Please be advised that there are known individuals that have been posting misleading and inaccurate information regarding Jose Bernardo Gutierrez de Lara School of Medicine on the Internet in various websites, and blog sites.

There are three individuals who have been identified.  These three nefarious persons are disgruntled employees who are seeking to harm the reputation of Jose Bernardo Gutierrez de Lara School of Medicine, it’s employees, the town where the school is located, Guerrero Mexico, it’s residents along with the medical school’s current students and future students.

Because of the unlawful postings, there has been a lawsuit filed in District Court for the Southern District of Texas Laredo District against these individuals.  Please see below.

Jose Bernardo Gutierrez de Lara School of Medicine Files a 2.5 Million-Dollar Lawsuit Against Anonymous Posters on Value MD and Network 54

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF TEXAS

LAREDO DISTRICT

MED SCHOOL GROUP, LLC and |

LARRY R. SANDS |

Plaintiffs, |

v. | CIVIL ACTION: 5:09CV61

|

JOHN DOES (1-100)                                    |

PLAINTIFFS’ ORIGINAL COMPLAINT

TO THE HONORABLE JUDGE:

COMES NOW, Med School Group, LLC Plaintiff (hereinafter Medical School) complaining of Defendants (hereinafter Does 1-100) and for just cause would show unto the Court as follows:

PARTIES

1. Plaintiff, Med School Group, LLC is a company that is organized under the laws of the State of Texas and has its principal address in Zapata County, Texas.

2. Plaintiff, Larry R. Sands is an individual, who is a citizen of the United States of America who has a residence in Zapata County, Texas.

3. Defendant, John Doe 1 is an unidentified individual who is believed to be a citizen of Mexico who is believed to be residing within the national border of the United States.

4. Defendant, John Doe 2 is an unidentified individual who is believed to be a citizen of Mexico who is believed to be residing within the national border of Mexico.

5. Defendant, John Doe 3, is an unidentified individual who is believed to be a citizen of the Bermuda who is residing within the Caribbean basin.

6. Defendant, Doe 4, is an unidentified corporation who is believed to be organized under the laws of the State of Washington but is operating as a Limited Liability Company under the State of Florida. (a/k/a ValueMD)

7. Defendant, Doe 5, is an unidentified corporation who is believed to be organized under the laws of the State of California. (a/k/a Net54)

8. Defendants John Does 6-100 are unidentified persons or companies, who acting individually or in concert with defendants have committed the acts complained of herein.

JURISDICTION

9. The Court has jurisdiction over the lawsuit because the cause of action or defenses thereto arises under 47 USC § 230 et seq. or its interpretation thereof.  Specifically, anonymous malicious and defamatory postings on forum internet sites have been posted.  It is believed that the residences from which the postings have occurred are in Mexico or the United States.  The defamation is directed at US citizens and companies.  The publication of the defamatory postings complained of herein is occurring in Republic of India.

10. The Court has jurisdiction over the lawsuit under 28 U.S.C. § 1332(a) (2) because the suit is between citizens of the various states and citizens of foreign states and the amount in controversy exceeds $150,000.00, excluding interest and costs.

CONDITIONS PRECEDENT

11. All conditions precedent have been performed or have occurred.

D. FACTUAL BASIS

12. Plaintiff Med School Group, LLC is a Texas company that owns the medical school “Jose Bernardo Guitierrez de Lara” which is located just across the Texas/Mexican border at Falcon Heights (hereinafter “Med School”) (Laredo District).

13. Plaintiff Larry R. Sands has been the chief operating officer of the Med School since its inception in 2003.

14. During the past years Med School has had students who attend the school.

15. The students who attend the Med School are typically foreign students.

16. Some of the students who attend the Med School at times have applied to US medical schools and have been unsuccessful in obtaining admission to the US medical schools.

17. Some of the students who attend the Med School are attempting to obtain a medical license in their home state (India) by attending a medical school in Mexico and completing the licensing requirements in their home state (India).

18. During prior years a series of employees Jose Rafael Bedolla, Miguel Bedolla and Victor Brooks (hereinafter Bedolla) operated and taught at Med School.

19. The persons were terminated for improper conduct or resigned.

20. On information and belief, the terminated Bedolla group has, anonymously, begun to publish internationally, false, defamatory and harassing postings on the internet forum sites ValueMD and Net54 in 2008-2009.

21. It is believed that ValueMD is a company or d/b/a created under the laws of the State of Washington and is believed to be listed as a LLC under the State of Florida.

22. It is believed that Net54 is a company or d/b/a created or located under the State of California.

23. The anonymous postings are believed to have been actually placed in Mexico or in the United States (persons posting are believed to be Mexican Nationals).

24. ValueMD and Net54 (a/k/a or d/b/a) are forum internet sites that post information for students and potential students about international medical schools (schools outside the United States).  These two forum sites do not target any US medical school hopefuls, but rather target Caribbean, Mexican, and international medical school students providing information about schools outside the United States.

