Zzzz Campbell's Second Lawsuit Against Sun-N-Fun Zzzz

[Ron Wanttaja]

For those who haven't heard, Jim Campbell has sued Sun-N-Fun for a second
time. The full text of the suit follows...some minor formatting and
spelling changes may have occurred during the digital conversion process,
and I have truncated the address block for the attorney involved.

This suit was filed with the Polk County Clerk of Court on 6/26/2003. There
have been dozens of additional pages filed since then by both parties
involved. These public records are available through the Polk County Clerk
of Court for a nominal fee. See:

http://www.polk-county.net/clerk/clerk.html

Those who wish to engage in this discussion are asked to not change the
"Subject" line of this posting, to allow simple filtering by those who have
no interest in this topic. Participants are also requested to trim down
unneeded quotes in their own postings.

Ron Wanttaja

--------------------------------------------------------------------


IN THE CIRCUIT COURT FOR THE TENTH JUDICIAL CIRCUIT
IN AND FOR POLK COUNTY, FLORIDA

JAMES CAMPBELL,
plaintiff

Vs. CASE NO. 53-2003CA-00 2626-0000-WH

SUN-N-FUN FLY IN, INC.,
Defendant

COMPLAINT
Comes now the Plaintiff, James Campbell, and sues the Defendant,
Sun-n-Fun Fly In, Inc. for money damages and for cause of action would
state:
[I]
JURISDICTION
[1] This is an action for damages that exceeds fifteen thousand
dollars ($15,000.00) exclusive of interest and cost.
[2] All statutory prerequisites, including all proper notices to the
Defendant, have been satisfied and meet by the Plaintiff prior to filing
suit.
[3] All acts subsequently alleged in the complaint occurred in Polk
County, Florida.

[II]
PARTIES
[4] The Plaintiff reiterates and reaffirms all allegations contained in
paragraphs one (1) through three (3) in this count as if included herein
verbatim.
[5] Jim Campbell is a private citizen, a resident of the State of
Florida and the owner, editor of "Aero-News Network," a news magazine of
general distribution dedicated to general aviation news.
[6] The Defendant, Sun-n-Fun Fly In, Inc. is a duly organized and
existing corporation under the laws of the State of Florida with it»s
principal place of business in Polk County, Florida.

[III]
LIBEL AND SLANDER
[7] The Plaintiff reiterates and reaffirms all allegations contained in
paragraphs one (1) through six (6) in this count as if included herein
verbatim.
[8] The Defendant conducted, managed, promoted and controlled a
weeklong public air show at the Lakeland Lender Airport in Lakeland,
Florida during a week in April 2002.
[9] The Defendant furnished the security personnel for said air show
through an organization known as D.S.I. Security Services, a non-
registered and inactive Florida corporation.
[10] The security personnel operated under the express direction of
the Defendant and at all times relevant to the facts alleged in this
complaint were the servant, agents and employees of the Defendant within
the ordinary course and scope of their employment.
[11] Prior to the air show in April 2002, the Defendant began a course
of conduct toward the Plaintiff to refuse the Plaintiff admittance to the
public air show due to the Defendant's animosity toward the Plaintiff
generated by the Plaintiffs criticism of the Defendants safety record at
prior air shows.
[12] The Defendant posted the Plaintiffs Florida drivers license
photograph and his personal drivers license information at all public
entrances and exits leading to and from said air show.
[13] Said photograph was visible to the public and all visitors
attending he air show which was the intent of the Defendant.
[14] In addition, the Defendant, through it's agents, instructed all
security personnel that the Plaintiff was not allowed into the air show
because he was a "trouble maker", "a terrorist" and '"wanted."
[15] The Defendants agents, servants and employees operating
within the course and scope of their employment and under the express
direction of the managerial personnel of the Defendant, told numerous
visitors to the air show when they inquired about the photograph that the
Plaintiff was "a known terrorist, a trouble maker and was wanted."
[16] These statements were witnessed and overheard by numerous
people, three of whom were advertisers to the Plaintiffs news magazine.
[17] The advertiser was even told by the agents and employees of the
Defendant that the Plaintiff was not only "wanted, but there was a reward
for him."
[18] These statements were patiently untrue and specifically
designed to injure the Plaintiffs reputation and credibility in the
aviation industry.
[19] The statements were made with actual malice and/or with a
reckless disregard for the truth.
[20] The statements accused the Plaintiff of the commission of both
Federal and State crimes and were libelous per se.
WHEREFORE, Plaintiff sues the Defendant for money damages.

[IV]
INVASION OF PRIVACY
[21] The Plaintiff reiterates and reaffirms all allegations contained in
paragraphs one (1) through twenty one (21) in this count as if included
herein verbatim.
[22] The publication by the Defendant of the State of Florida drivers
license photograph of the Plaintiff along with the drivers license
information for public consumption was done without the authority,
authorization or consent of the Plaintiff.
[23] The publication by the Defendant of the State of Florida drivers
license photograph of the Plaintiff coupled with the manner of said
publication, the conspicuous nature of the publication and the words used
to describe and define said photograph by the servants, employees and
agents of the Defendant constituted an invasion of the Plaintiffs privacy
and an infringement of his right to privacy.
[24] The publication held him us to public ridicule and was
published in a manner forbidden by State statute and in a manner
inappropriate for the photograph and for the benefit of the Defendant.
[25] The publication of said photograph and drivers license
information by the agents of the Defendant and at their express direction
and authority was done with malice and with the express purpose of
injuring and damaging the Plaintiffs reputation and credibility as a news
reporter.
[26] The publication of said photograph, the manner of publication
and the accompanying words were of such a nature a reasonable person
could foresee and knew or should have known would cause mental injury
and emotional pain to a normal a person of ordinary sensibilities.
WHEREFORE, Plaintiff sues the Defendant for money damages.

