Your Honor, if I may quote Oswego Laborers' Local 214 Pension Fund v. Marine Midland Bank, N.A.

1995, The Court of Appeals held that to state a cause of action under GBL 349, a plaintiff must allege that the defendant's conduct was: (1) consumer oriented; (2) deceptive or misleading in a material way; and (3) that plaintiff suffered injury as a result. Mr. Morgan Martin personally received a brochure from CPU teeming with false information, and as a result of this false information Mr. Martin pursued education at CPU, leaving him in debt, with a diploma that is to quote the plaintiff Isnt worth the paper its printed upon. Your honor, this evening you have had a case played out in front of you from two stand points, these individual standpoints are those of a Mr. Morgan Martin, and those of the Cattaraugus Programming University; in this trial we have heard from six individuals, each of whom provided essential information as to whether and injustice has occurred. You first heard from Morgan Martin, the plaintiff who made clear the problems with CPU. You then heard from Mr. Jordan Phillips a former employee of CPU, who was able to divulge pertinent information describing their horrendous business practices. And finally from the plaintiff you heard from Dr. Chris Cringle, who informed us of CPUs false accreditation and exposed their shocking business practices. From the defense we heard from Dana Debtor who told us of the schools target group: people who are completely new to the college experience, then a Dr. Shannon Charlton, who did by omitting certain pertinent information regarding CPU, mislead Mr. Morgan Martin. Finally we heard from Casey Key, Mr. /Ms. Key whom offered a biased speculation as to Mr. Martins Failure at CPU. It is from these persons, we are able to understand all of the false practices and fallacious statements CPU made. These deceptive acts carried out through a string of false advertising and misdirection, under New York State General Business Law 349 are unlawful. The foremost example of this false advertising started with a glossy brochure that made its way to Mr. Martins home, created by

Dr. Charlton and Mr. Phillips, this brochure made numerous false claims intended to mislead potential students of the university, these are: that 95% of CPU graduates DID NOT receive computer-related employment or proceeded to a four-year institution within one year after graduation, misleading in that computer related employment merely means that employees use computers at their job, not specifically programming; that CPUs career placement office DID NOT find unpaid internships for all of its students - in fact, they were unable to give Mr. Martin an unpaid internship. Additionally, CPU courses were not taught by accredited computer science professionals who possessed the highest qualifications in their field, in fact many of the professors took ill-timed sabbaticals to get these degrees that they supposedly already had making it near impossible for a student to graduate in the expected two years; and finally, that CPUs tuition DID NOT offer an excellent value for a world-class education in that it was more expensive than many higher credited universities. Moreover CPUs target students as so aptly put by Mr. Jordan Phillips are those who arent the brightest bulbs on the porch, those an easy group to lie to, and according to Ms/Mr. Dana Dettor, Our students are generally the first in the family to go to college and every step forward is a new experience and getting the sons and daughters of former assembly-line workers into our technical programs. Finally while touring the campus Mr. Morgans questions where not only deferred but also never answered directly ((((not to mention the pot hole the bus to the university drove over on the campus leaving him with neck injuries)))), misleading him into believing that CPU was indeed an esteemed university (and judging from what we heard today we can safely assume the opposite). It is because of these deceptive business practices that we the plaintiff respectfully request a judgment against the Defendant of an amount in excess of $80,000, and a permanent injunction enjoining and restraining Cattaraugus Programming University from engaging in such false and deceptive business practices, in the advertising and marketing of its associates degree program; and for such other and further relief you and this court deem just and proper. Thank you your honor.