Julie Bernet Affidavit

August 13, 1999

This document was filed on April 12, 1996 during Ms. Bernet’s suit against Cleveland Chiropractic College. A jury awarded substantial damages but the case was subsequently settled for an undisclosed sum.

State of Missouri
County of Jackson

1. At the time I was being recruited by Cleveland Chiropractic College to enroll as a student, I based my decision to enroll upon my belief that the representations made to me by the admissions representative were true. Additionally, I relied upon the truth of the statements in CCC’s printed brochures, handbooks and other literature.

2. While visiting the college for the first time in 1990, I was advised by the CCC admissions representative that my clinical experience would involve treating sick and injured public patients who sought out chiropractic treatment at the clinic. The admissions representative seriously misrepresented the nature of the clinical experience. Contrary to her assurances that I would fulfill my clinical requirements with patients provided to me by the clinic I learned at the beginning of the seventh trimester that in fact I would have to round up friends and acquaintances so I could experiment on them and practice chiropractic manipulation. By this time I had already invested an enormous amount of time and money in this education and felt I was forced to remain. Had the admissions counselor been honest with me during the admission process and admitted that the clinic was merely a money making venture for the college, designed to force the students to drag in their friends and family and charge them for unnecessary manipulation, I would have never enrolled at this disreputable institution.

3. In particular, I was assured that when it came time for me to complete the clinical portion of my studies that I would be provided with an ample volume and variety of patients by CCC. The admissions representative stressed that my clinical experience at CCC would involve treating real patients that came to the clinic genuine physical problems including a wide variety of pathologies which would allow me to gain a diverse experience in the clinical setting. This was absolutely untrue. Once I had entered the clinic I found that the school rarely attracted legitimate patients with genuine physical problems that required the types of chiropractic treatments necessary for successful completion of my clinical requirements. The clinic was described to me as just that, a clinic where sick patients came for chiropractic treatment. it was never explained to me by the admissions I personnel that the clinic was a money making venture for Cleveland Chiropractic College and that the student was required to lure or entice friends and family into the clinic, and then charge them for chiropractic treatment which they did not need.

4. Contrary to the oral assurances of the admissions personnel and the written representations made in the college’s brochures such as deposition Exhibit 8 attached hereto as Exhibit 1, the Cleveland Chiropractic Clinic never provided an ample volume and variety of patients to the students. Rather, the vast majority of “patients” were really not patients at all. We were urged by the clinic director . . . to recruit any and everyone we knew into the clinic to practice chiropractic upon them, whether they needed it or not. At the suggestion of my supervising clinicians, most of my “patients” were, in reality, friends and family who I wanted to assist me in obtaining the necessary requirements for the clinic so I could graduate.

5. During my second visit to CCC but prior to my decision to enroll, I visited the CCC with my parents. During that visit we met with an admissions representative or counselor of CCC. My father is a college administrator and asked very specific questions about how I would fulfill the clinical requirements. The admissions representative made it perfectly clear that my clinical requirements would be satisfied by treating patients that the clinic provided me from the general public who came to the clinic with legitimate physical problems. My experience in the clinic proved these statements to be absolutely untrue. Sometime during trimester seven, I was advised for the first time that it would be my responsibility to lure my friend and family in so I could manipulate their necks and backs. The vast majority of the chiropractic treatment rendered in the clinic was being performed on the students’ friends and families, as myself and other students desperately sought volunteers that we could work on.

6. At the conclusion of the second meeting with the college’s admissions personnel I was given a tour of the clinic itself. My parents accompanied us on this tour which was conducted by the admissions personnel attempting to persuade me to enroll. At the time of the tour I was very curious as to the types of patients I would be treating in the clinic. The admissions representative assured me and said that I would be exposed to a wide range of patients who either walked in from the street or were referred into the clinic for public chiropractic treatment. I was repeatedly assured that the school would be responsible for recruiting and procuring a sufficient volume and variety of chiropractic patients for me to complete my training and education.

7. I was also told during my tour of the clinic that the waiting room was always full of patients waiting for the student clinicians to treat. Once I had reached the point in my education where I was involved in the clinic I found this to be completely untruthful.

8. One of the most basic functions a chiropractor performs on each patient is the taking of a physical. A physical involves conducting a detailed examination of the patient to assess the individual’s need, if any, for chiropractic treatment. In order to satisfy that portion of my clinical experience dealing with physicals, I was required to complete 20 physicals. Although the admissions representative represented that the school would provide these patients, I recruited 13 or 14 of the 20 patients that I did physicals on.

9. Because I did not know a large number of people in the Kansas City area with serious neck and back problems, I was frequently forced to recruit patients for treatment who did not have any serious neck or back problems. Once my friends arrived at the clinic I was always given the approval of the supervising clinicians to perform spinal adjustments. I frequently was allowed to adjust friends and acquaintances necks and back who were, at the time, experiencing no neck or back pain or problems. Deposition Exhibit 8 stated that “students are taught how to care about patients as well as how to care for them” which was not true. The focus of my clinical experience was that the staff clinicians constantly stressed the need for me to recruit patients off the street, namely, my friends and acquaintances. An inordinate amount of time and energy was focused on teaching me how to generate income for the clinic by recruiting friends and acquaintances into the clinic for treatment that they would not otherwise have needed or sought treatment for. . . .

10. I first became aware that I had been lied to concerning the clinical portion of the program shortly following my starting the student intern program. This was in the seventh trimester in school. This was the beginning of my last year of education or my third year.

11. The hearing committee was not comprised of neutral parties because Dr. Moore had already decided to find against me.

12. The due process committee would not allow me to have legal counsel present.

13. I was not allowed to attend the hearing and, if fact, I was not permitted to confront or question any witnesses. I did not even know who the witnesses were against me. I was forced to remain seated in the hallway while my expulsion hearing was going on.

14. I neither falsified nor altered records, but merely reduced the charge made by the clinic to a patient that I was forced to repeatedly drag into the clinic in order to satisfy my clinical requirements. This was a common practice at the clinic for students to reduce charges on patients they were forced to drag into the clinic unnecessary adjustments, which the college not only condoned, but encouraged, in order to generate revenue for the clinic.

15. After the expulsion, the financial burden that I was left with, my lack of prospects for redeeming my career as a chiropractor and the time I had spent training and the humiliation prompted me to attempt suicide.

16. At the time I was expelled, I had completed all of my requirements for graduation with the exception of a few clinical requirements.

17. At the time of my enrollment, I was shown a promotional brochure identical to the “View Book”, which is marked as Exhibit 1.

18. I agreed to the rules and regulations policies and procedures in the 1991-1992 School Catalog. I was never even given a 1994 or 1995 catalog and certainly received no consideration for any rules changes made by Cleveland. Nor have I have agreed to abide by rules and regulations drafted years after my enrollment.

19. I did not transfer to another chiropractic college because of my disenchantment and disgust with chiropractic. Contrary to the representations made by the admissions representative, I have learned through their clinic that CCC encourages unnecessary chiropractic manipulation. Had I have known-that true nature of operation of a chiropractic clinic I would have never enrolled.

I, Julie Bernet, first being duly sworn on my oath states that the above statements are true to the best of my knowledge and belief.

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This article was revised on August 13, 1999