Sign in, say "hi", ... and be welcomed.

Re: Torrey Trial

Postby Bob Kuczewski » Wed Jan 12, 2022 11:17 pm

The trial has been continued until mid March 2022.

The "Trial Call" will be on Friday March 18th, 2022.

The actual trial will begin on Monday March 21, 2022.
Join a National Hang Gliding Organization: US Hawks at ushawks.org
View my rating at: US Hang Gliding Rating System
Every human at every point in history has an opportunity to choose courage over cowardice. Look around and you will find that opportunity in your own time.
Bob Kuczewski
User avatar
Contributor
Contributor
 
Posts: 7534
Joined: Fri Aug 13, 2010 2:40 pm
Location: San Diego, CA

Re: Torrey Trial

Postby Frank Colver » Thu Jan 13, 2022 9:08 am

March 18 is my 87 B-day, may it bring you good results. :thumbup:

Frank
Frank Colver
User avatar
Contributor
Contributor
 
Posts: 1266
Joined: Tue May 24, 2011 11:21 am

Re: Torrey Trial

Postby Chris McKeon » Thu Jan 13, 2022 10:19 am

Hello Bob:

Bob I have already said this to You. But I sure hope that You have a good retirement policy from the Court system. Heck You have been, and it looks as if You will be working for the Court ling enough to call it a Career.

Well I so hope to see You. Frank, John , John who will be My Crew-Chief by the way.
Chris McKeon
User avatar
Contributor
Contributor
 
Posts: 609
Joined: Wed Jul 31, 2013 7:46 pm

Re: Torrey Trial

Postby Bob Kuczewski » Thu Jan 13, 2022 12:44 pm

Frank Colver wrote:March 18 is my 87 B-day, may it bring you good results. :thumbup:

Happy Birthday Frank (in case I forget under pressure of the trial).

March 18th is what they refer to as the "Trial call" date. That's when the parties appear to report to the judge. The first day of actual testimony will be on Monday, March 21st. The trial itself is expected to last about a week.

Chris McKeon wrote:Bob I have already said this to You. But I sure hope that You have a good retirement policy from the Court system. Heck You have been, and it looks as if You will be working for the Court long enough to call it a Career.

You're right. In September of 2014 I testified as an expert witness for a young woman who was badly injued while training with Air California Adventure. That started 7 years of retaliation for my testimony including this ongoing trial. It has become my career.

It is sad that the sport of hang gliding has become so corrupted and dysfunctional that this could happen. That's one of the things we're trying to fix at the U.S. Hawks. Thanks for supporting us with your membership and posts!!
Join a National Hang Gliding Organization: US Hawks at ushawks.org
View my rating at: US Hang Gliding Rating System
Every human at every point in history has an opportunity to choose courage over cowardice. Look around and you will find that opportunity in your own time.
Bob Kuczewski
User avatar
Contributor
Contributor
 
Posts: 7534
Joined: Fri Aug 13, 2010 2:40 pm
Location: San Diego, CA

Re: Torrey Trial

Postby Craig Muhonen » Thu Jan 13, 2022 3:39 pm

Continued again? well 90 days seems like a life time. San Diego just keeps piling it on, and on and on. , In fact, you should submit a motion right away for a change of venue, the jury pool around there has been severely tainted in my opinion. After the trial, I think you should move to Texas, and get back into some "free flyn'".
Remember this to Sam Kellner in S. W. Texas?
A video by Robin Hamilton
https://www.youtube.com/watch?v=uj51Y0FdeJg


You posted this
:clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap:
:clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap:
:clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap:
:clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :clap: :thumbup:

We had a word in the Marines, "BOHICA", Bend Over, Here It Comes Again.

I think that you may have THEM by the "short hairs", because I don't see you bowing down. "just don't pick up the soap". ha . :srofl:
======================================================================================================================================


.
"grow brave by reflection". And invincible with written words.
Craig Muhonen
User avatar
Contributor
Contributor
 
Posts: 648
Joined: Tue Nov 05, 2019 9:58 pm
Location: The Canyons of the Ancients

Re: Torrey Trial

Postby Bob Kuczewski » Tue Feb 01, 2022 2:01 am

Update to front page:

I added the Complaint (second amended), Answer, Cross Complaint, and Cross Complaint Answer to the first post. I will try to add additional documents to that first post so that they can be easily found.

These are the documents added today:

    37-2015-00015685-CU-DF-CTL_ROA-224_09-04-19_Second_Amended_Complaint_1637640382170.pdf
        Complaint by Marien, Jebb, and ACA against Kuczewski (4.61 MiB)

    Answer_to_First_Amended_Cross-Complaint.pdf
        Answer by Kuczewski to Complaint by Marien, Jebb, and ACA (61.41 KiB)

    37-2015-00015685-CU-DF-CTL_ROA-14_08-12-15_Cross_Complaint_1637639427559.pdf
        Cross Complaint by Kuczewski against Marien, Jebb, and ACA (251.14 KiB)

    37-2015-00015685-CU-DF-CTL_ROA-13_08-12-15_Answer_1637639426622.pdf
        Cross Complaint Answer by Marien, Jebb, and ACA to Cross Complaint by Kuczewski (139.34 KiB)
Join a National Hang Gliding Organization: US Hawks at ushawks.org
View my rating at: US Hang Gliding Rating System
Every human at every point in history has an opportunity to choose courage over cowardice. Look around and you will find that opportunity in your own time.
Bob Kuczewski
User avatar
Contributor
Contributor
 
Posts: 7534
Joined: Fri Aug 13, 2010 2:40 pm
Location: San Diego, CA

Re: Torrey Trial

Postby Bob Kuczewski » Tue Feb 01, 2022 2:15 am

Thirty Three Causes of Action

These are the causes of action from the Second Amended Complaint by Marien, Jebb, and ACA:

IV. FIRST CAUSE OF ACTION
INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE
[Plaintiffs ROBIN MARIEN and AIR CALIFORNIA ADVENTURE, INC.
as to Defendants ROBERT KUCZEWSKI and MARJORIE MAE HOLLAND]

V. SECOND CAUSE OF ACTION
INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE
[Plaintiff GABRIEL JEBB as to Defendant ROBERT KUCZEWSKI]

VI. THIRD CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN, GABRIEL JEBB, and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

One example only of Eagle’s writing of or about Plaintiffs is the following posted on ushawks.org on May 9, 2015:
The Torrey Pines Ridge RATS ~ Well Known for posing as pilots while (sic) travelling the World.

The DEA, the Narcotics Department, and Homeland Security have been caught with (sic) there Pants Down, Hence there (sic) poor attitude.
Bashing their Own organisation (sic) and tolerating there (sic) Own Corruption.
The dealers operate right under there (sic) noses and are Laughing and Bragging About it.
Makes the entire Torrey Pines Gliderport look like fools at the risk of everyone's Lives.

We the People have Known about it for Years
~ They're above the Law and Yet still CRIMINALS ~


For his part, KUCZEWSKI replied on May 17, 2015:
“Your post sums it up perfectly!!!”


VII. FOURTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(A) On October 24, 2014:
“Here in San Diego, paraglider crashes are often reported by the press as “hang glider” crashes. I wonder where they get that information? Imagine that you’re a reporter doing a story on a rescue. Who are you going to call? The only public number for the Torrey Pines site is the concessionaire itself. Hmmm... So why do you think the press might be continually reporting paragliding crashes as “hang gliding” crashes?”


VIII. FIFTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(B) On November 11, 2014:
“My friend arrived just about the time that I tied the glider to the roof of my van. I’d been thinking long and hard about the choice in front of me. I thought about all the times that David Jebb and Gabe Jebb and Robin Marien had bullied people and threatened them with arrest. I thought about how they’ve always gotten away with it because everyone in the past (including myself) had always backed down. Then I thought about Rosa Parks. The choice was clear: I spent the good part of the evening and into the next morning in jail. It was an extremely unpleasant experience, but I accepted it as the price of justice.”


IX. SIXTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(D) On May 4, 2015:
“This is what you’re up against. Robin and Jebb were at the mafia table having lunch. Robin drives away with David Jebb, in a Red Corvette....The Godfather.”


X. SEVENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(E) On June 13, 2015:
“There have been numerous reports of paragliding being used as a “poor man’s air force” for both legal and illegal purposes. Uses include drug smuggling, surveillance, and law enforcement. It’s been long suspected that segments of the paragliding community are involved with some of these legal and/or illegal aspects of the sport. This has particular relevance to hang gliding since it may explain why the sport of paragliding seems to have a “protected” status at places like Torrey Pines and USHPA.”


XI. EIGHTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(B) June 7, 2011:
“My name is Bob Kuczewski and I have spoken here many times. Today, I am here to give voice to Lynne Perry who took her own life earlier this year. I had asked to feature Lynne in our newsletter and this was her reply: ‘Bob, thanks for thinking of me, but I need to decline at this time. I have been the victim of much bullying by some of the in pilots. I’m very selective as to who I fly with and I will leave a site if certain other pilots are there. Two years ago, I rarely left my home and did not fly for a period of five months due to fear of a vicious verbal assault by Josh Gelb during a club event. This was not an isolated event, just the final proverbial straw. The fact that the other pilots just stood by and let it happen led me to believe that they supported such behavior. I am still not emotionally healed and need to stay incognito as much as possible. You may have noticed that I do not post on the SDHGPA forum even though I am the owner. These days I typically fly with a hang glider pilots and only a select few paraglider pilots. Blossom is my passion and I am not going to let my fear get in the way of losing this site because I didn’t do anything. I wish that I were as thick skinned as you and able to keep going in spite of the verbal abuse. When David or Gabe Jebb bullied me, I let it go because I knew they bullied almost everyone. But when it came from pilots who I thought were my friends, it devastated me. Thanks again for thinking of me, but maybe at a later date. Lynne Perry, Paraglider Pilot, Consulting Geologist, Alpine, California.’ Now she’s gone. We need citizen oversight at the Torrey Pines Gliderport, Ms. Lightner. That’s in your district. The Torrey Pines City Park Advisory Board was formed by a lawsuit that this City lost because they were not providing adequate oversight at that Gliderport. The Advisory Board was formed, but it was not allowed to address any of the issues at that Gliderport, any of the bullying, any of the misconduct, any of the banning of pilots. It was not allowed to discuss any of the management issues at that Gliderport. Instead they played games rearranging the furniture. Where are we going to put the grass? Where are we going to put the parking? The Gliderport doesn’t need any discussion about grass and parking, it needs discussion about the bullying and the management problems at that site.”


XII. NINTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(B) September 25, 2012: “This is the Torrey Pines lessee. This is what we see. This is Robin Marien. This is just September 17th, 2012. Nicely pixilated, but I think you can see through the pixels there. Next slide please. Here he is again twice as nice, giving me two of those lovely signs that are not even allowed to be shown in this Council or spoken, although somebody slipped through. Next slide please. And again. Next slide please. And again. Next slide please. Robin Marien has a free lease. Free lease to the multi-million dollar Torrey Pines Gliderport with no citizen oversight. That’s the most important point. No citizen oversight. Next slide please. Does Robin look like a guy who needs no citizen oversight? Does he? Does he look like the guy that should be running the Torrey Pines Gliderport? It’s a world class facility. We have people from all over the world who come to fly at this site, come to enjoy this site and this is the thug who’s running it....


