COMPLAINT June 02, 2023 (2024)

 
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 RETURN DATE: JUNE 20, 2023 SUPERIOR COURTNEW YORK INSTITUTE OF TECHNOLOGY J DI OF HARTFORD Vv AT HARTFORDMICHAEL PARK MA\f 24, 2023 COMPLAINT I}L }|COUNT ONE1. The Plaintiff, NEW YORK INSTITUTE OF TECHNOLOGY (‘the Instit|te”), is a privateeducational institution with its principal place of business located at Norjhern BoulevardP.O. Box 392, Old Westbury, New York.2. The Defendant, MICHAEL PARK (“Park”), is an individual residing at|21 Hemlock Street,Manchester, Connecticut.3. The Plaintiff entered into an agreement with the Defendant. The Defendant requestedand attended the Plaintiffs educational institution and agreed to pay the Plaintiff tuition andattendance charges at an agreed upon price and terms.4. Park attended the Institute as a student in the College of Osteopathic Medicine from the2017-2018 to 2019-2020 terms before his withdrawal from the Institute5. Park incurred charges for tuition, cash for living expenses, insurancejand usual studentfees of $22,345.00. A true and accurate copy of all credits and debits to his account is setforth in the statement dated November 9, 2022 and attached as Exhibit/A.6. Park executed a Registration Form on September 27, 2019 (“agree ent’) agreeing topay attorney fees of up to 33.3% if the Institute had to collect any bala’ nve. A true andaccurate copy of the agreement is attached as Exhibit B and incorporat}d by reference7. Park further agreed to pay interest at the maximum legal rate for any|outstandingbalance due under the agreement which is eight percent (8%) under CGS §37-1(a). f t\\LSERVER2\Office Documents\Collections\OTHERINY Institute of Technology\Park, Michael\P Complaint|5-24-23.dacx8. Park defaulted on the balance due on January 27, 2020 by failing to fay his remainingbalance of $22,345.00 already set forth herein and in Exhibit A.9. Park further owes reasonable attorney fees of fifteen percent (15%) baing $3,351.75 forthis action under the agreement and under CGS §42-150aa.10. Park owes the following to the Institute under the agreement: a) $22 345.00 inprincipal; b) $3,351.75 reasonable attorney fees; c) interest of $5,958.81 W running fromJanuary 27, 2020 to May 27, 2023 being $148.97 per month x 40 and continuing to accrueThe foregoing total $31,655.55 not counting any future accrued interest,11. Despite demand made by the Institute or its representatives, Park refused to pay theamount which is justly due and owing to the Institute. |12. The Institute has been damaged by the breach of the agreement by Park through theloss of money and associated fees which are contractually due and owi 19 to it.COUNT TWO -5. Paragraphs 1-5 of Count One are incorporated by reference as if sét forth herein6. Park received a benefit of education, living expenses and insurance provided by theInstitute without full payment for same by him or others on his behalf when rendered.7. The Institute has not been paid the full value of services rendered by /Park8. Park owes the Institute $22,345.00 as set forth in ExhibitA. rt9. Park has been unjustly enriched by the receipt of goods and services| provided throughthe labor and property of the Institute without full payment to its detriment10. The Institute has been damaged by the utilization of its facilities and the efforts of itsstaff without fair compensation for the value of same by Park or others qi n his behalf. | | ; t\\LSERVER2\Office Documents\Collections\OTHERINY Institute of Technology\Park, Michael\P Complaint |-24-23.docx iWHEREFORE, the Plaintiff prays for the following relief:1. Damages2. Costs.3. Interest4. Attorney fees5. Any other relief the Court deems fair and equitable THE PLAINTIFF A oo wy. LEE Neal Tidhar, its attorney Law Offices of Bruce E. |3ergman 63 Imlay St., Hartford, CIT 06105 Tel: 860-522-1436; Fax:|860-522-9077 Juris Number: 431620\LSERVER2\Office Documents\Collections\OTHERINY Institute of Technology\Park, Michael\P Complaint {-24-23.docxRETURN