiffs incorporate paragraphs I - 88.
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113 . Various Plaintiffs were enrolled in programs requiring them to complete an offsite
externship in order to graduate and sit for the certification exam.
ll4. In order to keep these Plaintiffs enrolled, MedVance made false statements that
they would get on-the-job training, forge impOliant employment contacts, and would learn more
about the field through hands-on experience via the externship program.
115. Defendants, unable to place so many students at worthwhile externships or find
eventual employment for its students, knew that these statements were false when they were
made.
116. MedVance recruiters and financial aid personnel made various misrepresentations
to induce enrollment concerning: the extent and effect of accreditation; the ability to transfer
credits to other schools; the quality of education, facilities and equipment; the availability,
frequency and appropriateness of MedVance's courses and programs to the employment
objectives that it stated its programs were designed to meet; the nature, age and availability of
training devices and equipment and their appropriateness to the employment objectives that
MedVance stated its programs and courses were designed to meet; the number, availability and
qualifications, including the training and experience, of its faculty and other personnel; the
nature and availability of career services and career guidance; and employment statistics and
examination passage statistics for recent MedVance graduates.
117. These misrepresentations were made with the intent to induce Plaintiffs to act, in
the form of making payments to MedVance and incuning loan debt, staying enrolled and being
responsible for payment of tuition.
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118. Aside from generally being unable to find jobs, Plaintiffs were damaged by their
reliance on these misrepresentations by attending MedVance. Plaintiffs also incuned loan debt
in reliance on these misrepresentations.
COUNT V - Misleading Advertising (against MedVance Defendants only)
119. Plaintiffs incorporate paragraphs 1- 88.
120. According to Fla. Stat. § 817.41, which provides for a private cause of action,
misleading advertising is prohibited. Misleading advertising is defined at Fla. Stat. § 817.40(5).2
121. To further their sale of services and to encourage students to enroll, MedVance
advertised, both in print and with the use of recruiters. Brochures suggest that MedVance
graduates "will be able to seek entry-level positions in healthcare facilities ... With strong skills
sets in office technology, office management and customer service, the graduate will possess the
knowledge and be positioned to work within the team dynamic required in healthcare
administration today." See Exhibit B. More directly, recruiters told Plaintiffs that securing solid
jobs after graduation was a virtual certainty. Financial aid employees told Plaintiffs that paying
back student loans would be easy. After all, they would eventually be gainfully employed
according to MedVance personnel. These statements, as well as other representations by
MedVance discussed herein, are known, or through the exercise of reasonable care or
investigation could or might have been ascertained, to be untrue or misleading.
2
"The phrase 'misleading advertising' includes any statements made, or disseminated, in
oral, written, or printed form or otherwise, to or before the public, or any portion thereof, which
are known, or though the exercise of reasonable care or investigation could or might have been
asceliained, to be untrue or misleading, and which are or were so made or disseminated with the
intent or purpose, either directly or indirectly, of selling or disposing of real or personal propeliy,
services of any nature whatever, professional or otherwise, or to induce the public to enter into
any obligation relating to such propeliy or services."
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122. These statements were made for the purpose of selling services, namely,
educational services.
123. Plaintiffs relied on these false statements and adveltising strategies to their
detriment, by incurring loan debt and attending classes and externships that were, in effect,
wOlihless.
124. Defendant's false advertising practices were the proximate case of Plaintiffs'
injuries; were it not for MedVance's assurances and adveliisements, Plaintiffs would not have
emolled. In other words, had MedVance truthfully communicated Plaintiff's tme job prospects
and the actual implications of applying for hefty federal loans, Plaintiffs would not have emolled
at MedVance.
COUNT VI - Unfair or Deceptive Trade Practices (against MedVancc Defendants only)
126. Fla. Stat. § 501.204 provides for a private cause of action for those harmed by
"[u]nfair methods of competition, unconscionable acts or practices, and unfair or deceptive acts
or practices in the conduct of any trade or commerce .... "
127. MedVance, a for-profit private college, is engaged in the trade and commerce of
emolling students and collecting tuition payments.
128. Student recruitment is a vital aspect of MedVance's form of trade and commerce,
and their methods of recruitment are deceptive and unfair. The experiences of the individual
Plaintiffs have been confirmed by reports from govermnent and media. See Exhibit A.
Essentially, MedVance promised results that they knew were not fOlihcoming in order to make
money at Plaintiffs' expense.
48
SARELSON LAW FIRM, P,A., 1200 Brickell Avenue, Suite 1440, Miami, Florida 33131, 305-379-0.105, 800-421-9954 (f.'lx)
www.I·!oridaConsumerLawycrBlog.com
www.Sarelson.com
129. MedVance's unfair and deceptive trade practices caused Plaintiffs to enroll, incur
federal loan debt, expend time and effort, and not pursue other oPPOliunities.
130. Plaintiffs suffered damages as a result of MedVance's unfair and deceptive trade
practices. All Plaintiffs have had no success securing employment in their respective fields and
are currently burdened with crippling student loan debt.
COUNT VII - Rescission (against Sallie Mae, Inc. only)
132. As a servicer of student loans and beneficimy of loans provided at MedVance,
Sallie Mae uses MedVance employees as its agents. Without MedVance employees acting in
this capacity, Sallie Mae would never have entered into loan contracts with Plaintiffs.
133. Sallie Mae is at least constructively aware of recruitment, financial aid and
enrollment practices at MedVance, yet continues to enter into loan agreements with MedVance
students.
134. Plaintiffs entered into loan agreements with Sallie Mae at MedVance campuses to
pay for their MedVance education. Plaintiffs are borrowers and Sallie Mae is a lender.
135. The borrower-lender relationships were entered into as a result of false
representations by Sallie Mae's agents. For example, they informed Plaintiffs that they would
receive an accredited, quality education administered by an experienced and knowledgeable
faculty. They told Plaintiffs they would obtain employment upon graduation and that because of
this employment, loans would easily be paid off.
136. The borrower-lender relationships were entered into as a result of fraud on the
government by Sallie Mae's agents. These agents, presenting themselves as experts of federal
student aid regulations, instructed several Plaintiffs to lie on their FAFSAs. For example, Ms.
49
SARELSON LAW FIRM, P.A., 1200 Brickell Ayenue, Suite 1440, Miami, Florida 33131, 305-379-0305, 800-421-9954 (f.1X)
www.Sarclson.com
Meyer was instructed to overstate her dependents. Ms. Caudy-Richardson was told to use her
husband's tax return, which made her a more attractive loan candidate.
13 7. The Plaintiffs seek rescission and notify Sallie Mae, Inc. of rescission.
138. It is impossible and impracticable for Plaintiffs to restore the benefits of the
contract, if any, to the party furnishing those benefits. This would involve giving a worthless
education to a large financial institution.
139. Plaintiffs have no adequate remedy at law. Even if Plaintiffs secure certain
compensatory damages from the MedVance Defendants, they will still be Sallie Mae's
borrowers, subject to Sallie Mae's interest rates. The only way that Plaintiffs can truly be made
whole is through rescission of their loan agreements.
Demand fOJ' Jury Trial
Plaintiffs demand a trial by jury on all issues so triable.
Prayer for Relief
Plaintiffs pray that this Court enter judgment in their favor against Education Affiliates
Inc., and KIMC Investments, Inc., (both d/b/a MedVance Institute) and Sallie Mae, Inc., and
award Plaintiffs:
A. Compensatory damages equal to the amount of money paid in tuition;
B. Compensatory damages equal to the amount of interest and fees paid or payable to
Plaintiffs' student loan lenders;
C. Rescission of all loan agreements entered into as a result of Defendants' fraud;
D. Injunctive relief;
E. Attorneys' fees where applicable by statute;
F. Pre- and post-judgment interest;
50
SARELSON LAW I'Illi\I, P.i\., 1200 Brickell Aycouc, Suite 1440, Miami, Florida 33131, 305-379-0305, 800-421-9954 (fax)
ww\".FloridaConsumerL.1.w)'erBlog.com
www.Sarelson.com
G. Costs;
H. All other relief, both in law and in equity, this Comi deems appropriate.
Sat'elson, Esq.
Fla. Bar No. 888281
Max M. Nelson, Esq.
Fla. Bar No. 84532
SARELSON LAW FIRM, P.A.
1401 Brickell Avenue, Suite 510
Miami, Florida 33131
305-379-0305
800-421-9954 (fax)
msarelson@sarelson.com
mnelson@sarelson.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy was furnished via facsimile and U.S.
mail this Ilday of January, 2011, to John S. Lord, Jr., Foley & Lardner, LLP, 111 N. Orange
Ave., Suite 1800, Orlando, Florida, 32801-2386, (407) 648-1743 (fax); and Robert Lavet,
Powers, Pyles, Sutter & Verville, PC, 1501 M Street NW, i h Floor, Washington, DC 20005,
(202) 785-1756 (fax).
Matthew Seth Sarelson, Esq.
51
SARELSON LAW FIRM, P,A., 1200 Brickell Avenue. Suite 1440, Miami, Florida 33131, 30S~379-0305, 800-421-9954 (fax)
www.I·loridaConsumcrLawyerBlog.com
w\vw.Sarclson.com
GAO: 15 for-profit colleges used deceptive recruiting tactics Page I of2
GAO: 15 for-profit colleges used deceptive