XIII. TENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(C) March 5, 2013: “Over the years, I’ve been contacted by many people who have been bullied, abused, and in some cases even beaten by the Torrey Pines’ concessionaire or their staff. In most cases, they’ve asked me to remain quiet about it because they feared retribution. In other cases, they have gotten financial settlements with an agreement to remain silent, so I can’t tell their stories. But I can tell Lynne’s story. Lynne was a paraglider pilot who ended up taking her own life in 2011. These are her own words to me when I asked about featuring her site preservation efforts in our Torrey Hawks Club Newsletter. Lynne wrote: ‘Bob, thanks for thinking of me, but I need to decline at this time. I have been the victim of much bullying by some of the in pilots. I’m very selective as to who I fly with and will leave the site if other certain pilots are there. Two years ago, I rarely left my home and did not fly for a period of five months.’ This is someone who loves flying. ‘Did not fly for a period of five months due to fear of a vicious verbal assault by Josh Gelb during a club event. This was not an isolated event, just the final proverbial straw. The fact that the other pilots just stood by and let it happen led me to believe that the supported this behavior.’ She goes on to say ‘I am still not emotionally healed and need to stay incognito as much as possible. You may have noticed that I do not post to the San Diego Hang Gliding Paragliding Association forum even though I am the owner of that forum. These days I typically fly with a hang glider pilots and only a few select paraglider pilots. Blossom’... which is a local flying site... ‘is my passion and I am not going to let my fear in the way of losing the site because I didn’t do anything. I wish that I were as thick skinned as you.’ Talking about me. ‘And able to keep going in spite of the verbal abuse.’ She says ‘When David or Gabe Jebb bullied me.’ David Jebb was the concessionaire for ten years. He may still be the concessionaire, no one will say. ‘When David or Gabe Jebb bullied me, I let it go because I knew they bullied almost everyone.’ Isn’t that a sad statement? The bullying there is so common that she just accepts it because it happens to everyone. ‘But when it came from pilots whom I thought were my friends, it devastated me. Thanks again for thinking of me, but maybe at a later date.’ There was no later date. She eventually took her own life. She was a pilot in Alpine. She doesn’t have a council representative on this staff because she’s from Alpine. Next slide please. I’m asking this council to stop the bullying. That’s the guy who currently claims he is the concessionaire. Those are four different occasions. He’s giving people the finger. Please restart the Advisory Board.”


XIV. ELEVENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(D) March 19, 2013: “I did a brief internet search of various incidents that have happened at the Gliderport over the last three years and I limited it to just three years. March 6, 2013, less than two weeks ago we had a paraglider rescued from the cliffs near Torrey Pines. December 24th, that was just three months ago, we had a paraglider rescued from Torrey Pines Gliderport, taken to La Jolla hospital. By the way, I tried to be fair to various news agencies and get a smattering of all so we have the Union Tribune, we have the La Jolla Light, we have Channel 10, Channel 8. Woman dies, Torrey Pines paraglider crash - that was less than a year ago. Just this past year. Paraglider hurt in Torrey Pines area crash, August 12th, 2011. This is Channel 10 news. July 24, 2011, paraglider hurt after collision at Torrey Pines Gliderport. This was two students that collided into each other. Two students that were supposed to be on a radio and supposed to be being safeguarded by the instructors at the Gliderport to keep them from colliding into each other. This was a collision between a hang glider and an RC pilot. In fact, that was my hang glider and it was my friend flying that hang glider. His wrists broken. This was not even reported in the news at all. August 8, 2010, two paragliders collide in mid-air over Torrey Pines. Again, two students supposedly on radio with the concession’s instructors should be keeping them safe, instead they are colliding into each other. I actually witnessed this as well. After one of the incidents, we have Sergeant Bill Bender saying ‘After the accident there is a report that’s taken. The report is done by officials here at the Gliderport. That’s used to determine what the outcome of the accident it was and how it can be prevented in the future.’ How do you think they’re doing? Now, I want to key on the fact that he says ‘officials here at the Gliderport do the report’. What officials are at the Gliderport? That would be this guy (pointing a picture of Robin Marien). This is the guy that runs the Gliderport and makes the money from throwing people off that cliff. He’s the guy doing the report? We need oversight of that Gliderport. San Diego City Council please reactivate the Torrey Pines City Park Advisory Board so that there’s some responsible and independent oversight at the Torrey Pines Gliderport. That advisory Board is made up of citizens and clubs who want to fly and use that park safely. Please reactivate the Torrey Pines City Park Advisory Board before someone else gets bullied, beaten, or airlifted. Thank you.”


XV. TWELFTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(E) April 9, 2013: “Hello, I’m here to talk about possibly a golden opportunity for the Council today, for the Council to cooperate with Mayor Filner. Last week, a delegation of five members of our club, the Torrey Hawks Hang Gliding Club were able to meet with Mayor Filner and we presented him with a series of slides about the Gliderport. We presented a series of slides about the accidents that have happened at the Gliderport. Accidents that were actually overseen by the concessionaire. The concessionaire was flying too many students too close and they actually collided. These were students that were supposedly under control of the concessionaire’s instructors and ended up colliding into each other. We talked about the bullying at the Gliderport. I’ve shown that slide here before. We talked about the many requests for the Advisory Board to oversee the management of the Gliderport, repeatedly. And these are actually from the minutes of the Torrey Pines City Park Advisory Board. We talked about the concessionaire. About this guy. This is the guy who runs the Gliderport for the City of San Diego. Not only is he disrespectful to members of the public, but he’s breaking his own rules there. Smoking in a city park where he is not supposed to smoke. You can go there any day and watch him and some of his instructors smoking in our city park. I reminded him that agreement the City agreed to was to create an Advisory Board. Words have meanings folks. Advisory Board is an Advisory Board. Yet, somehow the City Council in 2007 created this supposedly Advisory Board under City Charter Section 43(b). 43(b) doesn’t define Advisory Boards. 43(b) defines citizens committees. An Advisory Board is not a citizens committee. They’re not the same. If the wording of the settlement agreement had been advisory committee or citizen’s board, you might say there is some ambiguity. But the settlement agreement is very clear. It said, the City shall create an established City Park Advisory Board. So, we talked to the Mayor about this as well. And then we presented our fix to this. And there are two fixes. One is that because the Mayor can actually create citizen’s committee’s on his own, he can actually just create a citizen’s committee to advise the City, on the advisory, on any issue he picks out like the management of the Gliderport. He can commission a citizen’s committee to advise that City on that management. He can just do that on his own. Because the Mayor, City Council, or City Manager, which we don’t have anymore, may create an established citizen committee. However, Advisory Boards are required to be created by the City Council. The City Council made by ordinance to create and establish Advisory Boards. So, if we want to have an Advisory Board, an on-going Board to oversee the Gliderport, it really should be done through the City Council. And that’s what I’m asking the City Council to do. This is the resolution that I’ve suggested before. The City Council of San Diego, pursuant to the City Charter Section 43(a), Torrey Pines City Park Advisory Board should remain an active board meeting monthly, that’s my request, thank you.”


XVI. THIRTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(F) April 23, 2013: “...There’s been bullying at the Gliderport. There’s been accidents at the Gliderport. And there’s been this guy at the Gliderport. [Shows slide of Robin Marien] Our old friend. This is the guy who runs the Gliderport and decides everything that happens at the Gliderport because the City won’t oversee him in any way. He gets away with everything he wants to do, doesn’t he Sherri? [...] How’s it been working out? Well, let’s review how it’s been working out. A couple of months after she wrote that, Lynne took her life, citing bullying to me before she died. A month later, or a couple months later, July 24th, we have an accident. Two paragliders collided under supervision of instructors at the Gliderport. Who reviews that? The concessionaire at the Gliderport. On August 12th, another paraglider hurt. May 12th, 2012, a woman died in a paraglider crash. No oversight from the City at all. December 24th, another injury. March 6th, just a month ago, another injury at the Torrey Pines, another rescue. This is the guy who needs oversight. Sherri Lightner continues to dodge the issue and I would request that Council President Gloria put this on the agenda.”


XVII. FOURTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(D) July 23, 2013: “My name is Bob Kuczewski ...This slide are the words of a women who ended up taking her life after saying that she had been the victim of much bullying by some of the in pilots at Torrey Pines. She said when David or Gabe Jebb bullied her, that those are the concessionaires, she let it go because she knew they bullied almost everyone, yet you’ve done nothing. What about the accidents? We have August 2010 paragliders collide, July 2011 paragliders hurt, August 2011 paraglider hurt , May 2012 a woman dies, December 2012 a paraglider rescued, March 2013 paraglider rescued. How long will it be until we get the next one? All of this courtesy of the San Diego City’s own Torrey Pines’ concessionaire. [Shows a picture of Robin Marien] There he is, breaking the rules....


XVII. FIFTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(H) September 21, 2013: “My name is Bob Kuczewski. [...]The Gliderport’s free lease expired in August of 2008. That is five years ago. It’s never been put up for bid and Jebb’s company has kept that free lease all this time. What are the odds that that was accidental? The current concessionaire posted, violated City posted ordinances everyday. There’s the guy that runs the place. See he has a cigarette in his hand. I’m filming him and he points to the sign in the background that says ‘No Smoking’. It’s the City of San Diego sign that says no smoking. He points right at it, flagrantly, violating the City’s ordinances right on our own property. There he is, this is his response to the public. (Shows a slide of Robin Marien) August - this is, this is- just a month ago, a month ago tomorrow. There he is again. This is how he treats the public. What are the odds
2 that all of this is accidental? It all adds up to corruption.”


XIX. SIXTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(I) September 17, 2013: “Before I get started, I want to direct City TV to my slides. I want my slides to be shown full screen throughout my entire presentation. So if you’re watching this on TV at home, and you see anything other than my slides during the entire time that I am presenting, than you know that someone in this City is trying to cover up what’s been happening at the Torrey Pines Gliderport. On July 30th, 2013, I showed 19 slides to this City Council. Only three of my slides appeared on City TV. Why is that? And I called in advance to City TV and asked them specifically to show my slides. And I believe I said so at the microphone as well. On September 10th, just last week, I showed 50 slides. Not one of my slides was on City TV. Who’s trying to cover this up? What are Sherri Lightner and Todd Gloria hiding from us? Sherri? Is it the accidents at Torrey Pines? One after another, after another, after another, after another, after another, after another, after another. Is it the bullying that’s been going on at Torrey Pines that hasn’t been addressed by any oversight by the City of San Diego? (David and Gabe Jebb’s names are highlighted on the slide). Could it be the violations of law? There’s the concessionaire. (Shows a picture of Robin Marien) The guy who has a free lease to our City park smoking and he can flick that cigarette and hit that ‘Non Smoking’ sign. There he is giving the public the finger. Which is very - properly considered inappropriate - but you need to see it because we see it. And the public needs to see it because we see it. Because that’s what we see at that Gliderport. There he is again. This is just a month ago, August 11th. He is smoking in front of the sign. In the upper left hand corner is the City of San Diego sign. He knows that I am taking his picture, I am videotaping him. He jokes about it, laughs, turns, and you will see him point at the sign just above his finger that says ‘No Smoking’. As if to say ‘screw you San Diego, I can do whatever I want at, at my Gliderport’. What kind of corruption brings this to our City? What kind of corruption, Sherri Lightner, allows this to be in our City park? What kind of corruption allows a settlement agreement that specified an Advisory Board to be created under the wrong section of the City Charter? City Charter Section 43(b) that does not address Advisory Boards at all. Instead it was established as a, as a citizen’s committee when the agreement was for an Advisory Board. Finally, what ties David Jebb and Jerry Sanders together? I will leave that as a cliff hanger for next week, thank you.”


