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

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

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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 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.

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

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

..



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

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

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.

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

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