[V]
DAMAGES
[27] The Plaintiff reiterates and reaffirms all allegations contained in
paragraphs one (1) through twenty six (26) in this count as if included
herein verbatim.
[28] As a direct and proximate result of the actions and statements
and publications alleged heretofore in this complaint, the Plaintiff lost
business, advertisers, subscribers and revenue in his business; thus,
substantially reducing his income and profits.
[29] As a direct and proximate result of the actions and statements
and publications alleged heretofore in this complaint, the Plaintiff
suffered emotional distress, loss of reputation, credibility and standing
both in the general community and in the community of his profession,
suffered a diminishment of an enjoyment of life, pain and suffering,
economic loss, loss of credit and credit ratings and interference with his
profession as a professional newspaper reporter in the aviation industry.
WHEREFORE, Plaintiff sues the Defendant for money damages.

[VI]
JURY TRIAL DEMAND
[30] The Plaintiff demands a jury to try these issues when joined.

[VII]
PRAYER OF RELIEF
[31] The Plaintiff demands a money judgment against the Defendant
in an amount that would fully compensate him for his damages and
injuries caused by the Defendant.
[32] The Plaintiff specifically reserves the issue of punitive damages
against the Defendant until the completion of discovery in the case and
application to the Court pursuant to state law.
[33] The Plaintiff demands the imposition of statutory interest on
any judgment both pre and post judgment interest at the rate decreed by
state statute.
[34] For other and further relief to which the Plaintiff might be
entitled according to the law and the facts.


Respectfully submitted,
(Signed)
Phillip E. Kuhn, Esq.

[Ron Natalie]

"Ron Wanttaja" > wrote in message ...
> For those who haven't heard, Jim Campbell has sued Sun-N-Fun for a second
> time. The full text of the suit follows...some minor formatting and
> spelling changes may have occurred during the digital conversion process,
> and I have truncated the address block for the attorney involved.
>
I guess he felt that the local courts would be more friendly to him than
the Federal Court judge that told him to Govern (well, the judge really
said conduct) Yourself Accordingly last time.

[Ron Wanttaja]

On Thu, 2 Oct 2003 10:41:55 -0400, "Ron Natalie" > wrote:

>
>"Ron Wanttaja" > wrote in message ...
>> For those who haven't heard, Jim Campbell has sued Sun-N-Fun for a second
>> time. The full text of the suit follows...some minor formatting and
>> spelling changes may have occurred during the digital conversion process,
>> and I have truncated the address block for the attorney involved.
>>
>I guess he felt that the local courts would be more friendly to him than
>the Federal Court judge that told him to Govern (well, the judge really
>said conduct) Yourself Accordingly last time.

Well, the local courts haven't been any friendlier to him. Campbell or his
business entities (US AVIATOR, Airedale, Aero-Media, ANN, etc.) have been
involved in at least 27 lawsuits. Of the 27 I found records of, he's never
won a suit he's filed, and, of those filed against him, he's lost seven and
had the judge rule in his favor only once.

Campbell was the plaintiff in ten. He outright lost two, SnF #1 and the
Pulsar case. Of the remainder, three were apparently settled out-of-court,
one is ongoing (the new SnF case), two were dropped due to Campbell failing
to prosecute the case, one had the service quashed RAF), and one was
dismissed due to lack of jurisdiction.

[I didn't count his RAH-15 countersuit in this one, but, of course, 13 out
of the 15 defendants were dismissed.]

Campbell's record as defendant is worse. Of the 17, he lost seven outright
("Lost" as in the judge ruling that he owed the plaintiff money). One even
included a garnishment action against Campbell. Two were settled
out-of-court (in one, the Airedale bankruptcy, Campbell agreed to pay
$50,000). Others were dropped for various reasons.

His one victory was when a suit by an apparent vendor was dismissed with
prejudice: STAR PRESS & SPALDING PUBLISHERS vs. CAMPBELL, JAMES
KINDRED SPIRIT PRESS, Polk County case 2000SC-002167-0000-00.

Ron Wanttaja

[ChuckSlusarczyk]

In article >, Ron Wanttaja says...
>Well, the local courts haven't been any friendlier to him. Campbell or his
>business entities (US AVIATOR, Airedale, Aero-Media, ANN, etc.) have been
>involved in at least 27 lawsuits. Of the 27 I found records of, he's never
>won a suit he's filed, and, of those filed against him, he's lost seven and
>had the judge rule in his favor only once.

27!!! that's more then I thought he had and he has the nerve to berate me
because I threatened to sue G Conn LOL!!!


>Campbell was the plaintiff in ten. He outright lost two, SnF #1 and the
>Pulsar case. Of the remainder, three were apparently settled out-of-court,


"settled out of court" I guess by jaun the toadies reasoning zoom has
"successfully sued" 3 times which by the same jaun logic means... he lost....

>Campbell's record as defendant is worse. Of the 17, he lost seven outright
>("Lost" as in the judge ruling that he owed the plaintiff money). One even
>included a garnishment action against Campbell. Two were settled
>out-of-court (in one, the Airedale bankruptcy, Campbell agreed to pay
>$50,000). Others were dropped for various reasons.

Hmmm wonder what "logic" jaun would produce for those :-) zoom didn't lose
....Chuck lied. LOL!!! would seem jauns hero has feet of clay and is sue happy.
All this and zoom has the nerve to try and judge other people what a phoney . I
hope his advertizers start reading RAH so they can see the kind of person they
are enabling with their ad money. Wonder how they'll feel going to SnF knowing
the guy they are supporting with their ad money is sueing SnF.I for one won't
support any of his advertizers and I will tell them why if they ask.