XX. SEVENTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(J) October 22, 2013: “My name is Bob Kuczewski and I am here to talk about the Torrey Pines City Park Advisory Board and I am going to work on connecting the dots. On the left we have David Jebb who ran the Gliderport for 10 years. On the right, we have Mayor Jerry Sanders. Both served on the San Diego Police Department together. Jebb writes a book, quote ‘The Lieutenant says ok Blue forget about the civil liberty lawyers, forget about the rules and regulations. Do whatever you have to do. We don’t care if you bury these blank heads. Is that clear enough? Blue replied yes sir. I need to know just how far you are willing to back me up if things get ugly.’ By the way, I want the camera on my slides during my entire presentation, thank you. ‘The Captain stood up, leaned over the desk and said, we will cover you to the limit Blue, as long as you keep your mouth shut about our agreement and as long as you don’t get caught operating outside the department policies or the law. If you get caught, we’ll deny ever having this conversation. Do you understand? Blue replied, wouldn’t have it any other way.’ Fiction or fact? Jebb gets a 10-year free lease to the million dollar city property known as the Torrey Pines Gliderport, with no oversight. Jebb’s been known to be doing lots of bullying. We have a quote here from a woman who ended up taking her life saying ‘When David Jebb or Gabe Jebb bullied me, I let it go because they bullied most everyone. Jebb bans individuals and entire clubs from their own city park. Jebb violates his own lease. In 2007, the City is sued for Jebb’s violations. In June 2007, the City of San Diego agrees to pay $20,000 to form a Torrey Pines City Park Advisory Board as part of the settlement. From June of 2007 through 2008, Sanders administrations delays formation of the Board, even though it’s supposed to be formed within 90 days. Under Sanders’ administration, eventually he creates the Board, an Advisory Board, under the wrong section of the City Charter. He created it under 43(b) which is citizen’s committee, it’s not Advisory Boards. Advisory Boards are 43(a). Sanders appoints Ginny Barnes to keep the Advisory Board from any oversight of the management at that Gliderport. San Diego spends almost half a million dollars on a plan with no implementation, wasted money. The only thing we needed was oversight. Jebb’s lease expires in 2008, but the City uses the Advisory Board as an excuse to allow Jebb to keep the lease for another five years without it going for public bid. Another inside deal. Jebb turns the lease over to his second in command in an undisclosed deal in 2009. This is the guy. This is the guy who now runs our Gliderport. There he is again violating the City’s own rules. ‘No Smoking’ - he smokes there everyday. We have accidents at the rate of about two a year. No oversight or review of what’s going on there. The Soaring Council private organization is totally unbalanced, totally corrupt. The City Park Advisory Board which is what we should have with equal balance of clubs has been dis-banned. Who is watching over this guy, Sherri? Who is watching over him? Who in this City is watching over what is going on in that Gliderport, Sherri?”


XXI. EIGHTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(K) January 14, 2014: “My name is Bob Kuczewski and I’m here to talk about the Torrey Pines City Park Advisory Board. I officially request that the City TV show all of my slides. I have made this request by phone, by calling the City TV and the City TV has refused to show my slides. I will point out that modifying a speaker’s presentation by either changing the slide order, or, not showing the slides, is likely a violation of the Brown Act. The Brown Act gives people the right to come here and speak, whether it’s pleasant or unpleasant and to be seen by the people who come to these meeting and that includes the people who watch it on television, so I ask that my slides be shown. Now this is an offensive slide to you Sherri. This is the guy who runs the Torrey Pines Gliderport. And this is the most offensive slide that I have. It shows basically a hand, missing a few fingers. This is the guy that is running the Gliderport. He’s running it under your auspices essentially, Sherri because I have asked you to have him removed. I have asked you to put oversight on him. Actually, I haven’t asked to have him removed, I’ve asked for oversight. I have asked for an Advisory Board that will oversee what this guy does at this Gliderport. You have refused to provide that for years now. For years, Sherri. Now there is a connection in the City. I believe there’s corruption between David Jebb who owns the Gliderport, or manages the Gliderport, and Jerry Sanders who was his Chief of police. They were both policemen together. I believe there is corruption there. There is Jebb behind the scenes just this past weekend, at the Gliderport, confiding with the guy who owns the finger to the right there. Jebb wrote a book telling of his time in the City of San Diego as a police officer. Jebb has a free-ten year lease. He’s had a free ten- year lease of that Gliderport and that lease expired in 2008. It’s 2014 now and that lease has still not been put up for bid. He’s been going on that free lease for five more years without it going up for bid. Jebb has bullied pilots. You’ve seen this slide before too. Someone saying I have been the victim of much bullying by some of the in pilots. When David or Gabe Jebb bullied me, I let it go because I know they bullied most everyone. This woman ended up taking her life...[.]


XXII. NINETEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

(L) November 11, 2014: “My name is Bob Kuczewski and I am here to talk about the Torrey Pines Gliderport. I officially request that City TV show all of my slides so the public of San Diego can see what’s been going on at that Gliderport. Yesterday I was at the Gliderport and I was arrested for doing this. For taking this photo of that gentleman standing there kiting his paraglider without a helmet. That’s a safety risk and he is demonstrating to students. He has students all around him that he’s showing how to paraglider. This is the Son of the owner and, and he has not helmet. That’s, that’s inexcusable for him to be demonstrating to students how to fly without a helmet. So I was documenting that. I have every right as a citizen to be in that park and to take those photos of - of what he was doing. He didn’t like it. He saw me taking the photos and so he drops his paraglider an approaches me. Step, by step, by step, by step, by step, by step, by step. And he starts telling me that I have to leave the Gliderport and I am not allowed to take pictures of him. Well how the heck are we going to get oversight of that Gliderport if people aren’t allowed to take pictures of what is going on at that Gliderport. Mr. Goldsmith, this City relies on citizens bringing evidence like this to you to show you what is going on in this City. And for them to bring the police, and they start surrounding me, putting their face in my camera, accusing me of - of attacking them, or following them. Look how close they are. And I’m just standing there. They approached me. They all approached me. These are the instructors at that Gliderport. At some point, that gentlemen there who owns the Gliderport, starts untying my hang glider. He unties it, and this guy, one of his thugs is basically blocking me from taking photos of him untying the hang glider. But I got a few pictures of him doing it anyway. And then he walks off, leaving my hang glider there, untied in the wind. That’s a tremendous safety hazard. That thing can blow away. Then they call the police on me. And I spent the night, last night, a good part of last night in the jail because I refused to leave our City park. For doing what? For having taken pictures to bring to this Council to show you what is going on in that park? That’s why I spent the night in jail? This is ridiculous. This is an outrage that our City parks are being given for free to that thug of a concessionaire to bully people and then to call our own police against our people. They gave me a choice of leaving the park or going to jail. I said, you know what? There’s a woman named Rosa Parks who stood up and brought the matter to Court and that’s what I’m doing. I ask this City to reinstate the Torrey Pines City Park Advisory Board so we can get some oversight in that Gliderport.”


XXIII. TWENTIETH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(M) On November 20, 2014: “Yesterday I went with a friend to the local police station to file a police report for assault and battery and false arrest. Brace yourself. The San Diego police refuse - REFUSED - to take the report. How can it be that citizens cannot even FILE a police report? Of course, let’s not forget that the report would implicate Gabriel Jebb - the son of former San Diego police officer David Jebb.”


XXIV. TWENTY-FIRST CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(N) On November 11, 2014: “My friend arrived just about the time that I tied the glider to the roof of my van. I’d been thinking long and hard about the choice in front of me. I thought about all the times that David Jebb and Gabe Jebb and Robin Marien had bullied people and threatened them with arrest. I thought about how they’ve always gotten away with it because everyone in the past (including myself) had always backed down. Then I thought about Rosa Parks. The choice was clear: I spent the good part of the evening and into the next morning in jail. It was an extremely unpleasant experience, but I accepted it as the price of justice.”


XXV. TWENTY-SECOND CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(O) On March 10, 2015: “One of the things that came up was the patterns of abuse from Gabe Jebb, and that reminded me of this incident from August 11, 2013. It’s interesting to see Gabe Jebb’s pattern of approaching people to intimidate them.”


XXVI. TWENTY-THIRD CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(P) On April 23, 2015: “...Regarding the term “bullying”, I knew a very nice female paragliding pilot who wrote to me saying: ‘When David or Gabe Jebb bullied me, I let it go because I knew that they bullied most everyone, but when it came from pilots whom I thought were my friends, it devastated me.’ She ended up taking her own life.”


XXVII. TWENTY-FOURTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(Q) On May 4, 2015: “This is what you’re up against. Robin and Jebb were at the mafia table having lunch. Robin drives away with David Jebb, in a Red Corvette. The Godfather.”


XXVIII. TWENTY-FIFTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(R) March 5, 2013: “Over the years, I’ve been contacted by many people who have been bullied, abused, and in some cases even beaten by the Torrey Pines’ concessionaire or their staff. In most cases, they’ve asked me to remain quiet about it because they feared retribution. In other cases, they have gotten financial settlements with an agreement to remain silent, so I can’t tell their stories. But I can tell Lynne’s story. Lynne was a paraglider pilot who ended up taking her own life in 2011. These are her own words to me when I asked about featuring her site preservation efforts in our Torrey Hawks Club Newsletter. Lynne wrote: ‘Bob, thanks for thinking of me, but I need to decline at this time. I have been the victim of much bullying by some of the in pilots. I’m very selective as to who I fly with and will leave the site if other certain pilots are there. Two years ago, I rarely left my home and did not fly for a period of five months.’ This is someone who loves flying. ‘Did not fly for a period of five months due to fear of a vicious verbal assault by Josh Gelb during a club event. This was not an isolated event, just the final proverbial straw. The fact that the other pilots just stood by and let it happen led me to believe that the supported this behavior.’ She goes on to say ‘I am still not emotionally healed and need to stay incognito as much as possible. You may have noticed that I do not post to the San Diego Hang Gliding days I typically fly with a hang glider pilots and only a few select paraglider pilots. Blossom’... which is a local flying site... ‘is my passion and I am not going to let my fear in the way of losing the site because I didn’t do anything. I wish that I were as thick skinned as you.’ Talking about me. ‘And able to keep going in spite of the verbal abuse.’ She says ‘When David or Gabe Jebb bullied me.’ David Jebb was the concessionaire for ten years. He may still be the concessionaire, no one will say. ‘When David or Gabe Jebb bullied me, I let it go because I knew they bullied almost everyone.’ Isn’t that a sad statement? The bullying there is so common that she just accepts it because it happens to everyone. ‘But when it came from pilots whom I thought were my friends, it devastated me. Thanks again for thinking of me, but maybe at a later date.’ There was no later date. She eventually took her own life. She was a pilot in Alpine. She doesn’t have a council representative on this staff because she’s from Alpine. Next slide please. I’m asking this council to stop the bullying. That’s the guy who currently claims he is the concessionaire. Those are four different occasions. He’s giving people the finger. Please restart the Advisory Board.”