DATE: JUNE 20, 2023 SUF'ERIOR COURTNEW YORK INSTITUTE OF TECHNOLOGY J.D) OF HARTFORD Vv. AT HARTFORDMICHAEL PARK MAY’ 24, 2023 STATEMENT OF AMOUNT IN DEMAND The amount in demand is over Fifteen Thousand Dollars ($15,000).p-00) excludinginterest and costs. THE PLAINTIFF wy, ZS Neal Tidhar, its attorney Law Offices of Bruce E. |3ergman 63 Imlay St., Hartford, CiT 06105 Tel: 860-522-1436; Fax:|860-522-9077 Juris Number: 431620\\LSERVER2\Office Documents\Collections\OTHERINY Institute of Technotogy\Park, Michael\P Complaint §-24-23.docxSS GRAY wt NEW YORK INSTITUTE = a OF TECHNOLOGY ‘Statement Date: 11/08/2022 NYIT Office of the Bursar Student ID: ems | Balance Due: $29,792.59 P.O. Box 392 ET Old Westbury, N.Y.11568 Due Data See information Below Fax 616 686 7833 $29,792.59 Phone 516 686 7510 I Emalt Bursar@nyitedu Michael Park 21 Hemlock Street EXHIBIT A Manchester CT 06040-4066 woe ee ee ee we ee ee ee ee ee ee if you are mailing a payment, jude the top portion and rememberto write your 7 digit 10 numb): on your payment. ERD ze Ue ar ely Payment Due Dates: NYIT College of Osteopathic Medicing Dia Dates: Fall: on or before August + The first halfof tuition and fees is due Aprill 16 for al! class levels. Spring: on or before January 1 The second half of tuition and fees is due November 1. Summer: on or before May 1 Please be sure to meet your financial obligation to NYIT in accordance with NYT policy. eis i SRE aw eee naa 2016-12-29 2017-2018 Tuition Deposit 2017-04-05 2017-2018 Technology Fee - Med 1st Year $250.00 2017-04-05 2017-2018 Activity Fee - Medical | $250.00 2017-04-05 2017-2018 Tuition Charge - Med N1 ist Ye $28,785.00 2017-04-05 2017-2018 Health Care Fee - Mad 1st Year $100.00 2017-04-05 2017-2018 Lab Fee - Medicel ist Year $125.00 2017-04-05 2017-2018 Life/Disability-Medical 1st Yr $115.50 2017-04-05 2017-2018 Sirulated Patient 1st Year $500.00 2017-08-02 2017-2018 COM Grad PLUS Loan 3 ~$15,954,50| 2077-08-02 2017-2018 COM Grad PLUS Loan 3 -$6,393.50 2017-08-02 2017-2018 COM Direct Unsub Loan 4 $22,232.00 2017-08-03 2017-2018 BankMobile Refund to Studsnt $15,954.50 2017-10-19 2017-2018 Tuition Charge - Med N2 $28,785.00 2018-01-07 2017-2018 OM Direct Unsub Loan 4 $22,232.00 2018-01-07 2017-2018 COM Grad PLUS Loan 3 $6,553.00 2018-01-08 2017-2018 BankMobile Refund to Student st 5,794.00 2018-02-20 2016-2019 Activity Fee - Medicat $250.00 2018-02-20 2018-2018 Technology Fee - Med 2nd Year $350.00 2018-02-20 2018-2019 Simulated Patient 2nd Year $500.00 2018-02-20 2018-2019 Life/Disablity-2nd, 3rd & 4th $126.00 2048-02-20 2018-2019 Lab Fee - Medical 2nd Year $175.00 2018-02-20 2018-2019 Health Care Fes - Med 2nd Year $100.00Narra: Michael Pari Student iD: Qa ‘Statement Date: 11/09/2022 Page 1 of 2= bid SIs eth (ei! a 2018-02-20 2018-2019 Tuition Charge - Med N1 2nd Ye g 2018-05-24 2047-2018 BankMobite Refund to Student 31,005.00 2018-05-24 2017-2018 COM Grad PLUS Loan 3 ~$16,799.00 2018-08-06 2018-2019 COM Direct Unsub Loan $21,134.09 2018-08-09 2018-2018 COM Grad PLUS Loan -$14,681.50 2018-08-09 2018-2018 COM Grad PLUS Loan $9,584.50 2038-08-09 2018-2019 BankMobits Refund to Student 14,681.50 tt 2018-09-24 2048-2019 Tuition Charge - Mad N2 $29,217.50 t 2019-01-02 2018-2019 COM Grad PLUS Loan -$8,083.50 1049-07-02 2018-2019 COM Grad PLUS Loan '; -$16, 181.50 2018-01-02 2018-2019 ‘COM Direct Unsub Loan t $21,134.00 2018-01-02 2018-2019 BankMobile Refund to Student 5 16,161.50 2019-03-01 2019-2020 Tuition Charge - Med N1 3rd Ye $29,675.00 2019-03-01 2019-2020 ‘Simulated Patient 3rd Year $475.00 2048-03-01 2019-2020 Life/Disabllity-2nd, 3rd & 4th $126.00 2079-03-01 2019-2020 Technology Fee - Med 3rd Year $375.06 2013-03-01 2019-2020 Health Care Fee - Med 3rd Yea $100.00 2019-03-01 2019-2020 Activity Fee - Medical $250.00 2019-07-01 2019-2020 COM Grad PLUS Loan 3 $25,105.00{ 2019-07-01 2019-2020 BankMobile Refund to Student 416,338.00 1 2019-07-01 2019-2020 COM Direct Unsub Loan4 | $22,234.00 I |! 