25. The location (Foreign State or one of the 50 States or whether it resides inside the United States) of the internet service provider’s hardware is unknown.

26. As a result of the postings Larry Sands, individually and in his capacity with the Med School group began to lodge complaints with ValueMD and Net54.

27. As either a result of Med School complaints or due to technical issues the complained of defamatory and harassing postings were removed by ValueMD but not by Net54.  The defamatory and harassing postings were subsequently reposted and continue to this date.

28. The defamation and harassment complained herein of involves publication of the false and defamatory information and materials in the Republic of India.

29. Specifically, Med School has a recruiter who is contracted in the Republic of India.

30. Numerous seminars were scheduled and several hundred potential students had attended the previous seminars and had been recruited for next year’s class periods (2009-2010 school years).  As a result of the publication of the defamation and false and malicious materials in the Republic of India, more than 100 recruits withdrew their interest and intent to attend from Med School.  The recruits have made statements that the sole basis for their withdrawal from the Med School program was due to the defamatory statements posted of ValueMD and Net54 in the Republic of India.

31. A series of emails took place between Med School and ValueMD and Net54 regarding the defamatory materials requesting that the materials be removed as they were and are false and defamatory.

32. Counsel has provided correspondence to ValueMD and Net54 requesting their withdrawal of the harassing and defamation materials without the necessity of litigation.

33. As the direct and proximate cause of the publication in the Republic of India of the defamatory materials Med School has been damaged in reputation and has suffered economic damages.

E. CAUSES OF ACTION

34. Plaintiffs bring this cause of action for defamation.  Does 1-100 have conspired (self admitted) to cause economic damages by their unlawful and unconscionable conduct to the Plaintiffs.  Specifically, Defendants have systematically posted in the US (to be published in the Republic of India) false, defamatory, and harassing statements calculated (self confessed) to cause economic harm by holding the plaintiffs out in disrepute and in fact causing economic harm by the holding the plaintiffs in disrepute.  The defamatory publications are not subject to any exception and are defamatory as a matter of law.

F. DAMAGES

35. Plaintiffs seek direct compensatory damages and punitive damages commensurate with the conduct of the defendants and in accordance with the evidence adduced at trial.  The tuition per student lost is in excess of $25,000.00 (United States Dollars).  At this time it is believed that the conduct of the defendants has caused the loss of more than 100 recruits (more than $2,500,000 US Dollars).  Discovery is ongoing and Plaintiff would request the opportunity to supplement as is necessary in the future.

G. ATTORNEYS’ FEES AND COSTS

36. Plaintiffs seek their attorneys’ fees and costs, pre-judgment and post-judgment interest as provided for by law.

PRAYER

FOR THESE REASONS, Plaintiffs asks for judgment against the defendants, jointly and severally for the following: actual damages, punitive damages, prejudgment and postjudgment interest, costs of suit including attorneys’ fees as applicable, punitive damages commensurate with the evidence adduced at trial and commensurate with the conduct of the defendants, all other relief whether at equity or in law to which the Plaintiffs show themselves entitled.

Respectfully submitted,

WILLIAM MAXWELL, PLLC /S/

By: ___________________________

William Maxwell

FBN# 29889

SBN# 24028775

1300 McGowen

Houston, Texas 77004

(713) 739-0663 Telephone

(713) 621-1449 Telecopier

ATTORNEYS FOR PLAINTIFFS

The following identifies the three individuals and their known aliases that they have posted under as well as a list of the numerous IP addresses associated with their aliases.

It is important to note the nefarious individuals allege that they are “warning” prospective students when in fact they are spreading untruths, lies and falsehoods about Jose Bernardo Gutierrez de Lara School of Medicine.  These individuals, regardless of their handles, posted names or impersonations seek to hide their identities to conceal their unlawful and illegal conduct.

1) Miguel Bedolla

His posts on Network54 and ValueMD reveal that he uses many false names to conceal his true identity. All of his IP Addresses are revealed at the bottom of each post, and are being sent from several IP computers.

