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Federal Lawsuit
Woodward v. American University of Antigua

Count I | Count II | Count III | Count IV


Neal Simon and American University of Antigua(AUA)filed the
following lawsuit against a former student, Woodward.

These are the numerous frivolous claims filed by AUA!
AUA refused to produce any documentation to support their claims!
The Federal Courts refused counterclaims filed against AUA, by Woodward!
The Federal Courts and Dept. of Education both refused to sanction AUA!
(Neal Simon is the General Counsel and President for AUA!)

Neal Simon signed this statement under oath
"Being First duly sworn:
I, Neal Simon, am an officer of the American University of Antigua and its
general counsel. I have personal knowledge of the facts set forth in this complaint and,
having read the same, I hereby attest that each and every allegation contained herein is
true to the best of my knowledge, information and belief.
"

Lawsuit filed by Neal Simon and AUA.
Federal Court Orders.


Top | Count II | Count III | Count IV

COUNT I-Federal Trademark/Tradename Infringement (AUA lost this claim!)
Neal Simon and AUA claimed Woodward violated the
Lanham Act, 15 U.S.C. 1114
Federal Judges ruled in Court Orders:
"Woodward is not selling, distributing, or advertising any goods or services on his website and the website does not contain links to any commercial sites.
The Lanham Act therefore cannot be properly invoked in this case."


The Lanham Act applies to corporations.
Lanham Act, 15 USC 1125(a)
False designations of origin, false descriptions, and dilution forbidden
(1) Any person who, on or in connection with any goods or services, or any container for goods, uses in commerce any word, term, name, symbol, or device, or any combination thereof, or any false designation of origin, false or misleading description of fact, or false or misleading representation of fact"

AUA advertised ""Since AUA's inception, USMLE Step 1 first-time pass rates for all students is 80.6%".
The university's own data shows AUA students only have about a "43.7%" USMLE pass rate.
(AUA refused to produce any data to support their "80.6%" claim.)
AUA USMLE Pass/Fail Rates


"20 USC 1011a"
(a) Protection of Rights
(2)(D) students should not be intimidated, harassed,
discouraged from speaking out, or discriminated against;
(E) students should be treated equally and fairly; and
(3) Protected speech
The term “protected speech” means speech that is protected under the first and 14th amendments to the Constitution, or would be protected if the institution of higher education involved were subject to those amendments.

Federal Rules of Civil Procedure, Rule 11
By presenting to the court a pleading, written motion, or other paper—whether by signing, filing, submitting, or later advocating it—an attorney or unrepresented party certifies that to the best of the person's knowledge, information, and belief, formed after an inquiry reasonable under the circumstances: (1) it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation;
(2) the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law;
(c) Sanctions. (1) In General. If, after notice and a reasonable opportunity to respond, the court determines that Rule 11(b) has been violated, the court may impose an appropriate sanction on any attorney, law firm, or party that violated the rule or is responsible for the violation. Absent exceptional circumstances, a law firm must be held jointly responsible for a violation committed by its partner, associate, or employee.


This claim was an attempt by AUA to cover-up AUA's
incompetance and corruption.
Judges refused to sanction AUA for filing this frivolous claim! Note: The Federal Courts enjoined Woodward from stating:
"AUA conspires to commit fraud and violations of civil rights;"

This is a blatant attack on "FREE SPEECH"
and "Due Process" and fraud committed by Federal Court judges!
This is an example of how the courts protect universities and violate students!

Top | Count I | Count III | Count IV

COUNT II-Infringement Under the ACPA (AUA lost this claim!)
Neal Simon and AUA claimed Woodward violated the
Anticycbersquatting Consumer Protection Act,15 U.S.C. 1125
Federal Judges concluded in Court Orders:
"the evidence indicates that Woodward created the website exclusively as a means of expressing his anger and dissatisfaction with AUA and its medical program.
Therefore, there is no evidence supporting a finding that Woodward's conduct violates the ACPA."


This claim was another frivolous claim filed by Neal Simon(AUA).
The Federal Courts refused to sanction AUA for filing frivolous claims!

"20 USC 1011a"
(a) Protection of Rights
(2)(D) students should not be intimidated, harassed,
discouraged from speaking out, or discriminated against;
(E) students should be treated equally and fairly; and
(3) Protected speech
The term “protected speech” means speech that is protected under the first and 14th amendments to the Constitution, or would be protected if the institution of higher education involved were subject to those amendments.

Federal Rules of Civil Procedure, Rule 11
By presenting to the court a pleading, written motion, or other paper—whether by signing, filing, submitting, or later advocating it—an attorney or unrepresented party certifies that to the best of the person's knowledge, information, and belief, formed after an inquiry reasonable under the circumstances: (1) it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation;
(2) the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law;
(c) Sanctions. (1) In General. If, after notice and a reasonable opportunity to respond, the court determines that Rule 11(b) has been violated, the court may impose an appropriate sanction on any attorney, law firm, or party that violated the rule or is responsible for the violation. Absent exceptional circumstances, a law firm must be held jointly responsible for a violation committed by its partner, associate, or employee.


This claim was an attempt by AUA to cover-up AUA's
incompetence and corruption.
Judges refused to sanction AUA for filing this frivolous claim!
Note: The Federal Courts enjoined Woodward from stating:
"AUA conspires to commit fraud and violations of civil rights;"

This is a blatant attack on "FREE SPEECH"
and "Due Process" and fraud committed by Federal Court judges!
This is an example of how the courts protect universities and violate students!

