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The Squeeze: Primary Documents

The university billed Kevin aggressively for five months — billing statements, late fees, two "FINAL" notices threatening collections within 30 days. Kevin disputed in writing. The institution never responded, never followed through on its own deadlines, and went completely silent for fifteen months. Then Kevin filed a federal civil rights lawsuit. Thirty-five days later, the university sent the account to a collection agency.

These are the original financial documents, collection notices, and institutional responses — in chronological order.

Source Disclosure

All documents below are originals from Kevin Bass's own records — financial aid letters, collection agency correspondence, institutional emails, and billing ledgers obtained through a Texas Public Information Act response. They are also cited in the Third Amended Complaint, a public federal court filing.

Primary Documents

Billing Ledger — Spring 2024 (TPIA response) — 3 pages. The actual transaction-by-transaction account history showing the reversal-disbursement-rebilling sequence.

Billing Statements — Jan–Apr 2024 (TPIA response) — 16 pages. Five months of billing statements, past-due notices, and account holds — then silence.

Balance Notification Letter — March 20, 2024 — TTUHSC acknowledged the $24,366.56 balance and placed a hold.

"FINAL NOTICE PRIOR TO COLLECTION" — March 26, 2024 — 30-day deadline. They did not follow through.

"FINAL BILL Prior to COLLECTIONS" — April 19, 2024 — Second 30-day deadline. They did not follow through.

Internal Collection Policy (TPIA response) — 3 pages. TTUHSC produced this defensively to justify the collection referral. It says collections begin "within 30 days." They set that deadline twice in 2024 and did not follow through either time.


February 12, 2024 — The Balance Is Created

Two months after the dismissal, the Financial Aid office sent this letter. The scholarship was cancelled, the loan was returned to the federal government, and Kevin was left with a $24,316.56 balance.

FROM: Melissa Mullins, Financial Aid Advisor TO: Kevin Bass DATE: February 12, 2024

Dear Kevin,

We have received notice that you have withdrawn from the Spring 2024 semester. Whenever a student withdraws, whatever the reason, our office has federal regulations we need to follow. Below are the results of that process.

Federal Title IV Regulations require that the school determine how much financial aid a student has earned based on how many days the student attended the institution...

The amount returned is $3,524.00 net from your Federal Direct Unsubsidized Loan. Please be advised, the School of Medicine has also cancelled the spring portion of your scholarship in the amount of 20,118.11. The loan amount has been de-fed from your Spring 2024 tuition account and returned to the Federal Processor. You have a balance now due on your HSC Spring 2024 tuition account of $24,316.56.

The letter says Kevin "withdrawn." He did not withdraw. He was dismissed. The university processed the dismissal as a withdrawal for Title IV purposes, cancelled his scholarship, returned his loan to the government, and billed him the difference.

Line Item Amount
Scholarship cancelled $20,118.11
Federal loan returned to government $3,524.00
Balance billed to Kevin $24,316.56

What the Billing Records Actually Show

The Mullins letter frames the balance as a routine Title IV withdrawal calculation. The actual billing ledger — obtained through a public records request — tells a different story.

Date Transaction Amount
Dec 4, 2023 All Spring tuition/fees reversed −$10,200
Dec 24, 2023 Scholarship disbursed on schedule +$20,118
Dec 24, 2023 Federal loan disbursed on schedule +$3,843
Dec 27, 2023 Refund to Kevin (direct deposit) −$21,448
Jan 11–12, 2024 Full tuition/fees re-charged +$10,200
Jan 12, 2024 Scholarship reversed −$20,118
Feb 12, 2024 Scholarship posted then immediately reversed again $0 net
Feb 12, 2024 Federal loan reversed −$3,524
Mar 15, 2024 Late payment charge +$50
Final balance $24,366.56

The sequence: On December 4 — exactly one month after the emergency removal — TTUHSC reversed all of Kevin's Spring 2024 tuition charges. But the financial aid disbursement pipeline was not stopped. Three weeks later, his scholarship and federal loan disbursed on schedule into an account with no charges. The entire disbursement — $21,448 — was refunded to Kevin as excess aid.

Then, in January, the institution re-charged full tuition, pulled back the scholarship, and pulled back the loan. Kevin now owed $24,366 with no financial aid applied.

The institution created this debt through its own administrative sequencing. It reversed the charges, let the aid flow through as a refund, then re-billed without restoring the aid. The Mullins letter described none of this. It said Kevin "withdrawn."


January – April 2024 — Five Months of Active Billing

The Mullins letter was not a one-time notice. It was the beginning of a five-month billing campaign. TTUHSC sent repeated billing statements, applied late fees, and issued two separate "FINAL" notices threatening collection — each with a 30-day deadline.

