Yesterday I reported the class actions initiated against Cooley and New York law schools. Here's an excerpt from the complaint in the third, this against Thomas Jefferson Law School:
BRIAN PROCEL State Bar No. 218657
bprocel@millerbarondess.com
2 Vll’JAY KOHLI, State Bar No. 268430
vkohli(imil Ierbarondess.com
3 MILLR BARONDESS, LLP
1999 Avenue of the Stars, Suite 1000
4 Los Angeles, California 90067
Telephone: (310) 552-4400
5 Facsimile: (310) 552-8400
6 Attorneys for Plaintiff
ANNA ALABURDA
7
8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SAN DIEGO
10
11 ANNA ALABURDA, an individual, on behalf CASE NO.
of herself and all others similarly situated,
12 COMPLAINT FOR:
Plaintiffs,
13 (1) UNFAIR BUSINESS PRACTICES
v. (BUS. & PROF. CODE § 17200 ET
14 SEQ.);
THOMAS JEFFERSON SCHOOL OF LAW,
15 and DOES 1 through 100, (2) VIOLATION OF THE FALSE
ADVERTISING ACT (BUS. &
16 Defendants. PROF. CODE
§ 17500 ET. SEQ.);
17 (3) INTENTIONAL FRAUD
18 (4) VIOLATION OF THE
CONSUMER LEGAL REMEDIES
19 ACT (CIV. CODE
§ 1750 ET.
20 SEQ.); AND
(5) NEGLIGENT
21 MISREPRESENTATION
22
DEMAND FOR JURY TRIAL
23
24
25
26
27
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CLASS ACTION COMPLAINT
78078.6
1
NATURE OF THE ACTION
2
1. This dispute arises out of the fraudulent and deceptive business practices of
3
Defendant Thomas Jefferson School of Law (“TJSL”). For more than 15 years, TJSL has churned
4
out law school graduates, many of whom have little or no hope of working as attorneys at any point
5
in their careers.
6
2. TJSL’s average student indebtedness, more than $135,000, is among the highest in
7
the nation. And its bar passage is consistently lower than 50 percent, well below the average in
8
California.
9
3. In order to attract students despite these dismal figures, TJSL has adopted a practice
10
of misrepresenting its post-graduation employment statistics. For instance, during a deep economic
11
recession affecting the legal industry on a widespread basis, TJSL reports that the median salary of
12
its graduates has remained constant between 2006 and 2011 (even though the average salary of
13
attorneys nationwide has seen a dramatic decline in recent years).
j3- 14
4. Moreover, TJSL misleads students by advertising post-graduation employment rates
15
that typically exceed 70 percent, and that topped 90 percent in 2010. TJSL, though, conceals the fact
16
that these figures include part time employment, as well as non law-related positions (i.e., a TJSL
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student will be considered employed after graduation if he works as a part time waiter or
18
convenience store clerk). Prospective students are led to believe that they will be hired as full time
19
attorneys when they graduate, even though that is frequently not the case.
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5. There is no reason for TJSL to present a figure concerning the percentage of
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graduates who are employed in any position (including part time and non law-related positions)
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other than to mislead prospective students.
23
6. TJSL knows that these statistics are widely reported by U.S. News & World Report’s
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“Best Graduate Schools” annual edition, which is reviewed by the bulk of prospective law school
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students and is considered to be the authority on law school rankings. TJSL also reports these
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misleading figures in one form or another on its website and in its marketing brochures.
27
7. Plaintiff Anna Alaburda (“Plaintiff’) graduated from TJSL in 2008 with more than
28
2
CLASS ACTION COMPLAINT
78078.6
1 $150,000 in student loan debt. Since then, Plaintiff has been unable to secure a full time job as an
2 attorney that pays more than non-legal jobs that are available to her, even though she graduated with
3 honors from TJSL. Plaintiff would not have attended TJSL and incurred more than $150,000 in
4 school loans if she knew the truth about her job prospects upon graduation.
5 8. At the end of the day, TJSL is more concerned with raking in millions of dollars in
6 tuition and fees than educating and training its students. The disservice TJSL is doing to its students
7 and society generally is readily apparent. Many TJSL graduates will never be offered work as
8 attorneys or otherwise be in a position to profit from their law school education. And they will be
9 forced to repay hundreds of thousands of dollars in school loans that are nearly impossible to
10 discharge, even in bankruptcy.
11 9. This lawsuit seeks damages and restitution exceeding $50,000,000 and injunctive
12 relief stemming from TJSL’s fraudulent and unlawful conduct.
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