..E~~X~mn9_!~.~!~~~,_..._. __"......_,.._. _. __.__.........._. . __..__.____ .__.__...._..___._ .....,...._
Washington Post Staff Writer Texas. Kaplan, Everest and Phoenix each were
1Jy Daniel de Vise and Paul K£me cited twice, for different campuses.
Thursday, August 5, 2010
Congressional officials on Wednesday Four of the colleges -- Westech, MedVance,
identified 15 for-profit coileges where Anthem and Westwood -- "encouraged
recruiters allegedly encouraged investigators fraudulent practices" in meetIngs with
posing as prospective students to commit undercover investigators, the report says. All
fraud on fmancial aid applications or misled 15 "made deceptive or otherwise questionable
them about such matters as tuition costs and statements." B,
potential salaries after graduation.
At a morning Senate hearing, some of the ~
The Govermnent Accountability Office's findi- most powerful revelations came in a brief vid· Ii
ngs, presented to a congressional committee eo presentation, spliced together from
"~
along with grainy video clips captured by
hidden cameras, may amplifY federal
bidden-camera feeds. !
.i
scrutiny of the fastest-growing higher- Attendees watched as a MedVance 1
I
education sector. admissions officer told an applicant he !,
needn't worry about loading up student debt:
Many of the largest for-profit entities were "It's not like a car note -- if you don't pay it,
named among the 15 sites targeted by GAO they won't come after you."
investigators: University of Phoenix, with
more than 400,000 students; Argosy A Texas admissions officer tells an applicant
University, part of the 136,OOO-student
Education Management Corp.; Kaplan College, :1
j
part of the 119,OOO-student Kaplan Higher 1
;
Education operation owned by The We focus on 1
.j
Washington Post Co.; and Everest College, automating
part of the 110,OOO-student Corinthian Marrlott@Hotels' 1
Colleges. global Invoice l
process. -So they
Also named: Westech College in California, don't have to.
Bennett Career Institute and Potomac College 1
in the District, MedVance Institute in Florida, Learn more at
College of Office Technology in Illinois, RealBuslness.com
Anthem Institute in Pennsylvania, and
Westwood College and AT! Career Training in xerox.€>'
;
....___ ._...__ ..... _...~!~'.'~~':~h.'".~!~.~~...t~~~~~I?~~~!2010~~~~~~201~~~~!~?:h.~m.t...,~ ___ .__._.__..__.

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http://www.washingtonpost.com/wp-dynlcontenllarticlel2010/08/04/AR20 10080403 816.... 10112/2010

..
GAO: 15 for-profit colleges used deceptive recruiting tactics Page 2 of2
GAO: 15 for-profit colleges used deceptive

. X~~r..~!ti.t:'_g_ t~£~l~~_. _..___._. _...._. _...___. ___....._.. ___.._....._.....___._....__..___. _...._.
not to report his savings on a loan
application; "They don't need to know how
much cash you have."
And a Florida recruiter quips to a reluctant

applicant, "What are you really afraid of'l"
and then rips up his application.
Leaders of industry giants Phoenix, Kaplan

and Corinthian all announced internal
investigations in response to the fmdings.
In ajoint statement, Donald E. Graham,

chainnan and chief executive of The W
ashington Post Co., and Andrew S. Rosen,
chainnan and chief executive of Kaplan Inc.,
described the tactics revealed in the
videotaped interviews as "sickening. n
"They violate in every way the principles on

which Kaplan is run," they said in a j
statement posted on The Washington Post
Co.'s Web site. "The. GAO and the Senate !
o}
[Health, Education, Labor and Pensions
.i
Committee] have done us a favor. We will do ;
everything in our power to eliminate such ;l
conduct from Kaplan's education ~ .,
We focus on 1
institutions." automating 11 j
l :1
MalTl ott<l> Hotels' j I
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global Invoice
process. So tlley Il :~
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http://www.washingtonpost.comlwp-dyn/contentlarticlel2010f08/04/AR20 10080403816.... IOfl2/20 10
I
For-Profit Colleges Seeking Loans 'Rob' Students, Senate Testimony to Say - Bloomberg Page I of4
I
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Search Quote& and News
Bloomberg An""'" Login
•
ROfil!td Nh't,; U.s. MOI'f:$tories
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u,s. Sloc);$ f'allAmld earnIngs CCrlCern: u.s.

