ANN is biased ZZZJJJ

"Ron Wanttaja" wrote in message
...
On Sat, 20 Dec 2003 14:05:34 -0500, "Larry Smith"
wrote:

"Ron Wanttaja" wrote in message
.. .
On Fri, 19 Dec 2003 15:20:54 GMT, I wrote:

On a side note, there has been some activity in the second Campbell
SnF
lawsuit...some papers filed by Zoom's attorney last week. More details
as
they become available.

Campbell's attorney has filed a "Request for Production" in the case.
This may be just a demand for Sun-N-Fun to answer their Interrogatories
(these were filed three-four months ago...curious they haven't done
so).

Most all the states have enacted the federal rules of civil procedure
into
their local procedure. Probably the pleading you're talking about is a
request for production of documents. It is ordinarily required that the
specific procedural rule is cited in the pleadings, as in "Pursuant to
FRCP
34, plaintiff requests production of the following documents:" (and then
vexatiously lists a horrendous volume of paperwork to retrieve and
produce
for the requesting party).

You nailed that one, Larry. Got a copy of the Request for Production. It
requests, among other things:

1. Copies of all board of directors' meeting minutes for the past four
years.
2. Any SnF document that mentions Jim Campbell or any of his businesses
either directly or indirectly.
3. Any documents relative to SnF's relationship with the city of Lakeland
4. Any documents concerning SnF's relationship with their security
company
5. All existing and deleted emails concerning Jim Campbell in any systems
owned or operated by any agents, servants, employees, officers, and
directors (don't know if this applies to volunteers)
6. Any correspondence between SnF and the Florida DMV regarding Campbell
7. Any correspondence with any agency of the US Government regarding
Campbell.
8. Any documents to any law enforcement agency regarding Campbell
(between
2000 and 2003)
9. Copies all canceled checks to the security provider
10. Copies of all can celled checks to the Florida DMV
11. Any reports generated by or received by SnF which in any way touches
on Jim Campbell or any of his business interests in the years 2000, 2001,
2002, and 2003.
12. Copies of all documents SnF will produce in trial
13. Copies of all documents that support SnF defenses.

(Summary of filing by J. Kuhn, P.A., 9 December 2003)

SnF is supposed to respond within 30 days.

Ron Wanttaja

Thanks for the report, Ron. It's nice to hear I got one right. Ah, watch
the defense lawyers amass their billable hours. Could this mean gate entry
fees at Sun'n'Fun will go sky-high?