>
>His one victory was when a suit by an apparent vendor was dismissed with
>prejudice: STAR PRESS & SPALDING PUBLISHERS vs. CAMPBELL, JAMES
>KINDRED SPIRIT PRESS, Polk County case 2000SC-002167-0000-00.

That's the one he'll toot all over the place .

Chuck S RAH-15/1 ret

"evil didn't prosper because good men spoke and evil is still nuts" anon

[Frank Hitlaw]

..
>

> >
> >His one victory was when a suit by an apparent vendor was dismissed with
> >prejudice: STAR PRESS & SPALDING PUBLISHERS vs. CAMPBELL, JAMES
> >KINDRED SPIRIT PRESS, Polk County case 2000SC-002167-0000-00.
>
> That's the one he'll toot all over the place .
>
> Chuck S RAH-15/1 ret
>
++++++++++++++++++++++++++++++++++++++++++++++++++ +++++++++++++++++++++++++++++=

Hey Chuck;

I know one case that he lost,the defendant didn't even have a
lawyer.He filed twice and went through five
attorneys.HAHAHAHAHAHA!!!!!
If you run into El Pollo Loco say hello for me.
Frank M.Hitlaw
Jakarta,Indonesia

[ChuckSlusarczyk]

In article >, Frank Hitlaw
says...

Hi Frank (my partner in the Great Chicken Heist)

Do you still have a copy of the lawsuit that zoom filed against you? I'd like to
have a copy for for a project I'm working on. I wonder if your suit was included
in the 27 that Ron W posted. Maybe there's more out there that we don't know
about. If he filed twice I wonder if that counts for 2 ? LOL!!!

Did he ever write about sueing SnF on ANN or is he keeping it a secret?

See ya

Chuck S RAH-15/1 ret aka "el Pollo Loco "

"evil didn't prosper because good men spoke and evil was still nuts" anon



> Hey Chuck;
>
> I know one case that he lost,the defendant didn't even have a
>lawyer.He filed twice and went through five
>attorneys.HAHAHAHAHAHA!!!!!
> If you run into El Pollo Loco say hello for me.
> Frank M.Hitlaw
> Jakarta,Indonesia

[Warren & Nancy]

Where-o-where is juan when you need him? Flying his BD-5J?

Warren

ChuckSlusarczyk wrote:

> In article >, Ron Wanttaja says...
> >Well, the local courts haven't been any friendlier to him. Campbell or his
> >business entities (US AVIATOR, Airedale, Aero-Media, ANN, etc.) have been
> >involved in at least 27 lawsuits. Of the 27 I found records of, he's never
> >won a suit he's filed, and, of those filed against him, he's lost seven and
> >had the judge rule in his favor only once.
>
> 27!!! that's more then I thought he had and he has the nerve to berate me
> because I threatened to sue G Conn LOL!!!
>
> >Campbell was the plaintiff in ten. He outright lost two, SnF #1 and the
> >Pulsar case. Of the remainder, three were apparently settled out-of-court,
>
> "settled out of court" I guess by jaun the toadies reasoning zoom has
> "successfully sued" 3 times which by the same jaun logic means... he lost....
>
> >Campbell's record as defendant is worse. Of the 17, he lost seven outright
> >("Lost" as in the judge ruling that he owed the plaintiff money). One even
> >included a garnishment action against Campbell. Two were settled
> >out-of-court (in one, the Airedale bankruptcy, Campbell agreed to pay
> >$50,000). Others were dropped for various reasons.
>
> Hmmm wonder what "logic" jaun would produce for those :-) zoom didn't lose
> ...Chuck lied. LOL!!! would seem jauns hero has feet of clay and is sue happy.
> All this and zoom has the nerve to try and judge other people what a phoney . I
> hope his advertizers start reading RAH so they can see the kind of person they
> are enabling with their ad money. Wonder how they'll feel going to SnF knowing
> the guy they are supporting with their ad money is sueing SnF.I for one won't
> support any of his advertizers and I will tell them why if they ask.
>
> >
> >His one victory was when a suit by an apparent vendor was dismissed with
> >prejudice: STAR PRESS & SPALDING PUBLISHERS vs. CAMPBELL, JAMES
> >KINDRED SPIRIT PRESS, Polk County case 2000SC-002167-0000-00.
>
> That's the one he'll toot all over the place .
>
> Chuck S RAH-15/1 ret
>
> "evil didn't prosper because good men spoke and evil is still nuts" anon

[Ron Wanttaja]

On 3 Oct 2003 03:13:52 -0700, ChuckSlusarczyk
> wrote:

>Do you still have a copy of the lawsuit that zoom filed against you? I'd like to
>have a copy for for a project I'm working on. I wonder if your suit was included
>in the 27 that Ron W posted. Maybe there's more out there that we don't know
>about. If he filed twice I wonder if that counts for 2 ? LOL!!!

No, I didn't count Frank's because I have found no data on it. His name
doesn't come up when I search the Polk County Clerk of Court's online
database (which only goes back nominally ten years). That was the source
of most of my information:

http://www.polk-county.net/clerk/clerk.html

This provides a basic summary of the papers filed in each listed case,
with, in some instances, a final listing of disposition.

A more interesting search engine is the Polk County public record site:

http://ori2.polk-county.net/wb_or1/or_sch_1.asp

Like the Clerk site, you have to search for business names ("Airedale",
etc.) as well. Or you can search for known defendants, such as "Pulsar".
This site has actual digital copies of the papers filed in many of these
cases, and a lot more, like tax liens.