XXIX. TWENTY-SIXTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(S) July 23, 2013: “My name is Bob Kuczewski and I would like to direct the City camera to my slides. I am here to talk about Todd Gloria’s hypocrisy and the plundering of our city parks. Todd Gloria said, ‘We as a City will not tolerate intimidation and harassment’. Really, Mr. Gloria? How many times have I shown you this slide? This slide are the words of a women who ended up taking her life after saying that she had been the victim of much bullying by some of the in pilots at Torrey Pines. She said when David or Gabe Jebb bullied her, that those are the concessions, she let it go because she knew they bullied almost everyone, yet you’ve done nothing. What about the accidents? We have August 2010 paragliders collide, July 2011 paragliders hurt, August 2011 paraglider hurt, May 2012 a woman dies, December 2012 a paraglider rescued, March 2013 paraglider rescued. How long will it be until we get the next one? All of this courtesy of the San Diego City’s own Torrey Pines’ concessionaire. [Shows a picture of Robin Marien] There he is, breaking the rules. He’s got a cigarette in his hand. He can flick that cigarette and hit that sign from the City that says ‘No Smoking Allowed’, yet nobody in this City will oversee this concessionaire. Yet Todd Gloria and Sherri Lightner do nothing. Fast forward to this past Sunday, or Saturday, July 20th, you see that Gliderport? That’s where we are supposed to be landing our hang gliders. The concessionaire has basically leased out our Gliderport to a private business for their company party. No oversight involved. Here’s my landing approach. I don’t know if you can see the hang glider coming in. See me landing right there? That’s where I landed last month in June. See that, those towers and those trees? Focus on them. You see the same towers and trees there. This is what our park looked like on Saturday. The concessionaire had basically sold it to, to a company to come have their private picnic and they picketed off so we couldn’t land or use the park. Let’s look at the lease. Lease says it is expressly agreed that the premises are leased solely and exclusively for the purposes of a flight Gliderport concession, the use of non-power aircrafts, and the general public. Non-power aircraft? We can’t fly there with cars parked in our landing zone. This is our landing zone. The general public, they got a picket fence saying ‘provide commerce guests only’. We’re excluded from our own city park so he can make money. The lease says that, that they should only use it for the purposes not expressly authorized herein. The use of any, of the premises for any unauthorized purpose shall constitute substantial default and subject this lease to termination. Nobody will enforce it. Consideration, the flight director gets no, sends no money to the City. The City gets no money for this. Yet he can sell that property and lease it out and make as much as he wants. Assignment and subletting, flight directors lessee shall not assign this property and shall not sublet the premises. Yet, he leased it our for this party just last Saturday. Who in the City is overseeing this? Parks and Recreation? Real Estate Assets? Nobody. The guy is getting away with whatever he wants to get away with. There he is breaking the law smoking, breaking the law smoking, rents our City, rents our City property for his own private business and nobody will oversee it. There’s no Advisory Board to advise the City on what needs to be done at that Gliderport, thank you.” He’s giving people the finger. Please restart the Advisory Board.”


XXX. TWENTY-SEVENTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(T) September 17, 2013: “Before I get started, I want to direct City TV to my slides. I want my slides to be shown full screen throughout my entire presentation. So if you’re watching this on TV at home, and you see anything other than my slides during the entire time that I am presenting, than you know that someone in this City is trying to cover up what’s been happening at the Torrey Pines Gliderport. On July 30th, 2013, I showed 19 slides to this City Council. Only three of my slides appeared on City TV. Why is that? And I called in advance to City TV and asked them specifically to show my slides. And I believe I said so at the microphone as well. On September 10th, just last week, I showed 50 slides. Not one of my slides was on City TV. Who’s trying to cover this up? What are Sherri Lightner and Todd Gloria hiding from us? Sherri? Is it the accidents at Torrey Pines? One after another, after another, after another, after another, after another, after another, after another. Is it the bullying that’s been going on at Torrey Pines that hasn’t been addressed by any oversight by the City of San Diego? (David and Gabe Jebb’s names are highlighted on the slide). Could it be the violations of law? There’s the concessionaire. (Shows a picture of Robin Marien) The guy who has a free lease to our City park smoking and he can flick that cigarette and hit that ‘Non Smoking’ sign. There he is giving the public the finger. Which is very - properly considered inappropriate - but you need to see it because we see it. And the public needs to see it because we see it. Because that’s what we see at that Gliderport. There he is again. This is just a month ago, August 11th. He is smoking in front of the sign. In the upper left hand corner is the City of San Diego sign. He knows that I am taking his picture, I am videotaping him. He jokes about it, laughs, turns, and you will see him point at the sign just above his finger that says ‘No Smoking’. As if to say ‘screw you San Diego, I can do whatever I want at, at my Gliderport.’ What kind of corruption brings this to our City? What kind of corruption, Sherri Lightner, allows this to be in our City park? What kind of corruption allows a settlement agreement that specified an Advisory Board to be created under the wrong section of the City Charter? City Charter Section 43(b) that does not address Advisory Boards at all. Instead it was established as a, as a citizen’s committee when the agreement was for an Advisory Board. Finally, what ties David Jebb and Jerry Sanders together? I will leave that as a cliff hanger for next week, thank you.”


XXXI. TWENTY-EIGHTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(U)
January 14, 2014:
“My name is Bob Kuczewski and I’m here to talk about the Torrey Pines City Park Advisory Board. I officially request that the City TV show all of my slides. I have made this request by phone, by calling the City TV and the City TV has refused to show my slides. I will point out that modifying a speaker’s presentation by either changing the slide order, or, not showing the slides, is likely a violation of the Brown Act. The Brown Act gives people the right to come here and speak, whether it’s pleasant or unpleasant and to be seen by the people who come to these meeting and that includes the people who watch it on television, so I ask that my slides be shown. Now this is an offensive slide to you Sherri. This is the guy who runs the Torrey Pines Gliderport. And this is the most offensive slide that I have. It shows basically a hand, missing a few fingers. This is the guy that is running the Gliderport. He’s running it under your auspices essentially, Sherri because I have asked you to have him removed. I have asked you to put oversight on him. Actually, I haven’t asked to have him removed, I’ve asked for oversight. I have asked for an Advisory Board that will oversee what this guy does at this Gliderport. You have refused to provide that for years now. For years, Sherri. Now there is a connection in the City. I believe there’s corruption between David Jebb who owns the Gliderport, or manages the Gliderport, and Jerry Sanders who was his Chief of police. They were both policemen together. I believe there is corruption there. There is Jebb behind the scenes just this past weekend, at the Gliderport, confiding with the guy who owns the finger to the right there. Jebb wrote a book telling of his time in the City of San Diego as a police officer. Jebb has a free-ten year lease. He’s had a free ten-year lease of that Gliderport and that lease expired in 2008. It’s 2014 now and that lease has still not been put up for bid. He’s been going on that free lease for five more years without it going up for bid. Jebb has bullied pilots. You’ve seen this slide before too. Someone saying I have been the victim of much bullying by some of the in pilots. When David or Gabe Jebb bullied me, I let it go because I know they bullied most everyone. This woman ended up taking her life....[.]”


XXXII. TWENTY-NINTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

(V) November 11, 2014: “My name is Bob Kuczewski and I am here to talk about the Torrey Pines Gliderport. I officially request that City TV show all of my slides so the public of San Diego can see what’s been going on at that Gliderport. Yesterday I was at the Gliderport and I was arrested for doing this. For taking this photo of that gentleman standing there kiting his paraglider without a helmet. That’s a safety risk and he is demonstrating to students. He has students all around him that he’s showing how to paraglide. This is the Son of the owner and, and he has not helmet. That’s, that’s inexcusable for him to be demonstrating to students how to fly without a helmet. So I was documenting that. I have every right as a citizen to be in that park and to take those photos of - of what he was doing. He didn’t like it. He saw me taking the photos and so he drops his paraglider an approaches me. Step, by step, by step, by step, by step, by step, by step. And he starts telling me that I have to leave the Gliderport and I am not allowed to take pictures of him. Well how the heck are we going to get oversight of that Gliderport if people aren’t allowed to take pictures of what is going on at that Gliderport. Mr. Goldsmith, this City relies on citizens bringing evidence like this to you to show you what is going on in this City. And for them to bring the police, and they start surrounding me, putting their face in my camera, accusing me of - of attacking them, or following them. Look how close they are. And I’m just standing there. They approached me. They all approached me. These are the instructors at that Gliderport. At some point, that gentlemen there who owns the Gliderport, starts untying my hang glider. He unties it, and this guy, one of his thugs is basically blocking me from taking photos of him untying the hang glider. But I got a few pictures of him doing it anyway. And then he walks off, leaving my hang glider there, untied in the wind. That’s a tremendous safety hazard. That thing can blow away. Then they call the police on me. And I spent the night, last night, a good part of last night in the jail because I refused to leave our City park. For doing what? For having taken pictures to bring to this Council to show you what is going on in that park? That’s why I spent the night in jail? This is ridiculous. This is an outrage that our City parks are being given for free to that thug of a concessionaire to bully people and then to call our own police against our people. They gave me a choice of leaving the park or going to jail. I said, you know what? There’s a woman named Rosa Parks who stood up and brought the matter to Court and that’s what I’m doing. I ask this City to reinstate the Torrey Pines City Park Advisory Board so we can get some oversight in that Gliderport.”


XXXIII. THIRTIETH CAUSE OF ACTION
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
[Plaintiffs ROBIN MARIEN, AIR CALIFORNIA ADVENTURE, INC., and GABRIEL JEBB
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

XXXIV. THIRTY-FIRST CAUSE OF ACTION
NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
[Plaintiffs ROBIN MARIEN, AIR CALIFORNIA ADVENTURE, INC., and GABRIEL JEBB
as to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

XXXV. THIRTY-SECOND CAUSE OF ACTION
DECLARATORY RELIEF
[Plaintiffs ROBIN MARIEN, AIR CALIFORNIA ADVENTURE, INC., and GABRIEL JEBB
as to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

XXXVI. THIRTY-THIRD CAUSE OF ACTION
INJUNCTIVE RELIEF
[Plaintiffs ROBIN MARIEN, AIR CALIFORNIA ADVENTURE, INC., and GABRIEL JEBB as
to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]
Join a National Hang Gliding Organization: US Hawks at ushawks.org
View my rating at: US Hang Gliding Rating System
Every human at every point in history has an opportunity to choose courage over cowardice. Look around and you will find that opportunity in your own time.
Bob Kuczewski
User avatar
Contributor
Contributor
 
Posts: 7534
Joined: Fri Aug 13, 2010 2:40 pm
Location: San Diego, CA

Re: Torrey Trial

Postby Bob Kuczewski » Sat Apr 16, 2022 11:48 am

Update:

The "Trial Call" will be on Friday April 22nd, 2022.