Date Document
Jan 14, 2024 First Spring 2024 billing statement
Jan 29, 2024 Second billing statement (after tuition re-charged)
Feb 12, 2024 Mullins letter: $24,316.56 balance created
Mar 15, 2024 $50 late payment charge applied
Mar 19, 2024 Past Due statement: "Your account as of now is on hold for non-payment"
Mar 20, 2024 Balance notification letter: $24,366.56 confirmed, hold placed
Mar 26, 2024 "FINAL NOTICE PRIOR TO COLLECTION" — 30 days to pay or account goes to collections
Apr 19, 2024 "FINAL BILL Prior to COLLECTIONS" — second 30-day deadline

Two "FINAL" notices. Two 30-day deadlines. The institution was actively pursuing this balance.

"FINAL NOTICE PRIOR TO COLLECTION" — March 26, 2024 FROM: Patricia Castillo, Senior Analyst, TTUHSC Student Business Services

The unpaid charges are subject to be placed with a collection agency if not paid in full by 30 days of this notice.

"FINAL BILL Prior to COLLECTIONS" — April 19, 2024

FINAL BILL Prior to COLLECTIONS

Unpaid charges are subject to be placed with a collection agency, if not paid within 30 days from the date of this statement.


May 29, 2024 — Kevin Disputes in Writing

After the second "FINAL" deadline passed with no action, Kevin sent a written dispute to TTUHSC's Financial Aid office:

FROM: Kevin Bass TO: Financial Aid HSC (financial.aid@ttuhsc.edu) DATE: May 29, 2024

I never withdrew from Texas Tech. More than anything, I wanted to complete my medical education. The school expelled me. I was on a full scholarship, and this scholarship money was deposited into my account, and I don't believe I owe the school anything.

TTUHSC did not respond. It did not correct the withdrawal characterization. It did not adjust the balance. It did not send the account to collections. It simply stopped.


May 2024 – October 2025 — Fifteen Months of Silence

After five months of active billing and two "FINAL" notices, the institution went completely silent. No response to Kevin's dispute. No more billing statements. No collection referral. The $24,366.56 balance sat dormant for fifteen months.

During this period:

  • Kevin completed his PhD and was awarded a doctorate by TTUHSC (2024)
  • Kevin filed TPIA requests for his student records (October 2025)
  • TTUHSC quoted him $1,800+ to copy his own education records
  • Kevin filed preservation notices and cost complaints

November 5, 2025 — The Federal Lawsuit

Kevin Bass filed suit in the Northern District of Texas. Seven claims against eleven defendants — First Amendment retaliation, disability discrimination, due process violations. Case No. 5:25-cv-00244-H-BV.


December 10, 2025 — Thirty-Five Days Later

TTUHSC issued a "Final Account Statement" and referred the account to Williams & Fudge, Inc., a third-party collection agency based in Rock Hill, South Carolina.

The balance had grown from $24,366.56 to $30,458.20. No interest was charged. The additional $6,091.64 was labeled "Fees" — with no breakdown, no authority cited, and no explanation of how they were calculated.

The math: $6,091.64 ÷ $24,366.56 = exactly 25%. This is a collection agency percentage markup applied to the principal — not an institutional charge for services rendered. Kevin asked for the authority and line-item breakdown in six written communications. Neither TTUHSC nor Williams & Fudge ever provided one.

FROM: Texas Tech University Health Sciences Center Lubbock TO: Kevin Bass DATE: December 10, 2025 DELIVERED VIA: NoticeDrop (automated email notification, December 15, 2025)

Final Account Statement

Dear Kevin Bass,

This is your final account statement for Account R11333575. Your total balance is $30,458.20.

Principal $24,366.56
Interest $0.00
Fees $6,091.64
Total Balance $30,458.20

Please note that your account has been placed with our collection agency, Williams & Fudge, Inc. All future communications regarding this balance will come directly from them.

Five months of active billing. Two "FINAL" notices. A written dispute. Then fifteen months of silence. Then a federal lawsuit. Then — thirty-five days later — collections.


December 15, 2025 — Kevin Disputes Immediately

Within two hours of receiving the NoticeDrop notification, Kevin filed a written dispute with the collection agency. By the next morning, he had also disputed directly with TTUHSC.

FROM: Kevin Bass TO: Williams & Fudge, Inc. (consumerassistance@wfcorp.com) DATE: December 15, 2025 — 11:17 PM

I dispute this debt in full. This letter is a written notice of dispute and request for validation/documentation.