For-Profit Colleges Seeking Loans 'Rob' Sleel "mlbf~. Up<IalGd 61111rofAu '90
Students, Senate Testimony to Say Vl<:cfn(J Maker$ GotMfKtd fUc.ptioo From U.s.
ByJI)br111IJ!M\an. S~J)30,2010 1O;COAM flT Jl,lllle.s OVir InJuryuW6uUs
\lpool6d 1 millllUAQO
Prim
Fed Omofals Were Prepared to 1!4$9 ·a.rurt
Long,' MInutes Say
For-profit colleges leave students with high debt and inadequate edtlca.tionsthat can harm ll1em Updlltd 12 rnlw\l;$ ~go
for years after they graduate or quit school, witne.ne.8 are-scheduled to te.6tify todllj" at a Senate
hearing In Washington. St<Jeks Deellne on Con~m About Ohlna,
Earnings UpCaied 19m'.nlll$ugo
Recruiter., enticed DanieUeJobnson, a mother from Iowa, to enron In Washington Post CO.'s
Kaplan education unit, saying she could train at home to bea nurse, a claim -that turned. out to be
untrue, sho.sald in testimony prepared for today's Senate Hccl.th, Education, La'oor Be Peosions
COmmilteehearlng. Kaplanrefused to release her transcripts, preventing her from transferring j
\
into a cheaper oomrnunlty college, she said.
While worlUngstudents must have access to programs thatflttheir .8Medules and training
requirements, tiler also need proteciJon from the predatory recruiting programs andlending
fraud uncovered bra government probe of education companies, said Arnold Mitchem,
president of the Counell for Oppartuntty in Education, in prepared C()tntnents for the hearing.
UA.ecesfI is critical, but aeces.s to what?" M!tchem said In tho prepared testimollY, "Mountains of
i
debt?" !
For-profit colleges represent about 12 percent oru.s. conege students. according: to the
ii
Association of PrivaleSecror Colleges and Universities, a Washington-hasedindusUy ,group ;i
formerly called too Career CoUegtAssoclation. Those students aceount for about aquarter of
U,S. student loan dollars, said l.auren Asher, president of the Institute (or Collcgo Access and ,~,
d
Success. an adVocacy group based in Oakland, California, In Cllmments prepared (ortha hearing. $
'Ssvere' Consequences
~
l
Gr&e!'1,pan Say.!. U,S,
Pi3Ji'lg 'OangSfOUl O!1m&'
~
About 43 percent of all former students who defaulted by 2010 on loans they began paying offin onSllm_ j
2008 were from for-profit colleges, Asher said. Tbe Cllusequenoos of those defaults are "severe :J
and long-lasting," shesaid in ber remarks. j
j
"You will likely be hounded by collectors, andyt;t1,lrdebt wnt increase significantly beuuse of ~.. '~;;i~~ .
default and eolleetiou fees," Aah~r saidJn her prepared comments. "You cannot g8tfederal
grants or loans to retum to school, and the debt can follow you untilrou die. There is no statute
oflimJtationsl and thegovemmentcan garnish yourwagcs, seize your tax refunds, and
eventually take aaUce o!your Soclal Security check."
For-profit colleges have helped Im}:lrove the lives oftnanystudents who earlier failed at
1l{" 'b,'.' ,j .
~ron ln~rMW £Xttlplon
Quant/{Qlive Easing. sn:1!V{
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traditional, nonprofit universities, said Harris Mmor, president and chief executive officer of the
U.S, EUI~ MIa 1
fOl'oprofit ooUeges' trade group. 1
'Aneooote Game'
DOW 11047.90 +37.67 (O.34V.)
i
http://www.bloomberg.com/news/20 10-09-30/for-profit·colleges-seeking-Ioans-rob-stude... 10/12/2010 ,
For-Profit Colleges Seeking Loans 'Rob' Students, Senate Testimony to Say - Bloomberg
"We canan playtbe IUlccdote game,n Miller said in a telephone lntervfewbefore:the hoating
began. "We have plenty of students who would be glad tote11 ilie committee how our schools
have turned their lives around,-
S&P 500
NASDAQ
1171.94
2420.79
Page2of4
+6,62 (0.57%)
+18.48 (0.71%)
I
Stoe!<G on the Move
About l~oostudents, teathert and adminiBtratota rallied in front of the u,s. Capitol building
yesterday to oppose proposed industl)" regulations that would (orce for-profit colleges to show Most Popular StorIes
that graduates Me ~paying their loans and make enoUgh to afford repayment. Stocks Deellne on Concern Ab1)ut China,
I!!.amlng. Up4~1ed 17 nWIuItl *
"All Stale does a gt'eatjob of preparing you to present yourself for aJob,It said8ru:ah Martin, 22, a
Marc PaberSaysWorid Heading for'Maj«
student at All State Cateer Scbool in Baltimore who rode to Wasblngton on one ofsix buses the
Innecuon PoInt'
collegesentto the rally.
Oblrnll. losing suppott.r~ in Pol as Jobleuntu
"It's upto you to take advantage althe situation,· Marlin .said. Ptompto Vot..-s' Dileonlllnt
For-profit colleges bave COme under fire sinee a. govemmentreport released Aug. 4 found that Republicans PM' Unpopular With Voter..
Agil1nlt.Obama.)n poll
reCl'uiteu at l5 colleges mlsledstudcnts to boost enrollment. Senator'fom Harkln, the Iowa
Democratwho heads the education oonuniltee, said he plans to hQldanother hearing the ilrst More Moll Poj>Ut¥Stoon.
week in Oerember. Harkin said he wilt release in(onnatloD at today's hearing collected from
w-ucatiOll companies,
No Degree
"'1110 companIes get the profits, and thcstudents get tbe debt," Haikin saldln a telephone r~~-;iL~j,,~·~··-----·---·~-··~~-··_·-_··n. __.__,
Interview before the hearing. j'And many tfmes they don't even get a degree."
Deceptive marketing has hurt low-fncome, minority students across the V.S" Mitchem said in
I,L. Cordo" B)'c\f.Qr).ndo
CulInary Arts C ego·Flnanclal ASd
I !
his prepazed testimony. Mitchem's group submitted a Usf. of stories fromstudcnts who said they
! Programs, Regla:ter Now &Swrt 11/8 f
~~.~flI!I~«lM I
had been misled by recruiters and admirustrators.
D'angelo Walker, a Curmer student at Hoffman Estates, lllinols·based Career Education Corp.'s
Sanford-Brown College whose stOlY was included In the submission, saldhis degree failed to
belp himget ajOO, andolher coUegeswon't accept the credits he earned. Coca.Cola Scholars II
We're p!ll!llonate about education. Learn
about Coca-CoJa scholarshlps. !
Starting Over I lhtPWi'tMtt.wnrJcWIJ I
-I feel1ike I've been robbed,b Walker said in the testimony. "Every scbool1stelling me that I will !_______. . __.___ ._~._._. .,. ~~.~_~.~~_i
bave to start over."
Ahnost halfofthe students at fot·proflt colleges are minorities and abouttwo.thirds of the .J
schools' 5tudents llaV6 incomes below the median for all undergraduates, Asher said.l1lese
students are three times as likely to borrow to pay far tbelr education as those attending §
{
1
nonprofit colleges. Asher said.
,
n
)
"The data clearly show that across levels of Income and categories of race/ethnicity, for--profit l
college students borrow more than those who attend cWowhcre," she said ill her testimony,
i
Kathleen A. Bittel. who works in Education Management Corp.'s Art rnstitute ofl1ttsburgh
online division, also is scheduled to tesUfy at the hearing. 'I1te company assembled dooeptive
. _-i
career~p1a.cement data by counting enby·leveljobs atTays "Rb Us, Starbucks and a convenience
store as related to students' degrees, Bittel said in a letter to CQngres.s: obtained by Bloomberg
News. The oompllnyinvestigated lJittel's claims and determined they were unfounded,
Education Matlagementsald yesterday in a statement.
Education Secxetary Arne Duncru\ saidln August that he will beefup hIs department's
enforcement arm to help stamp out predatory recruitment practices. The Education Department
Is preparing to publish rulesthat~trengthen sanctions for recruiters who mislead applicants,
and require (or-prof'lt colleges to tell students how many students graduate and get plaood In
jobs.
http://www.bloomberg.comlnews/2010~09-30/for-profit-colleges-seeking-loans-rob-stude... 10/12/2010
I
I
I
For-Profit Colleges Seeking Loans 'Rob' Students, Senate Testimony to Say - Bloomberg Page 3 of4
To contact: the reporter on this story: John Laucrmim in Boston atjlauenmm@bloom'btrg.net.
To contact theedltors responsible for this story: Jonathan Kaufman at

jkaufman17@bloomoorg.l1et.
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2009·MedVinoo Institute Overview' Palm Sprlng.·Campu.
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,A Vision For The Future' ~

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A, Comml(ment To Excellence II
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MedVarlC<j Insfltute is dedicated'to preparl~g'<iuaUfied candidates for.careers in fue medical field and has been doil,lg
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. ;': .. , ' '.., '. so for decades, " '.' . "
, ... ,ichieV9'your'educatlo~a! g\)als in '~,supppI!ive environment

i"g
. • Clioose,{rom a :variety of medica! trainiftg programs .,, ;~
l'
, . • Complet~ your medical career iraltiing in 7 to 24 months , "~
, • Enjoy the <;<>ilvenience of day, afiel1)oon,. and eve~1i1g'Class sche<jules II
. , • Expcdence the benont of sinaIl ~lasses and hands-on IMming ,t!
P.
.',Galn v~luable real world experience through cxte(DShips .'

• 'Lenr~ from qualified instructors who are highly trained ~rOfeSsionals ,
Gr~duates,'York in a variety of medicarsettings incluping hospitals, laboratorie;, physicians' ofti~es: long-tenn !-"'te R
. faclUt.ies; home'health care .businesses, rac!lology and.surgical.centers, can!",r treatment facilities;insurance , ;:
. . companies, and other'medical bUsinesses, ' '
"
MedVance Institute has campuSes in many states 'offering Certificate, Diploma, O~cupational Associate Deie-,
. " A~sociate In Occupational Shldies, an~ Assooiate ofApplied science Degree Pr?grams .
Our Purpose: Innovativeiy:Creating Opportunities. ~.