I know they are saying a lot more 205.188.116.131

Zee, you got me daydreamin’ 70.129.20.58

Barrister 70.238.69.5

Barrister – abogado 70.238.67.61

Thicken it a bit more 70.238.69.5

In support of Zee 75.24.67.150

Had dinner with a guy 70.255.168.76

You thought that the Zetas was all you had to worry about 70.255.168.76

Tiger Cheese 70.132.202.41

Transient on Hwy 83 205.188.116.131

The Thinker’ thinker 75.8.82.148

The Detective 70.238.67.61

The Yankee Gourmet 70.238.67.61

Rio Grande Guy 70.238.67.61

What? 70.238.67.61

The Artillery Guy who is a real investigator 70.254.69.96

The Big Ear 75.8.81.102

B de la Garza 71.149.162.68

B de la Garza 75.8.80.248

B de la Garza 75.32.92.143

B de la Garza 70.254.70.203

B de la Garza 70.255.172.37

B de la Garza 70.255.172.226

B de la Garza 70.254.65.173

B de la Garza 70.238.69.181

B de la Garza 70.251.192.179

B de la Garza 70.254.70.203

B de la Garza 70.255.172.37

B de la Garza 70.255.172.266

B de la Garza 70.254.65.173

B de la Garza 70.0.96.57

B de la Garza 70.238.69.181

B de la Garza 71.149.167.141

B de la Garza 75.8.81.211

B de la Garza 75.13.16.232

B de la Garza 70.251.192.179

B de la Garza 70.132.203.158

B de la Garza 70.129.23.218

B de la Garza 70.129.20.250

Tito Valdivia 70.254.70.169

Tito Valdivia 75.8.81.80

Anonymous-Moron 68.18.60.54

Wiltshire is back 71.149.167.141

Thanks to Google Earth 75.8.81.211

2) Victor Brooks

His posts on Network54 reveal that he uses many false names to conceal his true identity. All of his IP Addresses are revealed at the bottom of each post, and are being sent primarily from 5 of his IP computer addresses as noted below.