Sometimes, cases from other counties get mentioned in papers filed in
Polk... that's how I found data on the lawsuit against Don Jones/Jim
Campbell/AVIATOR INTERNATIONAL and Transcontinental Printing vs. Airedale
Press.

This site is also handy to determine if a lawsuit against "James Campbell"
is indeed against Zoom.

Happy surfing. :-)

Ron Wanttaja

[Fastglasair]

>Frank M.Hitlaw
> Jakarta,Indonesia

Frank, Why is Indonesia the "hot bed" of credit card fraud in the world. My
company almost got stung for $5,000 because we were ignorant of the problem in
general and Indonesia specifically. Fortunately we stopped delivery JIT due to
some red flags which made me suspicious, then I did some checking.

[B2431]

>Where-o-where is juan when you need him? Flying his BD-5J?
>
>Warren
>

Flying his BD-5J in covert ops in Iraq?

As for Campbell wasn't he told he was persona non grata at SNF? If so his case
is going nowhere.

Dan, U. S. Air Force, retired

[Eric Miller]

"Ron Wanttaja" > wrote
> Polk County Clerk of Court's online > database (which only goes back
nominally ten years).

So that means 27 suits in 10 years.... or 2-3 per year? That's disgusting.
Someone so litigous has clearly lost their rights to sue.

Eric

[RobertR237]

In article >, Ron Wanttaja
> writes:

>
>This site is also handy to determine if a lawsuit against "James Campbell"
>is indeed against Zoom.
>
>Happy surfing. :-)
>
>Ron Wanttaja
>
>

A couple of interesting points about his suit against Pulsar. Campbell used
Sun-N-Fun as his personal serving ground even though he was banned from the
location. He still managed to have Pulsar served with his lawsuit against them
at the 2002 Sun-N-Fun event. The intent of course was to force them to pay up
since it would be cheaper than having to take the time and fly all the way from
California to Florida for the trial. I don't think he believed the owner of
Pulsar would fight it and would just pay up. Surprise, he was wrong and the
owner of Pulsar was not going to be intimadated by Campbell's stupid suit.
This was also one of the reasons that Sun-N-Fun had barred him, he had done
this before.


Bob Reed
www.kisbuild.r-a-reed-assoc.com (KIS Builders Site)
KIS Cruiser in progress...Slow but steady progress....

"Ladies and Gentlemen, take my advice,
pull down your pants and Slide on the Ice!"
(M.A.S.H. Sidney Freedman)

[Frank Hitlaw]

ChuckSlusarczyk > wrote in message >...
> In article >, Frank Hitlaw
> says...
>
> Hi Frank (my partner in the Great Chicken Heist)
>
> Do you still have a copy of the lawsuit that zoom filed against you? I'd like to
> have a copy for for a project I'm working on. I wonder if your suit was included
> in the 27 that Ron W posted. Maybe there's more out there that we don't know
> about. If he filed twice I wonder if that counts for 2 ? LOL!!!
>
> Did he ever write about sueing SnF on ANN or is he keeping it a secret?
>
> See ya
>
> Chuck S RAH-15/1 ret aka "el Pollo Loco "
>
> "evil didn't prosper because good men spoke and evil was still nuts" anon
>
>
>
> > Hey Chuck;
> >
> > I know one case that he lost,the defendant didn't even have a
> >lawyer.He filed twice and went through five
> >attorneys.HAHAHAHAHAHA!!!!!
> > If you run into El Pollo Loco say hello for me.
> > Frank M.Hitlaw
> > Jakarta,Indonesia
++++++++++++++++++++++++++++++++++++++++++++++++++ ++++++++++++++++++++++++++++++

Chuck;

His lawsuit against me was filed in Highlands County, Florida
Sebring is the County seat. He refiled with a second attorney I don't
remember the exact date but the original was filed in April 1993.I
have the originals and will send them to you when I get back to the
States toward the end of the month. In 1991 he filed assault and
battery charges against me in criminal court in Polk County,As with
civil suit he lost. The only reason that there was no assault was that
the cowardly SOB ran from me and I couldn't catch him.He even said
that he beat feet away from me in his rag.Or you might say as juan
does he picked up his skirt and ran away!!To quote a great chicken
thief "what a phoney".
Frank M.Hitlaw, Executive Assistant to El Pollo Loco (Far East
Division)

[Ron Wanttaja]

On Fri, 03 Oct 2003 18:41:56 GMT, "Eric Miller" > wrote:

>"Ron Wanttaja" > wrote
>> Polk County Clerk of Court's online > database (which only goes back
>nominally ten years).
>
>So that means 27 suits in 10 years.... or 2-3 per year? That's disgusting.
>Someone so litigous has clearly lost their rights to sue.

Well, that's 27 suits involving him, but he was the plaintiff in "only" a
bit more than a third of them.

However, when you add up the total number of people and companies who have
been sued by him or his companies, you do end up with about that many.

Not including the RAH-15 case, the list includes two managing editors of US
AVIATOR, at least five companies (or owners of companies) who were former
advertisers, several individuals or companies I don't recognize (Kropp
Enterprises, Bottom Line Sales, Steven Mann, Aircraft Refinishing Systems,
Harry Smiley). And Sun-N-Fun twice, of course.

Now, you add the RAH-15 case to that, and the totals come to:

Two managing editors (Ken Cooke and Laurel Ramey)
One other employee (Alan Staats, RAH-15)
Two associate editors (the position is merely a title, no salary or
employment is involved...RAH-15 defendants Vern Barr and myself
fall in this category. But as I've mentioned in the past,
I was never *asked* if I wanted to be an associate editor)
Eight former advertisers (Three RAH-15, counting Richard Riley/Berkut)
Nine other RAH-15 co-defendants.
Five individuals or companies I don't know well enough to classify.
One non-profit organization (Sun-N-Fun...twice!)