, IT'S PERSONAL'
. ,
At MedVance Jnstih,\e, INNOV A'fIOl'i'is the .key to' our succeSs, What we do, healthcare ca~eer trai~ing, is highly,
. regulated and standardized throughout our· industry. However, how we do What we do is up to us. What does that
mean? It means We have the ability to create an experience that is extraordinary and will keep our'customers talking
, about uS long after graduntion. Innovation is. key to unlocking that extraordinary exp,erience. innovation means
,tbinking differently abo;,t something f;uuiliar. It's about going beyond tbe ordinary and creating somethin$ be.tter.
C~A'rlNG OPPORTUNITIES is our ~re p~rpose, Every day we create' opportunities for our customers, our
communiti.es.and o~selves, Opportunities can fake ,many foim,s, Just,remember.!hat for ev~ry' obstacle .. ,there is an
. opp.0rtuniti wa,itil'g to be discovered. .. .
.' .
IT'S PERSONAL describe~ how we fulfil.l Qur pu;Pose. We are accpuntable fat ensuring Qur .custo",«s receiVe a
pe~son.l, friendly and ~upportiye,educatlonal experience: We do not want them to f~ellikejust another number,
They have made a commitment to u,~ at;ld to their future and we in turn, have a'Commitment to help 'them realize it,
. ,IT'S PERSONAL als\) serves a ~u~l ~!"P0se and is an ~cronyl\l for our values.
Www.ri1edvance,edu
This-.;:atalog was prepared by M;dVanee Institute. CurrlculuM,tuition, rCeS.,·cxpcnse$, aca.demic rcqplren1<!nts, elc. arc subject to ch~ngo at Ih((discrClion o'flllQ
Sch~l. fllformation tontah)oo itt Ihis catalog: is troe.andaccUtalO to the best koowlcdge.orth9. School~s Administcnltoll. . .
Overview Palm Spr!ngs 49C 200.9 M~~ance·[/lStitute. AU rights reserved.
2009 Aca~eln.tc Pr~.gtamS j'Palm Springs Campus
COordination
:Medical Office, OADIOO Keyboarding Skill Building & 2,0140
:Administration OAD140
10.Key . .
Desktop Publishing 6,0180
oi ' OADI50 Trans(iriptlon 5:~SO
9AD160 'Human Resources 6,~180,
TOTALS Qtr Cr~dit Hours' Clock 1I0urs ss,omo'
• denotes general
COURSE DESCRiPTIONS
AHC140 HcaUhcare Facilities &
'lIusIn... Infrastrllclure, ",0 QH
.In this co.urS6, student.s ~ill learn the' ethical expectations of aU
individuals working in healthcare Ngardless of their rote. Stud~nts
will deve10p· reaSOnable expectations of the range of client reactions
in thd sensitive heatthcare 'environment) as well as the appropriate
response level that hoaltheare workers reasonably display. Students '
ar~ "trained in healthcaro law rolated to pl'ltient information, HIPPA,'
safety,and C«?mpliance with appUcable locai,'COunty, state and federal
nlles and regUlations. This course inch\des instruction in Basic. First
Aid, iMi~ding ~loodbornelAirbome Pathogens, 40 'leclure .hours,
..PROGRMi OBJE<ITIVE ' Prerequisite: None. .
The .program is designed to provide stud~nts, with the', multi;
in
dimensional $kiU sets 'required to exccl administrative roles today. , MASlli3 Medical OfflceProcedures , 6,0 QlI
Students learn the basics of com.mUnications in healthcare which Students ~m lcam the prim!lry duties performed in th~ medical oft1?6
.include medical tenninology, cOmputers at\d praetica management. by' the medica1 manager .includ~rrg ,compiling Qffico policies and
. Students also learn to navigate, and manage, databases, client, proceq.urtS,· patient. registration. human resource t\mctions,
in'fonnation.' and the laws and ethics related to client data appOintment scheduling, pa1ient billing, medical insurance a.!ld basic
management. ·This COUTllb also provides· training to students, In coding. Students' will apply a p"rflctical approach to nn.delltanding
tra!,scriptioo. billing & coding, human resources, d~ktop publishing. tbese rnedica.l office' proc~ures. Students also learn the fundamental
records management and informatics, ,skills, in business principles. of computer technology inoluding compu1tr concepts.
communications, accouilling' and tbe crllical Importance of strong terminology ahd applications, 40 lecture hoursl40 laboratory hours,
, customer scn'ice. Prerequisite: None, '
Upop completion.:()f this program" graduates will be abU, to seek MCSlOS Introduotion to ICD-9 & CPT Coding 3,0 QH
entry. revel POSitiOllS in healthc8rc facilities or other lndustdes in an 'Students learn Ihe theory nnd practice ()( coding medical services,
administrat,ivo suppOrt capacity, working jn DCeM sllch as front office, supplies And equipment using the CPT manual. Students team the '
admissions; client 'relations, office revenue, unit coordination, technique for locaring frequently used tenus in' the manual index.
,healthcare services adminlstratlon and out-pntient faellittes offices. Students abo study'the lCD-9·CM systems and acquire nn overview i
With strong skill sets in office technology: ofnoo' mahagement, and of the use of ICD-9 coding. 20 iecnlre hoursl20 laboratory hO\lrs. :i
customer service, the graduulc will possess the knowledge and be Prerequisite: N!?ne,
positioned to work within the team dynamic required In h~lthcafe '
.
,1I
adminlstratloll today. ' . 'COMIOI Communications , 4"Q QH
Students w.iIl leain· the con«pts of adaptation and critical thinking in
verbal and wri~en «Immunlcation, Upon suooessful co~ptetjon of
thiS course, stUdents win demonst.rate confidence and credibility In
1
'communicating in a range rif communication situations. 40 lecture.
1
h~urs, Prerequisite: None.
OAD120 Computerized AC(Ountlng &

'
j,
Fiscal Management ., , 6 , 0 QH . ,1
This CO\lrse includes' an overview of basic mathematical skiUs
Including addition, subtraetion, RlultiplieatiOJ\, division, (mctions,
decimals, and solv,lng word pr~btef!ls.. Students' also .learn
foundational skills involving ml'ln'a.gement ~f money including
banldng,.lnterest, checkbook maintenance and rcconcjliation of bank
a.cqounts, Slmple procedures for accurately malnt!'tlnlng It petty cash
fund. as welt as costs and ordering office supplies are covered. 1
Students wilileam basic bookkeeping and accounting prinCiples in a.
fiscal,cycle using manual fonns, as well as (orm~tting & calculating
i
I
, "
2009 Aeademtc Programs· Palm Springs Campus
'MEDICAL B.ILLlNG,~ CO'DING Basio 1I1s\lttmce: Delinq\\ent

Claims, &. Collectiotls
4,01.40
k.diOlrigy:P~thology & Medicine 3.0/40

SPECIALIST COding' !
i':
"
~iploma Program MCSI21 A'OOsthest. Coding, Phaml,ey 3.0140 " {
C(ldhig & HCPCS ' 'i 5
MCS122 Bvaluatlon 8< Managemen' Coding 3.0140' ,"
8< ModlHers' "
MCSI·23 SUrgel)" C(lding 6.0180
MCSI24 Insurance Verification. Claim. ',3.Q/40
Denials 8< Appe,ls "
MCSI25 -Insurance R.egulations &, 3.0140
ModicareIMedlciid
MCS'175 lCI?-9 & fCD-to Coding 5,0(80
MeSI8S Computerized Praotice 3,0140,
Managcn]ent '
MCSl86 ' Hospitsl Billing 3.0140
MC;:S\88 Blectronic Medical Records 2,0140
MCS225 Modi",,1 Dilling & Coding 4,01128
Extemship
TOT,AL Qtr Credit llourslClockHours 69.0/1008
I I
PR,OGRAM OlUEC1WE ·DanOtes General Education course
,t The Medi~1 Billing'& COding SpllCl"list progmm prepare, .iudents " ,

to analyze medio'l recordo and assi,gn codes'to medi ..l conditions, ,COlfRSE DF..sCRIPTIO~S
dlagM~es and ptoc.edures usIng &. complex healtheare coding and " , '
I
" .
classification system. Accurate, COdes ace essentia1 for researcb, ACIU40 He.a~th~lu:e t:acutties &
statistical datB and for determining reimbursement of health ClU'e D~sln~slntrMtructure 4.0 QH
i! services. In this wurst; stude!)t::; will learn the c.tbicnl expectatioM of ttil'
I. il\dividuaJ~ working ~n h'ealthclU'~ regardless of th.ck role, Stodel\ts'
Sl\ld'tllts build knowledge O-l'Id skill in CPT (Common Procedural wil) dev~lo11 reasonable expe~taliollS of tbe nmge of cli~l1t rC3ctio~
!I" Terminology) and ICD~9 and rCO-tO (international Classification of in the s~llsiti\,1! hCl\hhcBN environment, as well tbe appropriate
Ii Diseases, 9Jh' & 10th Editions) coding' as well as commonly used
medical billing: and medical r~r(j sofiv!are syst~ms. A atrong
cC$pOl\se level that h~3ltt\l,.lDlV'\VO\'ker~ reasQIli\bly displl\Y~ Students
are trained III h~lthcG.re lnw relat«t 'to patient mfotn\ation,
" foundation in tbe biosc1ences, medical raw and ·ethics and career HJPPA-. safety and tOlnpli\\llCe with IlPplic-o.ble focal. COllllty. ;;tate'
Ii,
; ,
'
readinw provide 1l balanced education, prepatlng g.r4ctUa.tes to work
effectively in the. medioal. envIronment.
imd ('eden'll Iille~ ;\nd. rcg\1ta~i0113, Tllfs OOUNe
in$lruCtion in Bask.· first Aid including Bloodbome1Airbon\e
.Pathogens. 40 tcctU[\l hour.s, ,Prcrcquisit¢: Non¢.
itlCl\lde.s '.
; :
Graduates find elltrY-level emploYlnen!' opPol1l.initics in physic\sn;s
", offices, billing offices, h~spita.{s. assisted Hving facilities. cUnics, . AHC147 Professio"al Develoflme"t ' 4.0 QH
irl.sut'ance compani,es) medical Iillal\cial COnS\\Mllg prnctices and This wurse is (\n oriel\l(\tion to the world,of'work. 'Professional
p~iyate_practiee, Graduates are able to sit foY the AAPC (Americal'l hu:;incss ptot(.lcol. f!1."Qfe:;~ion;\1 presence: nnd u customer~ftrst l\ttllUdc
Acadeiny of 1'"roCassional Coders) and AllIMA (Amerio,n Health . are ~'Kplored,:\lld discussed. S,tutrel)(S l~u\1l to develop n stundard of
lnfotmatlon Management AssociatiQn) Pmfenlonal, Coder ,exec-lIellee and 'Jlridc in work and ,adDress, ~hics. tl\lst, 1'eSpect.
certification examinations. . :5hite~ic lhll\king, find leadef1l,hip. ' Students will 1\150 gain skUJs in.
time managemCJ")t, streSs 1l\anagemehl; gonl setting, cornmu\lic.mng,
PROGRA~ OUTLINE 'pre."elltitl!J. ideus nnd cOliqpts t\S' weU, tiS' thinking crittcal1y t\nd
oreatively. 2.5 lecture hours/55 '\aboi'atory l\otlIS. Prerequisite.: NOll,\:)
Course #,
AlICt40
Course'l'ltte
Health~are Fnoilitie:;.& '8\ISlneSS