The actual trial will begin on Monday April 25, 2022.
Join a National Hang Gliding Organization: US Hawks at ushawks.org
View my rating at: US Hang Gliding Rating System
Every human at every point in history has an opportunity to choose courage over cowardice. Look around and you will find that opportunity in your own time.
Bob Kuczewski
User avatar
Contributor
Contributor
 
Posts: 7534
Joined: Fri Aug 13, 2010 2:40 pm
Location: San Diego, CA

Re: Torrey Trial

Postby Chris McKeon » Sat Apr 16, 2022 12:25 pm

This condition; Where our Employees have lost completely who their Employers are, is truly maddening for in my personal case. When I have had run ins withy one of My Employees. I can state the facts of they rangers situation up on the Mountain, and My position up on the Mountain to a Park Ranger. Yet They refuse to accept the facts. The Ranger is an employee to the Property owning Tax Paying "OWNERS" of said Park. The Reality of the situation was, the ranger who I WAS IN conflict with simply refused to accept the facts of His situation, and My situation. My position was and is., I am an Owner of the Park. For these Guys to Mentally decend into a state of fully willful denial, in the extreme case of the word, is maddening!

I mean if these State Park Rangers have such an deep, ingrained desire to Control other people at your place of Work. Then quit the Par. Take your Money and then start a Company. Then you will be able to control [YOUR EMPLOYEES}. In the mean time I say desist Stop messing with Your Current employers, Desist.
Chris McKeon
User avatar
Contributor
Contributor
 
Posts: 609
Joined: Wed Jul 31, 2013 7:46 pm

Re: Torrey Trial

Postby Bob Kuczewski » Sat Apr 16, 2022 6:12 pm

Thirty Three Causes of Action with Links

These are the causes of action from the Second Amended Complaint by Marien, Jebb, and ACA. They are the same as posted above but will be updated to include links to posts and videos:

IV. FIRST CAUSE OF ACTION
INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE
[Plaintiffs ROBIN MARIEN and AIR CALIFORNIA ADVENTURE, INC.
as to Defendants ROBERT KUCZEWSKI and MARJORIE MAE HOLLAND]

V. SECOND CAUSE OF ACTION
INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE
[Plaintiff GABRIEL JEBB as to Defendant ROBERT KUCZEWSKI]

VI. THIRD CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN, GABRIEL JEBB, and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



One example only of Eagle’s writing of or about Plaintiffs is the following posted on ushawks.org on May 9, 2015:
The Torrey Pines Ridge RATS ~ Well Known for posing as pilots while (sic) travelling the World.

The DEA, the Narcotics Department, and Homeland Security have been caught with (sic) there Pants Down, Hence there (sic) poor attitude.
Bashing their Own organisation (sic) and tolerating there (sic) Own Corruption.
The dealers operate right under there (sic) noses and are Laughing and Bragging About it.
Makes the entire Torrey Pines Gliderport look like fools at the risk of everyone's Lives.

We the People have Known about it for Years
~ They're above the Law and Yet still CRIMINALS ~


For his part, KUCZEWSKI replied on May 17, 2015:
“Your post sums it up perfectly!!!”


VII. FOURTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(A) On October 24, 2014:
“Here in San Diego, paraglider crashes are often reported by the press as “hang glider” crashes. I wonder where they get that information? Imagine that you’re a reporter doing a story on a rescue. Who are you going to call? The only public number for the Torrey Pines site is the concessionaire itself. Hmmm... So why do you think the press might be continually reporting paragliding crashes as “hang gliding” crashes?”


VIII. FIFTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(B) On November 11, 2014:
“My friend arrived just about the time that I tied the glider to the roof of my van. I’d been thinking long and hard about the choice in front of me. I thought about all the times that David Jebb and Gabe Jebb and Robin Marien had bullied people and threatened them with arrest. I thought about how they’ve always gotten away with it because everyone in the past (including myself) had always backed down. Then I thought about Rosa Parks. The choice was clear: I spent the good part of the evening and into the next morning in jail. It was an extremely unpleasant experience, but I accepted it as the price of justice.”


IX. SIXTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(D) On May 4, 2015:
“This is what you’re up against. Robin and Jebb were at the mafia table having lunch. Robin drives away with David Jebb, in a Red Corvette....The Godfather.”


X. SEVENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(E) On June 13, 2015:
“There have been numerous reports of paragliding being used as a “poor man’s air force” for both legal and illegal purposes. Uses include drug smuggling, surveillance, and law enforcement. It’s been long suspected that segments of the paragliding community are involved with some of these legal and/or illegal aspects of the sport. This has particular relevance to hang gliding since it may explain why the sport of paragliding seems to have a “protected” status at places like Torrey Pines and USHPA.”


XI. EIGHTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(B) June 7, 2011:
“My name is Bob Kuczewski and I have spoken here many times. Today, I am here to give voice to Lynne Perry who took her own life earlier this year. I had asked to feature Lynne in our newsletter and this was her reply: ‘Bob, thanks for thinking of me, but I need to decline at this time. I have been the victim of much bullying by some of the in pilots. I’m very selective as to who I fly with and I will leave a site if certain other pilots are there. Two years ago, I rarely left my home and did not fly for a period of five months due to fear of a vicious verbal assault by Josh Gelb during a club event. This was not an isolated event, just the final proverbial straw. The fact that the other pilots just stood by and let it happen led me to believe that they supported such behavior. I am still not emotionally healed and need to stay incognito as much as possible. You may have noticed that I do not post on the SDHGPA forum even though I am the owner. These days I typically fly with a hang glider pilots and only a select few paraglider pilots. Blossom is my passion and I am not going to let my fear get in the way of losing this site because I didn’t do anything. I wish that I were as thick skinned as you and able to keep going in spite of the verbal abuse. When David or Gabe Jebb bullied me, I let it go because I knew they bullied almost everyone. But when it came from pilots who I thought were my friends, it devastated me. Thanks again for thinking of me, but maybe at a later date. Lynne Perry, Paraglider Pilot, Consulting Geologist, Alpine, California.’ Now she’s gone. We need citizen oversight at the Torrey Pines Gliderport, Ms. Lightner. That’s in your district. The Torrey Pines City Park Advisory Board was formed by a lawsuit that this City lost because they were not providing adequate oversight at that Gliderport. The Advisory Board was formed, but it was not allowed to address any of the issues at that Gliderport, any of the bullying, any of the misconduct, any of the banning of pilots. It was not allowed to discuss any of the management issues at that Gliderport. Instead they played games rearranging the furniture. Where are we going to put the grass? Where are we going to put the parking? The Gliderport doesn’t need any discussion about grass and parking, it needs discussion about the bullying and the management problems at that site.”


XII. NINTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(B) September 25, 2012: “This is the Torrey Pines lessee. This is what we see. This is Robin Marien. This is just September 17th, 2012. Nicely pixilated, but I think you can see through the pixels there. Next slide please. Here he is again twice as nice, giving me two of those lovely signs that are not even allowed to be shown in this Council or spoken, although somebody slipped through. Next slide please. And again. Next slide please. And again. Next slide please. Robin Marien has a free lease. Free lease to the multi-million dollar Torrey Pines Gliderport with no citizen oversight. That’s the most important point. No citizen oversight. Next slide please. Does Robin look like a guy who needs no citizen oversight? Does he? Does he look like the guy that should be running the Torrey Pines Gliderport? It’s a world class facility. We have people from all over the world who come to fly at this site, come to enjoy this site and this is the thug who’s running it....


XIII. TENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(C) March 5, 2013: “Over the years, I’ve been contacted by many people who have been bullied, abused, and in some cases even beaten by the Torrey Pines’ concessionaire or their staff. In most cases, they’ve asked me to remain quiet about it because they feared retribution. In other cases, they have gotten financial settlements with an agreement to remain silent, so I can’t tell their stories. But I can tell Lynne’s story. Lynne was a paraglider pilot who ended up taking her own life in 2011. These are her own words to me when I asked about featuring her site preservation efforts in our Torrey Hawks Club Newsletter. Lynne wrote: ‘Bob, thanks for thinking of me, but I need to decline at this time. I have been the victim of much bullying by some of the in pilots. I’m very selective as to who I fly with and will leave the site if other certain pilots are there. Two years ago, I rarely left my home and did not fly for a period of five months.’ This is someone who loves flying. ‘Did not fly for a period of five months due to fear of a vicious verbal assault by Josh Gelb during a club event. This was not an isolated event, just the final proverbial straw. The fact that the other pilots just stood by and let it happen led me to believe that the supported this behavior.’ She goes on to say ‘I am still not emotionally healed and need to stay incognito as much as possible. You may have noticed that I do not post to the San Diego Hang Gliding Paragliding Association forum even though I am the owner of that forum. These days I typically fly with a hang glider pilots and only a few select paraglider pilots. Blossom’... which is a local flying site... ‘is my passion and I am not going to let my fear in the way of losing the site because I didn’t do anything. I wish that I were as thick skinned as you.’ Talking about me. ‘And able to keep going in spite of the verbal abuse.’ She says ‘When David or Gabe Jebb bullied me.’ David Jebb was the concessionaire for ten years. He may still be the concessionaire, no one will say. ‘When David or Gabe Jebb bullied me, I let it go because I knew they bullied almost everyone.’ Isn’t that a sad statement? The bullying there is so common that she just accepts it because it happens to everyone. ‘But when it came from pilots whom I thought were my friends, it devastated me. Thanks again for thinking of me, but maybe at a later date.’ There was no later date. She eventually took her own life. She was a pilot in Alpine. She doesn’t have a council representative on this staff because she’s from Alpine. Next slide please. I’m asking this council to stop the bullying. That’s the guy who currently claims he is the concessionaire. Those are four different occasions. He’s giving people the finger. Please restart the Advisory Board.”