That's 28 people or companies that have had to defend themselves against a
lawsuit by Jim Campbell or his controlled companies. Most were dismissed
for lack of service, or lack of prosecution (e.g., Campbell filed the suit
and just walked away). Three settled out of court.

Ron Wanttaja

[Frank Hitlaw]

(Fastglasair) wrote in message >...
> >Frank M.Hitlaw
> > Jakarta,Indonesia
>
> Frank, Why is Indonesia the "hot bed" of credit card fraud in the world. My
> company almost got stung for $5,000 because we were ignorant of the problem in
> general and Indonesia specifically. Fortunately we stopped delivery JIT due to
> some red flags which made me suspicious, then I did some checking.
++++++++++++++++++++++++++++++++++++++++++++++++++ ++++++++++++++++++++++++++++++

Howdy Fast;

Don't really know I thought Nigeria was the champ in that arena.
This place is pretty poor (a policeman makes about $21 a month) as you
can guess and alot of people are out of work.They had a big economic
collapse a couple of years back.I think it must be like a prison lots
of folks with time to think up scams. Right now I have about 20
Indonesian Mechanics working for me. They are exellent workers and as
far as I can tell pretty honest. A supervisor of line maintenance for
Garuda Airlines the National carrier makes about $600 a month.I pay my
guys a starting wage of $1000 a month.When I walk through the Jakarta
airport I feel like a rock star.All the mechanics are handing me
resumes an

[Frank Hitlaw]

(Fastglasair) wrote in message >...
> >Frank M.Hitlaw
> > Jakarta,Indonesia
>
> Frank, Why is Indonesia the "hot bed" of credit card fraud in the world. My
> company almost got stung for $5,000 because we were ignorant of the problem in
> general and Indonesia specifically. Fortunately we stopped delivery JIT due to
> some red flags which made me suspicious, then I did some checking.

++++++++++++++++++++++++++++++++++++++++++++++++++ ++++++++++++++++++++++++++++++

Sorry my computer decided to post my response before I was
done!!!The finish was to be.
and want to talk to me kind of a strange deal.So far I haven't been
scammed too badly that I know of.If you ever need anybody looked at
just e-mail me.
Frank

[Ron Wanttaja]

On 03 Oct 2003 16:19:03 GMT, (B2431) wrote:

>As for Campbell wasn't he told he was persona non grata at SNF? If so his case
>is going nowhere.

On 03 Oct 2003 16:19:03 GMT, (B2431) wrote:

>As for Campbell wasn't he told he was persona non grata at SNF? If so his case
>is going nowhere.

You are correct, but his lawsuit isn't *directly* about to the banning.
There are some interesting aspects, both to his suit and to Sun-N-Fun's
response to it.

Before I go any further, allow me to issue my standard disclaimer: I am
not a lawyer; I do not have any legal training or background. I have not
received any information from any party directly involved in this lawsuit.
This layman's analysis is based on the public papers filed in this case.
For those who are not aware, I was sued myself by Mr. Campbell about five
years ago (dismissed for lack of service).

Anyway, I began this thread by posting, in its entirety, Campbell's newest
suit against Sun-N-Fun. Basically, Campbell claims that Sun-N-Fun posted
his driver's license photos at the security stations at all entrances to
the fly-in "... with malice and with the express purpose of injuring and
damaging the Plaintiffs reputation and credibility as a news reporter", and
that Sun-N-Fun, "...under the express direction of the managerial personnel
of the Defendant [Sun-N-Fun], told numerous visitors to the air show when
they inquired about the photograph that the Plaintiff was "a known
terrorist, a trouble maker and was wanted." [Plaintiff's Complaint, Polk
County case 53-2003CA-00 2626-0000-WH)

As far as the harm this alleged activity caused, Campbell claims that he
"...lost business, advertisers, subscribers and revenue in his business;
thus, substantially reducing his income and profits." He also claims
"...emotional distress, loss of reputation, credibility and standing," etc.

[Again, this is a layman's summary of a seven-page legal document. Readers
are encouraged to read the original suit themselves and come to their own
conclusions.]

Sun-N-Fun's "Answer and Affirmative Defenses" was filed about a month after
Zoom's suit. The first section contains their responses to the specific
claims Campbell made in his original filing. Most are flat-out denials,
but some have fascinating subtleties.

For instance, in his suit, Campbell states:

"[5] Jim Campbell is a private citizen, a resident of the State of Florida
and the owner, editor of "Aero-News Network," a news magazine of general
distribution dedicated to general aviation news."

Sun-N-Fun's response: "It denies that Plaintiff is the owner of "Aero-News
Network"...."

Huh? Do they know something *we* don't? :-)

Actually, I think this is more intended to force Campbell to establish the
nature of his operation, as he describes it as a "magazine" throughout the
filing. I expect most people assume a "magazine" is a print-type
publication.

Campbell also made this claim, which SnF denies:

"11] Prior to the air show in April 2002, the Defendant began a course of
conduct toward the Plaintiff to refuse the Plaintiff admittance to the
public air show due to the Defendant's animosity toward the Plaintiff
generated by the Plaintiffs criticism of the Defendants safety record at
prior air shows."

I suspect their denial of this statement means that SnF plans to present
the evidence that justified their banning Campbell. Campbell has the
uphill road of trying to prove the *motivation* for the banning in the face
of the documentation SnF has gathered to support its actions.

After stating denials for all 34 of Campbell's allegations, SnF's response
swings into the Affirmative Defenses. Some are interesting:

"35. Plaintiffs claims against Defendant are barred for Plaintiffs failure
to join an indispensable party, DSI Security Services."