JBGDL Historian – IP# 68.18.60.127

JBGDL historian – IP# 68.157.6.29

Jab Jab – IP# 68.157.6.68

Jab Jab – IP# 68.157.6.68

JBGDL’s public defender Maxy Paxy – IP# 68.157.6.156

Observer from the side – IP# 68.157.6.156

LS WILTSHIRE – IP# 68.157.6.156

Jab Jab – IP# 68.157.18.73

JBGDL historian – IP# 68.157.18.73

Jab Jab IP# 68.157.18.217

JBGDL historian – IP# 68.157.18.217

Copier – IP# 68.157.59.109

Top Cat – IP# 68.157.59.101

Anonymous – IP# 68.210.2.60

LS Wiltshire – IP# 68.210.2.60

Looking on – IP# 68.210.2.60

Jab Jab – IP# 68.210.2.60

Edmund Dantes, Court of Monte Christo – IP# 68.210.2.60

JBGDL historian – IP# 68.210.4.35

JBGDL Historian – IP# 68.210.4.35

JBGDL apologist – IP# 68.210.4.35

The Truth – IP# 68.210.4.35

Jab Jab – IP# 68.210.4.113

Jab Jab – IP# 68.210.12.67

Jab Jab – IP# 68.210.12.208

Defrauded by JBGDL – IP# 68.210.12.208

L:S WILTSHIRE – IP# 68.210.12.178

Wow – IP# 68.210.12.208

Jab Jab – IP# 68.210.12.208

Jab Jab with uppercuts – IP# 68.210.12.208

JBGDL Historian – IP# 68.210.12.208

Jab Jab – IP# 68.210.16.122

ValueMD could close the threads but they cant stop swine flu – IP# 68.210.18.50

Anonymous – IP# 68.210.23.11

Jab Jab – IP# 68.210.23.38

JBGDL historian – IP# 68.210.23.176

All for exposing them – IP# 68.210.32.247

Jab Jab – IP# 68.210.32.247

JBGDL Historian – IP# 68.210.46.6

Jab Jab – IP# 70.152.209.215

Representative of unfaired ex JBGDL St. – IP# 70.152.209.215

JBGDL Historian – IP# 70.152.209.215

LS Wiltshire – IP# 70.152.209.215

Top Cat – IP# 70.152.209.122

JBGDL Historian – IP# 70.152.253.227

LS Wiltshire – IP# 70.152.254.173

ThE SWINE FLU WILL HELP ELIMINATE thE DE LARA SCAM – IP# 72.146.75.21

Jab Jab – IP# 72.146.75.159

JBGDL Historian – IP# 72.146.75.159

Anonymous – IP# 72.146.112.110

Observer of JBGDL ways – IP# 72.146.112.110

Zee Admirer – IP# 72.146.113.163

Zee Truth Admirer – IP# 72.146.113.163

Another Zee Admirer – IP# 72.146.113.163

Didn’t know better – IP# 72.146.113.163

Watching at the border – IP# 72.146.113.163

JBGDL Historian – IP# 72.146.113.159

Prospective JBGDL student – IP# 72.146.114.112

Jab Jab – IP# 72.146.114.200

JBGDL historian – IP# 72.146.115.207

LS WILTSHIRE – IP# 72.154.165.25

Jab Jab – IP# 72.154.165.70

Anonymous – IP# 72.154.165.233

re the $1,000 offer – IP# 72.154.173.57

Jab Jab – IP# 72.154.173.57

Jab Jab – IP# 72.154.173.64

Won’t be bullied – IP# 72-154.173.113

New JBGDL ADVERTISING – IP# 74.230.88.25

JAb Jab – IP# 74.230.88.128

Anonymous – IP# 74.230.88.128

JBGDL Historian – IP# 74.230.88.128

What A Howler – IP# 74.230.100.110

I have a Question JBGDL – IP# 74.230.100.110

Jab Jab IP# 74.230.100.110

JBGDL Historian – IP# 74.230.100.158

a Vindicted LS wiltshire – IP# 74.230.100.158

JBGDL admin – IP# 74.230.100.158

JAB JAB – IP# 74.230.100.158

JAB JAB – IP# 74.230.100.181

Jab Jab – IP# 74.230.100.181

68.157.33.13 (Zee truth, Really? Really?)

68.157.23.179 (Really, Really!, LS WILTSHIRE)

68.210.2.241 (Jab Jab)

68.210.32.69 (Jab, Jab)

68.157.3.121 (Jab Jab, Jab JAB, Observer, Fly on the Wall)

68.210.46.142 (Still Jabbing Larry, More Jabs in Larry TAIL)

72.154.165.70 (Jab, Jab)

72.146.113.228 (Jab Jab again, LS WILTSHIRE)

74.230.100.181 (JAB, JAB)

70.152.225.233 (Jab Jab, LS WILTSHIRE,  Ghost of King Kong)

70.152.207.72 (Jab Jab, Ex JBGDL STUDENT MINDING THEIR BUSINESS,  Ex JBGDL, JBGDL victim, JBGDL VICTIM, Almost duped by JBGDL, Little Larry boy)

Other known IP Addresses for Brooks

68.157.59.250, 68.157.33.237, 68.210.18.50, 68.157.59.101, 68.210.16.94, 72.146.75.21, 72.146.114.112, 72.146.75.21, 72.146.114.112, 72.146.113.133, 72.146.114.9, 70.152.209.89

The proper authorities in each country have been notified and investigation into the criminal conduct is underway. As for civil prosecution, litigation has already been initiated in the courts of the United States of America, Southern District of Texas. If you need the particulars, please let us know and we will provide you with the Court Name and Style of the pending litigation.

Below is just a sample from another student at another med school that Brooks taught at…  Victor Brooks main alias is Iswiltshire…

the bottom line is stop bashing, it obvious you dont like the school. By mentioning the AFB and the US embassy he is trying to show stability in the island. My god this is the worst case of bashing I have seen since the master basher (on almost all the forum) Iswilshire started posting.

People listen and listen good, the school is moving forward everyday, we are all studying and getting ready to take our tests. These people who post negative things all the time are trying to stop you from coming to St Martinus for some reason, they dont care about you or what you do, understand that. they only want to play games. If you subscribe to this type of trash your hurting yourself. I would visit the school and ask other students what they think, nothing is perfect, but the way these two jokers are posting you would think that the school is about to go under, its just not the case. Also im not cheerleading, im defending so dont even try to say im cheerleading.

Im sorry but this VMD site is a dangerous place to visit, there are predators all over this site. Its a shame and border line illegal. Now Iswiltshire will write a 4 page essay to discredit my post. so enjoy his molestation of the current situations at SMU. Im wondering actually if both of these people Doc and iswiltshire are working at a medical school that competes with SMU. By the way can you tell us where you work?

Id like to know your angle. we all would!!!!!!

Let see the game they play and run around they give us.

HYPERLINK “http://www.valuemd.com/members/docron.html”DocRon

Join Date: Dec 2003

Posts: 171

Downloads: 0

Uploads: 0

Member

These are but a few of many exchanges from various other students and schools from years ago that are found on the Internet.

3) Rafael Bedolla

In gathering documentation for the lawsuit, the following information has been discovered about Rafael Bedolla. His posts on Network54 and ValueMD reveal that he uses fictitious names to conceal his true identity.

Tumultuous Scum                                         148.221.172.22

Ztruth                                                             148.221.172.xxx

INDIA MINISTRY OF HEALTH EDUCATION   148.221.172.128

Larry Sandowsky, Medico Cirujano            148.221.172.79

Kerela Sherouck                                                148.221.172.128

Zverdad                                                         148.221.172.242

Vivoriba                                                         148.221.172.46

Wonderful Students at de Lara                     148.221.172.119

JBGDL Motto                                                148.221.172.47

don Juan de Lara                                       148.221.172.134

de Lara Defender                                                148.221.172.239

de Lara Defender                                                148.221.172.97

jbgdl defender                                                148.221.172.111

CVS                                                                  148.221.172.206

Sanguango Jr                                                148.221.172.206

LEW DIP                                                         148.221.172.154

Lew Dip                                                         148.221.172.228

Isaac Wallerstein, Ph.D                              148.221.172.63

J J Levine                                                         148.221.172.229