XIV. ELEVENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(D) March 19, 2013: “I did a brief internet search of various incidents that have happened at the Gliderport over the last three years and I limited it to just three years. March 6, 2013, less than two weeks ago we had a paraglider rescued from the cliffs near Torrey Pines. December 24th, that was just three months ago, we had a paraglider rescued from Torrey Pines Gliderport, taken to La Jolla hospital. By the way, I tried to be fair to various news agencies and get a smattering of all so we have the Union Tribune, we have the La Jolla Light, we have Channel 10, Channel 8. Woman dies, Torrey Pines paraglider crash - that was less than a year ago. Just this past year. Paraglider hurt in Torrey Pines area crash, August 12th, 2011. This is Channel 10 news. July 24, 2011, paraglider hurt after collision at Torrey Pines Gliderport. This was two students that collided into each other. Two students that were supposed to be on a radio and supposed to be being safeguarded by the instructors at the Gliderport to keep them from colliding into each other. This was a collision between a hang glider and an RC pilot. In fact, that was my hang glider and it was my friend flying that hang glider. His wrists broken. This was not even reported in the news at all. August 8, 2010, two paragliders collide in mid-air over Torrey Pines. Again, two students supposedly on radio with the concession’s instructors should be keeping them safe, instead they are colliding into each other. I actually witnessed this as well. After one of the incidents, we have Sergeant Bill Bender saying ‘After the accident there is a report that’s taken. The report is done by officials here at the Gliderport. That’s used to determine what the outcome of the accident it was and how it can be prevented in the future.’ How do you think they’re doing? Now, I want to key on the fact that he says ‘officials here at the Gliderport do the report’. What officials are at the Gliderport? That would be this guy (pointing a picture of Robin Marien). This is the guy that runs the Gliderport and makes the money from throwing people off that cliff. He’s the guy doing the report? We need oversight of that Gliderport. San Diego City Council please reactivate the Torrey Pines City Park Advisory Board so that there’s some responsible and independent oversight at the Torrey Pines Gliderport. That advisory Board is made up of citizens and clubs who want to fly and use that park safely. Please reactivate the Torrey Pines City Park Advisory Board before someone else gets bullied, beaten, or airlifted. Thank you.”


XV. TWELFTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(E) April 9, 2013: “Hello, I’m here to talk about possibly a golden opportunity for the Council today, for the Council to cooperate with Mayor Filner. Last week, a delegation of five members of our club, the Torrey Hawks Hang Gliding Club were able to meet with Mayor Filner and we presented him with a series of slides about the Gliderport. We presented a series of slides about the accidents that have happened at the Gliderport. Accidents that were actually overseen by the concessionaire. The concessionaire was flying too many students too close and they actually collided. These were students that were supposedly under control of the concessionaire’s instructors and ended up colliding into each other. We talked about the bullying at the Gliderport. I’ve shown that slide here before. We talked about the many requests for the Advisory Board to oversee the management of the Gliderport, repeatedly. And these are actually from the minutes of the Torrey Pines City Park Advisory Board. We talked about the concessionaire. About this guy. This is the guy who runs the Gliderport for the City of San Diego. Not only is he disrespectful to members of the public, but he’s breaking his own rules there. Smoking in a city park where he is not supposed to smoke. You can go there any day and watch him and some of his instructors smoking in our city park. I reminded him that agreement the City agreed to was to create an Advisory Board. Words have meanings folks. Advisory Board is an Advisory Board. Yet, somehow the City Council in 2007 created this supposedly Advisory Board under City Charter Section 43(b). 43(b) doesn’t define Advisory Boards. 43(b) defines citizens committees. An Advisory Board is not a citizens committee. They’re not the same. If the wording of the settlement agreement had been advisory committee or citizen’s board, you might say there is some ambiguity. But the settlement agreement is very clear. It said, the City shall create an established City Park Advisory Board. So, we talked to the Mayor about this as well. And then we presented our fix to this. And there are two fixes. One is that because the Mayor can actually create citizen’s committee’s on his own, he can actually just create a citizen’s committee to advise the City, on the advisory, on any issue he picks out like the management of the Gliderport. He can commission a citizen’s committee to advise that City on that management. He can just do that on his own. Because the Mayor, City Council, or City Manager, which we don’t have anymore, may create an established citizen committee. However, Advisory Boards are required to be created by the City Council. The City Council made by ordinance to create and establish Advisory Boards. So, if we want to have an Advisory Board, an on-going Board to oversee the Gliderport, it really should be done through the City Council. And that’s what I’m asking the City Council to do. This is the resolution that I’ve suggested before. The City Council of San Diego, pursuant to the City Charter Section 43(a), Torrey Pines City Park Advisory Board should remain an active board meeting monthly, that’s my request, thank you.”


XVI. THIRTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(F) April 23, 2013: “...There’s been bullying at the Gliderport. There’s been accidents at the Gliderport. And there’s been this guy at the Gliderport. [Shows slide of Robin Marien] Our old friend. This is the guy who runs the Gliderport and decides everything that happens at the Gliderport because the City won’t oversee him in any way. He gets away with everything he wants to do, doesn’t he Sherri? [...] How’s it been working out? Well, let’s review how it’s been working out. A couple of months after she wrote that, Lynne took her life, citing bullying to me before she died. A month later, or a couple months later, July 24th, we have an accident. Two paragliders collided under supervision of instructors at the Gliderport. Who reviews that? The concessionaire at the Gliderport. On August 12th, another paraglider hurt. May 12th, 2012, a woman died in a paraglider crash. No oversight from the City at all. December 24th, another injury. March 6th, just a month ago, another injury at the Torrey Pines, another rescue. This is the guy who needs oversight. Sherri Lightner continues to dodge the issue and I would request that Council President Gloria put this on the agenda.”


XVII. FOURTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(D) July 23, 2013: “My name is Bob Kuczewski ...This slide are the words of a women who ended up taking her life after saying that she had been the victim of much bullying by some of the in pilots at Torrey Pines. She said when David or Gabe Jebb bullied her, that those are the concessionaires, she let it go because she knew they bullied almost everyone, yet you’ve done nothing. What about the accidents? We have August 2010 paragliders collide, July 2011 paragliders hurt, August 2011 paraglider hurt , May 2012 a woman dies, December 2012 a paraglider rescued, March 2013 paraglider rescued. How long will it be until we get the next one? All of this courtesy of the San Diego City’s own Torrey Pines’ concessionaire. [Shows a picture of Robin Marien] There he is, breaking the rules....


XVII. FIFTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

This speech has not been located yet.


(H) September 21, 2013: “My name is Bob Kuczewski. [...]The Gliderport’s free lease expired in August of 2008. That is five years ago. It’s never been put up for bid and Jebb’s company has kept that free lease all this time. What are the odds that that was accidental? The current concessionaire posted, violated City posted ordinances everyday. There’s the guy that runs the place. See he has a cigarette in his hand. I’m filming him and he points to the sign in the background that says ‘No Smoking’. It’s the City of San Diego sign that says no smoking. He points right at it, flagrantly, violating the City’s ordinances right on our own property. There he is, this is his response to the public. (Shows a slide of Robin Marien) August - this is, this is- just a month ago, a month ago tomorrow. There he is again. This is how he treats the public. What are the odds
2 that all of this is accidental? It all adds up to corruption.”


XIX. SIXTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(I) September 17, 2013: “Before I get started, I want to direct City TV to my slides. I want my slides to be shown full screen throughout my entire presentation. So if you’re watching this on TV at home, and you see anything other than my slides during the entire time that I am presenting, than you know that someone in this City is trying to cover up what’s been happening at the Torrey Pines Gliderport. On July 30th, 2013, I showed 19 slides to this City Council. Only three of my slides appeared on City TV. Why is that? And I called in advance to City TV and asked them specifically to show my slides. And I believe I said so at the microphone as well. On September 10th, just last week, I showed 50 slides. Not one of my slides was on City TV. Who’s trying to cover this up? What are Sherri Lightner and Todd Gloria hiding from us? Sherri? Is it the accidents at Torrey Pines? One after another, after another, after another, after another, after another, after another, after another. Is it the bullying that’s been going on at Torrey Pines that hasn’t been addressed by any oversight by the City of San Diego? (David and Gabe Jebb’s names are highlighted on the slide). Could it be the violations of law? There’s the concessionaire. (Shows a picture of Robin Marien) The guy who has a free lease to our City park smoking and he can flick that cigarette and hit that ‘Non Smoking’ sign. There he is giving the public the finger. Which is very - properly considered inappropriate - but you need to see it because we see it. And the public needs to see it because we see it. Because that’s what we see at that Gliderport. There he is again. This is just a month ago, August 11th. He is smoking in front of the sign. In the upper left hand corner is the City of San Diego sign. He knows that I am taking his picture, I am videotaping him. He jokes about it, laughs, turns, and you will see him point at the sign just above his finger that says ‘No Smoking’. As if to say ‘screw you San Diego, I can do whatever I want at, at my Gliderport’. What kind of corruption brings this to our City? What kind of corruption, Sherri Lightner, allows this to be in our City park? What kind of corruption allows a settlement agreement that specified an Advisory Board to be created under the wrong section of the City Charter? City Charter Section 43(b) that does not address Advisory Boards at all. Instead it was established as a, as a citizen’s committee when the agreement was for an Advisory Board. Finally, what ties David Jebb and Jerry Sanders together? I will leave that as a cliff hanger for next week, thank you.”


XX. SEVENTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(J) October 22, 2013: “My name is Bob Kuczewski and I am here to talk about the Torrey Pines City Park Advisory Board and I am going to work on connecting the dots. On the left we have David Jebb who ran the Gliderport for 10 years. On the right, we have Mayor Jerry Sanders. Both served on the San Diego Police Department together. Jebb writes a book, quote ‘The Lieutenant says ok Blue forget about the civil liberty lawyers, forget about the rules and regulations. Do whatever you have to do. We don’t care if you bury these blank heads. Is that clear enough? Blue replied yes sir. I need to know just how far you are willing to back me up if things get ugly.’ By the way, I want the camera on my slides during my entire presentation, thank you. ‘The Captain stood up, leaned over the desk and said, we will cover you to the limit Blue, as long as you keep your mouth shut about our agreement and as long as you don’t get caught operating outside the department policies or the law. If you get caught, we’ll deny ever having this conversation. Do you understand? Blue replied, wouldn’t have it any other way.’ Fiction or fact? Jebb gets a 10-year free lease to the million dollar city property known as the Torrey Pines Gliderport, with no oversight. Jebb’s been known to be doing lots of bullying. We have a quote here from a woman who ended up taking her life saying ‘When David Jebb or Gabe Jebb bullied me, I let it go because they bullied most everyone. Jebb bans individuals and entire clubs from their own city park. Jebb violates his own lease. In 2007, the City is sued for Jebb’s violations. In June 2007, the City of San Diego agrees to pay $20,000 to form a Torrey Pines City Park Advisory Board as part of the settlement. From June of 2007 through 2008, Sanders administrations delays formation of the Board, even though it’s supposed to be formed within 90 days. Under Sanders’ administration, eventually he creates the Board, an Advisory Board, under the wrong section of the City Charter. He created it under 43(b) which is citizen’s committee, it’s not Advisory Boards. Advisory Boards are 43(a). Sanders appoints Ginny Barnes to keep the Advisory Board from any oversight of the management at that Gliderport. San Diego spends almost half a million dollars on a plan with no implementation, wasted money. The only thing we needed was oversight. Jebb’s lease expires in 2008, but the City uses the Advisory Board as an excuse to allow Jebb to keep the lease for another five years without it going for public bid. Another inside deal. Jebb turns the lease over to his second in command in an undisclosed deal in 2009. This is the guy. This is the guy who now runs our Gliderport. There he is again violating the City’s own rules. ‘No Smoking’ - he smokes there everyday. We have accidents at the rate of about two a year. No oversight or review of what’s going on there. The Soaring Council private organization is totally unbalanced, totally corrupt. The City Park Advisory Board which is what we should have with equal balance of clubs has been dis-banned. Who is watching over this guy, Sherri? Who is watching over him? Who in this City is watching over what is going on in that Gliderport, Sherri?”