DSI apparently was the contractor supplying security; SnF's point is that
any lawsuit regarding the behavior of the employees of *that* company
should include the contracting company as a defendant. A few paragraphs
later, SnF then claims "....Pursuant to Florida Statute § 768.81, Defendant
is not liable for the comparative fault of these other joint tortfeasors,
whether or not they are named as parties to this action."

Campbell's suit describes DSI Security as "a non-registered and inactive
Florida corporation." But it does seem logical that the company should
have been named as a co-defendant.

Just because a company is "a non-registered and inactive Florida
corporation" doesn't mean it's not still in operation; remember that
Campbell's own company was in that condition when he sued Sun-N-Fun the
first time. The way I understand it, it merely reflects whether the annual
paperwork and fees are paid. Campbell's inactive company was removed as a
plaintiff in SnF #1, but I don't know whether that would prevent such a
company from being listed as a co-defendant. I suspect the company owner
can be included, listed as "doing business as..."

Participation of DSI is vital to Campbell's case...that's why I'm surprised
that they weren't included in the original filing. After all, even if Zoom
has people who will say that a DSI employee told THEM that SnF instructed
them to make the claimed statements, that doesn't prove that SnF so
instructed them. Zoom needs DSI and its employees to testify to that.

As far as the posting-the-driver's license complaint, SnF basically claims
that the material is public domain, and it wasn't used for commercial,
trade, or advertising purposes. Because of Campbell's being banned from
the grounds, and the nature of the allegations against Campbell that led to
it, I can't see the courts objecting to the use of public-domain material
in an attempt to prevent his entrance to the site.

SnF's reaction to the alleged statements by DSI's employees is contained in
Tenth through the Fourteenth Affirmative Defenses, each claiming that the
claims are barred because some or all of the alleged statements....

"...is/are matters of opinion and are not actionable."
"...was/were made in good faith or for good motives.
"...Defendant or its agents had reasonable or probable cause to believe
that one or more of the alleged statements was/were true."
"...constituted fair comment."
"... was/were, in fact, true."

One would assume that SnF will be presenting evidence backing this up.
That should be interesting. One of Campbell's damage claims is that the
alleged actions of SnF damaged his reputation. He is a controversial
figure, and has been so for years. It seems like it would be hard for him
to point out exactly how the alleged SnF actions made his situation worse.
His history wasn't exactly a secret prior to SnF 2002, which SnF would have
no trouble proving.

On a related note, looking at SnF's various filings in this case, it looks
to me like SnF is going *hard* after Campbell's claims of having lost
subscribers, advertisers, and income.

For instance, in the Interrogatories, SnF demands circulation and
subscription information necessary to prove Campbell's claim of lost
income. Campbell has refused to provide this information, claiming it is
proprietary.

But unless he presents this data, it's going to be hard for him to prove he
suffered monetary losses. How is he going to prove that he lost
subscribers...unless he shows before and after subscriber lists? How is he
going to prove that he lost advertisers...without identifying which
advertisers he lost?

Subscription to ANN is free, so any loss of subscribers doesn't have a
direct financial impact. Since ANN is a web-based operation, there is no
provable subscription list anyway...a print publication will have receipts
from the post office showing magazines mailed. Any claim that alleged
actions by SnF were the direct cause of the loss of subscribers and
advertisers would have to show that the subscribers and advertisers had no
other source of information about Campbell's activities. You'll always
find individuals who haven't heard the stories, but I suspect most
potential advertisers have heard them.

In his suit, Campbell claims three advertisers heard the alleged comments.
He identifies them in response to SnF's Interrogatories. One is listed as
a Seattle area business that I haven't heard of (I live just south of
Seattle), but it's apparently in a type of aviation I'm not involved in
(couldn't find them on the web, but the name might be misspelled). The
other "two" advertisers are actually two people associated with a single
company. They both left that company right after the events in question,
so their status as advertisers is questionable.

As far as Campbell's claim that SnF's alleged actions caused ANN to lose
advertisers, remember Campbell's two recent lawsuits against kit companies
over advertising that they say they hadn't contracted for. Considering
that both these lawsuits were served at *that* particular SnF, how will
Campbell prove that any lost advertising was due to SnF's alleged actions,
and was NOT a reaction to what many consider bullying tactics by Campbell?

A final note: It does appear that the appearance of his driver's license
at SnF did generate a Zooming of massive proportions. In his response to
SnF's interrogatories, Zoom says he called DSI Security, the DMV, the
Lakeland City Attorney, the Lakeland Police Department, the Polk County
Sheriff, the "U.S. E.A.P. Association" (I presume this is actually the
EAA... doesn't Campbell read this stuff before it goes out under his
name?), the FAA Chief Counsel's office, the Regional Counsel for the FAA,
and "other people."

Most of those actually seem logical, but the EAA? The FAA Chief Counsel's
office? The FAA Regional Counsel? To me, it sounds more like he was
trying to generate trouble for Sun-N-Fun than address a grievance.


Ron Wanttaja

[ChuckSlusarczyk]

In article >, Ron Wanttaja says...

>As far as the harm this alleged activity caused, Campbell claims that he
>"...lost business, advertisers, subscribers and revenue in his business;
>thus, substantially reducing his income and profits." He also claims
>"...emotional distress, loss of reputation, credibility and standing," etc.


Ain't it amazing how he thinks he's been harmed after all the harm he's done to
others. Fact is he is responsible for his loss of reputation, credibility,
standing and finances. If he wasn't such a vindictive liar he could have had a
position in aviation other then that of which he now posesses.I hope the SnF
attorneys get to ask him some of the 100 questions on the zoom site .I would
love to see him explain the African food missions etc..