J J Levine                                                         148.221.172.144

Lew Dip                                                         148.221.172.46

J J Levine                                                         148.221.172.114

Gutierrez de Lara defender                              148.221.172.47

Roy Rogers                                                         148.221.172.1

KICK BUTT KID                                                148.221.172.131

Isaac Wallerstein, Ph D                              148.221.172.131

JBGDL SUCKS                                                148.221.172.35

Larry Sandowsky                                       148.221.172.51

J J Lavine                                                         148.221.172.27

JBGdL Defender                                                148.221.172.51

JBGdL Defender                                                148.221.172.145

Anonymous John Doe                              148.221.172.35

ZeeTruth                                                         148.221.172.49

Anonymous’s Dallas Lawyer                     148.221.172.158

Tumultous scum                                                148.221.172.87

Trivandum Patel                                                148.221.172.102

JBGL VICTIM                                                148.221.172.39

About JBGDL…Who is sorry now..?            148.221.172.39

Hollywood Star                                                148.221.172.112

Ztruth                                                                  148.221.172.183

Ztruth- A convicted Felon                              148.221.172.199

Ztruth- A convicted Felon                              148.221.172.207

Issac Wallerstein, PhD.                              148.221.172.11

Issac Wallerstein, PhD.                              148.221.172.220

Super Duie                                                         148.221.172.35

Lew DIP                                                         148.221.172.154

Official Complaint by Anonymous            148.221.172.207

Official Complaint by Anonymous            148.221.172.220

de Lara’s Professional Staff by Larry Sands, Medico Cirujano

148.221.172.205

I Love De Lara (uses vulgar lang.)            148.221.172.207

JJ Levin (..is so satisfying to write something BAD about De Lara..)                                                         148.245.230.1The Plot Thikens at the de Lara Law Soup 148.221.172.171

Ztruth, Ph. D.                                                148.221.172.108

zee Defender of zee Truth                              148.221.172.108

Rafael Bedolla                                                148.221.172.86

Rafa                                                                  148.221.172.6

De Keke scores!!!                                       148.221.172.220

Roger                                                                  148.221.172.220

zverdad                                                         148.221.172.253

Investigator z   (not the dumb one)            148.221.172.220

ztruth- can’t wait pendejo                              148.221.172.234

Lorenzo arenas                                                148.221.172.234

zverdad                                                         148.221.172.242

The proper authorities in each country have been notified and investigation into the criminal conduct is underway. As for civil prosecution, litigation has already been initiated in the courts of the United States of America, Southern District of Texas. If you need the particulars, please let us know and we will provide you with the Court Name and Style of the pending litigation.

Bedolla has also used the email aliases of  HYPERLINK “mailto:ideamanmd@yahoo.com” ideamanmd@yahoo.com.  This is an attempt to confuse and mimic the personal Internet identity of the Founder of the medical school in an effort to dupe the readers of these emails.  Various like emails have been sent out to staff members of the medical school and other individuals and organizations trying to make people believe the author of the email is someone other than Bedolla.  An investigation by Yahoo and AOL is underway for attempts at identity theft.

Jose Bernardo Gutierrez de Lara School of Medicine   has several accreditations and listings:

Foundation for Advancement of International Medical Education and Research (FAIMER)- This formal listing and the assignment of a code enables students to register for and take the USMLE Step 1, Step 2, and Step 3 examinations through the ECFMG – the Educational Committee for Foreign Medical Graduates. This organization also certifies foreign medical graduates for participation in the National Residency Match Program (NRMP) in U.S.

International Medical Education Directory (IMED)- IMED is the arm of FAIMER that provides the formal listing of those medical schools who are accredited by the appropriate government agency in the country where the medical school is located.

World Health Organization (WHO) - WHO in association with University of Denmark, Copenhagen recognizes credible Medical Schools worldwide in their AVICENNA directory. JBGdL’s application for this accreditation is in process.

Mexican Federal Government Recognition - S.E.P. is the Federal branch of the government that recognizes the medical school in Mexico as a degree granting entity that will allow graduates to achieve their Medico Cirujano degrees.

Mexican Tamaulipas State Government Recognition - S.E.P. is the Tamaulipas State branch of the government that recognizes the medical school in Mexico as a degree granting entity that will allow graduates to achieve their Medico Cirujano degrees.

If anyone has any additional queries, information or concerns, please contact our Attorney:

William Maxwell

1300 McGowen

Houston, Texas 77004

(713) 739-0663 Telephone

(713) 621-1449 Telecopier

The publications are defamatory as a matter of law, however; it is upon information and belief that the postings are being posted by members of the Bedolla group.

Pursuant to their advertising.

ValueMD and Net54 are affiliated in some manner according to ValueMD and Net54 advertisements however the exact relationship is unknown.