In({ustHletme
Qtr Credltl
ClockHrs,
4,0140
AHC235 'Cateer nevelopment' , " ,
Students, team to propate for lhe job search incl\lding resoorchiog ,
prospective· employers. performing' sc;lf. ass~$Sment evo,hlations)
.
'2.0 QH
, AlICI47 Professional Development ~,0180

"
-!' l.'omp'osing effective resumeS, and dev.eloping techniques for
AlIC23S Careet Deve{opment 2,0140 successfut interviews. Students also review COl' certifications.
B10102' Anatomy &. 'Physiology If 4.Q140 This course includes instruction in Basic ,First Aid including'
,aIOll3' Anatomy & 'Physiol~~gy II 4.Q140 use ofan AllD, Adult, Child, and Infant CPR and
BlopdbomefAirbome Pathogens, 10 [ecture hOUrsl30
MASI03 Medic{\\ Office Proced\\r~s 6,0180' laboratory hours. Prerequisite: None 1
j
MCSIOS {nlcoduelion to lCp·9, & :CPT 3.0140 ~
Codil1g 1
J
t
f
·Complete Ihe crosswQrd pun:le.
y
r . !-r
if\.
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-
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f-..--
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-.-.------.----- _.. ,.---~-.~

.'
Across
... •,'. "
2 morphology of .' _ .. ..AiJ..J '?-

neoplasms (3 words) ~ ....- . '1
3 chapter where " f1v.., r>-r <:tA 0-
neoplasms codes are C)I~
found (2 words) .
5 routine gyn exam
7 . pinworm infection.
11 . slurred speech
12 &code'for insect sting
'13 dermatitis due to hair
dyes
. 14 another name for stroke
·17 . unspecflfed primary .
. mafignllnt neoplaS;l1l site'
18 'extemal bleeding
hemorrhoids
19 overeating
20 code Devil's Grip
22 COPO code found In fhr. .... o.//'
A
what chapter (2 words) ~ J..7"'('~

24 personal hx of leukemia 1/ fO.c.ce>
25 XYY syndrome '15'iS:3 \
D!)WD
..-r- mini-stroke
4 fluid overload
.6 code shell shock
7 RibCA
8 code anaphylactic shock
. 9 Accidental poisoning
EO-code for sea l)nI!ke
bite ~1<Yd.OV
10 benign essential HTN .t./Ol. (
12 sunstroke e-code
15 family hx of polycystic
kidney disease
16 HBP
21 secondary CA of rib .
23 mental disorders app F\!(no ~
deleted (3 WOrds) . ..
b
:1
j
("'N~m~D,
~0m 07m.'l24~,
o ~~ ~',d''~~~~·~at,e _--:----:-_ Q<oy#1- 6018461,
Review Words
MAN G lOP LAS T Y ART H ROD E S I S P N ,E
,'N ART H R 0 Q E S I S A N PET E C H ,I A E T j'T
u,a S' L EM 8 0 LEe T o~, Y Y E ~ ERG ENe Y T
E Y ICY SUP 1 N E 1 N P N E U M 0 NEe TaM Y
V C S S I, 1 S Y L L, r ,C yeN E G :R, E M EM c v A" U
1 N E A U ~ S S L A A 1 Ad C C'L:U'~ I q N' L'A N P
,'r EDT 0'1.; T A ,T ,L 'I, C C A' a 'L L 'E M; ERG E' .N C Y
AGO S T PCS';P' 's T E C 'Ii' I L ,A, A i a S, T Y I I E
R R RIP C E C I AMP D U T Y GTe R A YC S' L P,
U E H D U F M T a l 0·8 CO' B S ,N T S C S G NIL I
C M T B 1 A 8 A E H SAO A R J I N E I U N',E L ~'D
A ERN P 0 0 C P ~ Y I'M L L'~ D S ~ ~ D B GAR N
U CAP R U L N TE HIS A E, I N A 0 E A S ~ C Y P
Y M C E ~ 'I EEL T CIT Y NeE ICC 1 0 E C C C
M CUT E Few E ENS A 0 L Y T Y I S a A M U H P
o AYE T L T SUP 1 NEE CAT 0 Y 0 'L T E B A 1
T v e e E U 0 P S D S N INC I A'L M TTY A AR A
'C E N H COM SUP 1 N E ISH E T E Y H C 8 I G E
ENE I H RYE E lEG ~ 8 E NIP U S L B A lEO
N T G'A l O i S A T R 1 E 8 I N 0 G RAP H Y R,B P
ORR E A S R SEE T C T R ACT R L Y S I 8 E T N
M lEY E C C S M R E Y MOT eEL 0 B M E 8 0 C D
U C M T VON E E N M C DOS 1 MET R Y SUP I E
E LEI 0 P Y C L E Lei R T N Eve T lOT N E P
N ENS V YEA E E E C A NO I TA T S E FIN AM
P P P S NRC DIS A L R 0 UTI NEe H A R GEE
N CUE PlY E Lei R T N E V Y T CUR A T 1 V E
o C 0 C D £ D N B U C CAL C R N N 0 1 S U Lee 0
l e T E D N 0 0 DIS TAL 0 E Y Y R T E MIS 0 D
TUM N I I SIN E C O'N T CRT E T W NEW E U C
A B I L Y PIT N SAW A A T S DIS TAL H R T Y
C S G A CUM C T R I R REA Y H PAR G 0 N 1 S I
I INC N SEA P N 10M L N A D R N LAC CUB C
F 8 I l E e T Rep HIP R 0 UTI NEe H A R G E
I, E,D D G I R T S T 8 00 T T T N E 1 TAP NIP Y
T D N ERN YES 0 I B U C CAL A T 8 IDE U C D
ROE M E P R L D G E G R A Ii C E N J T ,U 0 R P A 0
E R T C M A V e N T R I T'8 1,8 E T NEe A R 0 H T
C H A' YET E A S I S E T NEe A R a H T S T B A C
ETC A DIN W,E NIP U 8 SUP 1 N ~ DIS TAL
R RAY NEE I PUS N 0 I TAT S E FIN AMY E
PAR P R N T 1 Y F N POI I G N 1 D NET T A E C
o C Y 0 E T I R N 1 C T TEl N 8 E 1 AlE 1 M N 0
.,
•
Nama _______-,-__ Date _ _,--,,:-_ _~_
(Key# 1· 0(1846)
Use the clue to figure out the wQrd. Write the word and find the word in the word seflrch puzzle.
7. The total ofthe costs of all supplies that are
1. type care provided in the ER; doesn't matter iflhe custoinarily used to provide the service; items
patient is new or established included in the routine charge should not be billed
separately. ....
Write the ~ord: ____._....:._..:,_
Write the word:
found,.--.,.,..time(s) in the puZzle
found _ _ _ time(s) in the puzzle
. 2.. Ptlor 8.utborization from a· payer that must be

received before elective hospital.based or outpatient 8. SuffIX meaning to releaJ3e or free
surgeries are covered; also· preauthorization or
au!hor4ation. Write the word: ____ ~
·Write the word: found _ _ _ ume(s) in the puzzle
found _ _~. fune(s) in the pUzzle 9. Charaeteristic sign or symptom of \l disease.

Write the WOld: _.:.. __________ _
3. closure of a blood vessel found _ _ _ time(s) in the puzzle

Write the word: ___ .:.. ____ _
found _ _ _ time(s) in the puzzle 10. nothing by mouth

Write the word: __ _
4. one who has been formally admitted to a health care found _ _ _ time(s) in the puzzle
facility
Write the word: _______ "'--_
11. the organ system relating to lungs, nose and sinuses
found time(s) in the puzzle Write the word: __________ _
found lime(s) in the puzzle

5. the physician with the prima,,! responsibility for
care of the patient .
Write the woid: _..., ______ _ 12. procedure for viewing interior or the body using
x·rays and projecting it onto a TV sereen
found _ _ _ time(s) in the puzzle Write the word: __________ _

6. surgical or perQ procedure in a vessel to dilate
vessel openings; used to treat arteriosclerosis
disease
Write the word:
,~
q.-'"
I
• HeiDer: II
,
I
Name _ _:....,-_ _ _ _ _ __ [
\ f' J.J;I>t;~ ~ 1
, ".~ .. . 1. " . J f j}
t "~
. 13. lying on the back 19. Payment criterion of payers that requires medic"al ~
~
treatments·to be appropriateand.provided in . ~ "
t1[-1
.Write the word: -'-____ .:-. . accordance with generally accepted standards of
medical practice.' . . .. ,
f 11
[i
found time(s) in the puzzle .- . [ 5
i ~
14. removal of total lung --------~-~~--~--
i
1
"ff
u
: H
Write the word: . _.________ -.: __ _ ·foU\ld _ _ _ time(s) ltrthej>uule ! tl
II
. fpund _ _ _ time(s) in the puzzl~ "H
"
20, before meals U