Top | Count I | Count II | Count IV

COUNT III-Willful Violation of FERPA (AUA lost this claim!)
Neal Simon and AUA claimed Woodward violated the
Family Educational Rights and Privacy Act, 20 U.S.C. 1232g

Federal Judges concluded in Court Orders:
"Family Educational Rights and Privacy Act of 1974 fail to state a claim for relief as a matter of law."

That's right, "FERPA" only applies to schools, colleges, and universities, like AUA!

This is a list of private student names, USMLE, and GPA scores disclosed by AUA!

The Federal Courts knew this claim was frivolous during the first hearing!

The Court called AUA's FERPA claim "Ridiculous"

AUA accused Woodward of "Tortious Interference"
for publishing the private student records AUA disclosed!

The definition of "Tortious Interference" is
"intentional interference with contractual relations".

In an attempt to protect AUA for disclosing private student records
the Federal Courts enjoined Woodward from stating:
"AUA breaches contracts;"

AUA's student handbook states:
"PRIVACY RIGHTS
The University adheres to the mandates of the United States
Family Educational Rights and Privacy Act(FERPA)"


Example of the Court's ruling on Federal Laws:
FERPA, The Clery Act,
The Lanham Act, 20 U.S.C. 1011a,
and contract case law:


Ross v. Creighton University
957 F.2d 410-Court of Appeals 7th Cir. 1992
”basic legal relation between a student and a private university
or college is contractual in nature.
The catalogues, bulletins, circulars, and regulations of the institution
made available to the matriculant become a part of the contract”

Doherty v. Southern College of Optometry.
862 F.2d 570, 577, (6th Cir.1988).
"Catalogs, manuals, handbooks, bulletins, circulars and
regulations of a university may help define this contractual relationship."


Top | Count I | Count II | Count III

COUNT IV-Defamation:
- AUA students are sexually assaulted;
(AUA lost this claim!)

AUA claimed defamation for posting a news article about the sexual assault of an AUA student.
AUA admitted an AUA student was sexually assaulted.
AUA claimed "Tense". The only evidence AUA disclosed reads
" AUA student sexually assaulted!" Singular!
News article AUA tried to cover-up!


To protect AUA the Federal Courts lied in Court Orders:
"Woodward no longer states on his website that
"AUA students are sexually assaulted";
instead, he asserts:
"AUA student sexually assaulted."

AUA's own evidence proves Woodward never said "students"!

-AUA student pass rate for USMLE mmedical board exams is only 22.9%; (AUA lost this claim!)

AUA sued Woodward for publishing news articles,
documentation from Academic Medicine, and AUA's own student records concerning
United States Medical Licensing Exam(USMLE) scores.

News articles and Academic Medicine show that the USMLE pass rates
for the two medical schools on Antigua is only "22.9%"!

AUA testified and advertised an "80.6%" USMLE pass rate.
The other Antigua school,UHSA, advertised over a "90%" USMLE pass rate!
(90 + 80.6)/2 = 85.3% not 22.9%!)

The only evidence AUA produced shows what Woodward published.
"Antigua only has a 22.9% USMLE Pass Rate!"

AUA's own student records show AUA student USMLE pass rate is only "43.7%"!
AUA not only refused to produce any documentation to substantiate their claim, but
filed motions to quash subpoenas Woodward served to obtain
AUA's United States Medical Licensing Exam(USMLE) data.

The Federal Court granted all of AUA's motions to quash
to ensure the truth couldn't be discovered!

The Federal Courts lied in Court Orders:
Court Orders:

"Woodward no longer states that
"AUA's student pass rate for USMLE medical board exams is only 22.9%"
Instead Woodward states that
"Antigua only has a 22.9% USMLE Pass Rate!"


AUA's own evidence proves Woodward
never stated that AUA had a 22.9% USMLE pass rate!

"Antigua only has a 22.9% USMLE Pass Rate!"

The Federal Court lied in Orders to protect Neal Simon and AUA!

AUA and Neal Simon's defamation claim:
-"AUA agents are liars;" (AUA lost this claim!)

It has been proven "AUA agents are liars"!

AUA and Neal Simon's defamation claim:
-"AUA professors teach students wrong information;"
(AUA lost this claim!)

It has been proven "AUA professors teach students wrong information"!

-The locality of AUA is full of "rape, murder,
fraud, and government corruption."
(AUA lost this claim!)

Federal Judges concluded in Court Orders:

"Antigua, however, is not "concerning the plaintiff."
Moreover, Woodward presents evidence indicating that there is significant
rape, murder, fraud, and government corruption on Antigua."


Court Opinion and Order:


Top | Count I | Count II | Count III Count IV

The Federal Court enjoined the following statements:

"AUA falsifies its students’ grades"

"AUA routinely commits fraud upon its students"
"AUA conspires to commit fraud and violations of civil rights"
"AUA commits criminal activities reportable to the FBI"

Reference:
AUA Student Loans
Advertised USMLE Pass Rates
AUA Grading Policy


"AUA breaches contracts"

"AUA colluded with St. Joseph Hospital to
maliciously end [Woodward’s] career"


"AUA committed perjury"

Neal Simon, President and General Counsel for AUA
swore under oath that everything in their lawsuit was true!
AUA lost Counts I, II, III, and defamation claims in a sworn verified complaint!

This is just the beginning of the court documents that will be published on these claims....
Page Under Construction.