Please provide, in writing:

  1. The name and address of the current creditor and the basis for the claimed balance.
  2. A complete itemized accounting showing principal, fees, interest (if any), and how each amount was calculated.
  3. The term(s) charged and the dates of alleged enrollment/registration relied on for tuition liability.
  4. The authority for all fees (including any agreement, policy, or statute relied upon) and a line-item breakdown of the fees.

Pending verification, please confirm in writing that the account is coded DISPUTED and that all collection activity is paused while you obtain and provide validation.

FROM: Kevin Bass TO: TTUHSC Student Business Services (sbs@ttuhsc.edu) DATE: December 16, 2025 — 1:48 AM

I dispute the balance shown on the Final Account Statement dated 12/10/2025.

Please place a hold on collections activity and recall/suspend any placement with Williams & Fudge, Inc. pending verification.

Please provide, in writing:

  • Itemized account ledger showing each charge/credit/adjustment/reversal with term/semester identifiers and dates.
  • The term(s) charged and the basis for tuition liability you are applying (policy and the specific dates used).
  • Documentation and calculation for Fees: $6,091.64 (line-item breakdown and authority).
  • Any scholarship/aid posting and reversal entries for the billed term(s), with dates.

Please confirm in writing that (a) the account is marked DISPUTED, and (b) collection activity will be paused while you provide the above.

Over the next 24 hours, Kevin also:

  • Forwarded the dispute to named TTUHSC staff (Tabitha Baines, Karrie Anderson)
  • Requested enrollment verification from the Registrar
  • Called Student Business Services and was told the matter would be forwarded to Patricia Castillo
  • Filed a second written confirmation request with Williams & Fudge

Six communications in 24 hours. All in writing. All requesting the same thing: show me what I owe and why.


December 16, 2025 — Kevin Sends a Formal Dispute via FedEx

Not trusting email alone, Kevin sent a signed dispute letter to Williams & Fudge via FedEx with signature required.

FROM: Kevin Bass PhD MS TO: Williams & Fudge, Inc., 300 Chatham Ave, Rock Hill, SC 29730 DATE: December 16, 2025 METHOD: FedEx (Signature Required) RE: DISPUTE + REQUEST FOR VALIDATION — Account R11333575 / Notice 47002981

I dispute this debt in full. This letter is a written notice of dispute and request for validation/documentation.

Please provide, in writing:

  1. The name and address of the current creditor and the basis for the claimed balance.
  2. A complete itemized accounting showing principal, fees, interest (if any), and how each amount was calculated.
  3. The term(s) charged and the dates of alleged enrollment/registration relied on for tuition liability.
  4. The authority for all fees (including any agreement, policy, or statute relied upon) and a line-item breakdown of the fees.

Pending verification, please confirm in writing that the account is coded DISPUTED and that all collection activity is paused while you obtain and provide validation.

I request all communications in writing/email only.

ENCLOSURES: Copy of TTUHSC "Final Account Statement" dated 12/10/2025


December 18, 2025 — The Collection Agency Writes

Williams & Fudge sent their initial collection notice. The FDCPA-required disclosure confirmed the amount and gave Kevin until February 1, 2026 to dispute.

FROM: Williams & Fudge, Inc. (wfconsumer@wfcorp.com) TO: Kevin Bass DATE: December 18, 2025 — 6:39 PM

Williams & Fudge, Inc. is a debt collector. We are trying to collect a debt that you owe to Texas Tech University Health Sciences Center Lubbock.

As of December 10, 2025, you owed: $30,458.20
Interest charged: + $0.00
Fees charged: + $0.00
Payments/credits: - $0.00
Total amount of the debt now: $30,458.20

How can you dispute the debt? Call or write to us by February 1, 2026, to dispute all or part of the debt.

Kevin had already disputed — three days before this letter arrived.


December 19, 2025 — TTUHSC's Response

Four days after the dispute. Six written communications. One phone call. The institution's response:

FROM: Tabitha Baines, Associate Managing Director, Student Business Services TO: Kevin Bass DATE: December 19, 2025 — 3:33 PM

Mr. Bass,

Please file a dispute with Williams and Fudge so that they can mark it in the file as "disputed". They will provide you a itemized statement showing the outstanding changes.

Thank you

Tabitha Baines-Acs Associate Managing Director Student Business Services

Kevin had already filed the dispute with Williams & Fudge — four days earlier. Baines either did not read his emails or did not care. Instead of providing the itemized ledger Kevin requested, or pausing collections, or recalling the referral, the institution told him to take it up with the agency.