)
;;
15. farther from the point of attachment or origin Write the word: fi
H
Write the word: .__ ..:... __ _ found _~_ time(s).1n the pUzzle "r:~
"
fouud _ _ _ time(s) in the puzzle

,
II
21. remova) of blockage from the v~els n

[I
Write the word: __________ _ :1
16. type of patient who has no! received services within ;\
the past 3 years "I,
found time(s) in the puzzle
Write the word:
~:
·found ___ time(s) in the puzzle 22. surgical immobilization ofajoint
Write the word: ____ .:... _____ _
17, Tablet placed in the mouth between cheek and gum found ___ timc(s) in the puzzle
for absorption
Write the word: _____ _
23. Fee for services other than room and board
found _ _ _ time(s) in the puzzle provided during a patient's hospitalization, such as .,
anesthesia, pharmacy, supplies, and therapies, 1
Write'the word: ,
18, removal of fluid from thoracic cavity "{
Write the word: ____________ _ .,
j
found _ _ _. time(s) in the puzzle found ___ time(s) in the puzzle ~
l
1
1
24. 31lplication cif force to a limb
1
Write the word: _______ _ i
I
found __. _ time(s) in the puzzle
iI
I
•
I 1t
! 1
I
I
.. ,
N.ame - , . . . . . - - - - - - - ~l~
··~H~IDer
(:om . .Date
(Koy# 1·001846)
25•. radiographic reconting of the siUua or sinus tract

W:rite the word: _________ _
found ' tirue(s) in the puzzle
26. el]am.ber in lower,part Of the heart

. ,
'Writ~,the word: ______ :....._..:..:
found . fune(s) in the puzzle
27. sCientific calcuiation ofradi.tion emitted from

various radioactive'sources
Write the word: ______ :..... __
found tirue(s) in the puzzle
28. small pinpoint hemorrhages

Write the word: ________ _
found tirue(s) in the puzzle
29. Medication prescribed to kill or remove the

causative agent of a disease
Write the word: _______ _
found _ _ _ tirue(s) in the puzzle
30. after meals

Write the word:
found _ _ _ tlme(s) in the puzzle
l{
U
,
! I
, ~Ii
;
E-
!
" Answer Key: Ke~ # 1 - 601846 ,
.~ R
Review Words
it ~"",
,, ij
M ~A N G lOP LAS T YJ"A R T H ROD E S I S ) P N E I! 11
;A R T H ROD 6 S I SJ Vf\b(p E TEe H I A En I T

, iH!
~~ L (6 M B 0 L 6 C T/1 ,/M y)y (6 _M 6 R G E N C Y)T ,"
%
, 11
t 11 l.£:i
Y (8 U, P I N ~~ (P N 6 U M 0 N E C TOM y) i
l
ft
V G;"~I S Y ~ '!Xt'9,-y C NEG REM E)M ~--.:;1' A U
I N 6 A S S S/.9"'~ ~ A Co C C L U S ION) N N P ~
,.. 6 D TOt.: ~0A
AGO S T ~~vP ~ T '"
l"-iOOA
B ~'(E MER G ENe Y
H 1 ~~ ~I 0 S T rY I' 1 E
il
"({
"
Ii
I~~ ~ ~I ~ ~ 3'~~,
R
H
R R R A D T Y A Y C S L P II
,U E H D ""s;,I ~'j 0 S N i"'-. ~ "S G N I L I
~ti
III
C M T I/A B A H ~ r- ,,,,~R 1 I N 2-... ~N E 'L' A D
'iCE R. AS 0 0 C p :c
~N ~ ~ s 0 S H ~ GAR N
_U= A _,_ R U, L N T' E' ,N""-ip<.~,,,,,r' N 0 ~ R C Y p
11
:~
~E fiJ '1l'--.~ = l
""~
'11 l E E LTC.l C 1 E C C C
M I,!; T E 'F' C WEE i'j/"Y"< 2'-~;yv ")( I A M U H P 11
:~
it
,0 ,A IjT E T L T SUP. I A ;:}.::;V /Iy T E ~ A I
J' ~ C C E U 0 P S <lJfi N I/Vt "'Y ~'~ T ' ,A R A ~
C E N H COM SUP I / t Y /101 if T ~ H I G E ::1
,
ENE I H R ~ E E l tytv-fA~ N I P US) L B A E 0 ;
N T G A I 0 I S A ~y~..e: I N 0 G RAP H y) P 1,
ORR E A S R S EN~./1 R ACT R lL Y S I S E T N
M I E (?\s C C~V!y1 X MOT C E LOB, M E) S 6"(e) D
U C M T \j 0 N
E LEI 0 P 'V0A1
A6 C (0 0 S 1 MET R y~ U
A".A
L C I R T N E V) C T./\A T N E P
f?:f1
E
N ~ N S V ;: o/y.~ E E (C AXN 0 1 TAT F I N A M)

P I'" p S yr:Yt~~ SAL (R 0 'U T 1 1/tO/C H A R G E) E
IN' CUE I~~ (E L C IR T N E VY'oY ,,(C U RAT" 1 V E -1
i
o C a fC f'b/
(t5' 'N S U C CAL) <W 0 1 S U L C C a
.J
i
rv >6A
A
ley'
T U Ql1"
!
N 0 0 DIS T A
I l S I N f'" 0Q V0./W
1 L 'Y' P I T N S A vy1~1 AD 1ST A L) H R T Y
''O-t' R T E M I S 0 0
T W eN E W) E U C
it
~j
'\
C S G A CUM C T R ~ ~vt't H PAR G 0 N I $) 1