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF TEXAS

LAREDO DISTRICT

MED SCHOOL GROUP, LLC and |

LARRY R. SANDS |

Plaintiffs, |

v. | CIVIL ACTION: 5:09CV61

|

JOHN DOES (1-100)                                    |

PLAINTIFFS’ ORIGINAL COMPLAINT

TO THE HONORABLE JUDGE:

COMES NOW, Med School Group, LLC Plaintiff (hereinafter Medical School) complaining of Defendants (hereinafter Does 1-100) and for just cause would show unto the Court as follows:

A. PARTIES

1. Plaintiff, Med School Group, LLC is a company that is organized under the laws of the State of Texas and has its principal address in Zapata County, Texas.

2. Plaintiff, Larry R. Sands is an individual, who is a citizen of the United States of America who has a residence in Zapata County, Texas.

3. Defendant, John Doe 1 is an unidentified individual who is believed to be a citizen of Mexico who is believed to be residing within the national border of the United States.

4. Defendant, John Doe 2 is an unidentified individual who is believed to be a citizen of Mexico who is believed to be residing within the national border of Mexico.

5. Defendant, John Doe 3, is an unidentified individual who is believed to be a citizen of the Bermuda who is residing within the Caribbean basin.

6. Defendant, Doe 4, is an unidentified corporation who is believed to be organized under the laws of the State of Washington but is operating as a Limited Liability Company under the State of Florida. (a/k/a ValueMD)

7. Defendant, Doe 5, is an unidentified corporation who is believed to be organized under the laws of the State of California. (a/k/a Net54)

8. Defendants John Does 6-100 are unidentified persons or companies, who acting individually or in concert with defendants have committed the acts complained of herein.

B. JURISDICTION

9. The Court has jurisdiction over the lawsuit because the cause of action or defenses thereto arises under 47 USC § 230 et seq. or its interpretation thereof.  Specifically, anonymous malicious and defamatory postings on forum internet sites have been posted.  It is believed that the residences from which the postings have occurred are in Mexico or the United States.  The defamation is directed at US citizens and companies.  The publication of the defamatory postings complained of herein is occurring in Republic of India.

10. The Court has jurisdiction over the lawsuit under 28 U.S.C. § 1332(a) (2) because the suit is between citizens of the various states and citizens of foreign states and the amount in controversy exceeds $150,000.00, excluding interest and costs.

C. CONDITIONS PRECEDENT

11. All conditions precedent have been performed or have occurred.

D. FACTUAL BASIS

12. Plaintiff Med School Group, LLC is a Texas company that owns the medical school “Jose Bernardo Guitierrez de Lara” which is located just across the Texas/Mexican border at Falcon Heights (hereinafter “Med School”) (Laredo District).

13. Plaintiff Larry R. Sands has been the chief operating officer of the Med School since its inception in 2003.

14. During the past years Med School has had students who attend the school.

15. The students who attend the Med School are typically foreign students.

16. Some of the students who attend the Med School at times have applied to US medical schools and have been unsuccessful in obtaining admission to the US medical schools.

17. Some of the students who attend the Med School are attempting to obtain a medical license in their home state (India) by attending a medical school in Mexico and completing the licensing requirements in their home state (India).

18. During prior years a series of employees Jose Rafael Bedolla, Miguel Bedolla and Victor Brooks (hereinafter Bedolla) operated and taught at Med School.

19. The persons were terminated for improper conduct or resigned.

20. On information and belief, the terminated Bedolla group has, anonymously, begun to publish internationally, false, defamatory and harassing postings on the internet forum sites ValueMD and Net54 in 2008-2009.[1]

21. It is believed that ValueMD is a company or d/b/a created under the laws of the State of Washington and is believed to be listed as a LLC under the State of Florida.

22. It is believed that Net54 is a company or d/b/a created or located under the State of California.

23. The anonymous postings are believed to have been actually placed in Mexico or in the United States (persons posting are believed to be Mexican Nationals).

24. ValueMD and Net54 (a/k/a or d/b/a) are forum internet sites that post information for students and potential students about international medical schools (schools outside the United States).  These two forum sites do not target any US medical school hopefuls, but rather target Caribbean, Mexican, and international medical school students providing information about schools outside the United States.[2]

25. The location (Foreign State or one of the 50 States or whether it resides inside the United States) of the internet service provider’s hardware is unknown.

26. As a result of the postings Larry Sands, individually and in his capacity with the Med School group began to lodge complaints with ValueMD and Net54.

27. As either a result of Med School complaints or due to technical issues the complained of defamatory and harassing postings were removed by ValueMD but not by Net54.[3] The defamatory and harassing postings were subsequently reposted and continue to this date.

28. The defamation and harassment complained herein of involves publication of the false and defamatory information and materials in the Republic of India.