XXI. EIGHTEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(K) January 14, 2014: “My name is Bob Kuczewski and I’m here to talk about the Torrey Pines City Park Advisory Board. I officially request that the City TV show all of my slides. I have made this request by phone, by calling the City TV and the City TV has refused to show my slides. I will point out that modifying a speaker’s presentation by either changing the slide order, or, not showing the slides, is likely a violation of the Brown Act. The Brown Act gives people the right to come here and speak, whether it’s pleasant or unpleasant and to be seen by the people who come to these meeting and that includes the people who watch it on television, so I ask that my slides be shown. Now this is an offensive slide to you Sherri. This is the guy who runs the Torrey Pines Gliderport. And this is the most offensive slide that I have. It shows basically a hand, missing a few fingers. This is the guy that is running the Gliderport. He’s running it under your auspices essentially, Sherri because I have asked you to have him removed. I have asked you to put oversight on him. Actually, I haven’t asked to have him removed, I’ve asked for oversight. I have asked for an Advisory Board that will oversee what this guy does at this Gliderport. You have refused to provide that for years now. For years, Sherri. Now there is a connection in the City. I believe there’s corruption between David Jebb who owns the Gliderport, or manages the Gliderport, and Jerry Sanders who was his Chief of police. They were both policemen together. I believe there is corruption there. There is Jebb behind the scenes just this past weekend, at the Gliderport, confiding with the guy who owns the finger to the right there. Jebb wrote a book telling of his time in the City of San Diego as a police officer. Jebb has a free-ten year lease. He’s had a free ten- year lease of that Gliderport and that lease expired in 2008. It’s 2014 now and that lease has still not been put up for bid. He’s been going on that free lease for five more years without it going up for bid. Jebb has bullied pilots. You’ve seen this slide before too. Someone saying I have been the victim of much bullying by some of the in pilots. When David or Gabe Jebb bullied me, I let it go because I know they bullied most everyone. This woman ended up taking her life...[.]


XXII. NINETEENTH CAUSE OF ACTION
DEFAMATION
[Plaintiffs ROBIN MARIEN and ACA
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]



(L) November 11, 2014: “My name is Bob Kuczewski and I am here to talk about the Torrey Pines Gliderport. I officially request that City TV show all of my slides so the public of San Diego can see what’s been going on at that Gliderport. Yesterday I was at the Gliderport and I was arrested for doing this. For taking this photo of that gentleman standing there kiting his paraglider without a helmet. That’s a safety risk and he is demonstrating to students. He has students all around him that he’s showing how to paraglider. This is the Son of the owner and, and he has not helmet. That’s, that’s inexcusable for him to be demonstrating to students how to fly without a helmet. So I was documenting that. I have every right as a citizen to be in that park and to take those photos of - of what he was doing. He didn’t like it. He saw me taking the photos and so he drops his paraglider an approaches me. Step, by step, by step, by step, by step, by step, by step. And he starts telling me that I have to leave the Gliderport and I am not allowed to take pictures of him. Well how the heck are we going to get oversight of that Gliderport if people aren’t allowed to take pictures of what is going on at that Gliderport. Mr. Goldsmith, this City relies on citizens bringing evidence like this to you to show you what is going on in this City. And for them to bring the police, and they start surrounding me, putting their face in my camera, accusing me of - of attacking them, or following them. Look how close they are. And I’m just standing there. They approached me. They all approached me. These are the instructors at that Gliderport. At some point, that gentlemen there who owns the Gliderport, starts untying my hang glider. He unties it, and this guy, one of his thugs is basically blocking me from taking photos of him untying the hang glider. But I got a few pictures of him doing it anyway. And then he walks off, leaving my hang glider there, untied in the wind. That’s a tremendous safety hazard. That thing can blow away. Then they call the police on me. And I spent the night, last night, a good part of last night in the jail because I refused to leave our City park. For doing what? For having taken pictures to bring to this Council to show you what is going on in that park? That’s why I spent the night in jail? This is ridiculous. This is an outrage that our City parks are being given for free to that thug of a concessionaire to bully people and then to call our own police against our people. They gave me a choice of leaving the park or going to jail. I said, you know what? There’s a woman named Rosa Parks who stood up and brought the matter to Court and that’s what I’m doing. I ask this City to reinstate the Torrey Pines City Park Advisory Board so we can get some oversight in that Gliderport.”


XXIII. TWENTIETH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]



(M) On November 20, 2014: “Yesterday I went with a friend to the local police station to file a police report for assault and battery and false arrest. Brace yourself. The San Diego police refuse - REFUSED - to take the report. How can it be that citizens cannot even FILE a police report? Of course, let’s not forget that the report would implicate Gabriel Jebb - the son of former San Diego police officer David Jebb.”


XXIV. TWENTY-FIRST CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]



(N) On November 11, 2014: “My friend arrived just about the time that I tied the glider to the roof of my van. I’d been thinking long and hard about the choice in front of me. I thought about all the times that David Jebb and Gabe Jebb and Robin Marien had bullied people and threatened them with arrest. I thought about how they’ve always gotten away with it because everyone in the past (including myself) had always backed down. Then I thought about Rosa Parks. The choice was clear: I spent the good part of the evening and into the next morning in jail. It was an extremely unpleasant experience, but I accepted it as the price of justice.”


XXV. TWENTY-SECOND CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]



(O) On March 10, 2015: “One of the things that came up was the patterns of abuse from Gabe Jebb, and that reminded me of this incident from August 11, 2013. It’s interesting to see Gabe Jebb’s pattern of approaching people to intimidate them.”


XXVI. TWENTY-THIRD CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]



(P) On April 23, 2015: “...Regarding the term “bullying”, I knew a very nice female paragliding pilot who wrote to me saying: ‘When David or Gabe Jebb bullied me, I let it go because I knew that they bullied most everyone, but when it came from pilots whom I thought were my friends, it devastated me.’ She ended up taking her own life.”


This quote was taken from the Oz Forum here:
http://ozreport.com/forum/viewtopic.php?p=138998#p138998

That was posted when I was expelled from USHPA. Here's the full post:

by Bob Hawk »
Eric J wrote:As to the question of whether Bob asked Jack to commit voter fraud? I am pretty convinced at this point that that is complete hyperbole on Jacks part. Those who back up Jacks point of view, get to stay on Jacks site, and that includes some bullies.


Thanks for that analysis Eric. I always appreciate when people do their own thinking and come to their own conclusions. Thanks very much for your clear understanding of the "voter fraud" situation.

Regarding the term "bullying", I knew a very nice female paragliding pilot who wrote to me saying:

"When David or Gabe Jebb bullied me, I let it go because I knew that they bullied most everyone, but when it came from pilots whom I thought were my friends, it devastated me."

She ended up taking her own life.

That got me to thinking about what bullying really is, and I think it must always involve an element of superior power vested with the person doing the bullying. In the case of forums, the person who controls the "ban button" always has that power.

When I initiated the HGAA, I wanted to distribute that power to a group of us to keep it from being so centralized. Unfortunately, the actual control was still in the hands of one person (you guessed it ... Jack Axaopoulos "volunteered" to set up a site for us), and that effort only lasted a few months until it imploded.

I learned a lot from that, and we're trying to do a better job with the US Hawks (http://ushawks.org). So far, we've got a Board of Directors consisting of 5 good people from around the country, and we're slowly growing our membership. I still retain veto authority over the Board at this time, but we're working toward removing (or at least reducing) my power there as well.

What just happened at the USHPA Expulsion hearing reminds me that in addition to an elected Board, we're going to need a "Bill of Rights" to keep a corrupted Board from abusing the rights of our pilots. It's starting to sound like a rehash of the founding of our country ... and it probably is. The fundamentals behind governance and justice are probably similar across many situations.

It's been a long day, and I've just been expelled from USHPA, so I'm going to sign off for the night.

Davis, I am curious about the status of this topic and my own status on this forum. I would appreciate a little time to collect this topic as history before it's deleted or locked down again and before I'm re-banned. What are your thoughts on that topic.

Good night.


XXVII. TWENTY-FOURTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]



(Q) On May 4, 2015: “This is what you’re up against. Robin and Jebb were at the mafia table having lunch. Robin drives away with David Jebb, in a Red Corvette. The Godfather.”


XXVIII. TWENTY-FIFTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]

https://ushawks.org/forum/viewtopic.php?f=2&t=1385&p=6327#p6331
https://youtu.be/CMCuFRN5dzE


(R) March 5, 2013: “Over the years, I’ve been contacted by many people who have been bullied, abused, and in some cases even beaten by the Torrey Pines’ concessionaire or their staff. In most cases, they’ve asked me to remain quiet about it because they feared retribution. In other cases, they have gotten financial settlements with an agreement to remain silent, so I can’t tell their stories. But I can tell Lynne’s story. Lynne was a paraglider pilot who ended up taking her own life in 2011. These are her own words to me when I asked about featuring her site preservation efforts in our Torrey Hawks Club Newsletter. Lynne wrote: ‘Bob, thanks for thinking of me, but I need to decline at this time. I have been the victim of much bullying by some of the in pilots. I’m very selective as to who I fly with and will leave the site if other certain pilots are there. Two years ago, I rarely left my home and did not fly for a period of five months.’ This is someone who loves flying. ‘Did not fly for a period of five months due to fear of a vicious verbal assault by Josh Gelb during a club event. This was not an isolated event, just the final proverbial straw. The fact that the other pilots just stood by and let it happen led me to believe that the supported this behavior.’ She goes on to say ‘I am still not emotionally healed and need to stay incognito as much as possible. You may have noticed that I do not post to the San Diego Hang Gliding days I typically fly with a hang glider pilots and only a few select paraglider pilots. Blossom’... which is a local flying site... ‘is my passion and I am not going to let my fear in the way of losing the site because I didn’t do anything. I wish that I were as thick skinned as you.’ Talking about me. ‘And able to keep going in spite of the verbal abuse.’ She says ‘When David or Gabe Jebb bullied me.’ David Jebb was the concessionaire for ten years. He may still be the concessionaire, no one will say. ‘When David or Gabe Jebb bullied me, I let it go because I knew they bullied almost everyone.’ Isn’t that a sad statement? The bullying there is so common that she just accepts it because it happens to everyone. ‘But when it came from pilots whom I thought were my friends, it devastated me. Thanks again for thinking of me, but maybe at a later date.’ There was no later date. She eventually took her own life. She was a pilot in Alpine. She doesn’t have a council representative on this staff because she’s from Alpine. Next slide please. I’m asking this council to stop the bullying. That’s the guy who currently claims he is the concessionaire. Those are four different occasions. He’s giving people the finger. Please restart the Advisory Board.”