December 19, 2025 — The "Verification"

The same day Baines sent her response, Williams & Fudge claimed the debt was verified. The attached verification letter was signed by Patricia Castillo, Senior Analyst at TTUHSC.

FROM: Williams & Fudge, Inc. TO: Kevin Bass DATE: December 19, 2025 NOTICE ID: ES-152034 AGENT: Paul Irby

RE: KEVIN BASS

The following is a verification of the outstanding balance that was disputed.

Consumer KEVIN BASS
Creditor TEXAS TECH UNIVERSITY HEALTH SCIENCES CENTER LUBBOCK
Creditor Account R11333575
Total Outstanding Balance $30,458.20

I, Patricia Castillo, Senior Analyst at TEXAS TECH UNIVERSITY HEALTH SCIENCES CENTER LUBBOCK reviewed the account information set forth in this letter. I hereby verify the information herein, including the total outstanding balance, is accurate.

Signature: Patricia Castillo Date: 12-19-2025

Kevin asked four specific questions: What is the basis for the balance? How were the fees calculated? What terms and enrollment dates are you relying on? What authority supports the fees?

The "verification" answered none of them. Castillo signed a form letter confirming the number was correct. No itemization. No fee breakdown. No enrollment dates. No authority cited. Just: the balance is accurate.


December 19, 2025 — Kevin Files a TPIA Request

The same day, Kevin filed a Texas Public Information Act request targeting the collection decision itself — requesting the internal emails, collection placement packet, and Williams & Fudge contract.

FROM: Kevin Bass TO: publicinfo@ttu.edu DATE: December 19, 2025 SUBJECT: TPIA Request — Records re: TTUHSC Account R11333575 / Williams & Fudge placement

Requested records:

  1. Full student account ledger showing charges, credits, adjustments
  2. Collections placement packet/referral file sent to Williams & Fudge
  3. All internal notes (collection notes, call logs, dispute notes)
  4. All communications between SBS/AR and OGC and/or Williams & Fudge
  5. Contracts/SOW and written policies for Williams & Fudge collections
  6. Authorization and business justification for collection placement

What Their Own Policy Says

When Kevin filed his TPIA request for the collection records, TTUHSC produced its internal collection policy. They released it defensively — to suggest they followed standard procedure. Read it:

TTUHSC Internal Collection Policy (produced by TTUHSC in response to TPIA request)

Unpaid charges are subject to be placed with a collection agency if not paid within 30 days from the date of this statement.

Past due balances placed with a collection agency are subject to a minimum collection fee of 33⅓% of the balance.

The policy says collections begin "within 30 days." TTUHSC issued that exact 30-day warning twice — on March 26 and April 19, 2024. Both deadlines passed. The institution did not follow through. Kevin disputed on May 29. The institution went silent for fifteen months. Then Kevin filed a federal lawsuit. Then — and only then — collections began.

The institution produced this document to show it did nothing wrong. The document shows the opposite: they had a policy, they threatened to enforce it twice, they didn't, they waited for a lawsuit, and then they did.


The Pattern

Date Event Phase
Dec 4, 2023 TTUHSC reverses all Spring tuition charges Debt creation
Dec 24–27, 2023 Aid disbursed → $21,448 refunded to Kevin Debt creation
Dec 29, 2023 Kevin dismissed from medical school Debt creation
Jan 11–12, 2024 Tuition re-charged, scholarship + loan reversed Debt creation
Feb 12, 2024 Mullins letter: $24,316.56 balance created Active billing
Mar 15–26, 2024 Late fee, Past Due notice, balance notification, "FINAL NOTICE" — 30 days Active billing
Apr 19, 2024 "FINAL BILL Prior to COLLECTIONS" — second 30-day deadline Active billing
May 19, 2024 Second 30-day deadline passes — TTUHSC does not follow through
May 29, 2024 Kevin disputes in writing: "I never withdrew" Dispute
May 2024 – Oct 2025 No response. No bills. No collections. Complete silence. 15 months dormant
Nov 5, 2025 Kevin files federal civil rights lawsuit Protected activity
Dec 10, 2025 TTUHSC issues Final Account Statement + refers to Williams & Fudge 35 days after lawsuit
Dec 15–16, 2025 Kevin disputes immediately — 6 written communications in 24 hours
Dec 19, 2025 TTUHSC tells Kevin to take it up with the collection agency
Dec 19, 2025 W&F "verifies" debt without answering any questions

They billed actively for five months. They threatened collections twice. Kevin disputed. They stopped. They didn't respond to the dispute. They didn't adjust the balance. They didn't follow through on their own deadlines. Fifteen months later, Kevin sued. Thirty-five days after that, they followed through.


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