>Sun-N-Fun's response: "It denies that Plaintiff is the owner of "Aero-News
>Network"...."
>
>Huh? Do they know something *we* don't? :-)

Maybe zoomy found another deep pocket to finance him again.That could explain
why he's been behaving himself lately. In the old days he would have been
bragging up his lawsuit actually if he's so right why is he ashamed to write
about it on ANN?

>Actually, I think this is more intended to force Campbell to establish the
>nature of his operation, as he describes it as a "magazine" throughout the
>filing. I expect most people assume a "magazine" is a print-type
>publication.

Just like he always uses "we" when describing himself ,therefore a net posting
can become a "magazine". What a phony!!

>I suspect their denial of this statement means that SnF plans to present
>the evidence that justified their banning Campbell. Campbell has the
>uphill road of trying to prove the *motivation* for the banning in the face
>of the documentation SnF has gathered to support its actions.


That's the part that become fun to watch. zoomy got real shook when his days of
pretending to be a Dr. and the transcripts of his FAA hearing were introduced at
his bankruptcy hearing. I just might have to fly down to Florida to watch that
part of the trial. I could wear my "I was Zoomed and survived shirt" . :-)


>On a related note, looking at SnF's various filings in this case, it looks
>to me like SnF is going *hard* after Campbell's claims of having lost
>subscribers, advertisers, and income.
>
>For instance, in the Interrogatories, SnF demands circulation and
>subscription information necessary to prove Campbell's claim of lost
>income. Campbell has refused to provide this information, claiming it is
>proprietary.


That's when you know for sure he's got something to hide.


>But unless he presents this data, it's going to be hard for him to prove he
>suffered monetary losses. How is he going to prove that he lost
>subscribers...unless he shows before and after subscriber lists? How is he
>going to prove that he lost advertisers...without identifying which
>advertisers he lost?

It would be interesting to know what kind of numbers he gives potential and real
advertizers in determining the ad costs. I hope his advertizers are watching and
tracking how much bang for the buck their getting by advertizing with ANN.

> You'll always
>find individuals who haven't heard the stories, but I suspect most
>potential advertisers have heard them.

You'd think so but some still advertize and therefore become enablers for a
phony.

>
>In his suit, Campbell claims three advertisers heard the alleged comments.
>He identifies them in response to SnF's Interrogatories. One is listed as
>a Seattle area business that I haven't heard of (I live just south of
>Seattle), but it's apparently in a type of aviation I'm not involved in
>(couldn't find them on the web, but the name might be misspelled). The
>other "two" advertisers are actually two people associated with a single
>company. They both left that company right after the events in question,
>so their status as advertisers is questionable.


Well you gotta know ,in the world of jaun and jim if they said it it's true
..Therefore there were 3 advertizers.

>
>As far as Campbell's claim that SnF's alleged actions caused ANN to lose
>advertisers, remember Campbell's two recent lawsuits against kit companies
>over advertising that they say they hadn't contracted for.

He's still billing advertizers for ads they didn't order.He ain't changed a bit.

> Considering
>that both these lawsuits were served at *that* particular SnF, how will
>Campbell prove that any lost advertising was due to SnF's alleged actions,
>and was NOT a reaction to what many consider bullying tactics by Campbell?

Very interesting point but my guess that any lost advertizing was a result of
zoom's actions not SnF or anyone else. It's the same as when he lost advertizers
in US Aviator .People got sick of the lies about circulation and for his
reckless portrayal of the truth.

It would appear tht SnF is not going to "settle out" on this one and I hope not.

See ya

Chuck S RAH-15/1 ret


"evil didn't triumph because good men spoke and evil was nuts" anon

[RobertR237]

In article >, Ron Wanttaja
> writes:

>
>Anyway, I began this thread by posting, in its entirety, Campbell's newest
>suit against Sun-N-Fun. Basically, Campbell claims that Sun-N-Fun posted
>his driver's license photos at the security stations at all entrances to
>the fly-in "... with malice and with the express purpose of injuring and
>damaging the Plaintiffs reputation and credibility as a news reporter", and
>

What reputation and what credibility? Can't damage what he never had to begin
with.

Bob Reed
www.kisbuild.r-a-reed-assoc.com (KIS Builders Site)
KIS Cruiser in progress...Slow but steady progress....

"Ladies and Gentlemen, take my advice,
pull down your pants and Slide on the Ice!"
(M.A.S.H. Sidney Freedman)

[Frank Hitlaw]

Ron Wanttaja > wrote in message >...
> On 03 Oct 2003 16:19:03 GMT, (B2431) wrote:
>
> >As for Campbell wasn't he told he was persona non grata at SNF? If so his case
> >is going nowhere.

++++++++++++++++++++++++++++++++++++Snip++++++++++ ++++++++++++++++++++++++++++++

> Ron Wanttaja



Ron;

When I answered his claims against me I went to the Law library of
the Highlands County Court house. One of the folks working there
pointed an interesting little nugget out for me. Campbell mentioned
his usual nonsense obout numerous complaints ect, never was he
specific. Under Florida tort law you can ask for a "more definative
statement".Asking for exact dates, time and places along with who.
Like most of his B.S. he never answered with any substance and after
the case got stale and he ran out of attorneys it was dismissed. As
for the Assault case in Polk County he had a couple of his cronies lie
to the police about me touching him in a rude and insolent manner. I
tried to believe me if I could at that time got my hands on him there
would have been no doubt that he was assaulted,but he ran away.In the
time between the incident and my appearing in court he had some
disagreement with his witnesses.They suddenly came down with Campbell
induced amnesia and didn't remember anything about the action. The
States Attorney returned a finding of No Bill.The dozen or so times
that he called the police and tried to have me arrested(not counting
three times at SnF) are another story.
Frank M.Hitlaw The few, the proud, the sued.