XXIX. TWENTY-SIXTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]



(S) July 23, 2013: “My name is Bob Kuczewski and I would like to direct the City camera to my slides. I am here to talk about Todd Gloria’s hypocrisy and the plundering of our city parks. Todd Gloria said, ‘We as a City will not tolerate intimidation and harassment’. Really, Mr. Gloria? How many times have I shown you this slide? This slide are the words of a women who ended up taking her life after saying that she had been the victim of much bullying by some of the in pilots at Torrey Pines. She said when David or Gabe Jebb bullied her, that those are the concessions, she let it go because she knew they bullied almost everyone, yet you’ve done nothing. What about the accidents? We have August 2010 paragliders collide, July 2011 paragliders hurt, August 2011 paraglider hurt, May 2012 a woman dies, December 2012 a paraglider rescued, March 2013 paraglider rescued. How long will it be until we get the next one? All of this courtesy of the San Diego City’s own Torrey Pines’ concessionaire. [Shows a picture of Robin Marien] There he is, breaking the rules. He’s got a cigarette in his hand. He can flick that cigarette and hit that sign from the City that says ‘No Smoking Allowed’, yet nobody in this City will oversee this concessionaire. Yet Todd Gloria and Sherri Lightner do nothing. Fast forward to this past Sunday, or Saturday, July 20th, you see that Gliderport? That’s where we are supposed to be landing our hang gliders. The concessionaire has basically leased out our Gliderport to a private business for their company party. No oversight involved. Here’s my landing approach. I don’t know if you can see the hang glider coming in. See me landing right there? That’s where I landed last month in June. See that, those towers and those trees? Focus on them. You see the same towers and trees there. This is what our park looked like on Saturday. The concessionaire had basically sold it to, to a company to come have their private picnic and they picketed off so we couldn’t land or use the park. Let’s look at the lease. Lease says it is expressly agreed that the premises are leased solely and exclusively for the purposes of a flight Gliderport concession, the use of non-power aircrafts, and the general public. Non-power aircraft? We can’t fly there with cars parked in our landing zone. This is our landing zone. The general public, they got a picket fence saying ‘provide commerce guests only’. We’re excluded from our own city park so he can make money. The lease says that, that they should only use it for the purposes not expressly authorized herein. The use of any, of the premises for any unauthorized purpose shall constitute substantial default and subject this lease to termination. Nobody will enforce it. Consideration, the flight director gets no, sends no money to the City. The City gets no money for this. Yet he can sell that property and lease it out and make as much as he wants. Assignment and subletting, flight directors lessee shall not assign this property and shall not sublet the premises. Yet, he leased it our for this party just last Saturday. Who in the City is overseeing this? Parks and Recreation? Real Estate Assets? Nobody. The guy is getting away with whatever he wants to get away with. There he is breaking the law smoking, breaking the law smoking, rents our City, rents our City property for his own private business and nobody will oversee it. There’s no Advisory Board to advise the City on what needs to be done at that Gliderport, thank you.” He’s giving people the finger. Please restart the Advisory Board.”


XXX. TWENTY-SEVENTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]



(T) September 17, 2013: “Before I get started, I want to direct City TV to my slides. I want my slides to be shown full screen throughout my entire presentation. So if you’re watching this on TV at home, and you see anything other than my slides during the entire time that I am presenting, than you know that someone in this City is trying to cover up what’s been happening at the Torrey Pines Gliderport. On July 30th, 2013, I showed 19 slides to this City Council. Only three of my slides appeared on City TV. Why is that? And I called in advance to City TV and asked them specifically to show my slides. And I believe I said so at the microphone as well. On September 10th, just last week, I showed 50 slides. Not one of my slides was on City TV. Who’s trying to cover this up? What are Sherri Lightner and Todd Gloria hiding from us? Sherri? Is it the accidents at Torrey Pines? One after another, after another, after another, after another, after another, after another, after another. Is it the bullying that’s been going on at Torrey Pines that hasn’t been addressed by any oversight by the City of San Diego? (David and Gabe Jebb’s names are highlighted on the slide). Could it be the violations of law? There’s the concessionaire. (Shows a picture of Robin Marien) The guy who has a free lease to our City park smoking and he can flick that cigarette and hit that ‘Non Smoking’ sign. There he is giving the public the finger. Which is very - properly considered inappropriate - but you need to see it because we see it. And the public needs to see it because we see it. Because that’s what we see at that Gliderport. There he is again. This is just a month ago, August 11th. He is smoking in front of the sign. In the upper left hand corner is the City of San Diego sign. He knows that I am taking his picture, I am videotaping him. He jokes about it, laughs, turns, and you will see him point at the sign just above his finger that says ‘No Smoking’. As if to say ‘screw you San Diego, I can do whatever I want at, at my Gliderport.’ What kind of corruption brings this to our City? What kind of corruption, Sherri Lightner, allows this to be in our City park? What kind of corruption allows a settlement agreement that specified an Advisory Board to be created under the wrong section of the City Charter? City Charter Section 43(b) that does not address Advisory Boards at all. Instead it was established as a, as a citizen’s committee when the agreement was for an Advisory Board. Finally, what ties David Jebb and Jerry Sanders together? I will leave that as a cliff hanger for next week, thank you.”


XXXI. TWENTY-EIGHTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]



(U) January 14, 2014:
“My name is Bob Kuczewski and I’m here to talk about the Torrey Pines City Park Advisory Board. I officially request that the City TV show all of my slides. I have made this request by phone, by calling the City TV and the City TV has refused to show my slides. I will point out that modifying a speaker’s presentation by either changing the slide order, or, not showing the slides, is likely a violation of the Brown Act. The Brown Act gives people the right to come here and speak, whether it’s pleasant or unpleasant and to be seen by the people who come to these meeting and that includes the people who watch it on television, so I ask that my slides be shown. Now this is an offensive slide to you Sherri. This is the guy who runs the Torrey Pines Gliderport. And this is the most offensive slide that I have. It shows basically a hand, missing a few fingers. This is the guy that is running the Gliderport. He’s running it under your auspices essentially, Sherri because I have asked you to have him removed. I have asked you to put oversight on him. Actually, I haven’t asked to have him removed, I’ve asked for oversight. I have asked for an Advisory Board that will oversee what this guy does at this Gliderport. You have refused to provide that for years now. For years, Sherri. Now there is a connection in the City. I believe there’s corruption between David Jebb who owns the Gliderport, or manages the Gliderport, and Jerry Sanders who was his Chief of police. They were both policemen together. I believe there is corruption there. There is Jebb behind the scenes just this past weekend, at the Gliderport, confiding with the guy who owns the finger to the right there. Jebb wrote a book telling of his time in the City of San Diego as a police officer. Jebb has a free-ten year lease. He’s had a free ten-year lease of that Gliderport and that lease expired in 2008. It’s 2014 now and that lease has still not been put up for bid. He’s been going on that free lease for five more years without it going up for bid. Jebb has bullied pilots. You’ve seen this slide before too. Someone saying I have been the victim of much bullying by some of the in pilots. When David or Gabe Jebb bullied me, I let it go because I know they bullied most everyone. This woman ended up taking her life....[.]”


XXXII. TWENTY-NINTH CAUSE OF ACTION
DEFAMATION
[Plaintiff GABRIEL JEBB as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE
HOLLAND, and DOES 2-20]



(V) November 11, 2014: “My name is Bob Kuczewski and I am here to talk about the Torrey Pines Gliderport. I officially request that City TV show all of my slides so the public of San Diego can see what’s been going on at that Gliderport. Yesterday I was at the Gliderport and I was arrested for doing this. For taking this photo of that gentleman standing there kiting his paraglider without a helmet. That’s a safety risk and he is demonstrating to students. He has students all around him that he’s showing how to paraglide. This is the Son of the owner and, and he has not helmet. That’s, that’s inexcusable for him to be demonstrating to students how to fly without a helmet. So I was documenting that. I have every right as a citizen to be in that park and to take those photos of - of what he was doing. He didn’t like it. He saw me taking the photos and so he drops his paraglider an approaches me. Step, by step, by step, by step, by step, by step, by step. And he starts telling me that I have to leave the Gliderport and I am not allowed to take pictures of him. Well how the heck are we going to get oversight of that Gliderport if people aren’t allowed to take pictures of what is going on at that Gliderport. Mr. Goldsmith, this City relies on citizens bringing evidence like this to you to show you what is going on in this City. And for them to bring the police, and they start surrounding me, putting their face in my camera, accusing me of - of attacking them, or following them. Look how close they are. And I’m just standing there. They approached me. They all approached me. These are the instructors at that Gliderport. At some point, that gentlemen there who owns the Gliderport, starts untying my hang glider. He unties it, and this guy, one of his thugs is basically blocking me from taking photos of him untying the hang glider. But I got a few pictures of him doing it anyway. And then he walks off, leaving my hang glider there, untied in the wind. That’s a tremendous safety hazard. That thing can blow away. Then they call the police on me. And I spent the night, last night, a good part of last night in the jail because I refused to leave our City park. For doing what? For having taken pictures to bring to this Council to show you what is going on in that park? That’s why I spent the night in jail? This is ridiculous. This is an outrage that our City parks are being given for free to that thug of a concessionaire to bully people and then to call our own police against our people. They gave me a choice of leaving the park or going to jail. I said, you know what? There’s a woman named Rosa Parks who stood up and brought the matter to Court and that’s what I’m doing. I ask this City to reinstate the Torrey Pines City Park Advisory Board so we can get some oversight in that Gliderport.”


XXXIII. THIRTIETH CAUSE OF ACTION
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
[Plaintiffs ROBIN MARIEN, AIR CALIFORNIA ADVENTURE, INC., and GABRIEL JEBB
as to Defendants ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

XXXIV. THIRTY-FIRST CAUSE OF ACTION
NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
[Plaintiffs ROBIN MARIEN, AIR CALIFORNIA ADVENTURE, INC., and GABRIEL JEBB
as to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

XXXV. THIRTY-SECOND CAUSE OF ACTION
DECLARATORY RELIEF
[Plaintiffs ROBIN MARIEN, AIR CALIFORNIA ADVENTURE, INC., and GABRIEL JEBB
as to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20]

XXXVI. THIRTY-THIRD CAUSE OF ACTION
INJUNCTIVE RELIEF
[Plaintiffs ROBIN MARIEN, AIR CALIFORNIA ADVENTURE, INC., and GABRIEL JEBB as
to Defendant ROBERT KUCZEWSKI, MARJORIE MAE HOLLAND, and DOES 2-20][/quote]
Join a National Hang Gliding Organization: US Hawks at ushawks.org
View my rating at: US Hang Gliding Rating System
Every human at every point in history has an opportunity to choose courage over cowardice. Look around and you will find that opportunity in your own time.
Bob Kuczewski
User avatar
Contributor
Contributor
 
Posts: 7534
Joined: Fri Aug 13, 2010 2:40 pm
Location: San Diego, CA

PreviousNext
Forum Statistics

Who is online

Users browsing this forum: No registered users and 15 guests

Options

Return to Hang Gliding General

cron