(Plaintiff's Response to Request to Produce by Defendant, 4 February 2004)

Sun-N-Fun also requested the names of advertisers who dropped their
advertising with ANN because of SnF's alleged transgressions. Allow me to
quote from Zoom's response:

"The names of the advertisers who were influenced not to advertise with the
Plaintiff s business as a result of the slander alleged in the complaint
a
....
"4] Pulsar Aircraft Co. in El Monte, California for $3,500.00."

(Additional and Amended Answers to Interrogatories, 3 Feb 2004)

Keep in mind that Campbell's lawsuit is based on actions taken by the
Fly-In during SnF 2002...and Campbell sued Pulsar that same week, claiming
they'd ordered advertising but hadn't paid for it.

Pulsar won that case, of course. But I don't really imagine Zoom will ask
them to testify in his behalf....

This has an odd echo in another area, where Zoom has identified an
individual as one who would attest to some of SnF's actions. Rumor has it
that this person had a falling-out with Zoom. Just speculation based on
one or two external signs. But it might be interesting, if SnF insists
that he be deposed.

There have been a couple of interesting filings in the past two weeks (a
Motion to Compel and a Consent Order), but I haven't got copies of them
yet. If there's anything interesting, I'll post it. I wouldn't be at all
surprised if these were filings made in an attempt to get admittance this
year. Could happen, depending on whether SnF's attorney wants to make the
Fly-In look "reasonable" to the judge and thus not fight the request.



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)