I INC N SEA P V0,/lvfi A 0 R N (L A C C U s)c
F S 'I I E ! T R ~/'!V,Y~ 0 l T I N E C H A R G E)
lED, D G I ~R T s~V1 A" ~J T T (T N E I TAP N I) P Y
T D N ERN Y , .A./,...tl; U C C AtL)A T S I 0) E U 0 (151
ROE M E P <' A,,R1 G R A H C E N I T U 0 R)P ,Ala
E R T M A V V. ~ R I T (5 I S, E T N E (C A) R 0 H T
't
C HAY E T F.: qvk:I SET N E CAR 0 H n S T 8 (A C
E T (CJ A ''0 I n e E N I P U SX5 U P I N EXD I 5 TAL
R R ~ Y N 15-'Vp U S IN a I TAT S E F I N A M)Y E
PAR P r< ~ 'f I Y F eN P 0) i I eG N, ION E T T A) E C
tr . Y 0 E ~ I R N leT TEl N 5 [ 1 A I E l M N 0
, Diana Meyer
From: Diana [deemeyer@belisoulh.neIJ
Sent: Tuesday, August 03,201011:55 AM
To: Linda Hedges
ec: Jim Hackney
Subject: Resubmittion of letter because of non-reply.
I am resending this letter because I have not heard a response from you or Mr. Hackney. I
wasn't sure if you had received it.
Diana Meyer
-----Original Message-----
From: Diana [mailto:deemeyer@bellsouth.net]
Sent: Friday, July 23, 2e1e 2:29 PM
To: 'Linda Hedges'
Cc: Jim Hackney
Subject: RE: Response to blanket return to classes letter.
Mrs. Hedges,
Thank you for getting me the figures. Are the figures for the day classes or the night
classes that graduated in September 2009 and March 2e10? I am now in contact with 18 people,
some from the day classes but most of them from that night classes, that took the MBCS
program in 2009 and have taken the test, some have only taken the test once and others twice
and only one of them passed, with that information I will have to disagree with the figures
you are quoting because that doesn't add up to 70%. It seems odd that most of your students
that graduate the program do so with a 4.0 average and honors but yet can not pass the epc
exam.
Many of us were told by your salespeople that there would be no problem with night time
classes or night time externship, but classes were canceled or moved to the daytime hours and
extern ship that was given were with companies who needed people to file or stuff envelopes
for them. We did not pay that kind of money to be file clerks. We were never told that we
would have to become members of the AAPe which was an addition $70.00 as long as you were a
student and another $120.00 a year to remain a member. We were also told that the starting
pay for becoming a coder and biller was $40,000 - $50,000 a year. That is also incorrect, as
many people are now discovering by actually investigating this field that the starting pay is
on the average $10.00 - $12'.00 an hour. No where near the amount we were told to sell the
class to us.
If you would like the names of the people I am personally in touch with about this, all are
as dissatisfied with your program and are now stuck with paying back a very expensive loan.
I would be more then happy to give you the list so you or the new director can personally
talk to them also.
I have worked for the automobile industry for over 20 years and there are laws (lemon law)
against selling a vehicle under false pretenses and a continual expense for the owner. I am
sure there are laws out there to protect us from what your company has done, and that the
misrepresentation of your school and the Medical and Coding industry as Medvance as done to
many people.
I have researched and found the company that accredits Medvance, Accrediting Bureau of Health
Education Schools (ASHES) 7777 Leesburg Pike, Suite 314 N. Falls Church, VA 22043 Tel (703)
917-9503, and will be in contact with them to find out how exactly Medvance became accredited
1
and,ask them for the figures presented for that accreditation as well as giving them the
• information that I now have •
Sincerely,
Diana Meyer
From: linda Hedges [mailto:linda.Hedges@medvance.edu)
Sent: Thursday, July 22, 2010 6:29 PM
To: Diana
Hi Diana .•.
Pat has finally gathered the info. Thank you for your patience.
Please find the following credentialing pass rates for the MBCS program as follows:
2008/2e09 16/20 took exam and passed 80% 2009-2010 (still in progress) but as of now 14 out
of 18 took exam and passed= 78%
The overall benchmark that we aspire (however not required) to meet is 70% minimum
Thanks
Linda
From: Diana [mailto:deemeyer@bellsouth.net)
Sent: Friday, July 16, 2010 2:15 PM
To: Linda Hedges
Hello Mrs. Hedges,
It has been well over 2 weeks since you wrote me back and I still have not heard a response
on the pass rate for coders taking the CPC exam. I also talked to you on the phone 6 months
.back, when I received a phone call from your sales representative to try to get me to come
back and you told me then you would get with Mrs. St. John and call me back to give me the
numbers. I didn't get a return call from you then either.
I am surprised with you being the Director of Education that you would not have these figures
at your fingertips or computer.
I also noticed in your response that you addressed Mr. H. No where in my letter did I
mention the name of the teacher everyone had a problem with, but you knew exactly who I was
talking about, that is very strange.
I would still like to know the CPC exam pass rate for stUdents that finished the night
classes for the year of 2e09. I would also like to know the
name(s) and address of the people who accredits Medvance. I have some questions for them
also.
I look forward to hearing from you soon.
Sincerely,
Diana Meyer
2
, -;---Original Message-----
From: Linda Hedges [mailto:Linda.Hedges@medvance.edu]
sent: Friday, July 02, 2010 12:38 PM
To: Diana
tmportance: High
Diana, r am upset to hear all of this.
r will get with Pat St John when she returns from vacation to assess the pass rates.
I can assure you that the current coding classes and faculty (including Mr H) have been very
well received, without incident. I will investigate your claims.
Thank you
Linda
From: Diana [mailto:deemeyer@bellsouth.net]
Sent: Thursday, July 01, 2010 9:28 PM
To: Linda Hedges
Subject: Response to blanket return to classes letter.
Hello Mrs. Hedges,
Thank you for the letter. Before I would even consider returning to Medvance I would like to
hear how many of the Coding students from the classes that ended in July 2009 actually passed
the CPC exam. I have talked to everyone that was in my evening classes and only 1 person
passed that test and all because she had 25 years of being a medical transcriptionist under
her belt.
Several people have taken the test not once but twice and failed. r have complained, wrote
emails, talked with faculty at Medvance several times about the curriculum and inadequate
staffing that Medvance provided the nighttime students.
I don't know how much I can stress and did.stress that medical terminology was not taught to
the degree to be able to look at a word and figure out what it means to code it correctly.
Medvance use to have a class that was just medical terminology and removed it, because the
powers on up the chain decided that they would rush the classes even more then they did
before.
We
were the first class to be introduced to the 4 day a week 5 hours a night classes. Which from
what I have been told and seen first hand, had failed miserably.
Medvance had some teachers that were not qualified to teach the classes they were teaching.
We were asked to fill out evaluations for the teachers and even though EVERYONE complained
about the teacher and how he was hard to understand and didn't know what he was talking
about. We ended up getting him the next month ... not for just one class but both classes.
After that we all knew the evaluations were a farce. It didn't matter what we thought about
the class at all.
Internship was a joke for most. They were put in places that didn't even have them code. Just
file and stuff envelopes the entire time they were there. Now I am stuck with paying back a
loan for Medvance's failed program as many other students.
If you really need to talk to me, feel free to call me at 772-834-2990.
I
3
witl be more then happy to discuss this further and also give you the names of others who are
in the same boat I am.
Regards,
Diana Meyer
. From: Linda Hedges [mailto;Linda.Hedges@medvance.edu]
Sent: Wednesday, June 30, 2ele 7:48 AM
To: undisclosed-recipients:
Subject: GOOD NEWS FORMER MEDVANCE STUDENTS!!
Importance: High
STUDENTS,
FINISH what you STARTED!
For any student that REENTERS in JULY 2e10 and COMPLETES their program,
Medvance will waive any carry-in past due balance.
The term starts next Tuesday 7/6/10 so please contact me ASAP so I can
determine if you are able to start.
If you qualify, you balance will be waived (remember you MUST COMPLETE
YOUR PROGRAM THIS TIME AROUNO) and an appointment will be scheduled with
Financial Aid.
Regards,
Linda Hedges
Director of Education
MedVance Institute
Phone: 772-600-3921 Direct
Fax: 772-223-0522
Linda.Hedges@medvance.edu
Stuart Campus
851 SE Johnson Ave
Stuart, FL 34994
Tracking:
4
Max Nelson
From: kp45fan561@aol,com
Sent: Thursday, November 11,20108:10 AM
To: mnelson@sarelson.com
Subject: FYI
Attachments: NOVEMBER-CareerServicesTeleTrainingSchedule-Student.docx
Good Morning Max, Just thought I would send/forward the email from I got from
Med Vance. Note they are offering these gift cards for help on finding job leads.
Linda
From: Ruth-Ann Duren <Ruth-Ann.Duren@medvance.edu>
To: Ruth-Ann Duren <Ruth-Ann.Duren@medvance.edu>
Cc: Laura Duvall <Laura.Duvall@medvance.edu>; Rasheeda Mohammed <Rasheeda.Mohammed@medvance.edu>
Sent: Wed, Nov 10, 2010 11 :02 am
Subject: Are you working?
Career Services
772-221-9799
Please let us know if you are workingl If you are working, are there any openings? (See the end of this email)
Ruth Ann Duren, Director of Career Services

ruth-ann.duren@medVance.edu
Rasheeda Mohammed, Career Service Advisor

Rasheeda.mohammed@medvance.edu
Laura Duvall, Externship Coordinator

laura.duvall@medvance.edu
• Free Tele-Training sessions, November 15, 2010 (schedule attached above)
1O:OOAM-11 :OOAM Create a Target List

11 :00AM-11 :30AM Get Your Message Out-Networking
Also on November 17, 2010

6:00PM-6:30PM Time Management in Your Job Search
7:00PM-7:30PM Staying Active in Your Job Search during the Busy Holiday
Season
Call: 1-866-740-1260 pass code: 6331818#
• Please make sure you have emailed your updated resumes, including externship, to Career Services.
• You are invited to attend an Employability Workshop, Tuesday, November 23,2010, here on campus from
1 :OOPM to 3:00PM to assist with resumes and job search techniques. Please come dressed as if you were going
on an interview and have your resume in hand for Career Services to review. Lunch will be served.
1
• We are here Monday-Friday 8-5
(Tuesday and Thursdays we are available until 6:30PM)

You can call anytime to set up an appointment
• Have you worked anywhere since graduating (maybe a related field) even if you are no longer there, we need to
know! Also, is there a reason you are not working ... for example:
Illness In the family, pregnancy, back In School, military obligations, etc .. ,
Remember, you will receive a $25.00 gift card for each verifiable job lead you provide
to Career Services, and another $25.00 gift card for each job lead that turns into a hire
for one of MedVance's graduates!
2
August 10, 2009
To: The Department of Education
On behalf of all of the Medical lab Technician students we have decided to take action regarding our
program. We believe we have been neglected having a laboratory. We should receive the same
standards and treatment as the other programs as well as other campus location necessities. We have
been promised a Laboratory a year ago and stili have yet to receive it. As you know some of the
students are approaching there externship and are not educated in a full. laboratory environment. Since
, we have been a part of this program we have done nothing but be patient and understanding.
All of us are concerned with the accreditation. Is our program accredited, If not why not? We would
hate to finish this program only to learn that all that hard work and money we put Into your program Is
not accredited.
We have se,en all of our great teachers and a wonderful program director we have built a relationship
with, replaced. In our eyes atthe time they were our voices. We the MLT's believe that In order for a
teacher to teach:a subject, they must know the subject. We believe we are getting cheated out of our
studies. Our classes are very critical and Important for us to know. We are Investing time and money
Into this program:and for us to be cheated Is unacceptable. We demand a change.
-Medical LaboratoryTechnician Students
- \::'ncO-... \u...'(' ~
r::'4~~J
C:W(fj\Q \bv~'
- rt<H Cl.a.- {~ - SabI\I\C- ~'(x7"'"