29. Specifically, Med School has a recruiter who is contracted in the Republic of India.

30. Numerous seminars were scheduled and several hundred potential students had attended the previous seminars and had been recruited for next year’s class periods (2009-2010 school years).  As a result of the publication of the defamation and false and malicious materials in the Republic of India, more than 100 recruits withdrew their interest and intent to attend from Med School.  The recruits have made statements that the sole basis for their withdrawal from the Med School program was due to the defamatory statements posted of ValueMD and Net54 in the Republic of India.

31. A series of emails took place between Med School and ValueMD and Net54 regarding the defamatory materials requesting that the materials be removed as they were and are false and defamatory.

32. Counsel has provided correspondence to ValueMD and Net54 requesting their withdrawal of the harassing and defamation materials without the necessity of litigation.

33. As the direct and proximate cause of the publication in the Republic of India of the defamatory materials Med School has been damaged in reputation and has suffered economic damages.

E. CAUSES OF ACTION

34. Plaintiffs bring this cause of action for defamation.  Does 1-100 have conspired (self admitted) to cause economic damages by their unlawful and unconscionable conduct to the Plaintiffs.  Specifically, Defendants have systematically posted in the US (to be published in the Republic of India) false, defamatory, and harassing statements calculated (self confessed) to cause economic harm by holding the plaintiffs out in disrepute and in fact causing economic harm by the holding the plaintiffs in disrepute.  The defamatory publications are not subject to any exception and are defamatory as a matter of law.

F. DAMAGES

35. Plaintiffs seek direct compensatory damages and punitive damages commensurate with the conduct of the defendants and in accordance with the evidence adduced at trial.  The tuition per student lost is in excess of $25,000.00 (United States Dollars).  At this time it is believed that the conduct of the defendants has caused the loss of more than 100 recruits (more than $2,500,000 US Dollars).  Discovery is ongoing and Plaintiff would request the opportunity to supplement as is necessary in the future.

G. ATTORNEYS’ FEES AND COSTS

36. Plaintiffs seek their attorneys’ fees and costs, pre-judgment and post-judgment interest as provided for by law.

PRAYER

FOR THESE REASONS, Plaintiffs asks for judgment against the defendants, jointly and severally for the following: actual damages, punitive damages, prejudgment and postjudgment interest, costs of suit including attorneys’ fees as applicable, punitive damages commensurate with the evidence adduced at trial and commensurate with the conduct of the defendants, all other relief whether at equity or in law to which the Plaintiffs show themselves entitled.

Respectfully submitted,

WILLIAM MAXWELL, PLLC /S/

By: ___________________________

William Maxwell

FBN# 29889

SBN# 24028775

1300 McGowen

Houston, Texas 77004

(713) 739-0663 Telephone

(713) 621-1449 Telecopier

ATTORNEYS FOR PLAINTIFFS

[2] Pursuant to their advertising.

[3] ValueMD and Net54 are affiliated in some manner according to ValueMD and Net54 advertisements however the exact relationship is unknown.

Primary mission of JBGdL is to provide an excellent educational program within an environment of discipline and commitment to produce compassionate and caring physicians and specialists.  

For prospective medical students who are uncertain if JBGdL is the optimal place to study medicine, we offer a mini-medical school experience on the campus of Guerrero. There are no fees for the program other than your travel and lodging expenses. The mini-medical school experience will be offered 4 times a year (March, June, September, and December) during the 3rd weekend of the month. A variety of lectures representing the basic sciences curriculum will be presented by the faculty between 10 am and 2 pm on Saturday and Sunday, along with sample examinations. Participants will have an opportunity to meet with the Dean, the faculty, and current students in an informal setting, and tours of the town will be provided. 

To sign up for the mini-medical school experience, or for any questions, please contact Dr. Cunningham at scunningham@delara.us.
]]> http://josebernardogutierrezdelaraschoolofmedicine.wordpress.com/2009/06/13/the-jbgdl-mini-medical-school-experience/feed/ 0 jbgdl http://josebernardogutierrezdelaraschoolofmedicine.wordpress.com/2009/06/13/calendar/ http://josebernardogutierrezdelaraschoolofmedicine.wordpress.com/2009/06/13/calendar/#comments Sun, 14 Jun 2009 04:09:32 +0000 jbgdl http://josebernardogutierrezdelaraschoolofmedicine.wordpress.com/?p=102 ]]> JOSE BERNARDO GUTIERREZ DE LARA SCHOOL OF MEDICINE 2009 ACADEMIC CALENDAR

Queen B

Does your school have the government behind it?

The Jose Bernardo Gutierrez de Lara School of Medicine is licensed and accredited by the government of Mexico.

lildoc

If I fly from New York what is the closest majar town i would fly to?

Jose Bernardo Gutierrez de Lara School of Medicine is  located one and one half hours from McAllen, TX.

SaraM

Whats the population in Guerrero?

Guerrero, the town where Jose Bernardo Gutierrez de Lara School of Medicine is located has approximately 5000 residents.

futuredoc

Are the costs of utilities comparable to the U.S.?