[Ron Wanttaja]

On 5 Oct 2003 03:37:24 -0700, (Frank Hitlaw) wrote:

> When I answered his claims against me I went to the Law library of
>the Highlands County Court house.

Thanks, Frank, that was sufficient information. Found the case in the
Highlands County civil records, county case #93000102GCS.

http://www.clerk.co.highlands.fl.us/index_new.html

There were, indeed, three motions granted for counsel to withdraw.

Ron Wanttaja

[Richard Riley]

A minor correction...

On Sat, 04 Oct 2003 05:56:17 GMT, Ron Wanttaja >
wrote:

:Not including the RAH-15 case, the list includes two managing editors of US
:AVIATOR, at least five companies (or owners of companies) who were former
:advertisers, several individuals or companies I don't recognize (Kropp
:Enterprises, Bottom Line Sales, Steven Mann, Aircraft Refinishing Systems,
:Harry Smiley). And Sun-N-Fun twice, of course.
:
:Now, you add the RAH-15 case to that, and the totals come to:
:
:Two managing editors (Ken Cooke and Laurel Ramey)

Didn't Judy Wood ever sue?

:One other employee (Alan Staats, RAH-15)
:Two associate editors (the position is merely a title, no salary or
: employment is involved...RAH-15 defendants Vern Barr and myself
: fall in this category. But as I've mentioned in the past,
: I was never *asked* if I wanted to be an associate editor)
:Eight former advertisers (Three RAH-15, counting Richard Riley/Berkut)

We never advertised. Probably would have, but we were the
subject of a pre-emptive zooming.

:Nine other RAH-15 co-defendants.
:Five individuals or companies I don't know well enough to classify.
:One non-profit organization (Sun-N-Fun...twice!)

And, of course, he was sued by the Boy's and Girl's club.
That had to hurt.

:That's 28 people or companies that have had to defend themselves against a
:lawsuit by Jim Campbell or his controlled companies. Most were dismissed
:for lack of service, or lack of prosecution (e.g., Campbell filed the suit
:and just walked away). Three settled out of court.

Too bad it's not enough to get him classified as a vexatious
litigant.

[Ron Wanttaja]

On Sun, 05 Oct 2003 17:19:42 GMT, Richard Riley >
wrote:

>A minor correction...
>
>:Two managing editors (Ken Cooke and Laurel Ramey)
>
> Didn't Judy Wood ever sue?

No record of such in the online Polk County records.

>>Eight former advertisers (Three RAH-15, counting Richard Riley/Berkut)
>
> We never advertised. Probably would have, but we were the
> subject of a pre-emptive zooming.

Ah, my mistake then. I knew Chuck and Happy had advertised, and assumed
Berkut had as well. I suspect SnF used to advertise in the early days of
US AVIATOR, but didn't include them on my list.

>> One non-profit organization (Sun-N-Fun...twice!)
>
> And, of course, he was sued by the Boy's and Girl's club.
> That had to hurt.

Even more fun, one person is listed as a co-plaintiff with Campbell in a
suit he filed in March of 1993, and was listed as a co-defendant in a
lawsuit Zoom filed eight months later. Talk about blowing hot and cold....

In addition to the suit against Frank Hitlaw, I found another lawsuit that
had been filed against Campbell (The Printing House, Inc. vs. Airedale
Press, 1993). Campbell countersued, and they came to an out-of-court
settlement in December '93. The total count is now up to eleven suits with
Campbell or associated businesses as plaintiff, and 18 as a defendant.

One of the latter is a tentative. It was filed by a non-aviation entity
that had sued Zoom before, but I'm not entirely this one was against "the"
James Campbell. The first suit lists his business address, the second one
lists another address. But by that time US Aviator was closed down, and
the address listed on the filing may have been his home address.

On the other hand, the single case I listed as a "victory" because the suit
against him was dropped "with prejudice" may not have been correct. The
dismissal actually states the case had been "amicably settled." Sounds
more like another out-of-court settlement.

>>That's 28 people or companies that have had to defend themselves against a
>:lawsuit by Jim Campbell or his controlled companies. Most were dismissed
>:for lack of service, or lack of prosecution (e.g., Campbell filed the suit
>:and just walked away). Three settled out of court.
>
> Too bad it's not enough to get him classified as a vexatious
> litigant.

Tony gave me considerable insight into this sort of thing. Basically,
judges dislike making such findings (ruling that the suit is frivolous,
etc.) so they don't happen very often. Even when they rule against a
plaintiff, there's always a slight chance there might have been some
validity in the suit.

However, if it was to have been tried, it should have been done in 1993.
In that year, Campbell filed six different lawsuits. After that, he was
(mostly) in the defensive mode (the first suit against SnF, and the RAH-15
countersuit).

He's picking up steam, again, though: he's filed three lawsuits in the last
eighteen months.

Ron Wanttaja

[Scott Correa]

> :That's 28 people or companies that have had to defend themselves against
a
> :lawsuit by Jim Campbell or his controlled companies. Most were dismissed
> :for lack of service, or lack of prosecution (e.g., Campbell filed the
suit
> :and just walked away). Three settled out of court.
>
> Too bad it's not enough to get him classified as a vexatious
> litigant.


It might be enough to prove that he is filing SLAPP suits which have been
ruled
illegal. SLAPP stands for Strategic Litigation Against Private Parties.
These suits
were commonly filed by companies against persons to silence them as critics.

Might be worth a look.......