2019-10-08 2018-2020 Tuition Charge - Med N2 429,675.00 | 2019-12-09 2019-2020 BankMabile Refund to Student 17,683.00 2020-01-27 2019-2020 COM Grad PLUS Loan 3 $24,993.00 2021-08-19 2019-2020 Collection Agcy Placement - NY 422,345.00 2021-08-19 2019-2020 Collection Agcy Placement - NY $22,345.00 2021-08-19 2019-2020 Collection Fees - NYIT 187,447.59 TOTAL AMOUNT DUE: $29,792.59 Pte iy ciser ek -) me be Spring 2023 $0.00 *Financial Ald eward(s) ore not guaranteed and subjectto all revitions in federal, state and institutional policies, availabill I of funds, changes In enrollment, eninimum grade requirements, housing status and timely supmisston of all required documentation. You must meet Satlsfa ctory Academic Progress (SAP) Fequitements at all times in order to recelve and retain financial ald,Name: Michael Park ‘Student (D: (> ‘Statement Date: 11/09/2022 Page 2 of2Please Check the Campus You Wil! Be Attending: \n a [x | Old Westbury J L| Arkansas NYIT College of Osteopathic gy Medieme oi" SMnegistration Form Academic Year: 2019-2020 Class Yosh 20Name Park. Michest Last First MiddleLast 4 digits of Social Security#_ <2 ~Marital Starus: [',]Single ‘ [| married [| Divorced [7] widowedGender: [Male /L] FameDate of Birth WMO (QD Legal state of Residence®’it Cc ‘lass. 2024 ALL MAM. WILL BE SENT TO THIS ADDRESS ADDRESSStreet 15 Winchell Smith DrCity, FarmingtonState, cT Zip_ogo32___Telephoue: (_860)371 8689 “Cell Phone #:(___}An case of emergency cantact: Alex Park 8602057722 BrotherName Telephone Number Relationshi}> Qo Active Cl Active Reserve [_] ReserveBranch: C) ne O Air Fores C] Marines CJ Coast Guard. [__]National Guard \\, Hispanio/Latino [1] Non-Hispanic/L-atinoBace(Ontional\ Black or African American Ol Hawaiian/Pacific Islander Cc White Asian American/Alaska Native EXHIBIT @By authorizing a registration or by dropping and/or aiding or withdrawing ex being dismissed from the coursce Tregistored for thi} semester, I ugree to be changed in assordonce with the schedule set forth in NYTT"s: caline catalogs and ayit.edu with respect to payment of mit ida and fees, refunds dropping and adding courses, and, ‘withdrawal and dismissal poticies andprccdures, 1 agree to be boned by this registration form and abids by ‘NYIT's rules and re/ ulations eet forth ip NYIT"s ontine YT catplogs and nyit.edu, | agree to pry my debi ta NYIT for any amounts dye for tuition and fees and ather chargos, If ra) y charges ae not paid when dux, [agree to pay NYIT all Sees and costs associated with the collectionoff delinquent sccaunt. In addition to payment of the princip a art 9, the additional include collection agnoy fees egastinmting 33 to 501 percent of the principal amount due if fees and costs may NYIT engages ecllection agency 10, ect payment; legal fees ‘the principal amount due if NYIT en|gages legal cannes! to collect payment; any and all interest of 33.3% of ; ny and all other costa asenciated with collection of the amount dus NYTT. [ understand: may aobligation the ontstencting belance at the {maximum legal rite allowed by law to pay comme or all of t{rese additional fees and costa amocinted with collection of my delinquent account, Certify that the information above Is true, culate and complete. 278 Signature NV Date “Zach Student agrees that, once admitted ta New York Institute of Technology College Permission to take photographs and videos of the student for publicity purposes during oftheOsteopathic Medicine, AITCOM, has the student's class, at class-related {inctlons, activities and events, and that NYITCOM shall be the exclusive owner and copyright holder of, and possessall right, title, and interest tol'all such photographs and video.NYITCOM at Arkansas State Unversity NYIT College of Osteopathic vfeaineP.O.Box 119 Northern Blvd., PO Box 8000State University, AR 72467 Serota Building-Rm 222Phone: 870-972-2786 Oid Westbury, NY 11568-2000Fax: 870-680-8800 Phone: 516-686-3932comoregistrar@nyitedu Fax: 516-686-3891 medicineregistrar@nyit.edu 

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