The costs of electricity in Guerrero, where Jose Bernardo Gutierrez de Lara School of Medicine is located, is significantly greater than in the US, but overall the cost of living is less.

pitbull20

What kind of restaurants are nearby?

There are several Mexican restaurants within walking distance of the Jose Bernardo Gutierrez de Lara School of Medicine.

jasonw

Will there be a dress code?

There is no specified dress code at Jose Bernardo Gutierrez de Lara School of Medicine; however, as a physician-in-training you are a professional and expected to dress accordingly. 

judy2009

What about passports and visas will need them?

If you are not a Mexican citizen, you will need a passport and visa to attend Jose Bernardo Gutierrez de Lara School of Medicine.

kittykat

What should students have when applying to your school?

The application and documents required for Jose Bernardo Gutierrez de Lara School of Medicine are listed on our webpage (www.delara.us). 

bigdaddy

Are there internet courses available for students?

No, Jose Bernardo Gutierrez de Lara School of Medicine is an on-site program.

JenniferP

Do you have internet access at your school?

Yes,  Jose Bernardo Gutierrez de Lara School of Medicine has wireless internet access in all classrooms.

Are you recognized by the Mexican Government?

Yes.  Jose Bernardo Gutierrez de Lara School of Medicine is recognized by SEP, Secretaria de Educacion Publica, at both the Federal, Mexico City, and State, Tamaulipas, levels of the Mexican Government.

Where is the school located? 

Jose Bernardo Gutierrez de Lara School of Medicin is located in Nueva 
Ciudad Guerrero, Tamaulipas, Mexico on the Texas/Mexico border, 2 
miles from the border.  We are one and one half hours north from 
McAllen TX. 

What is the Mini Med School Experience? 

For prospective medical students who are uncertain if Jose Bernardo Gutierrez de Lara School of Medicine is the 
optimal place to study medicine, we offer a mini-medical school 
experience on the campus of Guerrero.  There are no fees for the 
program other than your travel and lodging expenses.  A variety of 
lectures representing the basic sciences curriculum will be presented 
by the faculty between 10 am and 2 pm on Saturday and Sunday, along 
with sample examinations. Participants will have an opportunity to 
meet with the Deans, the faculty, and current students in an informal 
setting, and tours of the town will be provided. 

What is the tuition for your school? 

Because of our new partnership with an international organization, 
Jose Bernardo Gutierrez de Lara School of Medicine is offering, for a 
very limited time, the tuition of $26,000.  This does not include 
housing or clinical clerkships. 

How long is your program? 

The program at Jose Bernardo Gutierrez de Lara School of Medicine is 
four years. 

The first two years are spent on the main campus in Guerrero in the 
basic science courses and the last two years are spent in American 
Hospitals for the clincal science portion of our program. 

Is your school listed in IMED? 

Yes.  Jose Bernardo Gutierrez de Lara School of Medicine is listed in 
Faimer’s IMED.  Below is the link. 

https://imed.faimer.org/details.asp?country=649&school=&currpage=1&cn… 

Can I return to the U.S. to practice medicine with my medical degree? 

Jose Bernardo Gutierrez de Lara School of Medicine grants a Medico Cirujano degree that allow our graduates to return to the United States to practice medicine. All students must contact each individual State in which they want to eventually practice medicine and get the specific rules and regulations. 

Do you accept all foreign students? 

Jose Bernardo Gutierrez de Lara School of Medicine accepts all qualified students regardless of ethnic origin, sex, or national citizenship. 

Will I be able to get loans to come to this school? 

Jose Bernardo Gutierrez de Lara School of Medicine has arranged loans internally for students. Students cannot get formal loans from U.S. institutions until we have graduated two classes that will not occur in 2011. 

Do you still have to pass the USMLE tests? 

Yes. Jose Bernardo Gutierrez de Lara School of Medicine provides the instruction necessary to pass the required USMLE Steps 1, 2 and 3. 

Is there Internet access on the campus? 

Yes.  Jose Bernardo Gutierrez de Lara School of Medicine provides wireless Internet access on campus.

https://imed.faimer.org/details.asp?country=649&school=&currpage=1&cname=MEXICO&city=&region

=NA&rname=North+America&mcode=649420&psize=25

Our graduates can return to the US to work.

DID YOU KNOW – For 17,000 medical school spots, there are 47,000 applicants for each spot… Where do you fit in? At JBGdL our curriculum is focused on passing the USMLE… The first time.

Our first class started in Sept. of 2006… We have students ready to take Step 1 of the USMLE.

JOSE BERNARDO GUTIERREZ DE LARA SCHOOL OF MEDICINE is authorized by Secretaria de Educacion Publica (SEP) in Ciudad Victoria, Tamaulipas, Mexico to give instruction in English.