~ ·-1rrt ('3 .. Ar---\A-' A~~e
JV\vl~e O(X\S
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t
~~
;;
IIMedVance
- - - I N S TIT U T E---
e
Date: May 3, 2010
To: Whom It May Concern
From: Thomas R. Filippi, Director ofEducatioll
RE: Jordana Soler, Medical Labato/y Techllology
To Whom It May Concern,
This letter is to confirm that JORDANA SOLER was enrolled in the Medical Laboratory
Technology Program at the MedVance Fort Lauderdale campus from 1112/2009 to 41l/2010.
Ms. Soler was enrolled from 8 am to 4 pm Monday through Thursday, which is considered full-
time. Ms. Soler had excellent attendance.
Ms. Soler had moved out of the area, causing a temporary disruption in her program. Any student
not attending class for more than 10 days must be withdrawn due to Financial Aid reasons so a
student is not billed for classes he/she is not attending. She only has extern ship left and is in
continual communication with our school. She is completing the externship paperwork and we
are anticipating her re-entering the program on or before June 1,2010. Her expected graduation
date will be October 31, 2010.
I hope that you will please extend any benefits to Ms. Soler during this brief break.
If you need any additional information or have any questions, please do not hesitate to contact
me at 954.587.7100, extension 6550.
Sincerely,
Thomas R. Filippi, MA MS
Director ofEducation
Page 1 of3
----- Forwarded Message ----

From: caryn Heaney <caryn.Heaney@medvance.edu>
To: Jordana Soler <Jordana.soler@yahoo.com>
Sent: Wed, April 28, 2010 11:48:06 AM
Subject: RE: Important papers
Hello Jordana,
Unfortunately, at this time you have been withdrawn from MedVance, Due to financial aid you can not miss more than 14 calendar days
from school or you will be withdrawn. This is done to protect you and make sure you don't get charged for classes you are not sitting in.
When you moved up north this caused a problem with having a site for you because you were not able to send your physical and drug
panel Or attend class until you were placed on a site. My best advice to you is to either come back to Ft. Lauderdale and re-enter into
the program or to contact the West Palm Beach MedVance, which is closer to where you live now. Please feel free to contact me with
any further questions.
Caryn Heaney
Registrar
P 954-587-7100 Ext #6536
F 954-332-4643
MedVance Institute
Fort Lauderdale Campus
4850 West Oakland Park Boulevard, Suite 200
Fort Lauderdale, FL. 33313
Caryn.Healley@MedVallce.Edu
From: Jordana Soler [mallto:jordana,soler@yahoo,comj

Sent: Wednesday, April 28, 20106:02 AM
To: Ca/yn Heaney
11116/2010
Page 2 of3
Subject: Fw: Important papers

Here is the email that was sent a few days ago. My appointment today is at 10:00 am this morning and I really need
this letter. Please email it to me as soon as you can. Much appreciated!! Thank you.
-Jordana Soler
----- Forwarded Message -"-

From: Sonja Peoples <Sonja.Peoples@medvance.edu>
To: Jordana Soler <jordana.soler@yahoo.com>
Sent: Tue, April 27, 20101:29:58 PM
carvn.heaney@medvance.edu
From: Jordana Soler [mailto:jordana.soler@yahoo.com]

Sent: Tuesday, April 27, 2010 1:14 PM
To: Sonja Peoples
Subject: Re: Important papers
thank you mrs. peoples. Is it easier to reach her by phone rather than email? is her email
caryn.heany@medyance.edu?
From: Sonja Peoples <Sonja.Peoples@medvance.edu>

To: Jordana Soler <jordana.soler@yahoo.com>
Sent: Tue, April 27, 2010 11:09:11 AM
Hello,
The person you need to contact is Caryn Heany, she is the registrar and will be able to write the letter for you. Her number
is 954-587-7100 x 6536, hope this helps.
Sonja Peoples
From: Jordana Soler [mailto:jordana.soler@yahoo,com]

Sent: Tuesday, April 27, 201011:05 AM
To: Sonja Peoples
Subject: Fw: Important papers
Hey Mrs, Peoples,
I sent Mr. Peter this email yesterday and maybe u can help me with this, I'm trying to get my son in
daycare and they need proof that I am in school. They need a letter stating how many hours and days I am
in school for externship.
It needs to he on a Medyance Letterhead. I tried to email Mrs, Woods but it wasn't going through. Maybe
the email i haye for her is wrong. Forward it to her if she would be more of assistants. Any help would
do. Thank you so much.
-Jordana
---.- Forwarded Message _.. -

From: Jordana Soler <jordana.soler@yahoo.com>
To: peter <peter.dusseault@medvance.edu>
Sent: Man, April 26, 2010 4:30:15 PM
Subject: Important papers
Hey Mr. Peter,

Hope you afe doing well. I just wanted to see if there was an update on externshlp sites for me? I
of hours a week I will be externing and where. It should be on a schools letter head. It's for dayca
11116/2010
Page 3 of3
I will need this by tomorrow evening. Please mr. peter, get back to me ASAP. Thanks.
-Jordana
11116/2010

Best V MedVance - Amended Complaint

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business as MedVance Institute ("MedVance"), for breach of contract, breach of the covenant of

rescission ofloan agreements entered into as a result ofMedVance's fraud.

1. This lawsuit concerns a private, for-profit educational facility, MedVance, which

To prevent irreparable harm to hundreds of students, it must be shut down.

federal student aid, MedVance is allowed to continue to operate.

3. MedVance victimizes its students. Plaintiffs, who were enticed by promises of a

subjected to out-of-control classes taught by disinterested and unqualified instructors. Instead of

educational externships capable of enhancing professional development, Plaintiffs were placed

detriment of its students.

Parties, Jurisdiction, Venue Etc.

MedVance Institute's West Palm Beach campus from 2009 to 2010.

5. Plaintiff Guerlande Exantus, a current resident of Palm Beach County, Florida,

6. Plaintiff Diana Medina, a current resident of Palm Beach County, Florida,

7. Plaintiff Teri Dolecki, a current resident of Martin County, Florida, attended

MedVance Institute's Stuart campus from 2008 to 2009.

MedVance Institute's Stuart campus from 2008 to 2009.

9. Plaintiff Linda O'Neill, a current resident of Palm Beach County, Florida,

attended MedVance Institute's Stuart campus from 2008 to 2009.

12. Plaintiff Lorene Caudy-Richardson, a current resident of Palm Beach County,

attended MedVance Institute's West Palm Beach campus in 2009.

MedVance Institute's West Palm Beach campus from 2009 to 2010.

attended MedVance Institute's West Palm Beach campus in 2010.

attended MedVance Institute's Stuart campus in 2009.

MedVance Institute's Stuart campus from 2008 to 2009.

MedVance Institute's Stuart campus from 2009 to 2010.

attended MedVance Institute's Stumt campus from 2009 to 2010.

21. Plaintiff Marianne Mackenzie, a current resident of Martin County, Florida,

attended MedVance Institute's Stumt campus from 2008 to 2009.

MedVance Institute's Stumt campus from 2008 to 2009.

MedVance Institute's Stumt campus from 2009 to 2010.

MedVance Institute's Stuart campus from 2009 to 2010.

MedVance Institute's Stuart campus from 2009 to 2010.

26. Plaintiff Louisanne Saint-Vii, a current resident of Broward County, Florida,

attended MedVance Institute's Ft. Lauderdale campus from 2008 to 2009.

MedVance Institute's Ft. Lauderdale campus from 2009 to 2010.

MedVance Institute's Ft. Lauderdale campus from 2008 to 2010.

law in excess of $15,000.

of action accrued in Palm Beach County, Florida.

Facts Common to All Counts

successful career in an in-demand occupational field. Oral representations aside, even

diagnoses and procedures . . . Graduates find entry-level employment opportunities in

physician's offices, billing offices, hospitals .... " See id

35. MedVance recruits students aggressively with mailings, television advertisements

and have an independent incentive, to make various misrepresentations to potential students to

The first "F" in the acronym FAFSA stands for "Free."

another program. Disturbingly, recruiters make promises that MedVance is "accreditated,"

MedVance as a quality institution. In reality, MedVance's "accreditation" was recognized by a

of federal loan programs.

overshadows the drive to educate, students suffer and business thrives.

subsidized and unsubsidized loans totaling approximately $11,500. MedVance's recruitment of

peers complained to MedVance administration after a few weeks of instructional negligence.

sat in a chair and sent text messages.

was a major waste of time and money.

personal lives or gossip, instead of thoughtfully teaching the subject matter.

the Medical Office Administration field.

emollment misrepresentations concerning the employability and earning potential of graduates.

courage to go back to school, but it was all a waste."

representations of institutional legitimacy and accreditation. In addition to these misleading

education and employability of graduates to be misleading.

order to receive externship credit, a requirement to graduate.

to do, or observe, any billing or coding work.

to perform tasks related to billing or coding.